MITCHELL D.

ROTH 6012
Prosecuting Attorney
Electronically Filed
KAUANOE A. JACKSON 8659 THIRD CIRCUIT
Deputy Prosecuting Attorney 3DCW-18-0002036
County of Hawai’i 23-JUL-2018
81-980 Haleki’i Street, Ste. 150 09:31 AM
Kealakekua, Hawai’i 96750

Tel. No. 322-2552

Attorneys for State of Hawai’i

IN THE DISTRICT COURT OF THE THIRD CIRCUIT

NORTH AND SOUTH KONA DIVISION
STATE OF HAWAI’I

STATE OF HAWAI’I Report Nos. As to Defendant MALIA

Plaintiff, KAALANEO LAJALA: C18020168;
C18020179; C18020295; C18020296;
vs. C18020297; C18020298

Report Nos. As to Defendant KRYSTLE

MALIA KAALANEO LAJALA, KRYSTLE LYNN FERREIRA: C18020168;
LYNN FERREIRA, AND JORGE ALLEN C18020179; C18020295; C18020296
PAGAN-TORRES,
Defendants. Report Nos. As to Defendant JORGE
ALLEN PAGAN-TORRES: C18020168;
C18020179; C18020295; C18020296

COMPLAINT

Honorable Judge Margaret K. Masunaga

Hearing Date: July 23, 2018 at 11:00 a.m.

COMPLAINT

COUNT 1 (C18020168)

On or about July 17-20, 2018, in the County and State of Hawaii, MALIA

KAALANEO LAJALA, KRYSTLE LYNN FERREIRA, AND JORGE ALLEN

PAGAN-TORRES, with the intent to hinder the apprehension, prosecution,

conviction and/or punishment of another, Justin Waiki, for murder in any degree,
did intentionally render assistance to Justin Waiki, thereby committing the offense

of Hindering Prosecution in the First Degree, in violation of Section 710-1029(1),

Hawaii Revised Statutes, as amended.

As to MALIA KAALANEO LAJALA, if she is convicted of this offense MALIA

KAALANEO LAJALA may be sentenced to a mandatory minimum period of

imprisonment without the possibility of parole in accordance with Section 706-

606.5 of the Hawai’i Revised Statutes where he/she is a repeat offender as he was

previously convicted of Robbery in the Second Degree and Burglary in the First

Degree a class B felony under criminal number Cr. 14-1-232K, date of conviction

being January 7, 2015, while she was represented by counsel, and the instant

offense, or any included felony offense, was committed within 10 years of that prior

conviction.

COUNT 2 (C18020179)

On or about the July 20, 2018, in the County and State of Hawaii, MALIA

KAALANEO LAJALA, KRYSTLE LYNN FERREIRA, AND JORGE ALLEN

PAGAN-TORRES, as accomplice(s), did intentionally engaged in conduct which,

under the circumstances as the person believed them to be, constituted a

substantial step in a course of conduct intended to culminate in the person’s

commission of Murder in the First Degree, as an accomplice, being that he/she

with the intent to promote or facilitate the commission of Murder in the First Degree

MALIA KAALANEO LAJALA, KRYSTLE LYNN FERREIRA, AND JORGE ALLEN

PAGAN-TORRES, either: did intentionally aid, agree, and/or attempt to aid another

person identified as Justin Waiki, in planning and/or committing Murder in the First

Degree and/or that MALIA KAALANEO LAJALA, KRYSTLE LYNN FERREIRA,

AND JORGE ALLEN PAGAN-TORRES, did intentionally fail to make reasonable

efforts to prevent the commission of Murder in the First Degree after having a legal

duty to prevent the commission of Murder in the First Degree, said crime of Murder

in the First Degree being that they intentionally causes the death of a

law enforcement officer, who was later identified as Sergeant Bryan Tina, Officer

Kevin Brodie, Officer Wayne Kennison, and/or Officer Patrick Aruello, arising out

of the performance of their official duties, intending such person to be a law

enforcement officer, thereby committing the offense of Murder in the First Degree,

in violation of Section(s) 702-222, 705-500(1)(b), and 707-701(1)(b), Hawaii

Revised Statutes, as amended.

As to MALIA KAALANEO LAJALA, if she is convicted of this offense or

included felony offense of Accomplice to Attempt Murder in the Second Degree,

Assault Against a Law Enforcement Officer in the First Degree, Assault Against a

Law Enforcement Officer in the Second Degree, Assault in the First Degree,

Assault in the Second Degree, MALIA KAALANEO LAJALA may be sentenced to

a mandatory minimum period of imprisonment without the possibility of parole in

accordance with Section 706-606.5 of the Hawai’i Revised Statutes where he/she

is a repeat offender as he was previously convicted of Robbery in the Second

Degree and Burglary in the First Degree a class B felony under criminal number

Cr. 14-1-232K, date of conviction being January 7, 2015, while she was

represented by counsel, and the instant offense, or any included felony offense,

was committed within 10 years of that prior conviction.

 COUNT 3 (C18020295)

On or about July 17-20, 2018, in the County and State of Hawai`i, MALIA

KAALANEO LAJALA, KRYSTLE LYNN FERREIRA, AND JORGE ALLEN

PAGAN-TORRES, as either the accomplice being that he/she with the intent to

promote or facilitate the commission of Place to Keep Pistol and/or Revolver,

he/she did either: (1) intentionally aid, agree, and/or attempt to aid another person

identified as Justin Waiki, in planning and/or committing Place to Keep Pistol

and/or Revolver, and/or (2) that he/she, did intentionally fail to make reasonable

efforts to prevent the commission of Place to Keep Pistol and/or Revolver, said

crime being that Justin Waiki, who was not licensed to carry a pistol or revolver

and ammunition pursuant to Section 134-9, or MALIA KAALANEO LAJALA,

KRYSTLE LYNN FERREIRA, AND JORGE ALLEN PAGAN-TORRES as

principles, who were not licensed to carry a pistoal or revolver and ammunition

pursuant to Section 134-9, and, except as provided in Section 134-5, being over

eighteen and while not engaged in hunting and/or target shooting, did intentionally

and/or knowingly possess an item, and that he/she intentionally, knowingly, or

recklessly disregarded a substantial and unjustifiable risk that such item was a

revolver, loaded and/or unloaded, operable and/or inoperable, and that he/she did

intentionally, knowingly, and/or recklessly failed to confine the firearm to his/her

place of business, residence, and/or sojourn and/or he/she intentionally,

knowingly, or recklessly failed to carry the firearm unloaded in an enclosed

container from the place of purchase to his/her place of business, residence, or

sojourn, or between these places upon a change of place of business, residence,

or sojourn, or between these places and: 1) a place of repair; 2) a target range; 3)

a licensed dealer’s place of business; 4) an organized, scheduled firearms show

or exhibit; 5) a place of formal hunter or firearm use training or instruction; or 6) a

police station thereby committing the offense of Place to Keep Pistol or Revolver,

in violation of Section 134-25(a) Hawai'i Revised Statutes, as amended.

As to MALIA KAALANEO LAJALA, if she is convicted of this offense MALIA

KAALANEO LAJALA may be sentenced to a mandatory minimum period of

imprisonment without the possibility of parole in accordance with Section 706-

606.5 of the Hawai’i Revised Statutes where he/she is a repeat offender as he was

previously convicted of Robbery in the Second Degree and Burglary in the First

Degree a class B felony under criminal number Cr. 14-1-232K, date of conviction

being January 7, 2015, while she was represented by counsel, and the instant

offense, or any included felony offense, was committed within 10 years of that prior

conviction.

COUNT 4 (C18020296)

On or about July 17-20, 2018, in the County and State of Hawai`i, MALIA

KAALANEO LAJALA, KRYSTLE LYNN FERREIRA, AND JORGE ALLEN

PAGAN-TORRES, with intent to promote and facilitate the commission of the crime

of Hindering Prosecution in the First Degree, did agree with one and/or more

persons, being either: Justin Waiki, Jamie Jason and/or Malia KAALANEO, that

they and/or one and/or more of them would intentionally engage in and/or solicit

the conduct and/or would cause and/or solicit the result specified by the definition

of the offense of Hindering Prosecuting in the First Degree, said offense being with

the intent to hinder the apprehension, prosecution, conviction and/or punishment

of another person identified as Justin Waiki, for murder in any degree, that MALIA
KAALANEO LAJALA, KRYSTLE LYNN FERREIRA, AND JORGE ALLEN

PAGAN-TORRES, did intentionally render assistance to Justin Waiki, and he/she

or another person with whom he/she conspired committed an overt act in

pursuance of the conspiracy, thereby committing the offense of Conspiracy to

Commit Hindering Prosecution in the First Degree in violation of Sections 707-701

and 705-520, Hawaii Revised Statutes, as amended.

As to MALIA KAALANEO LAJALA, if she is convicted of this offense MALIA

KAALANEO LAJALA may be sentenced to a mandatory minimum period of

imprisonment without the possibility of parole in accordance with Section 706-

606.5 of the Hawai’i Revised Statutes where he/she is a repeat offender as he was

previously convicted of Robbery in the Second Degree and Burglary in the First

Degree a class B felony under criminal number Cr. 14-1-232K, date of conviction

being January 7, 2015, while she was represented by counsel, and the instant

offense, or any included felony offense, was committed within 10 years of that prior

conviction.

COUNT 5 (C18020297; C18020298)

On or about July 17-20, 2018, in the County and State of Hawai`i, MALIA

KAALANEO LAJALA, knowingly possessed any dangerous drug,

methamphetamine and/or heroin, in any amount, thereby committing the offense

of Promoting a Dangerous Drug in the Third Degree, in violation of Section 712-

1243(1), Hawaii Revised Statutes, as amended.

Dated: Kealakekua, Hawai’i, July 23, 2018.

/S/ Kauanoe Jackson

KAUANOE A. JACKSON
Deputy Prosecuting Attorney