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STEPHEN M. WAGSTAFFE, DISTRICT ATTORNEY County of San Mateo, State of California State Bar No. 78470 1050 Mission Road South San Francisco, CA 94080 By: Rebecca A. Dreyfuss, Deputy District Attorney Telephone: (650) 877-5454 Attorney for Plaintiff

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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

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IN AND FOR THE COUNTY OF SAN MATEO

10 THE PEOPLE OF THE STATE OF CALIFORNIA 11

REPORT NO. PH16221694 DA CASE NO. 0732206

Plaintiff, 12 vs.

FELONY COMPLAINT

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PAUL JOSEPH SOUTER 274 MITCHELL LOOP BOSQUE FARMS, NM 87068

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Defendant.

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I, the undersigned, say, on information and belief, that in the County of San Mateo, State of California: COUNT 1: PC597(a) (Felony)

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On or about April 19, 2016, in the County of San Mateo, State of California, the crime of Cruelty To

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An Animal in violation of PC597(a), a Felony, was committed in that PAUL JOSEPH SOUTER did

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unlawfully, maliciously and intentionally maim, mutilate, torture, or wound a living animal, to wit:

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male maltipoo dog ''Sprocket''.

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COUNT 2: PC597(b) (Felony)

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On or between April 19, 2016 and May 1, 2016, in the County of San Mateo, State of California, the

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crime of Cruelty To An Animal in violation of PC597(b), a Felony, was committed in that PAUL

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JOSEPH SOUTER did unlawfully having the charge or custody of an animal, to wit Maltipoo dog

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''Sprocket'', either as owner or otherwise, subjected the animal to needless suffering, or inflicted

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unnecessary cruelty upon the animal, or in any manner abused the animal, or failed to provide the

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animal with proper food, drink, or shelter or protection from the weather.

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Pursuant to Penal Code Section 1054.5(b), the People are hereby informally requesting that defendant(s) and his or her attorney provide to the People the discovery required by Penal Code

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Section 1054.3. This is a continuing request pursuant to the provisions of Penal Code Section 1054.7.

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I declare under penalty of perjury that the foregoing is true and correct except for those things

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stated on information and belief and those I believe to be true. Executed on August 3, 2016, at San Mateo County, California.

14 15 _______________________________ COMPLAINANT

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RAD/rad

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