Cooper County Sheriff's Office Probably Cause Document

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IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI

AT

POLICE NO. : 2023-01974


PROSECUTOR NO. : 095478013
OCN:

STATE OF MISSOURI, )
PLAINTIFF, )
vs. )
)
RACHEL R ATHERTON )
200 Main St ) CASE NO. 2416-CR
Boonville, MO 65233 ) DIVISION
DOB: )
Race/Sex: W/F )
S.S.N.: )
DEFENDANT. )

COMPLAINT
WARRANT REQUESTED
Count II. Involuntary Manslaughter 1st Degree (565.024-001Y20200999.0)

The Prosecuting Attorney of the County of Jackson, State of Missouri, upon


information and belief, charges that the defendant, in violation of Section 565.024, RSMo,
committed the class C felony of involuntary manslaughter in the first degree, punishable upon
conviction under Sections 558.002 and 558.011, RSMo, in that October 26, 2023, in the County
of Cooper, State of Missouri, the defendant, an employee of the Cooper County Sheriff's
department, recklessly caused the death of Brooke L. Bailey, an individual in the custody of
the Cooper County jail, by failing to procure necessary medical attention for Brooke L.
Bailey and by discouraging other employees of the Cooper County Sheriff’s Department
from procuring such medical attention for Brook L. Bailey.
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 three (3) years and not
to exceed ten (10) years; or by a fine not to exceed ten thousand dollars ($10,000); 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.

The facts that form the basis for this information and belief are contained in the
statement(s) of facts filed contemporaneously herewith, made a part hereof, and submitted
as a basis upon which this court may find the existence of probable cause.
State vs. Rachel R Atherton, Case No.

Wherefore, the Prosecuting Attorney prays that an arrest warrant be issued as


provided by law.
JEAN PETERS BAKER
Prosecuting Attorney
Jackson County, Missouri
by,

/s/ P. Benjamin Cox


P. Benjamin Cox (#60757)
Assistant Prosecuting Attorney
415 E. 12th St., Fl 7M
Kansas City, MO 64106
(816) 881-3975
[email protected]

WITNESSES:

The State’s witnesses as of 2/29/2024 are included on the “State’s Witness List” filed
contemporaneously with this Complaint.
IN THE CIRCUIT COURT OF COOPER COUNTY, MISSOURI

POLICE NO. : 2023-01974


PROSECUTOR NO. : 095477733
OCN:

STATE OF MISSOURI, )
PLAINTIFF, )
vs. )
)
ROBYN L PFEIFFER )
200 Main Street ) CASE NO.
Boonville, MO 65233 ) DIVISION
DOB: )
Race/Sex: W/F )
S.S.N.: )
DEFENDANT. )

COMPLAINT
WARRANT REQUESTED
Count I. Involuntary Manslaughter 1st Degree (565.024-
001Y20200999.0)

The Special Prosecuting Attorney of the County of Cooper, State of Mis-


souri, upon information and belief, charges that the defendant, in violation of
Section 565.024, RSMo, committed the class C felony of involuntary manslaugh-
ter in the first degree, punishable upon conviction under Sections 558.002 and
558.011, RSMo, in that on or about October 26, 2023, in the County of Cooper,
State of Missouri, the defendant, an employee of the Cooper County Sheriff’s
department, recklessly caused the death of Brooke L. Bailey, an individual in
the custody of the Cooper County jail, by failing to procure necessary medical
attention for Brooke L. Bailey and by discouraging other employees of the
Cooper County Sheriff’s Department from procuring such medical attention for
Brook L. Bailey.

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 three
(3) years and not to exceed ten (10) years; or by a fine not to exceed ten thousand
dollars ($10,000); 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
State vs. Robyn L Pfeiffer, Case No.

more than double the amount of the offender's gain from the commission of the
crime.

The facts that form the basis for this information and belief are contained
in the statement(s) of facts filed contemporaneously herewith, made a part
hereof, and submitted as a basis upon which this court may find the existence of
probable cause.

Wherefore, the Prosecuting Attorney prays that an arrest warrant be is-


sued as provided by law.
JEAN PETERS BAKER
Prosecuting Attorney
Jackson County, Missouri
Special Prosecuting Attorney
Cooper County, Missouri
by,

/s/ P. Benjamin Cox


P. Benjamin Cox (#60757)
Assistant Special
Prosecuting Attorney
415 E. 12th St., 10th Floor
Kansas City, MO 64106
(816) 881-3975
[email protected]

WITNESSES:

The State’s witnesses as of 2/29/2024 are included on the “State’s Witness


List” filed contemporaneously with this Complaint.

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