an amended complaint
COpy 1 2 3 4
5
JEFF W. REISIG DISTRICT ATTORNEY OF YOLO COUNTY By: Martha Holzapfel/228705 Deputy District Attorney 301 Second Street Woodland, California 95695 Telephone: (530) 666-8180 Entry No.: 190297 Attorney for People
6 7
8
SUPERIOR
9
COURT OF THE STATE OF CALIFORNIA COUNTY OF YOLO
10 11
FIRST AMENDED
12
15
COMPLAINT
Plaintiff,
13 14
Case No. 13-0305
Dept. 6
THE PEOPLE OF THE STATE OF CALIFORNIA,
vs. DAVID SCOTT SNYDER
16
Defendant (s)
17 18
I, the undersigned,
19
the County
20
Count
say, on information
and belief,
that in
of Yolo, State of California: 1 : On or about January
21
did commit a FELONY,
22
of the California
23 -
HAZARDOUS -WAS-TE,-in--that--DAVID-SCOTT SNYDER- did- knowingl-YGr- -----
24
recklessly
25
hazardous
26
danger
27 28
namely,
17, 2013, DAVID SCOTT SNYDER
Health
a violation
of Section 25189.6(b)
and Safety Code, RECKLESS
treat, handle,
transport,
dispose,
DISPOSAL
OF
or store a
waste in a manner which caused an another to imminent
of death or serious
injury.
Count 2 : On or about January did commit a FELONY,
namely,
17, 2013" DAVID SCOTT SNYDER
a violation
COMPLAINT
- 1
of Section 25189.6(b)
1
of the California
2
HAZARDOUS
3
recklessly
4
hazardous
5
danger of death or serious injury.
6
Count 3 : On or about January
treat, handle,
transport,
dispose,
OF
or
or store a
waste in a manner which caused an another to imminent
17, 2013, DAVID SCOTT SNYDER
did commit a FELONY, namely, a violation
8
of the California
9
HAZARDOUS
WASTE,
10
recklessly
11
hazardous
12
danger
of Section 25189.6(b)
Health and Safety Code, RECKLESS
DISPOSAL
in that DAVID SCOTT SNYDER did knowingly
treat, handle, transport,
dispose,
OF
or
or store a
waste in a manner which caused an another to imminent
of death or serious injury.
13
Count
14
did commit
15
of the California
16
HAZARDOUS
17
recklessly
18
hazardous
19
danger
4 : On or about January
17, 2013, DAVID SCOTT SNYDER
a FELONY, namely, a violation
WASTE,
of Section
Health and Safety Code, RECKLESS
25189.6(b) DISPOSAL
in that DAVID SCOTT SNYDER did knowingly
treat, handle,
transport,
dispose,
OF
or
or store a
waste in a manner which caused an another
to imminent
of death or serious injury.
Count
5 : On or about January
17, 2013, DAVID SCOTT SNYDER
21
did commit a FELONY, namely, a violation
22
the California
23
DISPOSAL
in that DAVID SCOTT SNYDER did knowingly
7
20
-
WASTE,
Health and Safety Code, RECKLESS
Penal Code, POSSESSION
of Section
18715(a) of
OF DESTRUCTIVE
DEVICE OR
--EXPLOSIVE,-i-n-that--BAV-ID-SeOTT SNY-DE-R-cli-d-willf-u-:1:1-Yj unlawfully,
24
and recklessly
25
on a public
26
school,
college,
27
private
habitation,
28
passenger
possess
any destructive
street and highway,
device and any explosive
in and near any theater,
church, hotel, other public building, in, on, and near any aircraft,
- 2
and
railway
train, car, cable road and cable car, vessel
COMPLAINT
hall,
engaged
1
in carrying
2
ordinarily
3
passengers
for hire, and other public place
passed by human beings.
Count 6 : On or about January 17, 2013, DAVID SCOTT SNYDER
4
did commit a FELONY, namely,
5
the California
6
EXPLOSIVE,
7
and recklessly
8
on a public
9
school,
college,
10
private
habitation,
11
passenger
12
in carrying
13
ordinarily
14
Penal Code, POSSESSION
of Section 18715(a)
OF DESTRUCTIVE
in that DAVID SCOTT SNYDER did willfully, possess
any destructive
street and highway,
train,
church,
of
DEVICE OR unlawfully,
device and any explosive
in and near any theater,
hotel, other public building,
in, on, and near any aircraft,
hall,
and
railway
car, cable road and cable car, vessel engaged
passengers
for hire, and other public place
passed by human beings.
Count 7 : On or about January 17, 2013, DAVID SCOTT SNYDER
15
did commit a FELONY, namely,
16
California
17
MAKE DESTRUCTIVE
18
willfully
19
any combination
20
make any destructive
21
obtaining
22
explosive.
-23
a violation
Penal Code,
a violation
POSSESSION
DEVICE,
and unlawfully
OF MATERIALS
WITH INTENT TO
in that DAVID SCOTT SNYDER did possess
of substances
a permit
of Section 18720 of the
any substance,
and materials,
Count 8 : Onorabout-cJanuary
24
did commit a FELONY, namely,
25
California
26
MAKE DESTRUCTIVE
27
willfully
28
any combination
DEVICE,
and unlawfully
without
first
device and
17,--28l-3,--DAVIDSCOTT SNYDE-R-
a violation
Penal Code, POSSESSION
and
with the intent to
device and any explosive,
to make such destructive
material,
of Section 18720 of the
OF MATERIALS
WITH INTENT TO
in that DAVID SCOTT SNYDER did possess any substance,
of substances
and materials,
COt-'IPLAINT
-
3
material,
and
with the intent to
1
make any destructive
2
obtaining
3
explosive.
a permit
device and any explosive,
to make such destructive
Count 9 : On or about January
4 5
did commit
a FELONY, namely,
6
California
Penal Code, POSSESSION
7
MAKE DESTRUCTIVE
8
willfully
9
any combination
DEVICE,
and unlawfully
make any destructive
11
obtaining
12
explosive.
a permit
possess
to make such destructive
a FELONY, namely,
15
California
Penal Code, POSSESSION
16
MAKE DESTRUCTIVE
17
willfully
18
any combination
19
make any destructive
20
obtaining
21
explosive.
and unlawfully
without
first
device and
of Section
OF MATERIALS
18720 of the
WITH INTENT TO
in that DAVID SCOTT SNYDER did possess
any substance,
and materials,
to make such destructive
material,
without
first
device and
17, 2013, DAVID SCOTT SNYDER
-commit a--FELONY-,-name-l-y,av-i-ol-ai:ci-GH-oE-Se-G-t.i-on 626.9
the California
25
GROUNDS
Penal Code, POSSESSING
26
willfully
27
grounds
of a campus
28
student
housing,
OF UNIVERSITY
OR COLLEGE,
and unlawfully
OR BRINGING
of, or buildings research,
COMPLAINT
(i)
of
FIREARM ON
in that DAVID SCOTT SNYDER did
bring or possess
teaching,
and
with the intent to
device and any explosive,
Count 11 : On or about January
24
and
17, 2013, DAVID SCOTT SNYDER
a violation
of substances
a permit
material,
with the intent to
device and any explosive,
DEVICE,
18720 of the
WITH INTENT TO
any substance,
and materials,
did commit
--z3di-d
of Section
in that DAVID SCOTT SNYDER did
14
22
device and
OF MATERIALS
Count 10 : On or about January
13
first
17, 2013, DAVID SCOTT SNYDER
a violation
of substances
10
without
a firearm upon the
owned or operated and administration
- 4
for by, a
1
public
2
are clearly marked
3
permission
4
designee,
5
or private
university
or college,
university
of the university or equivalent
property,
university
6
did commit a FELONY, namely,
7
the California
8
GROUNDS
the written
9
willfully
his or her
17, 2013, DAVID SCOTT SNYDER
a violation
OR COLLEGE,
of Section 626.9(i) of
OR BRINGING
FIREARM ON
in that DAVID SCOTT SNYDER did
bring or possess
a firearm upon the
10
grounds
of a campus of, or buildings
owned or operated
11
student
housing,
and administration
12
public
13
are clearly marked
14
permission
15
designee,
16
teaching,
or private
research,
university
or college,
university
of the university or equivalent
property,
university
or college authority. 17, 2013, DAVID SCOTT SNYDER
18
the California
19
GROUNDS
20
willfully
21
grounds
of a campus of, or buildings
owned or operated
22
student
housing,
and administration
23
publicoT
24
are clearly marked
25
permission
26
designee,
27
28
a violation
Penal Code, POSSESSING
OR BRINGING
university
of the university
FIREARM ON
a firearm upon the for by, a
-co-lIege, --that-are-contigBous- or- property,
without
the written
or college president,
university
Count 14 : On or about January did commit a FELONY, namely,
626.9(i) of
in that DAVID SCOTT SNYDER did
research,
pri vate-uni versi tyor
or equivalent
of Section
bring or possess
teaching,
or
his or her
did commit a FELONY, namely,
and unlawfully
by, a
without the written
17
OR COLLEGE,
for
that are contiguous
or college president,
Count 13 : On or about January
OF UNIVERSITY
or
or college authority.
Penal Code, POSSESSING
and unlawfully
without
or college president,
Count 12 : On or about January
OF UNIVERSITY
that are contiguous
or college authority. 17, 2013, DAVID SCOTT SNYDER
a violation
COMPLAINT
his or her
- 5
of Section
626.9(i) of
1
the California
2
GROUNDS
3
willfully
4
grounds of a campus of, or buildings
owned or operated
5
student housing,
and administration
6
public or private
7
are clearly marked
8
permission
9
designee,
10
Penal Code, POSSESSING
OF UNIVERSITY
OR COLLEGE,
and unlawfully
research,
university
or college,
university
of the university
FIREARM ON
in that DAVID SCOTT SNYDER did
bring or possess
teaching,
or equivalent
OR BRINGING
property,
a firearm upon the
without the written his or her
17, 2013, DAVID SCOTT SNYDER
11
did commit a FELONY, namely,
12
the California
13
GROUNDS
14
willfully
15
grounds
of a campus of, or buildings
owned or operated
16
student
housing,
and administration
17
public
18
are clearly marked
19
permission
20
designee,
21
a violation
Penal Code, POSSESSING OR COLLEGE,
and unlawfully
or private
OR BRINGING
or college,
university
of the university
626.9(i) of
FIREARM ON
in that DAVID SCOTT SNYDER did
research,
university
or equivalent
of Section
bring or possess
teaching,
property,
a firearm upon the
university
for by, a
that are contiguous without
his or her
or college authority. 17, 2013, DAVID SCOTT SNYDER
22
did commit a FELONY, namely,
a violation
23-
the California
of Section
626.9(i) of
24
GROUNDS
25
willfully
26
grounds
of a campus of, or buildings
owned or operated
27
student
housing,
and administration
28
public
~Pen~al--e-ode, ~-POSSES-S-ING-ORBRINGING-FIREARMGNOR COLLEGE,
and unlawfully
or private
research,
university
or college,
COMPLAINT
-- ---- -
in that DAVID SCOTT SNYDER did
bring or possess
teaching,
or
the written
or college president,
Count 16 : On or about January
OF UNIVERSITY
or
or college authority.
Count 15 : On or about January
OF UNIVERSITY
by, a
that are contiguous
or college president,
university
for
- 6
a firearm upon the for by, a
that are contiguous
or
1
are clearly marked
2
permission
3
designee,
university
of the university or equivalent
property,
university
or college
his or her
authority.
17, 2013, DAVID SCOTT SNYDER
5
did commit a FELONY, namely,
6
the California
7
GROUNDS
8
willfully
9
grounds
of a campus of, or buildings
owned or operated
10
student
housing,
and administration
11
public
12
are clearly marked
13
permission
14
designee,
16
a violation
Penal Code, POSSESSING
OF UNIVERSITY
OR COLLEGE,
and unlawfully
OR BRINGING
or college,
university
of the university
property,
under penalty
of perjury
for by, a
that are contiguous without
or college
Executed
on February
the written his or her
authority.
that the foregoing
7, 2013, at Woodland,
18 19 20 21 22 :2-3 --
FIREARM ON
correct.
17
--
-
------
24 25 26 27 28
COMPLAINT
of
a firearm upon the
or college president,
university
626.9(i)
in that DAVID SCOTT SNYDER did
research,
university
or equivalent
of Section
bring or possess
teaching,
or private
I declare
15
--
the written
or college president,
Count 17 : On or about January
4
without
- 7
California.
is
or
5
JEFF W. REISIG DISTRICT ATTORNEY OF YOLO COUNTY By: Martha Holzapfel/228705 Deputy District Attorney 301 Second Street Woodland, California 95695 Telephone: (530) 666-8180 Entry No.: 190297 Attorney for People
6 7
8
SUPERIOR
9
COURT OF THE STATE OF CALIFORNIA COUNTY OF YOLO
10 11
FIRST AMENDED
12
15
COMPLAINT
Plaintiff,
13 14
Case No. 13-0305
Dept. 6
THE PEOPLE OF THE STATE OF CALIFORNIA,
vs. DAVID SCOTT SNYDER
16
Defendant (s)
17 18
I, the undersigned,
19
the County
20
Count
say, on information
and belief,
that in
of Yolo, State of California: 1 : On or about January
21
did commit a FELONY,
22
of the California
23 -
HAZARDOUS -WAS-TE,-in--that--DAVID-SCOTT SNYDER- did- knowingl-YGr- -----
24
recklessly
25
hazardous
26
danger
27 28
namely,
17, 2013, DAVID SCOTT SNYDER
Health
a violation
of Section 25189.6(b)
and Safety Code, RECKLESS
treat, handle,
transport,
dispose,
DISPOSAL
OF
or store a
waste in a manner which caused an another to imminent
of death or serious
injury.
Count 2 : On or about January did commit a FELONY,
namely,
17, 2013" DAVID SCOTT SNYDER
a violation
COMPLAINT
- 1
of Section 25189.6(b)
1
of the California
2
HAZARDOUS
3
recklessly
4
hazardous
5
danger of death or serious injury.
6
Count 3 : On or about January
treat, handle,
transport,
dispose,
OF
or
or store a
waste in a manner which caused an another to imminent
17, 2013, DAVID SCOTT SNYDER
did commit a FELONY, namely, a violation
8
of the California
9
HAZARDOUS
WASTE,
10
recklessly
11
hazardous
12
danger
of Section 25189.6(b)
Health and Safety Code, RECKLESS
DISPOSAL
in that DAVID SCOTT SNYDER did knowingly
treat, handle, transport,
dispose,
OF
or
or store a
waste in a manner which caused an another to imminent
of death or serious injury.
13
Count
14
did commit
15
of the California
16
HAZARDOUS
17
recklessly
18
hazardous
19
danger
4 : On or about January
17, 2013, DAVID SCOTT SNYDER
a FELONY, namely, a violation
WASTE,
of Section
Health and Safety Code, RECKLESS
25189.6(b) DISPOSAL
in that DAVID SCOTT SNYDER did knowingly
treat, handle,
transport,
dispose,
OF
or
or store a
waste in a manner which caused an another
to imminent
of death or serious injury.
Count
5 : On or about January
17, 2013, DAVID SCOTT SNYDER
21
did commit a FELONY, namely, a violation
22
the California
23
DISPOSAL
in that DAVID SCOTT SNYDER did knowingly
7
20
-
WASTE,
Health and Safety Code, RECKLESS
Penal Code, POSSESSION
of Section
18715(a) of
OF DESTRUCTIVE
DEVICE OR
--EXPLOSIVE,-i-n-that--BAV-ID-SeOTT SNY-DE-R-cli-d-willf-u-:1:1-Yj unlawfully,
24
and recklessly
25
on a public
26
school,
college,
27
private
habitation,
28
passenger
possess
any destructive
street and highway,
device and any explosive
in and near any theater,
church, hotel, other public building, in, on, and near any aircraft,
- 2
and
railway
train, car, cable road and cable car, vessel
COMPLAINT
hall,
engaged
1
in carrying
2
ordinarily
3
passengers
for hire, and other public place
passed by human beings.
Count 6 : On or about January 17, 2013, DAVID SCOTT SNYDER
4
did commit a FELONY, namely,
5
the California
6
EXPLOSIVE,
7
and recklessly
8
on a public
9
school,
college,
10
private
habitation,
11
passenger
12
in carrying
13
ordinarily
14
Penal Code, POSSESSION
of Section 18715(a)
OF DESTRUCTIVE
in that DAVID SCOTT SNYDER did willfully, possess
any destructive
street and highway,
train,
church,
of
DEVICE OR unlawfully,
device and any explosive
in and near any theater,
hotel, other public building,
in, on, and near any aircraft,
hall,
and
railway
car, cable road and cable car, vessel engaged
passengers
for hire, and other public place
passed by human beings.
Count 7 : On or about January 17, 2013, DAVID SCOTT SNYDER
15
did commit a FELONY, namely,
16
California
17
MAKE DESTRUCTIVE
18
willfully
19
any combination
20
make any destructive
21
obtaining
22
explosive.
-23
a violation
Penal Code,
a violation
POSSESSION
DEVICE,
and unlawfully
OF MATERIALS
WITH INTENT TO
in that DAVID SCOTT SNYDER did possess
of substances
a permit
of Section 18720 of the
any substance,
and materials,
Count 8 : Onorabout-cJanuary
24
did commit a FELONY, namely,
25
California
26
MAKE DESTRUCTIVE
27
willfully
28
any combination
DEVICE,
and unlawfully
without
first
device and
17,--28l-3,--DAVIDSCOTT SNYDE-R-
a violation
Penal Code, POSSESSION
and
with the intent to
device and any explosive,
to make such destructive
material,
of Section 18720 of the
OF MATERIALS
WITH INTENT TO
in that DAVID SCOTT SNYDER did possess any substance,
of substances
and materials,
COt-'IPLAINT
-
3
material,
and
with the intent to
1
make any destructive
2
obtaining
3
explosive.
a permit
device and any explosive,
to make such destructive
Count 9 : On or about January
4 5
did commit
a FELONY, namely,
6
California
Penal Code, POSSESSION
7
MAKE DESTRUCTIVE
8
willfully
9
any combination
DEVICE,
and unlawfully
make any destructive
11
obtaining
12
explosive.
a permit
possess
to make such destructive
a FELONY, namely,
15
California
Penal Code, POSSESSION
16
MAKE DESTRUCTIVE
17
willfully
18
any combination
19
make any destructive
20
obtaining
21
explosive.
and unlawfully
without
first
device and
of Section
OF MATERIALS
18720 of the
WITH INTENT TO
in that DAVID SCOTT SNYDER did possess
any substance,
and materials,
to make such destructive
material,
without
first
device and
17, 2013, DAVID SCOTT SNYDER
-commit a--FELONY-,-name-l-y,av-i-ol-ai:ci-GH-oE-Se-G-t.i-on 626.9
the California
25
GROUNDS
Penal Code, POSSESSING
26
willfully
27
grounds
of a campus
28
student
housing,
OF UNIVERSITY
OR COLLEGE,
and unlawfully
OR BRINGING
of, or buildings research,
COMPLAINT
(i)
of
FIREARM ON
in that DAVID SCOTT SNYDER did
bring or possess
teaching,
and
with the intent to
device and any explosive,
Count 11 : On or about January
24
and
17, 2013, DAVID SCOTT SNYDER
a violation
of substances
a permit
material,
with the intent to
device and any explosive,
DEVICE,
18720 of the
WITH INTENT TO
any substance,
and materials,
did commit
--z3di-d
of Section
in that DAVID SCOTT SNYDER did
14
22
device and
OF MATERIALS
Count 10 : On or about January
13
first
17, 2013, DAVID SCOTT SNYDER
a violation
of substances
10
without
a firearm upon the
owned or operated and administration
- 4
for by, a
1
public
2
are clearly marked
3
permission
4
designee,
5
or private
university
or college,
university
of the university or equivalent
property,
university
6
did commit a FELONY, namely,
7
the California
8
GROUNDS
the written
9
willfully
his or her
17, 2013, DAVID SCOTT SNYDER
a violation
OR COLLEGE,
of Section 626.9(i) of
OR BRINGING
FIREARM ON
in that DAVID SCOTT SNYDER did
bring or possess
a firearm upon the
10
grounds
of a campus of, or buildings
owned or operated
11
student
housing,
and administration
12
public
13
are clearly marked
14
permission
15
designee,
16
teaching,
or private
research,
university
or college,
university
of the university or equivalent
property,
university
or college authority. 17, 2013, DAVID SCOTT SNYDER
18
the California
19
GROUNDS
20
willfully
21
grounds
of a campus of, or buildings
owned or operated
22
student
housing,
and administration
23
publicoT
24
are clearly marked
25
permission
26
designee,
27
28
a violation
Penal Code, POSSESSING
OR BRINGING
university
of the university
FIREARM ON
a firearm upon the for by, a
-co-lIege, --that-are-contigBous- or- property,
without
the written
or college president,
university
Count 14 : On or about January did commit a FELONY, namely,
626.9(i) of
in that DAVID SCOTT SNYDER did
research,
pri vate-uni versi tyor
or equivalent
of Section
bring or possess
teaching,
or
his or her
did commit a FELONY, namely,
and unlawfully
by, a
without the written
17
OR COLLEGE,
for
that are contiguous
or college president,
Count 13 : On or about January
OF UNIVERSITY
or
or college authority.
Penal Code, POSSESSING
and unlawfully
without
or college president,
Count 12 : On or about January
OF UNIVERSITY
that are contiguous
or college authority. 17, 2013, DAVID SCOTT SNYDER
a violation
COMPLAINT
his or her
- 5
of Section
626.9(i) of
1
the California
2
GROUNDS
3
willfully
4
grounds of a campus of, or buildings
owned or operated
5
student housing,
and administration
6
public or private
7
are clearly marked
8
permission
9
designee,
10
Penal Code, POSSESSING
OF UNIVERSITY
OR COLLEGE,
and unlawfully
research,
university
or college,
university
of the university
FIREARM ON
in that DAVID SCOTT SNYDER did
bring or possess
teaching,
or equivalent
OR BRINGING
property,
a firearm upon the
without the written his or her
17, 2013, DAVID SCOTT SNYDER
11
did commit a FELONY, namely,
12
the California
13
GROUNDS
14
willfully
15
grounds
of a campus of, or buildings
owned or operated
16
student
housing,
and administration
17
public
18
are clearly marked
19
permission
20
designee,
21
a violation
Penal Code, POSSESSING OR COLLEGE,
and unlawfully
or private
OR BRINGING
or college,
university
of the university
626.9(i) of
FIREARM ON
in that DAVID SCOTT SNYDER did
research,
university
or equivalent
of Section
bring or possess
teaching,
property,
a firearm upon the
university
for by, a
that are contiguous without
his or her
or college authority. 17, 2013, DAVID SCOTT SNYDER
22
did commit a FELONY, namely,
a violation
23-
the California
of Section
626.9(i) of
24
GROUNDS
25
willfully
26
grounds
of a campus of, or buildings
owned or operated
27
student
housing,
and administration
28
public
~Pen~al--e-ode, ~-POSSES-S-ING-ORBRINGING-FIREARMGNOR COLLEGE,
and unlawfully
or private
research,
university
or college,
COMPLAINT
-- ---- -
in that DAVID SCOTT SNYDER did
bring or possess
teaching,
or
the written
or college president,
Count 16 : On or about January
OF UNIVERSITY
or
or college authority.
Count 15 : On or about January
OF UNIVERSITY
by, a
that are contiguous
or college president,
university
for
- 6
a firearm upon the for by, a
that are contiguous
or
1
are clearly marked
2
permission
3
designee,
university
of the university or equivalent
property,
university
or college
his or her
authority.
17, 2013, DAVID SCOTT SNYDER
5
did commit a FELONY, namely,
6
the California
7
GROUNDS
8
willfully
9
grounds
of a campus of, or buildings
owned or operated
10
student
housing,
and administration
11
public
12
are clearly marked
13
permission
14
designee,
16
a violation
Penal Code, POSSESSING
OF UNIVERSITY
OR COLLEGE,
and unlawfully
OR BRINGING
or college,
university
of the university
property,
under penalty
of perjury
for by, a
that are contiguous without
or college
Executed
on February
the written his or her
authority.
that the foregoing
7, 2013, at Woodland,
18 19 20 21 22 :2-3 --
FIREARM ON
correct.
17
--
-
------
24 25 26 27 28
COMPLAINT
of
a firearm upon the
or college president,
university
626.9(i)
in that DAVID SCOTT SNYDER did
research,
university
or equivalent
of Section
bring or possess
teaching,
or private
I declare
15
--
the written
or college president,
Count 17 : On or about January
4
without
- 7
California.
is
or
