The Nevada Attorney General's office says the three suspects, Johnny, Jacklynn and Savanna Espinoza, all of Las Vegas, face 14 counts, including conspiracy to commit burglary, burglary, and cruelty to animals.
The Nevada Attorney General's office says the three suspects, Johnny, Jacklynn and Savanna Espinoza, all of Las Vegas, face 14 counts, including conspiracy to commit burglary, burglary, and cruelty to animals.
The Nevada Attorney General's office says the three suspects, Johnny, Jacklynn and Savanna Espinoza, all of Las Vegas, face 14 counts, including conspiracy to commit burglary, burglary, and cruelty to animals.
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AARON D. FORD
Attorney General
CHELSEA KALLAS (Bar No. 13902) 16
Deputy Attorney General Le
Office of the Attorney General
555 E. Washington Ave., Ste. 3900
Las Vegas, Nevada 89101-1068
P: (702) 486-5707
F: (702) 486-0660
Ckallas@ag.nv.gov
Attorneys for the State of Nevada
JUSTICE COURT, LAS VEGAS TOWNSHIP
CLARK COUNTY, NEVADA
STATE OF NEVADA, Case No.: 19F09650ABC
Plaintiff, Dept. No.: 3
v.
JOHNNY ESPINOZA,
JACKLYNN ESPINOZA,
SAVANNA ESPINOZA,
Defendants.
CRIMINAL COMPLAINT
AARON D. FORD, Attorney General for the State of Nevada, complains and charges that:
‘The above-named defendants, JOHNNY ESPINOZA, JACKLYNN ESPINOZA and SAVANNA
ESPINOZA, have committed one or more of the following crimes: CONSPIRACY TO COMMIT
BURGLARY, a gross misdemeanor in violation of NRS 205.060, 199.480; BURGLARY, a category “
felony in violation of NRS 205.060; THEFT IN THE AMOUNT OF $650 OR MORE BUT LESS THAN
$3,500 WITH THE ASSISTANCE OF A CHILD, a technological crime under NRS 205A.030 and a
category “C” felony in violation of NRS 205.0832, 193.162; THEFT IN THE AMOUNT OF $650 OR
MORE BUT LESS THAN $3,500, a technological crime under NRS 205A.030 and a category “C” felony
in violation of NRS 205.0832; THEFT IN THE AMOUNT OF $3,500 OR MORE WITH THE
ASSISTANCE OF A CHILD, a technological crime under NRS 205A.030 and a category “B” felony in
violation of NRS 205.0832, 193.162; CRUELTY TO ANIMALS, a category “D” felony, in violation of
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INRS 574.100(1)(a); and OWNERSHIP OR POSSESSION OF FIREARM BY PROHIBITED PERSON, a
category B felony, in violation of NRS 202.360.
All of the acts alleged herein have been committed or completed between November 2016, and
February 2018, by the above-named defendants, within the County of Clark, State of Nevada, in the
following manner:
COUNT 1
CONSPIRACY TO COMMIT BURGLARY
Gross Misdemeanor - NRS 205.060, 199.480
The Defendant, JOHNNY ESPINOZA, did on or about November 2016, willfully and unlawfully
conspire with SAVANNA ESPINOZA, to commit a burglary, by the Defendant and SAVANNA
ESPINOZA agreeing to commit the acts as set forth in Count 2, said acts being incorporated by this reference
as though fully set forth herein.
COUNT2
BURGLARY
Category "B" Felony - NRS 205.060
‘The Defendant, JOHNNY ESPINOZA, did on or about November 2016, willfully, unlawfully and
feloniously enter a building, owned or occupied by CURTIS POPPETT, located at 9745 Grand Teton Drive,
‘Unit 2003, Las Vegas, Clark County, Nevada, with intent to commit larceny and/or a felony, to wit: thet,
the Defendant(s) being criminally liable under one or more of the following principles of criminal liability,
{to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime,
‘with the intent that this crime be committed, by Defendant JOHNNY ESPINOZA transporting his
icoconspirator(s) to said building with the intent larceny and/or theft be committed; and/or (3) pursuant to a
conspiracy to commit this crime, with the intent that this crime be committed.
COUNT3
THEFT IN THE AMOUNT OF $650 OR MORE BUT LESS THAN $3,500
‘WITH THE ASSISTANCE OF A CHILD
Category "C" Felony - NRS 205.0832; 205A.030; 193.162
The Defendant, JOHNNY ESPINOZA, did on or about November 2016, willfully, knowingly,
feloniously, without lawful authority, with the assistance of a child, control property of another person with
the intent to deprive that person of the property and/or obtain property or services of another person by a
material misrepresentation with intent to deprive that person of the property or services, with the value of
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said property being $650 or more but less than $3,500, by way of acts that involved, directly or indirectly,
any component, device, equipment, system or network that, alone or in conjunction with any other
component, device, equipment, system or network, is designed or has the capability to (a) be programmed;
or (b) generate, process, store, retrieve, convey, emit, transmit, receive, relay, record or reproduce any data,
information, image, program, signal or sound in a technological format, including, without limitation, a
format that involves analog, digital, electronic, electromagnetic, magnetic or optical technology, in the
following manner, to wit: Defendant knowingly obtained a Husky dog named Luna from CURTIS
POPPETT, with the assistance of a child, by falsely representing to CURTIS POPPETT that he would
provide a home for said dog, knowing said dog would instead be sold for profit, with the value of said dog
being $650 or more but less than $3,500; Defendant using the internet and/or cellular device to make said
representations and/or sell said dog, the Defendant(s) being criminally liable under one or more of the
following principles of criminal liability, to wit: (1) by directly committing this crime; and/or (2) by aiding
or abetting in the commission of this crime, with the intent that this crime be committed, by Defendant
transporting his coconspirator(s) to retrieve said dog and/or to complete sale of said dog; and/or (3) pursuant
toa conspiracy to commit this crime, with the intent that this crime be committed.
COUNT 4
THEFT IN THE AMOUNT OF 5650 OR MORE BUT LESS THAN $3,500
WITH THE ASSISTANCE OF A CHILD
Category "C" Felony - NRS 205.0832; 205A.030; 193.162
The Defendants, JOHNNY ESPINOZA and JACKLYNN ESPINOZA, did on or about December
2016, willfully, knowingly, feloniously, without lawful authority, with the assistance of a child, control
property of another person with the intent to deprive that person of the property and/or obtain property or
services of another person by a material mistepresentation with intent to deprive that person of the property
or services, with the value of said property being $650 or more but Jess than $3,500, by way of acts that
involved, directly or indirectly, any component, device, equipment, system or network that, alone or in
conjunction with any other component, device, equipment, system or network, is designed or has the
capability to (a) be programmed; or (b) generate, process, store, retrieve, convey, emit, transmit, receive,
relay, record or reproduce any data, information, image, program, signal or sound in a technological format,
including, without limitation, a format that involves analog, digital, electronic, electromagnetic, magnetic or
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