CAUSE NUMBERS: F16-76111, F16-76113, F17-00162, F17-00163, F17-00164, F17- 00165, F17-00166, F17-00167, F17-00168/ | |_ = b THE STATE OF TEXAS § IN THE, sd JUpICrAL. ST Rs ir VS. § bisrayercouRe OF RAYAN GANESH § NOTICE OF EXTRAN! OFFENSE: Pursuant to TEX. CODE CRIM. PRO, ART. 38.37, TEX. R. CRIM. EVID. 404(B), and CODE, CRIM. PRO. ART. 37.07, | am hereby giving you notice that during presentation of State's ease in chief, or during punishment, in the above-captioned and numbered criminal action, the following crimes, ‘wrongs or acts, other than the act alleged in the indictment, may be introduced: ‘NATURE OF ACT (OBFENSE /ARREST Location Dare Tndecency with a Child by Exposure ‘Apal through July 2016 | Dallas County, Texas In a continuing course of conduct, the defendant ‘would masturbate openly in his office when others were present. On ovo instances he did this in font of the child complaint listed in indictments F16-76111 and F16-76113. On one oceasion the CW was sitting and working at the desk est to the defendant. The defendant pulled his penis out of the top of his pants and moved it up and down with his hand. After the defendant finished, he paid the CW her daily salary and then cleaned his hand with a tissue. ‘The second occasion was when the CW was translating a phone call between the defendant and a client. The defendant pulled out his penis through his zipper in masturbated. The defendant committed the offense of indecent “Apiil through July 2016 | Dallas County, Texas exposure in front of ENE While the CW was working in her office she looked over and saw the defendant at his desk masturbating with his penis exposed. He would stare at her while he did this and | give her a creepy half smile. In a continuing course of conduct, the defendant “Apzil through July 2016 | Dallas County, Texas would regularly touch his penis over his clothing while other employees were present. In particular he did this in front of a 13 year old employee, M.C,, whose identity has been disclosed in the discovery process.CAUSE NUMBERS: F16-76111, F16-76113, F17-00162, F17-00163, F17-00164, F17- 00165, F17-00166, F17-00167, F17-00168 THE STATE OF TEXAS § vs. § RAYAN GANESH § IN THE 2824 JUDICIAL DISTRICT COURT OF DALLAS COUNTY, TEXAS MG. looked away from the defendant when he started to unzip his pants Ina continuing course of conduct, the defendant ‘would show employees pornography on his phone and computer. ‘Apu through July 2016 | Dallas County, Texas ‘The defendant is known to view and collect vast amount of potnogaphy. The defendant bookmarks | and favorites many URL. that lead to pornography Apsil through July 2016 | Dallas County, Texas “The defendant is known to take many “selfies” including images of his face and penis. January 2016 to present | Dallas County, Texas The defendant is known in the community to awkwardly stare down at young women and stare at their breasts. He is known in the community to offer alcohol to minors and give young women gifts to receive attention. ‘January 2016 to present | Dallas County, Texas The defendant is known in the community to solicit young, Hispanic females to work in his office under the guise of needing translators, usually by approaching them in the hallways of the Frank Crowley Courthouse January 2016 to present | Dallas County, Texas Respectfully submitted, Z1—~_ Joi McMillin ‘Assistant District Attorney Dallas County, Texas Bar Card Number: 24078984 CERTIFICATE OF SERVICE Thereby cently that a true and correct copy of the foregoing Motions have been JX hand-delivered, {| mailed, (] electronically mailed [] faxed, to the Attorney for the Defendant on this the YA. day of Some, 2017. i} District Atomey