16CR00908

Div 18

IN THE DISTRICT COURT OF JOHNSON COUNTY, KANSAS

STATE OF KANSAS,
Plaintiff,
VS.

COMPLAINT

No.

MICHAEL WAYNE CHINN JR.,

Defendant.
STATE OF KANSAS, JOHNSON COUNTY, ss:
I, Sara Walton, Assistant District Attorney of said County, upon information and
belief, state under oath to the court that
MICHAEL WAYNE CHINN JR.
did the following:
Count I- That on or about March 30, 2016, in the County of Johnson, State of Kansas
MICHAEL WAYNE CHINN JR did then and there unlawfully, feloniously, willfully and
intentionally, kill a human being, to-wit: William Ray Schutkesting, by shooting the said
William Ray Schutkesting with a firearm, a severity level 1 person felony, in violation of
K.S.A. 21-5403, K.S.A. 21-6804 and K.S.A. 21-6807. (murder second degree)
Count II- Further, that on or about March 30, 2016, in the County of Johnson, State of
Kansas MICHAEL WAYNE CHINN JR did then and there unlawfully, feloniously,
recklessly and without authority discharge any firearm, at a dwelling, building or structure,
to-wit: 189 S. Rogers Road, Olathe, Kansas, in which there is a human being, to-wit: Sara
Leeker, whether the person discharging the firearm knows or has reason to know that
there is a human being present, a severity level 7 person felony, in violation of K.S.A. 216308(a)(1)(A), K.S.A. 21-6804, and K.S.A. 21-6807
Count III- Further, that on or about March 30, 2016, in the County of Johnson, State of
Kansas MICHAEL WAYNE CHINN JR did then and there unlawfully, feloniously and
knowingly place another person, to-wit: Jessica Koupie, in reasonable apprehension of
immediate bodily harm with a deadly weapon, to-wit: a fire arm, a severity level 7 person
felony, in violation of K.S.A. 21-5412(b), K.S.A. 21-6804 and K.S.A. 21-6807.
(aggravated assault)

Clerk of the District Court, Johnson County Kansas

04/01/16 11:07am JL

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I declare under penalty of perjury that the foregoing is true and correct.
Executed by and on this date.

/s/ SARA WALTON

Dated: 04/01/16
_____________________________
Sara Walton/dmh #24106
Assistant District Attorney
100 North Kansas Avenue
Olathe, Kansas 66061
(913)715-3000

WITNESSES:
Officer Shoemaker
Officer Urbik
Officer Kibbee
Officer Glabrecht
Officer Mills
Officer Yeldell
Officer Carlson
Officer Bonney
Det Peters
Det. B Smith
Det, Foster
Det. Evans
Det. Ramey
Officer Forcier
Det. Thompson
Dan Hoerchler
Solomon Franco
Tasha Umscheid
Thomas Martin JR
Christopher Anderson
Randal Byers
Daniel Hoerckler
Matthew Ronchetto
Jenna Tripp
Kate Meyer JOCO Crime Lab
911 personnel
Johnson County Med Act 1151 personnel

Officer Blom
Officer Clausius
Offficer Orbin
Officer Fitzpatrick
Officer Alsbrooks
Officer Bussell
Officer Styles
Det Campbell
Det. Bowman
Det. Spegal
Det. Ross
Det. McMillian
Det. Breiner
Officer Sebasto
Dawn Clausius
Jessica Kaupie
Matthew Braswell
Michelle Clauser
Carrie Lee
Eric Mudick
Pandy Fuller
Steven Leuthauser
Richard Schroeder
Dr. Michael Handler
Johnson County Crime Lab Personnel
Olathe Medical Center personnel

Clerk of the District Court, Johnson County Kansas

04/01/16 11:07am JL

IN THE DISTRICT COURT OF JOHNSON COUNTY, KANSAS

Criminal Department
State of Kansas
Vs.
MICHAEL WAYNE CHINN, JR, Defendant
INITIATION OF ACTION
Offense(s) Alleged:
21-5403(a)(1)
21-6308(a)(1)(A
21-5412(b)

MURDER/2ND DEGREE-INTENTIONAL
DISCHARGE OF GUN IN OCC DWELL
AGGRAVATED ASSAULT

_X_ The Court finds from the complaint and affidavit that there is probable cause to believe
both that a crime has been committed in Johnson County, Kansas and that the defendant
committed the same.
Defendant's bond is set at $1,000,000 cash or surety with the following conditions:
HOUSE ARREST WITH GPS
NO USE OF ILLEGAL DRUGS OR CONTROLLED SUBSTANCES/SUBMIT TO TESTING
WHEN DIRECTED BY COURT
NO ALCOHOL
NO FIREARMS
NO CONTACT VICTIM(S)/WITNESSES, THEIR RESIDENCE/ EMPLOYMENT
WHETHER OR NOT THEY POST BOND

/s/ DANIEL W VOKINS

04/01/16
Judge of the District Court

Clerk of the District Court, Johnson County Kansas

04/01/16 11:07am JL