STATE OF MISSOURI ) The Circuit Attorney of the City of St. Louis, State of Missouri, upon information and belief, charges that

Transcription

1 STATE OF MISSOURI VS YOUNG, EILEEN N DIV #: CA#: CAUSE#: DESTINATION: GRAND JURY (AT LARGE) D E F E N D A N T I N F O R M A T I O N ADDRESS: 37XX CALIFORNIA AVE APT XX Saint Louis, MO PEDIGREE: RACE: B DOB: XX/XX/1983 HGT: 5'02" SEX: F AGE: 31 WGT: 174 ID #s: COMPLAINT#: LID: ARREST#: DIST: SLMPD OCN: ALIASES: SSNs: XXX-XX-XXXX STATE OF MISSOURI ) CITY OF ST. LOUIS ) SS COMPLAINT The Circuit Attorney of the City of St. Louis, State of Missouri, upon information and belief, charges that Count 1: Involuntary Manslaughter 1st Degree (Class C FELONY) RSMo ON 2/5/2015 Time: 3:15 PM Place: I-55 and Bates (SCC 10051) The defendant, in violation of Section , RSMo, committed the class C felony of involuntary manslaughter in the first degree, punishable upon conviction under Sections and , RSMo, in recklessly caused the death of L.W. by operating a vehicle on Interstate 55 at a speed in excess of the posted speed limit. Count 2: Assault 3rd Degree - Pursuant To Subdivisions (1), (2), (4) & (6) (Class A recklessly created a grave risk of death or serious physical injury to M.B. operating a vehicle on Page 1 09/03/2015

2 Count 3: Assault 3rd Degree - Pursuant To Subdivisions (1), (2), (4) & (6) (Class A recklessly created a grave risk of death or serious physical injury to R.P. by operating a vehicle on Count 4: Assault 3rd Degree - Pursuant To Subdivisions (1), (2), (4) & (6) (Class A recklessly created a grave risk of death or serious physical injury to A.P. by operating a vehicle on Count 5: Possession Of Controlled Substance Except 35 Grams Or Less Of Marijuana (Class C FELONY) RSMo ON 2/5/2015 Time: 3:15 PM Place: I-55 and Bates (SCC 32450) The defendant, in violation of Section , RSMo, committed the class C felony of possession of a controlled substance, punishable upon conviction under Sections and , RSMo, in possessed Heroin, a controlled substance, knowing of its presence and nature. Count 6: Possession Of Controlled Substance Except 35 Grams Or Less Of Marijuana (Class C FELONY) RSMo ON 2/5/2015 Time: 3:15 PM Place: I-55 and Bates (SCC 32450) The defendant, in violation of Section , RSMo, committed the class C felony of possession of a controlled substance, punishable upon conviction under Sections and , RSMo, in possessed Alprazolam, a controlled substance, knowing of its presence and nature. Count 7: Possession Of Up To 35 Grams Marijuana (Class A MISDEMEANOR) RSMo ON 2/5/2015 Time: Place: I-55 and Bates (SCC 32457) Page 2 09/03/2015

3 The defendant, in violation of Section , RSMo, committed the class A misdemeanor of possession of a controlled substance, punishable upon conviction under Sections and , RSMo, in that on or about February 5, 2015, in the City of St. Louis, State of Missouri, the defendant possessed marijuana, a controlled substance, knowing of its presence and nature. 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 Circuit Attorney prays that an arrest warrant be issued as provided by law. Jennifer M. Joyce Circuit Attorney of the City of St. Louis, State of Missouri By (Original Signed) Assistant Circuit Attorney Page 3 09/03/2015

4 PROBABLE CAUSE STATEMENT DATE: September 3, 2015 I, Scott Sailor, knowing that false statements on this form are punishable by law, state that the facts contained herein are true. 1. I have probable cause to believe that Eileen N Young, a Black Female DOB: XX/XX/83 Age: 31, committed one or more criminal offense(s). Count 1: Involuntary Manslaughter In The First Degree (Class C FELONY) RSMo ON 2/5/2015 Time: 3:15 PM Place: I-55 and Bates (SCC 10051) Count 2: Assault 3rd Degree (Class A MISDEMEANOR) RSMo ON 2/5/2015 Time: 3:15 PM Place: I-55 and Bates (SCC Count 3: Assault 3rd Degree (Class A MISDEMEANOR) RSMo ON 2/5/2015 Time: 3:15 PM Place: I-55 and Bates (SCC Count 4: Assault 3rd Degree (Class A MISDEMEANOR) RSMo ON 2/5/2015 Time: 3:15 PM Place: I-55 and Bates (SCC Count 5: Possession Of A Controlled Substance (Class C FELONY) RSMo ON 2/5/2015 Time: 3:15 PM Place: I-55 and Bates (SCC 32450) Count 6: Possession Of A Controlled Substance (Class C FELONY) RSMo ON 2/5/2015 Time: 3:15 PM Place: I-55 and Bates (SCC 32450) Count 7: Possession Of Up To 35 Grams Marijuana (Class A MISDEMEANOR) RSMo ON 2/5/2015 Time: Place: I-55 and Bates (SCC 32457) 2. The facts supporting this belief are as follows: The defendant drove a business located in the area of I-55 and Germania St. to pick up the four victims Victim R.P. got into the front passenger seat, Victim L.W. was seated in the rear passenger seat, Victim M.B. was seated in the middle back seat, and Victim A.P. was in the driver s rear seat. The defendant drove the vehicle onto I-55 travelling northbound. The defendant and Victim R.P. began arguing while the defendant was driving. While travelling north a short time later, near Bates Ave., the defendant stated that she was going to run the car into the median wall. A short time later the vehicle while travelling in excess of the speed limit, veered towards the center median wall and struck it head on causing the vehicle to overturn. Victim L.W. was thrown from the inside rear of the vehicle and struck the windshield causing his death. Victim M.B. was also transported to the hospital because of her injuries. Inside the vehicle, the defendant was in possession of a grey powder that was later identified by the lab as heroin. The defendant was also in possession of a yellow tablet that was later identified by the lab as alprazolam. The defendant was also in possession of a green leafy substance that was later identified by the lab as marijuana. Scott Sailor (Original Signed) Page 4 09/03/2015

5 PRINT NAME SIGNATURE Page 5 09/03/2015