SUBSTITUTE INFORMATION IN LIEU OF INDICTMENT
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1 IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY POLICE NO. : PROSECUTOR NO. : OCN : W STATE OF MISSOURI, ) PLAINTIFF, ) vs. ) ) THU HONG NGUYEN ) 3528 St. John Ave. ) CASE NO CR Kansas City, MO ) DIVISION 9 DOB: 06/20/1972 ) Race/Sex: A/F ) ) DEFENDANT. ) SUBSTITUTE INFORMATION IN LIEU OF INDICTMENT In the Circuit Court of Jackson County, Missouri, at Kansas City, Term, In Division Number thereof, designated by the rules of said Court as Criminal Division. Count I. Causing Catastrophe ( Y ) , RSMo, committed the class A felony of causing catastrophe, punishable upon conviction under Section , RSMo, in that on or about October 12, 2015, in the County of Jackson, State of Missouri, the defendant knowingly caused a catastrophe by causing a fire at 2608 Independence Ave and that fire caused substantial damage to five or more inhabitable structures. 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.
2 State vs. Thu Hong Nguyen, Case No CR Count II. Arson 1st Degree - Causing Serious Physical Injury Or Death ( Y ) , RSMo, committed the Class A Felony of Arson in the First Degree, punishable upon conviction under Section , RSMo, in that on or about October 12, 2015, in the county of Jackson, State of Missouri, the defendant knowingly damaged a building consisting of a mixed use commercial and apartment complex located at 2608 Independence Ave., and the defendant did so by starting a fire at a time when persons were then present or in near proximity thereto and thereby recklessly placed such persons in danger of death or serious physical injury. Further as a result of such fire set by the defendant, Larry Leggio and John Mesh died. 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. Count III. Murder 2nd Degree - Felony Murder - During Perpetration/attempted Perpetration/flight From Perpetration Of A Felony, A Person Dies ( Y ) , RSMo, committed the Class A Felony of Murder in the Second Degree, punishable upon conviction under Section , RSMo, in that on or about October 12, 2015, in the County of Jackson, State of Missouri, Larry Leggio was killed by the collapse of a building at 2608 Independence Ave., a result of the perpetration of the Class A Felony of Arson in the First Degree under Section , RSMo committed by the defendant on or about October 12, 2015, in the County of Jackson, State of Missouri. 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.
3 State vs. Thu Hong Nguyen, Case No CR Count IV. Murder 2nd Degree - Felony Murder - During Perpetration/attempted Perpetration/flight From Perpetration Of A Felony, A Person Dies ( Y ) , RSMo, committed the Class A Felony of Murder in the Second Degree, punishable upon conviction under Section , RSMo, in that on or about October 12, 2015, in the County of Jackson, State of Missouri, John Mesh was killed by the collapse of a building at 2608 Independence Ave., a result of the perpetration of the Class A Felony of Arson in the First Degree under Section , RSMo committed by the defendant on or about October 12, 2015, in the County of Jackson, State of Missouri. 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. Count V. Assault 2nd Degree ( Y ) , RSMo, committed the class C felony of assault in the second degree, punishable upon conviction under Sections and , RSMo, in that on or about October 12, 2015, in the County of Jackson, State of Missouri, the defendant recklessly caused serious physical injury to Dan Werner by causing a fire at 2608 Independence Avenue. The range punishment for a class C felony is imprisonment in the custody of the Missouri Department of Corrections for a term of years not less than two (2) years and not to exceed seven (7) years; or by imprisonment for a special term not to exceed one (1) year in the county jail or other authorized penal institution; or by a fine not to exceed five thousand dollars ($5,000); or by both imprisonment and a fine. If money or property has been gained through the commission of the crime, any fine imposed may be not more than double the amount of the offender's gain from the commission of the crime up to a maximum of twenty thousand dollars ($20,000).
4 State vs. Thu Hong Nguyen, Case No CR Count VI. Assault 2nd Degree ( Y ) , RSMo, committed the class C felony of assault in the second degree, punishable upon conviction under Sections and , RSMo, in that on or about October 12, 2015, in the County of Jackson, State of Missouri, the defendant recklessly caused serious physical injury to Chris Anderson by causing a fire at 2608 Independence Avenue. The range punishment for a class C felony is imprisonment in the custody of the Missouri Department of Corrections for a term of years not less than two (2) years and not to exceed seven (7) years; or by imprisonment for a special term not to exceed one (1) year in the county jail or other authorized penal institution; or by a fine not to exceed five thousand dollars ($5,000); or by both imprisonment and a fine. If money or property has been gained through the commission of the crime, any fine imposed may be not more than double the amount of the offender's gain from the commission of the crime up to a maximum of twenty thousand dollars ($20,000). Count VII. Arson 1st Degree ( Y ) , RSMo, committed the class B felony of arson in the first degree, punishable upon conviction under Section , RSMo, in that on or about July 25, 2013, in the County of Jackson, State of Missouri, the defendant knowingly damaged a building consisting of a Nail Salon ''Nails USA'' located at 410 SW Ward Road, and defendant did so by starting a fire at a time when persons were then in near proximity thereto and thereby recklessly placed such persons in danger of death or serious physical injury. 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 B felony is imprisonment in the custody of the Missouri Department of Corrections for a term of years not less than five (5) years and not to exceed fifteen (15) years.
5 State vs. Thu Hong Nguyen, Case No CR JEAN PETERS BAKER Prosecuting Attorney Jackson County, Missouri by, /s/ Theresa E. Crayon Theresa E. Crayon (#41063) Assistant Prosecuting Attorney 415 East 12th Street 11th Floor Kansas City, MO (816) WITNESSES: 1.
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IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY
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