Complaint Filing Document - San Bernardino County District Attorney

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO 

BARSTOW DISTRICT 

THE PEOPLE OF THE STATE OF CALIFORNIA, 

vs. 

Scott Christopher Johnson , 

Mioshi Tikia Johnson 

Complaint DA CASE NO: 2011-00-0044212 

Plaintiff 

Defendant 

The undersigned is informed and believes that: 

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COUNT 1 

Page 1 

COURT CASE NO 

FELONY COMPLAINT 

DA CASE NO 2011-00-0044212 

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

district, the crime of LEWD ACT UPON A CHILD, in violation of PENAL CODE SECTION 288(a), a 

felony, was committed by Scott Christopher Johnson, who did willfully, unlawfully, and lewdly 

commit a lewd and lascivious act upon and with the body and certain parts and members thereof 

of Jane Doe #1, DOB: 02-01-1997, 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. 

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

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

"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."

"NOTICE: The above offense is a serious felony within the meaning of Penal Code section 

1192.7(c) and a violent felony within the meaning of Penal Code section 667.5(c)." 

"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." 


***** 

COUNT 2 


district, the crime of ORAL COPULATION OF A PERSON UNDER 14, in violation of PENAL 

CODE SECTION 288a(c)(1), a felony, was committed by Scott Christopher Johnson, who did 

unlawfully participate in an act of oral copulation with Jane Doe #1, a person under the age of 

fourteen years and more than ten years younger than defendant Scott Christopher Johnson. 






"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 

Page 2

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." 




report." 


***** 

COUNT 3 


district, the crime of ORAL COPULATION OF A PERSON UNDER 14, in violation of PENAL 

CODE SECTION 288a(c)(1), a felony, was committed by Scott Christopher Johnson, who did 

unlawfully participate in an act of oral copulation with Jane Doe #1, a person under the age of 

fourteen years and more than ten years younger than defendant Scott Christopher Johnson. 






"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." 

Page 3








report." 


***** 

COUNT 4 


district, the crime of AGGRAVATED SEXUAL ASSAULT OF A CHILD - PC261(a)(2), in violation of 

PENAL CODE SECTION 269(a)(1), a felony, was committed by Scott Christopher Johnson, who 

did commit the following act upon victim, Jane Doe #1, who was under the age of 14 years, the 

defendant Scott Christopher Johnson, being 7 and more years older than the victim: Rape, in 

violation of Penal Code Section 261(a)(2) and Penal Code Section 261(a)(6). 








report." 

Page 4


***** 

COUNT 5 


district, the crime of AGGRAVATED SEXUAL ASSAULT OF A CHILD - PC289(a), in violation of 

PENAL CODE SECTION 269(a)(5), a felony, was committed by Scott Christopher Johnson, who 

did commit the following act upon victim, Jane Doe #1, who was under the age of 14 years, the 

defendant Scott Christopher Johnson, being 7 and more years older than the victim: Sexual 

penetration, in violation of Penal Code Section 289(a). 




report." 

***** 

COUNT 6 

On or about May 9, 2006 through May 8, 2007, in the above named judicial district, the 

crime of LEWD ACT UPON A CHILD, in violation of PENAL CODE SECTION 288(a), a felony, was 

committed by Scott Christopher Johnson, who did willfully, unlawfully, and lewdly commit a lewd 

and lascivious act upon and with the body and certain parts and members thereof of Jane Doe #2, 

DOB: 05-09-1998, 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. 






report." 

Page 5







***** 

COUNT 7 

On or about May 9, 2006 through May 8, 2007, in the above named judicial district, the 











report." 

Page 6







***** 

COUNT 8 

On or about December 18, 2009 through December 17, 2010, in the above named judicial 




of Jane Doe #3, 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. 






report." 



Page 7





***** 

COUNT 9 

On or about December 18, 2009 through December 17, 2010, in the above named judicial 




of Jane Doe #3, 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. 






report." 



Page 8





***** 

COUNT 10 

On or about December 18, 2010 through July 12, 2011, in the above named judicial district, 

the crime of LEWD ACT UPON A CHILD, in violation of PENAL CODE SECTION 288(a), a felony, 

was committed by Scott Christopher Johnson, who did willfully, unlawfully, and lewdly commit a 

lewd and lascivious act upon and with the body and certain parts and members thereof of Jane 

Doe #3, 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. 






report." 






Page 9


***** 

COUNT 11 

On or about July 6, 2011, in the above named judicial district, the crime of LEWD ACT 

UPON A CHILD, in violation of PENAL CODE SECTION 288(a), a felony, was committed by Scott 

Christopher Johnson, who did willfully, unlawfully, and lewdly commit a lewd and lascivious act 

upon and with the body and certain parts and members thereof of Jane Doe #3, 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. 






report." 






Page 10


***** 

COUNT 12 

On or about October 28, 2008 through October 27, 2010, in the above named judicial 












report." 






Page 11


***** 

COUNT 13 

On or about October 28, 2010 through July 12, 2011, in the above named judicial district, 

the crime of LEWD ACT UPON A CHILD, in violation of PENAL CODE SECTION 288(a), a felony, 

was committed by Scott Christopher Johnson, who did willfully, unlawfully, and lewdly commit a 

lewd and lascivious act upon and with the body and certain parts and members thereof of Jane 

Doe #4, 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. 






report." 






Page 12


***** 

COUNT 14 

On or about June 1, 2011 through July 12, 2011, in the above named judicial district, the 











report." 






Page 13


***** 

COUNT 15 

On or about February 10, 2004 through February 9, 2005, in the above named judicial 












report." 






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It is further alleged, within the meaning of Penal Code section 667.61(b)and (e), as to 

counts 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15 that the following circumstances apply: 

multiple victims. 


***** 

COUNT 16 

On or about February 1, 2007 through May 8, 2008, in the above named judicial district, the 

crime of CHILD ABUSE, in violation of PENAL CODE SECTION 273a(a), a felony, was committed 

by Mioshi Tikia Johnson, who did willfully and unlawfully, under circumstances likely to produce 

great bodily harm and death, injure, cause, and permit a child, Jane Doe #1, to suffer and to be 

inflicted with unjustifiable physical pain and mental suffering, and, having the care and custody of 

said child, injure, cause, and permit the person and health of said child to be injured and did 

willfully cause and permit said child to be placed in such situation that his/her person and health 

was/were endangered. 




report." 

***** 

COUNT 17 

On or about February 1, 2007 through May 8, 2008, in the above named judicial district, the 

crime of CHILD ABUSE, in violation of PENAL CODE SECTION 273a(a), a felony, was committed 

by Mioshi Tikia Johnson, who did willfully and unlawfully, under circumstances likely to produce 

great bodily harm and death, injure, cause, and permit a child, Jane Doe #2, to suffer and to be 

inflicted with unjustifiable physical pain and mental suffering, and, having the care and custody of 

said child, injure, cause, and permit the person and health of said child to be injured and did 

willfully cause and permit said child to be placed in such situation that his/her person and health 

was/were endangered. 

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report." 


***** 

COUNT 18 

On or about July 6, 2011, in the above named judicial district, the crime of CHILD ABUSE, 

in violation of PENAL CODE SECTION 273a(a), a felony, was committed by Mioshi Tikia Johnson, 

who did willfully and unlawfully, under circumstances likely to produce great bodily harm and 

death, injure, cause, and permit a child, Jane Doe #3, to suffer and to be inflicted with unjustifiable 

physical pain and mental suffering, and, having the care and custody of said child, injure, cause, 

and permit the person and health of said child to be injured and did willfully cause and permit said 

child to be placed in such situation that his/her person and health was/were endangered. 




report." 

***** 

COUNT 19 

On or about July 6, 2011, in the above named judicial district, the crime of CHILD ABUSE, 

in violation of PENAL CODE SECTION 273a(a), a felony, was committed by Mioshi Tikia Johnson, 

who did willfully and unlawfully, under circumstances likely to produce great bodily harm and 

death, injure, cause, and permit a child, Jane Doe #4, to suffer and to be inflicted with unjustifiable 

physical pain and mental suffering, and, having the care and custody of said child, injure, cause, 

and permit the person and health of said child to be injured and did willfully cause and permit said 

child to be placed in such situation that his/her person and health was/were endangered. 



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report." 


***** 

* * * * * 

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 ATTORNEY 

The 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 19 COUNT(S). 

Executed at Barstow, California, on September 30, 2011. 

Lana Dallas 

DECLARANT AND COMPLAINANT 

Agency: Barstow Police Department Prelim Est. 00:00 

Defendant 

Scott Christopher Johnson 

Mioshi Tikia Johnson 

Birth Date 

06/15/1971 

07/10/1975 

Booking No. 

Page 17 

CII No. 

A08701490 

NCIC

Complaint Filing Document - San Bernardino County District Attorney

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