1716-CR02794

IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI
AT KANSAS CITY

POLICE NO. 
PROSECUTOR NO. 095438308

STATE OF MISSOURI. 
PLAINTIFF, 
vs. 
ROBERT B. 

CASE NO. 1716-CR

DIVISION

DOB: 02/13/1971 
Race/Sex' 





DEFENDANT.

 

COMPLAINT
Count I. Receiving Stolen Property (570.080-002Y20022803.)

The Attorney General of the State of Missouri and the Prosecuting Attorney of the
County of Jackson, State of Missouri, upon information and belief, charges that the
defendant, in violation of Section 570 080, committed the class felony of
receiving stolen property, punishable upon conviction under Sections 558 01 and
560 011, in that on or about September 10,2015, in the County ofJackson, State of
Missouri, the defendant, acting in concert with Xtreme Concrete and Outdoor Living, LLC,
With the purpose to deprive Gail Yaw of Currency, retained such property, knowmg or
believing that it had been stolen, and the property appropriated was money ofa value of at
least five hundred dollars

The range punishment (at a class felon). ts In the custody nl'the 
lot a tettn ot'years not less than ten (2) years and not It) exceed set en years. or for a special tetnt
not It) exceed one l] teat In the jail tn olher penal b) a fine not to exceed five thousand
dollars 155 otm tn both and a fine it money at property has been gained thtongh the of
the crlme an). fine may be not ntnte than double the amount of the offender's gem {tom the commission of the
crlme up [0 a maxlmum thousand dollars (320,000)

Count II. Deceptive Business Practice (407.020-001Y19672607.)
The Attorney General of the State of Missouri and the Prosecuting Attorney of the
County of Jackson, State of Missouri, upon information and belief, charges that the
defendant, in violation of Sections 407.020, RSMo, committed the Class D Felony of
Unlawful Merchandising Practices, punishable upon conviction under Sections 558.011
and 560.011 RSMo, in that on or about September 10, 2015, in the County of Jackson, State
of Missouri, defendant, acting in concert with Xtreme Concrete and Outdoor Living, LLC,
in connection with the sale of merchandise in trade and commerce, to-wit: home repair and
renovation services to Gail Yaw, willfully, knowingly, and with the intent to defraud, made
the false promise to Gail Yaw that in exchange for money paid in advance, he would
complete agreed upon concrete remodel and repair services, a representation that was false
or misleading as to defendant’s intention or ability to perform the promise, or likelihood the
promise would be performed.
Count III. Receiving Stolen Property (570.080-002Y20022803.)
The Attorney General of the State of Missouri and the Prosecuting Attorney of the
County of Jackson, State of Missouri, upon information and belief, charges that the
defendant, in violation of Section 570.080, RSMo, committed the Class C Felony of
Receiving Stolen Property, punishable upon conviction under Sections 558.011 and
560.011, RSMo, in that on or about June 13, 2015, in the County of Jackson, State of
Missouri, the defendant, acting in concert with Xtreme Concrete and Outdoor Living, LLC,
with the purpose to deprive Robert Meints of U.S. Currency, retained such property,
knowing or believing that it had been stolen, and the property appropriated was money of a
value of at least five hundred dollars.
The range punishment for a class C felony is imprisonment in the custody of the Missouri Department of Corrections
for a term of years not less than two (2) years and not to exceed seven (7) years; or by imprisonment for a special term
not to exceed one (1) year in the county jail or other authorized penal institution; or by a fine not to exceed five thousand
dollars ($5,000); or by both imprisonment and a fine. If money or property has been gained through the commission of
the crime, any fine imposed may be not more than double the amount of the offender's gain from the commission of the
crime up to a maximum of twenty thousand dollars ($20,000).

Electronically Filed - Kansas City Criminal/Traffic - June 27, 2017 - 11:22 AM

State vs. Robert B. Williams

 Count IV. Deceptive Business Practice (407.020-001Y19672607.)
The Attorney General of the State of Missouri and the Prosecuting Attorney of the
County of Jackson, State of Missouri, upon information and belief, charges that the
defendant, in violation of Sections 407.020, RSMo, committed the Class D Felony of
Unlawful Merchandising Practices, punishable upon conviction under Sections 558.011
and 560.011 RSMo, in that on or about June 13, 2015, in the County of Jackson, State of
Missouri, defendant, acting in concert with Xtreme Concrete and Outdoor Living, LLC, in
connection with the sale of merchandise in trade and commerce, to-wit: home repair and
renovation services to Robert Meints, willfully, knowingly, and with the intent to defraud,
made the false promise to Robert Meints that in exchange for money paid in advance, he
would complete agreed upon concrete remodel and repair services, a representation that was
false or misleading as to defendant’s intention or ability to perform the promise, or likelihood
the promise would be performed.
Count V. Receiving Stolen Property (570.080-002Y20022803.)
The Attorney General of the State of Missouri and the Prosecuting Attorney of the
County of Jackson, State of Missouri, upon information and belief, charges that the
defendant, in violation of Section 570.080, RSMo, committed the Class C Felony of
Receiving Stolen Property, punishable upon conviction under Sections 558.011 and
560.011, RSMo, in that on or about June 29, 2015, in the County of Jackson, State of
Missouri, the defendant, acting in concert with Xtreme Concrete and Outdoor Living, LLC,
with the purpose to deprive Kevin and Michelle Thomas and Thomas Crushing, LLC, of
U.S. Currency, retained such property, knowing or believing that it had been stolen, and the
property appropriated was money of a value of at least five hundred dollars.
The range punishment for a class C felony is imprisonment in the custody of the Missouri Department of Corrections
for a term of years not less than two (2) years and not to exceed seven (7) years; or by imprisonment for a special term
not to exceed one (1) year in the county jail or other authorized penal institution; or by a fine not to exceed five thousand
dollars ($5,000); or by both imprisonment and a fine. If money or property has been gained through the commission of
the crime, any fine imposed may be not more than double the amount of the offender's gain from the commission of the
crime up to a maximum of twenty thousand dollars ($20,000).

Electronically Filed - Kansas City Criminal/Traffic - June 27, 2017 - 11:22 AM

State vs. Robert B. Williams

 Count VI. Deceptive Business Practice (407.020-001Y19672607.)
The Attorney General of the State of Missouri and the Prosecuting Attorney of the
County of Jackson, State of Missouri, upon information and belief, charges that the
defendant, in violation of Sections 407.020, RSMo, committed the Class D Felony of
Unlawful Merchandising Practices, punishable upon conviction under Sections 558.011
and 560.011 RSMo, in that on or about June 29, 2015, in the County of Jackson, State of
Missouri, defendant, acting in concert with Xtreme Concrete and Outdoor Living, LLC, in
connection with the sale of merchandise in trade and commerce, to-wit: home repair and
renovation services to Kevin and Michelle Thomas and Thomas Crushing, LLC, willfully,
knowingly, and with the intent to defraud, made the false promise to Kevin and Michelle
Thomas and Thomas Crushing, LLC, that in exchange for money paid in advance, he would
complete agreed upon concrete remodel and repair services for them, a representation that
was false or misleading as to defendant’s intention or ability to perform the promise, or
likelihood the promise would be performed.
The facts that form the basis for this information and belief are contained in the
attached statement(s) of facts, made a part hereof and submitted as a basis upon which this
court may find the existence of probable cause.
Wherefore, the Prosecuting Attorney prays that an arrest warrant be issued as
provided by law.
JEAN PETERS BAKER
Prosecuting Attorney
Jackson County, Missouri
by,
/s/ Julia A. Hamilton
Julia A. Hamilton (#45429)
Assistant Prosecuting Attorney
415 East 12th Street
Kansas City, MO - 64106
WITNESSES:
Tony Eierman , Office of the Attorney General

Electronically Filed - Kansas City Criminal/Traffic - June 27, 2017 - 11:22 AM

State vs. Robert B. Williams