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SUPERIOR COURT OF WASHINGTON FOR KING COUNTY THE STATE OF WASHINGTON, Plaintiff,
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v. MARK W. RATHBUN,
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No.
06-1-03230-2 SEA
AMENDED INFORMATION
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Defendant.
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COUNT!
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I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington, do accuse MARK W. RATHBUN of the crime of Burglary
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in the First Degree, committed as follows:
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That the defendant MARK W. RATHBUN in King County, Washington, on or about May 13, 1996, did enter and remain unlawfully in a building located at 329 Northwest 46th Street, Seattle, in said county and state, with intent to commit a crime against a person or property therein, and in entering, and while in such building and in immediate flight therefrom, the defendant did assault a person, to-wit: p.v.;
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Contrary to RCW 9A.52.020, and against the peace and dignity of the State of Washington.
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And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington further do accuse the defendant MARK W. RATHBUN has committed multiple current offenses and the defendant's high offender score results in some of the current offenses going unpunished, under the authority ofRCW 9.94A.535(2)(c). And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington further do accuse the defendant MARK W. RATHBUN's prior unscored misdemeanor or prior unseored foreign criminal history results in a presumptive Daniel T. Satterberg, Prosecuting Attorney
AMENDED INFORMATION - 1
W554 King County Courthouse 516 Third Avenue Seattle. Washington98104 (206) 296-9000, FAX (206) 296-0955
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sentence that is clearly too lenient in light of the purpose of this chapter, as expressed in RCW 9.94A.OIO, contrmy to RCW 9.94A.535(2)(b).
2 COUNT II
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And I, Daniel T. Satterberg, Prosecuting Attorney aforesaid further do accuse MARK W., RATHBUN of the crime of Rape in the First Degree, a crime of the SaIne or similar character and based on a series of acts connected together with another crime charged herein, which crimes were part of a common scheme or plan, and which crimes were 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 other, committed as follows: That the defendant MARK. W. RATHBUN in King County, Washington, on or about May 13, 1996, by forcible compulsion did engage in sexual intercourse with another person naIned P.V., under circumstances where the defendant feloniously entered into the building where P.V. was situated;
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Contrmy to RCW 9A.44.040(1)(d), and against the peace and dignity of the State of Washington. And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the naIne and by the authority of the State of Washington further do accuse the defendant MARI( W. RATHBUN has committed multiple current offenses and the defendant's high offender score results in some of the current offenses going unpnnished, under the authority ofRCW 9.94A.535(2)(c).
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And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the naIne and by the authority of the State of Washington further do accuse the defendant MARI( W. RATHBUN's prior unscored misdemeanor or prior unscored foreign criminal history results in a presumptive sentence that is clearly too lenient in light of the purpose of this chapter, as expressed in RCW 9.94A.010, contrary to RCW 9.94A.535(2)(b).
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And I, Daniel T. Satterberg, Prosecuting Attorney aforesaid further do accuse MARK W. RATHBUN of the crime ofBurgIary in the First Degree, a crime of the SaIne or similar character and based on a series of acts connected together with another crime charged herein, which crimes were part of a common scheme or plan, and which crimes were 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 other, committed as follows: That the defendant MARK. W. RATHBUN in King County, Washington, on or about August J, 1996, did enter and remain unlawfully in a building located at 411 Northwest 42nd Street, Seattle, in said county and state, with intent to commit a crime against a person or property therein, and in entering, and while in such building and in immediate flight therefrom, the defendant did assault a person, to-wit: lW.; Daniel T. Satterberg, Prosecuting Attorney
AMENDED INFORMAnON - 2
W554 King County Courthouse 516 Third Avenue Seattle Washington 98104 (206) 296-9000, FAX (206) 296-0955 j
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Contrary to RCW 9A.52.020, and against the peace and dignity of the State of Washington. And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington further do accuse the defendant MARK W. RATHBUN has committed multiple current offenses and the defendant's high offender score results in some of the current offenses going unpunished, under the authority ofRCW 9.94A.535(2)(c).
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And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington further do accuse the defendant MARK W. RATHBUN's prior unscored misdemeanor or prior unscored foreign criminal history results in a presumptive sentence that is clearly too lenient in light of the purpose of this chapter, as expressed in RCW 9.94A.OI0, contrary to RCW 9.94A.535(2)(b).
8 COUNT IV
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And I, Daniel T. Satterberg, Prosecuting Attorney aforesaid further do accuse MARK W. RATHBUN of the crime of Rape in the First Degree, a crime of the same or similar character and based on a series of acts connected together with another crime charged herein, which crimes were part of a common scheme or plan, and which crimes were 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 other, committed as follows: That the defendant MARK W. RATHBUN in King County, Washington, on or about August 1, 1996, by forcible compulsion did engage in sexual intercourse with another person named J.W., under circumstances where the defendant feloniously entered into the building where J.W. was situated;
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Contrary to RCW 9A.44.040(1)(d), and against the peace and dignity of the State of Washington. And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority ofthe State of Washington further do accuse the defendant MARK W. RATHBUN has committed mUltiple current offenses and the defendant's high offender score results in some of the CtUTent offenses going unpunished, under the authority ofRCW 9.94A.535(2)(c).
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And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington further do accuse the defendant MARK W. RATHBDN's prior unscored misdemeanor or prior unscored foreign criminal history results in a presumptive sentence that is clearly too lenient in light of the purpose of this chapter, as expressed in RCW 9.94A.010, contrary to RCW 9.94A.535(2)(b).
22 23 Daniel T. Satterberg, Prosecuting Attorney W554 King County Courthouse
AMENDED INFORMATION - 3
516 Third Avenue Seattle, Washington 98104 (206) 296-9000, FAX (206) 296-0955
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COUNT V
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And I, Daniel T. Satterberg, Prosecuting Attorney aforesaid further do accuse MARK W. RATHBUN of the crime of Burglary in the First Degree, a crime of the same or similar character and based on a series of acts connected together with another crime charged herein, which crimes were part of a common scheme or plan, and which crimes were 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 other, committed as follows:
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That the defendant MARK W. RATHBUN in King County, Washiugton, on or about December 15, 1996, did enter and remain unlawfully in a building located at 361 Northwest 46th Street, Seattle, in said county and state, with intent to commit a crime against a person or property therein, and in entering, and. while in such building and in immediate flight therefrom, the defendant did assault a person, to-wit: E.K.;
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Contrary to RCW 9A.52.020, and against the peace and dignity of the State of Washington. And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington further do accuse the defendant MARK W. RATHBUN has committed multiple current offenses and the defendant's high offender score results in some of the current offenses going unpunished, under the authority ofRCW 9.94A.53 5(2)(c).
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And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington further do accuse the defendant MARK W. RATHBUN's prior unseored misdemeanor or prior unscored foreign criminal history results in a presumptive sentence that is clearly too lenient in light of the purpose of this chapter, as expressed in RCW 9.94A.OI0, contrary to RCW 9.94A.535(2)(b).
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And I, Daniel T. Satterberg, Prosecuting Attorney aforesaid further do accuse MARK W. RATHBUN of the crime of Rape in the First Degree, a crime of the same or similar character and based on a series of acts connected together with another crime charged herein, which crimes were part of a common scheme or plan, and which crimes were 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 other, committed as follows: That the defendant MARK W. RATHBUN in King County, Washington, on or about December 15, 1996, by forcible compulsion did engage in sexual intercourse with another person named E.K_, under circumstances where the defendant feloniously entered into the building where E.K. was situated;
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Contrary to RCW 9A.44.040(I)(d), and against the peace and dignity of the State of Washington. Daniel T. Satterberg, Prosecuting Attorney
AMENDED INFORMATION - 4
W554 King County Courthouse 516 Third Avenue Seattle~
Washington 98104
(206) 2%ยท9000, FAX (206) 296-0955
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And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington further do accuse the defendant MARK W. RATHBUN has committed multiple current offenses and the defendant's high offender score results in some of the current offenses going unpunished, under the authority of RCW 9 .94A.53 5(2)(c). And I, Daniel T. Satterberg, Prosecuting Attorney for King County in the name and by the authority of the State of Washington further do accuse the defendant MARK W. RATHBUN's prior unscored misdemeanor or prior unscored foreign criminal history results in a presumptive sentence that is clearly too lenient in light of the purpose of this chapter, as expressed in RCW 9.94A.010, contrary to RCW 9.94A.535(2)(b).
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9 can . O'Domell, WSBA #31488 Deputy Prosecuting Attorney
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23 Daniel T. Satterberg, Prosecuting Attorney WS54 King County Courthouse
AMENDED INFORMATION - 5
516Third Avenue Seattle, Washington 98104 (206) 296-9000, PAX (206) 296-0955