ENDORSEDFILED IN MY OFFICE THIS

^UN g I 2015

eLER(fUgfR|6T6^URT

D-202-CR-2015-00105

STATE OF NEW MEXICOCOUNTY OF BERNALILLOSECOND JUDICIAL DISTRICT

STATE OF NEW MEXICO,

Plaintiff,

V.

DOMINIQUE PEREZ,

Defendant.

AMENDED INFORMATION

Randi McGiim, Special Prosecutor for the Second Judicial District of the State of New

Mexico, accuses Dominique Perez of SECOND DEGREE MURDER (FIREARM

ENHANCEMENT), VOLUNTARY MANSLAUGHTER (FIREARM ENHANCEMENT),

INVOLUNTARY MANSLAUGHTER (FIREARM ENHANCEMENT), and AGGRAVATED

ASSAULT (DEADLY WEAPON) (FIREARM ENHANCEMENT), and charges:

COUNT 1: SECOND DEGREE MURDER (FIREARM ENHANCEMENT),VOLUNTARY MANSLAUGHTER (FIREARM ENHANCEMENT), ANDINVOLUNTARY MANSLAUGHTER (FIREARM ENHANCEMENT)

That on or about March 16, 2014, in Bemalillo County, New Mexico, the above-named

defendant did kill James Boyd without lawful justification or excuse and without acting upon

sufficient provocation while knowing that his acts created a strong probability of death or great

bodily harm to James Boyd or to another, contrary to NMSA 1978, 30-2-1(B) and NMSA

1978, 31-18-16; AND FURTHERMORE, the defendant is hereby notified that upon trial of

this cause the finder of fact may be instructed to consider voluntary manslaughter (firearm

enhancement), contrary to NMSA 1978, 30-2-3 andNMSA 1978, 31-18-16; and to consider

involuntary manslaughter (firearm enhancement), contrary to NMSA 1978, 30-2-3 and NMSA

1978, 31-18-16.

COUNT 2: AGGRAVATED ASSAULT (DEADLY WEAPON) (FIREARM

ENHANCEMENT)

That on or about March 16, 2014, in Bemalillo County, New Mexico, the above-named

defendant did unlawfully assault or strike at James Boyd with a firearm (a deadly weapon)

contrary to NMSA 1978, 30-3-2 andNMSA 1978, 31-18-16.

The names of the witnesses upon. whose testimony this information is based are as

follows: Geoff Stone, Rocky Edwards, and other such witnesses as may be called at the

preliminary examination in this matter.

CERTIFICATE OF SERVICE

I hereby certify that a copy of thispleading was served by e-mail on all

counsel of record on June 22, 2015.

:>Randi McGinnKevin P. Holmes

Special Prosecutors for the State of New Mexico

McGinn, Carpenter, Montoya & Love, P.A.

201 Broadway, SEAlbuquerque, New Mexico 87102ph.: (505) 843-6161f: (505)242-8227e-mail: randi(%mcgmnlaw.com

kevm(%mcgiimlaw. corn

STATE v. Dominique PerezAmended Information

C-oi^'-J oSTATE OF?W-MX4GQ~. )

LA H&bL )COUNTY OF B-BRNA-M-fcfcO- )

VERIFICATION

Randi McGiim, Special Prosecutor for the Second Judicial District, State of New Mexico,being duly sworn, says that the facts stated in the foregoing Information are true according to the

best of her information and belief.

idi M.cGSm, Special Prosecutor

Subscribed and sworn to before me

this _[fday of J ^''U _ 2015.

Notary Public

My Commission Expires:

02 - lci- Z D it

"KORI LUCINDADAIViPNOTARY PUBLIC^

STATE OF COLORADO^ID 20154007089

MY ^7ssio'N EXPIRES 02/19/20^

DA file #: 2014-01565-2STN: N/AMET. CT. #: N/ALEA/RPT #: APD # 14-0023683PROS: RANDI MCGINN (SPECIAL PROSECUTOR)

DOB: 03/13/1981SS#XXX-XX-3192DEF ATTY: LUIS ROBLES AND DAVID ROMANADD: 500 Marquette Ave NW, Albuquerque, NM 87102BOOKING/ARREST DATE AND #: NOT ARRESTED

Penalty as to Count 1 : a second degree felony resulting in the death of a human being (firearm),

fifteen years imprisonment plus a one-year mandatory enhancement of the basic sentence.