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In the Circuit Court of Greene County, Missouri
Associate Division 21
Motion to take Judicial Notice
State of Missouri,
Robin C. McDermott
Case No.: CR398-1214M
Come now defendant, Robin C. McDermott, and requests that this honorable
court take judicial notice of the following facts:
defendant must request that the Honorable court take Judicial Notice of
Officer Royal’s failure to accurately report the injuries his dog did inflict
on defendant, the failure of Officer Royal to follow the Standard Operating
Guidelines in regards to canine force, and the resulting liability of the
city of Springfield incurred by the unconstitutional and criminal actions
of the operatives of the City of Springfield on the night of 23rd
of January 1998.
Defendant was at the hospital, Cox North, on the 23rd day
of January 1998, for treatment of a dog bite, which was inflicted upon
her by a canine under the control of Officer T.D. Royal of the Springfield
The injuries upon defendant’s person were on her inner thigh
and buttocks, as noted in the hospital report and the photographs enclosed.
Officer Royal’s report falsely defines the extent of the
injuries for which defendant was treated.
Standard Operating Guidelines for the Springfield Police
Department specifically forbids the use of canine force in the arrest of
misdemeanor offenders. SOG # .
Officer Smith’s arrest report states that he forced defendant
to sit on the injuries for which she was at the hospital to receive treatment.
Officer Smith’s Report enclosed.
RSMo 565.083.1(5) charges the defendant with an attempt to
have unauthorized physical contact with Officer Smith.
the misdemeanor charge to which the defendant has been called to defend
herself has no basis and the state’s certified witnesses have already failed
to make true and accurate official reports in the case at bar, and the
operatives of the city have failed to follow the Standard Operating Guidelines
of their department. The defendant must ask this honorable court to recognize
the fact that a cover-up of police abuse is occurring.
Robin C. McDermott
1601 N. Waverly
Springfield, Mo. 65803
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