IN THE DISTRICT COURT OF KANSAS
EIGHTEENTH JUDICIAL DISTRICT
SEDGWICK COUNTY, CRIMINAL DEPARTMENT
THE STATE OF KANSAS )
Plaintiff, )
vs. )
) Case No.
DENNIS L. RADER, )
W/M, DOB: 03/09/45, )
)
Defendant. )
____________________________________)
COMPLAINT/INFORMATION
COUNT ONE
COMES NOW KIM T. PARKER, a duly appointed, qualified and acting Deputy District Attorney of the l8th Judicial District of the State of Kansas, and for and on behalf of said State gives the court to understand and be informed that in the County of Sedgwick, and State of Kansas, and on or about the 15th day of January, 1974, A.D., one DENNIS L. RADER did then and there unlawfully, kill a human being, to-wit: Joseph Otero, maliciously, willfully, deliberately and with premeditation by strangulation and/or asphyxiation, inflicting injuries from which the said Joseph Otero did die on or about January 15, 1974;
Contrary to Kansas Statutes Annotated 21-3401, Murder in the First Degree, Class A Felony [L. 1969, ch. 180, 21-3401; L. 1972, ch. 112, 1; July 1], Count One
COUNT TWO
and on or about the 15th day of January, 1974, A.D., in the County of Sedgwick, State of Kansas, one DENNIS L. RADER did then and there unlawfully, kill a human being, to-wit: Julie Otero, maliciously, willfully, deliberately and with premeditation by strangulation, inflicting injuries from which the said Julie Otero did die on or about January 15, 1974;
COUNT THREE
and on or about the 15th day of January, 1974, A.D., in the County of Sedgwick, State of Kansas, one DENNIS L. RADER did then and there unlawfully, kill a human being, to-wit: Josephine Otero, maliciously, willfully, deliberately and with premeditation by strangulation, inflicting injuries from which the said Josephine Otero did die on or about January 15, 1974;
COUNT FOUR
and on or about the 15th day of January, 1974, A.D., in the County of Sedgwick, State of Kansas, one DENNIS L. RADER did then and there unlawfully, kill a human being, to-wit: Joseph Otero, Jr., maliciously, willfully, deliberately and with premeditation by strangulation and/or asphyxiation, inflicting injuries from which the said Joseph Otero, Jr. did die on or about January 15, 1974;
Contrary to Kansas Statutes Annotated 21-3401, Murder in the First Degree, Class A Felony [L. 1969, ch. 180, 21-3401; L. 1972, ch. 112, 1; July 1], Count Two
Contrary to Kansas Statutes Annotated 21-3401, Murder in the First Degree, Class A Felony [L. 1969, ch. 180, 21-3401; L. 1972, ch. 112, 1; July 1], Count Three
Contrary to Kansas Statutes Annotated 21-3401, Murder in the First Degree, Class A Felony [L. 1969, ch. 180, 21-3401; L. 1972, ch. 112, 1; July 1], Count Four
COUNT FIVE
and on or about the 4th day of April, 1974, A.D., in the County of Sedgwick, State of Kansas, one DENNIS L. RADER did then and there unlawfully, kill a human being, to-wit: Kathryn Bright, maliciously, willfully, deliberately and with premeditation by strangulation and stabbing, inflicting injuries from which the said Kathryn Bright did die on April 4, 1974;
COUNT SIX
and on or about the 17th day of March, 1977, A.D., in the County of Sedgwick, State of Kansas, one DENNIS L. RADER did then and there unlawfully, kill a human being, to-wit: Shirley Vian, maliciously, willfully, deliberately and with premeditation by strangulation, inflicting injuries from which the said Shirley Vian did die on March 17, 1977;
COUNT SEVEN
and on or about the 8th day of December, 1977, A.D., in the County of Sedgwick, State of Kansas, one DENNIS L. RADER did then and there unlawfully, kill a human being, to-wit: Nancy Fox, maliciously, willfully, deliberately and with premeditation by strangulation, inflicting injuries from which the said Nancy Fox did die on December 8, 1977;
Contrary to Kansas Statutes Annotated 21-3401, Murder in the First Degree, Class A Felony [L. 1969, ch. 180, 21-3401; L. 1972, ch. 112, 1; July 1], Count Five
Contrary to Kansas Statutes Annotated 21-3401, Murder in the First Degree, Class A Felony [L. 1969, ch. 180, 21-3401; L. 1972, ch. 112, 1; July 1], Count Six
Contrary to Kansas Statutes Annotated 21-3401, Murder in the First Degree, Class A Felony [L. 1969, ch. 180, 21-3401; L. 1972, ch. 112, 1; July 1], Count Seven
COUNT EIGHT
and on or about the 27th day of April, 1985, A.D., to the 28th day of April, 1985, A.D., in the County of Sedgwick, State of Kansas, one DENNIS L. RADER did then and there unlawfully, kill a human being, to-wit: Marine Hedge, maliciously, willfully, deliberately and with premeditation by strangulation, inflicting injuries from which the said Marine Hedge did die on April 27, 1985;
COUNT NINE
and on or about the 16th day of September, 1986, A.D., in the County of Sedgwick, State of Kansas, one DENNIS L. RADER did then and there unlawfully, kill a human being, to-wit: Vicki Wegerle, maliciously, willfully, deliberately and with premeditation by strangulation, inflicting injuries from which the said Vicki Wegerle did die on September 16, 1986;
COUNT TEN
and on or about the 18th day of January, 1991, A.D., to the 19th day of January, 1991, A.D., in the County of Sedgwick, State of Kansas, one DENNIS L. RADER did then and there unlawfully, kill a human being, to-wit: Dolores E. Davis, maliciously, willfully, deliberately and with premeditation by strangulation, inflicting injuries from which the said Dolores E. Davis did die on January 19, 1991;
Contrary to Kansas Statutes Annotated 21-3401, Murder in the First Degree, Class A Felony [L. 1969, ch. 180, 21-3401; L. 1972, ch. 112, 1; July 1], Count Eight
Contrary to Kansas Statutes Annotated 21-3401, Murder in the First Degree, Class A Felony [L. 1969, ch. 180, 21-3401; L. 1972, ch. 112, 1; July 1], Count Nine
Contrary to Kansas Statutes Annotated 21-3401(a), Murder in the First Degree, Off-Grid Person Felony, [L. 1969, ch. 180, 21-3401; L. 1972, ch. 112, 1; July 1, L. 1989, ch. 87, 1, L. 1990, ch. 100, 2] Count Ten
all of the said acts then and there committed being contrary to the statutes in such cases made and provided and against the peace and dignity of the State of Kansas.