JEFFREY S. ROSELL, DISTRICT ATTORNEY 



- I 

STATE EAR NUMBER: 138433 I UEEFREQAAEHT
COUNTY OF SANTA CRUZ 1A: g;
701 OCEAN STREET, ROOM 200 

SANTA CRUZ, CALIFORNIA 95060
TELEPHONE: (831) 454*2400

FOR THE PEOPLE

SUPERIOR COURT OF CALIFORNIA

COUNTY OF SANTA CRUZ

Case  

THE PEOPLE OF THE STATE OF CALIFORNIA,

 

 

 

 

 

Plaintiff, DIRECT FILE OF JUVENILE
COMPLAINT CRIMINAL
uvs?
Date:' 7/30/2015
ADRIAN JERRY GONZALEZ, . 
I Time: 8:15 am
DOB: 10/20/1999 Dept:
Defendant(s). Event:

 

ARRC.

JEFFREY S. ROSELL, District Attorney of the County of Santa

Cruz, State Of California,

accuses ADRIAN JERRY GONZALEZ of the
following crime(s) committed in the County of Santa Cruz, State of
California: I
COUNT-1

On or about 07/26/2015, in the above named Judicial District,
the crime of MURDER, in violation of PENAL CODE SECTION 187(a), a
Felony, was personally committed by ADRIAN JERRY GONZALEZ, who did

unlawfully, and with malice aforethought personally kill and murder

Madyson Jordan Middleton, a human being.~





 

SPEC BY WAIT

It is further alleged that the murder of' Madyson Jordan
Middleton was committed by the Defendant and that the Defendant
intentionally and personally killed the victim while lying in wait,

within the meaning of Penal Code Section 

SPEC ALLEG-FELONY MURDER-

It is further alleged that the murder cf Madyson Jordan
Middleton was personally committed by the Defendant while the said
Defendant was engaged in the commission and attempted commission of
the crimes of kidnapping {in violation of Penal Code section 207 and
209), forcible rape-(in violation of Penal Code section 261), lewd
or lascivious act upon a child under the age of 14 (in violation of
Penal Code section 288(a)), and rape by instrument (in violation of

Seetion 289), within the meaning of Penal Code section 

COUNT 2

'On or about 07/26/2015, in the above named Judicial District,
the crime of KIDNAPPING TO COMMIT ANOTHER CRIME, in violation-of
PENAL CODE SECTION 209(b)(1), a Felony, was personally committed by
ADRIAN JERRY GONZALEZ, who did unlawfully kidnap and carry away

Madyson Jordan Middleton_to commit rape'and violations of Penal Code

sections 288 and 289.

SPECIAL ALLEGATION-GREAT BODILY INJURY

It is further alleged as to Count 2 that in the commission of

the above offense the

said Defendant ADRIAN JERRY GONZALEZ,

persOnally inflicted great bodily injury upon Madyson Jordan

2

 

abme



'17Middleton, not an accomplice to Ithe above offense, within the

meaning of Penal Code Section 12022.7(a) and also causing the above
offense to become a serious felony within the meaning of Penal Code

Section 

COUNT 3

On or about July 26,

2015, in the above named JudiCial
District, the crime of SEXUAL PENETRATION BY FOREIGN OBJECT-VICTIM
in violation-of PENAL CODE SECTION a Felony,
was personally committed by ADRIAN JERRY GONZALEZ, who committed an
act of senual penetration. against the will of Madyson. Jordan
Middleton, who was under the age of 14 years, by means of_force,

violence, duress, menace and fear of immediate and unlawful bodily

injury on Madyson Jordan Middleton and another person.

COUNT 4

On or 'about July '26, 2015, in the above named Judicial
District, the crime of FORCIBLE LEWD ACT UPON CHILD, in violation of
PENAL CODE SECTION a Felony, was personally committed by.
ADRIAN JERRY GONZALEZ, who did willfully, unlawfully, and lewdly
commit a lewd and lascivious act upon and with the body and certain
parts and_members thereof of Madyson Jordan Middleton, a child under
the age of fourteen years, with the intent of arousing, appealing
to, and gratifying the lust, I

passions, and sexual desires of the

said Defendant anmi the said child, by lh?i of force, violence,

duress, menace, and threat of great bodily harm.,




 



COUNT 5

On or about July 26, 2015, in the above named Judicial
District, the crime Of FORCIBLE UNDER 14 YEARS, in
violation of PENAL CODE SECTION a Felony, was personally
committed by ADRIAN JERRY GONZALEZ, who did unlawfully have and
accomplish gul act of sexual intercourse with a person, to wit,
Madyson. Jordan_imiddleton, not fhis spouse, against. saiCi person?s
Will, by ineans of force, violence, 'duress, menace and Ifear Of
immediate and unlawful bedily injury on said person-and another.
It is further alleged that the victim was a child, under 14

years of age.



on or about July 26, '2015, in the above named Judicial

District, the crime of FORCIBLE ACT UPON CHILD, in violation of
PENAL CODE a Felony, was perSOnally committed by
ADRIAN JERRY GONZALEZ, who did willfully, unlawfully, and lewdly
commit a lewd and lascivious act upon and with the body and certain
parts-and members thereof of Madyson Jordan Middleton, a child under
the age of fourteen-years, with the-intent of arousing, appealing
to, and gratifying the lust, I

passions, and sexual desires of the

said. Defendant and time sale! child, t5! use cu? forCe, ?violence,

'duress, menace, and threat of great bodily harm.

SPEC SEX CRIMES

It is further alleged, as to Counts 3, 4, 5 and 6, within the

meaning of Penal Code sections and 

4

 

 

.22
-23'

24
25
26
27
28

 

 

that the following circumstances apply: the Defendant kidnapped the
victim (in violation of Penal Code sections 207 and 209) and the
movement of the victim substantially increased the risk of harm over

and above that level of risk necessarily inherent in the underlying

offense.

SPECIAL ALLEGATION SEX 
AGGRAVATED CIRCUMSTANCES GBI
It is further alleged, as to Counts 3, 4, 5, and a, that said
Defendant, ADRIAN JERRY.GONZALEZ, personally inflicted great bodily
injury on the victim in the commission of the above offense in
violation of Penal Code section l2022.53 or 12022.7 or l2022.8,
within the meaning of Penal Code section 667.6l(a) and 
SPEC ALLEG- SEX CRIMES-
AGGRAVATED CIRCUMSTANCES
It is further alleged, as to Counts 3, 4, 5, and 6, within the
meaning of Penal Code sections. 667.6l(a) and that the

following circumstances apply: the Defendant personally inflicted

bodily harm.on the victim who was under 14 years of age.

SPECIAL ALLEGAEION SEX CRIMES
AGGRAVATED CIRCUMSTANCES - USE OF DEADLY WEAPON
It is further alleged, as to Counts that

said Defendant, ADRIAN JERRY GONZALEZ, personally used a dangerous

_or deadly weapon in the commission of the above offense in violation

of Penal.Code section 12022 or 12022.3, within the meaning of Penal

Code section and 

 





LUMP

 

 

SPEC SEX CRIMES

AGGRAVATED CIRCUMSTANCES
It is further alleged, as to Counts 3, 4, 5, and 6, within the
meaning of Penal Cede sections and that the

following circumstances apply: the Defendant engaged in tying_or

Ibinding of the victim in the commission of the present offense.

SPEC SEX CRIMES
AGGRAVATING CIRCUMSTANCES

It is further alleged, as to Counts 3, 4, 5,.and 6, within the
meaning of Penal Code sections and
that the victim-in the above offense was a Child under 14
years (IE age and following circumstanCes apply: the
Defendant kidnapped the victim (in violation of Penal Code sections
207 and 209); the Defendant personally used a dangerous or deadly
weapon in the commission_of the above offense in violation of Penal

Code section 12022 or 12022.3; the Defendant engaged in tying or

binding of the victim in the commission of the present offense.

MURDER AGE 14 0a OLDER KILLED
I SPEC CIRCUMSTANCE
It is further alleged, pursuant to subdivision of Welfare
and Institutions Code section 602, that the Defendant was 14 years
of age and older when the Defendant personally killed the victim,

and that a special circumstance enumerated in subdivision of
Penal section 190.2 is applicable.




 

 my 14

0301.42SEXUAL ASSAULT er MINOR 14 OR
OLDER WITH CIRCUMSTANCE
It is further alleged, pursuant to subdivision of Welfare
and Institutions Code section 602, that the Defendant was 14 years
of age and older at the time the Defendant personally committed
Counts 3, 4, 5, and. 6, and that 51 circumstance enumerated. in

subdivisions mm and km of Section 667.61 (IE the Penal Code is

applicable.

SPECIAL ALLEGATION 14 YR OLD-MINOR DEATH
OR LIFE CURRENT CRIME
It_is further alleged as to Counts pursuant to subdivision of section 707 of the Welfare

'and Institutions code, that the Defendant was a minor who was at

least 14 years.of age at the time of the commission of the above

offenses;

Therefore, complainant declares under penalty of perjury that

the foregoing is true and correct.

Executed on, July 29, 2015 at Santa Cruz, California.

  

Respectfully submitted,

 

Agency SCPD 
DA Log 15?07?176481-1