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TEONNA BROWN * * * * *

* * * *


MEMORANDUM OF PLEA AGREEMENT NOW COMES the State of Maryland, by Scott D. Shellenberger, States Attorney for Baltimore County and Rachel Cogen, Assistant States Attorney for Baltimore County, and Leanne Lauenstein, Assistant States Attorney for Baltimore County, who enter into this written plea agreement with the above named Defendant with the advise of her counsel Timothy Knepp, Esq. 1. The Defendant is charged in a five-count indictment stemming from the April 18, 2011, assault of Christopher Polis, aka Chrishtalynn Polis at the McDonalds Restaurant located at 6315 Kenwood Avenue, in Baltimore County. 2. The Defendant will be qualified under oath to insure that she fully understands that her guilty plea is free and voluntary. 3. The Defendant will read and sign a copy of this plea agreement acknowledging that her plea is voluntary and that the facts in support thereof are true and correct. 4. The Defendant will plead guilty to the First Count charging First Degree Assault, and the Third Count charging Hate Crime. The maximum

sentence for First Degree Assault is twenty-five years incarceration, and the maximum sentence for 5. the Hate Crime is ten years incarceration.

Upon the Courts acceptance of the guilty plea the State will Nolle Pros the balance of counts.


The State will recommend a sentence of 10 years to the Division of Corrections, with all but five years to be suspended, and a period of probation to be determined by the court. Counsel for the Defense is free to argue for whatever sentence he feels is appropriate.

STATEMENT OF FACTS IN SUPPORT By way of background: the victim in this case was born with the name Christopher Polis. She now goes by the name Chrissy and identifies herself as a woman, although she was physiologically born as a male. She has identified herself as a woman throughout her entire adulthood, and much of her childhood. At about 7:50 pm, on April 18, 2011, Chrissy Polis entered the McDonalds restaurant at 6315 Kenwood Avenue in the Rosedale area of Baltimore County. The Defendant and her 14-year-old friend were at the restaurant eating when the victim walked in. They watched the victim, who was dressed as a woman, enter the womens bathroom. Immediately, they got up from their seats and complained to management of the restaurant that a man was using the womens bathroom. Both the Defendant and the Juvenile then approached the victim at the door to the restroom and confronted her. An argument ensued and the Defendant and the Juvenile became physical with Ms. Polis. The Defendant and the Juvenile repeatedly punched and kicked the victim, including at times punching and kicking her in the head as she lay on the floor. This Defendant dragged Ms. Polis by her hair through the restaurant and continued to beat her. The manager of the McDonalds, Derrick Jones, attempted on numerous occasions to escort the Defendant and the Juvenile outside. Mr. Jones pushed the Defendant and Juvenile away from the victim and at times they actually left the restaurant and then returned to continue the assault. At one point during the assault, Ms. Vicki Thoms, entered the McDonalds. When she observed the victim being dragged and beaten, Ms. Thoms attempted to intervene on behalf of the victim. The Juvenile and the Defendant argued with Ms. Thoms, and the Juvenile hit Ms. Thoms in the face. An employee of the McDonalds videotaped a portion of the assault on his cell phone. Ms. Polis eventually had a seizure during the assault. Finally the Defendant and the Juvenile fled the location only after being urged to leave by McDonalds employees because the police were on their way.

If called to testify the Victim would identify Teonna Brown as one of the persons who kicked and beat Ms. Polis with the intent to cause serious physical injury. The beating was motivated by the victims sexual orientation. Videotape of the surveillance video from McDonalds as well as the video that was recorded by an employee of McDonalds are incorporated into the Statement of facts and entered into evidence as States Exhibits.


RACHEL COGENN Assistant States Attorney

TIMOTHY KNEPP Counsel for the Defendant

LEANNE LAUENSTEIN Assistant States Attorney