STATE OF WISCONSIN L, ., CIRCUIT COURT LA CROSSE COUNTY Evita STATE OF WISCONSIN, CRIMINAL COMPLAM Plaintiff, FEB 2 3 2005 913151!? - VS. s: .. fit-- 253?? . EUGENE J. T. SPEARS, JR., DOB: CASE NO. S4804 State Highway 35, Apartment 1 Genoa, Wisconsin PETER H. STEPHAN, DOB: 03-28?1958 CASE NO. 06-CF-157 1710 La Crescent Street, Apartment 108 La Crosse, Wisconsin 54603 NATHAN E. PETERSON, DOB: 11-15-1982 CASE NO. 06-CF-158 1710 La Crescent Street, Apartment 108 La Crosse, Wisconsin 54603 ROBERT M. NEARY, DOB: 01-22-1985 1731 La Crescent Street, Apartment 60 La Crosse, Wisconsin 54603 CASE NO. 06-CF-159 PATRICK W. JONES, DOB: 10-22-1982 CASE NO. 06-CF-160 No Pennanent Address ALISHA J. GROSS, DOB: 12-19?1987 CASE NO. 06-CF-161 1007 Mary Street Watertown, Wisconsin 53098 AMANDA R. GREEN, DOB: 10-14-1984 CASE NO. 06-CF-162 818 1st Avenue South West Waukon, Iowa 52172 ROBIN K. PETERSON, DOB: 12?08-1960 CASE NO. 1710 La Crescent Street, Apartment 108 La Crosse, Wisconsin 54603 Defendants. SPEARS: SEX: MALE RACE: WHITE HT: 5?10? WT: 154 HAIR: BROWN EYES: BLUE OTHER: ustWare #x?IS?l 139; WI DL No.: Warrant/commitment issued by LaCmsse Municipal Court dated 6-9-05 STEPHAN: SEX: MALE RACE: WHITE HT: 5?08" WT: 240 HAIR: BLACK EYES: BROWN OTHER: JustWare #x?6-1136; WI No.: 152796; FBI No.: WI DL NO.: NATHAN PETERSON: SEX: MALE RACE: WHITE HT: 5?08? WT: 115 HAIR: BROWN EYES: BROWN OTHER: JustWare #x-6-1137; WI DL No.: NEARY: SEX: MALE RACE: WHITE HT: 5?09? WT: 250 HAIR: BROWN EYES: BLUE OTHER: STATE OF WISCONSIN . Criminal Complaint Vs. Page 2 SPEARS, Stephan; Nathan Peterson; Neary; Jones; Gross; Green; Robin Peterson JustWare #x-6-1142; MN DL No.: N600745603060IEXPIRED JONES: SEX: MALE RACE: WHITE HT: 6?03" WT: 215 HAIR: BROWN EYES: BLUE OTHER: JustWare #x?6-1144; WI No.: 883096; FBI No.: DL No.: SEX: FEMALE RACE: WHITE HT: 5?04? WT: 105 HAIR: BLONDE EYES: BROWN OTHER: JustWare #x-6-1145; WI No.: 1067156; FBI No.: WI DL No.: 0620-0108-7959-02NAL1D GREEN: SEX: FEMALE RACE: WHITE HT: 5?04? WT: 100 HAIR: BROWN EYES: BROWN OTHER: JustWare #x-6-ll42, IA DL No.: ROBIN PETERSON: SEX: FEMALE RACE: WHITE HT: 5?03? WT: 200 HAIR: BROWN EYES: GREEN OTHER: ustWare #x-6-1154; WI No.: 221842; FBI No.: MN No.: 98020282; WI DL No.: P362- INVESTIGATOR RANDY RANK, City of La Crosse Police Department, being ?rst duly sworn on oath says that on information and belief: COUNT I: CONSPIRACY TO DELIVER MARIJUANA IN EXCESS OF 10000 GRAMS: During approximately November 15, 2005 through February 21, 2006, at various locations in the County of La Crosse, Wisconsin, the defendant did, with the intent that a crime be committed and while within drug free zones, conspire with others for the purpose of unlawfully delivering marijuana, a Schedule I controlled substance containing tetrahydrocannabinols, in an amount in excess of 1,000 grams but less than 2,500 grams, contrary to Wis. Stat. Sec. 939.31 and a Class Felony, usually punishable by a fine of not more than $25,000, imprisonment for not more than ten (10) years, or both, pursuant to Wis. Stat. Sec. 961 .41(1x), but, due to the fact that the offense was committed while within a drug free zone, the maximum term of imprisonment may be increased by not more than ?ve (5) years, pursuant to Wis. Stat. Sec. for a total maximum term of imprisonment of not more than ?fteen (15) years, and, upon conviction, the court shall suspend or revoke the defendant?s operating privileges for not less than six (6) months, nor more than ?ve (5) years, pursuant to Wis. Stat. Sec. 961 50(1); and prays that the defendant be dealt with according to law; that the basis for complainant?s charge of such offense is: PRIOR RECORD OF EUGENE J. T. SPEARS. JR. Upon a review of an of?cial Teletype provided by the Wisconsin Criminal Information Bureau, the Wisconsin Circuit Court Automated Program, and the files of the La Crosse County District Attorney?s Of?ce, when available, it has been determined that EUGENE J. T. SPEARS, JR. has the following convictions of record: DATE OFFENSE COUNTY FILE NO. NO CCAP ENTRIES PRIOR RECORD OF PETER H. Upon a review of an official Teletype provided by the Wisconsin Criminal Information Bureau, the Wisconsin Circuit Court Automated Program, and the ?les of the La Crosse County District Attorney's Office, when available, it has been determined that PETER H. STEPHAN has the following convictions of record: STATE OF WISCONSIN Criminal Complaint Vs. Page 3 SPEARS, Stephan; Nathan Peterson; Neary; Jones; Gross; Green; Robin Peterson DATE OFFENSE COUNTY FILE NO. 01-02-1980 Reckless Use of Weapon La Crosse unknown 01-03-1980 Reckless Use of Weapon La Crosse unknown 02-18-1980 PTC Felony Theft La Crosse unknown (Sentenced to prison-Waupon with 12-12-1980 parole date) 07-074 989 Delivery of Cocaine La Crosse 88-CF-462 (Five years priSOn) 07-07-1989 Delivery of Cocaine La Crosse 88-CF-462 (Five years prison-consecutive) 07-07-1989 Delivery of Cocaine La Crosse 88-CF-462 (Five years prison~consecutive, paroled 08?19-1994) CURRENT BOND CONDITIONS OF PETER H. STEPHAN I have reviewed the ?les of the La Crosse County District Attorney?s Of?ce and 1 note that PETER H. STEPHAN was previously released from custody pursuant to bonds in the following court ?les: LA CROSSE COUNTY 04-CF-428: Peter Stephan was released ?om custody on July 21, 2004. The defendant was charged with six counts of Forgery-Uttering, which are Felony offenses, and one count of Illegal Possession of Prescription Drug, which is a Misdemeanor offense. The defendant signed said bond, which remained in full force and effect through the present. Conditions of said bond include: appear at such times and places as required by the court; commit no crimes while out on bond; no contact with Rita and Roy no possession or consumption of any controlled substances without a prescription from a licensed physician; and do not leave La Crosse County without court permission. On August 11, 2004, the court modi?ed the bond to allow Stephan to leave the county as his work took him outside the county. PRIOR RECORD OF NATHAN E. PETERSON Upon a review of an of?cial Teletype provided by the Wisconsin Criminal Information Bureau, the Wisconsin Circuit Court Automated Program, and the ?les of the La Crosse County District Attomey?s Of?ce, when available, it has been determined that NATHAN E. PETERSON has the following convictions of record: DATE OFFENSE COUNTY FILE NO. NO CCAP ENTRIES PRIOR RECORD OF ROBERT M. NEARY Upon a review of an of?cial Teletype provided by the Wisconsin Criminal Information Bureau, the Wisconsin Circuit Court Automated Program, and the ?les of the La Crosse County District Attorney?s Of?ce, when available, it has been determined that ROBERT M. NEARY has the following convictions of record: DATE OFFENSE COUNTY FILE NO. NO CCAP ENTRIES PRIOR RECORD OF PATRICK W. JONES Upon a review of an of?cial Teletype provided by the Wisconsin Criminal Information Bureau, the Wisconsin Circuit Court Automated Program, and the ?les of the La Crosse County District STATE OF WISCONSIN Criminal Complaint Vs. Page 4 SPEARS, Stephan; Nathan Peterson; Neary; Jones; Gross; Green; Robin Peterson Attorney?s Of?ce, when available, it has been determined that PATRICK W. JONES has the following convictions of record: DATE OFFENSE COUNTY FILE NO. 08-10-2001 Possession of Marijuana Dane 113 04-30-2003 PTC Criminal Trespass to Dwelling Dodge 03-CM-53 PRIOR RECORD OF ALISHA J. GROSS Upon a review of an of?cial Teletype provided by the Wisconsin Criminal Information Bureau, the Wisconsin Circuit Court Automated Program, and the files of the La Crosse County District Attorney?s Of?ce, when available, it has been determined that ALISHA J. GROSS has the following convictions of record: DATE OFFENSE NO CCAP ENTRIES CURRENT BOND CONDITIONS OF ALICIA J. GROSS I have reviewed the ?les of the Jefferson County District Attorney?s Of?ce and I note that ALICIA J. GROSS was previously released from custody pursuant to bonds in the following court ?les: COUNTY FILE NO. JEFFERSON COUNTY Alisha Gross was released from custody on August 29, 2005. The defendant was charged with Possession of Marijuana and Possession of Drug Paraphernalia, both as Misdemeanor offenses. The defendant signed said bond, which, upon information and belief, remained in full force and effect through the present due to a deferred prosecution agreement entered into on October 11, 2005 for a period of six months. Conditions of said bond include: appear at such times and places as required by the court; commit no crimes while out on bond; and no possession of drug paraphernalia or possession or consumption of controlled substances without a valid prescription. PRIOR RECORD OF AMANDA R. GREEN Upon a review of an official Teletype provided by the Wisconsin Criminal Information Bureau, the Wisconsin Circuit Court Automated Program, and the ?les of the La Crosse County District Attorney?s Of?ce, when available, it has been determined that AMANDA R. GREEN has the following convictions of record: DATE OFFENSE COUNTY FILE NO. NO CCAP ENTRIES PRIOR RECORD OF ROBIN K. PETERSON Upon a review of an of?cial Teletype provided by the Wisconsin Criminal Information Bureau, the Wisconsin Circuit Court Automated Program, and the ?les of the La Crosse County District Attorney?s Of?ce, when available, it has been determined that ROBIN K. PETERSON has the following convictions of record: DATE OFFENSE COUNTY FILE NO. 05?24-2004 Illegal Possession of Prescription Drug La Crosse 05-24?2004 Illegal Possession of Prescription Drug La Crosse O4-CM-140 STATE OF WISCONSIN Criminal Complaint Vs. Page 5 SPEARS, Stephan; Nathan Peterson; Neary; Jones; Gross; Green; Robin Peterson I CURRENT BOND CONDITIONS OF ROBIN K. PETERSON I have reviewed the ?les of the La Crosse County District Attomey?s Of?ce and I note that ROBIN K. PETERSON was previously released from custody pursuant to bonds in the following court ?les: LA CROSSE COUNTY 06-CM-86: Robin Peterson was released from custody on or about November 21, 2005. The defendant was charged with three counts of Retail Theft and one count of Bail Jumping, all as Misdemeanor offenses. The defendant signed said bond, which remained in full force and effect through the present. Conditions of said bond include: appear at such times and places as required by the court; and commit no crimes while out on bond. FACTUAL BASIS I am informed in an of?cial report prepared by Investigator Marion Byerson, of the City of La Crosse Police Department (LCPD), which indicates that the LCPD was contacted by an individual, hereinafter referred to as Confidential Informant (CI), who provided Investigator Byerson with the names of two individuals who were involved in selling methamphetamine, ecstasy (MDMA), LSD (acid), and a new form of marij uana, which is referred to as Keefer (compressed marijuana composed of pure tetrahydrocannabinols The drug dealers were also involved in selling high grade marijuana and crank. The CI only knew the two individuals by their nicknames, which were Mike (found to be Robert M. Neary) and Nate (found to be Nathan E. Peterson). The CI agreed to make recorded phone calls to Neary and Nathan Peterson and to wear a body wire to record conversations. Investigator Byerson then contacted the Town of Campbell Police Department (CPD) and asked for their assistance because the two identified dealers resided in their jurisdiction. Through recorded phone calls and body wire conversations arrangements were made by the CI to purchase one ounce of the high grade marijuana and one ounce of the new drug called Keefer. Neary told the CI that both drugs would cost approximately $895. Neary also told the CI that his dealer would be leaving Nathan Peterson?s residence in approximately ten minutes to go pick up the two drugs. Investigator Rick Pfennig, LCPD, and Investigator Byerson followed an individual believed to be Neary?s dealer as that person drove from 1710 La Crescent Street in a 1995 which is registered to Nathan Peterson. The vehicle was followed to the Outback Steakhouse in the City of Onalaska where Investigator Byerson observed a white female come out of the building and engage in conversation 'with the driver of the vehicle through the driver?s door. The female then ran back into the restaurant but she returned in a few moments and she then appeared to hand the driver something. The? vehicle then drove into the Hampton Inn parking lot where it parked at the south end of the building. Investigator Byerson then observed a white male enter the building from that location. After a short period of time the same individual was observed leaving the motel and he was then followed back to 1710 La Crescent Street. Investigator Byerson met with the CI in the Perkins parking lot and had the CI call Neary to see if the drugs were available. Neary stated that he was looking at the drugs and wanted to know if the CI would meet him at the same location he met him at earlier, which was next to the laundry mat a half block away from 1710 La Crescent Street. Investigator Byerson advised the CI to have Neary meet him at the Hardees restaurant at Rose and Clinton Streets, City of La Crosse. Neary agreed to this STATE OF WISCONSIN Criminal Complaint Vs. Page 6 SPEARS, Stephan; Nathan Peterson; Neary; Jones; Gross; Green; Robin Peterson and stated it would take 20 to 25 minutes for him to arrive there. Investigator Byerson then contacted Sergeant Keith Roh, of the Onalaska Police Department (OPD), to request his assistance after learning that drugs were present at the Hampton Inn, which is located in the City of Onalaska. *Arrest at Hardees: While waiting for the arrival of Neary, Investigator Byerson contacted ADA Todd Bj erke to request assistance in the application for a search warrant for 1710 La Crescent Street. While applying for the telephonic search warrant, Investigator Byerson observed the same 1995 that was followed to the Hampton Inn pull into the Hardees parking lot. Once the search warrant was obtained Investigator Byerson instructed LCPD of?cers to effect an arrest on the occupants in the vehicle. Investigator Byerson went to the location of the arrests and he observed a male sitting in the CPS vehicle. The male was identi?ed as Robert Neary. Neary was searched and he was found to have two ziplock baggies of the high grade marijuana, two ziplock baggies of Keefer, ?ve hits of LSD, a green MDMA pill, a postal weighing scale and other contraband in his pockets. The vehicle Neary had driven to the area was then located in the Kwik Trip lot at 1300 Rose Street. Investigator Byerson made contact with the passenger in the vehicle, who ?t the description of the individual Investigator Byerson had observed driving Peterson?s vehicle earlier to the Outback Steakhouse and who had gotten out of the vehicle at the Hampton Inn. Investigator Byerson removed him from the front passenger seat and placed him under arrest. During a custodial search, a motel swipe key card, which was later identified by Investigator Byerson as belonging to the Hampton Inn, was located on his person. The person was identi?ed as Eugene Spears, Jr. While Investigator Byerson was arresting Spears a white female came out of Kwik Trip. As she was getting into the vehicle she was approached and identi?ed as Amanda Green. Green stated that she was the driver of the vehicle. She stated that she had driven the vehicle, with Spears and Neary to the Kwik Trip. She, too, was arrested and transported to the LCPD. The vehicle was driven to the LCPD by Investigator Pfennig for further searching. *Execution of Search Warrant at 1710 La Crescent Street: The of?cers then executed the search warrant at 1710 La Crescent Street, Town of Campbell. Assisting at this time were Of?cer Chris Carley, CPD, Sergeant Roh, Investigator Byerson, Investigator Pfennig and Of?cer Wieczorek, LCPD. When the of?cers approached the residence the living room lights were on. When the of?cers knocked on the door the lights went out. The of?cers could hear that someone was in the residence, but they would not come to the door. Due to the fact that the warrant was a knock and announce search warrant, the of?cers ?rst attempted to make contact with people inside the residence. Investigator Byerson then went to the window and could observe a white male looking through the peephole, but the male would not open the door. The of?cers then decided that a forced entry would be made, but a female was heard yelling, ?Hang on.? She then opened the door and Investigator Byerson entered and proceeded to look for the white male who was no longer in sight. The female was identi?ed as Robin Peterson. Robin Peterson stated that she was in bed when Peter Stephan came in and told her that the cops were at the door. He told her to not open the door and to be quiet. STATE OF WISCONSIN Criminal Complaint Vs. . Page 7 SPEARS, Stephan; Nathan Peterson; Neary; Jones; Gross; Green; Robin Peterson Investigator Byerson observed that the bathroom door was shut and a male party was heard stating that he was coming out. The male was identi?ed as Peter Stephan. Stephan had ?ushed the toilet but Investigator Byerson observed that a plastic bag containing numerous smaller ziplock plastic baggies did not ?ush down. The baggies were removed and maintained as evidence. Nathan Petersen was located in his bedroom, where he was sleeping. During a search of his bedroon officers located a gun case, which had a lock on it, which contained a 9 millimeter handgun with two magazines with live rounds. There were two other handguns located in the bedroom, which were found to be C02 guns and which were not removed from the residence. There was an obvious odor of marijuana in the bedroom and drug related evidence was removed. For details refer to the property report. After all three individuals were detained, the of?cers conducted a full search of all the rooms of the residence. In the bedroom of Robin Peterson, Investigator Byerson located a white powdery substance on her dresser on a mirror and a razor blade and other sharp objects with white powder on them. There were other items of drug paraphernalia located in her bedroom as well. In the living room area, where Stephan indicated he sleeps, the of?cers located, next to the couch, a marijuana pipe with residue and other packaging materials commonly used for packaging controlled substances. Also located in his area was a Radio Shack 200 channel scanner with antenna and a piece of paper that listed frequencies for the La Crosse County Sheriff?s Department, the LCPD, the West Salem Police Department, and frequencies for cordless phones. Drug dealers commonly use scanners to monitor the location and presence of law enforcement of?cers so they can avoid apprehension. Scanners are also utilized during the commission of other crimes. Also located in the kitchen was a spoon, which was burned on the bottom. Robin Peterson indicated that the spoon was used by Stephan to heat up his drugs before consuming them. Robin Peterson and Nathan Peterson were both advised of their rights verbally by Investigator Byerson while in the living room of the residence and while in the presence of several of the assisting of?cers. They both indicated they understood their rights, however, Nathan stated he did not want to speak with an attorney. *Initial Interview with Robin Peterson: Robin Peterson agreed to Speak with Investigator Byerson at the residence and she admitted that her son, Nathan Peterson, had been involved with drug trafficking with Neary and Spears. She also stated that Nathan Peterson and Neary were selling drugs for Spears. She stated that Stephan was buying drugs from her son, Nathan Peterson, and Stephan was also eating hydrocodone and percocet prescription pills, which he was obtaining from her son and other people. She further stated that Stephan would utilize spoons to heat up his drugs. Approximately two weeks ago, she indicated that Stephan shot up dilaudids, and used her needles to inject the drug into the top of his hand. She also stated that Stephan is in the methodone program and he is not suppose to be obtaining other drugs from others nor is he to be using other drugs. Robin Peterson was then transported to the LCPD where she gave a video taped interview to Investigator Byerson and Inv. Pfennig. Her interview was conducted at approximately 1:25 AM on 2-22-06 and completed at 2:15 AM. STATE OF WISCONSIN Criminal Complaint Vs. Page 8 SPEARS, Stephan; Nathan Peterson; Neary; Jones; Gross; Green; Robin Peterson *Second Interview with Robin Peterson: During a video taped interview, Robin Peterson gave further information about her involvement with and knowledge of controlled substances. She stated that she was using controlled substances, which she would obtain from Spears and her son, Nathan Peterson. She further stated that the white powdery substance found on top of her dresser would be crank (methamphetamine), which she had consumed. She stated that the crank came from Spears. She further stated that she also bangs drugs (referring to injection of the drugs by needle into a vein in her arm). She stated that because she is diabetic, she would utilize her own needles. She further stated that Stephan also used her needles to consume drugs. Robin Peterson identi?ed Spears as her son?s dealer. She stated that on Saturday, February 18, 2006, she went to Iowa with her son, Nathan Peterson, to pick up Spears. While in Iowa at Spear?s friend?s house, they consumed methamphetamine, which was provided to her by Spears. She further stated that she purchased crank from Spears on three occasions on that day. She stated that she consumed some of the crank and she brought some back to La Crosse. She stated that on Sunday, February 19, 2006, while in the city of La Crosse, she again used crank, which was what she had obtained from Spears. She stated that Spears has frequented her house with drugs on a number of occasions and had been ongoing for over one year to include when she lived at her residence on Diagonal Road in La Crosse. Over the last year Spears has delivered to her and to her son various drugs, to include methamphetamine, ecstasy/MDMA, LSD, methamphetamine, marijuana, and the new drug called Keefer on numerous occasions. She stated that her son, Nathan Peterson and Neary sell quantities of these drugs to other individuals in the city of La Crosse for Spears. She stated that she has overheard conversations between Spears and her son, Nathan Peterson, during which Spears talks about how he cooks methamphetamine and he also boasts about the amounts of money he makes from selling it. She stated that Spears charges S45 for a quarter ounce of methamphetamine and $25 for a quarter ounce of crank. Robin Peterson also stated she was aware that Spears had a dealer, who lived out of town, who sells high grade marijuana LSD and estacy. She thought that the dealer was in the city of La Crosse at this time because of a conversation she overheard. She provided further information relating to Stephan as to how he is stealing from Wal- mart stores. She stated that he is taking digital cameras, video cameras and other expensive devices from Wal?mart Without their permission. She further stated she has been present with him on several occasions and she observed how he was getting the merchandise out of the store. She stated that he would go to the check out counters with the merchandise where there were no clerks and he would scan the stolen items so the bar code would be de-coded and he would then walk out of the store with the items. She stated that he has been doing this for sometime. She stated that Stephan would give the stolen items to a white female would sell the stolen items for him and the white female would be provided with some of the money as a result. *Interview with Amanda Green: Investigator Byerson attempted to interview Amanda Green, who advised her address and admitted that her boyfriend is Eugene Spears. She further stated that she and Spears were not involved in selling drugs. She admitted that she stayed at 1710 La Crescent Street, Apartment 108 for one night and she admitted that she knew the individuals identi?ed through the investigation. *Interview with Eugene Spears: When asking Spears if he wanted to answer questions, he related that he just wanted to talk to his attorney before speaking with the police. STATE OF WISCONSIN - Criminal Complaint Vs. Page 9 SPEARS, Stephan; Nathan Peterson; Neary; Jones; Gross; Green; Robin Peterson *Interview with Robert Neary: Neary provided a video taped interview in reference to his involvement in drug trafficking. Neary stated that the drugs that he had in his possession were provided to him by Eugene Spears while at 1710 La Crescent Street, Apartment 108. He stated that Spears is the main supplier of drugs to him and to Nathan Peterson. The drugs include several different controlled substances, which they would then sell to others. They would then provide Spears with the money from those sales. He stated that Spears was picked up in Iowa over the weekend and brought back to La Crosse. He stated that spears is involved with methamphetamine. He stated that Spears has a dealer who lives in Watertown, Wisconsin. Spears had gone to pick up his dealer and he then brought him back to the city of La Crosse. He believed that the dealer was staying at the Hampton Inn. He stated that the name of the dealer should be Pat (found to be Patrick Jones) and his girlfriend is Alisha (found to be Alisha Gross). He further stated that Jones and Gross are the ones that supply Spears with high grade marijuana as well as the new drug they call Keefer, which he stated is pure THC. He knew that Jones also sells LSD and he knew that a half sheet of acid that was obtained from Jones earlier. Neary went on to state the marijuana that he was caught with was suppose to go to a customer of his and he was going to sell the drugs for $895 for two ounces of the Keefer drugs and for a half ounce of nuggets of high grade marijuana. Neary further stated that Spears was the one who went to the motel to obtain the drugs that Neary was arrested with. He stated that Spears obtained the drugs from Jones. He stated that Spears used Nathan Peterson?s vehicle to go pick up the controlled substances. He related that Nathan Peterson was aware that Spears was picking up drugs in his vehicle because both Nathan Peterson and Neary sold drugs for Spears. Neary further stated that he has known Spears for approximately three months and during that time period, he has purchased ecstasy, methamphetamine, high grade marijuana, keefer and crank, on a total of approximately 15 to 20 occasions. He would then sell these drugs for Spears and he would obtain a small amount of money for that. Neary further stated that Spear?s girlfriend, Amanda Green, gave him marijuana to smoke on February 21, 2006. He stated that Green is always with Spears when Spears would come to deliver the controlled substances to him and that she would witness the delivery of the drugs. He related that on Sunday, February 19, 2006, he observed a half sheet of acid at 1710 La Crescent Street. He related that Spears is a cooker of methamphetamine and that his girlfriend, Green, is somewhat involved with that. Sergeant Roh went to the Hampton Inn and attempted to make contact with Jones and Gross by using the key card that had been obtained from Spears. Sergeant Roh had determined that a female by the name of Alisha Gross had registered in room 201 and that she was from Watertown, Wisconsin. This information was con?rmed by Neary and was consistent with the information that Sergeant Roh had obtained. *Execution of Search Warrant at the Hampton Inn, Onalaska: With the assistance of the CPD, Investigators Byerson and Pfennig and Of?cer Wieczorek executed a search warrant that had previously been obtained for room 201 of the Hampton lnn. While standing by Room 201, Investigator Byerson heard the lid on the commode slam and it appeared that something was being flushed down the toilet. It was decided that the of?cers would then gain entry to the room. The inner latch had to be forced open. Upon entering the room, the of?cers could hear people in the bathroom and entry was gained into the bathroom where both Alisha Gross and her boyfriend, Patrick Jones, were located. STATE OF WISCONSIN Criminal Complaint Vs. Page 10 SPEARS, Stephan; Nathan Peterson; Neary; Jones; Gross; Green; Robin Peterson Investigator Byerson observed that there was a marijuana bud ?oating in the commode. Also in the bathroom, Investigator Byerson observed two large quantities of compressed marijuana, which was consistent with the marijuana found on the person of Neary. The weight of that substance was approximately 160 grams. Both Jones and Gross were found to be in possession of large quantities of money, which totaled $1464.00. *Interview with Alisha Gross: A taped interview was conducted with Gross, who admitted that she resided in Watertown, Wisconsin. She stated that she was not employed at this time and that when she was working, she was doing housecleaning. She stated that she and Jones were picked up and brought to La Crosse by a friend of theirs. Gross would not admit to any drug involvement. *Interview with Patrick Jones: Jones stated that he and his girlfriend were brought to La Crosse by a friend who was identi?ed as Spears. He stated that Spears brought them here in a vehicle later discovered to belong to Nathan Peterson. Jones stated that he and Gross have been staying at the motel for a couple of days. Jones related that he had been arrested for drug related matters in the past. He further. stated that he wanted to be honest about what was going on but he was not the type of person that rats out his friends and cause them to be placed in jail. Therefore, he did not want to speak about his involvement and knowledge of drug traf?cking. *Search of the 1995 No controlled substances were found in the vehicle other than some marijuana seeds located in a small Dirt Devil vacuum cleaner. There were other items located in the vehicle, which included a digital camera, binoculars, GPS device, and a night scope. These items were consistent with items that Robin Peterson admitted were being stolen from Wal-mart by Peter Stephan. It should be noted that Investigator Byerson did observe numerous other digital cameras when the search warrant was executed at Robin Peterson?s residence on La Crescent Street. Subscribed and sworn to before me and approved for ?ling. Datdt yofFeb ry,2006. ?ea; ?ag Mb RANDY RANK T0156 w. BJERKE, State Bar No. 1016005 Complainant Assistant District Attorney La Crosse County, Wisconsin