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SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO

SAN BERNARDINO J USTICE CENTER DISTRICT


THE PEOPLE OF THE STATE OF CALIFORNIA,
Plaintiff
vs.
Terry Dean McKinney

Defendant
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COURT CASE NO




FELONY COMPLAINT


DA CASE NO 2014-00-0048311

The undersigned is informed and believes that:
COUNT 1
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED MURDER OF A PEACE OFFICER/FIREFIGHTER/CUSTODIAL OFFICER-
WILLFUL, DELIBERATE, PREMEDITATED, in violation of PENAL CODE SECTION 664/187(a), a
felony, was committed by Terry Dean McKinney, who did unlawfully attempt to murder Officer
Robert Snyder , who was a peace officer engaged in the performance of duty and this was known,
and reasonably should have been known, by the defendant(s).
It is further alleged, within the meaning of Penal Code Section 664(e) and (f), that the above
offense was willful, deliberate and premeditated.
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).
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Complaint DA CASE NO: 2014-00-0048311

*****
COUNT 2
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED MURDER OF A PEACE OFFICER/FIREFIGHTER/CUSTODIAL OFFICER-
WILLFUL, DELIBERATE, PREMEDITATED, in violation of PENAL CODE SECTION 664/187(a), a
felony, was committed by Terry Dean McKinney, who did unlawfully attempt to murder Officer
Brian Olvera , who was a peace officer engaged in the performance of duty and this was known,
and reasonably should have been known, by the defendant(s).
It is further alleged, within the meaning of Penal Code Section 664(e) and (f), that the above
offense was willful, deliberate and premeditated.
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 3
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED MURDER OF A PEACE OFFICER/FIREFIGHTER/CUSTODIAL OFFICER-
WILLFUL, DELIBERATE, PREMEDITATED, in violation of PENAL CODE SECTION 664/187(a), a
felony, was committed by Terry Dean McKinney, who did unlawfully attempt to murder Officer
Ernest Luna , who was a peace officer engaged in the performance of duty and this was known,
and reasonably should have been known, by the defendant(s).
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Complaint DA CASE NO: 2014-00-0048311
It is further alleged, within the meaning of Penal Code Section 664(e) and (f), that the above
offense was willful, deliberate and premeditated.
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 4
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED MURDER OF A PEACE OFFICER/FIREFIGHTER/CUSTODIAL OFFICER-
WILLFUL, DELIBERATE, PREMEDITATED, in violation of PENAL CODE SECTION 664/187(a), a
felony, was committed by Terry Dean McKinney, who did unlawfully attempt to murder Officer
Francisco Hernandez , who was a peace officer engaged in the performance of duty and this was
known, and reasonably should have been known, by the defendant(s).
It is further alleged, within the meaning of Penal Code Section 664(e) and (f), that the above
offense was willful, deliberate and premeditated.
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
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Complaint DA CASE NO: 2014-00-0048311
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 5
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED MURDER OF A PEACE OFFICER/FIREFIGHTER/CUSTODIAL OFFICER-
WILLFUL, DELIBERATE, PREMEDITATED, in violation of PENAL CODE SECTION 664/187(a), a
felony, was committed by Terry Dean McKinney, who did unlawfully attempt to murder Officer
J esse Shank , who was a peace officer engaged in the performance of duty and this was known,
and reasonably should have been known, by the defendant(s).
It is further alleged, within the meaning of Penal Code Section 664(e) and (f), that the above
offense was willful, deliberate and premeditated.
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 6
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED WILLFUL, DELIBERATE, AND PREMEDITATED MURDER, in violation of PENAL
CODE SECTION 664/187(a), a felony, was committed by Terry Dean McKinney, who did
unlawfully and with malice aforethought attempt to murder Natalie D, a human being.
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Complaint DA CASE NO: 2014-00-0048311
It is further alleged that the aforesaid attempted murder was committed willfully, deliberately
and with premeditation within the meaning of Penal Code section 664(a) and is a serious felony
pursuant to Penal Code section 1192.7(c).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 7
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED WILLFUL, DELIBERATE, AND PREMEDITATED MURDER, in violation of PENAL
CODE SECTION 664/187(a), a felony, was committed by Terry Dean McKinney, who did
unlawfully and with malice aforethought attempt to murder Miguel Z, a human being.
It is further alleged that the aforesaid attempted murder was committed willfully, deliberately
and with premeditation within the meaning of Penal Code section 664(a) and is a serious felony
pursuant to Penal Code section 1192.7(c).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
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Complaint DA CASE NO: 2014-00-0048311
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 8
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED WILLFUL, DELIBERATE, AND PREMEDITATED MURDER, in violation of PENAL
CODE SECTION 664/187(a), a felony, was committed by Terry Dean McKinney, who did
unlawfully and with malice aforethought attempt to murder J ose Segura , a human being.
It is further alleged that the aforesaid attempted murder was committed willfully, deliberately
and with premeditation within the meaning of Penal Code section 664(a) and is a serious felony
pursuant to Penal Code section 1192.7(c).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 9
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED WILLFUL, DELIBERATE, AND PREMEDITATED MURDER, in violation of PENAL
CODE SECTION 664/187(a), a felony, was committed by Terry Dean McKinney, who did
unlawfully and with malice aforethought attempt to murder Ernesto Sanchez , a human being.
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Complaint DA CASE NO: 2014-00-0048311
It is further alleged that the aforesaid attempted murder was committed willfully, deliberately
and with premeditation within the meaning of Penal Code section 664(a) and is a serious felony
pursuant to Penal Code section 1192.7(c).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 10
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED WILLFUL, DELIBERATE, AND PREMEDITATED MURDER, in violation of PENAL
CODE SECTION 664/187(a), a felony, was committed by Terry Dean McKinney, who did
unlawfully and with malice aforethought attempt to murder Carolina Sanchez , a human being.
It is further alleged that the aforesaid attempted murder was committed willfully, deliberately
and with premeditation within the meaning of Penal Code section 664(a) and is a serious felony
pursuant to Penal Code section 1192.7(c).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
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Complaint DA CASE NO: 2014-00-0048311
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 11
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED WILLFUL, DELIBERATE, AND PREMEDITATED MURDER, in violation of PENAL
CODE SECTION 664/187(a), a felony, was committed by Terry Dean McKinney, who did
unlawfully and with malice aforethought attempt to murder Orlando Arreguin , a human being.
It is further alleged that the aforesaid attempted murder was committed willfully, deliberately
and with premeditation within the meaning of Penal Code section 664(a) and is a serious felony
pursuant to Penal Code section 1192.7(c).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 12
On or about September 14, 2014, in the above named judicial district, the crime of
ATTEMPTED WILLFUL, DELIBERATE, AND PREMEDITATED MURDER, in violation of PENAL
CODE SECTION 664/187(a), a felony, was committed by Terry Dean McKinney, who did
unlawfully and with malice aforethought attempt to murder Ramiro Perez DeAnda , a human being.
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Complaint DA CASE NO: 2014-00-0048311
It is further alleged that the aforesaid attempted murder was committed willfully, deliberately
and with premeditation within the meaning of Penal Code section 664(a) and is a serious felony
pursuant to Penal Code section 1192.7(c).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 13
On or about September 14, 2014, in the above named judicial district, the crime of
SHOOTING AT OCCUPIED MOTOR VEHICLE, in violation of PENAL CODE SECTION 246, a
felony, was committed by Terry Dean McKinney, who did willfully, unlawfully, and maliciously
discharge a firearm at an occupied motor vehicle.

"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: It is further alleged that, pursuant to Penal Code section 1203.095, there is a
presumptive minimal jail time required if you are convicted of this charge."

"NOTICE: The above offense is a serious felony within the meaning of Penal Code section
1192.7(c)."
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said
defendant(s) Terry Dean McKinney personally and intentionally discharged a firearm, a handgun,
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Complaint DA CASE NO: 2014-00-0048311
within the meaning of Penal Code Section 12022.53(c) also causing the above offense to become
a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the
meaning of Penal Code section 667.5(c)(8).
It is further alleged as to count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 that said defendant(s)
Terry Dean McKinney personally used a firearm, a handgun, within the meaning of Penal Code
Section 12022.53(b) also causing the above offense to become a serious felony pursuant to Penal
Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section
667.5(c)(8).

*****
COUNT 14
On or about September 14, 2014, in the above named judicial district, the crime of
RESISTING EXECUTIVE OFFICER, in violation of PENAL CODE SECTION 69, a felony, was
committed by Terry Dean McKinney, who did unlawfully attempt by means of threats and violence
to deter and prevent Detective J . Simpson , who was then and there an executive officer, from
performing a duty imposed upon such officer by law, and did knowingly resist by the use of force
and violence said executive officer in the performance of his/her duty.
*****

* * * * *
NOTICE TO DEFENDANT AND DEFENDANTS 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."

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Complaint DA CASE NO: 2014-00-0048311
I DECLARE UNDER PENALTY OF PERJ URY THAT THE FOREGOING IS TRUE AND
CORRECT AND THAT THIS COMPLAINT CONSISTS OF 14 COUNT(S).
Executed at San Bernardino, California, on September 16, 2014.
Robert P. Brown
Robert P. Brown
DECLARANT AND COMPLAINANT

Agency: San Bernardino Police Department Prelim Est. 00:00

Defendant
Terry Dean McKinney

Birth Date
12/22/1954

Booking No.


CII No.


NCIC




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Complaint DA CASE NO: 2014-00-0048311

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