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A Criminal Court complaint was filed against the defendant, Willie Johnson, charging him with two counts of assault in the third degree, one count of attempted assault in the third degree and one count of harassment in the second degree. The complaint, which alleged that defendant struck the complainant numerous times and pulled hair from her head, was based on information furnished to the subscribing police officer and was not corroborated by the complainant.

The following day the People obtained a new complaint, sworn to by the complainant, which added the factual allegation that the defendant’s actions occurred in the presence of the complainant’s two minor children and added a charge of endangering the welfare of a child. In all other respects, the factual allegations and charges mirrored the original complaint. This superseding information was served and filed on May 5, 2003 in the courtroom. Treating it as an information, the court set a motion schedule.

 
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