THE ~ _A)ERIOR COURT, STATE OF CALIFlJtZNIA For the County of Santa Barbara Figueroa Division. Plaintiff, COUNT

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1 THE PEOPLE OF THE STATE OF CALIFORNIA THE ~ _A)ERIOR COURT, STATE OF CALIFlJtZNIA For the County of Santa Barbara Figueroa Division vs. Plaintiff, GILBERT ARMJJO DOB: 12/26/] 950 Defendant. DA No Court No. I Fl. 'r5e b3~0 D SUPe-RiG, " :rn!f r"!,-o 'i~!ia MISDEMEf\:NOR COMPLAINT JMI nD The undersigned is informed and believes that: COUNT <'~:\f' 6y '.L 8L-\i1 ~ 1_ oj. Or 1\,t 2SrY\, Eft)"'r--S< On or about December 22, 2007, in the County of Santa Barbara, the crime of DRIVING UNDER THE INFLUENCE OF ALCOHOL, in violation of VEHICLE CODE SECTION 23152(a), a Misdemeanor, was committed by GILBERT ARMJJO, who did willfully and unlawfully drive a motor vehicle while under the influence of an alcoholic beverage. "NOTICE: If convicted of this offense the court must suspend your driving privileges if you are under the age of21 years. Vehicle Code Section " COUNT 2 On or about December 22, 2007, in the County of Santa Barbara, the crime of DRIVING WHILE HA VING A 0.08% OR HIGHER BLOOD ALCOHOL, in violation of VEHICLE CODE SECTION 23152(b), a Misdemeanor, was committed by GILBERT ARMJJO, who did unlawfully, while having a 0.08% and more, by weight, of alcohol in hislher blood, drive a vehicle. It is further alleged that the defendant had a blood alcohol content of 0.15% and higher within the meaning of Vehicle Code Section "NOTICE: If convicted of this offense the court must suspend your driving privileges if you are under the age of21 years. Vehicle Code Section " "NOTICE: Pursuant to CVC Section you are notified that the District Attorney will request impoundment of your vehicle, at your expense, in the event of a conviction of this offense." * * * * * * * *

$Or 1\,t 2SrY\, Eft)"'r--S< On or about December 22, 2007, in the County of Santa Barbara, the crime of DRIVING UNDER THE INFLUENCE OF ALCOHOL, in violation of VEHICLE CODE SECTION 23152(a), a$

2 Pursuant to Penal Code Section I 054.5(b), the People are hereby infomlally requesting that defense counsel provide discovery to the People as required by Penal Code Section I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT ANI THAT THIS COMPLAINT CONSISTS OF 2 COUNT(S). Executed at Santa Barbara, Califomia, on January 3, c?k47'd- ~ JAMES J. KREYGER SR. DEPUTY DISTRICT ATTORNEY

as required by Penal Code Section 1054.3.

3 William L. Redell SB# Michael B. Clayton & Associates 2 II 400 East Orange Street Santa Maria, California II Telephone: Facsimile: II Attorney for Defendant: Gilbert Armijo SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA BARBARA THE PEOPLE OF THE STATE OF CALIFORNIA, Plaintiff, vs. Case No.: Motion to Recuse Santa Barbara District Attorney County GILBERT ARMIJO, DOB: 12/26/1950 Defendant. 4/II/Or 7/t'~ II TO: CHRISTIE STANLEY, DISTRICT ATTORNEY OF SANTA BARBARA 21 COUNTY, SANTA BARBARA, CALIFORNIA, AND TO THE CLERK OF 22 THE COURT: Defendant, GILBERT ARMIJO, formally requests the Santa Barbara County District 25 Attorneys Office to recuse itself or seek a determination ftom the Attorney General 26 whether a conflict of interest is present because of Mr. Armijo's senior level executive 27 job classification with the County. Said motion is based on the file and records in this 28 action, and any evidence, oral or documentary, which may be presented at the hearing on -I

5221 4 5 II Attorney for Defendant: Gilbert Armijo 6 7 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA BARBARA 10 11 12 13 14 THE PEOPLE OF THE STATE OF CALIFORNIA, Plaintiff, vs.

4 this motion. 2 3 II Dated: February 17, Respectfully submitted, t: /l ~.~ Attorney for GILBERT ARMIJO ]

Respectfully submitted, 5 6 7 8 t: /l ~.

5 F f L E DECLARATION OF GILBERT ARMIJO SUPERIOR COURT of CALIFORNIA COUNTY OF SANTA BARBARA 10II Q / GARY M. 8~~.EXEC. 0 FICER I, Gilbert Anl1ijo, do say and declare as follows: BY--pavid~GI~een'De utyci Entered Intu sustain by _ erk I. 1 am employed as an Executive Assistant with the County of Santa Barbara with Department Head Level Classification. 2. I was notified in February 2007, that Sheriff Brown was using overtime pay t reward deputies within the department who had supported him during his campaign. 3. The estimated amount is $4.6 million by June of 2008, which is nearly 2.5 time more than any sheriff's administration has ever spent on such pay. 4. I have been outspoken with regard to the overtime payment and belief that I wa targeted unfairly with regard to the case in question. 5. I base this assumption on the fact that the tow truck company was called prior t any contact with me. 6. The first deputy sheriff told me I would be arrested for drunk driving prior t conducting any tests. 7. Knowing there might be a conflict of interest, I requested a CHP Office immediately and they did not call for one because he said it did not matter as I would be arreste for drunk driving anyway. 8. It should be noted that there were four deputy sheriffs on scene with two of the having their weapons drawn. 9. Finally, it should be noted that I never drove the vehicle and have never bee arrested for anything in my 42 years of driving experience. 10. Please feel free to contact me with questions or requests for additiona infonnation. I declare under penalty of perjury that the foregoing is true and correct, to the best of m knowledge. Dated this 18thday of February / -1- Declaration of Gilbert Am1ijo

1 am employed as an Executive Assistant with the County of Santa Barbara with Department Head Level Classification. 2.

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN DIEGO NORTH COUNTY DIVISION

SUPERIOR COURT OF CALIFORNIA, Y OF SAN DIEGO NORTH Y DIVISION THE PEOPLE OF THE STATE OF CALIFORNIA, Plaintiff, v. RAMIL ABALKHAD, dob 08/23/63; NELLIE CHA NOLAND, dob 06/27/80; CT No. CN341467 DA No.