in the circuit court of jackson county, missouri at kansas city

IN THE CIRCUIT COURTOF JACKSON COUNTY, MISSOURIAT KANSAS CITYSTATE OF MISSOURI, ))Plaintiff, )) Division No. 14vs. )))Michele Kraft, ) Case No. 1216-CR03052))Defendant. )STATE’S MOTION TO CORRECT CLERICAL ERROR ANDREINSTATE ORIGINAL BONDCOMES NOW the State of Missouri, by and through Assistant ProsecutingAttorney Trisha Lacey, and moves this Honorable Court correct a clerical error andreinstate the defendant’s original bond of $100,000/10%.1. The defendant has been charged with Assault in the First Degree, a class Afelony and Endangering the Welfare of a Child in the First Degree, a class Cfelony. The victim is an 8 year old child.2. Upon filing of complaint on July 20, 2012, the State requested the bond beset in the amount of $100,000/10%.3. The warrant for arrest signed by Judge Fahnestock on July 20, 2012 shows abond of $100,000/10%.4. A review of the Order of Commitment shows the original bond was set at$100,000/10%.5. A review of the State’s “Request for Grand Jury Indictment” indicates theState requested a bond of $100,000/10%.6. A review of the State’s “Case Record Sheet” indicates that AssistantProsecuting Attorney Julie Hamilton recorded the bond upon indictment as$100,000/10%.

7. On July 27, 2012 the case was presented to the grand jury for indictment.The grand jurors issued a true bill. The bond written on the indictment was$10,000/10%.8. The record reflects no request to reduce the bond was filed by the defendantand the State did not request or agree to a reduced bond.9. Co-defendant, Jeffrey Kraft (1216-CR03053), who was charged withcommitting the same crimes, was charged by complaint on the same day asthis defendant. His bond was set at $100,000/10% upon the filing of thecomplaint. The co-defendant was indicted on the same day as thisdefendant. The co-defendant’s bond remained the same at $100,000/10%.10. The State believes a clerical error occurred when recording the bond on theIndictment. The State believes the correct bond in this matter is$100,000/10%.11. The defendant has posted the erroneous $10,000/10% bond that wasrecorded on the Indictment.WHEREFORE, the State believes that a clerical error occurred when the bond waswritten on the indictment. The State moves this Honorable Court to correct the errorand reinstate the correct and appropriate bond of $100,000/10%. The Staterequests this Court to order the defendant to surrender herself to the Court and postthe correct bond. If the defendant is unwilling to do this, the State requests awarrant issue for the defendant’s arrest.Jean Peters BakerJackson County Prosecuting Attorneyby,_____________________________Cole Eason #43695Assistant Prosecuting Attorney415 E. 12th St., Floor 7-MKansas City, Missouri 64106(816) 881-3888

A copy of the above was mailed this_______ day of August, 2012 to:Reginald Davis750 Ann Avenue, Ste BKansas City, KS 66101And faxed to 913-371-8790_______________________Cole Eason #43695