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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             609.498                                             X1040                N         FILE NO.           AGENCY                CONTROL NO
                                                                                                  10-5305            MN0270000             10009350


                                                                                                  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
JONATHAN NICHOLAS TURNER                                                                            Date of Birth       MNCIS #:         27-CR-
    aka THIRSTY TURNER                                                                                6/25/85           LE#:             10-16858
                                                                                                                        SILS ID:         504824
                                                                            DEFENDANT,                                  TRACK ID:        2410531
MCF ST CLOUD
ST CLOUD, MN


                                                                                   COMPLAINT
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, Bernie Bogenreif, of the Hennepin County Sheriff's Office, has investigated the facts and circumstances
of this offense and believes the following establishes probable cause:

On 3/4/2010, JONATHAN NICHOLAS TURNER, the defendant named herein, was in custody at the Hennepin
County Adult Detention Center pending trial on two separate first degree murder cases. He was transported to a
holding cell awaiting a court appearance just after 8 a.m. on 3/4/2010. The defendant was mistakenly put in the same
holding cell as Victim A, a known adult male. Victim A had provided a taped statement to police implicating the
defendant in the murder cases. The defendant had received discovery and was aware that Victim A had provided the
taped statement.

At approximately 9:35 a.m., the video surveillance tape shows that Turner and Victim A were standing in the
entrance the cell restroom. A privacy wall screens the toilet area from surveillance camera view. The surveillance
video shows the defendant punch Victim A in the face and then the two disappeared behind the privacy wall. The
assault appears to continue as other inmates move to get a view of what is occurring. At approximately 9:38, the
defendant is seen dragging the victim out of the opening while a deputy comes to the cell door. After the deputy
leaves, the defendant again drags Victim A back into the toilet area out of camera view. At 9:39 a.m., the defendant
is escorted out of cell A and moved to another holding area.

Victim A told your complainant that the defendant confronted him about “jumping on his case.” He also confronted
him about his association with another witness who had testified against the defendant in two prior trials of the


FORM-J                                                                                                                                            REV. 12/95
                                                                                                            Page     2




defendant’s murder case. Victim A states that the defendant then suddenly struck him in the face and forced him
back into the toilet area that was off camera. The defendant pinned him in a headlock and continued to punch him.
The defendant had him over the sink and told him that he had heard Victim A’s statement on a CD or DVD. Victim
A did not tell the deputies what had happened but as soon as he arrived in court, he told his attorney.

Victim A’s account is corroborated by several other inmates who were present in the holding cell. In addition, your
complainant has reviewed written documents seized from the defendant’s cell pursuant to a search warrant. In those
documents, the defendant states: “I just hit Lemon in his mouth for making a statement on me. That’s why I’m in the
hole right now. I tried my best not to do it, but he betrayed me. I just couldn’t stand it. He sat there and lied to me
and tried to put it on his kids. It was crazy.” Lemon is a nickname for Victim A.

Other written documents seized from the defendant reference the defendant’s attempts to script testimony of other
possible witnesses in advance of his murder trial set for June 16, 2010. Victim A provided his statement to police
within a year of this assault.

The defendant is presently in custody.
                                                                                                                        Page     3
                                               COMPLAINT SUPPLEMENT

         CCT     SECTION/Subdivision             M.O.C.         GOC




                                                          OFFENSE

COUNT 1:       TAMPERING WITH A WITNESS-FIRST DEGREE (FELONY)
               MINN. STAT. § 609.498, SUBD. 1(f), 1a
               PENALTY: 0-5 YEARS AND/OR $10,000

That on or about March 4, 2010, in Hennepin County, Minnesota, JONATHAN NICHOLAS TURNER injured any
person or property in retaliation against Victim A, a person who provided information to law enforcement authorities
concerning a crime, within a year following the trial, proceeding or inquiry.




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:
   Detective Bernie Bogenreif
                       Being duly authorized to prosecute the offense(s) charged, I hereby approve this Complaint.
DATE:                                                                   PROSECUTING ATTORNEY’S SIGNATURE:
        May 13, 2010                             hlw
PROSECUTING ATTORNEY:
NAME/TITLE:                                                         ADDRESS/TELEPHONE:
   JUDITH A. JOHNSTON (150940)                                      C2100 Government Center, Minneapolis, MN 55487
   Assistant County Attorney                                        Telephone: 612-348-4083
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:

TITLE:

                                                 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.

                                                               SUMMONS
       THEREFORE YOU, THE ABOVE-NAMED DEFENDANT(S), ARE HEREBY SUMMONED to appear on the _______ day of
____________________, 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.

                                                        WARRANT
                                                  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: $500,000 + CR

Conditions of Release: No contact with victims; with witness(es); No contact with address of the offense or home/work of victim(s) and
witness(es)


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

NAME:                                                                     SIGNATURE

TITLE:      JUDGE OF DISTRICT COURT
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:
                    JONATHAN NICHOLAS TURNER
                      aka THIRSTY TURNER

                            Defendant(s).

				
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