13 “ 15 16 a 1 20 aa 22 23 24 25 26 LACEY LINCOLN Deputy County Attorney FILED act 26,2018 Missoula County sluloe Court [STATE OF MONTANA, Buh sn ‘Rt 0-261- 0000018 Jape Lande Howey KIRSTEN H. PABST Missoula County Attomey Missoula County Courthouse Missoula, Montana 59802 (408) 258-4737 ATTORNEYS FOR PLAINTIFF IN THE JUSTICE COURT OF THE STATE OF MONTANA IN AND FOR THE COUNTY OF MISSOULA STATE OF MONTANA, Plaintitt,| Bepactment No. ca COMPLAINT JANGELA JO ELANOR JOAN COBLER, Defendant, LACEY LINCOLN, Deputy County Attorney, deposes and says that on, about, or between the 1st day of April, 2014 and the 24" day of July, 2018, in Missoula County, the Defendant committed the offenses of COUNT I: CHILD CRIMINAL, ENDANGERMENT, a Felony, in violation of Montana law, namely: Mont. Code Ann. 45-5- 628(1)(f), punishable by 10 years MSP and/or $50,000 fine; COUNT Il: ASSAULT ON A MINOR, a Felony, in violation of Montana law, namely: Mont. Code Ann, 45-5-212, punishable by 5 years MSP and/or $50,000 fine; COUNT Ill: ASSAULT ON A MINOR, a Felony, in violation of Montana law, namely: Mont. Code Ann. 45-5-212, punishable by 5 years MSP and/or $50,000 fine; COUNT IV: ASSAULT ON A MINOR, a Felony, in violation of Montana law, namely: Mont. Code Ann. 45-5-212, punishable by 5 years MSP* || and/or $50,000 fine; COUNT V: ASSAULT ON A MINOR, a Felony, in violation of Montana law, namely: Mont, Code Ann. 45-5-212, punishable by 5 years MSP and/or $50,000 fine; COUNT VI: ASSAULT ON A MINOR, a Felony, in violation of Montana law, s ||Mamely: Mont. Code Ann. 45-5-212, punishable by 5 years MSP and/or $50,000 fine; 6 || COUNT Vil: ASSAULT ON A MINOR, a Felony, in violation of Montana law, namely: Mont. Code Ann, 45-5-212, punishable by 5 years MSP and/or $50,000 fine; COUNT VIII; ENDANGERING WELFARE OF CHILDREN - 1ST OFFENSE, a Misdemeanor, in 10 |] Violation of Montana law, namely: Mont. Code Ann. 45-5-622(1)[tst], punishable by 6 11 |] months MCDF and/or $500 fine; COUNT IX: ENDANGERING WELFARE OF CHILDREN 12 |]-2ND OR SUBSEQUENT OFFENSE, a Misdemeanor, in violation of Montana law, * namely: Mont. Code Ann. 45-5-622(1)[2nd], punishable by 6 months MCDF and/or $1,000 “ fine. 15 ae The facts constituting the offense are: n COUNT |: On, about, or between the 1* day of April, 2014 and the 23” day of July, 28 || 2018, the above-named Defendant purposely, knowingly, or negligently caused substantial tisk of death or serious bodily injury to a child under 14 years of age by failing to attempt to 20 Provide proper nutrition for a child, resulting in a medical diagnosis of nonorganic failure to 2 22 || thrive. 2 COUNT II: On or about the 23rd day of July, 2018, the above-named Defendant 4 || purposely or knowingly caused reasonable apprehension of bodily injury in Jane Doe, to wit: striking with her hand, and at the time of the offense, Jane Doe was under 14 years of age and the Defendant was 18 years of age or older.Fr rr 2 Fey ry 18 16 uv we 1 a 22 23 24 25 26 2 20 COUNT Il: On or about the 19th day of July, 2018, the above-named Defendant purposely or knowingly caused reasonable apprehension of bodily injury in Jane Doe, to wit: repeatedly striking with her hand, and at the time of the offense, Jane Doe was under 14 years of age and the Defendant was 18 years of age or older. COUNT IV: On or about the 13th day of July, 2018, the above-named Defendant purposely or knowingly caused reasonable apprehension of bodily injury in Jane Doe, to wit: forcing dog to bite Jane Doe's forearm, and at the time of the offense, Jane Doe was under 14 years of age and the Defendant was 18 years of age or older. COUNT V: On or about the 12th day of July, 2018, the above-named Defendant purposely or knowingly caused reasonable apprehension of bodily injury in Jane Doe, to wit: shoves down a blindfolded Jane Doe into furniture, and at the time of the offense, Jane Doe was under 14 years of age and the Defendant was 18 years of age or older. COUNT VI: On, about, or between the 1st day of April, 2014 and the 23" day of July, 2018, the above-named Defendant purposely or knowingly made physical contact of an insulting or provoking nature with Jane Doe, to wit: duct taping her mouth, and/or arms and legs to the bed or floor, and at the time of the offense, Jane Doe was under 14 years of age and the Defendant was 18 years of age or older. COUNT VII: On, about, or between the 1st day of April, 2014 and the 23" day of, July, 2018, the above-named Defendant, in an act separate and distinct from Count VI, purposely or knowingly made physical contact of an insulting or provoking nature with Jane Doe, to wit: forcing her to eat vomit, and at the time of the offense, Jane Doe was under 14 years of age and the Defendant was 18 years of age or older.