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COMPLAINT STATE OF MISSOURI COUNTY OF ST. CHARLES ) ) ss. ) July 30, 2013 WARRANT ORI: St.

Peters Police Dept. OCA: 13-18598 OCN: K7021365

IN THE ELEVENTH JUDICIAL CIRCUIT STATE OF MISSOURI STATE OF MISSOURI vs. CHERYL DARLENE DUDLEY 1304 Cave Springs Estates Dr. St. Peters, MO 63376 SSN: DOB: SEX: RACE: HEIGHT: WEIGHT: 489-02-3892 09/29/1976 Female White 5'00 180 LBS ) ) ) ) ) ) ) ) ) ) ) ) ) )

PA FILE NO. 183208354

Incarcerated: St. Peters P.D. X: 00 COUNT 1 Endangering welfare 2604599.) COUNT 2 Endangering welfare 2604599.) COUNT 3 Abuse Or Neglect Of COUNT 4 Endangering welfare 2604599.) COUNT 5 Endangering welfare 2604599.) COUNT 6 Endangering welfare 2604599.) COUNT 7 Endangering welfare 2604599.) COUNT 8 Endangering welfare 2604599.) COUNT 9 Endangering welfare 2604599.) of child 1st degree (MO Charge Code of child 1st degree (MO Charge Code A Child (MO Charge Code 2606499.) of child 1st degree (MO Charge Code of child 1st degree (MO Charge Code of child 1st degree (MO Charge Code of child 1st degree (MO Charge Code of child 1st degree (MO Charge Code of child 1st degree (MO Charge Code

COUNT 1 The Prosecuting Attorney of the County of St. Charles,

State of Missouri, charges that the defendant, in violation of Section 568.045, RSMo, committed the class C felony of

endangering

the

welfare

of

child

in

the

first

degree,

punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about July 29, 2013, in the County of St. Charles, State of Missouri, the defendant knowingly acted in a manner that created a substantial risk to the life and body of W.B., child less than seventeen years old, by using a rope to tie 22 month old W.B. to a garage door. COUNT 2 The Prosecuting Attorney of the County of St. Charles, State of Missouri, charges that the defendant, in violation of Section

568.045, RSMo, committed the class C felony of endangering the welfare of a child in the first degree, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about July 29, 2013, in the County of St. Charles, State of Missouri, the defendant knowingly acted in a manner that created a substantial risk to the body and health of W.B., child less than seventeen years old, by allowing five flea infested dogs to reside in the home causing twenty-two month old W.B. to have numerous flea bites on her legs, arms, and torso.

COUNT 3 The Prosecuting Attorney of the County of St. Charles,

State of Missouri, charges that the defendant, in violation of Section 568.060, RSMo, committed the class C felony of abuse of a child, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that between July 22, 2013 and July 29, 2013,

in the County of St. Charles, State of Missouri, the defendant knowingly caused. W.B., a child less than eighteen years old, to suffer from physical injury by striking W.B., on her right leg. No probation or parole until the defendant has served no less than one year of such sentence.
COUNT 4

The

Prosecuting

Attorney

of

the

County

of

St.

Charles,

State of Missouri, charges that the defendant, in violation of Section 568.045, the RSMo, welfare committed of a the in class the C felony of

endangering

child

first

degree,

punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about July 29, 2013, in the County of St. Charles, State of Missouri, the defendant knowingly acted in a manner that created a substantial risk to the life and body and health of W.B., child less than seventeen years old, by leaving unidentified prescription medication within the reach of twentytwo month old W.B.
COUNT 5

The

Prosecuting

Attorney

of

the

County

of

St.

Charles,

State of Missouri, charges that the defendant, in violation of Section 568.045, the RSMo, welfare committed of a the in class the C felony of

endangering

child

first

degree,

punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about July 29, 2013, in the County of St. Charles, State of Missouri, the defendant knowingly acted in a manner that created a substantial risk to the life and body and health of N.D., child less than seventeen years old, by leaving

unidentified prescription pills within the reach of seven year old N.D.

COUNT 6 The Prosecuting Attorney of the County of St. Charles,

State of Missouri, charges that the defendant, in violation of Section 568.045, the RSMo, welfare committed of a the in class the C felony of

endangering

child

first

degree,

punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about July 29, 2013, in the County of St. Charles, State of Missouri, the defendant knowingly acted in a manner that created a substantial risk to the life and body and health of W.B., child less than seventeen years old, by leaving a loaded rifle in a crib, an area within reach of twenty-two month old W.B.
COUNT 7

The

Prosecuting

Attorney

of

the

County

of

St.

Charles,

State of Missouri, charges that the defendant, in violation of Section 568.045, the RSMo, welfare committed of a the in class the C felony of

endangering

child

first

degree,

punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about July 29, 2013, in the County of St. Charles, State of Missouri, the defendant knowingly acted in a manner that created a substantial risk to the life and body and health of N.D., child less than seventeen years old, by leaving a loaded rifle in a crib, an area within reach of seven year old N.D.

COUNT 8 The Prosecuting Attorney of the County of St. Charles,

State of Missouri, charges that the defendant, in violation of Section 568.045, the RSMo, committed of a the in class the C felony of

endangering

welfare

child

first

degree,

punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about July 29, 2013, in the County of St. Charles, State of Missouri, the defendant knowingly acted in a manner that created a substantial risk to the life and body and health of W.B., child less than seventeen years old, by allowing twenty-two conditions.
COUNT 9

month

old

W.B.

to

reside

in

unsanitary

living

The

Prosecuting

Attorney

of

the

County

of

St.

Charles,

State of Missouri, charges that the defendant, in violation of Section 568.045, the RSMo, welfare committed of a the in class the C felony of

endangering

child

first

degree,

punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about July 29, 2013, in the County of St. Charles, State of Missouri, the defendant knowingly acted in a manner that created a substantial risk to the life and body and health of N.D., child less than seventeen years old, by allowing seven year old N.D. to reside in unsanitary living conditions.

Defendant is a prior offender under Section 558.016, RSMo, in that she has pleaded guilty to a felony as follows: On or about December 18, 2008, defendant pleaded guilty to the felony of

Hindering Prosecution of a Felony in the Circuit Court of St. Charles, County, Missouri under Cause No. 0811-CR04823.

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 Prosecuting Attorney prays that a warrant be issued as provided by law. TIMOTHY A. LOHMAR PROSECUTING ATTORNEY ST. CHARLES COUNTY, MISSOURI BY: _______________________ Rebeca Navarro-McKelvey Assistant Prosecuting Attorney Missouri Bar No. 49804