William Gallagher PC

7/28/2019 William Gallagher PC

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647022 Page 1 04/10/2013

STATE OF MISSOURIVS

GALLAGHER, WILLIAM JOSEPH

DIV #: CA#: 510647022 CAUSE#:DESTINATION: GRAND JURY

D E F E N D A N T I N F O R M A T I O N

ADDRESS: 90XX SOUTHVIEW LNSaint Louis, MO 63123

PEDIGREE: RACE: W DOB: XX/XX/1994 HGT: 5'11"SEX: M AGE: 18 WGT: 150

ID #s: COMPLAINT#: 130016261 LID: 352556ARREST#: 1130008886 DIST: SLMPD OCN:

ALIASES:SSNs:

STATE OF MISSOURI ) COMPLAINTCITY OF ST. LOUIS )SS

The Circuit Attorney of the City of St. Louis, State of Missouri, upon information and belief,charges that

Count 1: Murder 2nd Degree - Felony Murder - During Perpetration/attemptedPerpetration/flight From Perpetration Of A Felony, A Person Dies (Class A FELONY) RSMo565.021 ON 4/9/2013 Time: Place: Osage at Nebraska (SCC 10036)

The defendant, in violation of The defendant, in violation of Section 565.021, RSMo, committed

the class A felony of murder in the second degree, punishable upon conviction under Section 558.011,

RSMo, in that on or about April 9, 2013, in the City of St. Louis, State of Missouri, V.B. was killed

by having the vehicle in which she was a passenger struck by the car the defendant was driving as a

result: of the immediate flight from the perpetration of the class C felony of Assault in the Second

Degree of a Law Enforcement Officer under Section 565.0082, RSMo committed by the defendant on

April 9, 2013, in the City of St. Louis, State of Missouri or the perpetration of the Class C felony of

Tampering in the First Degree under Section 569.080.1(2), RSMo committed by the defendant on Apri

9, 2013, in the City of St. Louis, State of Missouri or the perpetration of the Class D felony of Resisting a

Lawful Stop creating a Substantial Risk to any person under Section 575.150, RSMo, committed by the

defendant on April 9, 2013, in the City of St. Louis, State of Missouri.

Count 2: Armed Criminal Action (FELONY) RSMo 571.015ON 4/9/2013 Time: Place: Osage at Nebraska (SCC 31010)

The defendant, in violation of Section 571.015, RSMo, committed the felony of armed criminal

action, punishable upon conviction under Section 571.015.1, RSMo, in that on or about April 9, 2013, in


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the City of St. Louis, State of Missouri, the defendant committed the felony of Murder in the 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 Degree by, with and through, the

knowing use, assistance and aid of a dangerous instrument.

In the alternative to count I,

Count 3: Involuntary Manslaughter 2nd Degree (Class D FELONY) RSMo 565.024ON 4/9/2013 Time: Place: Osage at Nebraska (SCC 10052)

The defendant, in violation of Section 565.024, RSMo, committed the class D felony o

involuntary manslaughter in the second degree, punishable upon conviction under Sections 558.011 and

560.011, RSMo, in that on or about April 9, 2013, in the City of St. Louis, State of Missouri, the

defendant caused the death of V.B. by colliding with a vehicle in which the victim was an occupant and

did so with criminal negligence in that the defendant was driving at a high rate of speed and failed tostop at a stop sign.

In the alternative to Count II,


The defendant, in violation of Section 571.015, RSMo, committed the felony of armed crimina


the City of St. Louis, State of Missouri, the defendant committed the felony of Involuntary Manslaughte

in the First Degree charged in Count III, all allegations of which are incorporated herein by reference,

and the defendant committed the foregoing felony of Involuntary Manslaughter in the First Degree by,

with and through, the knowing use, assistance and aid of a dangerous instrument.

Count 5: Tampering With Motor Vehicle 1st Degree (Class C FELONY) RSMo 569.080ON 4/9/2013 Time: Place: 39XX S GRAND BLVD (SCC 23013)

The defendant, in violation of Section 569.080.1(2), RSMo, committed the class C felony of

tampering in the first degree, punishable upon conviction under Sections 558.011 and 560.011, RSMo

in that on or about April 9, 2013, in the City of St. Louis, State of Missouri, the defendant knowingly and

without the consent of the owner unlawfully operated an automobile, a 1997 Honda Accord.


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Count 6: Resisting Arrest/detention/stop By Fleeing - Creating A Substantial Risk Of SeriousInjury/death To Any Person (Class D FELONY) RSMo 575.150ON 4/9/2013 Time: Place: 39XX S GRAND BLVD (SCC 27025)

The defendant, in violation of Section 575.150, RSMo, committed the class D felony of resisting

a lawful stop, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on o

about April 9, 2013, in the City of St. Louis, State of Missouri, M.C., a law enforcement officer, were

attempting to make a lawful stop of a vehicle driven by the defendant, and the defendant knew or

reasonably should have known that the officer was making a lawful stop, and, for the purpose of

preventing the officer from effecting the stop, resisted the stop of defendant by fleeing from the officer

and the defendant fled in such a manner that created a substantial risk of serious physical injury o

death to other persons in that the defendant operated a motor vehicle on Alberta driving the wrong way

failing to stop at multiple stop signs and driving on Osage at speeds approaching 70 miles an hour.

Count 7: Assault 2nd Degree On Law Enforcement Officer, Corrections Officer, EmergencyPersonnel, Highway Worker, Utility Workeror Probation And Parole Officer - Acts With CriminalNegligence - Means Of A Deadly Weapon Or Dangerous Instrument (Class C FELONY) RSMo565.082 ON 4/9/2013 Time: Place: 39XX S Grand (SCC 13145)

The defendant, in violation of Section 565.082, RSMo, committed the class C felony of assault of

a law enforcement officer in the second degree, punishable upon conviction under Sections 558.011 and

560.011, RSMo, in that on or about April 9, 2013, in the City of St. Louis, State of Missouri, the

defendant ith criminal negligence created a substantial risk of death or serious physical injury to M.C., a

law enforcement officer, by almost striking him with the car the defendant was driving.

Count 8: Armed Criminal Action (FELONY) RSMo 571.015ON 4/9/2013 Time: Place: 39XX S Grand (SCC 31010)

The defendant, in violation of Section 571.015, RSMo, committed the felony of armed criminal


the City of St. Louis, State of Missouri, the defendant committed the felony of Assault in the Second

Degree of a Law Enforcement Officer charged in Count VII, all allegations of which are incorporated

herein by reference, and the defendant committed the foregoing felony of Assault in the Second Degree

of a Law Enforcement Officer by, with and through, the knowing use, assistance and aid of a dangerous

instrument.


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Count 9: Resisting Or Interfering With Arrest For A Felony (Class D FELONY) RSMo575.150 ON 4/9/2013 Time: Place: Osage at Nebraska (SCC 27020)

The defendant, in violation of Section 575.150, RSMo, committed the class D felony of resisting

an arrest, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about

April 9, 2013, in the City of St. Louis, State of Missouri, M.T. and D.W., law enforcement officers, were

making an arrest of defendant for Leaving the Scene of an Accident (felony), and the defendant knew orreasonably should have known that the officers were making an arrest, and, for the purpose of

preventing the officers from effecting the arrest, resisted the arrest of defendant by fleeing.

Count 10: Leaving Scene Of Motor Vehicle Accident - Injury, Property Damage (Class DFELONY) RSMo 577.060 ON 4/9/2013 Time: Place: Osage at Nebraska(SCC 48865)

The defendant, in violation of Section 577.060, RSMo, committed the class D felony of leaving

the scene of a motor vehicle accident, punishable upon conviction under Sections 558.011 and 560.011

RSMo, in that on or about April 9, 2013, the defendant, while operating a motor vehicle on Osage. a

highway, at or near Nebraska in the City of St. Louis, State of Missouri, was a party to an accident that

caused other persons to sustain physical injury and property damage, and the defendant knew that such

injury or damage had occurred, and the defendant left the scene of the accident without stopping and

giving sufficient information by which the defendant could be readily identified and located to such

persons or to a police officer in the vicinity.

Count 11: Leaving Scene Of Motor Vehicle Accident (Class A MISDEMEANOR) RSMo577.060 ON 4/9/2013 Time: Place: 39XX S Grand (SCC 48866)

The defendant, in violation of Section 577.060, RSMo, committed the class A misdemeanor of

leaving the scene of a motor vehicle accident, punishable upon conviction under Sections 558.011 and

560.016, RSMo, in that on or about April 9, 2013, the defendant, while operating a motor vehicle on

a parking lot for an old Arby's, a parking lot generally open for use by the public, at or near 39XX S

Grand in the City of St. Louis, State of Missouri, was a party to an accident that caused another personto sustain property damage and the defendant knew that such damage had occurred, and the defendant

left the scene of the accident, without stopping and giving sufficient information by which the defendant

could be readily identified and located, to such person or to a police officer in the vicinity.


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The facts that form the basis for this information and belief are contained in the attached

statement(s) of facts, made a part hereof and submitted as a basis upon which this court may find the

existence of probable cause.

Wherefore, the Circuit Attorney prays that an arrest warrant be issued as provided by law.

Jennifer M. JoyceCircuit Attorney of the City of St. Louis,State of MissouriBy __Original Signed______________

Assistant Circuit Attorney


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PROBABLE CAUSE STATEMENT

DATE: April 10, 2013

I, Michael Pratt DSN 6475, a law enforcement officer for the City of St. Louis, State of Missouri, knowingthat false statements on this form are punishable by law, state that the facts contained herein are true.

1. I have probable cause to believe that William Joseph Gallagher, a White Male DOB: XX/XX/94 Age18, committed one or more criminal offense(s).Count 1: Murder 2nd Degree During Flight From Prepetration Of Felony (Class A FELONY)

RSMo 565.021ON 4/9/2013 Time: Place: Osage at Nebraska (SCC 10036)


Count 3: Involuntary Manslaughter In The Second Degree (Class D FELONY) RSMo 565.024ON 4/9/2013 Time: Place: Osage at Nebraska (SCC 10052)

Count 4: Armed Criminal Action (FELONY) RSMo 571.015

ON 4/9/2013 Time: Place: Osage at Nebraska (SCC 31010)

Count 5: Tampering First Degree: Motor Vehicle, Etc. (Class C FELONY) RSMo 569.080ON 4/9/2013 Time: Place: 39XX S GRAND BLVD (SCC 23013)

Count 6: Resist/interfering With Lawful Stop Or Detention-subst Risk (Class D FELONY) RSMo575.150ON 4/9/2013 Time: Place: 39XX S GRAND BLVD (SCC 27025)

Count 7: Assault 2nd Degree LEO, crim Neg (Class C FELONY) RSMo 565.082ON 4/9/2013 Time: Place: 39XX S Grand (SCC 13145)

Count 8: Armed Criminal Action (FELONY) RSMo 571.015

ON 4/9/2013 Time: Place: 39XX S Grand (SCC 31010)Count 9: Resisting Or Interfering With Arrest For Felony (Class D FELONY) RSMo 575.150

ON 4/9/2013 Time: Place: Osage at Nebraska (SCC 27020)

Count 10: Left Scene Of Accident (Class D FELONY) RSMo 577.060ON 4/9/2013 Time: Place: Osage at Nebraska (SCC 48865)

Count 11: Left Scene Of Accident (Class A MISDEMEANOR) RSMo 577.060ON 4/9/2013 Time: Place: 39XX S Grand (SCC 48866)

2. The facts supporting this belief are as follows:

The defendant was driving a 1997 Honda Accord, owned by K.S. The car had been reported stolen onApril 1, 2013 from St. Louis County, near where the defendant formerly lived. The defendant told me heknew it was stolen. PO M.C. went up to the defendant while the defendant had stopped the car in theparking lot of the former Arbys after getting information that the defendant would be there. The officerhad information that the defendant had a juvenile in the car that was reported as missing from FranklinCounty as well as the fact that the defendant had multiple wanteds from St. Louis County. PO M.C.approached the car and told the defendant he was under arrest and to place his hands in the air. Insteadthe defendant placed the car in reverse, almost striking PO M.C. PO M.C. told me that it made him fearfor his safety. The 1997 Honda Accord then struck a parked car, a Cadillac Deville, pushing it over aconcrete parking curb. The defendant drove off the lot onto Alberta, driving east, a one way street going


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west. The defendant told me that he drove east approximately two blocks, went south and then travelledeast on Osage. The defendant told me he did not stop at any stop signs and was travellingapproximately 85 miles an hour. Osage has a speed limit of 25 miles an hour. The defendant then strucka car driven by M.K. at the intersection of Osage and Nebraska. Her mother, 87 year old, V.B. was thefront seat passenger. V.B. was pronounced deceased approximately three hours later. She died fromthe injuries she sustained in the car crash. Over a thousand dollars of damage was done to M.K.s car.The defendant, after striking two other parked cars, fled from the scene on foot. He was taken intocustody by PO M.T. and PO D.W. after fleeing from them as well when they told him to stop.

Michael Pratt Dsn 6475 Original SignedPRINT NAME SIGNATURE

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William Gallagher PC