STATE OF SOUTH DAKOTA) IN CIRCUIT COURT

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COUNTY OF LINCOLN) SECOND JUDICIAL COURT
State of South Dakota, URL '77
Plaintiff, Complnint for
vs. C1. 1: Raps, First Degree,

SDCL 22-22-1 (1)
Ct 2: Possession of Child Pornography,
SDCL 
Sioux Falls SD 57108 cm 3: Possession of Child Pornography,

DDB-- SDCL 

Ct. 4: Possession of Child 

Defendant. SDCL 
Ct. 5: Possession of Child Pornography,

SDCL 
CL. 6: Possession of Child Pumography,

SDCL 

Ct, 7: of Child Pornography,
SDCL 

CI. 8: Possession of Child Pornography,
SDCL 

Ct. 9: Possession of Child Pornography,
SDCL 

Ct, 10: Possession of Child 
SDCL 

C1. 1 1: Possession of Child Pornography,
SDCL 

 

The undersigned being duly upon dam charges:

That on or between the 28th day of January, 2019 and the 23"" day of January, 2020 in the
County of Lincoln, State of South Dakota, uan Dr Thomas, In, did commit the public offense of:
Count 1.

RAPE, FIRST DEGREE (SDCL 2142-10)) in that he did accomplish an act of sexual
to wit:_ Juan D, 

 

   
 

3232.10)

act pf sexunl Ion -age 10, in violation or 
felon 

    

Page 1 of4 County, .D.

Clark Circuit Con

Count 2,

POSSESSION OF CHILD PORNOGRAPHY (SDCL 22-24A-3 in that he did possess,
manufacture, or distribute child pornography by knowingly possessing, distributing, or otherwise
disseminating any visual depiction of a minor engaging in a prohibited sexual act, or in the
simulation of such an act, to-wit: Juan D. Thomas Jr. did possess, manufacture, or distribute child
pornography by knowingly possessing, distributing, or otherwise disseminating any visual
depiction of a minor engaging in a prohibited sexual act, or in the simulation of such an act in
violation of SDCL (Cl. 4 felony);

Count 3.

POSSESSION OF CHILD PORN OGRAPHY (SDCL 22-24A-3 in that he did possess,
manufacture, or distribute child pornography by knowingly possessing, distributing, or otherwise
disseminating any visual depiction of a minor engaging in a prohibited sexual act, or in the
simulation of such an act, to-wit: Juan D. Thomas Jr. did possess, manufacture, or distribute child
pornography by knowingly possessing, distributing, or otherwise disseminating any visual
depiction of a minor engaging in a prohibited sexual act, or in the simulation of such an act in
violation of SDCL 22-24-38), (Cl. 4 felony);

Count 4.

POSSESSION OF CHILD PORNOGRAPHY (SDCL 22-24A-3 in that he did possess,
manufacture, or distribute child pornography by knowingly possessing, distributing, or otherwise
disseminating any visual depiction of a minor engaging in a prohibited sexual act, or in the
simulation of such an act, to?wit: Juan D. Thomas Jr. did possess, manufacture, or distribute child
pornography by knowingly possessing, distributing, or otherwise disseminating any visual
depiction of a minor engaging in a prohibited sexual act, or in the simulation of such an act in
violation of SDCL 22-24-38), (Cl. 4 felony);

Count 5.

POSSESSION OF CHILD PORNOGRAPHY (SDCL in that he did possess,
manufacture, or distribute child pornography by knowingly possessing, distributing, or otherwise
disseminating any visual depiction of a minor engaging in a prohibited sexual act, or in the
simulation of such an act, to-wit: Juan D. Thomas Jr. did possess, manufacture, or distribute child
pornography by knowingly possessing, distributing, or otherwise disseminating any visual

depiction of a minor engaging in a prohibited sexual act, or in the simulation of such an act in

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violation of SDCL 22-24-30), (Cl. 4 felony);
Count 6.

POSSESSION OF CHILD PORNOGRAPI-IY (SDCL 22-24A-3 in that he did possess,
manufacture, or distribute child pornography by knowingly possessing, distributing, or otherwise
disseminating any visual depiction of a minor engaging in a prohibited sexual act, or in the
simulation of such an act, to-wit: Juan D. Thomas Jr. did possess, manufacture, or distribute child
pornography by knowingly possessing, distributing, or otherwise disseminating any visual
depiction of a minor engaging in a prohibited sexual act, or in the simulation of such an act in
violation of SDCL (Cl. 4 felony);

Count 7.

POSSESSION OF CHILD PORNOGRAPHY (SDCL 22-24A-3 in that he did possess,
manufacture, or distribute child pornography by knowingly possessing, distributing, or otherwise
disseminating any visual depiction of a minor engaging in a prohibited sexual act, or in the
simulation of such an act, to-wit: Juan D. Thomas Jr. did possess, manufacture, or distribute child
pornography by knowingly possessing, distributing, or otherwise disseminating any visual
depiction of a minor engaging in a prohibited sexual act, or in the simulation of such an act in
violation of SDCL 22-24-36), (Cl. 4 felony);

Count 8.

POSSESSION OF CHILD PORNOGRAPHY (SDCL in that he did possess,
manufacture, or distribute child pornography by knowingly possessing, distributing, or otherwise
disseminating any visual depiction of a minor engaging in a prohibited sexual act, or in the
simulation of such an act, to-wit: Juan D. Thomas Jr. did possess, manufacture, or distribute child
pornography by knowingly possessing, distributing, or otherwise disseminating any visual
depiction of a minor engaging in a prohibited sexual act, or in the simulation of such an act in
violation of SDCL (Cl. 4 felony);

Count 9.

POSSESSION OF CHILD PORNOGRAPHY (SDCL in that he did possess,
manufacture, or distribute child pornography by knowingly possessing, distributing, or otherwise
disseminating any visual depiction of a minor engaging in a prohibited sexual act, or in the
simulation of such an act, to?wit: Juan D. Thomas Jr. did possess, manufacture, or distribute child

pornography by knowingly possessing, distributing, or otherwise disseminating any visual

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depiction of a minor engaging in a prohibited sexual act, or in the simulation of such an act in
violation of SDCL 22-24-30), (Cl. 4 felony);
Count 10.

POSSESSION OF CHILD PORNOGRAPHY (SDCL 22-24A-3 in that he did possess,
manufacture, or distribute child pornography by knowingly possessing, distributing, or otherwise
disseminating any visual depiction of a minor engaging in a prohibited sexual act, or in the
simulation of such an act, to-wit: Juan D. Thomas Jr. did possess, manufacture, or distribute'child
pornography by knowingly possessing, distributing, or otherwise disseminating any visual
depiction of a minor engaging in a prohibited sexual act, or in the simulation of such an act in
violation of SDCL 22-24-36), (Cl. 4 felony);

Count 11.

POSSESSION OF CHILD PORNOGRAPHY (SDCL in that he did possess,
manufacture, or distribute child pornography by knowingly possessing, distributing, or otherwise
disseminating any visual depiction of a minor engaging in a prohibited sexual act, or in the
simulation of such an act, to-wit: Juan D. Thomas Jr. did possess, manufacture, or distribute child
pornography by knowingly possessing, distributing, or otherwise disseminating any visual
depiction of a minor engaging in a prohibited sexual act, or in the simulation of such an act in
violation of SDCL 22-24-30), (Cl. 4 felony);

contrary to the statute in such case, made and provided against the peace and dignity of the
State of South Dakota.

Dated this 29th day of January, 2020.

 

Prbs?cuting Attorney

Subscribed and sworn to before me this 29th day of January, 2020.

 

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