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					                                 SUPERIOR COURT OF CALIFORNIA
                                    COUNTY OF SANTA CLARA
                                       SAN JOSE FACILITY

THE PEOPLE OF THE STATE OF CALIFORNIA,           |
                                      Plaintiff, |
                                                 |                 FIRST AMENDED
                                                 |                 FELONY COMPLAINT
                                                 |                 DOCKET NO: C1103298
                           vs.                   |                 DA NO: 110306957
                                                 |
VINCENT CHRISTOPHER MERGONOTO (1/11/1992),       |                      CEN
                                                 |                     11013703 VM SORP 3/30/2011
CHANDRA DICKY PURNAMA (6/12/1989),               |                     11013698 CP SORP 3/30/2011
 aka CHANDRA DEDDY PURNAMA,                      |
                                                 |
                                   Defendants. |
                                                 |

The undersigned is informed and believes that:

                                                 COUNT 1
On or about March 20, 2011, in the County of Santa Clara, State of California, the crime of
VEHICULAR MANSLAUGHTER WITH GROSS NEGLIGENCE, in violation of PENAL CODE
SECTION 192(c)(1), a Felony, was committed by VINCENT CHRISTOPHER MERGONOTO AND
CHANDRA DICKY PURNAMA who did without malice kill Ashley Krieger, a human being, in the
driving of a vehicle with gross negligence, in the commission of an unlawful act, that is, a violation of
section V.C. 23109(a) of the Vehicle Code, and in the commission of a lawful act which might produce
death in an unlawful manner.




                                                 COUNT 2
On or about March 20, 2011, in the County of Santa Clara, State of California, the crime of FALSE
PERSONATION EXPOSING THE VICTIM TO LIABILITY, in violation of PENAL CODE SECTION
529, a Felony, was committed by CHANDRA DICKY PURNAMA who did falsely personate another,
Chandra Deddy Purnama, in his private and official capacity and in such assumed character committed
an act whereby, if done by the person falsely personated, he might become liable to a suit and
prosecution, and to pay a sum of money, and to incur a charge, forfeiture and penalty, and whereby a
benefit might accrue to the party personating and to another person.
Any defendant, including a juvenile, who is convicted of and pleads guilty and no contest to any felony
offense, including any attempt to commit the offense, charged in this complaint or information is
required to provide buccal swab samples, right thumbprints and a full palm print impression of each
hand, and any blood specimens or other biological samples required pursuant to the DNA and Forensic
Identification Database and Data Bank Act of 1998 and Penal Code section 296, et seq.




Further, attached and incorporated by reference are official reports and documents of a law enforcement
agency which the complainant believes establish probable cause for the pretrial restraint of defendant
VINCENT CHRISTOPHER MERGONOTO, for the above-listed crimes.




Further, attached and incorporated by reference are official reports and documents of a law enforcement
agency which the complainant believes establish probable cause for the pretrial restraint of defendant
CHANDRA DICKY PURNAMA, for the above-listed crimes.




Complainant therefore requests that the defendants be dealt with according to law.
I certify under penalty of perjury that the above is true and correct.
Executed on March 29, 2011, in SANTA CLARA County, California.



                                                      Soto S1992
                                                     ( Janssen J4780 )
                                                     SCPD (408) 615-4760 112953 ***
                                                     SMITH/ D516/ FELONY/ mw
                     MERGONOTO AND PURNAMA
                  DISTRICT ATTORNEY CASE STATUS REPORT

File No: 110306957
Facility: SAN JOSE FACILITY                Docket No:
Arresting Agency: SANTA CLARA POLICE DEPARTMENT       Officer: JANSSEN

 1.    Defendant:Vincent Christopher Mergonoto            CEN: 11013703

       Charges: PC192(c)(1)



       Lab No.:            BA%:                  Drugs:

       Defense Attorney:

 2.    Defendant:Chandra Dicky Purnama                    CEN: 11013698

       Charges: PC192(c)(1), PC529



       Lab No.:            BA%:                  Drugs:

       Defense Attorney:

                                                             Offense Date: 3/20/2011
Priors:                           Cite No:                   Date:
DMV/SUSP:                         OFCN No: 112953            Date:
FBI:                              CII:                       Div:

Time Est:                         Offer:                     Review:

DATE                                                                             DEPUTY
                           SUPERIOR COURT OF CALIFORNIA
                                   San Jose Facility

THE PEOPLE OF THE STATE OF CALIFORNIA,           |
                                      Plaintiff, |
                                                 |   FIRST AMENDED
                                                 |   FELONY COMPLAINT
                                                 |   DOCKET NO: C1103298
                           vs.                   |   DA NO: 110306957
                                                 |
VINCENT CHRISTOPHER MERGONOTO (1/11/1992),       |     CEN
                                                 |    11013703 VM SORP 3/30/11
CHANDRA DICKY PURNAMA (6/12/1989),               |    11013698 CP SORP 3/30/11
 aka CHANDRA DEDDY PURNAMA,                      |
                                   Defendants. |
                                                 |


                                 CASE SUMMARY

Count   Charge        Charge Range   Defendant             Allegation   Alleg. Effect
1       PC192(c)(1)   2-4-6          VINCENT CHRISTOPHER
                                     MERGONOTO
                                     CHANDRA DICKY
                                     PURNAMA

2       PC529         16-2-3         CHANDRA DICKY
                                     PURNAMA

				
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