IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY COMPLAINT
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1 IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY Police# Prosecutor# CR OCN# B STATE OF MISSOURI COMPLAINT 6430 Jackson Ave. Kansas City, MO DOB: 11/18/1959; Race/Sex: B/M; SS# Defendant. Count I. Assault 1st Degree Or Attempt - Serious Physical Injury Or Special Victim ( 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 Assault in the First Degree, punishable upon conviction under Section , RSMo, in that on or about January 13, 2017, in the County of Jackson, State of Missouri, the defendant shot at, and such conduct was a substantial step toward the commission of the crime of attempting to kill or cause serious physical injury to., and was done for the purpose of committing such assault, and in the course thereof inflicted serious physical injury on 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. An individual convicted and sentenced for this offense shall not be eligible for parole until eighty-five percent of the sentence is served.
2 THE STATE OF MISSOURI 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 January 13, 2017, in the county of Jackson, State of Missouri, the defendant committed the felony of Assault 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 Assault in the First Degree by, with and through, the knowing use, assistance and aid of a deadly weapon. 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. The range of punishment for the offense of Armed Criminal Action in violation of section RSMo. as a second offense is imprisonment in the custody of the Missouri Department of Corrections for a term of years not less than five (5) years without eligibility for parole, probation, conditional release or suspended imposition or execution of sentence for a period of five (5) calendar years. The range of punishment for the offense of Armed Criminal Action in violation of section RSMo. as a third offense is imprisonment in the custody of the Missouri Department of Corrections for a term of years not less than ten (10) years without eligibility for parole, probation, conditional release or suspended imposition or execution of sentence for a period of ten (10) calendar years. Any punishment imposed pursuant to section RSMo. shall be in addition to any punishment provided by law for the crime committed by, with, or through the use, assistance, or aid of a dangerous instrument or deadly weapon. 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. law. Wherefore, the Prosecuting Attorney prays that an arrest warrant be issued as provided by
3 THE STATE OF MISSOURI JEAN PETERS BAKER Prosecuting Attorney Jackson County, Missouri by, Faiza H. Alhambra (MO# 62280) Assistant Prosecuting Attorney 415 East 12th Street Floor 7M Kansas City, Missouri (816) WITNESSES: DET Dawn M. Jones, 1125 Locust, Kansas City, MO DET David D. Kissee, 1125 Locust, Kansas City, MO DET Dawn M. Minor, 1125 Locust, Kansas City, MO PO Slade A. Whetro, 1125 Locust, Kansas City, MO 64106
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IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI AT KANSAS CITY COMPLAINT
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