03/08/2011 14: 02 8168814314 JACKSON CO PROSECUTO PAGE 03/06

XN THE CIRCUIT COURT

OF JACKSON COIJNTY, M I S S O W
AT K&NSAS CITY

COMPLAINT
STATE OF MISSOURI[

Felieia D. Eurks
12615 E.58th St.
Kansas City, MO 64133
DOB: 11/29/1969; Race/Sex: BlF;
I
DefeadanL

-
Connt I. Domestic essanlt 1st degree serioos physical iajnry(avail(13009990)
The Prosecuting Attorney of the County o f Ja~kson,State o f Missouri, upon idomation
and belief, chmges that the defendant, inaviolaticiono f Section 565.072, RSMo, cormnittixi the
d m A felony o f domestic assault in the Oust degree, p d h a b l e upon conviction unda Section
558-011, RSMo, in that on or ahofit March 5 , 2011, in the County of Jackson, State o f Missouri,
the defendant attempted to kill or cause serious physical, injury to T.L.R by shooting at him, and
such conduct was a substantial step toward the c~mrnissiunof thc crime of attemptiuag to kill or
~auseserious physical injury to T.L.R and was done for the purpose of committing rmch assault,
and in the course thereof inflicted seriaus physical injury on T.L.R., and T.L.R. and the
defmdmi: were family or household members in that hc and the defmdant w ~ adults e who were
or had been im a continuing social relationship of a romantic or intimate nature.

Count U. Armed criminal actha, (31010990)

The Prosecuthg Attorney a f the County o f Jackban, Statc of Missouri, upon infomation
m d belief, chwges that the defendant, in violation af Section 571.0 15, RSMa, committed the
f h y of armed crim,inalaction, punishable upon oanviction under Section 571.015.1, RSMQ,in
that on or about Maroh 5, 2011, in the county of Jackson, State of Missouri, the defmdant
c o k e d the felony o f Domestic Assault in the First Degree ohaged in Camt I, all allegatiwn
~f which me incorporated herein by reference, and the defendant committed the foregoing felony
of Domestic Assault in the First Degree by, with and thrwmj the knowing use, assistance and
aid of a deadly weapon.
 PAGE 84/85

Caurat ITX. I)lischargefshoot Zirearm at or. from motor vthielelsh~otat p (31152990)

The Prosecuting Attorney of the County of Jackson, State of Missouri, upon jnfomation
and belief, charges that the defmdmt3in violation of Section 571.034 RSMo, ~ammittedthe
1 o f a w e q o n punishable y o n convi~tionunder Sections 558.01 1
class B felony a f u n l ~ w f i use
and 5'71.030.9, RSMo, ia,that on or about March 5 , 2011, in the County o f Jackeog, State o f
M~vIo the~defendan$
~, knowingly discharged a fueam~at a ~ l o t o vehicle,
r ta wiG a white Fad
TBUWS*

Count IV. A r m d criminal aetion (31010990)

ahc Prosecuting Attorney o f the County af Tacksoh State o f Missouri, upan information
ehwg~sthat tZxe defendant, fn violatian of Seedion 571.015, RSMa, c
and b@J.i.,lief,
~ m ( ; ~ crhind
f d o of d i punish,ableupon canviction undm S~pctian571.015.1, RSMo, fa
a ~ ton,
on or about March 5 , 2011, in tbe county o f J ~ h o n State
, o f Missouri, t;he definCg,mt
tted tbe felony o f Unlawful TJse o f a Werywn: discharge at a motor vehicle charged ia

the $:~r~@oingfelony o f Udwful Use o f a Weapon: discharge at a motor vehide by,

and aid of a deadly weapon.
gh, the knowing use, as~istmce

The fact5 that fim the basis far this i d o m t t i o nandl b&l:lir;f'me csnt&n& in t h ~
attaeh~dl
s t w t m t ( s ) of facts, made a part hmdaf and submitted as a basis upan which this W may flnd
the existence o f probable cause.

mereforn, the Prosecuting Attorney prays that an me5t warrant be issud as provided by
Ia,w*
J A m S Ph ATZm
Prosecutkg A.ttomey
Y~ G ~ S R @amv7
ID. Missaari
A fl
 JACKSON GO PROSECUTO PAGE 05/06

PROBABLE CAUSE STATEmNT FORM

Dak: 03/05/2011 CRN: 11-151,23

I, Detective Patsick J, M c K e d e
offieer. or persm having infomatiion as probable c a u a
(Name and identify law e~~fomement

knowing that fahe statementson this form are punishable by law, state that the Bicts contained herin are true.

I have probable cause to believe that on 03/05/203 1 , at 12615 E 58* ST. _.. i.n
f]Pa@) (Address)

Kiinsas City, JACKSON Mi,ssowi Eelicia D.Burks

@am@] (Name of Ofknder(~))

B\P, 1 112911,869 a - c o h a e d one or mme criminal offense(s).

@escripticm of Identity)

Tbe facts suppbmng this belief are as follows:

On 03/05/2031, at 12:36 a.m., Officers of the Kansas City, Missouri Police Department were dispat~hed
16 12615 E 5sth ST.,Kansas City, Jackson County, M U regarding a disturbance call. Upon asrival o@,cers
conhcted a subject later identified as Felicia D. Bnrb, B\F, 11/29/1969, who fiaely stated she had been
involved in an altercation with the At 1 vi dm,her boyfriend, which resulted in a gun battle between them.
€Wficenthen made contact with Ehe #2 victim at an area hospital at which time he statd Burla assaulted him
and victim # 1.

The #2 victim stated an 03/04/2011, at apploximately 0035, wh,iJeat a club, the victim and Burks
became inv9Pd in a verbal dispute so he and the #1 victim left and returned to victim#l.'s residence located at
12615 B.58 St. Victim #2 stated as they pulled into the driveway?the garage door opened ad Burkrr exited
the g8;1:age with a gun, pointed it at Victim #1 and pulled tha trigger several times, but the gun appear4 to have
jammed,. Victim #2 i5xrth.m stated victim #I began running around the car trying to get in md Burks rhen began
shooting at victim #1 as he tried to get into the now moving vehicle. Victim ff2 stated victim #1 eventually got
in the vehicle, yelling, Y've beem hit." Victim #2 then drove victim#l to an area hospital.

Victim #1 stated hc and Burh became involved itl a verbal altercation while in a vehicle and Barks,
who was sitting behind him, bcgan assaulting him with her fists and scratching his face. Victim #. I he
stated
was final1,yable restnin Burks. Victim #I stated they dropped Bnrks off at her vehicle and she left. Victim #I
stated he and Victim ((2 then drove to his home and upon arrival,,Burks came out of the garage and aimed the
gun at him and began trying to shoot him; the gun failing to fire several times. Victim #1 fuaher stated he
heard a s h o several
~ more clicks and as he was flnaiJ,yentd.ng the 1efi rear passenger door ofthe vehide he
heard anothm sh.otand realized he Bad been hit,

The Witness stated she was inside the residence at 12615 E 5gm Street and suddenly heard gunshots.
The witness stated she ran to her bedroom window and observed victim #2 driving and victim #1tryi.wgto get i,n
the driver's side rear door ofthe car. The Witness said she also observed Burks pointing the gun at their car
and shooting. The witness stated sh,ealso thought she hewd a shot hthe garage afkr Burlrs reentered it.

Page 1 of 2
Fohn 50 P.D. (Rw.9-2008)
 03/08/2011 14:02 8168814314 JACKSON CO PRQSECUTD PAGE 06106

PROBABLE CAUSE.STATEMENT FORM

CRN 11-1.5123

Officers observed spent shell casings in the street to Q,e south of the residence and one spmt shell casing
on t he driveway in front of the no& garage door. Officers also observed a spent bullet inside the garage on the
floor next to a vehicle parked there. O&cers further observed the victim to have a single gunshot wound to his
left bicep. Officer's observed the victim's vehicle to 'beparked at an area hospital with an app- bullet hole
in it.
The #I victim was transported to an area hospital where he was treated for his injuries.

Oficers contacted Burks. Officers arrested Burks and hrmsportedher to Police HeadquaJrtem for
questioning.

Burks has three prior arrests for domestic violence and poses a h a t to the victim's safety.

Printed. Name Patrick J. McKen.de Signature

The Court finds probable cause and directs the issuance of a waxant this day o f

Circuit Court of County, State of Missouri.

Page 2 of 2