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15CR01802

Div 17

IN THE DISTRICT COURT OF JOHNSON COUNTY, KANSAS


STATE OF KANSAS,
Plaintiff,
COMPLAINT

VS.

No.

ANTHONY MONROE TOWNSEND,


Defendant.
STATE OF KANSAS, JOHNSON COUNTY, ss:
I, Ryan W. Walkiewicz, Assistant District Attorney of said County, upon information and
belief, state under oath to the court that
ANTHONY MONROE TOWNSEND
did the following:
COUNT I - That on or about the 1st day of August, 2015, in the County of Johnson and State of
Kansas, ANTHONY MONROE TOWNSEND did then and there unlawfully, feloniously, and
knowingly cause great bodily harm to another person or disfigurement of another person, to-wit:
Robert Dyche, a severity level 4 person felony, in violation of K.S.A. 21-5413(b), K.S.A. 21-6804
and K.S.A. 21-6807. [Aggravated Battery]
COUNT II Further, that on or about the 1st day of August, 2015, in the County of Johnson and
State of Kansas, ANTHONY MONROE TOWNSEND did then and there unlawfully, feloniously,
and knowingly cause great bodily harm to another person or disfigurement of another person,
to-wit: Cindy Dyche, a severity level 4 person felony, in violation of K.S.A. 21-5413(b), K.S.A.
21-6804 and K.S.A. 21-6807. [Aggravated Battery]
COUNT III Further, that on or about the 1st day of August, 2015, in the County of Johnson
and State of Kansas, ANTHONY MONROE TOWNSEND did then and there unlawfully, willfully,
feloniously and without authority enter into or remain within a building, in which there was some
human being, to-wit: Robert Dyche and/or Cindy Dyche, with the intent to commit a felony, a
severity level 5 person felony, in violation of K.S.A. 21-5807(b), K.S.A. 21-6804 and K.S.A. 216807. [Aggravated Burglary]
I declare under penalty of perjury that the foregoing is true and correct.
Executed by and on this date.

/s/ RYAN WALKIEWICZ


Dated: 08/03/15

_____________________________
Ryan W. Walkiewicz/dmh #23486
Assistant District Attorney
100 North Kansas Avenue
Olathe, Kansas 66061
(913)715-3000

Clerk of the District Court, Johnson County Kansas


08/03/15 10:50am JL

*
*
*

WITNESSES:
Sgt. Hall
Ofc. Rhomberg
Ofc. G. Lozano
Ofc. J. Nahrebeski
Ofc. J. Pennington
Ofc. T. Gist
Det. V. Henson
Det. T. Gorman
Robert Dyche
Cindy Dyche
R.E.D. (Under 18 YOA)
C.J.D. (Under 18 YOA)
Waltor Bator
Linda Bator
Althea Townsend
James Townsend Jr.
Med-Act Personnel
Overland Park Regional Personnel
911 Dispatch Personnel

Clerk of the District Court, Johnson County Kansas


08/03/15 10:50am JL

IN THE DISTRICT COURT OF JOHNSON COUNTY, KANSAS


Criminal Department
State of Kansas
Vs.
ANTHONY MONROE TOWNSEND, Defendant
INITIATION OF ACTION
Offense(s) Alleged:
21-5413(b)(1)(A
21-5413(b)(1)(A
21-5807(b)

AGG BATTERY/GREAT BODILY HARM


AGG BATTERY/GREAT BODILY HARM
AGGRAVATED BURGLARY

_X_ The Court finds from the complaint and affidavit that there is probable cause to believe
both that a crime has been committed in Johnson County, Kansas and that the defendant
committed the same.
Defendant's bond is set at $250,000 cash or surety with the following conditions:
HOUSE ARREST WITH GPS
NO USE OF ILLEGAL DRUGS OR CONTROLLED SUBSTANCES/SUBMIT TO TESTING
WHEN DIRECTED BY COURT
NO ALCOHOL
NO FIREARMS
NO CONTACT VICTIM(S)/WITNESSES, THEIR RESIDENCE/ EMPLOYMENT
WHETHER OR NOT THEY POST BOND

/s/ DANIEL W VOKINS


08/03/15
Judge of the District Court

Clerk of the District Court, Johnson County Kansas


08/03/15 10:50am JL

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