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State of Kansas vs. Christopher James Herz

IN THE DISTRICT COURT OF MITCHELL COUNTY, KANSAS - CASE NO. MC-2oa5-CR

STATE OF KANSAS, PLAINTIFF

vs. CHRISTOPHER JAMES HERZ, DEFENDANT

COMPLAINT/INFORMATION

Mark J. Noah, a duly appointed, qualified and acting County Attorney of Mitchell

County, Kansas, and for and on behalf of the state of Kansas being first duly sworn on

oath gives the Court to understand and be informed, that he is informed and verily

believes:

COUNT ONE

That on or about January' 13, 2025, the above-named Defendant, within Mitchell

County in the State of Kansas, then and there being, did then and there contrary to the

statutes of the State of Kansas unlawfully and feloniously and while in the commission

of operating a motor vehicle in Violation of K.S.A. 8-1567, kill a human being (Travis

Gene Cady).

Crime: Involuntary Manslaughter

Statute: K.S.A. 215405(a)(3), (b)(2), and amendments thereto

Penalty: Level 4 Person Felony (1'72 months/$300,000)

COUNT TWO

That on or about January 13, 2025, the above-named Defendant, within Mitchell

County in the State of Kansas, then and there being, did then and there contrary to the

statutes of the State of Kansas unlawfully and feloniously and while in the commission

of operating a motor vehicle in violation of K.S.A. 8-1567, did cause bodily harm to

another ((Travis Gene Cady), in a manner whereby great bodily harm, disfigurement or

death can result.

Crime: Aggravated Battery

Statute: K.S.A. 215413(b)(3)(B), (h)(2)(D) and amendments thereto

Penalty: Level 8 Person Felony (23 months/$100,000)

COUNT THREE

That on or about January 13, 2025, the above named Defendant, within Mitchell

County in the State of Kansas, then and there being, did then and there contrary to the

statutes of the State of Kansas unlawfully and intentionally operate or attempt to

operate a vehicle while under the influence of any drug or combination of drugs to a

degree that rendered him/her incapable of safely driving a vehicle.

Crime: Driving while Under the Influence of Alcohol - 1st

Statute: K.S.A. 8-1567(a)(4), (b)(1)(A) and amendments thereto

Penalty: Class B Nonperson Misdemeanor (6 months/$ 1,000)