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-COUNT30 NEGLIGENT CAUSING A FIRE BY DEVICE, in violation of Section 4435 of the Public Resource Code, a Misdemeanor. Defendant (9) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), (On or about the 19th day 9f October, 2020, did negligently cause a fire by operation of a device ‘which may kindle afte, uid fire having escaped from the place where it originated. couNT 31 UNLAWBUL FIRE ON PROPERTY OR ANOTHER, in violation of Section 4421 of the Public Resource Code, a Misdemeanor. Defendant (3) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), On or about the 19th day 2f October, 2020, did willfully and unlawfully se fire or cause to be set fire any forest, brush or cther emmeble material on any land not belonging tothe defendant without the permission ofthe owner, lesse, or agent ofthe owner or lessee of the land ENHANCEMENTS 452.1(a)(1) PC SPECIAL ALLEGATION ~ RECKLESSLY CAUSING FIRE - AGGRAVATING FACTORS tis further alleged that the defendants) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), ‘As to Count(s) 5, 6,7, 8, 9and 10, itis further alleged, pursuant to Penal Code Section 452.1(2), thatthe following aggravating factor exists: defendant has previously been convicted of a felony violation of Penal Code section 451 or 452, to wit a violation of Penal Code Section 452 and was ‘convicted thereafon or about the 16TH DAY OF JUNE, 2020, in the BUTTE County Court, Case # 20CF 1422, 452.1(a)(2) PC SPECIAL ALLEGATION ~ RECKLESSLY CAUSING FIRE ~ AGGRAVATING FACTORS tis further alleged that tke defendants) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), ‘As to Count 5, itis further alleged, pursuant to Penal Code Section 452.1(a), that the following ‘aggravating factor exists: a firefighter, peace officer, or other emergency personnel suffered great bodily injury asa result of the offense ae452.1(a)(8) PC SPECIAL ALLEGATION ~ RECKLESSLY CAUSING FIRE AGGRAVATING FACTORS | iis futher alleged thatthe defendant(s) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), {As to Count 5 tis furthe: alleged, pursuant to Penal Code Section 452,1(a, thatthe following ing factor exists: defendant proximately caused great bodily injury to more than one 454(A) PC SPECIAL ALLEGATION ARSON DURING STATE OF EMERGENCY vis further alleged thatthe defendant(s) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), ‘As to Count(s) 5, 6, 7,8, 9,10, and 11, itis alleged the defendant, committed the above offense ‘during and within an area of a state of emergency, pursuant to Section 8625 of the Goverument ‘Code, which was proclaimed by the Governor ofthe Stae of California, within the meaning of Penal Code Section 454, 4452.1(a)(4) PC SPECIAL ALLEGATION ~ RECKLESSLY CAUSING FIRE - AGGRAVATING FACTORS Itis further alleged thatthe defendant(s) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), ‘As to Count 6, it is furthes alleged, pursuant to Penal Code Section 452.1(a, thatthe following ‘aggravating factor exists: defendant proximately caused multiple structures to burn, ‘STEPHANIE A BRIDGET District Attormey Subsoribed and swom on September 24, 2021 Pursuant to Penal Code Section 1054.5(b), the People ae hereby informally requesting that defense ‘counsel provide discovery tothe people as required by Penal Code Section 1054.3, SABIKb aeHOLDING ORDER It appearing to me tat the offenses) inthe within complaint has/have been committed, and ‘hat there is sufficient cause to belive that the defendant(s) SAS AND ELECTRIC COMPANY (PG&E), PACIFIC is guilty thereof. “The defendants) PACIFIC GAS AND ELECTRIC COMPANY (PG&E), having waived preliminary hearing to the offense(s) set forth in this complaint, Excoptions/A dalitons/Conditions: Loder tha the defendant be held to answer to same. In my capacity as Judge ofthe Superior ‘Court, Ideem the within complaint to be an Information and order it filed inthe Superior Court order thatthe defendant be held to answer to same. An Information is tobe filed by the Distet Attomey’s Office within the statutory time limit for defendant’ arraignment on said Information Date Dept. — —Tlge ofthe Superior Court Sitting as MagistrateShasta County District Attomey’s Office Bureau of Investigation CRIME REPORT #20GCOR47AHI INVESTIGATOR: Alex Houston #143 H Supplemental Report Dater OW DHD0OT ‘Tavoctated Cases): 20CASHU00097S (CAL TIRE) ‘Chargers 193 1) PC, UG) PC,ASZD) FC, HHO PC, ADOT HES, 450) PC, ‘Summarys On OOFTIUDD, the Zogg Fire Wared near Zong Mine Rood, in Igo, California: On 10/02/2020, the Shasta County DA"s Office was requestel to assist wit the investigation Tiere | vet [en _[ i [Cone {ah | et a | Door Sow KING, Karin om OWA [mae i-_ = ri ali .-_ — we Decensed Date af Death 0927/2020 [Tey Tamar | Cares | oem] a er [nom 0572874 [we ‘eas ROWE MCLEOD, Alaina Michelle ie li ‘nD oosased ~ Date of Death 09/27/2020 Fret [TOE || ORT | H Sem MCLEOD, Feyla Reve [eon oarrariz a in it it i | es Deceased ~ Dale of Death 0972972020 SHASTA COUNTY DISTRICT ATTORNEY'S OFFICE INVESTIGATOR: Alec Hour #143 BOI CASE: 200C08N7AHT RELATED CASE 20 Ul02078 (CAL FIRE)135 Wet Set Rene. CA. 960) — 301245:600 Shasta County District Attomey’s Office Bureau of Investigation. CRIME REPORT #20GC0847 AHI INVESTIGATOR: Alex Honston #143, H Supplemental Report [Resse Cer TCHSTOOOOTE (CAL HR) [Date ENT] Charges Contnaeds TOT TAS, OSTRG, WAT TRG AS FRC AITO PUG AT) Tas on) Has, eye) PC 4524) PC, ASB) PC ASD Summary Sex pgs a RI ET Co v= MAICTINZ, fe [ | a se] aoe a Firefighter Tra Fim] ed | Cee] CS ‘eo Fire Captain Speciaist Darren Stewart [20m ras 5 Ge Ai alla OT White: Male. “ : | ve CAE FRY ones SE OS ST [OO | hea» Battalion Chief JT Zulliger # 2256 bom ‘oun ra TS Gp Ree Reig, Calan 960. [na (YS 2D Wwe [wae [1 [ re CAL FRE Lge S| [OI SSE TO ion SHASTA COUNTY DISTRICT ATTORNEY'S OFFICE INVESTIGATOR: Alex Houten 43 BOL CASE 20600847 RELATED CASE: 20CASHUIDS97S (CAL-FIRE)‘Summary of Event ‘Beginning on 0922/2020 at 1302 hours, the National Weather Service Forecast Office (NWSFO) out of Sacramento, California ssued a Fire Weather Watch forthe Tgo area for “citicl fire weather conditions to occur between 09/26/2020 and 09/28/2020. On 09/25/2020 a 1008 hours, NWSFO issued ‘Red Flag Weming far the Teo sre for “ritcal fire weather conditions" to occur between 2100 hours {09/26/2020 to 1200 hourson 09/28/2020, On 09/25/2020 at 2048 hous, the term “critical fire weather conditions” had been changed to “extreme fire weather conditions.” The forecast on 09/25/2020 had predicted north to east winds 15-30 miles pee hour (mph) with gusts fom 40-45 mph and stronger gusts ‘yp to 35 mph in favored gaps and canyons (009/27/2020, at 1435 hous, (11 minutes prior othe first 911 repor of the Zogs Fite), NWSFO issued ‘Red Flag Warning for “extreme fire weather conditions” with predicted north to east winds 15-30 mp ‘with gusts 40-45 mp with stronger gusts up to 65 mph possible through the favored gaps and canyons. ‘The NWSFO Fire Weather Watch and Warnings are publily available on the Forecas¢ Office website ‘At approximately 1446 hours, the Zoge Fite was reported inthe community of Igo, inthe County of ‘haste, and State of Califomia, Due to this lotion being within the unincorporated area of Shasta County, Califia Departnent of Forestry and Fire Protection (CAL FIRE), Shaste County Fire epartment, Happy Valley Fire Department, Redding Fie Departmeat and Anderson Fite Protection District personnel were dzptched tothe location of the fre. CAL FIRE Fire Captain Specialist Darren Stewart #3481 also responded and arrived on seone at approximately1509 hous. Captain Stewart was assigned a the lead origin and cause Investigator due tothe fire being inthe State Responsibility Area, proteded by CAL FIRE. Captain Stewart conducted a dette origin and cause investigation over a ten-day riod. Captain Stewart received assistance from nine additional CAL FIRE peace officers, These offices assisted Captsin Stewart with locating fre patter indicators and gridéing bf the scene. “The ave of origin wes detemined by Captin Stewart to be 70’ northeast of Zoge Mine Rotd and $20" northwest of $499 Zoge Mine Road, The aren where the fre originated isin California Public Uity Commission (CPUC) Tier 2 irethrst area, Tit 2 indicates there is an elevated risk ineluding ketthood td potential impacts on people ad property) from ullty-associated wildfires, Historical fire history data in the Zogg Fite area of orign shows te same area burned inthe 2018 Cart Fire end in the 1950 Kanaka Creek Fie ‘The cause ofthe Zoge Fire was determined to be a gray pine falling in a southerly direction, striking powerlines owned and opested by Pacific Gas and Electric Company (PG&E). PGRE has identified the powerline asthe Girvan 1101, 12 KV Distribution Cireut. An arborist and electrical engineer were retained by CAL FIRE to provide an assessment of the aay pine and damaged electrical conductor. “The axborst determined the grey pine was over 105" tall end over 2" in diameter atthe base. The tee Jned decay and a significant cavity atthe bas af the tre tha would have predisposed itt adownsope failure, The tree was over 80 years old and in 2019, it had «23° lean towards the power lines. The 23° Tean was determined by the arborist. The 23° lean was independently confirmed off LIDAR data aethored by PGAE in @ 2019 LIDAR survey ofthe surrounding ares. SHASTA COUNTY DISTRICT ATTORNEY'S OFFICE INVESTIOATOR: Alextosston #103, BOI CASE 200C0sCA1 [RELATED CASE # 20¢4S11U008078 (CAL FIRE)“The ean would have been cbvious to pre-inspectrs. Decay was observed in the center ofthe tee, The cavity and absence of supprting rots onthe cavity side would have been visible from the sides and “phil even if briefly viewed The rots on both sides ofthe eavity were excessively large, which was evidence they had develope aver a ong period of high mechanical stress, The cavity was determined to have predated the Zogg Fire and Carr Fie. If established protools for hazard tree identification and removal had been followed the tee defect would have been discovered and subsequently removed prior to fur, Prior tothe eolletion of evitence, I viewed the gray pine. I observed te large cavity and Inoticed three {indentations on branches tit were facing the ground. The indentations were all similar in size and pproximately the sizeof ts conductor that Was laying under the tree, The indentations on the branches sppeared fo have been caused by the conductor and electrical arcing. A ater possible causes ofthe Zoge Fite were eliminated during the investigation. PORE as statutory and regulatory duties to mitigate such risks by removing hazard trees. Publicly available information demonstrates in 2018, PG&E marked the gray pine forremaval that caused the ‘ogg Fire. The gray pine was not removed, and subsequent PGALE vegetation management patols failed to mark or remove the tree, PG&E has repestedy and publicly acknowledged its awareness that such failures are likely to produos erent bodily harm or death (0n 10/02/2000, st approximately 1225 hours, I was assigned to the Zogg Fite. I responded to the Igo ftea and errved at epproximately 1320 hours, I contacted CAL FIRE Battalion Chief Zalliger. Chief Zalliger informed me the fait site involving Karin King (79 years old), was loated on Zogg Mine Roed, north of South Fork Road. Chief Zulliger sai the fatality site involving Alaina Rowe McLeod (4 years old) and Feyla McLeod (6 years old) was located on Archer Road, north of South Fork Road, (Chie? Zulliger said the fourh fealty was Kenneth Vossen (52 years old). Chief Zullger said Kent ‘was transported by medieal personnel to local hospital and he was later transfered to the UC Davis Brn Center, located in Saomment, Californis. Chief Zulliger sald he believed Kenneth sustained major ‘bums to his body and he Ir succumbed to his injures at UC Davis Medical Cente. Chief Zulliger escorted me to Karin’s fatality site. We arived at approximately 1540 hours, I noticed ‘what appeared fo be a burntChevy Trailblazer. noticed Karin's remains had been previously removed. 1 noticed wit appeared to be a deceased animal inside the rer cargo area ofthe vehicle. Late, I spoke with Captain Stewart who told me he located Karin's severely bummed remains on 09/27/2020, et ‘proximately 1630 hours. The remains were located onthe ground, next othe open driver's side door. ‘The closest posted address sgn to Kern's vehicle was located at 8221 Zogg Mine Road. reviewed Shasta County Coroner Case Number €20-0666 and noticed postmortem toxicologie analysis of blood was conducted, Ioticed the Forensic Pathologist reported the carboxyhemaglobin saturation, ‘which s an indication of aremortem exposure to products of cambustion, was slightly elevated but not ate lethal level, Ths suggests Karin was alive atthe time ofthe fie and she inated the smoke. Karin ‘was overcome by the fire al succumbed to thermal injuries asa result. The eause of death was certified as thermal injuries. Chief Zalliger and I responded to Altina's end Feyla's fatality site, located on Archer Road. Chief Zulliger and I arrived at approximately 1706 hous. Inoticed what appeared to be a Ford pickup, located on the southside of Archer Road, approximately 2.1 miles from South Fork Road. SHASTA COUNTY DISTRICT ATTORNEY'S OFFICE, INVESTIGATOR: Aletiouson #143, ol Cage #: 20GIBATAKE RELATED CASE # 2054SHU009978 (CAL FIRE)Later, spoke with a neighbor of Alina and Feyla, who fold me she had fent he pickup to them minutes prior tothe fire reaching their residence. As the neighbor was evacuating (minutes after leading her ‘ehicleto Alaina and Fey) ste observed her vehicle, disabled off the roadoay,flly engolfed in ames, On 0928/2020 at epproxinately 0230 hour, two Redding Police Officers located Alaina and Feyls, inside the front passenger eampartment ofthe pickup 1 reviewed Shasta County Coroner Case Numbers ©20-0668 and €20-0669 and noticed postmortem toxleologie analysis of blood was conducted. I noticed the Forensic Pathologist reported the tarbexykemoglobin seturalion, Which i an indication of antemortem exposure to products of ‘combustion, was slightly elevated ut nota a lethal level in both eases, This suggests both Alaina and Feyle were alive atthe tm ofthe fire and they both inhaled the smoke, Both Alaina and Feyla were tvercome by the fire and succumbed to thermal injuries asa result. The causes of death were both certified as thermal injuries, ‘located Kenneth's property at 1327 South Fork Road. I noticed Kenneths residence and detached garage were consined by te fire, On the same property, Iocated an All-Terain Vehicle collision site fd a set of keys near the site, I noticed what appeared tp be burat and melted fabric attached to the keys. Later, Kenneth’ wife positively identified Kenneth Keys. Kenneth’s wife also reported seeing ‘Kenneth just prior to the fe reaching their residence. I contacted a neighbor who reported he located Kenneth in the seine ase, while the firo Was still Buming. The neighbor reported Kenneth was not ‘wearing clothes and it appated he was severely bumed all over his body. “interviewed medical personel that assisted Kennet, afer he was found badly bumed by his neighbor. Teonfimmed Kenneth was tansported {0 a local hospital and later transferred to UC Davis Medical Center. Kenneth succumbel to his injuries on 09/29/2020 at 1725 hous. The UC Davis physician attending to Kenneth, determined Kenneth's cause of death to be multisystem failure, as an fomediate ‘cause, with 90% foal body 2 and 3 dogree burs a a condition leading to the cause. The physician lls stated with the extensive bum Kenneth experienced, he inhaled toxins. A toxiologic analysis of ‘blood was conducted and th physician said Kenneth's carbaxyemoglobin was elevated ‘0n 10/02/2020, inte Firefighter Albert Martinez (29 years old) was assigned tothe Ibi Conservation Fire Camp and ie was deployed on the Zope Fi. During fire suppression efforts, Albert received major Injuries aftora ree fell on hin, Albers injuries consisted of tree fractures tothe upper thoracic part of| his spine, 2 hea injury, paralysis ust under the chest area and no feling or movement of his legs. 1 requested Certificates of Desth for Karin, Alsina Feyla and Kenneth. On 12/14/2020, 1 received a Sacramento County Certfeate of Death for Kenneth (State File Number 3052020235695). On 12/15/2020, I received Shasta County Certfeates of Death for Kerin (State File Number 3052020223448), Alaina ‘State File Number 3052020235454) and Feyla (State ile Number 3052020234468). (On 10/09/2020, 1 walked the Girvan 1101 creat, north of the origin location, I located numerous locations where I observed violations ofthe California Public Resource Code. located numerous areas where there were dead tres within striking distince of the PG&E conductors. 1 noted numerous Tocations where there were clearance violations around non-exempt PGAE owned utility poles. 1 obtained digital photographs and video from the ground, I obtained digital photographs and video fom the ai, utilizing’ helicopte and Unmanned Aireraft Veicles. I also obtained imagery utilizing laser scanning equipment SHASTA COUNTY DISTRICT ATTORNEY'S OFFICE INVESTIGATOR Alex!ouson #143, BOI CASE #: 20GIBHAK RELATED CASE # 20:ASHUOO907S (CAL. FIRE)| conducted several interviews with victims reporting the deaths oftheir animals. At the conclusion of nny inital interviews, [believe at minimum, te following animels died as direct result ofthe Zone Fite: | hors, 18 cattle 9 ofthem pregnant), 8 dogs, 2 cats and I bearded dragon lizard. There were as numerous other cnimals that were injured as well as other dogs and cats believed to have perished. T have consulted several stuties related to the health hazards of consuming wildfire smoke, conducted by several medical experts. A meteorologist and ar resource specialist have been employed to assist ime with assessing the impr of te wildfire smoke on the residents residing in Shasta County and other Surrounding counties. Based on evidence collected during the active Zope Fite, local air quality Advisories, various imagers, my own observations of seeing and smelling the smoke, and expen’s Dpinions, {believe PG&E used the negligent end reckless emissions of ar contaminants during the dates of 09/27/2020 to 10/0-/2020. In 2017, PG&E was conviced of several felonies related tothe 2010 San Bruno pipeline explosion. 1 received PGAE"s Original ludgement and conditions oftheir Federal Probation (Case Number 0971 ‘3: 14CRDOI7), {read the documents and noticed the Date of imposition of Judgement was 01/26/2017 land PG&E was sentenced tc probation for aterm of five years. In 2020, PG&E was conviced of eighty-four felonies rolated to the 2018 Camp Fire. I received Butte ‘County Superior Court minute orders from the PG&E plea and sentencing hearing, related othe Camp Fire (Case number 20CF01422), The minatcrders were dated 06/16/2020, 06/17/2020 and 06/18/2020. “The Zogg Fire destoyed 24 inhabited structures, damaged an additional 27 structures, and burned 56,338 aces, within 616 paces, located in Shaste and Tehama counties, The Zogg Fire ocurred during ‘a Governors declared State of Emergency. The state of emergency had been declared due to multiple Targe willand fies that were occurring within the state of California atthe time of the delaration. {was informed of ational PG&E caused firs in Shasta County. [reviewed the Daniel Fire CAL FIRE, Report (CAL FIKE Case Number 20CASHU0007430) The Datel Fire wcut.ed near Daniels ane and [Bear Mountain Road, Jones Valley, California, The date of ignition was 07/28/2020. I reviewed four photos displuying the evicence of the fire, 1 noticed a Fire Apperatus Engineer conducted the Jnvestgation end detenmined the cause to be “Electrical Power". The Engineer indicated a oak tre, ‘with rotten wood near the Fase, fell nto the powerlines and caused the fire. Based on the Engineer's ‘report and photograph, Ibdieve Pacific Gus and Blectc i in violation of sections 452(c) Penal Code, 13001 Heath and Safety Cade, 2110 Public Utilities Code, £293 Public Resouree Code, 4421 Public Resource Code and 4435 Public Resource Code 1 reviewed the Ponder Fite CAL FIRE Report (CAL FIRE. Case Number 20CASHU0010829). The Ponder Fire occured on Ponder Way, West Valley, Califomia. The date of ignition was 10/19/2020. 1 reviewed four photos and a sketch, displaying the evidence ofthe fire. I noticed a Fire Apparats Fngineer conducted the investigation and determined the cause tobe “Electrical Power". The Engineer listed factors contributing t the ignition to be “Are from felty contact, broken conductor". The Fngineer indicated there wat obvious evidence ofa damaged power poe. The Engineer determined the fire tobe caused by damage electrical equipment contscting the power pole support cable. Based on the Engineer's repor, sketch, and photographs, I believe Pacific Gas and Electric isin violation of sections 452(e) Penal Code, 13001 Health and Safety Code, 2110 Public Uiilities Code, 4421 Public Resouree Code and 4435 Public Resource Code. ‘SHASTA COUNTY DISTRICT ATTORNEY'S OFFICE. INVESTIGATOR Alexloason #145 ol case#-200c0e0raa RELATED CASE & 20¢ASHUOO9078 (CAL FIRE)(0n 08/19/2021, a epproxinstely 2052 hours, Chief Zuliger notified me of the Woody Fite (CAL FIRE. Case Number 21ASHUOO0891 1), Chief Zulliger sid he was investigating the Woody Fire that ignited catir that day, off Woody Lane in Jones Valley, California. Chief Zuliger said gray pine, that was ‘marked for removal, filed, struck @ PG&E conductor, and caused the Woody Fie, On 08/20/2021, 1 responded tothe Woody Fie origin, I observed the gray pine that was marked for removal. I observed the bum scar and a damage outbuilding. Based on CAL FIRE?s investigation I believe Pacific Gas and ecrie is in violation of setions 452(c) Penal Code, 13001 Health and Safety Code, 2110 Public Uilities Code, 4293 Public Resource Code, 4421 Public Resource Code and 4435 Public Resource Cade. ee —- Aus bef ass: SHASTA COUNTY DICTRICT ATTORNEY'S OFFICE INVESTIGATOR: Aleiaustn #43, BOI CASE n 200087 RELATED CASE ¥: 20¢ASHU009978 (CAL FIRE)