ELECTRONICALLY FILED

Superior Court
Case No: STK-CR-FE-2023-0002047
Date: 02/15/2023
1 RONALD J. FREITAS
District Attorney, County of San Joaquin By: Joseph Montanez
2 State Bar Number 135885
By: Donald Vaughn, SBN 232955
3 Deputy District Attorney
222 E. Weber Avenue, First Floor, Room 101,
4 P.O. Box 990
Stockton, California 95201
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Telephone: (209) 468-2400
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Attorneys for Plaintiff
7

8 SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF SAN JOAQUIN

9 STOCKTON BRANCH
10

11 THE PEOPLE OF THE STATE OF CALIFORNIA, No. SO22-16405

SAN JOAQUIN COUNTY
12 Plaintiff, SHERIFF'S OFFICE CASE
DA Case: 0936055
13 vs.
Complaint No: 202302151990
14 SHAKIR KHAN,
COMPLAINT
15 Defendant(s).

16

17
I, the undersigned, say, on information and belief, that in the County of SAN JOAQUIN, State
18
of California:
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COUNT 1: Code Section EL 18100(A) CAUSING/PROCURING/ALLOWING FALSE
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VOTER REGISTRATION OF SELF/ANOTHER PERSON
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On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
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SHAKIR KHAN did did commit the crime of CAUSING/PROCURING/ALLOWING FALSE
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VOTER REGISTRATION OF SELF/ANOTHER PERSON, in violation of Section 18100(a)
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of the Elections Code, a FELONY, who at the time and place last aforesaid, did willfully cause,
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procure, and allow themselves/any other person to be registered as a voter, and acted knowing
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AW

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 1 themselves/another person are not entitled to this voter registration, to wit: VARIOUS

2 INDIVIDUALS.

4 For a further and separate cause of complaint, being a different offense from but connected in

5 its commission with the charge(s) above, complainant further complains and says:

7 COUNT 2: Code Section EL 18101 FALSE REGISTRATION/REREGISTRATION OF

8 FICTITIOUS PERSON/PERSON NOT REQUESTING REGISTRATION

9 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

10 SHAKIR KHAN did did commit the crime of FALSE REGISTRATION/REREGISTRATION

11 OF FICTITIOUS PERSON/PERSON NOT REQUESTING REGISTRATION, in violation of

12 Section 18101 of the Elections Code, a FELONY, who at the time and place last aforesaid, did

13 willfully and knowingly complete, procure the completion of, in whole and in part, an affidavit

14 of registration and voter registration card, with the intent to cause the registration or

15 reregistration as a voter of a fictitious person and any person who had not requested registration

16 or reregistration as a voter, to wit: VARIOUS INDIVIDUALS.

17

18 For a further and separate cause of complaint, being a different offense from but connected in

19 its commission with the charge(s) above, complainant further complains and says:

20

21 COUNT 3: Code Section EL 18200 SUBSCRIPTION OF FICTITIOUS NAME TO

22 NOMINATION PETITION

23 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

24 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO

25 NOMINATION PETITION, in violation of Section 18200 of the Elections Code, a FELONY,

26 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another

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 1 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe

2 the name of another to a nomination petition, to wit: JOHN or JANE DOE.

4 For a further and separate cause of complaint, being a different offense from but connected in

5 its commission with the charge(s) above, complainant further complains and says:

7 COUNT 4: Code Section EL 18200 SUBSCRIPTION OF FICTITIOUS NAME TO

8 NOMINATION PETITION

9 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

10 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO

11 NOMINATION PETITION, in violation of Section 18200 of the Elections Code, a FELONY,

12 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another

13 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe

14 the name of another to a nomination petition, to wit: JOHN or JANE DOE.

15

16 For a further and separate cause of complaint, being a different offense from but connected in

17 its commission with the charge(s) above, complainant further complains and says:

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19 COUNT 5: Code Section EL 18200 SUBSCRIPTION OF FICTITIOUS NAME TO

20 NOMINATION PETITION

21 On or about June 1, 2020 to November 3, 2020,in the County of San Joaquin, California,

22 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO

23 NOMINATION PETITION, in violation of Section 18200 of the Elections Code, a FELONY,

24 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another

25 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe

26 the name of another to a nomination petition, to wit: JOHN or JANE DOE.

27 //

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 1 For a further and separate cause of complaint, being a different offense from but connected in

2 its commission with the charge(s) above, complainant further complains and says:

4 COUNT 6: Code Section EL 18200 SUBSCRIPTION OF FICTITIOUS NAME TO

5 NOMINATION PETITION

6 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

7 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO

8 NOMINATION PETITION, in violation of Section 18200 of the Elections Code, a FELONY,

9 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another

10 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe

11 the name of another to a nomination petition, to wit: JOHN or JANE DOE.

12 For a further and separate cause of complaint, being a different offense from but connected in

13 its commission with the charge(s) above, complainant further complains and says:

14

15 For a further and separate cause of complaint, being a different offense from but connected in

16 its commission with the charge(s) above, complainant further complains and says:

17

18 COUNT 7: Code Section EL 18200 SUBSCRIPTION OF FICTITIOUS NAME TO

19 NOMINATION PETITION

20 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

21 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO

22 NOMINATION PETITION, in violation of Section 18200 of the Elections Code, a FELONY,

23 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another

24 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe

25 the name of another to a nomination petition, to wit: JOHN or JANE DOE.

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 1 For a further and separate cause of complaint, being a different offense from but connected in

2 its commission with the charge(s) above, complainant further complains and says:

4 COUNT 8: Code Section EL 18200 SUBSCRIPTION OF FICTITIOUS NAME TO

5 NOMINATION PETITION

6 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

7 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO

8 NOMINATION PETITION, in violation of Section 18200 of the Elections Code, a FELONY,

9 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another

10 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe

11 the name of another to a nomination petition, to wit: JOHN or JANE DOE.

12

13 For a further and separate cause of complaint, being a different offense from but connected in

14 its commission with the charge(s) above, complainant further complains and says:

15

16 COUNT 9: Code Section EL 18200 SUBSCRIPTION OF FICTITIOUS NAME TO

17 NOMINATION PETITION

18 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

19 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO

20 NOMINATION PETITION, in violation of Section 18200 of the Elections Code, a FELONY,

21 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another

22 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe

23 the name of another to a nomination petition, to wit: JOHN or JANE DOE.

24

25 For a further and separate cause of complaint, being a different offense from but connected in

26 its commission with the charge(s) above, complainant further complains and says:

27 //

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 1 COUNT 10: Code Section EL 18203 FALSE NOMINATION/DECLARATION OF

2 CANDIDACY

3 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

4 SHAKIR KHAN did did commit the crime of FALSE NOMINATION/DECLARATION OF

5 CANDIDACY, in violation of Section 18203 of the Elections Code, a FELONY, who at the

6 time and place last aforesaid, did willfully and knowingly file, submit for filing, a nomination

7 paper/declaration of candidacy, which is in whole and in part false, to wit: JOHN or JANE

8 DOE.

10 For a further and separate cause of complaint, being a different offense from but connected in

11 its commission with the charge(s) above, complainant further complains and says:

12

13 COUNT 11: Code Section EL 18203 FALSE NOMINATION/DECLARATION OF

14 CANDIDACY

15 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

16 SHAKIR KHAN did did commit the crime of FALSE NOMINATION/DECLARATION OF

17 CANDIDACY, in violation of Section 18203 of the Elections Code, a FELONY, who at the

18 time and place last aforesaid, did willfully and knowingly file, submit for filing, a nomination

19 paper/declaration of candidacy, which is in whole and in part false, to wit: JOHN or JANE

20 DOE.

21

22 For a further and separate cause of complaint, being a different offense from but connected in

23 its commission with the charge(s) above, complainant further complains and says:

24

25 COUNT 12: Code Section EL 18500 FRAUDULENT CASTING OF VOTES

26 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

27 SHAKIR KHAN did did commit the crime of FRAUDULENT CASTING OF VOTES, in

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 1 violation of Section 18500 of the Elections Code, a FELONY, who at the time and place last

2 aforesaid, did willfully commit fraud, attempt to commit fraud, aid/abet fraud, attempt to

3 aid/abet fraud, in connection with any vote cast, attempted to be cast, and to be cast in the

4 future, to wit: VARIOUS INDIVIDUALS.

6 For a further and separate cause of complaint, being a different offense from but connected in

7 its commission with the charge(s) above, complainant further complains and says:

9 COUNT 13: Code Section EL 18561(a)

10 PROCURING/ASSISTING/COUNSELING/ADVISING ANOTHER NOT QUALIFIED

11 TO VOTE

12 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

13 SHAKIR KHAN did did commit the crime of

14 PROCURING/ASSISTING/COUNSELING/ADVISING ANOTHER NOT QUALIFIED TO

15 VOTE, in violation of Section 18561(a) of the Elections Code, a FELONY, who at the time

16 and place last aforesaid, did willfully and knowingly procure, assist, counsel, advise another

17 person to give and offer their vote at any election when that other person is not qualified to vote

18 in said election.

19

20 For a further and separate cause of complaint, being a different offense from but connected in

21 its commission with the charge(s) above, complainant further complains and says:

22

23 COUNT 14: Code Section EL 18561(b) AIDING AND ABETTING COMMISSION OF

24 FRAUDULENT VOTING

25 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,

26 SHAKIR KHAN did did commit the crime of AIDING AND ABETTING COMMISSION OF

27 FRAUDULENT VOTING, in violation of Section 18561(b) of the Elections Code, a

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 1 FELONY, who at the time and place last aforesaid, did willfully aid and abet in the fraudulent

2 casting of a vote.

4 If the above-named defendant(s) is/are presently on probation in San Joaquin County, any

5 evidence presented at a preliminary hearing in the instant case will be used not only as a basis

6 for a holding order in this case but also as evidence of a violation of probation and, at any

7 formal hearing on that violation of probation, the People will move the transcript of the

8 preliminary hearing into evidence as a basis for the violation.

10 That attached hereto and by this reference incorporated herein is a declaration setting forth

11 facts in support of probable cause for the issuance of warrant of arrest herein.

12

13 Pursuant to Penal Code Section 1054.5(b), the People hereby informally request that the

14 defendant and their attorney disclose to the People all information and materials described in

15 Penal Code Section 1054.3.

16

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

18 stated on information and belief and those I believe to be true.

19

20 Executed on February 13, 2023, at Stockton, California.

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22
DONALD VAUGHN
23 Deputy District Attorney
DV/mm
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