In the Circuit Court of Greene County, Missouri
Associate Division 21
State of Missouri,
Robin C. McDermott
Case No.: CR398-1214M
Motion to take Judicial Notice

            Come now defendant, Robin C. McDermott, and requests that this honorable court take judicial notice of the following facts:

    1. 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 Police Department.
    2. The injuries upon defendant’s person were on her inner thigh and buttocks, as noted in the hospital report and the photographs enclosed.
    3. Officer Royal’s report falsely defines the extent of the injuries for which defendant was treated.
    4. Standard Operating Guidelines for the Springfield Police Department specifically forbids the use of canine force in the arrest of misdemeanor offenders. SOG # .
    5. 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.
    6. RSMo 565.083.1(5) charges the defendant with an attempt to have unauthorized physical contact with Officer Smith.
        Therefore, the 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.

        Wherefore, 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.

Respectfully Submitted,

Robin C. McDermott
1601 N. Waverly
Springfield, Mo. 65803

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