Jay Mack - Probable Cause

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St. Louis Circuit Attorney

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STATE OF MISSOURI VS MACK, JAY DIV #: CA#: 510534984 CAUSE#: DESTINATION: GRAND JURY (AT LARGE) DEFENDANT INFORMATION ADDRESS: 1X DORIS AVE O'Fallon, MO 63368 PEDIGREE: RACE: W DOB: XX/XX/1979 HGT: 5'08" SEX: M AGE: 33 WGT: 210 ID #s: COMPLAINT#: 120063612 LID: ARREST#: ATLARGE DIST: SLMPD OCN: ALIASES: SSNs:

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 Count 1: Sexual Contact With Student By Teacher, Student Teacher, Employee, Contract Employee, School Official Or Volunteer (Class D FELONY) RSMo 566.086 ON 12/6/2012 Time: Place: 38XX MAGNOLIA AVE (SCC 22023) The defendant, in violation of Section 566.086, RSMo, committed the class D felony of sexual contact with a student on public school property, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between December 6, 2012 and December 6, 2012, in the City of St. Louis, State of Missouri, the defendant was a teacher for the State of Missouri Department of Elementary and Secondary Education at Missouri School for the Blind, and knowingly had sexual contact with B.C., a student of Missouri School for the Blind by placing her hand on his penis through the clothing at the Missouri School for the Blind on Magnolia Avenue.

Count 2: Sexual Misconduct 1st Degree (Class A MISDEMEANOR) RSMo 566.090 ON 12/5/2012 Time: Place: Near Grand and Magnolia Avenues (SCC 22010) The defendant, in violation of Section 566.090, RSMo, committed the class A misdemeanor of sexual misconduct in the first degree punishable upon conviction under Sections 558.011 and 560.016 RSMo, in that on or between December 5, 2012 and December 5, 2012, in the City of St. Louis, State of Missouri, the defendant for the purpose of arousing defendant's sexual desire subjected K.K. to sexual contact through the clothing by placing her hand on his penis without K.K.'s consent.
534984 Page 1 12/13/2012

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 Circuit Attorney prays that an arrest warrant be issued as provided by law. Jennifer M. Joyce Circuit Attorney of the City of St. Louis, State of Missouri By __Original Signed__________ Assistant Circuit Attorney

534984

Page 2

12/13/2012

PROBABLE CAUSE STATEMENT DATE: December 13, 2012 I, Marquis Wren, a law enforcement officer for the City of St. Louis, State of Missouri,, knowing that false statements on this form are punishable by law, state that the facts contained herein are true. 1. I have probable cause to believe that Jay Mack, a White Male DOB: XX/XX/79 Age: 33, committed one or more criminal offense(s). Count 1: Sexual Contact With Student By Teacher, Student Teacher, Employee, Contract Employee, School Official Or Volunteer (Class D FELONY) RSMo 566.086 ON 12/6/2012 Time: Place: 38XX MAGNOLIA AVE (SCC 22023) Count 2: Sexual Misconduct 1st Degree (Class A MISDEMEANOR) RSMo 566.090 ON 12/5/2012 Time: Place: Near Grand and Magnolia Avenues (SCC 22010) 2. The facts supporting this belief are as follows: K.K. informed me that this defendant, a fellow teacher at the Missouri School for the Blind, grabbed her by the wrist and placed her hand on his penis through his clothing. At the time he did this, he was talking about the size of his penis both erect and not. He was driving her back from a location on Grand Avenue to the school address on Magnolia. The following day, B.C., a student at the Missouri School for the Blind reported that this defendant took her hand and put it on his penis through his clothing on school property during a class period. Marquis Wren PRINT NAME Original Signed SIGNATURE

534984

12/13/12

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