IN THE DISTRICT COURT OF JOHNSON COUNTY, KANSAS

STATE OF KANSAS,
VS.

Plaintiff,
AMENDED COMPLAINT

No. 14CR2167

RICHARD DEAN BIRD,

Defendant.
STATE OF KANSAS, JOHNSON COUNTY, ss:
I, Keith Henderson, Assistant District Attorney of said County, upon information and
belief, state under oath to the court that
RICHARD DEAN BIRD
did the following:
COUNT I - That on or about the 22nd day of September, 2014, in the County of Johnson
and State of Kansas, RICHARD DEAN BIRD did then and there unlawfully, feloniously and
willfully and with premeditation commit an overt act, to-wit: shoot at Deputy Chaulks
marked and occupied patrol vehicle with a rifle during a chase, toward the perpetration of
the crime of first-degree murder, as defined by K.S.A. 21-5402, which is unlawfully,
feloniously, intentionally and with premeditation kill a human being, with the intention to
commit said crime but failed in the perpetration thereof, or was prevented or intercepted in
the execution thereof, a severity level 1 person felony, in violation of K.S.A. 21-5301,
K.S.A. 21-5402, and K.S.A. 21-6806. (attempted first-degree murder)
COUNT II Further, that on or about the 22nd day of September, 2014, in the County of
Johnson and State of Kansas, RICHARD DEAN BIRD did then and there unlawfully,
feloniously and willfully obtain or exert unauthorized control over property to-wit: fuel tank,
with the intention to permanently deprive the owner, to-wit: Haven Construction, of the
possession, use or benefit of the property, of a value of less than $1,000, a class A nonperson misdemeanor, in violation of K.S.A. 21-5801 and K.S.A. 21-6602(a)(1). (theft)
COUNT III Further, that on or about the 22nd day of September, 2014, in the County of
Johnson and State of Kansas, RICHARD DEAN BIRD did then and there unlawfully,
willfully and feloniously possess a quantity of methamphetamine, a drug severity level 5
felony, in violation of K.S.A. 65-4107(d)(3), K.S.A. 21-5706(a), K.S.A. 21-6805 and K.S.A.
21-6808. (possession of methamphetamine)

Clerk of the District Court, Johnson County Kansas

12/11/14 11:13am KC

COUNT IV Further, that on or about the 22nd day of September, 2014, in the County of
Johnson and State of Kansas, RICHARD DEAN BIRD did then and there unlawfully,
knowingly and willfully use or possess with intent to use drug paraphernalia, to-wit:
syringes, glass vial, and/or straw, to store, contain, conceal, inject, ingest, inhale or
otherwise introduce into the human body a controlled substance, in violation of the Uniform
Controlled Substances Act, a class A nonperson misdemeanor, in violation of K.S.A. 215709(b)(2), and K.S.A. 21-6602(a)(1). (possession of drug paraphernalia)
I declare under penalty of perjury that the foregoing is true and correct. Executed on
the 11th day of December, 2014.
/s/ KEITH HENDERSON
Dated: 12/11/14
________________________
Keith Henderson #22080
Assistant District Attorney
100 North Kansas Avenue
Olathe, Kansas 66061
(913)715-3000
WITNESSES:
Haven Construction personnel
Bruce Hughart
Sgt. B. Deer
Det. R. Crabtree
Capt. Pfannenstiel
Johnson County Sheriffs Office personnel

Melissa Atkinson
Sgt. T. Chaulk
Det. B. Wilson
Sgt. Theiss
Deputy Williams
Johnson County Crime Lab personnel

Amendment Adding Counts 3 and 4.

Clerk of the District Court, Johnson County Kansas

12/11/14 11:13am KC