E-FILED IN COUNTY CLERK'S OFFICE PIERCE COUNTY, WASHINGTON April 30 2012 11:01 AM

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
INFORMATION- 1 vs. JENNIFER LYNN MOTHERSHEAD, INFORMATION SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY STATE OF WASHINGTON, Plaintiff, CAUSE NO. 12-1-01509-2

KEVIN STOCK COUNTY CLERK

DOB: 6/13/1982 PCN#:

Defendant. SEX : FEMALE SID#: UNKNOWN COUNT I

RACE: WHITE

I, MARK LINDQUIST, Prosecuting Attorney for Pierce County, in the name and by the authority of the State of Washington, do accuse JENNIFER LYNN MOTHERSHEAD of the crime of ASSAULT OF A CHILD IN THE FIRST DEGREE, committed as follows: That JENNIFER LYNN MOTHERSHEAD, in the State of Washington, on or about the 12th day of May, 2011, a person eighteen years of age or older, did unlawfully, feloniously, and intentionally assault a child, to-wit: K.M., being under the age of 13, and recklessly inflicts great bodily harm, contrary to RCW 9A.36.120(1)(b)(i), a domestic violence incident as defined in RCW 10.99.020, and the crime was aggravated by the following circumstances: pursuant to RCW 9.94A.535(3)(n), the defendant used his or her position of trust, confidence, or fiduciary responsibility to facilitate the commission of the current offense, and/or pursuant to RCW 9.94A.535(3)(a), the defendant's conduct during the commission of the current offense manifested deliberate cruelty to the victim, and/or pursuant to RCW 9.94A.535(3)(b), the defendant knew or should have known that the victim of the current offense was particularly vulnerable or incapable of resistance, and against the peace and dignity of the State of Washington.

Office of the Prosecuting Attorney 930 Tacoma Avenue South, Room 946 Tacoma, WA 98402-2171 Main Office (253) 798-7400

12-1-01509-2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
INFORMATION- 2

IN THE ALTERNATIVE I, MARK LINDQUIST, Prosecuting Attorney for Pierce County, in the name and by the authority of the State of Washington, do accuse JENNIFER LYNN MOTHERSHEAD of the crime of ASSAULT OF A CHILD IN THE FIRST DEGREE, committed as follows: That JENNIFER LYNN MOTHERSHEAD, in the State of Washington, on or about the 12th day of May, 2011, a person eighteen years of age or older, did unlawfully, feloniously, and intentionally assault a child, to-wit: K.M., being under the age of 13, causing substantial bodily harm and the person has previously engaged in a pattern or practice of assaulting the child which has resulted in bodily harm that is greater than transient physical pain or minor temporary marks, contrary to RCW 9A.36.120(1)(b)(ii)(A), a domestic violence incident as defined in RCW 10.99.020, and the crime was aggravated by the following circumstances: pursuant to RCW 9.94A.535(3)(n), the defendant used his or her position of trust, confidence, or fiduciary responsibility to facilitate the commission of the current offense, and/or pursuant to RCW 9.94A.535(3)(a), the defendant's conduct during the commission of the current offense manifested deliberate cruelty to the victim, and/or pursuant to RCW 9.94A.535(3)(b), the defendant knew or should have known that the victim of the current offense was particularly vulnerable or incapable of resistance, and against the peace and dignity of the State of Washington.

IN THE ALTERNATIVE I, MARK LINDQUIST, Prosecuting Attorney for Pierce County, in the name and by the authority of the State of Washington, do accuse JENNIFER LYNN MOTHERSHEAD of the crime of ASSAULT OF A CHILD IN THE FIRST DEGREE, committed as follows: That JENNIFER LYNN MOTHERSHEAD, in the State of Washington, on or about the 12th day of May, 2011, a person eighteen years of age or older, did unlawfully, feloniously, and intentionally assault a child, to-wit: K.M., being under the age of 13, causing substantial bodily harm and the person has previously engaged in a pattern or practice of causing the child physical pain or agony that is equivalent to that produced by torture, contrary to RCW 9A.36.120(1)(b)(ii)(B), a domestic violence incident as defined in RCW 10.99.020, and the crime was aggravated by the following circumstances: pursuant to RCW 9.94A.535(3)(n), the defendant used his or her position of trust, confidence, or fiduciary responsibility to facilitate the commission of the current offense, and/or pursuant to RCW 9.94A.535(3)(a), the defendant's conduct during the commission of the current offense manifested deliberate cruelty to the victim, and/or pursuant to RCW 9.94A.535(3)(b), the defendant knew or should have known that the victim of the current offense was particularly vulnerable or incapable of resistance, and against the peace and dignity of the State of Washington.

Office of the Prosecuting Attorney 930 Tacoma Avenue South, Room 946 Tacoma, WA 98402-2171 Main Office (253) 798-7400

12-1-01509-2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
geb

DATED this 30th day of April, 2012. PIERCE COUNTY SHERIFF WA02700 MARK LINDQUIST Pierce County Prosecuting Attorney

By:

/s/ GRANT E. BLINN GRANT E. BLINN Deputy Prosecuting Attorney WSB#: 25570

INFORMATION- 3

Office of the Prosecuting Attorney 930 Tacoma Avenue South, Room 946 Tacoma, WA 98402-2171 Main Office (253) 798-7400