The Amended Criminal Complaint was handed out today against Craig Titus & Kelly Ryan. What was amended was adding charges of Murder and Kidnapping to Kelly Ryan, as well as Kidnapping to Craig Titus, which surprised some of the people in the courthouse. The official documents are three pages long, but here is an easier way to read the complaint.
Justice court, Las Vegas Township
Clark County, Nevada
The State of Nevada - Plaintiff
Vs.
Craig Michael Titus #1895641,
Kelly Ann Ryan,
Anthony R. Gross #1692881, - Defendants
Case No: 05F23407A-C
Dept No: 4
Amended Criminal Complaint
The Defendants above named having committed the crimes of Murder With Use Of Deadly Weapon (Felony - NRS 200.010, 200.030, 193.165); Kidnapping (Felony - NRS 200.310); Accessory to Murder (Felony - NRS 195.030, 195.040, 200.010, 200.030) and Third Degree Arson (Felony - NRS 205.020), in the manner following, io-wit: That the Defendants, on or between the 13th day of December and the 14th day of December, 2005, at and within the County of Clark, State of Nevada.
Count 1 - Murder With Use Of A Deadly Weapon
Defendants Craig Michael Titus and Kelly Ann Ryan, did then and there, willfully, feloniously, without authority of law, and with malice aforethought, kill Melissa James, a human being, by applying an "Air Taser" gun to the body of Melissa James and/or asphyxiating Melissa James and/or suffocating Melissa James and/or administering morphine and/or a related drug to Melissa James and/or manner; and means unknown, with a deadly weapon, to-wit: an "Air Taser'" gun and/or fabric ligature and/or wire ligature and/or other unknown object, the Defendants being responsible under one of more of the following principles of criminal liability; to wit:
(1) by directly committing the acts constituting the offense; and or (2) by said Defendants aiding and abetting each other in its commission, by counseling, encouraging, hiring, commanding, inducing or otherwise procuring each other to commit the acts constituting the offense, as evidenced by the conduct of the Defendants before, during and after the offense, and/or
(3) by the Defendants conspiring with each other to commit murder whereby each Defendant is vicariously liable for the acts of the other committed in furtherance of the conspiracy, and/or
(4) by committing the offense during the commission of a felony, to-wit: a kidnapping.
Count 2 - First Degree Kidnapping
Defendants Craig Michael Titus and Kelly Ann Ryan did then and there, willfully, unlawfully, feloniously, and without authority of law, seize, confine, inveigle, entice, decoy, abduct, conceal, kidnap, or carry away Melissa James, a human being, with the intent to hold or detain the said Melissa James against her will, and without her consent, for the purpose of inflicting substantial bodily hard or death; the Defendants being responsible under one or more of the following principles of criminal liability, to wit:
(1) by directly committing the acts constituting the offense, and/or (2) by said Defendants aiding and abetting each other it its commission by counseling, encouraging, hiring, commanding, inducing, or otherwise procuring each other to commit the acts constituting the offense, as evidenced by the conduct of the Defendants before, during, and after the offense, and/or
(3) by the Defendants conspiring with each other to commit the offense whereby each Defendant is vicariously liable for the acts of the other committed in furtherance of the conspiracy.
Count 3 - Accessory to Murder
Defendants Craig Michael Titus, Kelly Ann Ryan and Anthony R. Gross, did then and there willfully, unlawfully and feloniously harbor, conceal, or aid Craig Michael Titus and/or Kelly Ann Ryan, with the intent that the said Craig Michael Titus and/or Kelly Ann Ryan might avoid or escape from arrest, trial, conviction, or punishment, having knowledge that the said Craig Michael Titus and/or Kelly Ann Ryan had committed a felony, to-wit: murder, and was liable to arrest therefore.
Count 4 - Third Degree Arson
Defendants did then and there willfully, unlawfully, maliciously, and feloniously set fire to, and thereby cause to be burned, the unoccupied personal property of another, to-wit: a 2003 Jaguar, bearing Nevada License No. 269PPL, the property of Kelly Ann Ryan and/or unknown financial institution, being then and there located at Clark County, Nevada, by use of open flames and/or combustible materials, and/or by manner and means unknown; Defendants being responsible under one or more of the following principles of criminal liability, to wit:
(1) by directly committing the acts constituting the offense, and/or
(2) by said Defendants aiding and abetting each other in its commission by counseling, encouraging, hiring, commanding, inducing or otherwise procuring each other to commit the acts constituting the offense; and/or
(3) by the Defendants conspiring with each other to commit arson whereby each Defendant is vicariously liable for the acts of the other committed in furtherance of the conspiracy.
All of which is contrary to the form, force and effect of Statutes in such cases made and provided and against the peace and dignity of the State of Nevada. Said Complainant makes this declaration subject to the penalty of perjury.