Page 1 of 7 Pages Crystal Lake Police its)
UNITED STATES OF AMERICA
STATE OF ILLINOIS, COUNTY OF MCHENRY
INTHE CIRCUIT COURT OF THE TWENTY SECOND JUDICIAL CIRCUIT
COMPLAIN;
PEOPLE OF THE STATE OF ILLINOIS OR
EASE NUMBER
‘A MUNICIPAL CORPORATION SAONUMBER
~vs~ ‘DOCUMENT CONTROL NUMBER
—_CLPD.-19-007922_
Andrew T Freund REPORT NUMBER
DEFENDANT -
CITY, VILLAGE, TOWNSHIP File Stamp Here
AND CODE
COUNT ONE
In the name and by the authority of the People ofthe State of Iinois, Detective Bitel hereinafter
called the complainant, on oath charges that on or about the _1Sth__dayof April, 2019 ___in McHenry County,
Minos Andrew TT Freund hereinafter called the defendant commited the offense of
First Degree Murder
in violation of Chapter _720_ Act Section __9-I(@X1) of the Ilinois Compiled Statutes in that said Defendant
without lawful justification, forced A.P. (minor child, D.O.B, 10/14/2013) to remain in a cold shower for an extended period
of time and/or struck A.P. on or about his body, knowing said acts would cause the death of A.F., thereby causing the death of
AR
antrary to the form of the Statute in such ease made and provided and against the peace and digaity ofthe People of the State of Ilinois
Felony [Misdemeanor Class__M
COUNT TWO
In the name and by the authority of the People of the State of Illinois__Detective Eitel__ hereinafter
called the complainant, on oath charges that on or about the_1Sth__day of ____April, 2019 __ in McHenry County,
in Andrew T Freund hereinafter called the defendant committed the offense of
First Degree Murder
in violation of Chapter 720 _ Act 5 _ Section __91(2)(2) _ of the Illinois Compiled Statutes in that said Defendant
‘without legal justifiation, forced A.F, (minor child, DOB 10/14/13), to remain ina cold shower for an extended period of
time and/or struck AF. on or about his body, knowing that said acts created a strong probability of death or great bodily harm
AR,
Contrary to the form of the Statute in such case made and provided and against the pence and dignity of the People of the State of Iinois,
[Felony C)Misdemeanor class _M
RIGHTS EXPLAINED
pate
DATE_£224
(VERIFICATION ON LAST PAGE)
omPage 2 of 7 Pages Crystal Lake Police 13)
TAF Z4I0
Cuse Number
‘SAO Naber
“Bova Const None |
COUNT 3 CLPD-19-007922
Report Number
In the name and by the authority of the People of the State of Illinois Detective Eitel
called the complainant, on oath charges that on or about the _1Sth
Ilinois Andrew T Freund
hereinafter
day of __April, 2019 in MeHenry County,
hereinafter called the defendant committed the offense of
First Degree Murder
in violation of Chapter _720__ Act Section __9-1(@)(3)__ of he Illinois Compiled Statutes in that said Defendant
‘without lawful justification, while committing or attempting to commit a forcible felony, Aggravated Battery in violation of
Section 12-3.05(b)(1) of Act 5 of Chapter 720 of the Illinois Compiled Statutes, forced AF. (minor child, D.O.B. 10/14/2013)
to remain in a cold shower for an extended period of time and/or struck A-F. on or about his body thereby causing the death of
AR,
Contrary to the form of the Statute in such case made and provided and against the peace and dignity ofthe People ofthe State of Iinots
Felony [Misdemeanor Class M
COUNT 4
In the name and by the authority of the People of the State of Illinois Detective i hereinafter |
called the complainant, on cath charges tha ono abou the 15th dayot Ap, 2019 ia Mefewy Couns,
Illinois Andrew T Freund
hereinafter called the defendant committed the offense of
First Degree Murder
in violation of Chapter 720 _ Act Section __9-I(@)(3)__of the Illinois Compiled Statutes in that said Defendant
without lawful justification, while committing or attempting to coramita forcible felony, Aggravated Battery, in violation of
Section 12-3.05(6)(2) of Act $ of Chapter 720 of the linois Compiled Statutes, forced A.F. (minor child, D.O.B. 10/14/2013)
to remain ina cold shower for an extended period of time andlor struck A.F. on or about his body thereby causing the death of,
AF.
Contrary tthe form ofthe Statute in such case made and provided and aginst the peace and diglty ofthe People of the State of
DB Felony Misdemeanor Class__M
RIGHTS EXPLAINED
BY 4é__
DATEL
(VERIFICATION ON LAST PAGE)
fePage 3 of 7 Pages Crystal Lake Potice 3)
14240
‘Case Number
Tardicion NemeiCade
‘SAO Namber
“Donat Cal aba
COUNT 5 ccurb.19.007922
Ta Nand
Ine name and by the authority of the People ofthe Sate of ios
hereinafter
called the complainant, on oath charges that on or about the__1Sth day of __April, 2019) in McHenry County,
Miinois ‘Andrew T Freund
Det
Eitel
hereinafter called the defendant committed the offense of
First Degree Murder
in violation of Chapter 720 Act.
Section __9-1(@\(3)__of the llinois Compiled Statutes in that said Defendant
‘without lawful justification, whil
‘committing a forcible felony, Aggravated Domestic Battery, in violation of Section
12:3.3(a) of Act 5 of Chapter 720 of the Illinois Compiled Statutes, forced A.F. (minor child, D.O.B. 10/14/2013) to remain
‘in a cold shower for an extended period of time and/or struck A.F. on of about his body thereby causing the death of A.F,
Jcontrary to the form ofthe Statute i
such case made and provided and against the peace and dignity of the People of the State of Illinois
Felony [Misdemeanor Class __M.
COUNT 6
In the name and by the authority of the People of the State of Ilinois,
alled the complainant, on oath charges that on or about the,
Minois
Detective Eitel hereinafter
15th
day of April 2019 in McHenry County,
Andrew T Freund
hereinafter called the defendant committed the offense of
Aggravated Battery
in violation of Chapter _720_ Act
Section __12-3.05(b\(1)_of the Illinois Compiled Statutes in that said Defendant
in committing a battery, knowingly and without legal justification forced A.F. a minor child under 13 years of age (D.OB.
10/14/2013) to remain in a cold shower for an extended period of time and/or struck A.F. on or about his body thereby
‘causing great bodily harm in that it caused A.F.'s death,
‘ontrary (othe form ofthe Statute in such case made and provided and agzinst the peace and digni
ofthe People ofthe
[Felony DMisdemeanor
Class X
RIGHTS EXPLAINED
(VERIFICATION ON LASTPAGE) ay gees
DATE Zz
w