ENDORSED

FILED IN MY OFFICE THIS

STATE OF NEW MEXICO
COUNTY OF BERNALILLO

^UN g I 2015

SECOND JUDICIAL DISTRICT

eLER(fUgfR|6T6^URT

STATE OF NEW MEXICO,

Plaintiff,

D-202-CR-2015-00105

V.

DOMINIQUE PEREZ,
Defendant.

AMENDED INFORMATION
Randi McGiim, Special Prosecutor for the Second Judicial District of the State of New
Mexico, accuses Dominique Perez of SECOND DEGREE MURDER (FIREARM

ENHANCEMENT), VOLUNTARY MANSLAUGHTER (FIREARM ENHANCEMENT),

INVOLUNTARY MANSLAUGHTER (FIREARM ENHANCEMENT), and AGGRAVATED
ASSAULT (DEADLY WEAPON) (FIREARM ENHANCEMENT), and charges:

COUNT 1: SECOND DEGREE MURDER (FIREARM ENHANCEMENT),

VOLUNTARY MANSLAUGHTER (FIREARM ENHANCEMENT), AND

INVOLUNTARY MANSLAUGHTER (FIREARM ENHANCEMENT)
That on or about March 16, 2014, in Bemalillo County, New Mexico, the above-named

defendant did kill James Boyd without lawful justification or excuse and without acting upon
sufficient provocation while knowing that his acts created a strong probability of death or great

bodily harm to James Boyd or to another, contrary to NMSA 1978, 30-2-1(B) and NMSA
1978, 31-18-16; AND FURTHERMORE, the defendant is hereby notified that upon trial of
this cause the finder of fact may be instructed to consider voluntary manslaughter (firearm
enhancement), contrary to NMSA 1978, 30-2-3 andNMSA 1978, 31-18-16; and to consider

involuntary manslaughter (firearm enhancement), contrary to NMSA 1978, 30-2-3 and NMSA
1978, 31-18-16.

COUNT 2: AGGRAVATED ASSAULT (DEADLY WEAPON) (FIREARM

ENHANCEMENT)
That on or about March 16, 2014, in Bemalillo County, New Mexico, the above-named

defendant did unlawfully assault or strike at James Boyd with a firearm (a deadly weapon)
contrary to NMSA 1978, 30-3-2 andNMSA 1978, 31-18-16.
The names of the witnesses upon. whose testimony this information is based are as
follows: Geoff Stone, Rocky Edwards, and other such witnesses as may be called at the
preliminary examination in this matter.

:>
Randi McGinn
Kevin P. Holmes
Special Prosecutors for the State of New Mexico
McGinn, Carpenter, Montoya & Love, P.A.

201 Broadway, SE
Albuquerque, New Mexico 87102

ph.: (505) 843-6161

f: (505)242-8227
e-mail: randi(%mcgmnlaw.com
kevm(%mcgiimlaw. corn

CERTIFICATE OF SERVICE
I hereby certify that a copy of this
pleading was served by e-mail on all
counsel of record on June 22, 2015.

STATE v. Dominique Perez

Amended Information
C-oi^'-J o

STATE OF?W-MX4GQ~. )

LA H&bL )

COUNTY OF B-BRNA-M-fcfcO- )

VERIFICATION
Randi McGiim, Special Prosecutor for the Second Judicial District, State of New Mexico,
being duly sworn, says that the facts stated in the foregoing Information are true according to the
best of her information and belief.

idi M.cGSm, Special Prosecutor

Subscribed and sworn to before me

this _[fday of J ^''U _ 2015.

Notary Public

My Commission Expires:

"KORI LUCINDADAIViP

NOTARY PUBLIC^
STATE OF COLORADO^
ID 20154007089
MY ^7ssio'N EXPIRES 02/19/20^

02 - lci- Z D it
DA file #: 2014-01565-2

STN: N/A
MET. CT. #: N/A

LEA/RPT #: APD # 14-0023683

PROS: RANDI MCGINN (SPECIAL PROSECUTOR)

DOB: 03/13/1981
SS#XXX-XX-3192

DEF ATTY: LUIS ROBLES AND DAVID ROMAN

ADD: 500 Marquette Ave NW, Albuquerque, NM 87102

BOOKING/ARREST DATE AND #: NOT ARRESTED

Penalty as to Count 1 : a second degree felony resulting in the death of a human being (firearm),
fifteen years imprisonment plus a one-year mandatory enhancement of the basic sentence.