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KEVIN STOCK
COUNTY CLERK
COUNT 1
I, Mary E. Robnett, Prosecuting Attorney for Pierce County, in the name and by the authority of the State of
Washington, do accuse MATTHEW ALLEN FARRAR of the crime of ASSAULT OF A CHILD IN THE SECOND
DEGREE, committed as follows:
That MATTHEW ALLEN FARRAR, in the State of Washington, on or about the 12th day of May, 2019, a
person eighteen years of age or older, unlawfully and feloniously, did: (a) commit the crime of assault in the
second degree, as defined in RCW 9A.36.021, against C.F., a child under the age of thirteen; or (b) did
intentionally assault said child causing bodily harm that was greater than transient physical pain or minor
temporary marks, and the person had previously engaged in a pattern or practice either of (i) assaulting the
child which has resulted in bodily harm that is greater than transient pain or minor temporary marks, or (ii)
causing the child physical pain or agony that is equivalent to that produced by torture., contrary to RCW 9A.
36.130, and against the peace and dignity of the State of Washington.
COUNT 2
And I, Mary E. Robnett, Prosecuting Attorney for Pierce County, in the name and by the authority of the State of
Washington, do accuse MATTHEW ALLEN FARRAR of the crime of ASSAULT 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 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 MATTHEW ALLEN FARRAR, in the State of Washington, on or about the 12th day of May, 2019, a
person eighteen years of age or older, did unlawfully and feloniously, under circumstances not amounting to
assault of a child in either the first or second degree, assault C.F., a child under the age of 13 years, when the
defendant, with criminal negligence, did cause bodily harm to C.F., by means of a weapon or other instrument
or thing likely to produce bodily harm, contrary to RCW 9A.36.031(1)(d) and 9A.36.140(1), and against the
peace and dignity of the State of Washington.