For Official Use

STATE OF WISCONSIN
STATE OF WISCONSIN

CIRCUIT COURT

MILWAUKEE COUNTY

DA Case No.: 2016ML024550
Court Case No.:

Plaintiff,

vs.
Heaggan-Brown, Dominique L
5313 North 65th Street
Milwaukee, WI 53218
DOB: 01/08/1992
Defendant,

CRIMINAL COMPLAINT
Complaining Witness:
Lt. Patrick Fortune

THE ABOVE NAMED COMPLAINING WITNESS BEING DULY SWORN, ON INFORMATION AND
BELIEF STATES THAT:
Count 1: SECOND DEGREE SEXUAL ASSAULT
The above-named defendant on or about Sunday, August 14, 2016, at 5313 North 65th Street, in the
City of Milwaukee, Milwaukee County, Wisconsin, did have sexual intercourse with a person, AV1, who
was under the influence of an intoxicant to a degree which rendered that person incapable of giving
consent, and the defendant had the purpose to have sexual intercourse with the person while the
person was incapable of giving consent, contrary to sec. 940.225(2)(cm), 939.50(3)(c) Wis. Stats.
Upon conviction for this offense, a Class C Felony, the defendant may be fined not more than One
Hundred Thousand Dollars ($100,000), or imprisoned not more than forty (40) years, or both.
Count 2: PROSTITUTION - NONMARITAL SEXUAL INTERCOURSE
The above-named defendant between December 1, 2015 and December 31, 2015, at 5313 North 65th
Street, in the City of Milwaukee, Milwaukee County, Wisconsin, did intentionally request to have nonmarital sexual intercourse from AV2, for anything of value, contrary to sec. 944.30(1m)(a), 939.51(3)(a)
Wis. Stats.
Upon conviction for this offense, a Class A Misdemeanor, the defendant may be fined not more than
Ten Thousand Dollars ($10,000), or imprisoned not more than nine (9) months, or both.
Count 3: PROSTITUTION - NONMARITAL SEXUAL INTERCOURSE
The above-named defendant between July 1, 2016 and August 13, 2016, at 5313 North 65th Street, in
the City of Milwaukee, Milwaukee County, Wisconsin, did intentionally request to have non-marital
sexual intercourse from AV3, for anything of value, contrary to sec. 944.30(1m)(a), 939.51(3)(a) Wis.
Stats.
Upon conviction for this offense, a Class A Misdemeanor, the defendant may be fined not more than
Ten Thousand Dollars ($10,000), or imprisoned not more than nine (9) months, or both.
Count 4: SECOND DEGREE SEXUAL ASSAULT
The above-named defendant on or about Saturday, July 30, 2016, at 5313 North 65th Street, in the City
of Milwaukee, Milwaukee County, Wisconsin, did have sexual contact with AV4, who the defendant
knew was unconscious, contrary to sec. 940.225(2)(d), 939.50(3)(c) Wis. Stats.

 Upon conviction for this offense, a Class C Felony, the defendant may be fined not more than One
Hundred Thousand Dollars ($100,000), or imprisoned not more than forty (40) years, or both.
Count 5: CAPTURE AN INTIMATE REPRESENTATION WITHOUT CONSENT
The above-named defendant on or about Saturday, July 30, 2016, at 5313 North 65th Street, in the City
of Milwaukee, Milwaukee County, Wisconsin, , did capture an intimate representation without the
consent of the person depicted under circumstance in which AV4 had a reasonable expectation of
privacy, where the defendant had reason to know that AV4 who was depicted nude did not consent to
the capture of an intimate representation, contrary to sec. 942.09(2)(am)1, 939.50(3)(i) Wis. Stats.
Upon conviction for this offense, a Class I Felony, the defendant may be fined not more than Ten
Thousand Dollars ($10,000), or imprisoned not more than three (3) years and six (6) months, or both.

This complaint is supported by the written reports of City of Milwaukee law enforcement officers whose
written reports were prepared through the normal course of police business and which your
complaining witness has relied upon in the past and found to be truthful and accurate. Based upon a
review of the reports pertaining to the investigation of this matter, your complaining witness believes
that:

AS TO ADULT VICTIM ONE

At 4:20 AM on August 15, 2016, Matthew O’Brien was working in his capacity as a security officer for
Saint Joseph’s hospital when the above defendant came into the hospital lobby seeking O’Brien’s
assistance. The defendant claimed to have been out drinking with adult victim #1 (hereinafter AV1) at a
bar, informing O’Brien that AV1 drank too much and was “out of it.”
Matthew O’Brien retrieved a wheelchair and proceeded to the defendant’s car to assist AV1. As O’Brien
and the defendant walked to the defendant’s car, the defendant told O’Brien that AV1 was “completely
out, zonked out of his gourd.” Upon making contact with AV1, O’Brien attempted to rouse AV1 by
rubbing AV1’s sternum. AV1 twitched in response, but did not otherwise become alert. The defendant
placed AV1 into the wheelchair. O’Brien and the defendant took AV1 to emergency room #1 and placed
AV1 onto a hospital bed.
As the nurses entered the room and began providing aid to AV1, AV1 flipped out. “Help me, help me,
he was touching me”, exclaimed AV1. AV1 was terrified, gripping O’Brien’s arm with a “little child death
grip.” Additional security was called into the room to secure AV1 and attempt to calm AV1 down.
O’Brien noticed that AV1 flipped out when the defendant was visible to AV1, prompting security
personnel to hide the defendant from AV1’s view. As the defendant left the hospital, AV1 was secured
in a four-point restraint. “He raped me, he raped me”, AV1 exclaimed. AV1 repeatedly told security
personnel that AV1 was trying to help security capture the defendant.
Matthew O’Brien recognized the defendant as a City of Milwaukee Police Officer whom O’Brien worked
with at least a dozen times in the past through O’Brien’s capacity as a security officer with Saint
Joseph’s Hospital. O’Brien identified the defendant in a photo array.
AV1 participated in a sexual assault examination and physical evidence was collected from AV1’s body
and sent to the Wisconsin State Crime Laboratory. AV1’s pants and underwear were also collected and
processed as physical evidence.

 One day after the assault, on August 16, 2016, AV1 participated in an interview with police wherein
AV1 provided the following information. AV1 did not know the defendant prior to July 12, 2016. AV1 first
met the defendant through FACEBOOK. AV1 was looking for another musician to help AV1 with AV1’s
music. As a rapper, the defendant thought he could assist AV1. The defendant wanted to meet up with
AV1 and requested AV1’s number. AV1 provided AV1’s number to the defendant.
The defendant sent text messages to AV1 on three to four occasions attempting to meet. On August
14, 2016, the defendant sent another text message to AV1 requesting to meet. AV1 agreed, and at
11:00 PM, the defendant picked AV1 up and took AV1 to the bar.
Once at the Bar, the defendant engaged in a private conversation with the bartender. Upon returning to
AV1, the defendant told AV1 the bar did not sell Hennessy, but the bar has it for the defendant. The
defendant informed AV1 that the defendant was the boss and there are no limitations on how the
defendant lives. The bartender asked AV1 what AV1 wanted to drink. AV1 informed the bartender AV1
does not usually drink. The bartender made AV1 a long island iced tea. The defendant and AV1 sat and
watched television, as coverage of the Sherman Park protests aired.
The bartender brought shots over for the defendant and AV1. During AV1’s time at the bar, AV1
believed that AV1 ingested two long island iced teas, three shots of Hennessy, and a pink drink. As the
defendant and AV1 drank, the two discussed music. The defendant bragged about being able to do
whatever the defendant wanted without repercussions. The defendant asked AV1 what AV1’s limits
were. The defendant reiterated that the defendant did not have limits.
AV1 had difficulty remembering what transpired after AV1 left the bar with the defendant. AV1 did recall
waking up to the defendant attempting to place the defendant’s penis in AV1’s anus. AV1 was
struggling to breathe as the defendant raped AV1. AV1 saw a gun in the room. As AV1 recalled the
events of being assaulted by the defendant, AV1’s eyes filled with tears.
When asked what else AV1 remembered, AV1 recalled the defendant undressing AV1. The defendant
repeatedly told AV1 to get on the bed. AV1 repeatedly responded, “no.” The defendant escorted AV1 to
the bed. AV1 felt drugged. The defendant instructed AV1 to open AV1’s mouth. Feeling threatened,
AV1 opened AV1’s mouth. The defendant put the defendant’s penis into AV1’s mouth. The defendant
told AV1 that AV1 was cute. The defendant ejaculated into AV1’s mouth.
AV1 attempted to move away from the defendant. The defendant responded, “what are you doing, what
are you doing, you are mine now.” The defendant attempted to put the defendant’s penis into AV1’s
anus. AV1 squeezed to try and prevent insertion. The defendant got on top of AV1 and put the
defendant’s penis in AV1’s anus. AV1 was having difficulty breathing.
During the course of AV1’s interview with police, AV1 exhibited signs of trauma whenever AV1
discussed being raped by the defendant. AV1’s eyes would tear up, AV1’s lower lip would shake
vigorously, and AV1’s eyes would roll back. When asked if AV1 knew what the defendant did for a
living, AV1 responded that AV1 believed the defendant was a rapper and may also be a police aide.
Through the course of the investigation into this matter, Kelli Ramsdell, a registered nurse with Saint
Joseph’s Hospital who attended to AV1 during the early morning hours of August 15, 2016, was
interviewed by police. Upon AV1 being brought to Saint Joseph’s Hospital on August 15, 2016, RN
Ramsdell spoke with the defendant. The defendant informed RN Ramsdell that the defendant and AV1
were at the bar and that AV1 began to act weird and unresponsive, prompting the defendant to bring
AV1 to the hospital.
Minutes later, the defendant left the hospital. Soon thereafter, AV1 came to, telling RN Ramsdell that
AV1 recalled going to the bar with the defendant. AV1 could not recall much thereafter, until AV1 woke

 up with the defendant’s penis in AV1’s mouth. AV1 was very agitated, yelling “don’t touch me, don’t
touch me” and “the guy who brought me to the hospital raped me.”
On August 17, 2016, City of Milwaukee Police obtained a copy of the surveillance video from Saint
Joseph’s Hospital captured during the early morning hours of August 15, 2016. The video shows the
defendant arrive in the defendant’s personal car at 4:16 AM. The defendant exits his car and walks into
the hospital. One minute later, the defendant returns to his car along with security officer Matthew
O’Brien, who is pushing a wheel chair. The defendant and O’Brien lift AV1 out of the passenger seat
and place AV1 into the wheelchair. O’Brien pushes the wheelchair holding AV1 into the hospital,
followed by the defendant. At 4:32 AM the defendant exits the hospital and gets back into his car,
where the defendant remains until 4:39 AM, when the defendant drives away.
City of Milwaukee police also secured a copy of surveillance video from the bar captured during the
evening of August 14, 2016. The video shows the defendant and AV1 arriving to the bar at 11:38 PM
and leaving at 1:18 AM. While at the bar, the defendant and AV1 drink large alcoholic drinks and
multiple rounds of shots.
On August 22, 2016, City of Milwaukee Police made contact with the defendant. During contact with the
defendant, the defendant confirmed having AV1’s shirt, belt, and cell phone in the defendant’s car.
Police located and recovered AV1’s shirt, belt, and phone inside the defendant’s car. The defendant
also turned the defendant’s cell phone over to police. The defendant consented to have the defendant’s
residence, 5313 N. 65th Street, in the City of Milwaukee, County of Milwaukee, searched by police.
City of Milwaukee police responded to the defendant’s residence and found most of the defendant’s
belongings had been moved out of the residence.
At 9:21 AM on August 15, 2016, City of Milwaukee Police Sergeant Joseph Hall, a mentor of the
defendant, received a text message from the defendant stating:
“Not so good got a separate situation Need your help big time… Fucked
up big time… But need to handle this the most secret and right way
possible.” (emphasis added).
Sergeant Hall agreed to meet the defendant. During the meeting, the defendant admitted going out with
AV1, drinking with AV1, and then taking AV1 back to the defendant’s house where the defendant had
sex with AV1. The defendant claimed the sex was consensual, but admitted that AV1 was drunk and
had “medical issues.” Sergeant Hall believed, based on information from the defendant that AV1 drank
more alcohol at the defendant’s residence. The defendant admitted that AV1 was messed up and
acting funny while at the defendant’s residence.
Through the course of the investigation into this matter, Amy Sasman, a toxicologist with the Wisconsin
State Crime Laboratory, was provided with AV1’s weight, the total number, and type of drinks ingested
by AV1 during the evening of August 14, 2016, into the early morning hours of August 15, 2016. Based
upon the information provided, Amy Sasman indicated that AV1’s blood/alcohol concentration level
would have reached between a .19 and a .23 sometime after AV1 left the bar with the defendant.
THE SEARCH OF THE DEFENDANT’S PHONE
Based on the above investigation, a search warrant was executed on the defendant’s cell phone. A
search of the defendant’s cell phone demonstrated that the defendant attempted to pay money in
exchange for sex with a person hereinafter identified as adult victim 2 (AV2). The defendant’s phone
also contained a video of the defendant engaged in penis to anus sexual intercourse with a person
hereinafter identified as adult victim 3 (AV3). The defendant’s cell phone also contained multiple distinct

 images of the defendant and adult victim 4 (hereinafter AV4) wherein AV4 is naked and the defendant
appears to be naked. In some of the photos, the defendant’s penis is close to, if not touching AV4.
Additional images were located on the defendant’s phone and further investigation is being conducted
to identify the person(s) within those images.
AS TO ADULT VICTIM TWO

City of Milwaukee police officials were able to identify and interview AV2. Based upon that interview
and a review of the text messages on the defendant’s phone, your complaining witness believes that:
During December of 2015 the defendant began exchanging text messages with AV2. On December 17,
2015, AV2 sent the defendant a text message telling the defendant “ Bro im ready for dat move.” AV2
asked the defendant if the defendant was willing to pay $200. The defendant responded that the
defendant was on the clock, but requested “a pic or sum I’m horny.” During the exchange the defendant
warned AV2, “ok yea cause I fuck aggressive.”
At 5:28 PM on December 18, 2015, the defendant sent a text message to AV2 stating, “what’s good.”
AV2 responded, “tryna bust move” and offered, “Ill top you for 50” to the defendant. The defendant
responded, “naw don’t need that I can catch that anywhere.”
At 3:02 AM on December 19, 2015, the defendant sent a text to AV2 stating, “I need to fuck sum.” AV2
responded, “how much you got.” The defendant told AV2, “I’m tipsy but I got at least 70 I’m teyna dick
sum down.” The defendant further stated, “well more not issue just u ain’t never attempted to take dick
so until I know u can take dick it won’t go up.”
During the text message exchange on December 19, 2015, the defendant expressed frustration with
AV2 never replying. AV2 responded that AV2 was free later in the evening. The defendant instructed
AV2, “Ok send me sum in the meantime.” When AV2 asked the defendant what the defendant wanted,
the defendant requested “ass shot dick pics sum good finger in it idk think of sum.”
At 3:27 AM on December 21, 2015, the defendant sent a text to AV2 stating, “need sum ass.” The
defendant sent a second message two minutes later stating, “50 for first time if it go smooth it can go up
from here on out.” By 4:28 AM the defendant told AV2, “when you outside let me know.” At 4:31 AM,
AV2 responded, “outside.” The defendant responded, “side door.”
During AV2’s interview with police, AV2 reported knowing the defendant. AV2 called the defendant
“Domo” and believed the defendant was a rapper prior to becoming a City of Milwaukee police officer.
AV2 confirmed that the defendant was attempting to persuade AV2 to engage in sexual activity with the
defendant over text messages. AV2 explained the message “Ill top you for 50” meant AV2 would
perform oral sex on the defendant for $50. On December 19, 2015, the defendant offered AV2 $70 to
have sex with AV2. AV2 wanted more money from the defendant and declined the defendant’s offer.
On December 21, 2015, AV2 confirmed going to the defendant’s residence, the above address, in
response to the defendant’s offer of $50 for the first time. AV2 was unsure if the $50 was for oral sex or
sex. While at the defendant’s residence, AV2 drank alcohol with the defendant and the two discussed
the defendant exchanging money for sex with AV2. Despite discussing money for sex, AV2 never had
sex with the defendant.

 AV2 confirmed that the defendant offered AV2 money in exchange for sex on many occasions. The
defendant even provided AV2 with $20 for AV2 to pay a phone bill, believing AV2 would have sex with
the defendant in return.
In total, AV2 believed the defendant propositioned AV2 to have sex in exchange for money on 8 to 9
separate occasions.
AS TO ADULT VICTIM THREE

City of Milwaukee law enforcement were able to identify and interview AV3 through AV3’s cell phone
number on the defendant’s phone. AV3 knew the defendant.

Around July 2, 2016, AV3 attended a party. The defendant was present at the party as the DJ. During
the party, the defendant and AV3 were both drinking. The defendant became “touchy” with AV3. When
AV3 rebuked the defendant, the defendant told AV3 that AV3 need not be shy, the defendant would
pay money. The defendant gave AV3 $50 and told AV3 to think about it.
After midnight on July 5, 2016, AV3 went out drinking with the defendant. AV3 recalled drinking a lot
and not feeling normal. AV3 originally reported that AV3 and the defendant stayed out until
approximately 3:00 AM, when the defendant took AV3 home.
On August 2, 2016, the defendant sent AV3 a text, “if you got some pics send sum tryna get off real
quick will delete em when I’m done nbs”. AV3 told the defendant AV3 could come over. During the text
exchange AV3 offered to come over to the defendant’s residence and “whack” the defendant off. The
defendant’s response messages made clear the defendant wanted more.
AV3 went to the defendant’s residence. Once inside the defendant’s residence, the above address,
AV3 observed the defendant masturbating. The defendant gave AV3 $75 and masturbated AV3. AV3
believed the defendant knew that AV3 needed money.
In total, the defendant offered AV3 money in exchange for sex on three to four occasions via text
message and AV3 believed that AV3 made a couple hundred dollars from the defendant.

AS TO ADULT VICTIM FOUR

City of Milwaukee law enforcement were able to identify and interview AV4 through AV4’s cell phone
number on the defendant’s phone. AV4 confirmed knowing the defendant.
On July 30, 2016, AV4 went out to a strip club with a group of friend, including the defendant to
celebrate a friend’s birthday. AV4 drank a fifth of Hennessy and was intoxicated. AV4 recalled waking
up the next morning at the defendant’s residence. AV4 was so intoxicated the previous evening that
AV4 could not recall how AV4 got to the defendant’s residence, the above address.
Upon waking up, AV4 was only wearing boxers. AV4 was “pissed off” as the defendant was in bed next
to AV4. The defendant was also only wearing underwear.
After leaving the defendant’s residence, AV4 sent the defendant a text message, “WTF happened last
night?” The defendant responded, “nothing kid… room on yourself.. I left thoe and came back but tried

 to get u in your crimb and keys didn’t work so I think u was at wrong house.” The defendant told AV4
that AV4 was throwing up and the defendant had to remove AV4’s clothes.
AV4 was shown a picture of a naked person which was found on the defendant’s cell phone. A portion
of the photo showing a part of the defendant’s penis, close to if not touching AV4, was covered up. AV4
identified the naked person as AV4. Upon seeing the full picture, AV4 did not know who the other
person was. AV4 was shown a second photo, again depicting AV4’s buttocks, this time with the
defendant’s buttocks on top of AV4. AV4 responded, “that’s fucking crazy.” AV4 did not consent to any
sexual contact with the defendant on July 30, 2016, nor did AV4 consent to the defendant taking any
photographs of AV4 naked buttocks on July 30, 2016.

This complaint does not exhaust all the State’s information regarding this case or the videos/pictures
found on the defendant’s phone. The State make seek leave of the Court to add additional charges at a
later date.

****End of Complaint****
Subscribed and sworn to before me and approved for filing this

Erin M. Karshen
Assistant District Attorney
1036930

day of October, 2016.

Complaining Witness Signature