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Page 2 Complaint DA CASE NO: 2013-00-0032001 

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 3

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 4

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 5

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Page 3 Complaint DA CASE NO: 2013-00-0032001 

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 6

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 7

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

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Page 4 Complaint DA CASE NO: 2013-00-0032001 

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 8

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 9

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe,DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 10

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Page 5 Complaint DA CASE NO: 2013-00-0032001 

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 11

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 12

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

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Page 6 Complaint DA CASE NO: 2013-00-0032001 

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 13

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 14

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 15

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Page 7 Complaint DA CASE NO: 2013-00-0032001 

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 16

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 17

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

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Page 9 Complaint DA CASE NO: 2013-00-0032001 

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 21

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 22

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

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Page 10 Complaint DA CASE NO: 2013-00-0032001 

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 23

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 24

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, a DOB 08/10/1995 minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 25

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Page 11 Complaint DA CASE NO: 2013-00-0032001 

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 26

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 27

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

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Page 12 Complaint DA CASE NO: 2013-00-0032001 

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 28

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 29

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 30

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Page 13 Complaint DA CASE NO: 2013-00-0032001 

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the

crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c),

a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual

intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor 

being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

*****

COUNT 31

On or about January 1, 2007 through January 31, 2007, in the above named judicial district,

the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE

SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did unlawfully

participate in an act of oral copulation with John Doe, DOB 01/26/1992, a person under the age of 

eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood

test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency

Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code

section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples

pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a

crime."

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Page 14 Complaint DA CASE NO: 2013-00-0032001 

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse

Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5

limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the

report."

*****

COUNT 32

On or about September 1, 2007 through January 31, 2008, in the above named judicial

district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL

CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did

unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under 

the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood

test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency

Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code

section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples

pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a

crime."

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Page 15 Complaint DA CASE NO: 2013-00-0032001 

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse

Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5

limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the

report."

*****

COUNT 33

On or about September 1, 2007 through January 31, 2008, in the above named judicial

district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL

CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did

unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under 

the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood

test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency

Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code

section 290. Willful failure to register is a crime."

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Page 16 Complaint DA CASE NO: 2013-00-0032001 

"NOTICE: Conviction of this offense will require you to provide specimens and samples

pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a

crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse

Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5

limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the

report."

*****

COUNT 34

On or about September 1, 2007 through January 31, 2008, in the above named judicial

district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL

CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did

unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under 

the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood

test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency

Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code

section 290. Willful failure to register is a crime."

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Page 17 Complaint DA CASE NO: 2013-00-0032001 

"NOTICE: Conviction of this offense will require you to provide specimens and samples

pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a

crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse

Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5

limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the

report."

*****

COUNT 35

On or about September 1, 2007 through January 31, 2008, in the above named judicial

district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL

CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did

unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under 

the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood

test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency

Syndrome (AIDS). Penal Code section 1202.1."

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Page 18 Complaint DA CASE NO: 2013-00-0032001 

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code

section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples

pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a

crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse

Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5

limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the

report."

*****

COUNT 36

On or about September 1, 2007 through January 31, 2008, in the above named judicial

district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL

CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did

unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under 

the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood

test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency

Syndrome (AIDS). Penal Code section 1202.1."

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Page 19 Complaint DA CASE NO: 2013-00-0032001 

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code

section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples

pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a

crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse

Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5

limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the

report."

*****

COUNT 37

On or about September 1, 2007 through January 31, 2008, in the above named judicial

district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL

CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did

unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under 

the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood

test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency

Syndrome (AIDS). Penal Code section 1202.1."

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Page 20 Complaint DA CASE NO: 2013-00-0032001 

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code

section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples

pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a

crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse

Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5

limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the

report."

*****

COUNT 38

On or about September 1, 2007 through January 31, 2008, in the above named judicial

district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL

CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did

unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under 

the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood

test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency

Syndrome (AIDS). Penal Code section 1202.1."

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Page 21 Complaint DA CASE NO: 2013-00-0032001 

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code

section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples

pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a

crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse

Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5

limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the

report."

*****

COUNT 39

On or about September 1, 2007 through January 31, 2008, in the above named judicial

district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL

CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did

unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under 

the age of eighteen years.

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Page 22 Complaint DA CASE NO: 2013-00-0032001 

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood

test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency

Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code

section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples

pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a

crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse

Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5

limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the

report."

*****

COUNT 40

On or about September 1, 2007 through January 31, 2008, in the above named judicial

district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL

CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did

unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under 

the age of eighteen years.

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Page 23 Complaint DA CASE NO: 2013-00-0032001 

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood

test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency

Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code

section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples

pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a

crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse

Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5

limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the

report."

*****

COUNT 41

On or about September 1, 2007 through January 31, 2008, in the above named judicial

district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL

CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did

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Page 24 Complaint DA CASE NO: 2013-00-0032001 

unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under 

the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood

test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency

Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code

section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples

pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a

crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction

HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or 

prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and

Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse

Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5

limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the

report."

*****

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Page 25

* * * * *

NOTICE TO DEFENDANT AND DEFENDANT’S ATTORNEY Pursuant to Penal Code Sections 1054.5.(b), the People are hereby informally requesting that

defense counsel provide discovery to the People as required by Penal Code Section 1054.3.

NOTICE TO ATTORNEYThe materials accompanying this notice may include information about witnesses. If so, these

materials are disclosed to you pursuant to Penal Code section 1054.2 which provides: "No

attorney may disclose or permit to be disclosed to a defendant the address or telephone number of 

a victim or witness whose name is disclosed to the attorney pursuant to subdivision (a) of Section

1054.1 unless specifically permitted to do so by the court after a hearing and a showing of good

cause."

I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND

CORRECT AND THAT THIS COMPLAINT CONSISTS OF 41 COUNT(S).

Executed at San Bernardino, California, on July 8, 2013.

Natasha Crawford

Natasha Crawford

DECLARANT AND COMPLAINANT

 Agency: Redlands Police Department Prelim Est. 00:00 

DefendantLaura Elizabeth Whitehurst

Birth Date11/03/1984

Booking No. CII No. A27810842

NCIC