Here are the facts:

Mom of 4 day old has child out at 1:30 AM. Child is improperly secured in Child Seat and Seat is improperly installed.
Mom is on painkillers, so she allows unlicensed driver, who had been drinking, to drive her vehicle.
Driver, known by police to not have a license, is seen by police, who try to stop him.
He evades, high rate of speed. Ignores stoplights and stop signs. (Residential and Business area of town.)

I would like to indict driver for evading (3rd because of previous convictions for evading) and endangering a child. (For not having child properly restrained and evading with child in vehicle.)

I would like to indict mom for not insuring child is properly secured.

Anyone got any thoughts? Pro or Con