Fax: (620) 230-585 steven.
. FILED .... SUBSCRlBED TO AND SWORN TO before me this "£ "q-day of March,
FILED DISTRICT COURT PRATT COUUTY, KS Steven W. Wilhoft #15513 Assistant Attorney General Criminal Litigation Division 821 N. Broadway Pittsburg, KS 66762 Tel: (620) 230-5824 Fax: (620) 230-585 steven.
[email protected]
Zill? flRR 2 Pr7 Y 08
ClPf3vz- ~~d
IN THE DISTRlCT COURT OF PRATT COUNTY, KANSAS 30th JUDICIALDISTRlCT
STATE OFKANSAS,
Plaintiff,
Case No. 2017 CR v.
ALEX BRIDGES DEATON
Defendant.
COMPLAINT I INFORMATION COMES NOW the State of Kansas, by and through Derek L. Schmidt, Kansas Attorney General, Steven W. Wilhoft, Assistant Attorney General and Tracey Beverlin, Pratt County Attorney and for its Complaintiinformation against the Defendant abovenamed, alleges and states:
COUNT I On or about the 1st day of March, 2017, in Pratt County, Kansas, the defendant, Alex Bridges Deaton, did then and there unlawfully, feloniously and intentionally
commit an overt act, to-wit: shot Riley Mitchell Juel, toward the perpetration of the crime of Murder in the First Degree, as set forth in KS.A. 21-5402(a)(l) and amendments thereto, which is the unlawful, felonious, premeditated and intentional killing of a human being with the intent to commit such crime, but failed in the perpetration thereof. Attempted First Degree Murder, in violation ofK.S.A. 215402(a)(l) and 21-5301(a) and (c)(l), a level 1 person felony. COUNT2 On or about the 1st day of March, 2017, in Pratt County, Kansas, the defendant, Alex Bridges Deaton, did then and there unlawfully, feloniously and knowingly take property from the person or presence of Riley Mitchell Juel by force or threat of bodily harm while armed with a dangerous weapon and/or that bodily harm was inflicted upon Riley Mitchell Juel during the course of the robbery. Aggravated Robbery, in violation ofK.S.A. 21-5420(b), a level 3 person felony. COUNT3 On or about the 1st day of March, 2017, in Pratt County, Kansas, the defendant, Alex Bridges Deaton, did then and there unlawfully, feloniously and knowingly obtained or exerted unauthorized control over property to-wit: a Cadillac CTS, Kansas License Plate o13JVR, belonging to Riley Mitchell Juel with the intent to permanently deprive the owner of the possession, use or benefit of the owner's property and the above described property was worth at least $1,500 but less than $25,000. Theft, in 2
violation ofK.S.A. 21-5801(a)(I) and (b)(3), a level 9 person felony. COUNT4 On or about the 1st day of March, 2017, in Pratt County, Kansas, the defendant, Alex Bridges Deaton, did then and there unlawfully and willfully fail or refuse to bring the vehicle he was operating to a stop for a pursuing police vehicle after being given visual or audible signals to stop and during the police pursuit engaged in reckless driving as dermed by K.S.A. 8-1566. Fleeing or Attempting to Elude a Police Officer, in violation ofK.S.A. 8-1568(b)(I)(C) and (c)(2), a level 9 person felony. Respectfully submitted, OFFICE OF THE KANSAS ATTORNEY GENERAL
DEREK SCHMIDT
~J ~l:Jf Derek Schmidt, # 17781 Kansas Attorney General 120 SW 1Qth Avenue, 2nd Floor Topeka, Kansas 66612-1597
Ste;';n W. ~Ihoft#15513 Assistant:.A1torney General Criminal Litigation Division 821N. Broadway Pittsburg, KS 66762 Tel: (620) 230-5824 Fax: (620) 230-585 steven.
[email protected] 3
Tracey Bev Pratt County Attorney 300 S.Ninnescah Pratt, KS 67124 Tel: (620) 672-7271 Fax: (620) 672-5675 Witness List: Traci Allen Tim Beckham Robert Conde A.J. DiMartino Raymond Duke Joby Harrison Riley Mitchell Juel KBI Lab Personnel Verla King Cory Latham Michael Lind Matthew Lyon Murray Marston Bruce Mellor Paul Payne Kelly Ralston Ralph Seiple Troy Travis leffWard VERIFICATION
STATE OF KANSAS
)
) ss: COUNTY OF PRATT
)
I, Steven W. Wilhoft, oflawful age, being first duly sworn upon oath do solemnly swear, that the matters set forth in the foregoing Complaint! Information are, to the 4
best of my knowledge and belief, true. So help me God.
Steven Wil'ilhoft, #15513 Assistant Attorney General
SUBSCRlBED TO AND SWORN TO before me this "£ "q-day of March, 2017.
STATE OF KANSAS
)
) ss: COUNTY OF PRATT
)
I, Tracey Beverlin, of lawful age, being fIrst duly sworn upon oath do solemnly swear, that the matters set forth in the foregoing Complaint! Information are, to the best of my knowledge and belief, true. So help me God.
SUBSCRlBED TO AND SWORN TO before me this
2.:¥- day of March,
~ , -
TAMMY R. MAIER
Notary Public - Stat~.:.Pf Kansas
My t~ppt. Expires
5
2017.
'It>
--0 - l
