IN THE CIRCUIT COURT

OF JACKSON COUNTY, MISSOURI

AT KANSAS CITY

COMPLAINT
STATE OF MISSOURI

-
VS.

Bryant L. Green
507 Quincy
Kansas City, MO 64123
DOB: 02/09/1988; RaceISex: B/M;

Defendant.

Count I. Murder 2nd degree (10031 110)

The Prosecuting Attorney of the County of Jackson, State of Missouri, up011 infornation
and belief, charges that the defendant, in violation of Section 565.021, RSMo, committed the
class A felony of murder in the second degree, punishable upon conviction under Section
558.011, RSMo, in that on or about October 10, 2010, in the County of Jackson, State of
Missouri, Stephanie N. Roberts was killed by being shot as a result of the attempted perpetration
of the class D felony of Unlawful Use of a Weapon under Section 571.030, RSMo colnlnitted by
the defendant on or about October 10,201 0, in the County of Jackson, State of Missouri.

Count 11. Unlawful use of a weapon (31 020990)

The Prosecuting Attorney of the County of Jackson, State of Missouri, upon il~fonl~ation
and belief, charges that the defendant, in violation of Section 571.030.1(4), RSMo, cornlnitted
the class D felony of unlawful use of a weapon, punishable upon conviction under Sections
558.011 and 560.01 1, RSMo, in that on or about October 10, 2010, in the County of Jackson,
State of Missouri, the defendant knowingly exhibited, in the presence of one or more persons a
9inm handgun, a weapon readily capable of lethal use, in an angry or threatening maimer.

Count 111. Assault 1st degree - serious physical injury (13011050)

The Prosecuting Attorney of the County of Jackson, State of Missouri, upon information
and belief, charges that the defendant, in violation of Section 565.050, RSMo, coinmitted the
class A felony of assault in the first degree, punishable upon conviction under Section 558.01 1,
RSMo, in that on or about October 10, 2010, in the County of Jackson, State of Missouri, the
defendant shot Vernelle Waxter, and such conduct was a substantial step toward the colnmission
of the crime of attempting to kill orcause serious physical injury to Vernelle Waxter, and was
 PROBABLE CAUSE STATEMENT FORM
Date: CRN: 10-078742

I, Detective Robert D. Guffey

(Naii~eand identify law enforcelnent officer, or person having ii~fonnatioiias probable cause.)

knowing that false statements on this form are punishable by law, state that the facts contained herein are tiue.

I have probable cause to believe that on 10-10-20 10 , at 3019 E. 12"' Street in

(Date) (Address)

Kansas City, Jacltsoi~ Missouri Bryant L.Green

(Cou1lt-y) (Name of Offender(s))

B/M, 02-09-1988, committed one or inore criminal offense(s)

The facts supporting this belief are as follows:

On 10-10-10 at approxiinately 0134 hours, members of the Kansas City, Missouri Police Department were
dispatched to 301 9 E. 1 2t1',Kansas City, Jacksoil County, Missouri regarding a shooting. Stephanie N. Roberts
W/F, 01-15-89 (victim) was located in the parlting lot located to the west of the address deceased from appar-ent
gunsllot wounds.

Dr. Mary H. Dudley Chief Medical Examiner of the Jackson County, Missouri Medical Office ruled the
cause of death a gunshot wouild of the head and neck and the rnaimer Homicide.

On 10-09-20 1 0 Stephanie Roberts arrived at the Jay's Bigger Jigger located at 3019 E. 12th with a group
of friends. Shoitly after arriving at Jay's Bigger Jigger; a fight broke out inside of the bar involviilg the #1
MTitnessand Vernelle K. Waxter BIM, 05-02-84 along wit11 several other parties. The bar staff broke the
altercation up and separated the parties iilvolved. The group associated with Stephanie Roberts was escorted
out of the front door; while the second group involved was escorted out of the south rear door of the bar. Shortly
after being escorted out of the front door a verbal altercatioil ensued between the two groups. The #3 Witness
stated "He's got a gun" referring to a person associated with the second group that was escorted out of the south
door of the establislunent. The #2 Witness stated that his brother, Bryant L. Green B/M, 02-09-88 walked to
his vehicle and obtained his fireann. The #2 Witness stated that Bryant Green fired a single shot in the air near
the parked vehicle located along the west side of the parkillg lot. The #2 Witness stated the he observed
Vernelle K. Waxter (identified fro111 a photo spread consistii~gof six black males) pull out a gun from hi s
waistband and started firing towards their direction. The #2 Witi~essstated that Bryant Green retur~~ed GI-c
towards the group associated with Vernelle Waxter. The #2, #3, and #4 Witnesses place Stephanie Roberts
behind Bryant Green at the time of the shooting. The #2 Witness stated he heard four or five shots fired from
across the parking lot and heard S tephalrie Roberts fall to the ground. After the slzots were fired witnesses
observed Vernelle Waxter flee fkom the scene in a black vehicle accompanied by a red vehicle from the south
entrance of the parking lot. The initial call for service was updated with Vernelle Waxter showing up at a local
Hospital with injuries sustained fiom gunshot wounds. Both vehicles that arrived at the Hospital were detained
until Detectives arrived on scene. Detectives observed a firearm located inside the #1 Witliesses vehicle.
Page 1 of 3
Form 50 P.D. (Rev. 9-2008)
 PROBABLE CAUSE STATEMENT FORM
CRN 10-078742

Witness #5 stated while they were driving Vernelle Wavter to the Hospital she observed a firearm lying of the
floor board near her feet. The #5 Witness was infonned that the firearrn belonged to the #1 Witness. Tlie #5
witness wrapped the firearm inside a white hooded sweatshirt and walked it over to the #1 Witnesses vehicle.
Video surveilla~~ce obtained fiom the Hospital revealed that Vernelle Waxter was transported to tlie Hospital in
the bIaclc Mercury Cougar. It further revealed the #5 Witness transporting an object wrapped in a \vhile from licr
vehicle to the # 1 Witnesses vehicle,

The #1 Witness stated that he was inside the bar prior to the shooting. The #1 Witness further stated that a
fight broke out inside tlie bar. Tlie #1 Witness stated that lie walked outside and gunshots starting going off. The
#1 Witness stated that "they started shooting first," referring to tlie parties towards the iiorth side of the parking
lot located to the west of the establishment. The #I Witnes was informed by Vernelle Waxter that he had been
shot. The #1 Witness further stated that Vernelle Waxter had lcnowledge of the firearm being inside of his
vehicle because he displayed the fireann to Vernelle Waxter before. The #1 Witiless further stated that
Vernelle Waxter had the fireanii at the scene but denied seeing Vernelle Waxter shooting the fireaim. The #1
Witiiess stated that the #5 Witness gave him a white shirt which contained what he believed to be his firearn at
the Hospital.

The #3 Witness transported the firearm that was that was shot by Bryant Green; which was give11 to
Detective prior to her foin~alstatement. The #3 Witness stated that he observed the firearn inside her vehicle's
center console prior to the shooting. The #3 Witness during the verbal altercation between parties associated
with Stephanie Roberts and the parties associated with the # 1 Witness she stated "011my God, he's got a guii."
The #3 Witness stated she rail after she heard gunshots and was not able to identify the shooter associated with
the #1 Witness.

The #4 Witness stated that he was involved in t l ~ ealtercation inside the bar prior to the shootiiig. The #4
Witness stated tlie verbal altercation continued outside in tlie parking lot. The #4 Witness stated tl~atas he was
appi-oacl~ingthe group of people that exited the south rear door when he heard a couple of gunshots behind hint.
The #4 Witness stated that Bryant Green was obviously shooting and he took cover behind solne vehicles. The
#4 Witness stated that he felt he was dodging bullets in attempt to get baclc to his vehicle to leave. The #4
Witness was unable to identify the second shooter involved.

Bryant Green respoiided to Police Headquarters after the shooting. Bryant Green admitted sliootil~ghis
handgun in the air as a wanling shot and also returning gunfire after being shot at. Bryant Green identified
Vernelle Waxter as being the second shooter with whoin he was exchanging gunfire.

Vernelle Waxter denied having any involvement regarding the shooting and the handling of a fiream.
Vernelle Waxter stated that he was involved in a physical altercation inside the bar and remembered being shot
after walking out the back door. Vernelle Waxter stated that he was driven to the Hospital by his friend in the
# 5 Witnesses vehicle.

The spent shell casings that were recovered at the scene were compared to the firearms recovered through
the course of the investigation. The comparisons revealed the shell casing to match the firearms recovered,
revealing no other f i r e m s had been fired.
Page 2 of 3
Form 50 P.D. (Rev. 9-2008)
 such assault, and in ihe course thereof inflicted serious
done for the pulyose o f co~~~mitting
pl~ysicalinjury on Vemelle Waxter.

Count IV. Armed crilninaB1 action (31010990)

The Prosecuting Attorney o f ihc Goullty o f Jackson, Stale o f Missouri, up011infornlation

and belief, charges that the defendant, in violation of Section 571.015, RSMo, committed the
felony o f armed criminal action, punishable upon conviction under Section 571.0%5.1, RSMo, m
that on or almui October 10, 2010, in the county of Jackson, State o f Missouri, the defa~danl
commiltcd t11c Felony o f assault in the first degree charged in Colu~t111, all allegations o f which
arc incorpol-atcd herein by reference, and the defendant co~nrnittcdthe foregoing felony of
assault in the firs1 degree by, with and through, the knowing use, assistance and aid o f a deadly
weapon,

'The fac1.s khal foz~ntlae basis for h i s i ~ a f ~ r ~ ~ x aand r ~ are contained in the attachcd
t i obelief
statc~xent(s)o f facts, made a part hereof and submitted as a basis up011 which this cou~-imay find
Ihe exisle~~ce
of probable cause.

W~erefore,the Prosecutillg Attorney prays that an arrest warrant be issued as provided by

law.

JAMES F, IlgrSaNATZAR
PI-osecutia~g
Attorney
Jackson County, Missouri