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-OR IN THE ALTERNATIVE –
COUNT 1 – CHILD ABUSE ~ a felony on or between the first day of January, 2005, and the 11th day of October, 2005, the crime of CHILD ABUSE was feloniously committed in Lincoln County, State of Oklahoma, by MICHAEL LEE PORTER, who willfully or maliciously injured, tortured, maimed or used unreasonable force upon a child under the age of eighteen (18) years , specifically, KELSEY SMITH BRIGGS, thirty-three (33) months of age, to wit: by MICHAEL LEE PORTER, severely beating or using unreasonable force upon Kelsey Smith Briggs, thereby inflicting blunt force trauma to her abdomen resulting in bruising, lacerations, and internal injury; and beating her on or about the head, face, chest, back, buttocks, legs, on the 11th day of October, 2005, contrary to the provisions of Section 7115 of Title 10 of the Oklahoma Statutes and against the peace and dignity of the State of Oklahoma.
COUNT 2 – CHILD SEXUAL ABUSE ~ a felony on or between the 1st day of January, 2005, and the 11th day of October, 2005 the crime of SEXUAL ABUSE OF A CHILD was feloniously committed in Lincoln County, the State of Oklahoma, by MICHAEL LEE PORTER, who knowingly and intentionally looked upon and touched the body and private parts of Kelsey Smith Briggs, who was at the time thirty-three (33) months of age or less, in a lewd and lascivious manner and in a manner calculated to arouse and excite sexual interests, to-wit; by MICHAEL LEE PORTER sexually assaulting Kelsey Smith Briggs in the anal and/or vaginal area with a part of his body or an foreign unknown object resulting in bruising and tearing to the anal and/or vaginal area of Kelsey Smith Briggs, contrary to the provisions of Section 7115 of Title 10 of the Oklahoma Statutes , and against the peace and dignity of the State of Oklahoma.
Richard L. Smothermon
DISTRICT ATTORNEY
