NAME: ALEJANDRO IBARRA CAUSE NO: 1Q-0L1-138 CRU)
OFFENSE: ENGAGING IN ORG. CRIM. ACTIVITY BOND: aeetlha
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DEGREE: Second Degree Felony DATE FILED: alia
IN THE NAME AND BY THE AUTHORITY OF THE STATE OF TEXAS, the Grand
Jury, duly selected, organized, sworn and impaneled as such for the County of Wilson, State of
Texas at the January, A.D., 2019, term of the 81/218" Judicial District Court for said County,
upon their oaths present in and to said Court, that on or about the 15" day of AUGUST, 2016,
and between the 15" day of March, 2017, and before the presentment of this indictment, in the
County and State aforesaid, ALEJANDRO IBARRA (hereinafter called Defendant), did then and
there:
with the intent to participate in a combination, the combination consisting of the defendant
and Dustin Norman and Juvenile #105 (a pseudonym), who collaborated in carrying on the
hereinafier described criminal activity, conspire to commit the offense of SEXUAL,
ASSAULT by agreeing with each other that they would engage in conduct that constituted
the offense, and the defendant performed an overt act or acts in pursuance of the agreement,
to-wit:
on or about August 15, 2016, the defendant held the Juvenile #57 (a pseudonym)
attempted to cause the penetration of the complainant’s anus with a cardboard rod;
and
‘on or about September 30, 2016, the defendant held the Juvenile #57 (a pseudonym) and
attempted to cause the penetration of the complainant's anus with a shampoo bottle;
‘on or about November 15, 2016, the defendant held the Juvenile #65 (a pseudonym) and
attempted to cause the penetration of the complainant’s anus with a CO2 air bottle;
Against the peace and dignity of the State,
By Sh. seu
Fofeperson of the Grand Jury
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OR RECORD
‘DUNTY. TEXAS.
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2013 JUN 1AM 10:
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