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Criminal Complaint Template The Hennepin County Attorney


									State of Minnesota                                                                                                               District Court
County of Hennepin                                                                                                       Fourth Judicial District
                                                                                                            CTY ATTY         CONTROLLING
CCT            LIST CHARGE STATUTE ONLY                             MOC                  GOC                FILE NO.         AGENCY              CONTROL NO.
1              609.19                                               H2010                 N                  08-6127         MN0271100            03198140

                                                                                                            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
                                                                                                               GROSS MISDM DWI        ORDER OF DETENTION
                                                                    PLAINTIFF,                                 GROSS MISDM            EXTRADITION


NAME: first, middle, last                                                                            Date of Birth         MNCIS #:
JONATHAN NICHOLAS TURNER                                                                                6/25/85
AKA Thirsty                                                                                                                LE#:      08-32471
                          DEFENDANT,                                                                                       SILS ID:  504824
9908 NICOLLET AVE S                                                                                                        TRACK ID: 2261180

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:

Your complainant, Sgt. Chris Hauglid, is an investigator with the Minneapolis Police Department assigned to the
Homicide Unit. In that capacity, he has investigated the facts and circumstances of the offense alleged herein by
reviewing reports prepared by other officers and by conducting personal investigation.

Your complainant has learned that on July 29, 2003, Marcus Julius Dortch, Victim A, was found with multiple
gunshot wounds near the intersection or 22nd Street East and Oakland Avenue South, Minneapolis, Hennepin
County, Minnesota. A known adult female hereinafter referred to as Victim B had sustained a grazing bullet injury in
her back. Ambulance crews transported the victims to the Hennepin County Medical Center. Victim A was
pronounced dead by emergency room physicians; Victim B was treated and released.

Victim B was interviewed by the police. She stated that she was approaching the intersection of 22 nd and Oakland
Avenue South when she observed an adult female known to her as “Dee.” She observed Dee talking with the victim
who was standing in the street with his bicycle. Victim B joined the conversation. Shortly thereafter, Victim B
observed two men quickly approaching them. Both men were armed with handguns and dressed in black. As they
got to within two feet of Victim A, one of them called him “Nigger.” When Victim A turned, the two men began to
shoot at him. Victim A tried to flee with Victim B and the men chased both of them. The men continued to fire their
guns from close range. The men fled the scene.

A known adult male, hereinafter referred to as Witness C, told police that he had witnessed the shooting. Witness C
was with a friend, Witness D, walking on the street near the shooting. Near 22nd Street East and Oakland Avenue
South, Witness C observed two men. One of those men was introduced to him as “Thirsty.” Witness C did not
remember the name of the second man. Both men were dressed in black hoodies and dark pants. The men were
FORM-J                                                                                                                                                 REV. 12/95
                                                                                                            Page        2

standing in a “cubby hole” by the trees. Witness C and D continued to walk across Oakland Avenue South. Witness
C heard some footsteps and turned to see “Thirsty,” AKA JONATHAN NICHOLAS TURNER, the defendant
named herein, and the second man running. He heard shots fired and so he took cover. He continued to observe and
saw both men firing from close range into Victim A’s back. The unidentified man ran from the scene. Witness C
continued to observe the defendant and saw him standing over the victim clicking an empty gun. The defendant then
fled. Witness C and D left the area in a car. A short time later, Witness D called the defendant and talked with him
briefly about the shooting. Your complainant has confirmed that a call was made from Witness D’s cell phone to the

Witness D corroborated the statement from Witness C. He stated that he observed two men dressed in black run up
on Victims A and B from the nearby bushes. He then observed the men shoot Victims A and B. In his initial
interviews, Witness D stated that the defendant was not one of the persons involved in the shooting. When
interviewed a second time, however, he told the police that the defendant was one of the shooters and that he had not
identified him previously because he didn’t want to get involved.

The defendant is presently in custody.
                                                                                                                      Page     3
                                             COMPLAINT SUPPLEMENT

        CCT     SECTION/Subdivision            M.O.C.         GOC


              MINN. STAT. § 609.19, SUBD 1(1); § 609.11
              PENALTY: 3 YEARS-40 YEARS

That on or about July 29, 2003, in Hennepin County, Minnesota, JONATHAN NICHOLAS TURNER AKA
THIRSTY, while using a firearm, caused the death of Marcus Julius Dortch, a human being, with intent to effect the
death of that person or another, but without premeditation.

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:
   Sergeant Chris Hauglid
                     Being duly authorized to prosecute the offense(s) charged, I hereby approve this Complaint.
DATE:                                                                 PROSECUTING ATTORNEY’S SIGNATURE:
August 20, 2008                                hlg
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:


                                                 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: $1,000,000+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

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


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