THE PEOPLE OF THE STATE OF CALIFORNIA, v. JILL ANN BURNELL, ALEX BURNELL.

Marin County

No. SC184823A

I, THE UNDERSIGNED, SAY, ON INFORMATION AND BELIEF, THAT IN
THE COUNTY OF MARIN, STATE OF CALIFORNIA:

COUNT 001: On or about December 18, 2012, to December 27,
2012, the crime of CRUELTY TO AN ANIMAL, in violation of Section
597(b) of the Penal Code, a felony a misdemeanor, was committed by JILL ANN

BURNELL AND ALEX BURNELL, who, at the time and place last
aforesaid, did willfully and unlawfully deprive an animal of
necessary substance, drink, and shelter, to wit: Romantic Star.

COUNT 002: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 001, complainant further complains
and says: On or about December 18, 2012, to December 27, 2012,
the crime of CRUELTY TO AN ANIMAL, in violation of Section
597(b) of the Penal Code, a felony a misdemeanor, was committed by JILL ANN
BURNELL AND ALEX BURNELL, who, at the time and place last
aforesaid, did willfully and unlawfully deprive an animal of
necessary substance, drink, and shelter, to wit: Pookie.

COUNT 003: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 002, complainant further complains
and says: On or about December 18, 2012, to December 27, 2012,
the crime of CRUELTY TO AN ANIMAL, in violation of Section
597(b) of the Penal Code, a felony a misdemeanor, was committed by JILL ANN
BURNELL AND ALEX BURNELL, who, at the time and place last
aforesaid, did willfully and unlawfully deprive an animal of
necessary substance, drink, and shelter, to wit: Radieshen.

COUNT 004: For a further and separate cause of complaint, being a

different offense from but connected in its commission with the

charge set forth in Count 003, complainant further complains
and says: On or about December 18, 2012, to January 4, 2013,
the crime of CRUELTY TO AN ANIMAL, in violation of Section
597(b) of the Penal Code, a felony a misdemeanor, was committed by JILL ANN
BURNELL AND ALEX BURNELL, who, at the time and place last
aforesaid, did willfully and unlawfully deprive an animal of
necessary substance, drink, and shelter, to wit: Blackie.

COUNT 005: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 004, complainant further complains
and says: On or about December 18, 2012, to January 4, 2013,
the crime of CRUELTY TO AN ANIMAL, in violation of section
597(b) of the Penal Code, a felony a misdemeanor, was committed by JILL ANN
BURNELL AND ALEX BURNELL, who, at the time and place last
aforesaid, did willfully and unlawfully deprive an animal of
necessary substance, drink, and shelter, to wit: Nutsie.

NOTICE: Conviction of this offense(s), as to Counts 1, 2,
3, 4, and 5, will require the said defendant(s), JILL ANN
BURNELL, to provide specimens and samples pursuant to Penal Code
Section 296. Willful refusal to provide the specimens and
samples is a crime.

NOTICE: Conviction of this offense(s), as to Counts 1, 2,
3, 4, and 5, will require the said defendant(s), ALEX BURNELL,
to provide specimens and samples pursuant to Penal Code Section
296. Willful refusal to provide the specimens and samples is a
crime.

COUNT 006: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 005, complainant further complains
and says: On or about December 18, 2012, to December 27, 2012,
the crime of KEEPING AN ANIMAL WITHOUT PROPER CARE, in violation

of Section 597.1(a) of the Penal Code, a misdemeanor, was
committed by JILL ANN BURNELL AND ALEX BURNELL, who, at the time
and place last aforesaid, was the owner, driver, and keeper of
an animal, to wit: Romantic Star, who, did willfully and
unlawfully permit the same to be in a building, enclosure, lane,
street, square, and lot, to wit: Romantic Star, without proper
care and attention.

COUNT 007: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 006, complainant further complains

and says: On or about December 18, 2012, to December 27, 2012,
the crime of KEEPING AN ANIMAL WITHOUT PROPER CARE, in violation
of Section 597.1(a) of the Penal Code, a misdemeanor, was
committed by JILL ANN BURNELL AND ALEX BURNELL, who, at the time
and place last aforesaid, was the owner, driver, and keeper of
an animal, to wit: Pookie, who, did willfully and unlawfully
permit the same to be in a building, enclosure, lane, street,
square, and lot, to wit: Pookie, without proper care and
attention.

COUNT 008: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 007, complainant further complains
and says: On or about December 18, 2012, to December 27, 2012,
the crime of KEEPING AN ANIMAL WITHOUT PROPER CARE, in violation
of Section 597.1(a) of the Penal Code, a misdemeanor, was
committed by JILL ANN BURNELL AND ALEX BURNELL, who, at the time
and place last aforesaid, was the owner, driver, and keeper of
an animal, to wit: Radieshen, who, did willfully and unlawfully
permit the same to be in a building, enclosure, lane, street,
square, and lot, to wit: Radieshen, without proper care and
attention.

COUNT 009: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 008, complainant further complains
and says: On or about December 18, 2012, to January 4, 2013,
the crime of KEEPING AN ANIMAL WITHOUT PROPER CARE, in violation
of Section 597.1(a) of the Penal Code, a misdemeanor, was
committed by JILL ANN BURNELL AND ALEX BURNELL, who, at the time
and place last aforesaid, was the owner, driver, and keeper of
an animal, to wit: Blackie, who, did willfully and unlawfully
permit the same to be in a building, enclosure, lane, street,
square, and lot, to wit: Blackie, without proper care and
attention.

COUNT 010: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 009, complainant further complains
and says: On or about December 18, 2012, to January 4, 2013,
the crime of KEEPING AN ANIMAL WITHOUT PROPER CARE, in violation
of Section 597.1(a) of the Penal Code, a misdemeanor, was
committed by JILL ANN BURNELL AND ALEX BURNELL, who, at the time
and place last aforesaid, was the owner, driver, and keeper of
an animal, to wit: Nutsie, who, did willfully and unlawfully
permit the same to be in a building, enclosure, lane, street, square,

and lot, to wit: Nutsie, without proper care and
attention.

COUNT 011: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 010, complainant further complains
and says: On or about December 18, 2012, to December 27, 2012,
the crime of CRUELTY TO AN ANIMAL, in violation of Section
597(b) of the Penal Code, a misdemeanor, was committed by JILL
ANN BURNELL AND ALEX BURNELL, who, at the time and place last
aforesaid, did willfully and unlawfully deprive an animal of
necessary substance, drink, and shelter, to wit: Aloha.

COUNT 012: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 011, complainant further complains
and says: On or about December 18, 2012, to December 27, 2012,
the crime of CRUELTY TO AN ANIMAL, in violation of Section
597(b) of the Penal Code, a misdemeanor, was committed by JILL
ANN BURNELL AND ALEX BURNELL, who, at the time and place last
aforesaid, did willfully and unlawfully deprive an animal of
necessary substance, drink, and shelter, to wit: Federalist.

COUNT 013: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 012, complainant further complains
and says: On or about December 18, 2012, to December 27, 2012,
the crime of CRUELTY TO AN ANIMAL, in violation of Section
597(b) of the Penal Code, a misdemeanor, was committed by JILL
ANN BURNELL AND ALEX BURNELL, who, at the time and place last
aforesaid, did willfully and unlawfully deprive an animal of
necessary substance, drink, and shelter, to wit: Red Wine.

IT IS FURTHER ALLEGED, as to Counts 11, 12, and 13, this
count is hereby specified to be a misdemeanor offense as to said

defendant, JILL ANN BURNELL, pursuant to Penal Code Section
17(b)(4).

IT IS FURTHER ALLEGED, as to Counts 11, 12, and 13, this
count is hereby specified to be a misdemeanor offense as to said
defendant, ALEX BURNELL, pursuant to Penal Code Section
17(b)(4).

COUNT 014: For a further and separate cause of complaint, being
a different offense from but connected in its commission with
the charge set forth in Count 013, complainant further complains

and says: On or about November 24, 2012, to April 9, 2013, the

crime of OPERATING A COMMERCIAL ANIMAL ESTABLISHMENT WITHOUT A
PERMIT, in violation of Section 8.04.240 of the Marin County
Code, a misdemeanor, was committed by JILL ANN BURNELL AND ALEX
BURNELL, who, at the time and place last aforesaid, did
willfully and unlawfully operate or maintain a commercial animal
establishment without first obtaining a permit.

I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS
TRUE AND CORRECT EXCEPT AS TO THOSE MATTERS STATED ON THE
INFORMATION AND BELIEF AND AS TO THOSE MATTERS I BELIEVE THEM TO
BE TRUE.

EXECUTED ON 5/23/2013, AT SAN RAFAEL, CALIFORNIA.

TERESA LEON VARELA
DEPUTY DISTRICT ATTORNEY

View Amended Complaint

View Plea Agreement – Remaining 11 counts dismissed