10 ul 12 12872 3/16/20a4 kn oe012478 20880243 INFO. on 1508 w counry tLEtks oFFice am, MAR 12 2004 py. SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY STATE OF WASHINGTON, Plant, | CAUSE NO. 04-1-01247-5 vs, MICHAEL DAVID JACKSON, INFORMATION Defendant OST BUS DOB: 117671965 SEX: MALE RACE: WHITE PCN SID#: UNKNOWN DOL#: UNKNOWN COUNT! |, GERALD A. HORNE, Prosecuting Attorney for Pierce County, in the name and by the authority of the State of Washington, do accuse MICHAEL DAVID JACKSON of the crime of RAPE OF A CHILD IN THE THIRD DEGREE, committed as follows ‘That MICHAEL DAVID JACKSON, in the State of Washington, during the period between the 28th day of October, 2001 and the 27th day of October, 2002, did unlawfully and feloniously, being at least 48 months older than B.B., engage in sexual ntercourse with B.B., who is at least 14 years old but less than 16 years old and not married to the defendant, contrary to RCW 9A.44.079, and against the peace and dignity of the State of Washington COUNT II And I, GERALD A. HORNE, Prosecuting Attorney for Pierce County, in the name and by the authority of the State of Washington, do accuse MICHAEL DAVID JACKSON of the crime of RAPE OF A CHILD IN THE THIRD DEGREE, a crime of the same or similar character, and/or a crime based on the same conduct or on a series of acts connected together or constituting parts of a single scheme or plan, and/or 50 closely connected in respect to time, place and occasion that it would be difficult to separate proof of one charge from proof of the others, committed as follows ‘That MICHAEL DAVID JACKSON, in the State of Washington, during the period between the 28th day of October, 2001 and the 27th day of October, 2002, did unlawfully and feloniously, being at INFORMATION- 1 Ottis ofthe Prosecuting Attorney 930°Tacoms Avene South Room M6 ORIGINAL “Tacoma, WA 984022171 Main Office 253) 798-7400 geert19 20 21 2 23 4 12872 sqnenzeed Jeast 48 months older than B.B., engage in sexual intercourse with B.B., who is at least 14 years old but Jess than 16 years old and not married to the defendant, contrary to RCW 9A.44.079, and against the peace and dignity of the State of Washington COUNT III And |, GERALD A. HORNE, Prosecuting Attorney for Pierce County, in the name and by the authority of the State of Washington, do accuse MICHAEL DAVID JACKSON of the crime of RAPE OF ACHILD IN THE FIRST DEGREE, a crime of the same or similar character, and/or a crime based on the same conduct or on a series of acts connected together or constituting parts of a single scheme or plan, and/or so closely connected in respect to time, place and occasion that it would be difficult to separate proof of one charge from proof of the others, committed as follows: That MICHAEL DAVID JACKSON, in the State of Washington, during the period between the 28th day of November, 1999 and the 27th day of November, 2000, did unlawfully and feloniously being at least 24 months older than N.B., engage in sexual intercourse with N.B., who is less than 12 years old and not married to the defendant, contrary 0 RCW 9A.44,073, and against the peace and dignity of the State of Washington. COUNTIV ‘And I, GERALD A. HORNE, Prosecuting Attomey for Pierce County, in the name and by the authority of the State of Washington, do accuse MICHAEL DAVID JACKSON of the crime of RAPE OF A CHILD IN THE SECOND DEGREE, a crime of the same or similar character, and/or a ime based on the same conduct or on a series of acts connected together or constituting parts of a single scheme or plan, and/or so closely connected in respect to time, place and occasion that it would be difficult to separate proof of one charge from proof of the others, committed as follows: ‘That MICHAEL DAVID JACKSON, in the State of Washington, during the period between the 28th day of November, 2001 and the 27th day of November, 2002, did unlawfully and feloniously, being at least 36 months older than N.B., engage in sexual intercourse with N.B., who is at least 12 years old but less than 14 years old and not married to the defendant, contrary to RCW 9A.44,076, and against the peace and dignity of the State of Washington. COUNT V And |, GERALD A. HORNE, Prosecuting Attomey for Pierce County, in the name and by the authority of the State of Washington, do accuse MICHAEL DAVID JACKSON of the crime of RAPE OF A CHILD IN THE SECOND DEGREE, a crime of the same or similar character, and/or a ime based on the same conduct or on a series of acts connected together or constituting parts of a single scheme or plan, and/or so closely connected in respect to time, place and occasion that it would be difficult to separate proof of one charge from proof of the others, committed as follows: INFORMATION. 2 Office ofthe Prosecuting Atorey 930 Tacoma Avenue South, Room 946 Tacoma, WA. 58802-2171 ‘Main Office (283) 798-7400 aee7210 u 12 14 15 16 17 19 20 21 12872 a¢enoaees| & ‘That MICHAEL DAVID JACKSON, in the State of Washington, during the period between the 28th day of November, 2002 and the 21st day of October, 2003, did unlawfully and feloniously, being at least 36 months older than N.B., engage in sexual intercourse with N.B., who is at feast 12 years old but less than 14 years old and not married to the defendant, contrary to RCW 9A.44,076, and against the peace and dignity of the State of Washington. DATED this 12th day of March, 2004 PIERCE COUNTY SHERIFF GERALD A. HORNE WA02700 Pierce County Prosecuting Attorney sko By, Y.KO Deputy Prosecuting Attorney WSB#: 20425 INFORMATION: 3 Offic of the Prosecuting Atorney 930 Tacoma Avenue Sout, Room 945, “Tacoms, WA 98402-2171 Main Office (253) 798-1400 227210 ul 12 14 15 17 18 19 NO. 04-1-01247-5, DECLARATION FOR DETERMINATION OF PROBABLE CAUSE SUNNI Y. KO, declares under penalty of perjury: ‘That I am a deputy prosecuting attorney for Pierce County and I am famitiar with the police report and/or investigation conducted by the PIERCE COUNTY SHERIFF, incident number 032670728; ‘That the police report and/or investigation provided me the following information; ‘That in Pierce County, Washington, between 11-28-99 and 10-21-03, the defendant, MICHAEL, DAVID JACKSON, did commit the crime of Rape of a Child in the First Degree and Rape of a Child in the Second Degree. ‘There are two victims. B.B. is 16 years old. Her DOB is 10-28-86. N.B. is 13 years old. Her DOB is 11-28-89. Defendant is their stepfather. He has been in their lives for the past 10 years, He left on 9-25-03 after B.B. disclosed that she and the defendant had engaged in sexual intercourse when she was 15. N.B previously disclosed that the defendant sexually abused her when she was 10 years old. She was interviewed and placed in foster care. She later recanted and the case was closed. She now reports that the past allegations were true and that there have been additional episodes of sexual assault since that time, ‘On 9-24.03, police contacted B.B. at her high school. B.B. had disclosed to her art teacher that she and the defendant had had sexual intercourse. The art teacher contacted a counselor and the counselor called the police. B.B. told police that when she was 15 years old and her mom was cut of town on business, she and the defendant were outside barbecuing. She told the defendant, “You can have it whenever you are ready.’ She and the defendant went to the garage and kissed. Defendant went into the house and returned with a condom. They got into a 1974 Volkswagen Bug and had engaged in sexual intercourse, (Count 1) The next day, they had sexual intercourse in B.B.’s bedroom, (Count il) ‘On 10-21-03, a forensic interviewer interviewed N.B.. She told the interviewer that the first incident occurred when she was 10 years old. They were in bed in her mom’s bedroom. Her clothes were ‘half off. His pants were off and his underwear was only half off. Defendant was on top of her, and he penetrated her vagina with his penis. He had on a condom. She told him to stop because he was hurting her vaginal area. She was in fourth grade and it was during Summer time. (Count {I1). When she was 12 ‘years old, she had to give him oral sex. He had dropped off the other children at school. NB. was home from school because she was not feeling well. Defendant told her to “suck his thing” and when she said “[she] didn’t have to”, he said, “Yes you do.” Defendant was standing up and she was kneeling down. (Count IV). The last time he had sexual intercourse with N.B. was when she was 13 years old. B.B. was not home and her younger brother was in his room sleeping. He told N.B. to go into his bedroom. When she said she did not want to, he said, “Do it.” She did as she was told. He told her to take her clothes off. DECLARATION FOR DETERMINATION 59 ie Progcting Atomey OF PROBABLE CAUSE -I Tacoma, WA 98802-2171 Main Ofie (283) 798-740020 21 22 23 24 12873 3y4Neo1ZAB Again she said she did not want to, and he said, “Do it.” He also slapped her face. N.B. took off her clothes and he inserted his penis in her vagina. (Count V). | DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE OF WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT DATED: March 12, 2004 PLACE: TACOMA, WA LO KO, WSB# 20425 DECLARATION FOR DETERMINATION feof te Prosecuting Aorney 930 azana vee Sah, Ron OF PROBABLE CAUSE -2 Tee oma WA 9800271 Mason 03987 eee7s