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									12/13/2006   16:19    8168813572                     MAJOR CRIMES                             PAGE 02




                             IN THE CIRCUIT COURT
                     OF JACKSON COUNTY, MISSOURI
                                   AT KANSASCITY
                                   Police #06-077623
                                   Prosecutor #0984180
                                   CASE# 0616~CR
                                   QCN#

                                        COMPLAINT
 THE STATE OF MISSOURI

              vs.

 Erica Bennett
 1115 Concord
 Independmce, MO
 DOB:IZ112/1985;Race/Sex: BLK IF;
 SS#       --
               Defendant.

                               Count I. Murder 2nd Degree (1003111.0)

         The Prosecuting Attorney of the County of Jackson, State of Missouri, upon information and
 belief, charges the defendant, Erica Bennett, in violation of Section 565.021, RSMo, committed the
 Class A Felony of Murder in the Second Degree, punishableupon convictionunder Section 558 .011,
 RSMo,in that on or aboutthe 26th day of November,2006, in the County of Jackson, State of Missouri,
 the defendant,Erica Bennett,either acting aloneor purposeftillyin concertwith another,with the purpose
 of causing serious physical injury to Rickey L. Gardner caused the death of Rickey L. Gardner by
 shootinghhn, and defendantis further givennotice shouldthe State submit Murder in the SecondDegree
 _ felony, under Section 565.021.1(2),RSMo,2000, it will be based on the'death of Rickey L. Gardner as
 the result of the attempted pmpetration of the Class A Felony of Robbery in the First Degree, under
 Section 558.011.1(1)on or aboutNovember26, 2006, in the Countyof Jackson, Stateof Missouri.

                            Count D. Armed Criminal Action (3101099.0)

         The Prosecuting Attorney of the County of Jackson, State of Missouri, upon infonnation and
 belief, charges the defendant, Erica Bennett, in violation of 571.015, RSMo, committedthe Felony of
 Armed Criminal Action, punishable upon conviction under Section 571.015.1, RSMo, in that on or
 about 26th day of November,2006, in the Countyof Jackson, State of Missouri, the defendantknowingly
 committed the felony of murder in second degree charged in Count I, all allegations of which are
 incorporated herein by reference, and the defendant committed the foregoing felony of murder in the
 second degraeby, with and throughthe use, assistanceand aid of a deadly weapon.

                                                       (1003111.0)
                             Count m. MuJder 2nd DegJ"ee

         The Prosecuting Attorney of the County of Jackson, State of Missouri, upon information and
 belief, charges the defendant, Erica Bennett, in violation of 565.021, RSMo, committed the Class A



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12/13/2006   16:19     8168813572                      MAJOR CRIMES                             PAGE      03




 Felony of Murder hi the Second Degr~ punishableupon convictionunder Section 5S8 .011, RSMo,
 in that Onor about the 26th day of November,2006, in the County of Jackson, State of Missouri, the
 defenclant,Erica Bennett,.either acting aloneor purposefullyin concertwith another,with the purpose of
 csmsingserious physical injury to Kimberly C. Ford caused the death of Kimberly C. Ford by shooting
 her, and defendantis further given notice shouldthe State submit Murder in the SecondDegree - felony,
 under section 565.021.1(2),RSMo,2000, it will be based on the death of KimberlyC. Ford as the result
 of the attempted perpetration of the Class A Felony of Robbery in the First Degree. under Section
 558.011.1(1)on or aboutNovember26,2006, in the Countyof Jackson, State of Missouri.

                            Count IV. Armed CriBdDaiAction (3101099.0)

        The Prosecuting Attorney of the County of Jackson, State of Missouri, upon information and
 belie~ charges the defendant,Erica Bennett, in violation of 571.015.RSMo, committed the Felony of
 Armed 'CrimInal Action, punishable upon conviction under Section S71.015.1, RSMo, in that on or
 about 26th day ofNovembcr, 2006. in the Countyof Jackson,State of Missouri, the defendantknow:ing1y
 committed the felony of murder in second degree charged in Count In, an allegations of which 8le
 incorporated herein by reference, and the defendant committed the foregoing felony of murder in the
 second degreeby, with and throughtheuse, assistanceand aid of a deadly weapon.

                  Count V. Assault 1st Degree - Serious PhysieallnJury    (1301104.0)

        The Prosecuting Attorney of the County of Jackson, State of Missouri, upon information and
belief, charges the defendant, Erica BeDDett, in violation of 565.050, RSMo, committed the Class A
Felony Of Assault In The FIrst Degree, punishableupon convictionunder Section 558.011, RSMo, in
that on or about 26th day of November,2006, in the Countyof Jackson, State of Missouri, the defendant,
either acting alone or pwposefully in concertwith another, shot Myron C. Ford, and such conduct was a
substantial step toward the commissionof the crime of attemptingto kill or cause serious physical injury
to Myron C. Ford, and was done for the purpose of committing such assault, and in the course thereof
inflicted seriousphysical injury on MyronC. Ford.

                            Count VI. Armed Criminal Action (3101099.0)

      The ProsecutingAttorneyof the Countyof Jackson, State of Missouri,upon infonnation and belief,
charges the defendant,Erica Bennett, in violation of 571.015,RSMo, committed the Felony of Armed
Crbnfnal AetioD,punishableupon convictionunder Section 571.015.1,RSMo,in that on or about 26 day
of November,2006, in the Countyof Jackson, State of Missowi, the defendantknowinglycommittedthe
felony of assault in the first degree chargedin Count V, all aDegationsof which are incoJP01'atcdherein
by reference, and the defendantcommittedthe foregoingfelony of assault in the first degree by, with and
throughthe use, assistanceand aid of 8 deadlyweapon.

       The factsthat formthe basis for this infonnation andbelief are containedin the attached
statement(s)offacts concemmgthis matterwhich statement(s)are made a part hereof and are submitted
herewith as a basis upon which this comt may find the e~stence of probable cause for the issuanceof the
warrant.

       Wherefore,the ProsecutingAttorneyprays that an mest wmant be issued as provided by law.




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                                                                                                          PAGE         85
                                                                                                                                      I




                                           STATEMENT OF PROBABLE CAUSE
                                                                                      CRN 06-077623

          '.~~      !lQW~a sworn Law Enforcement Officer for the State of Missouri. knowing that false
          ~~Qts        on this form are punishable by law. and that the facts contained herein are true. state.s..as
          ,fbllows;
                  On 11126120061918hoursKansas City,Missouri PoliceofficersW~ dispatchedto 14534S. 71
                                 at
                       an
          ~ghway OD ambulancecall. Upon mival they contactedvictim#3 lying on the floor in front of aparlment
         ;~~~ ~e told;~~officer.s ~ a male namedJunior had comeinsidethe apartmentwherehe lives, shot him and
                                              to
         '~,~o.1R. OBicers.respondecUhen 14534S. 71 Highway #204, Kansas City, Jackson Co1U11y,         Mi.S!D~
          ~~.:the.aparfm_      they discoveredRickey L. Gardner,BIM06/08/1919and KimberlyC. Ford. BIF
          07/15/1976both dead 110m    what appearedto be gunshotwounds. Victim#3 was transportedto a local,hospital
          werebe was treated for gunshotwoundsto the face and arms. Gardnerand Ford were both transportedto the
                  Cowty Medical Examinersoffice. The medical examinerdetennined both deathswere causedby
          lac;ks.9n
      ,c.,'.
       ;i'-,~-1'14i
                    hot.

                             v
                 On 12/8106, ictim #3 provideda fom:18l  interviewstatingthat on 11/26/06,he was homewith his
         mother, victim #2. and her boyfiiend,victhn #1. There was a knock at the door and victim#3 opened the door
         and saw two femalesand one male. Victim #1 was shown a lineupand identified,Erica Beonett, bIt, 12/22/85,
         as one of these females. Victim#3 went on to state that Bennett and the other female cameinto the bedroom
         wheR the victim's were watchingTV. A short time later, Junior,who was armedwith a gun. and the other
         black maIe came into the room with their faces coveredand demandedmoney from victim#1. Duringthe
         robbery,the black male reachedinto victim #1's pocket and removedsome money,placingit into his own
         pocket. Bennett was also pushingFord's purse tow,ardsJunior so thathe could check it for money, however;
         Junior never looked in the purse. JUniorthen shot victim #1, #2. and #3. Duringthe shooting,BeoDettand the
         other female and male, ran fromthe room. Junior remainedand continuedshooting. Victim #3 stated he was
         besideFord when she was shol After the suspectand otherparties had left victim #3 went to the first .floorand
         hada neighborcall 9-1-1. ~ callingpartystatedwhenvictim#3 cameto herdoorhe toldherthatthesospect
         had shot him and the deceasedvictims.

                A witness contactedstated they had seen a white four doorDodgeNeon or Suzuki vehiclewith tinted
         windows come onto the property. The driver of the vehicle askedwhere building"34" was located. Whenthe
         witness talked to the male they observedfourparties inside the vehicle. After the shootingocwned, witnesses
        observed a white four door sma1lvehicleleavingtheparking lot ftom beside building 14534. A witness stateda
        male by the name of Junior was banned fromthe propertyby management. The manager of the propertywas
        contactedand stated they had banned a male by the name ofWardeJI L. WilliamsJR, BIM 06/10/1986also
        known as Junior. Detectivesplaced a photographlineuptogetherwith five unknownblack males and suspect
        Williams. The photographlineupwas shown to victim #3 who identifiedsuspect Williamsas theperson that
        shot him and the deceasedvictims.

                             B
                On 11128/06, ennett was mested and transportedto Police Headquartersfor questioningwhere she
       was read her Miranda Rights and waived her rights. Bennett admittedto committingthe robberythat occurred
       on 11/26/06at 14534S 71 HWY#204 with Williams,Jackson, and AufaL Bennett stated all suspect's were
                                                             n                  to
       awaretheyweregoingto commita robbery,however; o onewassupposed be hurt. Bennettadmitted              her
      job in the robberywas to get the victim's to open the door becausetheywere her mends. She was then to leave
      the door unlockedso Jackson and Williamscouldenter. Duringthe robbery,they were all in the back bedroom
      with the victim.s when WilJiamsshot victim#1. Bennett said she, Jackson,and Aufai ran to Aufai's white
      Suzuki and drove around to the tront where they saw Williamsrunningout of the ftont door of the apartment
      complexwith the long gun. Williams got into the backseatand was driven to the area of3Slhand Prospect
      FOI'n'I P.O. (Rev."~4>
           ~
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                              1.s: 1<9     8lS8813572
                                                         -                                                               PAGE 86



                                                        STATEMENTOF PROBABLE CAUSE
                                                                                                         CRN,OM1762:3.




          .;"'~~                         the
                       amtJ;,t.c:ksoaexiUd vehicletogetherwith the gun. A few nrlnutes1aterthey cameback to the
              ,A1nr.,]_--:'~ ut the
           -:J.
           ...~~.~o..               gun.


                                                                            Det. Janice Liddle#4415
                                                                            Detective's Name and Serial Number
                                                                           Printed or TypewritteQ
                                           e~           and.directs the issuance of a warranUbis
                                            '.




                                                                     Judge
                                 Circuit Court of                                   County, State of Missouri.




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