0 2 3 4 15]) 16 18 | 20 21 2 2 4 25 26 al] 28 FILED File No. F-21-06622 Stephanie A. Bridgett DISTRICT ATTORNEY SEP 24 2021 Sata County ea 1535 West Set scour super coer Reading, CA 96001 (530) 245.6300 Shastada@co.shasta.ca.us Attorney for Plaintift IN THE SUPERIOR COURT OF CALIFORNIA, COUNTY OF SHASTA, ‘Redding Branch THE PEOPLE OF THE STATE OF CALIFORNIA, No. 21-06622 Plaintiff, COMPLAINT-CRIMINAL ¥s Felony PACIFIC GAS AND ELECTRIC COMPANY Next Court Date DA FFo21-06622 CAL FIREICDF 20CASHU009978 The Disret Atorey of Shasta County, by and through the undersigned Deputy District ‘Attorney, on information and belief, complains and accuses defendant(s) of having committed, in the County of Shasta, Stae of California, the crime(s) of coUNT 1 INVOLUNTARY MANSLAUGHTER: FAILURE TO PERFORM LEGAL DUTY, Violation of Section 192(b) of the Penal Code, a Felony. Defenan PACIFIC GAS AND ELECTRIC COMPANY (PG&E), Cn orabout the 2 ay 5 Sepebe 3000 40 willy and unl nase the death of hua being fo it HELA MCLEOD, without male, ea rniatrest fi detent? file vith ring nel gence o perform legal dy owed o FEYLA MCLEOD, to wit legal tty afl opeas lei transmission and dtibuton ines na ne th iii the risk of eaustopic wirescount 2 INVOLUNTARY MANSLAUGHTER: FAILURE TO PERFORM LEGAL DUTY, in violation of Section 192(b) of the Penal Code, a Felony. Dotnet TACIFIC GAS aND ELECTRIC COMPANY (PG&), nora 27 ay Sete 2000 ly sd wily cause he death of Iman tengo it ALATNA ROWE, witht main a pronase’ fare witherminal el gnc to pafom eal du owed o ALAINA ROWE, owt ge dy tose opts elec! tannin ad ibn Ines na mane ht nize te fk ofeatastopbi dies COUNT3 INVOLUNTARY MANSLAUGHTER: FAILURE TO PERFORM LEGAL DUTY, in violation of Section 192(b) of the Penal Code, a Felony. Defendant PACIFIC GAS AND ELECTRIC COMPANY (PGR), Cn or aba the Sh ay September 3005, wily and uf case the death of human being to it KARIN RING, witht male, a proxinate rest of hd dfendan's fate wath inal np gence to perfor gal duty owed o KARIN KING, twit leg daty tsa opens elected arsmisdon and dtibuton ines inamanner that minimizes th ik of Caastoph ies count 4 INVOLUNTARY MANSLAUGHTER: FAILURE TO PERFORM LEGAL DUTY, in violation of Section 192(b) of the Penal Code, a Felony. Defeat PACIFIC GAS AND ELECTRIC COMPANY (PG&E), Cn orbeut the 2h ay Septet 2026 wilfully and uf cause the det human being wit KENNETH VOSSEN, without ali, wa proxies of tend flue with emia negligence perform aegl ty owed fo KENNETH VOSSEN, tot leg dt fo sly opt ketal nsnaton and Sittin Ines in manner at minimizes thik of atatrophi wines10 R 3] “4 Is 1s " is 9 2» a 2 B 4 25 26 n 8 counrs RECKLESSLY CAUSING FIRE WITH GREAT BODILY INJURY, in violation of Seetion 452(A) of the Penal Cod: a Felony. Defendant PACIFIC GAS AND ELECTRIC COMPANY (PG&E), Cn or abet ie Th yo Septem, 2000 hd lela rskesly sire to and bun and Cause o be bined strc, forest fn pesonl propery and id cuse great boli KARIN KING AND FEYLA MCLEOD AND ALAINA ROWE AND KENNETH VOSSEN AND FIREFIGHTER A, MARTINEZ COUNT 6 RECKLESSLY CAUSING FIRE TO INHABITED STRUCTURE, in violation of Section 452(B) of the Penal Code, a Felony. Defendant () PACIFIC GAS AND ELECTRIC COMPANY (PG&P), (On or about the 27th dey of September, 2020, did unlawfully and recklessly set fie to and bum and cause fo be burned an inhabited structure and inhabited property loeated at ZOGG MINE ROAD (OGG FIRE) COUNT? RECKLESSLY CAUSING FIRE OF STRUCTURE OR FOREST, in violation of Section 452(C) of the Penal Cod:, a Felony. Defendant (s) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), On or about the 27th day of September, 2020, did unlawfully and recklessly set fie toand bum and ‘ause to be bummed a structure and forest land located at ZOGG MINE ROAD (Z0GG FIRE), counTs jon of Section RECKLESSLY CAUSING FIRE OF STRUCTURE OR FOREST, in viol 4452(C) of the Penal Code, Felony. Defendant (9) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), ‘On or about the 28th day of July, 2020, did unlawfully and recklessly set fire to and bum and cause ta be burned a structure and forest land located at BEAR MOUNTAIN ROAD (DANIEL FIRE).counr9 RECKLESSLY CAUSING FIRE OF STRUCTURE OR FOREST, in violation of Seetion 452(C) of the Penal Cod:, a Felony. Defendant () PACIFIC GAS AND ELECTRIC COMPANY (PG&E), (On or about the 19th day of October, 2020, did unlawfully aud recklessly set fire to and burn and cause fo be bummed a structure and forestland located at PONDER WAY (PONDER FIRE), COUNT 10 RECKLESSLY CAUSING FIRE OF STRUCTURE OR FOREST, in violation of Seetion 452(C) of the Penal Cod:, a Felony. Defendant (3) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), (On or about the 19th day of August, 2021, did unlawfully and recklessly set fie to-and burn and ‘cause to be bummed a structure and forestland located at SHASTA COUNTY (WOODY FIRE), couNT 1 RECKLESSLY CAUSE FIRE TO PROPERTY OF ANOTHER, in 452(D) of the Penal Code, a Felony. Defendant (9 PACIFIC GAS AND ELECTRIC COMPANY (PG&E), On or abut Tayo Sep, 2000 snl an kes et seo and bur nd used tobe burned the property of nae, to wit MULTIPLE DOMESTICATED ANIMALS, Incted st Z0G0 MINE ROAD (2OGG FIRE) COUNT 12 in violation of Section 13001 of the Health and Safety Code, NEGLIGENT FIRE STARTIN Defentn ( TACIFIC GAS AND ELECTRIC COMPANY (PG&E), Cn or about the Sh ayo Sep 2020 dd lly and unflly, hogh aces and esliget acto, tizow an plac any lige igre, cigar ass, oe ming or lowing Subse and any sabtnc and thing whch may ene fit, nay place where ay ely and indirectly stata fireCOUNT 13 FAILURE TO MAINTAIN FIREBREAK, jon of Section 4292 of the Public Resource Code, a Misdemeanor. Defendant (9 PACIFIC GAS AND ELECTRIC COMPANY (PG&E), Cn or abut ite eh tayo Septic, 2020, 4h wilful an nll, wl owing, operating cr maintaining any cletialtrnsnsion ot dstribton Hine pon any moins Md, fest covered land brascovere lan, or grse-coveted lan, fio main a Brebreak of not less than 10 fect neath etn om the tr crumerence from any pole or over which Suppor switch, fs tasfomen lightning aes, line etono dead endo comer pole || cctemsined by the ageny mich has primary responsibility for fe poten of such ae, COUNT 14 FAILURE-TO MAINTAIN CLEARANCE, in violation of Section 4293 of the Public Resource Code, a Misdemeanor. Defendant (9) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), (On ot about the 27th day of September, 2020, did willfully and unlawfully, while owning, ‘opetating, ot maintaining any electrical transmission or distribution line upon any mountainous land, forestcovered lan, brish-covered land, or grass-covered lan, fil to maintain proper clearance between all vegetation and all conductors carrying electrical cuentas determined by the ‘agency which has primary responsibility fr fire protection of such area. cousris || UNLAWFUL FIRE ON PROPERTY OR ANOTHER, in violation of Section 4421 of the | Public Resource Code, « Misdemeanor. | Defendant(s) FACIEIC GAS AND ELECTRIC COMPANY (PG&E), Conor ous the Sh ayo Soper, 2006s wily snugly st reo case tobe et fre any fore bash, other famable materi on ny lnd a eonglog tthe defendant ‘ihe pemfsin ofthe owe, sez or gent of the owner or aes of the andCOUNT 16 NEGLIGENT CAUSING A FIRE BY DEVICE, in violation of Section 4435 of the Public Resouree Code, a Misdemeanor. | Detendan PACIFIC GAS AND ELECTRIC COMPANY (PG&E), | On or about the 27th day of September, 2020, did negligently cause a fte by operation of «device ‘which may kindle a fit, sad fire having escaped from the place where it originated. count 17 UTILITY FAILURE T0 COMPLY WITH REGULATIONS, in violation of Section 2110 of ‘the Publie Utility Code,a Misdemeanor. Defendant (3) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), (On or about the 27th day of September, 2020, a8 public wility who violated or failed to comply ‘with any par of any provision of the California Constitution or the Publie Utlities Code, to wit, section 451 of the Public Utilities Code, by unlawfully failing to furnish and maintain such ‘adequate, efficient, just, nd reasonable service, instrumentalties, equipment, and facilities, as are necessary to promote the safety, health, comfort and convenience ofits patrons, employees, and the public. UNE IS NEGLIGENT EMISSION OF AIR POLLUTION, in violation of Section 42400.1(a) of the Health and Safety Code, a Misdemeanor. Defendant (9 FACIFIC GAS AND ELECTRIC COMPANY (PG88), ‘mor abou the 27 day of Sepember, 2000, a nelgent ent contaminant wt, ste smoke and ltl pat attr nd as volton of Health and Salty Code Sections #1700 and 4170) Health and Salty Coe seton 41700 prohibits he diehage rom day source whotsooterof quis ofa continents rather material th case injury detimentmisnce, or tnoyancet any considerable rub of persons oro te pic or tht Snaner ie comfort pose, heh, o Safety of ny of those persone or he publi ot ease, ri utr teeny tease ny or darage to bins or proper Health and Safety Coseseuion 41701 ron its hedge no he mosphere fom oy soice whatsoever of any Sircentamiaany ot thn uncombined water apr, fora prod or petods aggreting mor than thre mints ary one nor whichis nck order in sha aha designated aN, 2 onthe ‘inglmann Choro used byte Und States Bure of Mine,count 19 NEGLIGENT EMISSION OF AIR POLLUTION, in violation of Section 42400.1(a) of the Health and Safety Code. a Misdemeanor. Defendant (9 PACIFIC GAS AND ELECTRIC COMPANY (PG&E), Cm or atti sh ayo Septem, 202 ch negligent eas contain, owt wie smoke and elated pares mater anda in vsti of Heath and Stey Code Sistine #1700 and 41701) Heath and Safety Cade seston 4700 probit the discharge om tay source whatsoever of quanites of aircon or other material at casey, Aetimerymisene, or aroyancs to any considerable unber of persons ot th pb, o that endanger the confor eps, heath, sf of any of hose persons rte public o tht ese, Grave ental endeny to aus, ijury or aage to batines or proper Heh and Say Code section 41701 pron te dschare i the snosphere om ny soars whatsoever of any Sircontamizant ote tha unconbined wate apr, ora pid oe periods agerepting more than thee minutes in any one hour whi sx ack o aker in shadeas hat designated as No.2 on he Ringelmann Chart as pulsed by the United States Buea of Mines. ‘couNT 20 NEGLIGENT EMISSION OF AIR POLLUTION, in violation of Section 42400.1(a) of the Health and Safety Code a Misdemeanor, Defeadan () PACIFIC GAS AND ELECTRIC COMPANY (PG&E), (nor abut the 2th day f September, 2020, ded aeglgealy eri an ae contaminant to wi, Slr sooke and late prelate ater and ab, in volton of Health and Safety Code Sctons 41700 and $1701. Health and Safety Code section 41700 peoibis the dssharge from ny source whatsoever of quanilies of ax conlainans or ote material that eause injury detent, nuisance, or encyance to any considerable mabe f persons oo the publi, or that tnianger the comfort, repose heath, or eet of any of those persons or the public, or hat use, Sr have amature tendency to cause, jury or damage to busines or property. Health and Safety {ode section 41701 prohibits the dacbarge into the atmonpee fom any source whatsoever of ny Sir contaminant, other tan uncombined water vapor, or petod or periods aggregating more han tc minutes in any one our wich sa dai or darker in shade as hat designated as No.2 on the | Ringeimann Char os plished by te United States Bureau of MinesCOUNT 21 || NEGLIGENT EMISSION OF AIR POLLUTION, in violation of Section 42400.1(a) of the Health and Safety Code, Misdemeanor. Defendant (3) 5 PACIFIC GAS AND ELECTRIC COMPANY (PG&E), (On or about the 30th day of September, 2020, did negligently emit an air contaminant, to wit, 6|| wildfire smoke and related particulate matter and ash, in violation of Health and Safety Code sections 41700 and 41701(a), Health and Safety Code section 41700 prohibits the discharge from ‘ay source whatsoever of quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons orto the public, or that endanger the comfort, repos, health, or safety of any of those persons or the public, or that cause, 9|| or have a natural tendency to cause, injury or damage to business or property. Health and Safety Code section 41701 prohibits the discharge into the atmosphere from any source whatsoever of any 10] aircontaminant, other thas uncombined water vapor, fora period or periods aggregating more than 1 thtee minutes in any one our which is sda ar darker in shade a8 hat designated as No, 2 onthe |] Ringelmann Chart, as published by the United States Bureau of Mines. COUNT 22 NEGLIGENT EMISSION OF AIR POLLUTION, in violation of Section 42400.1(a) of the 16| | Health and Safety Code,a Misdemeanor. 17| | Defendant(s) ‘PACIFIC GAS AND ELECTRIC COMPANY (PG&E), 18|| On orabout the Ist day af October, 2020, did negligently emit an air contaminant, to wit, wildfire smoke and related particulate matter ard ash, in violation of Health and Safety Code sections 41700 19]| and 41701(@), Health and Safety Code section 41700 prohibits the discharge from any source ‘whatsoever of quantities of air contaminants or other material that eause injury, detriment, nuisance, or annoyance to any considerable number of persons or tothe publi, or that endanger the comfor, repose, health, or safety of any of those persons or the public, or that cause, or have a natural tendeney to cause, injury or damage to business or property. Health and Safety Code section 41701 22 | prohibits the discharge into the atmosphere from any source whatsoever of any air contaminant, other than uncombined water vapor, fora period or periods aggregating more than three minutes in 23/| any one hour which is as dark or datker in shade as that designated as No. 2 on the Ringelmann Chart, as published by the United States Bureau of Mines.COUNT 23 RECKLESS EMISSION OF AIR POLLUTION, in violation of Section 42400.3(b) of the Health and Safety Code, a Misdemeanor. Defendant ( PACIFIC GAS AND ELECTRIC COMPANY (268), On orate 27h ay Sete 2000 theless ep rhe Hk of rat bly sry or da of ny pron dient contaminant, wilde ske and elated purclete mater nash nwlton Heal ad Salty Codeseaon 4170, that deat n Eh ueasonbl ik of pet bodily nury to, oF death of any peron. COUNT 24 RECKLESS EMISSION OF AIR POLLUTION, in violation of Section 42400.3(b) of the “Health and Safety Code a Misdemeanor. Defendant PACIFIC GAS AND ELECTRIC COMPANY (GSE), Cn orate Sh ayo Sepa, 202 eles septs forthe sk of great bodily injury fo, o death of any person iden at ir contarinant to wi, wlire smoke, nd related panels rate ndash invilton of Health and Safty Code scton 4170, that direst in En unreasonable ik of pet oly injury, death of, ny person. COUNT 25 RECKLESS EMISSION OF AIR POLLUTION, in violation of Section 42400.3(b) of the Health and Safety Code, a Misdemeanor. Defendant PACIFIC GAS AND ELECTRIC COMPANY (PSE), Cor about 5 day of September, 202, wth oeles dae fr the risk of ret bodily Injury t,o death of ny person dient ar contrat o Wi wre sok, and related | pul mater and asin vltion of Health nd Safety Code secon 41700, tat i resut in | En unresooable rit of peat body inry to, oF death of, any person.COUNT 26 RECKLESS EMISSION OF AIR POLLUTION, in violation of Section 42400.3(b) of the Health and Safety Code, a Misdemeanor. 2 3 4] Detendant (9) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), 5|] on oratour the 3h day 9 September, 2020, wih reckless dsregtd forthe rsk of great bodily 6 || iia to, or death of any person did emit an ir contaminant, to wit, wilde sok, and elated particulate mater and ash in violation of Health and Safety Code section 41700, that did result in |] anunteasonablersk of great bodily injury t, or death of, any person, 8 9 0 COUNT 27 of Section 42400.3(b) of the RECKLESS EMISSION OF AIR POLLUTION, in violati Health and Safety Code, a Misdemeanor. 11] Defendant PACIFIC GAS AND ELECTRIC COMPANY (PG&E), 12] On or about te Ist day of October, 2020, with reckless disregard for the vsk of great bodily injury to, or death of, ny persor, did emit an ae contaminant, to wit, wilde smoke, and related 13]| particulate mater and ash, in violation of Health and Safety Code section 41700, that did result in ln unreasonable risk of great bodily injury to, or death of, any person, 4 8 COUNT 28 16]| NEGLIGENT FIRE STARTING, in violation of Section 13001 of the Health and Safety Code, 17|| # Misdemeanor. 18] Defendant 9) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), ‘Onorabout the 19th day 2 October, 2020, did wilflly and unlawhll, through careless and | negligent action, throw ard place any lighted eigaret, cigar ashes, othe flaming or glowing 20|| substance, and any substance and thing which may caus a fie, in any place where it may dretly and indirectly tara fire. 2 couNT 29 23 || UTILITY FAILURE TO COMPLY WITH REGULATIONS, in violation of Section 2110 of the Publie Utility Code, a Misdemeanor. 95 || Defendant (9 PACIFIC GAS AND ELECTRIC COMPANY (PG&E), || One adoutibe 19th dy of October, 2020, a8 a publi ity who volted or fed to comply with || any part of any provision af the California Constitution or the Public Uses Code o wit, setion 27|| A5t of the Public Utilities Code, by unlawfully ailing to furnish and maintain such adequate, || ettciens, just, and resonable sevice, instramentalities, equipment, and facilities, as ae necessary 28 |] to promote the safety, heh, comfort and convenience ofits patrons, employees, and the publi. -0-