Criminal Court of the City of Syracuse Felony Complaint ta eines People of te State of New York vs. Rayshon Works Defendant 08/04/1989 pos State ofNew York) County of Onondaga) 1 PO. R. Thompson #420 the complainant herein, accuse Rayshon Works the DEFENDANT in this action, and charge, upon information and belief that on or about 26han16 atabout 19:30 in the aftemoon a 609 Kirkpatrick St. #3 CITY OF SYRACUSE, COUNTY OF ONONDAGA, STATE OF NEW YORK, the DEFENDANT committed the offense of Aggravated Animal Cruelty in violation of Section 3538 sub. ofthe Agriculture and Marketing Law. The source of Complainants information and belie are derived from: Towit: ‘On the above stated date, time, and location, the above named defendant, Rayshon Works, did with no justifiable purpose intentionally killed and intentionally caused serious physical injury to @ companion animal, that animal being a brown male pit boll named Cain with aggravated cruelty during a domestic dispute and after kicking the dog in the stomach. For purposes of this section, "aggravated cruelty" shall mean conduct which is intended to cause extreme pain and is done or carried out in an especially depraved or sadistic manner. The defendant did so cause serious physical injury and intentionally killed Cain by taking a sharp instrument and stabbing Cain one time causing a .Scm, cireular, deep puncture ‘wound found to penetrate 8-10cm on the cranial aspect of the right shoulder causing significant muscle damage and hemorrhage consistent with a penetrating stab wound as indicated from the Necropsy report from the Veterinary Medical Center. The actions of the defendant did cause a severe hemorrhage secondary to the wound in the cranial right shoulder causing death. Said actions by the defendant caused Cain extreme pain and was done in an especially depraved manner as the dog walked 3 blocks from his home at 609 Kirkpatrick St. bleeding out profusely, while laying down several times until he finally lays down in the rear of 914 Kirkpatrick St. laying up against the fence and dies. Said actions by the defendant constitute aggravated animal cruelty. Aggravated animal cruelty is a class E Felony. =o 8 23 \FHEREFORE | REQUEST THAT CRIMINAL PROCESS BE ISSUED TO COMPEL THE DEFENDANT TO ANSWER THE Ge septesaivaccisarion OB Bn ytesto mene prions Cas Amide secon 21045 ofthe Pn Lavoe Sag OB - AFFIRMED UNDER PENALTY OF PERJURY this ey “ ath dayor Febuary 20[u & ® 20.%¢c. FIZ ‘COMPLAINANTRa 16137792 Cheng Cotmy Diet Anrmey Misdemeanor Information Docket Criminal Court of the City of Syracuse siatoftiew York) People ofthe Sate of New York County of Onondaga) fe Rayshon Works Defendant 0810471993 os 1.0. R.Thompson #420 thecomplainant herein residingat” S178 Se St, Syaoise NY 13202 accuse Rayon Works the DEPENDANT in hisaeton, and charge that on or about the 2th ayo tansay «2016 «at_—_—6OSKikpaick 3 inthe CITY OF SYRACUSE, COUNTY OF ONONDAGA, STATE OPNEW YORK, at about 11:19 inthe forenoon, said DEFENDANT did commit the misdemeanor, of Unjustifiable animal eruelty-ailed to provide proper medical attentio ‘contrary to the provisions oFSection 353 ofthe Agriculture and Marketing Law of the State of New York by intentionally Law Section: Overdriving. torturing and injuring animals; failure to provide proper sustenance. A person who overdrives, overloads tortures or envelly beats or unjustifiably injures, maims, mutilates or kills any animal, whether wild or tame, and whether belonging to himself orto another. or deprives any animal af necessary sustenance, food or drink, ornegleets or refuses to furnish it such sustenance or drink, or causes, procures or pemnits any animal to be overdriven, overloaded, ortured, cruelly beaten, or unjustifiably injured, maimed. mutilated or killed, orto be deprived of necessary food or érink, or who willfully sets on foot, instigates, engages in, orn any way furhers any act of cruelty to any animal, or any act tending to produce such ervelty. is puilty of # class A misdemeanor. To wit: On the above stated date, time, and location, the above named defendant, Rayshon Works, did fil to provide proper medica! attention to ‘brown male pit bull named Cain, by refusing to fursish Cain with such medical care after stabbing the dog i the right shoulder causing a Sem circular, deep puncture wound about 8-10em deep which caused 2 severe subcutaneous hemomtage which led to the death of the dog as shown in the Necropsy report provided by the veterinary medical center. The defendant did such setions| purposefully and after causing sald injury filed to bring the dog to get necessary emergency medical attention. The defendants actions tid cause the dog prolonged and signifieant pain and suffering asthe dog traveled 3 block while bleeding profusely, laying down in the snow several times and finally resting in the rear yard of 914 Kirkpatrick St. against a fence and dies, ‘Animal cruelty- failure to provide proper medical care is Class A misdemeanor. =< & 23 Coe ee re = ne ; ; Wasa gn and dived fom annexed fi of SByKo othe 4 day of February 2016 or police investigation. 3 Pan Reroxe 1 REQUEST THATCCRIMINAL PROCESS BE ISSUED TO COMPEL THE DEFENDANT T0 ANSWER THE “SFOWBSAID ACCUSATION. NOTE: Fplse FRements made herein re punishable as @ Class A misdemeanor pursuant to section 21045 ofthe Penal Law ofthe state ot New York AFFIRMED UNDER PENALTY OF PERJURY this th dayof February 2016 Lia See ‘COMPLAINAN