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Trial Information: Keith Jones

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E-FILED 2023 JAN 31 4:50 PM POLK - CLERK OF DISTRICT COURT

IN THE IOWA DISTRICT COURT FOR POLK COUNTY

STATE OF IOWA, CRIMINAL NO. FECR365745


Plaintiff, FECR365837
v.
ROBERT LEE MILLER III, TRIAL INFORMATION
KEITH ERIC JONES,
Defendants.

COMES NOW Kimberly Graham, as County Attorney of Polk County, Iowa, and in the
name of and by the authority of the State of Iowa, accuses ROBERT LEE MILLER III
and KEITH ERIC JONES of committing the following crime(s) in Polk County, Iowa,
on or about December 13, 2022, individually or by joint criminal conduct, or by aiding and
abetting another:

COUNT I: HOMICIDE BY VEHICLE BY OWI, in violation of Iowa Code


Section(s) 707.6A(2)(a) and/or (c), by unlawfully and unintentionally causing the
death of M.F. 4 yrs old, by operating a motor vehicle while under the influence of
an alcoholic beverage. (Class B Felony)

COUNT II: HOMICIDE BY VEHICLE BY RECKLESS DRIVING, in


violation of Iowa Code Section(s) 707.6A(2)(a) and/or (c), by unlawfully and
unintentionally causing the death of M.F. 4 yrs old, by operating a motor vehicle
in a reckless manner with willful or wanton disregard for the safety of persons or
property and/or by exceeding the speed limit by 25 miles per hour or more (Class
C Felony)

COUNT III: HOMICIDE BY VEHICLE BY DRAG RACING, in violation of


Iowa Code Section(s) 707.6A(3), by unlawfully and unintentionally causing the
death of M.F. 4 yrs old, by operating a motor vehicle while drag racing (Class D
Felony)

COUNT IV: SERIOUS INJURY BY VEHICLE BY OWI, in violation of Iowa


Code Section(s) 707.6A(4) by unlawfully and unintentionally causing a serious
injury to M.DC, by operating a motor vehicle while under the influence of an
alcoholic beverage. (Class D Felony)

COUNT V: SERIOUS INJURY BY VEHILCE BY RECKLESS DRIVING,


in violation of Iowa Code Section(s) 707.6A(4), by unlawfully and
unintentionally causing a serious injury to M.DC by driving a motor vehicle in a
reckless manner with willful or wanton disregard for the safety of persons or
property and/or by exceeding the speed limit by 25 miles per hour or more (Class
D Felony)

COUNT VI: LEAVING THE SCENE OF AN ACCIDENT CAUSING DEATH, in


violation of Iowa Code Section 321.261(4) and 321.263 by failing to remain at
the scene of an accident causing in death or before leaving the scene of the fatal
accident, failing to leave his driver’s license, automobile registration receipt or
other identification data at the scene of the accident or after leaving the scene
of an accident resulting in death, he failed to promptly report the accident to
law enforcement authorities. (Class C Felony)(as to Defendant Jones only)
E-FILED 2023 JAN 31 4:50 PM POLK - CLERK OF DISTRICT COURT

THIS IS A TRUE INFORMATION.


KIMBERLY GRAHAM
POLK COUNTY ATTORNEY

/S/ Jaki L. Livingston


JAKI L. LIVINGSTON, AT0004730
Assistant Polk County Attorney
222 Fifth Avenue
Des Moines, Iowa 50309
Telephone: (515) 286-3737
Jaki.Livingston@polkcountyiowa.gov
E-FILED 2023 JAN 31 4:50 PM POLK - CLERK OF DISTRICT COURT

State of Iowa Courts

Type: Approval of Trial Information

Case Number Case Title


FECR365837 STATE VS KEITH ERIC JONES

On this date, I have reviewed the attached Trial Information and the accompanying Minutes
of Testimony and find that they contain evidence which, if unexplained, is sufficient to
warrant a conviction by a trial jury. Being satisfied from the showing made that the case
should be prosecuted, I approve the Trial Information.

Release conditions are set by separate Order of the Court.

So Ordered

Electronically signed on 2023-01-31 16:50:31 page 3 of 3

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