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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             609.342                                             L1021                N         FILE NO.           AGENCY                CONTROL NO

 2             609.342                                             L1421                N         10-5270            MN0272100             09006955
 3             609.344                                             L1055                N
 4             609.344                                             L1025                N         COURT CASE NO.                 DATE FILED
 5             609.344                                             L1425                N

                                                                                                    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
ROGER SHANIELLE ELLIS                                                                               Date of Birth       MNCIS #:         27-CR-
                                                                                                      2/28/73           LE#:             10-16406
                                                                            DEFENDANT,                                  SILS ID:         369372
3439 15TH AVE S #4                                                                                                      TRACK ID:        2408490
MINNEAPOLIS, MN 55411


                                                                                   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, Robert Baumgartner, of the St Louis Park Police Department, has investigated the facts and
circumstances of this offense and believes the following establishes probable cause:

On November 18, 2009, your Complainant was assigned a welfare check of two juvenile girls, Child A, who is 16
years of age and Child B who is 12 years of age. A report was received that both girls had been sexually assaulted by
their father, Defendant, ROGER SHANIELLE ELLIS, and were pregnant by him. Your Complainant spoke with
the Defendant on November 24, 2009 and the Defendant denied having sex with either Child A or Child B. The
Defendant further stated that his ex-wife lost custody of their children and she constantly makes up lies about him.

Your Complainant then interviewed Child A on November 25, 2009, and she stated that the father of her unborn child
was her boyfriend, whose last name she did not know. Child A stated that Child B was not pregnant. On December
3, 2009, your Complainant received a call from a Park Nicollet social worker reporting that Child B was 24 months
pregnant. Based on this information, your Complainant arranged to have Child B interviewed at CornerHouse. In
that interview, Child B claimed that she had been sexually assaulted by her brother, Child C and that he had gotten
her pregnant. Your Complainant took Child C into custody. He admitted having sex with Child B when they had
lived in Chicago, but denied having sex with her since moving to Minnesota.

Your Complainant collected a buccal swab from the Defendant and from Child C. Child A’s baby was born on
January 8, 2010. Child B’s baby was born March 10, 2010. Buccal swabs were taken from both babies.

On April 19, 2010, the Bureau of Criminal Apprehension issued a report stating that the Defendant cannot be
excluded from being the father of Child A’s baby. “It is estimated that 99.9999997% of the general population can
FORM-J                                                                                                                                            REV. 12/95
                                                                                                           Page       2




be excluded from being the biological father of [Child A’s baby].” The report further stated that the Defendant
cannot be excluded from being the father of Child B’s baby. “It is estimated that 99.9991% of the general population
can be excluded from being the biological father of [Child B’s baby].” Child C was excluded from being the
biological father of Child B’s baby.

The Defendant is not in custody. Due to his having continued contact with Child A and Child B and the potential for
witness tampering, a warrant is being requested.



                                                   OFFENSE



COUNT 1:      CRIMINAL SEXUAL CONDUCT IN THE FIRST DEGREE (FELONY)
              MINN. STAT. § 609.342, SUBD. 1(a), SUBD. 2; § 609.101, SUBD. 2; § 609.3455
              PENALTY: 0-30 YEARS AND/OR $12,000-$40,000 PLUS CONDITIONAL RELEASE

That on or between July 1, 2009 and January 1, 2010, in Hennepin County, Minnesota, ROGER SHANIELLE
ELLIS, born 2/28/73, engaged in sexual penetration with Child B, a person under the age of thirteen years, and more
than thirty-six months younger than ROGER SHANIELLE ELLIS.

COUNT 2:      CRIMINAL SEXUAL CONDUCT IN THE FIRST DEGREE (FELONY)
              MINN. STAT. § 609.342, SUBD. 1(h)(ii), SUBD. 2; § 609.101, SUBD. 2; § 609.3455
              PENALTY: 0-30 YEARS AND/OR $12,000-$40,000 PLUS CONDITIONAL RELEASE

That on or between July 1, 2009 and January 1, 2010, in Hennepin County, Minnesota, ROGER SHANIELLE
ELLIS, born 2/28/73, engaged in sexual penetration with Child B, a person under sixteen (16) years of age at the time
of the sexual penetration, and ROGER SHANIELLE ELLIS is the victim's father, and the victim suffered personal
injury.

COUNT 3:      CRIMINAL SEXUAL CONDUCT IN THE THIRD DEGREE (FELONY)
              MINN. STAT. § 609.344, SUBD. 1(e), SUBD. 2; § 609.101, SUBD. 2; § 609.3455
              PENALTY: 0-15 YEARS AND/OR $9,000-$30,000 PLUS CONDITIONAL RELEASE

That on or between May 1, 2009 and December 1, 2009, in Hennepin County, Minnesota, ROGER SHANIELLE
ELLIS, born 2/28/73, who was in a position of authority over the Child A, engaged in sexual penetration with Child
A, a person at least sixteen (16) years but less than eighteen (18) years of age, and more than forty-eight months
younger than ROGER SHANIELLE ELLIS.



                                      Offense portion continued on next page.
                                                                                                                      Page     3
                                             COMPLAINT SUPPLEMENT

        CCT     SECTION/Subdivision            M.O.C.         GOC




COUNT 4:      CRIMINAL SEXUAL CONDUCT IN THE THIRD DEGREE (FELONY)
              MINN. STAT. § 609.344, SUBD. 1(f), SUBD. 2; § 609.101, SUBD. 2; § 609.3455
              PENALTY: 0-15 YEARS AND/OR $9,000-$30,000

That on or between May 1, 2009 and December 1, 2009, in Hennepin County, Minnesota, ROGER SHANIELLE
ELLIS, born 2/28/73, engaged in sexual penetration with Child A, a person at least sixteen (16) but under eighteen
(18) years of age at the time of the sexual penetration, and ROGER SHANIELLE ELLIS is the victim's father.


COUNT 5:      CRIMINAL SEXUAL CONDUCT IN THE THIRD DEGREE (FELONY)
              MINN. STAT. § 609.344, SUBD. 1(g)(ii), SUBD. 2; § 609.101, SUBD. 2; § 609.3455
              PENALTY: 0-15 YEARS AND/OR $9,000-$30,000

That on or between May 1, 2009 and December 1, 2009, in Hennepin County, Minnesota, ROGER SHANIELLE
ELLIS, born 2/28/73, engaged in sexual penetration with Child A, a person at least sixteen (16) but under eighteen
(18) years of age at the time of the penetration, and ROGER SHANIELLE ELLIS is the victim's father, and the
victim suffered personal injury.


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:
   Robert Baumgartner
                     Being duly authorized to prosecute the offense(s) charged, I hereby approve this Complaint.
DATE:                                                                 PROSECUTING ATTORNEY’S SIGNATURE:
May 7, 2010                                    hlg
PROSECUTING ATTORNEY:
NAME/TITLE:                                                       ADDRESS/TELEPHONE:
   DEBORAH L. RUSSELL (242998)                                    C2100 Government Center, Minneapolis, MN 55487
   Assistant County Attorney                                      Telephone: 612-348-6077
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 victim(s); No contact 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:
                    ROGER SHANIELLE ELLIS


                            Defendant(s).

				
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