#3. The acts of alleged offense must be described in a non-prejudicial common language that anyone can understand or comprehend and detailed so as to enable a man or woman of average intelligence to understand the nature of the charge (to enable preparation of defense); the actual act or acts constituting the offense complained of.
The charge must not be described by parroting the statute or government Code; not by the language of same. The naming of the acts of the offense describes a specific offense whereas the verbiage of a government statute or code describes only a general class of offense. Facts in conclusion, of the law, must be stated. Presumptions, Assumptions, Opinions, or Conclusions cannot be considered in the determination of the probable cause. Think about it..
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