Complaint Review: West-Anderson Paralegal Services - Kansas City Kansas

Lafayette County, MO case #09LF-CR00757-01-Alleged Burglary - $20,000.00 Cash Bonds; & (sub-case didn't know that the person was a Material Witness For The State, He was also the witnesses SURETY on her own bond) 10LF-CR00019-01 - Alleged Witness Tampering - $50,000.00, State of Missouri vs Danny Bounds.

See below for sample case document prepared Pro Se, this defendant also proved JURY TAMPERING/RIGGING againstKellie Ritchie, Lafayette County, MO Prosecutor- (32,960 citizens in the County, jury pool consisted of 42 names, where 1/2 of jury pool were law enforcement personnel or related to law enforcement, 4-of the jurors had recent cases before the judge and/or been involved with the prosecutors, and 8-others failed to disclose guilty pleaes and other pertinent information):

COMES NOW, Defendant, Danny Lee Bounds, Pro Se, in this matter, with my Claim to Reasonable Doubt (Due To My Former Attorney Knowingly & Willingly Not Doing His Job), and I state as follows:

1.

That based on the discovery the Lafayette County, Missouri Prosecutors sent to my former attorney, there were 3-witnesses (Delbert F. Gray; Gerald William Gray, Sr., and Shawn Michael Fisher/Gray note: these 3-men are related) that completed Voluntary Witness Statements (attached as 12/31/2010 Exhibit #1-#3) related to the alleged 19717 North Outer Road, Higginsville, MO, burglary, yet not one of these witnesses reported:

a.

Seeing me burglarize the building,

b.

Seeing me inside, nor near the building,

c.

Seeing any broken window, or broken glass, nor any property outside the premises near any broken window, or broken glass.

d.

Seeing me in possession of any stolen property.

e.

Seeing me on the south side of the building, the alleged location of the broken window

2.

That based on the discovery the Lafayette County, Missouri Prosecutors sent to my former attorney, the 3-Voluntary Witness Statements related to alleged 19717 North Outer Road, Higginsville, MO, burglary, their stories are conflicting as follows:

a.

Both Gerald William Gray, Sr., Shawn Michael Fisher/Gray, father and son claim that they saw a gray pick-up truck with the license plate #40G, near a tube on the north side of the building, at about 7:56 p.m., yet on that date, August 15, 2009, according to the Sunrise & Sunset For U.S.A., (attached as 12/31/2010 Exhibit #4) for the Missouri area, the sun set at 7:55 p.m., which meant that it was dark at the time the father and son claim they saw the gray pick-up truck. Also, due to the summer season, vegetation and foliage would have hidden or obstructed the view of the

d.

The license plate on my Toyota Tundra does NOT have #40G on it.

e.

Even more conflicting, on Delbert F. Grays Voluntary Witness Statement, he says that he saw a gray to silver truck at the 19717 North Outer Road, Higginsville, MO location in military time at 21:00 21:30 p.m., which in day light savings time, would have been at 9:00 9:30 p.m., which is when the Lafayette County, Missouri Sheriffs had already taken me in custody.

3.

Both Gerald William Gray, Sr., Shawn Michael Fisher/Gray, father and son stated that a rifle was pointed at them from the gray pick-up truck, the son, Shawn Michael Fisher/Gray stated that the passenger in the gray pick-up truck pointed the rifle. Remember, these 2-witnesses live in Mayview, Missouri, which is a rural part of eastern Missouri, and certainly they know the difference between a rifle and a shotgun, which is what the Lafayette County, Missouri law enforcement officers stated that they recovered from the

a.

Neither the father, nor the son ever stated that they saw me point any weapon at them, nor did they state that they saw any weapon in my possession, and neither of them stated that they ever saw me throw any weapon from the gray pick-up truck.

4.

In further conflict with the statements of Gerald William Gray, Sr., Shawn Michael Fisher/Gray, father and son, Delbert F. Gray, stated that he saw the driver of a gray to silver pick-up truck throw an object, possibly a 9mm Smith & Wesson or Glock weapon into bushes and undergrowth, yet the Lafayette County, Missouri law enforcement officers NEVER recovered any such weapon. Remember, this is the same witness that stated he saw a gray to silver pick-up truck at 21:00 21:30 p.m. military time, which is when the Lafayette County, Missouri Sheriffs had already taken me in custody.

a.

This witness never gave an estimate of the year of the silver to gray pick-up truck he claimed he saw.

b.

This witness never stated that he saw a Toyota Tundra, which is the make and model of my vehicle, and my vehicle is a 2003 (late model) silver-gray in color, NOT silver to gray, and it is NOT a pick-up truck it is a Tundra, there is a difference.

c.

This witness never gave a license plate number of the vehicle he claimed he saw.

5.

There is a Chain Of Custody Issue Related To The 20-Guage Shotgun that the Lafayette County, MO law enforcement officers stated they recovered on the Outer Road in Higginsville, MO, after I had already been taken into custody, it was after dark, at about 9:00 p.m.

a.

According to the Probable Cause Statement made by Officer Stephen Munson (attached as 12/31/2010 Exhibit #5), on page #3, which states in part, I stopped my inventory search when Sgt. Thompson advised me he had found a shotgun lying next to the roadway. I inspected the firearm, a single shot 20-gauge Savage Arms shotgun. I photographed the shotgun and then recovered it and secured it in by trunk. (Wonder what happened to that picture?) How can trained law enforcement officers miss a 20-guage shotgun laying next to the roadway, RIGHT IN PLAIN VIEW???

b.

There is also a conflict with the Probable Cause Statement made by Officer Danny Logan (attached as 12/31/2010 Exhibit #6), concerning the alleged shotgun, which states in part on the first page, 4^th & 5^th paragraphs, During my investigation I ran the Higginsville Police Department K9 Cody around the suspect vehicle. Sgt. Thompson, located one of the firearms (20 gauge shotgun) approximately 50-yards behind the suspect vehicle. Now come on, you have a trained K-9 Officer Cody that is taught to sniff out contraband, yet not only does the trained K-9 Officer miss a 20-guage shotgun allegedly RIGHT IN PLAIN VIEW, but his Commanding Officer, Danny Logan also misses this large weapon.

c.

Contrary to this law enforcement officers statement, when the picture of the 20-guage shotgun was placed into evidence by the Lafayette County, Missouri Prosecutors, the shotgun had been moved, and the picture presented to the jury had been taken in the DAYLIGHT. Dont forget, in Officer Munsons statement, he said he photographed the shotgun, so again, what happened to that picture?

d.

How can anyone know whether or not the 20-guage shotgun alleged recovered by the Lafayette County, Missouri law enforcement officers at night, after dark, is the same shotgun entered into evidence by the Lafayette County, Missouri Prosecutors, since the pictures the law enforcement officers took were NOT entered into evidence, but the picture used by the Prosecutors were presented to the jury that had been taken in the DAYLIGHT?

e.

Remember, both Gerald William Gray, Sr., Shawn Michael Fisher/Gray, father and son stated that a rifle was pointed at them from the gray pick-up truck, the son, Shawn Michael Fisher/Gray stated that the passenger in the gray pick-up truck pointed the rifle. Remember, these 2-witnesses live in Mayview, Missouri, which is a rural part of eastern Missouri, and certainly they know the difference between a rifle and a 20-guage shotgun, which is what the Lafayette County, Missouri law enforcement officers stated that they recovered.

6.

That based on the discovery the Lafayette County, Missouri Prosecutors sent to my former attorney, that besides the 3-above witnesses, there were no other alleged witnesses to any of the crimes I was charged with. This means that, no one has reported:

a.

Seeing me burglarize any building,

b.

Seeing me inside, nor near any building,

Seeing me brake any window, nor remove any property from any premises.

d.

Seeing me in possession of any stolen property.

e.

Seeing me at any location committing any crime, pawning any merchandise,

kick-in any door(s), transporting any property to any location, tamper with any vehicle, removing any property from any shed or other location.

f.

Seeing any alleged stolen property on, near, nor in my Toyota Tundra.

g.

Seeing me with any rifle, or shotgun, or handgun, or seeing me toss any rifle or shotgun, or handgun.

7.

That based on the discovery the Lafayette County, Missouri Prosecutors sent to my former attorney, that there were no witnesses that place me at any alleged crime scene:

a.

Lafayette Bridge Maintenance Building - 19717 North Outer Road, Higginsville, MO.

b.

Cash America Pawn

Mayview, MO.

h.

Shed Belonging To Richard Limback 305West 4^th Street, Alma, MO.

i.

Kim Piepmeier, (Deputy Clerk For Lafayette County, MO) with property allegedly at Lafayette County Bridge Maintenance Building Unknown Address, Unknown City, Unknown State.

8.

That based on the discovery the Lafayette County, Missouri Prosecutors sent to my former attorney, no date was ever disclosed as to when the alleged burglary, kick-ins, and tampering with a truck even occurred.

9.

Based upon Written Statements made by Richard Limback and Kim Piepmeier, (attached as 12/31/2010 Exhibit #7 & #8) they didnt even know they had been burglary victims until the Lafayette County, Missouri law enforcement officers contacted them about property recovered from the following locations, and at the time of the property recovery, I was already in Lafayette County, Missouri law enforcement custody:

a.

Lafayette Bridge Maintenance Building - 19717 North Outer Road, Higginsville, MO.

b.

Cash America Pawn

c.

RV Parking Area 9400 East U. S. 40 Hwy, Independence, MO.

d.

Walmart Parking Lot 40 Hwy & I-70, City Unknown, MO.

e.

Behind & Outside 3515 South Denton, Independence, MO.

10.

That color pictures of the 19717 North Outer Road, Higginsville, MO location clearly

show that NO TRESPASSING SIGNS were NOT displayed, nor posted, and that the building is adjacent to, and sits in, and on an open field. (The color pictures are being filed as a separate document.)

11.

That color pictures of the 19717 North Outer Road, Higginsville, MO, location clearlyshow that the building itself is structured of metal/steel, a theft and burglary deterrent. The south side of the building has 3-small windows, situated far away from the steel security entry doors, and that there are no other windows at this building. The color pictures will also show that all the doors around the perimeter of the building are ALL STEEL SECURITY DOORS, as well as the 7-steel garage/bay doors to the east side of the building, which means how could I have possibly entered this building without keys and/or an alarm and lock security codes? The investigation reports show that the 27-keys on a key ring the Lafayette County, Missouri law enforcement officers took from my Toyota Tundra BELONGED TO ME!!

12.

That based on the discovery the Lafayette County, Missouri Prosecutors sent to my former attorney, 2-Voluntary Witness Statements were made by Ronald G. McCaslin (attached as 12/31/2010 Exhibit #9 & #10), related to pawned and recovered property. These statements were made while I was in the custody of Lafayette County, Missouri law enforcement, and clearly shows:

a.

That I was not in possession of any stolen goods/property.

b.

That I did not pawn any stolen goods/property

c.

That at the time of the pawn and recovery that I was in Lafayette County, Missouri law enforcement CUSTODY.

d

That if the surveillance videos 2-weeks before, and 5-days after the alleged incidents took place were reviewed, that I was not at any place or location where stolen goods/property was taken, nor did I pawn any recovered stolen goods/property.

WHEREFORE, I, Danny Lee Bounds, the Pro Se Defendant, in this matter claim Reasonable Doubt, because the Lafayette County, Missouri Prosecutors, should never have taken this case to trial because the did not have any evidence that would have convinced a jury beyond a reasonable doubt that I was guilty of any crime, and the case should have been dismissed.