STATEMENT OF ERIK PEREZ
Factual Background
I, Erik Perez (the “Complainant”), am a law-abiding male adult of sound mind and a resident of 3817 South Hill Street, Los Angeles, CA 90037. I am lodging this Complaint against Maria Avalos, Magaly Avalos, and Blanca Hernandez, and hereby states as follows:
- Maria Avalos is a female adult of sound mind and a resident of 3819 S. Hill St., Los Angeles, CA 90037.
- Blanca Rodriguez is a female adult of sound mind and a resident of 3819 S. Hill St., Los Angeles, CA.
- Magaly Avalos is an adult of sound mind residing in the State of California.
- On December 11, 2017, Blanca Hernandez gave a false testimony under oath.
- On or around December 12, 2017, Maria Avalos gave a false testimony under oath.
- On or around December 12, 2017, Magaly Avalos gave a fasle testimony under oath.
- On or around December 13, 2017, Maria Avalos gave a false testimony under oath.
- On or around December 13, 2017, Magaly Avalos gave a false testimony under oath.
Legal Argument
- Penal Code 118 (a) provides as follows: “Every person who, having taken an oath that he or she will testify, declare, depose, or certify truly before any competent tribunal, officer, or person, in any of the cases in which the oath may by law of the State of California be administered, willfully and contrary to the oath, states as true any material matter which he or she knows to be false, and every person who testifies, declares, deposes, or certifies under penalty of perjury in any of the cases in which the testimony, declarations, depositions, or certification is permitted by law of the State of California under penalty of perjury and willfully states as true any matter which he or she knows to be false, is guilty of perjury.”
- Maria Avalos, Magaly Avalos, and Blanca Rodriguez purposefully made false statements against Erik Perez while under oath.
- “The elements of perjury are: a willful statement, under oath, of any material matter which the witness knows to be false.” People v. Garcia, 141 P. 3d 197 (2006).
- Maria Avalos, Magaly Avalos, and Blanca Rodriguez maliciously made false statements against Erik Perez to obtain a restraining order.
- Maria Avalos, Magaly Avalos, and Blanca Rodriguez are guilty of the crime of perjury.
REASONS WHEREFORE, PREMISES CONSIDERED, Erik Perez respectfully requests punishment for Maria Avalos, Magaly Avalos, and Blance Rodriguez in the form of imprisonment for 4 years in state prison.
Dated this 11th day of January, 2022.
Respectfully Submitted,
___________________________________
Erik Perez
3817 South Hill St.,
Los Angeles, CA 90037
Complainant in pro per
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