Benjamin B. Willoughby, #10716 Rich County Attorney 20 S. Main Street Randolph, Utah 84064 Telephone: (435) 793-2100 IN THE SECOND JUDICIAL DISTRICT COURT FOR THE COUNTY OF RICH, STATE OF UTAH ‘THE STATE OF UTAH ae INFORMATION Plaintiff, el CASE NO. Judge Thomas Willmore KAYLEEN RICHINS, D.O.B.: 09-19-1978, Defendant. ‘The undersigned prosecutor states on information and belief that the defendant, in Rich County, State of Utah, committed the crime of: COUNT 1 NEGLIGENT HOMICIDE, a class-A misdemeanor, in violation of Utah Code Ann, § 76-5-206, as follows: That the above named defendant, on or about September 23, 2018, acting with criminal negligence, caused the death of Z.K. This Information is based on evidence obtained from witnesses Sheriff Dale Stacey, Deputy Tom Wahlberg, and Officer Kip King.PROBABLE CAUSE STATEMENT: The undersigned prosecutor is the Rich County Attorney and has received information from the investigating officers above, and the information herein is based upon such personal observations and investigation of said officers. On September 23, 2018, fourteen year old Z.K. was shot and killed in Rich County, Utah, On that day, Z.K. was with his parents and his sister in the Eli Ridge area of the Monte Cristo Mountain Range about half way between Woodruff and Huntsville. This area is part of the Uinta-Wasatch-Cache National Forest. The family was there to see the fall leaves. ‘The family was driving through an aspen forest along a dirt road off of Highway 39 when their jeep was pierced by a single round, which caused Z.K.’s immediate death. ‘The Defendant and her family were using a paper target on a cardboard box to sight in a hunting rifle. Beyond the target was a dense forest. The Defendant was ‘unaware that there was a road through the trees behind the target. The presence of the road is not immediately apparent from where the Defendant fired the rifle. To observe the road would have required investigating what lay beyond the trees behind the target. ‘The Defendant did not investigate beyond the trees. It was this failure to properly ascertain what was downrange of the target before setting up the target and firing the shot that led to Z.K.’s death, Authorized November 5, 2018 ( for presentment and filing: AL LX Benjamin B) Willoughby Rich County Attorney