FILED

12 OCT 18 PM 3:18

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Defendant.

KING COUNTY SUPERIOR COURT CLERK E-FILED CASE NUMBER: 12-1-05668-1 SEA

SUPERIOR COURT OF WASHINGTON FOR KING COUNTY THE STATE OF WASHINGTON, Plaintiff, v. MICHAEL CRAIG HEYES, ) ) ) ) ) ) ) ) )

No.

12-1-05668-1 SEA

INFORMATION

I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington, do accuse MICHAEL CRAIG HEYES of the crime of Animal Cruelty in the First Degree, committed as follows: That the defendant MICHAEL CRAIG HEYES in King County, Washington, during a period of time intervening between July 22, 2012 through July 23, 2012, did intentionally and unlawfully inflict substantial pain on and/or cause physical injury to a black dog; Contrary to RCW 16.52.205, and against the peace and dignity of the State of Washington. DANIEL T. SATTERBERG Prosecuting Attorney

By: Benjamin Carr, WSBA #40778 Deputy Prosecuting Attorney

Daniel T. Satterberg, Prosecuting Attorney

INFORMATION - 1

W554 King County Courthouse 516 Third Avenue Seattle, Washington 98104 (206) 296-9000, FAX (206) 296-0955

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 REQUEST FOR BAIL Pursuant to CrR 2.2(b)(2)(i) and (ii), the State requests that bail be set at $50,000 based on the danger the defendant poses to the community and the likelihood he will fail to appear in response to a summons. This is an increase from the $25,000 bail initially imposed at First Appearance and reflects a greater understanding of the defendants violent behavior toward animals and himself and the defendants significant mental health issues. In this case, the defendant is alleged to have slashed his puppys throat. After doing so, the defendant took multiple pictures of the puppywhich he believed to be deadand sent the pictures to family and friends, telling them that he had just slit [his] dogs throat. With at least one family member, the defendant then sent a picture of him displaying a middle finger toward the camera with the caption F*** jail. The puppy survived and was placed in protective custody. The defendant gave differing accounts to police and veterinary technicians about what happened to his dog: he said he had been attacked by strangers on the street who slit the dogs throat to piss [the defendant] off, he said his puppys throat had been slashed during a home invasion incident, and he said that he slashed his own dogs throat as part of a military mission. The defendant also said multiple times that the puppy belonged to him and he could do with it what he wanted. The defendant said that if slashing the puppys throat didnt kill it, he would have dragged it behind a car until it died. In the immediate aftermath of this incident, the defendant was civilly committed. During the defendants commitment period, his home was searched by his family. Inside, his family discovered multiple videos recorded by the defendant of the defendant engaged in bestiality with his other pet dogs. The defendants other dogs were placed in protective custody. According to the defendants family, the defendant has a long history of mental illness including bi-polar disorder and schizophrenia. The defendant is also an active heroin and morphine user. Family and friends recently called police after the defendant displayed suicidal behaviors. Family members told police that there were previous incidents of unreported animal cruelty. CAUSE NO. 12-1-05668-1 SEA PROSECUTING ATTORNEY CASE SUMMARY AND REQUEST FOR BAIL AND/OR CONDITIONS OF RELEASE The State incorporates by reference the Certification for Determination of Probable Cause written by Officer Corbray regarding Redmond Police Department incident number 12-012582.

Prosecuting Attorney Case Summary and Request for Bail and/or Conditions of Release - 2

Daniel T. Satterberg, Prosecuting Attorney

W554 King County Courthouse 516 Third Avenue Seattle, Washington 98104 (206) 296-9000, FAX (206) 296-0955

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The defendants criminal history consists primarily of substance abuse and domestic violence offenses. As of October 18, 2012, the defendant's criminal history includes the following convictions: Attempting to Elude Police/ Reckless Endangerment (with DUI dismissed) (2010), Negligent Driving 1 (from DUI) (2009), Reckless Driving (from DUI) (2007), and Assault 4-DV (from Assault 3-DV) (2004). The defendant had at least one other incident of domestic violence in 2004 that was dismissed pursuant to plea. The defendant has a charge of Use of Drug Paraphernalia (2/20/12) currently pending. Given the disturbing allegations in this case, evidence of unreported violence against animals, and the defendants violent history, significant bail should be imposed to protect the community. Additionally, the State requests that the defendant be ordered to have no contact with animals of any kind. Signed this 18th day of October, 2012.

Benjamin Carr, WSBA #40778

Prosecuting Attorney Case Summary and Request for Bail and/or Conditions of Release - 3

Daniel T. Satterberg, Prosecuting Attorney

W554 King County Courthouse 516 Third Avenue Seattle, Washington 98104 (206) 296-9000, FAX (206) 296-0955