IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY COMPLAINT. Count I. Murder 1st Degree ( Y )
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1 IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY POLICE NO. : PROSECUTOR NO. : STATE OF MISSOURI, ) PLAINTIFF, ) vs. ) DERIUS TAYLOR ) 7401 E 87th St, ) Kansas City, MO ) DOB: 07/31/1988 ) Race/Sex: B/M; ) SSN: ) DEFENDANT. ) CASE NO CR DIVISION COMPLAINT Count I. Murder 1st Degree ( Y ) The Prosecuting Attorney of the County of Jackson, State of Missouri, upon information and belief, charges that the defendant, in violation of Section , RSMo, committed the Class A Felony of Murder in the First Degree, punishable upon conviction under Section , RSMo, in that on or about April 23, 2015, in the County of Jackson, State of Missouri, the defendant after deliberation, knowingly caused the death of Dominique Stafford by shooting him. The range of punishment for a class A felony is imprisonment in the custody of the Missouri Department of Corrections for a term of years not less than ten (10) years and not to exceed thirty (30) years, or life imprisonment. Count II. Armed Criminal Action ( Y ) The Prosecuting Attorney of the County of Jackson, State of Missouri, upon information and belief, charges that the defendant, in violation of Section , RSMo, committed the Felony of Armed Criminal Action, punishable upon conviction under Section , RSMo, in that on or about on or about April 23, 2015, in the County of Jackson, State of Missouri, the defendant committed the felony of Murder in the First Degree charged in Count I, all allegations of which are incorporated herein by reference, and the defendant committed the foregoing felony of Murder in the First Degree by, with and through, the knowing use, assistance and aid of a deadly weapon.
2 State vs. Derius Taylor The range of punishment for the offense of Armed Criminal Action in violation of section RSMo. is imprisonment in the custody of the Missouri Department of Corrections for a term of years not less than three (3) years without eligibility for parole, probation, conditional release or suspended imposition or execution of sentence for a period of three (3) calendar years. Count III. Robbery 1st Degree ( Y ) The Prosecuting Attorney of the County of Jackson, State of Missouri, upon information and belief, charges that the defendant, in violation of Section , RSMo, committed the Class A Felony of Robbery in the First Degree, punishable upon conviction under Section , RSMo, in that on or about April 23, 2015, in the County of Jackson, State of Missouri, the defendant forcibly stole a necklace in the possession of Dominique Stafford, and in the course thereof the defendant was armed with a deadly weapon. An individual convicted and sentenced for this offense shall not be eligible for parole until eighty-five percent of the sentence is served. The range of punishment for a class A felony is imprisonment in the custody of the Missouri Department of Corrections for a term of years not less than ten (10) years and not to exceed thirty (30) years, or life imprisonment. The facts that form the basis for this information and belief are contained in the attached statement(s) of facts, made a part hereof and submitted as a basis upon which this court may find the existence of probable cause. Wherefore, the Prosecuting Attorney prays that an arrest warrant be issued as provided by law. JEAN PETERS BAKER Prosecuting Attorney Jackson County, Missouri by, /s/ Ashleigh A. Ragner Ashleigh A. Ragner (#63694) Assistant Prosecuting Attorney 415 E. 12th St. 11th Floor Kansas City, MO (816) ARagner@jacksongov.org
3 State vs. Derius Taylor WITNESSES: DET Daniel W. Frazier, 1125 Locust, Kansas City, MO PO Jacob Harris, 1125 Locust, Kansas City, MO DET Leland Blank, 1125 Locust, Kansas City, MO DET Mark Spiegel, 1125 Locust, Kansas City, MO DET Kristofer Oldham, 1125 Locust, Kansas City, MO DET Ray Lenoir, 1125 Locust, Kansas City, MO DET Wayne Fitzner, 1125 Locust, Kansas City, MO Sgt. Barbara Eckert, 1125 Locust, Kansas City, MO 64106
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