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RAWLINGS, #6969
Davis County Attorney
p~O. Box 618
800 West StateStreet
FanningtonUT 84025
Telephone: (801) 451-4300
Fax: (801) 451-4328
COUNT 1
first degreefelony, as follows: That betweenApril 29, 2010 and May 8, 2010 at the place
following circumstances
(a) the homicide was committed incident to an act, scheme,course of conduct, or criminal
(b) the homicide was committed incident to one act, scheme~course of conduct~or criminal
episodeduring which the actor committed the crime of abuseor desecrationof a dead human
(d) the homicidewas committedby meansof the administrationof any lethal substanceor of any
(e) the homicide was committed in an especially heinous, atrocious, cruel, or exceptionally
(t) the actor dismembers,mutilates,or disfiguresthe victim's body, whetherbeforeor after death,
OR
With reckless indifference to human life, did causethe death of another incident to an act,
If Notice of Intent to Seekthe DeathPenaltyis filed: (1) Death;(2) Life Without Parole;or (3)
an IndeterminateTenn of25 Yearsto Life.
If Notice of Intent to Seekthe DeathPenaltyis not filed: (1) Life Without Parole;or (2) an
IndetenninateTerm of20 Yearsto Life.
COUNT 2
That between April 29, 2010 and May 8, 2010 at the place aforesaid the defendant did
intentionally Of knowingly inflict upon a child serious physical injury Of, having the care Of
custodyof such child, intentionally or knowingly causedor pennitted anotherto inflict serious
COUNT 3
follows: That betweenMay 6, 2010 and May 11, 2010 at the placeaforesaidthe defendantdid,
(a) prevent,by deception,any personfrom perfonning any act that might aid in the discovery,
COUNT 4
third degreefelony, as follows: That betweenMay 6, 2010 and May 11, 2010 beginning in
Davis and continuing into WeberCounty. the defendantdid disturb. move. remove.conceal.or
destroy a dead human body or any part of it; or damageany part or portion of a deadhuman
body-
This Information is basedon evidenceobtainedfrom witnessBrooke Plotnick.
Davis County Attorney and has received information from the investigating officer, Brooke
Plotnick of the Layton Police Department,and the information herein is based upon such
party, engagedin multiple acts inflicting seriousinjuries upon a four-rear-old male victim. The
severe abuse resulted in the child's death. The criminal acts included beatings, burning,
drugging, isolating, malnourishing,leaving the child alone and unattendedwhile suffering, and
3. The defendant and a co-defendant then falsely reported to the police that the
TROY S. RAWLINGS
Davis County Attorney
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avis Coun
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orney