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STATE OF MINNESOTA                                                          DISTRICT COURT

COUNTY OF HENNEPIN                                             FOURTH JUDICIAL DISTRICT

                                                                COURT FILE NO: 09-271789
                                                            PROSECUTOR FILE NO: 2080698


State of Minnesota,

                             Plaintiff,


V.
Esther Ruth Brown
(DOB: 05/20/1969)
4227 James Ave. N.
Minneapolis, MN 55412

                             Defendant.

The complaint, 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):

                                           COUNT 1
On or about the 27th day of August, 2009, in Hennepin County, Minnesota, the defendant, JANE
DOE did wrongfully and unlawfully assault another with a deadly weapon.

Said acts constituting the offense of Assault in the second degree in violation of MN Statute:
§609.222. Subdivision1. Dangerous weapon: May be sentenced to imprisonment for not
more than seven years or to payment of a fine of not more than $14,000, or both.
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                           STATEMENT OF PROBABLE CAUSE


The complainant states that the following facts establish probable cause:

Your complainant is an investigator with the St. Paul Police Department and bases this complaint
upon her own investigation.

Officer Hedberg of the St. Paul Police Department reports that on 08/27/2009 at approximately
1649 hours, he was dispatched to the intersection of 36th Ave. N. and Penn Ave. N. in regards to
an attempted second degree assault. Upon arrival he observed a black male later identified as
Derrick Leron Charleston. Officer Hedberg recognized Derrick Charleston from an email sent
out by Sgt. Downing listing him as the only suspect in a burglary that occurred on 08/26/2009
where a 9mm handgun was stolen. Officer Hedberg then placed Charleston in the back seat of
his squad car. In regards to the second degree assault Charleston stated he was walking WB on
the north side of 36th Ave. N. towards Penn Ave. N. Charleston stated he looked to his left and
saw a dark green colored car with 20” silver rims driving up towards him. He then saw the front
seat passenger hold up a black handgun with both hands; point pointed at him and fired three
times. Charleston stated he was not hit. Charleston recognized the shooter as Esther Ruth Brown
and the vehicle as her car. Officer Hedberg was then approached by a white female, later
identified as Patricia Jean Knapp. Knapp stated she heard three shots coming from a dark green
colored vehicle. Officer Hedberg then searched the area. While searching he located three spent
9mm shell casings. Officer Hedberg then contacted Sgt. Downing and informed him that he had
located Charleston. Sgt. Downing advised Officer Hedberg to book Charleston for PC Burglary.
Charleston immediately stated he never burglarized a house. Charleston stated he was living with
Esther Brown and she had recently kicked him out. Charleston stated he has made several
attempts to get his things from the house and even contacted police to stand by while he gathered
his things. He then stated he finally got tired of waiting and attempted to gain entry into the
residence through a window. Officer Hedberg then contacted Sgt. Downing and advised him that
Brown had been located and taken into custody. He also advised Sgt. Downing of what
Charleston had told him regarding the burglary and the recovered 9mm shell casings. Sgt.
Downing then advised Officer Hedberg not to book Charleston but to inform him that he needed
to stop by the precinct and speak with Sgt. Downing. Officer Hedberg then transported
Charleston from the HCJ to the residence of 2120 Oliver Ave. N. Officer Hedberg then
proceeded to Browns residence in an attempt to locate the vehicle involved at the attempted
second degree assault. Once Officer Hedberg had arrived at Browns residence he recognized it
from a traffic stop he had conducted in the past. He remembered from the traffic stop that brown
parks her vehicle in the garage. He was unable to locate the vehicle.

				
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