Cornealious Michael Anderson III Notice of Claim
Cornealious Michael Anderson III Notice of Claim
Cornealious Michael Anderson III Notice of Claim
Halscott Megaro
March 6, 2015
Francis G. Slay
Mayor, City of St. Louis
1200 Market, City Hall, Room 200
St. Louis, Missouri 63103
Colonel Sam Dotson
Chief of Police
Metropolitan Police Department
1915 Olive Street
St. Louis, Missouri 63103
Re:
Through the efforts of his defense team, evidence was obtained that directly refuted the allegations
against him and proved that he was innocent of the crime for which he was arrested. This evidence
was readily available to the police immediately after his arrest; indeed, as he was being handcuffed,
my client begged the police to investigate his alibi and speak with the people he was with
immediately prior to his arrest to confirm he was innocent. The evidence consisted of video
surveillance recordings, digital photographs, social media, and numerous reputable witnesses.
As a result of a thorough investigation by the Prosecutor as well as Mr. Anderson's defense team,
on February 5, 2015 all charges against Mr. Anderson were dismissed. A copy of the press release
from the Prosecutor is attached to this letter and incorporated by reference. I have also enclosed
copies of the police incident report and the complaint that was filed with the Court.
The nature of the claims to be made against the foregoing individuals and the City of St. Louis
will be made pursuant to 42 U.S .C. 1983 for deprivation of Federal civil rights, and commonlaw
causes of action for false arrest, false imprisonment, battery, negligent and intentional infliction of
emotional distress, as well as a claim for municipal liability under Monell v. Department of Social
Services of the City ofNew York, 436 U.S. 658 (1976). My client is claiming monetary damages
as a result of the actions of the foregoing in an appropriate amount to be determined.
My client has the option to immediately bring a lawsuit in a public judicial forum to seek redress
for damages. It is anticipated that his claim would be brought in the United States District Court
Mr. Anderson also has the option to engage in private discussions to ascertain whether a private
resolution of this matter is warranted.
Should you or your legal representative wish to discuss this matter please contact my office by
April 1, 2015 . Ifl do not hear from you or an appropriate representative by that date, I will assume
that you have no interest in trying to resolve these issues privately.
Thank you for J1 ur attention to this very important matter.
Thursday, February 5, 2015, St. Louis - Today, Circuit Attorney Jennifer M. Joyce has announced that, after a thorough
investigation of the facts and circumstances conducted by her office, she has dismissed a second-degree robbery charge
against Mr. Cornealious Anderson.
Anderson was charged in connection with a robbery that occurred on Sunday, November 16, 2014 at the White Castle
located in the 800 block of S. Broadway. Two witnesses initially identified Mr. Anderson as the perpetrator. Based on
this information, a charge of second-degree robbery was filed, and Mr. Anderson posted bond the following day.
As in every case in the Circuit Attorney's Office, the investigation continued after charges were filed. Prosecutors
gathered surveillance video from area businesses and the media, interviewed additional witnesses and worked with the
defense attorney to ensure all available information was reviewed. The investigation revealed questions regarding the
procedures by which the victim and witness identified the suspect.
"The exhaustive and expeditious review unearthed additional information that cast serious doubt on the case against
Mr. Anderson. On behalf of the Circuit Attorney's Office, I sincerely apologize to Mr. Anderson and thank him, his
defense attorney and area businesses for their cooperation in assisting us in getting to the truth of this matter. Their
participation was essential to th is case," said Circuit Attorney Jennifer M . Joyce. " Because of the immense amount of
local and national attention regarding Mr. Anderson, we wanted to immediately release this information to the media to
clear his name of the recent accusations against him ."
Prosecutors are legally, ethically and morally required to seek any available evidence that could either prove a case or
exonerate a defendant. According to Joyce, this level of investigation occurs every day with every case in the Circuit
Attorney's Office.
"We are duty-bound to protect the rights of all," said Circuit Attorney Joyce. "We will use every legal tool available to
ensure that the correct person is charged with the correct crime. If we ever learn of information casting reasonable
doubt in a case, we immediately dismiss charges as we did in this matter."
The Circuit Attorney's Office cannot provide any additional details at this time, as the investigation into the robbery
remains open and active. Joyce said that she has spoken to the St. Louis Metropolitan Police Chief Sam Dotson about the
details her office uncovered regarding the initial investigation. The Circuit Attorney's Office is now working with police to
review internal policies and procedures in this case.
Police and prosecutors ask that anyone with any information regarding this robbery come forward immediately so that
the person who committed this robbery can be held accountable.
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JAIME HALSCOTT
APPEALS LAW GROUP
33 E ROBINSON ST STE 220
ORLANDO FL 32801-1682
FRANCIS G SLAY
MAYOR, CITY OF ST. LOUIS
1200 MARKET ST
RM200
SAINT LOUIS MO 63103-2805
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JAIME HALSCOTT
APPEALS LAW GROUP
33 E ROBINSON ST STE 220
ORLANDO FL 32801- 1682
Commercial Base Pricing Priority Mail rates apply. There is no fee for USPS
Tracking service on Priority Mail service with use of this electronic rate shipping
label. Refunds for unused postage paid labels can be requested online 30 days from
the print date.
~b';i%~f::if!E.. Thank you for shipping with the United States Postal Service!
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STATE OF MISSOURI
vs
ANDERSON, CORNEALIOUS MICHAEL
CAUSE#:
CA#: 510665616
DIV#:
DESTINATION : GRAND JURY
DEFENDANT INFORMATION
ADDRESS: 2XX LITHIA AVE
SAINT LOUIS , MO 63119
PEDIGREE: RACE : B
DOB: XX/XX/1977
HGT: 6'02"
SEX: M
AGE : 37
WGT: 200
ID#s:
COMPLAINT#: 140053381
LID:
ARREST#: 3140022356
DIST: SLM PD
OCN :
ALIASES:
SSNs: XXX-XX-XXXX
STATE OF MISSOURI )
CITY OF ST. LOUIS
)ss
COMPLAINT
The Circuit Attorney of the City of St. Louis, State of Missouri , upon information and belief,
charges that
(Class B FELONY) RSMo 569.030
Count1 :
Robbery 2nd Degree
1:00 AM TO 11/16/2014 at 1:03 AM Place: 8XX S BROADWAY
FROM 11/16/2014 at
(SCC 12020)
The defendant, in violation of Section 569.030, RSMo, committed the class B felony of robbery in
the second degree, punishable upon conviction under Section 558.011 , RSMo , in that on or between
November 16, 2014 at 1:00 AM and November 16, 2014 at 1:03 AM , in the City of St. Louis, State of
Missouri , the defendant forcibly stole a purse in the possession of D.L.
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 Circu it Attorney prays that an arrest warrant be issued as provided by law.
Jenn ife r M. Joyce
Circuit Attorney of the City of St. Louis,
State of Missouri
By
(original signed)
Assistant Circuit Attorney
Stephen Ogunjobi
PRINT NAME
(original signed)
SIGNATURE
Page 1 of 11
- 304
- 304
11/17/2014 02:53:56
304
304
11/17/2014 02:54:59
3.
STATUS / DATE:
ORlGIN CODE:
CLEARED
11/1612014
RADIO
11/16/2014
11/16/2014
01 :00
BEAT:
INCIDENT LOCATION:
DATEfl'IME OF REPORT:
NEIGHBORHOOD:
4/41 1 /421
11/16/2014
35 DOWNTOWN
NO
GANG RELATED:
LOCATION TYPE:
1. HIGHWAY/ROAD/ALLEY 2. 3.
BIAS CRIME:
DRJVEBY:
02:00
01 :03
NO
BIAS MOTIVATION:
WEAPONS DISCHARGED BY
POLJCE:
NO
(FOR BURGLARY)
POINT F ENTRY:
NO
NO
IMPERSONATIONS:
FORCED ENTRY:
NO
ACTIONS TO VICTlM:
SUSPECT BEHAVIOR:
ACTION TO PROPERTY:
INCIDENT SUMMARY
#1 Vic tim, of Robber y , Victim Injuries: Mi n or #1 Suspect , Arrested ; Weapons : Hand ,
Fists , Feet; Weapons Di scharged by Offi c er : No ; Offi c er(s) Injured: No
- - - - - - - - - - ----
----- _,,_.. - -
_ ____ - -
.. ...
....
Page 3of11
CHARGE INFORMATION
CHARGE:
CN, ROBBERY 2ND DEGREE, STATE OF
MISSOURI
COURT NAME:
CRIME CATEGORY:
DATE:
DOCUMENT NUMBER:
FELONY
11/16/2014
14-053381
COURT NUMBER:
DATE:
TIME:
DESCRIPTORS
EYE COLOR:
BUILD:
MUSCULAR
BROWN
FACIAL HAIR
CHIN:
HAIR COLOR:
HAIR STYLE:
EARS:
NOSE:
FACE:
SUSPECT HARACTER!STfCS:
APPEARANCE - NEAT;
SUSPECT CLOTHTNG:
SCARS/MARKSffATTOOS :
ADDITIONAL DESCRIPTORS:
-304
PROP. #
1
PROPERTY DESCRIPTION:
IBRCODE:
ROBBERY 2ND DEGREE
VALUE:
BRAND:
MODEL:
COACH
PURSE
LOCATION STOLEN:
REFERENCE NO.:
DRUG MEASUREMENT:
DISPOSITION:
FROM SHOULDER
OWNER:
(Las~
First. Middle)
PHONE#:
Home
LEBLANC, DEBBIE
RECOVERY DATE
LOCATION OF RE .OVERY:
(239) 223-3428
PHONE#:
Business (239) 772-8423
OFFICER:
ADDRESS OF RECOVERY:
ADDITIONAL DESCRIPTORS:
- - - - -- - - - - - - - - - - - -- - ---- - - -- -
------- ---- -- -- - - - - -- -- --
Page 2of11
Leblanc, Debbie
HOME ADDRESS: (Unit#, City, State, Zip)
20397 TORRE DEL LAGO ST ESTERO, FL 33928
BUSINESS ADDRESS: (Unit#, City, State, Zip)
RACE:
WHITE
OCCUPATION:
PHONE#:
Home
(239) 2233428
PHONE#:
Business (239) 772-8423
D.0.B.:
AGE:
MARITAL STATUS:
OPP-33 ISSUED:
02/04/1969
45
SINGLE
YES
SOCIAL S CURITY #:
RESIDENT STATUS
ETHNICITY:
PLACE OF BIRTH:
SEX:
FEMALE
UNKNOWN
AGGRAVATED ASSAULT I
HOMICIDE CIRCUMSTANCES:
NON RESIDENT
INJURY TYPE: :
JUSTIFIABLE HOMICIDE
CIR CUM STANCES:
NON HISPAN IC
RELATIONSHIP OF
VICTIM TO OFFENDER:
I. MINOR INJURY
# I.STRANGER
2.
3.
#2.
Person Discovering
Person Securi ng
D. B.:
01/17/1970
PH NE#:
Home
(239) 223-3428
PHONE#:
SN:
Police Officer
Other
PLACE OF BIRTH:
Business
RELA1IONSHIP TO:
RELATIONSHIP TO:
VICTIM#2.
OFFENDER #2.
ALIAS NAME(S):
Anderson, Comealious
HOME ADDRESS: (Unit#, City, State, Zip)
207 LITHIA AVE ST LOUIS COUNTY, MO 63119
BUSINESS ADDRESS: (Unit#, City, State, Zip)
PHONE#:
(314) 629-7132
Home
PHONE#:
(314) 324-6199
D.O.B.:
AGE:
03/26/1977
37
INJURY:
DRIVERS LICENSE# I STA TE:
N204013051 I MO
NONE I UNKNOWN
ETHNICITY:
RESIDENT STATUS :
NON RESIDENT
NON HISPANIC
DISPOSITION OF OFFENDER
TYPE OF ARREST:
ON-VIEW ARREST
UNDER I8:
Business
HEIGHT:
WEIGHT:
PLACE OF BIRTH:
SSN#:
6'0T'
200
358-68-5820
OCCUPATION:
MARITAL STATUS:
OWNER
SINGLE
SEX:
RACE:
MALE
BLACK
OFFENDER WAS ARMED WITII:
I. UNARMED
2.
ARRESTING OFFICER:
DATE OF ARREST:
11/16/2014
ASSISTING OFFICER:
TIM E OF ARREST:
DISTRICT OF ARREST
02:30
4
MIRANDA WARNING GIVEN
L.l.D. NUMBER:
YES
- 304
- -- - - - --
Page 4of1 1
PROP.#
2
PROPERTY DESCRIPTION:
STATUS:
STOLEN/ETC.
WALLET
BRAND:
MODEL:
UNKNOWN
REFERENCE NO .:
DRUG MEASUREMENT:
DISPOSITION:
PHONE#:
LEBLANC, DEBBIE
20397 TORRE DEL LAGO ST ESTERO, FL 33928
RECOVERY DATE
(239) 223-3428
Home
PHONE#:
Business (239) 772-8423
ADDRESS OF RECOVERY:
OFF! ER:
ADDITIONAL DESCRIPTOR :
IBRCODE:
ROBBERY 2ND DEGREE
VALUE:
VERIZON ANDROID MOTOROLA DROID RAZOR
BRAND:
MODEL:
MOTOROLA
ANDROID/RAZOR
LOCATION STOLEN:
REFERENCE NO.:
Home
LOCATION OF RECOVERY:
ADDITIO AL DESCRIPTORS:
23 772-8423
DISPOSITION:
PHONE#:
LEBLANC, DEBBIE
RECOVERY DATE
DRUG MEASUREMENT:
(239) 223-3428
PHONE#:
Business (239) 772-8423
OFFICER:
ADDRESS F RECOVERY:
Page 5of11
4
PROPERTY DESCRIPTION:
$300.00 TO 400.00 IN US CURRENCY
BRAND:
MODEL:
LOCATION STOLEN:
(Las~ Fir.i~
OWNER:
REFERENCE NO.:
Middle)
DRUG MEASUREMENT:
DISPOSITION:
PHONE#:
LEBLANC, DEBBIE
Home
PHONE #:
Busi11C3
LOCATION OF
C VERY:
(239) 223-3428
(239) 772-8423
ADDRESS OF RECOVERY:
OFF! ER:
PROP. #
5
PROPERTY DESCRIPTION:
STATUS:
IBRCODE:
VALUE:
BRAND:
MODEL:
SD CARD
LOCATION STOLEN:
REFERENCE NO.:
DRUG MEASUREMENT:
DISPOSITION:
LABORATORY
OWNER:
(las~ Fi"~
PHONE #:
Middle)
SLM PD
Home
PHONE#:
RECOVERY DATE
11/16/2014 00:00:00
(314) 444-5474
Business
LOCATION OF RECOVERY:
ADDRESS OF RECOVERY:
OFFICER:
BACK OF CAMERA
Page 6of 11
STATUS:
PROP.#
6
PROPERTY DESCRIPTION:
BRAND:
MODEL:
LOCATION STOLEN:
REFERENCE NO.:
OWNER:
(La s~
First, Middle)
PHONE#:
SLM PD
Home
PHONE#:
(314 444-5538
Business
ADORES OF RECOVERY:
OFFICER:
(11096) OGUNJOBI, STEPHEN
ADDITIONAL E CRIPTORS:
CATEGORY:
STATUS:
JBRCODE:
VALUE:
PROPERTY DESCRIPTION:
LINE-UP FORM GEN 129
BRAND:
MODEL:
LOCATION STOLEN:
REFERENCE NO.:
DRUG MEASUREMENT:
DISPOSITION:
DIVISION PROPERTY ROOM
PHONE#:
SLMPD
Home
PHONE#:
RECOVERY DATE
11/17/2014 00:00:00
314)444-5474
Business
LOCATION OF RECOVERY:
ADDRESS OF RECOVERY:
OFFICER:
- - - - - - ----- --
Page 7of11
PROP. #
STATUS:
PROPERTY DESCRIPTION:
BRAND:
MODEL:
LOCATION STOLEN:
REFERENCE NO.:
DRUG MEASUREMENT:
DISPOSITION:
DIVISION PROPERTY ROOM
OWNER:
(Last,
First, Middle)
PHONE :
Home
(314)444-5538
PHONE #:
SLMPD
Business
RECOVERY DATE
11117/2014 00:00:00
ADDITIONAL DE
LOCATION OF RECOVERY:
ADDRE S OF RECOVERY:
OFFICER:
RIPTORS:
304
ASSISTING OFFICER:
(7824) BOYCE, TIMOTHY M
304
ASSISTING OFFICER:
(7999) MURPHY, RYAN J
304
ASSISTJNG OFFICER:
(6777) MOTON, JOHN T IV 304
ASSISTJNG OFFICER:
(5645) JACKSON, JERMAINE D
344
ASSISTJNG OFFICER:
(3602) PRYOR, DAVID A
304
ASSISTING OFFJCER:
(8117) GOTTSCHALL, AMBER
303
ASSISTING OFFICER:
(8040) WILMOT, SCOTT A
303
- - -- - - - - - - - - - -- - - -- - - -- - - - - - - ------
------------ -- - -- - - - - - - - - -
Page 9of11
At this t ime, I informed Cornealious A. that he was under arrest for " Robbery
2nd Degree "I advised him of his Constitutional Righ t s per MPD Form GEN-19, to
which he responded, " I did not do this crime I need you to go out and find him
so I can get home to my wife and child."
Medic 2 responded to the scene and treated victim Leblanc for minor abrasions
P.O. Pryor conveyed Cornealious A . to the Central Patrol Holdover.
Since I did not speak with Victim Leblanc at the scene, I contacted her on
Witness Schrijuer ' s cell phone number.
Victim Leblanc stated that she was in the White Castle drive-thru as a passenger
in witness Schrijuer vehicle, and stepped outside of the vehicle to smoke a
cigarette because she was in a rental car . The suspect approached her from an
unknown direction and stated that he would give her 50 cents for a cigarette.
Before she could take out a cigarette, the suspect later identified as
Cornealious A. grabbed her purse which was on her shoulder and began pulling on
it in order to take her purse from her possession . She stated she was dragged
across 4th Street causing the purse strap to break . Leblanc described the
suspect as a black male , approximately 6'2 , athletic build , and wearing a black
beanie-style hat, a shiny black puffy style jacket with squared pockets , and
blue jeans . Leblanc stated that she last saw the subject running east on Gratiot
towards the riverfront out of sight .
Witness Schrijuer stated he was in the vehicle during the incident. Schrijuer
saw a black male suspect later identified as Cornealious A. approach Leblanc . He
saw them exchanging words and moments later Schrijuer saw Cornealous A. pulling
the purse from Leblanc before removing the purse off her arm in the middle of
4th Street. After hearing Leblanc yell f o r her purse , Schrijuer parked his
vehicle , jumped out of the vehicle , and attempted to detain Cornealous A . to no
avail . Schrijuer described Cornaelious A . as a black male approximately 6 ' 1 with
a lean to athletic build , wearing a shiny black winter coat, blue jeans, and
brown s h oes . Schrijuer stated he followed the subject east through a derelict
open parking building but last saw the suspect running northbound on south 4th
street .
I asked both witnesses if they were certain that they had correctly identified
the individual who commit t ed this crime and both stated they were certain .
A computer check of Cornealious A. revealed a prior hist o ry and n o active want
(s) or warrant (s) .
I took multiple pictures of the clothing that Cornealious A. was wearing and
packaged the SD card as evidence and conveyed it to the Department Laboratory.
P . P . O. Wr i ght had victim Leblanc and witness Schrijver sign (Show-up) MPD Form
Gen - 409 . I packaged both forms and had them placed in the Division Property
- -- - -- - -
- - --
--- - - -- -- - - - ------ - - - - - - - -
Page 8of11
CN 14-053381
Printed: 12/04/2014 08:03:58 DSN: 11124
P . P . O. Jamar Wright, DSN 11165, in car 3422, and P.O. David Pryor, DSN 3602 , in
car 3406, received a radio assignment for a "Purse Snatching " at 806 South
Broadway.
Sergeant Colin Rumpsa, DSN 5250, in car 2414 arrived and supervised the scene .
I was on patrol, in car 3423 , in the area near South 4th and Gratiot , when I
heard a flash description broadcasted on the radio by Sgt Rumpsa, of a " tall,
slender , black male wearing blue jeans , a black puffy coat with a shiny finish,
and a black beanie hat. Sgt . Rumpsa also stated the subject may be in the area
of 4th and Walnut and might have "ditched" his hat.
PPO Jamar Wright, DSN 11165 collected the following statements from the victim
and witness :
Victim Debbie Leblanc stated she was standing outside of the White Castle
located at 806 N Broadway when an unknown black male approached her asking if he
could buy a cigarette . Leblanc said the subject then grabbed her purse , and
pushed her to the ground. While Leblanc attempted to keep her purse she was
dragged into the street . The subject then ran with her purse east on Gratiot
until out of sight . Leblanc described the subject as a black male , clean shaven ,
wearing a black hat , black puffy coat with a shiny finish and blue jeans .
Witness Eric Schrijver said he was in his vehicle in the White Castle drive
through when he observed the above mentioned subject approach Leblanc . Schrijver
said when the struggle for the purse ensued he exited his vehicle and chased
the subject on foot . Schrijver said he lost visual contact with the subject when
he ran north behind a building located at 4th and Gratiot . Schrijver described
the subject as a black male , clean shaven, wearing a black hat , black puffy coat
with a shiny finish and blue jeans .
I responded to the area of 4th and Walnut and saw a black male walking North on
the west side of 4th street who matched the description of the suspect that was
broadcasted. I ob s erved no other black males who fit his description in the
area . I parked my patrol vehicle , identified myself as a police officer , and
conducted a pedestrian check on the suspect later identified as Cornealious A. I
informed Cornealious A . that he was being detained pending a further
investigation about a purse snatching that recently occur r ed south of this
location . Cornealious A. spontaneously stated that he was walking from the
" Social House Bar " to his car located near 6th and Olive . When P.O . David
Bosler , DSN 4077 , in car 3452 , arrived , I placed Cornealious A . in handcuffs ,
and P.O . Bosler conveyed him back to the location of the occurrence .
Upon arriving at the above mentioned location , I had Cornealious A. step out of
the vehicle and shined my f l ashlight on him to illuminate him . P.P . O Wr ight was
with Victim Debbie Leblanc and Witness Eric Schrijuer and he asked them i f th i s
was the suspect that robbed victim Leblanc . Both of them stated Cornealious A.
was the suspect who committed the crime . They further stated he was wearing the
s a me brown shoes , but at the time of the robbery , he was wearing a black hat .
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CN 14-053381
Room.
Cornealious A. was booked without incident.
Cornealious A. was offered a chance to reduce his statement to writing to which
he declined .
After meeting both victims at the warrant office, Assistant Circuit Attorney
Osundare asked victim Leblanc and Witness Schrijuer if they would assist in a
physical line-up. Both parties stated that they would assist.
Detective Scott Wilmot, DSN 8040, in car 2481 and P . O. Amber Gottschall , DSN
8117 , in car 2328 assisted me in conducting a physical line - up. Detective Wilmot
and I responded to the 2nd floor of the Justice center and located (3)
additonal subjects for the line-up. It should be noted that there was a limited
amount of subjects to choose from for the physical lineup . P . O. Gottschall
separated Leblanc and Schrijuer and made sure that they did not talk about the
line-up to each other .
The line-up was conducted in the following order :
NAME :
William Anthony
George Miller
Cornealious A .
Aaron Russell
AR :
4-22365
4-22336
Suspect
4- 22355
P.O . Gottschall escorted victim Leblanc in the viewing room and we began the
lineup . Anthony walked into the room and she said " No , thats not him ." Miller
walked into the room and she said " No , not him. " When Cornealious A . walked into
the room P.O. Gottschall stated that Leblanc became visibly upset and started
to shake and stated " That ' s him. " Russell walked into the room and she said " No "
P.O . Gottschall escorted victim Leblanc out of the room and brought in witness
Schrijuer . Anthony walked into the room and he immediately said "No" . Miller
walked into the room and he said " No " . When Cornealouis A. walked into the room ,
he stated " That ' s definately him. " When Russell walked into the room he said
"No " ..
I packaged Line - up form MPD Form GEN-129 was prepared and later marked ,
packaged, and placed it in the Central Patrol Division Property Room .
Victim Leblanc and Witness Schrijuer completed Line-up viewing form MPD Form
GEN- 409 and I later marked, packaged , and placed it in the Central Patrol
Division Property Room.
I photographed the lineup and the memory card was later marked , packaged and
conveyed it to the Department lab.
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CN 14-053381
I responded back to the Circuit Attorney's office after the completion of the
physical line-up, and met with Assistant Circuit Attorney Osundare who reviewed
the case and issued a Robbery 2nd Degree charge against Cornealious A.
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