On April 21, 2003, K. Vella, Stanislaus County District Attorney's Office, complains and alleges, upon information and belief that said defendant did commit the following crime (s) in the county of Stanislaus, State of California.


COUNT I:

On or about and between December 23, 2002 and December 24, 2002, defendant did commit a felony, murder, violation of Section 187 of California Penal Code in that the defendant did willfully, unlawfully and feloniously and with malice aforethought murder Laci Denise Peterson, a human being.



SPECIAL ALLEGATION:

It is further alleged as to Count I, murder, that the defendant acted intentionally, deliberately and with premeditation.



ENHANCEMENT:

TERMINATION OF PREGNANCY. During the commission of the murder of Laci Denise Peterson, the defendant, with the knowledge that Laci Denise Peterson was pregnant did inflict injury on Laci Denise Peterson resulting in the termination of her pregnancy, a violation of Section 12022.9 (a) of the California Penal Code.


COUNT II:

On or about and between December 23, 2002 and December 24, 2002, defendant did commit a felony, murder, violation of Section 187 of California Penal Code in that the defendant did willfully, unlawfully and feloniously and with malice aforethought murder Baby Connor Peterson, a fetus.



SPECIAL ALLEGATION:

It is further alleged as to Count II, murder, that the defendant acted intentionally, deliberately and with premeditation.



THE FOLLOWING SPECIAL ALLEGATION
APPLIES TO BOTH COUNTS:

It is further alleged as to Counts I and II, murder, the defendant did commit more than one murder in the 1st or 2nd degree in this proceeding, and is a special circumstance within the meaning of Penal Code section 190.2 (a) (3)