Hr?Ir?tt?Ir?II?II?tr?Ir?t 36 MICHAEL A. HEETHIH County of Riverside State of?nlifornla wm?d??tl?h-Ih-UJMH ND MICHAEL A. HESTRIN BAIL: $1,000,000.00 District Attorney $1,000,000.00 County of Riverside $1,000,000.00 3960 Orange Street, First Floor $1,000.000.00 Riverside, California 92501 Telephone: (951) 955-5400 Ii Chief Assistant District Attorney State Bar No. 189395 APR 14 2015 MM armada SUPERIOR COURT OF CALIFORNIA COUNTY OF RIVERSIDE (Riverside) THE PEOPLE OF THE STATE OF NORIF CALIFORNIA, IN I Plaintiff, V. ERICK MONSIVAIS JOHN DAVID YODER WILLIAM CLYDE THOMPSON NOLAND ANTHONY HARPER DAI2015027009 __Defendants. COUNT The Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses ERICK MONSIVAIS of a violation of Penal Code section 288.7 subdivision a felony, in that on or about January 2014, through and including March 2014, in the County of I Riverside, State of California, he did wil?illy and unlawfully participate in an act of oral copulation or sexual penetration, as de?ned in Penal Code section 289, with JOHN a person who is 10 years of age or younger. I [Ell 9102 0% HM 36 MICHAEL A. HEETRJN DISTRICT County ef?ivtnide Start: off: all [ornia COUNT 2 For a further and separate cause of action, being a different offense from but connected in its commission with the charge set forth in count 1 hereof, the Criminal Grand Jury of the County-of Riverside by this Indictment hereby accuses ERICK MONSIVAIS of a violation of Penal Code section 288.7 subdivision a felony, in that on or about January 2014, through and including March 2014, in the County of Riverside, State of California, he did wilfully and unlawfully participate in an act of oral copulation or sexual penetration, as de?ned in Penal Code section 289, with JOHN a person who is 10 years of age or younger. COUNT 3 For a timber and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 and 2 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses ERICK MONS IVAJS of a violation of Penal Code section 288.7 subdivision a felony, in that on or about February 2014, in the County of Riverside, State of California, he did wil?Jlly and unlawfully participate in an act of oral copulation or sexual penetration, as de?ned in Penal Code section 289, with JOHN a person who is 10 years of age or younger. COUNT 4 For a ?lrther and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 3 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses ERICK MONSIVAIS of a violation of Penal Code section 288a, subdivision subsection (1), a felony, in that on or about April 2014, through and including August 2014, in the County of Riverside, State of California, he did wilfully and unlawfully participate in an act of oral copulation with JOHN a person under the age of fourteen years and more than ten years younger than defendant Erick A Monsivais. COUNT For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 4 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses ERICK MONSIV AIS of a violation of Penal Code section 288, subdivision a felony, in that on or about June 2014, through and including August 2014, in the County of Riverside, State of California, he did wil?illy, unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. mMI?t? 36 DISTRICT ATTORNEY County of Riverside Stat: cl? Callforaia Li?) MICHAEL A. HESTRIH COUNT 6 For a ?lrther and separate cause of action, being a different offense from but connected in its with the charges set forth in counts 1 through 5 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses ERICK MONSIVAIS of a violation of Penal Code section 288, subdivision a felony, in that on or about June 2014, through and including August 2014, in the County of Riverside, State of California, he did wilfully, unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. COUNT 7 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 6 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses ERICK MONSIVAIS of a violation of Penal Code section 311.11, subdivision a felony, in that on or about February 2015, in the County of Riverside, State of California, he did knowingly control and possess any matter, representation of information, data and image in which the production involves the use of a person under the age of 18 years, knowing that the material or matter depicts a person under the age of 13 years personally engaging in or simulating sexual conduct, as de?ned in subdivision of Penal Code section 311.4. COUNT 8 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 7 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses ERICK MONSIVAIS of a violation of Penal Code section 311.11, subdivision a felony, in that on or about February 2015, in the County of Riverside, State of California, he did knowingly control and possess any matter, representation of information, data and image in which the production involves the use of a person under the age of 18 years, knowing that the material or matter depicts a person under the age of 18 years personally engaging in or simulating sexual conduct, as de?ned in subdivision of Penal Code section 311.4. COUNT 9 For a ?thher and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 3 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses ERICK MONSIVAIS of a violation of Penal Code section 311.11, subdivision a felony, in that on or about 36' MICHAEL A. HEETRIH DISTRICT ATIDRNEY County of Riverside Stat: of California February 2015, in the County of Riverside, State of California, he did knowingly control and possess any matter, representation of information, data and image in which the production involves the use of a person under the age of 18 years, knowing that the material or matter depicts a person under the age of 18 years personally engaging inor simulating sexual conduct, as de?ned in subdivision of Penal Code section 311.4. COUNT 10 For a ?lrther and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 9 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses JOHN DAVID YODER of a violation of Penal Code section 288, subdivision a felony, in that on or about November 2014, through and including December 2014, in the County of Riverside, State of California, he did wilfully, unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. COUNT 11 For a further and separate cause of action, being a different offense ?om but connected in its commission with the charges set forth in counts 1 through 10 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses JOHN DAVID YODER of a violation of Penal Code section 288, subdivision a felony, in that on or about November 2014, through and including December 2014, in the County of Riverside, State of California, he did wil?Jlly, unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts. and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. COUNT 12 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 11 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses JOHN DAVID YODER of a violation of Penal Code section 288, subdivision a felony, in that on or about November 2013, through and including January 2015, in the County of Riverside, State of California, he did wilfully, unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. 36 MICHAEL A. HEETRIN County of Riverside Stat: ofEalifar n1: COUNT 13 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 12 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses JOHN DAVID YODER of a violation of Penal Code section 28 3, subdivision a felony, in that on or January 2014, through and including December 2014, in the County of Riverside, State of California, he did unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. COUNT 14 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 13 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses JOHN DAVID YODER of a violation of Penal Code section 266j, a felony, in that on or about June 2013 through and including December 2014, in the County of Riverside, State of California, he did willfully and unlawfully and intentionally give, transport, provide, and make available, and offered to give, tran5port, provide and make available to another person JOHN a child under the age of 16 years for the purpose of any lewd or lascivious act as defined in Penal Code section 28 8, and who caused, induced, and persuaded a child under the age of 16 years to engage in such an act with another person. COUNT 15 For a further and separate cause of action, being a different offense ?om but connected in its commission with the charges set forth in counts 1 through 14 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses JOHN DAVID YODER of violation of Penal Code section 266j, a felony, in that on or about June2013, through and including December 2014, in the County of Riverside, State of California, he did will?illy and unlawfully and intentionally give, transPort, provide, and make available, and offered to give, transport, provide and make available to another person JOHN S), a child under the age of 16 years for the purpose of any lewd or lascivious act as de?ned in Penal Code section 288, and who caused, induced, and persuaded a child under the age of 16 years to engage in such an act with another person. I 36 MICHAEL A. HESTRIN County of Riverside Stat: nfCalil?cha COUNT 16 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 15 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses JOHN DAVID YODER of violation of Penal Code section 266j, a felony, in that on or about June 2013, through and including December 2014, in the County of Riverside, State of California, he did willfully and unlawfully and intentionally give, transPort, provide, and make available, and offered to give, tranSport, provide and make available to another person JOHN C), a child under the age of 16 years for the purpose of any lewd or lascivious act as de?ned in Penal Code section 288, and who caused, induced, and persuaded a child under the age of 6 years to engage in such an act with another person. Forafu COUNT l7 'her and separate cause of action, being a different offense ?'om but connected in its commission with the charges set forth in counts 1 through 16 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses JOHN DAVID YODER of a violation of Penal Code section 236.1, subdivision a felony, in that on or about June 2013, through and including December 2014, in the County of Riverside, State of California, he did and cause, induce, and persuade, and attempt to cause, induce and persuade JOHN a minor at the time of the commission of the offense, to engage in a commercial sex act, with the intent to effect and maintain a violation of Penal Code sections 266, 26611, 266i, 266j, 267, 311.1, 3112, 311.3, 311.4, 311.5, 311.6 and 518. COUNT 18 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses JOHN DAVID YODER of a violation of Penal Code section 236.1, subdivision a felony, in that on or about June 2013, through and including December 2014, in the County of Riverside, State of California, he did will?Jlly and unlawfully cause, induce, and persuade, and attempt to cause, induce and persuade JOHN a minor at the time of the commission of the offense, to engage in a commercial sex act, with the intent to effect and maintain a violation of Penal Code sections 266, 266b, 266i, 266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6 and518. 36 MICHAEL A. HEETHJH County of Riverside Stat: of California COUNT 19 For a further and separate cause of action, being a different offense from but connected in its conunission with the charges set forth in counts 1 through 18 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses JOHN DAVID YODER of a violation of Penal Code section 236.1, subdivision a felony, in that on or about June 2013, through and including December 2014, in the County of Riverside, State of California, he did willfully and unlawfully cause, induce, and persuade, and attempt to cause, induce and persuade JOHN C), a minor at the time of the commission of the offense, to engage in a commercial sex act, with the intent to effect and maintain a violation of Penal Code sections 266, 266h, 266i, 266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6 and 518. COUNT 20 For a further and separate cause of action, being a different offense ?om but connected in its commission with the charges set forth in counts 1 through 19 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses JOHN DAVID YODER of a violation of Penal Code section 32, a felony, in that on or about June 2013, through and including December 2014, in the County of Riverside, State of California, he did wilfully and unlawfully, having knowledge that the crime of child pornography, a felony, in the State of Nevada, had been committed by WILLIAM THOMPSON, did harbor, conceal and aid said WILLIAM THOMPSON, with the intent that he might avoid and escape ?om arrest, trial, conviction, and punishment for said felony. COUNT 21 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 20 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 236.1, subdivision a felony, in that on or about June 2013, through and including December 2014, in the County of Riverside, State of California, he did will?illy and unlawfully cause, induce, and persuade, and attempt to cause, induce and persuade JOHN a minor at the time of the commission of the offense, to engage in a commercial sex act, with the intent to effect and maintain a violation of Penal Code sections 266, 266h, 266i, 266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6 and 518. HH?lr?lI?iI?lI?iI?il?II?i NM OHM 36 MICHAEL A. HESTHIN County of Riverside State at California .-L COUNT 22 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 21 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 236.1, subdivision a felony, in that on or about January 2014, through and including December 2014, in the County of Riverside, State of California, he did willfully and unlawfully cause, induce, and persuade, and attempt to cause, induce and persuade JOHN a minor at the time of the commission of the offense, to engage in a commercial sex act, with the intent- to effect and maintain a violation of Penal Code sections 266, 266b, 266i, 266j, 267, 3 1 .1, 311.2, 311.3, 311.4, 311.5, 311.6 and 518. COUNT 23 For a further and separate cause of action, being a different offense from but connected in its with the charges set forth in counts 1 through 22 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses CLYDE THOMPSON of a violation of Penal Code section 236.1, subdivision a felony, in that on or about January 2014, through and including December 2014, in the County of Riverside, State of California, he did willfully and unlaw?Jlly cause, induce, and persuade, and attempt to cause, induce and persuade JOHN C), a minor at the time of the commission of the offense, to engage in a commercial sex act, with the intent to effect and maintain a violation of Penal Code sections 266, 266h, 266i, 266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6 and 518. COUNT 24 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 23 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 236.1, subdivision a felony, inithat on or about January 2014, through and including December 2014, in the County of Riverside, State of California, he did willfully and unlawfully cause, induce, and persuade, and attempt to cause, induce and persuade JOHN P), a minor at the time of the commission of the offense, to engage in a commercial sex act, with the intent to effect and maintain a violation of Penal Code sections 266, 266b, 266i, 266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6 and 518. I MICHAEL A. HESTRIN County nl? Riverside Stste of California 26 I: COUNT 25 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 24 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 23 6.1, subdivision a felony, in that on or about January 2014, through and including December 2014, in the County of Riverside, State of California, he did willfully and unlawfully cause, induce, and persuade, and attempt to cause, induce and persuade JOHN a minor at the time of the commission of the offense, to engage in a commercial sex act, with the intent to effect and maintain a violation of Penal Code sections 266, 266h, 266i, 266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6 and 518. COUNT 26 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 25 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 236.1, subdivision a felony, in that on or about January 2014, through and including December 2014, in the County of Riverside, State of California, he did willfully and unlawfully cause, induce, and persuade, and attempt to cause, induce and persuade JOHN a minor at the time of the commission of the offense, to engage in a conunercial sex act, with the intent to effect and maintain a violation of Penal Code sections 266, 266h, 266i, 266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6 and 518. COUNT 27 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 26 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288.7, subdivision a felony, in that on or about August 2014, in the County of Riverside, State of California, he did wil?illy and unlawfully engage in sexual intercourse or sodomy with JOHN C), a person who is 10 years of age or younger. COUNT 28 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 27 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288, subdivision a felony, in that on or about January 2014, through and including March 2014, in the County of 36 MICHAEL A, HEETRIN DISTRICT ATTORNEY County of Riverside State of Callie rnla Riverside, State of California, he did wilfully, unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of JOHN DOECN C), a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the-said defendant and the said child. COUNT29 a For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 28 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288, subdivision a felony, in that on or about January 2014, through and including March 2014, in the County of Riverside, State of California, he did wilfully, unlawfully, and lewdly commit a lewd and lascivious act upon andwith the body and certain parts and members thereof of JOHN C), a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. COUNT 30 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 29 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288.7 subdivision a felony, in that on or about January 2014, through and including March 2014, in the County of Riverside, State of California, he did wilfully and'unlawfully participate in an act of oral copulation or sexual penetration, as de?ned in Penal Code section 289, with JOHN a person who is 10 years of age or younger. COUNT 31 For a further and separate cause of action, being adifferent offense from but connected in its commission with the charges set forth in counts 1 through 30 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288.7 subdivision a felony, in that on or about January 2014, through and including March 2014, in the County of Riverside, State of California, he did wilfully and unlawfully participate in an act of oral copulation or sexual penetration, as de?ned in Penal Code section 289, with JOHN C), a person who is 10 years of age or younger. Hf 10 I?ir?lh?lr?iHl??I?iI?ll?i 36 MICHAEL A. HESTRIN DISTRICT ATIURNET County of Riverside State of California ?43 COUNT 32 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 31 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288, subdivision a felony, in that on or about January 2014, through and including December 2014, in the County of Riverside, State of California, he did wilfully, unlawfully, and lewdly commit a lewd and Iascivious act upon and with the body and certain parts and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. COUNT 33 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 32 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288, subdivision a felony, in that on or about January 2014, through and including December 2014, in the County of Riverside, State of California, he did wilfully, uniaw?illy, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. COUNT 34 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 33 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOIVIPSON of a violation of Penal Code section 288.7 subdivision a felony, in that on or about April 2014, in the County of Riverside, State of California, he did wil?illy and unlawfully participate in an act of oral copulation or sexual penetration, as defined in Penal Code section 289, with JOHN a person who is 10 years of age or younger. COUNT 35 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 34 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288a, subdivision subsection (1), a felony, in that on or about May 2014, in the County of Riverside, State of California, he did 11 36 MICHAEL A. HEETHJH DISTRIETATTERHEY County nl?RiursIdt Stale nf California wilfully and unlawfully participate in an act of oral copulation with JOHN a person under the age of fourteen years and more than ten years younger than defendant William Clyde Thompson. COUNT 36 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 35 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288a, subdivision subsection (1), a felony, in that on or about June 2014, in the County of Riverside, State of California, he did wilfully and unlawfully participate in an act of oral copulation with JOHN a person under the age of fourteen years and more than ten years younger than defendant William Clyde Thompson. COUNT 37 For a ?lrther and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 36 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section. 283a, subdivision subsection (1), a felony, in that on or about April 2014, in the County of Riverside, State of California, he did and unlawfully participate in an act of oral copulation with JOHN P), a person under the age of fourteen yearsand more than ten years younger than defendant William Clyde Thompson. COUNT 33 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 37 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 238a, subdivision subsection (1), a felony, in that on or about May 2014, in the County of Riverside, State of California, he did wilfully and unlawfully participate in an act of oral copulation with JOHN P), a person under the age of fourteen years and more than ten years younger than defendant William Clyde Thompson. COUNT 39 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 33 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288a, subdivision subsection 12 r?Ir?ir?n lbs-THC} .ILUJ j?I. RD n?t 36 MICHAEL A. HEETRIH DISTRICTATIGRNEY Eu unty of Riverside Stats at Califurnin p?t Ln cc IO mm tun?h- (1), a felony, in that on or about May 2014, in the County of Riverside, State of California, he did wilfully and unlawfully participate in an act of oral copulation with JOHN P), a person under the age of fourteen years and more than ten years younger than defendant William Clyde Thompson. COUNT 40 For a further and separate cause of action, being a different offense ?om but connected in its commission with the charges set forth in counts 1 through 39 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288.7, subdivision a felony, in that on or about May, 2014, in the County of Riverside, State of California, he did wilfully and unlaw?illy engage in sexual intercourse or sodomy with JOHN C), a person who is 10 years of age or younger. COUNT 41 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 40 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 238, subdivision a felony, in that on or about August 2013, through and including June 2014, in the County of Riverside, State of California, he did wilfully, unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. COUNT 42 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 41 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288, subdivision a felony, in that on or about February 2014, in the County of Riverside, State of California, he did wilfully, unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. 13 36 MICHAEL A. HEETRIN DISTRICT ATTORNEY County of Riverside Stat: af?alilarnia COUNT 43 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 42 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 288a, subdivision (0), subsection (1), a felony, in that on or about February 2014, in the County of Riverside, State of California, he did wilfully and unlawfully participate in an act of oral copulation with JOHN S), a person under the age of fourteen years and more than ten years younger than defendant William Clyde Thompson. The Criminal Grand Jury of the County of Riverside by this indictment further alleges that WILLIAM CLYDE THOMPSON has been convicted in the present case and cases of committing a qualifying sex offense as speci?ed in Penal Code section 667.61, subdivision against more than .one victim, within the meaning of Penal Code section 667.61, subdivision subsection (4). COUNT 44 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 43 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 311.11, subdivision a felony, in that on or about January 2015, in the County of Riverside, State of California, he did knowingly control and possess any matter, representation of information, data and image in which the production involves the use of a person under the age of 18 years, knowing that the material or matter depicts a person under the age of 18 years personally engaging in or simulating sexual conduct, as de?ned in subdivision of Penal Code section 311.4. COUNT 45 For a ?lrther and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 44 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 311.11, subdivision a felony, in that on or about January 2015, in the County of Riverside, State of California, he did knowingly control and possess any matter, representation of information, data and image in which the production involves the use of a person under the age of 18 years, knowing that the material or matter depicts a person under the age of 18 years personally engaging in or simulating sexual conduct, as de?ned in subdivision of Penal Code section 311.4. 14 369 MICHAEL A. DISTRICT County of Riverside State of California. COUNT 46 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 45 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses WILLIAM CLYDE THOMPSON of a violation of Penal Code section 311.11, subdivision a felony, in that on or about January 2015, in the County of Riverside, State of California, he did knowingly control and possess any matter, representation of information, data and image in which the production involves the use of a person under the age of 18 years, knowing that the material or matter depicts a person under the age of 18 years personally engaging in or simulating sexual conduct, as de?ned in subdivision of Penal Code section 311.4. COUNT 47 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 46 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAND ANTHONY HARPER of a violation of Penal Code section 236.1, subdivision a felony, in that on or about January 2014, through and including December 2014, in the County of Riverside, State of California, he did willfully and unlawfully cause, induce, and persuade, and attempt to cause, induce and persuade JOHN a minor at the time of the commission of the offense, to engage in a commercial sex act, with the intent to effect and maintain a violation of Penal Code sections 266, 266h, 266i, 266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6 and 518. COUNT 48 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 47 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAND ANTHONY HARPER of a violation of Penal Code section 236.1, subdivision a felony, in that on or about January 2014, through and including December 2014, in the County of Riverside, State of California, he did willfully and unlawfully cause, induce, and persuade, and attempt to cause, induce and persuade JOHN C), a minor at the time of the commission of the offense, to engage in a commercial sex act, with the intent to effect and maintain a violation of Penal Code sections 266, 266h, 266i, 266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6 and 518. 15 36 MICHAEL A. HESTRIN County ul'?ivenide State ut'Califernia COUNT 49 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 43 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAND ANTHONY HARPER of a violation of Penal Code section 236.1, subdivision a felony, in that on or about January 2014, through and including December 2014, in the County of Riverside, State of California, he did willfully and unlawfully cause, induce, and persuade, and attempt to cause, induce and persuade JOHN a minor at the time of the corrunission of the offense, to engage in a commercial sex act, with the intent to effect and maintain a violation of Penal Code sections 266, 266h, 266i, 266j, 267, 311.1, 311.2, 311.3, 311.4, 311.5, 311.6 and 518. COUNT 50 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 49 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAND ANTHONY HARPER of violation of Penal Code section 266j, a felony, in that on or about December 2014, in the County of Riverside, State of California, he did willfully and unlawfully and intentionally give, transport, provide, and make available, .and offered to give, transport, provide and make available to another person JOHN a child under the age of 16 years for the purpose of any lewd or lascivious act as de?ned in Penal Code section 288, and who caused, induced, and persuaded a child under the age of 16 years to engage in such an act with another person. COUNT 51 For a ?thher and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 50 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAND ANTHONY HARPER of violation of Penal Code section 266j, a felony, in that on or about December 2014, in the County of Riverside, State of California, he did willfully and unlawfully and intentionally give, transport, provide, and make available, and offered to give, tranSport, provide and make available to another person JOHN a child under the age of 16 years for the purpose of any lewd or lascivious act as de?ned in Penal Code section 288, and who caused, induced, and persuaded a child under the age of 16 years to engage in such an act with another person. 16 I. Hr?Ir?hr?Ir?hr?Ir?t DO 36 MICHAEL A. County or Riversld? State of California ?all I-n RD Lu CD COUNT 52 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 51 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAND ANTHONY HARPER of violation of Penal Code section 266j, a felony, in that on or about December 2014, in the County of Riverside, State of California, he did and unlawfully and intentionally give, transport, provide, and make available, and offered to give, transport, provide and make available to another person JOHN S), a child under the age of 16 years for the purpose of any lewd or lascivious act as de?ned in Penal Code section 288, and who caused, induced, and persuaded a child under the age of 16 years to engage in such an act with another person. COUNT 53 For a further and separate cause of action, being a different offense from but connected . in its commission with the charges set forth in counts 1 through 52 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAND ANTHONY HARPER of violation of Penal Code section 266j, a felony, in that on or about December 2014, in the County of Riverside, State of California, he did willfully and unlawfully and intentionally give, transport, provide, and make available, and offered to give, transport, provide and make available to another person JOHN S), a child under the age of 16 years for the purpose of any lewd or lascivious act as de?ned in Penal Code section 288, and who caused, induced, and persuaded a child under the age of 16 years to engage in such an act with another person. I COUNT 54 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 53 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAND ANTHONY HARPER of violation of Penal Code section 266j, a felony, in that on or about December 2014, in the County of Riverside, State of California, he did willfully and and intentionally give, transport, provide, and make available, and offered to give, tranSport, provide and make available to another person JOHN a child under the age of 16 years for the purpose of any lewd or lascivious act as de?ned in Penal Code section 28 8, and who caused, induced, and persuaded a child under the age of 16 years to engage in such an act with another person. I 17 l?Ll?l summth U143- 36 MICHAEL A. HEETRIH utsTarcr County of Riverside Stall.- nl'EaHl'crnis COUNT 55 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 54 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAND ANTHONY HARPER of a violation of Penal Code section 288a, subdivision subsection (1), a felony, in that on or about January 2014, through and including August 2014, in the County of Riverside, State of California, he did wilfully and unlawfully participate in an act of oral copulation with JOHN a person under the age of fourteen years and more than ten years younger than defendant Noland Anthony Harper. COUNT 56 For a further and separate cause of action, being a different offense ?om but connected in its commission with the charges set forth in counts 1 through 55 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAND ANTHONY HARPER of a violation of Penal Code section 288, subdivision a felony, in that on or about January 2014, through and including August 2014, in the County of Riverside, State of California, he did wilfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. COUNT 57 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 56 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAND ANTHONY HARPER of a violation of Penal Code section 288, subdivision a felony, in that on or about December 2014, in the County of Riverside, State of California, he did wilfully, unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of JOHN a child under the age of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child. I 1/ I 18 36 MICHAEL A. HEETRIN DISTRICT Ct'tantg.f of Riverside State of California Ewe-1thme COUNT 58 For a further and separate cause of action, being a different offense ?om but connected in its commission with the charges set forth in counts 1 through 57 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses NOLAN ANTHONY HARPER of a violation of Penal Code section 311.11, subdivision a felony, in that on or about February 201 S, in the County of Riverside, State of California, he did knowingly control and possess any matter, representation of information, data and image in which the production involves the use of a person under the age of 18 years, knowing that the material or matter depicts a person under the age of 13 years personally engaging in or simulating sexual conduct, as de?ned in subdivision of Penal Code section 311.4. COUNT 59 For a further and separate cause of action, being a different offense from but connected in its commission with the charges set forth in counts 1 through 58 hereof, the Criminal Grand Jury of the County of Riverside by this Indictment hereby accuses ERICK MONSIVAIS, JOHN DAVID YODER, WILLIAM CLYDE THOMPSON, and NOLAND ANTHONY HARPER of a violation of Penal Code section 182, subdivision subsection (1), a felony, in that on or about January 2013, through and including January 2015, in the County of Riverside, State of California, they did wil?illy and unlawfully conspire together and with another person and persons whose identity is unknown to commit the crime of COMMIT CHILD PORNOGRAPHY, in violation of Penal Code section a felony, and that pursuant to and for the purpose of carrying out the objects and purposes of the aforesaid conspiracy, the said defendants therea?er committed the following overt act and acts at and in the County of Riverside: OVERT ACT NO. 1 Lured underage minors to participate in child pornography. OVERT ACT NO. 2 Facilitated the production of child pornography. OVERT ACT NO. 3 Provided money and gifts to minors to persuade them to take pornographic photos. 19 I-a. Ln.) Chm-t: MMF??Dk?mn?Jmm-?-wwr?I?k?m? DJ 36 JIWEL A. HESTHIH DISTRICT C??nlf at Riverside Stall! of California April 14, 2015 The Criminal Grand Jury of the County of Riverside by this indictment further alleges that NOLAND ANTHONY HARPER has been convicted in the present case and cases of committing a qualifying sex offense as speci?ed in Penal Code section 667.61, subdivision against more than one victim, within the meaning of Penal Code section 667.61, subdivision subsection (4). MICHAEL A. HESTRIN District Attorney bullie- John Aki Chief Assistant District Attorney JA:jsg Names of witnesses examined by the Criminal Grand Jury on ?nding of the foregoing Indictment: Diane Asato Pedro Beltran Desiree Collins Stacy Denham John Doe (BS) John Doe (BS) John Doe (CM) John Doe (DA) John Doe (DY) John Doe (ES) John Doe (KH) .. John Doe (MB) John Doe (NC) John Doe (P0) Mike Gallagher Lyndon (Russ) Kimberly Brandee Levy Andy Liu 5 Elizabeth Massey 20 36 MICHAEL HEETRIH DISTRICT at" Rheum: Stilt at Andy Liu Elizabeth Massey Tim Pierce . Matt Remmers Dayna Reelfs Melinda Rueb Anthony Ruiz Veronica Thomas Elizabeth Wright Cody Yeder A TRUE BILL: Aim 1] if Forepersen the Cri nal Grand Jury 21