Criminal Complaint Template - DOC - DOC by m4N9Vg

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									State of Minnesota                                                                                                    District Court
County of Hennepin                                                                                            Fourth Judicial District
 CCT           LIST CHARGE STATUTE ONLY                            MOC                  GOC       CTY ATTY           CONTROLLING
 1             609.352                                             Z1101                A         FILE NO.           AGENCY                CONTROL NO
                                                                                                  10-5747            MN0272100             10003850

                                                                                                  COURT CASE NO.                 DATE FILED

                                                                                                    Amended         Tab Charge Previously Filed
  if more than 6 counts (see attached)   if Domestic Assault as defined by MS 518B01, sub2a,b

                                                                                                     SERIOUS FELONY                SUMMONS
             State of Minnesota,                                                                     FELONY                        WARRANT
                                                                                PLAINTIFF,           GROSS MISDM DWI               ORDER OF DETENTION
                                                 VS.                                                 GROSS MISDM                   EXTRADITION

NAME: first, middle, last
IAN SCOT LAURIE                                                                                     Date of Birth       MNCIS #:         27-CR-
                                                                                                       6/5/68           LE#:             10-20579
                                                                            DEFENDANT,                                  SILS ID:         438360
13230 94TH AVE N                                                                                                        TRACK ID:        2426583
The Complainant, being duly sworn, makes complaint to the above-named Court and states that there is probable cause to believe that the
Defendant committed the following offense(s). The complainant states that the following facts establish PROBABLE CAUSE:

Complainant, Officer Bryan Kruelle of the St Louis Park Police Department, has investigated the facts and
circumstances of this offense and believes the following establishes probable cause:

On July 15, 2010, officers from the St. Louis Park Police Department spoke to a confidential informant who informed
them that he had been contacted numerous times by an individual identified as IAN SCOT LAURIE, Defendant
herein, who was seeking to have sex for money with a juvenile female. The Defendant had located the confidential
informant through a website where he runs an escort service. Over the past few months, the Defendant has repeatedly
contacted the CI asking him to find a juvenile female for him to have sex with. The CI initially told the Defendant
that he was not interested in pursuing this with him, but after repeated contact from the Defendant the CI agreed to
“play along.” At one point the CI offered to set the Defendant up with an 18-year-old female, but the Defendant
declined and told the CI that it should be a juvenile under 16-years-old.

On July 15th, 2010, the CI contacted the Defendant and told him that he had located a 15-year-old female for him to
have sex with and that the fee would be $185.00 for full sex service, but no anal penetration. The CI had not actually
located a 15-year-old female and immediately called the St. Louis Park Police Department after talking to the

On July 16, 2010, the Defendant contacted the CI to make arrangements to meet the juvenile female. During that
conversation, the Defendant indicated that the price of $185.00 might be a problem and the CI agreed to a price of
$100.00 solely for the Defendant to “do” the juvenile female.

Prior to the arranged time, an undercover, plain clothes officer arrived at the meeting location in order to pose as the
15-year-old female the Defendant had arranged to have sex with for money. At approximately 4:15 p.m. on July 16 th,
2010, the Defendant arrived at the meeting location and initially left because he wanted to wait for the CI to arrive.
When the Defendant came back a second time, the CI asked him if he was backing out of the arrangement because
FORM-J                                                                                                                                            REV. 12/95
                                                                                                           Page    2

she wasn’t cute enough. The Defendant replied “no sweetie, you’re perfect.” Defendant LAURIE then asked the
undercover officer if she was 15 and she replied that she was. The Defendant then left again and said he would return
in 10 minutes to see if the CI had arrived yet.

Prior to the Defendant returning, officers located him at his nearby office and placed him under arrest.

The Defendant is in custody.
                                                                                                                       Page     3
                                              COMPLAINT SUPPLEMENT

        CCT       SECTION/Subdivision             M.O.C.       GOC

                MINN. STAT. § 609.352, Subd. 2, Subd. 4; § 609.17
                PENALTY: 0-1 ½ YEARS AND/OR $2,500

That on or about July 15, 2010 to July 16, 2010, in St. Louis Park, Hennepin County, Minnesota, IAN SCOT
LAURIE, who was 18 years of age or older, attempted to solicit a known juvenile, 15 years of age or younger, to
engage in sexual conduct with intent to engage in sexual conduct.

NOTICE: You must appear for every court hearing on this charge. A failure to appear for court on this
charge is a criminal offense and may be punished as provided in Minn. Stat. § 609.49.

THEREFORE, Complainant requests that said Defendant, subject to bail or conditions of release be:
     (1) arrested or that other lawful steps be taken to obtain defendant’s appearance in court; or
     (2) detained, if already in custody, pending further proceedings;
and that said Defendant otherwise be dealt with according to law.
COMPLAINANT’S NAME:                                                COMPLAINANT’S SIGNATURE:
   Officer Bryan Kruelle
                      Being duly authorized to prosecute the offense(s) charged, I hereby approve this Complaint.
DATE:                                                                  PROSECUTING ATTORNEY’S SIGNATURE:
              July 19, 2010                 red
NAME/TITLE:                                                        ADDRESS/TELEPHONE:
   KRISTA L. BETTINGER (29066x)                                    C2100 Government Center, Minneapolis, MN 55487
   Assistant County Attorney                                       Telephone: 612-348-8488
FORM I-2                                                                                                            Rev. 3/94
                                                                                                                                   Page       4
Court Case # ________________________
This COMPLAINT was subscribed and sworn to before the undersigned this ____ day of __________________, 20___.
NAME:                                                                       SIGNATURE:


                                                 FINDING OF PROBABLE CAUSE
From the above sworn facts, and any supporting affidavits or supplemental sworn testimony, I, the Issuing Officer, have determined that
probable cause exists to support, subject to bail or conditions of release where applicable, Defendant(s) arrest or other lawful steps be taken
to obtain Defendant(s) appearance in Court, or his detention, if already in custody, pending further proceedings. The Defendant(s) is/are
thereof charged with the above-stated offense.

____________________, 20_____ at _______ AM/PM before the above-named court at _______________________________________
_________________________________________________ to answer this complaint.
       IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued.

                                                  EXECUTE IN MINNESOTA ONLY
         To the sheriff of the above-named county; or other person authorized to execute this WARRANT; I hereby order, in the name of the
State of Minnesota, that the above-named Defendant(s) be apprehended and arrested without delay and brought promptly before the above-
named Court (if in session, and if not, before a Judge or Judicial Officer of such Court without unnecessary delay, and in any event not later
than 36 hours after the arrest or as soon thereafter as such Judge or Judicial Officer is available) to be dealt with according to law.

                                                     ORDER OF DETENTION
        Since the above-named Defendant(s) is already in custody; I hereby order, subject to bail or conditions of release, that the above-
named Defendant(s) continue to be detained pending further proceedings.
Bail: $75,000 + CR

Conditions of Release:

This COMPLAINT-                  ORDER OF DETENTION           duly subscribed and sworn to, is issued by the undersigned Judicial
Officer this ____ day of _____________________________, 20____.

NAME:                                                                     SIGNATURE

Sworn testimony has been given before the Judicial Officer by the following witnesses:

STATE OF MINNESOTA                         COUNTY OF HENNEPIN                                Clerk's Signature or File Stamp:

                   STATE OF MINNESOTA
                                                                                                 RETURN OF SERVICE
                               Plaintiff                                  I hereby Certify and Return that I have served a copy of this
                                                                          COMPLAINT – SUMMONS, WARRANT, ORDER OF
                                  vs.                                     DETENTION upon Defendant(s) herein-named.
                                                                                          Signature of Authorized Service Agent:
                         IAN SCOT LAURIE


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