TJF/Jail

STATE OF WISCONSIN

CIRCUIT COURT
CRIMINAL COMPLAINT

DANE COUNTY

STATE OF WISCONSIN
Plaintiff,
-vsDOUGLAS MYERS GILL
5 Indian Mil Rd
Winnetka, IL 60093
DOB: 04/01/1995
Sex/Race: M/W
Eye Color: Brown
Hair Color: Brown
Height: 6 ft 0 in
Weight: 180 lbs
Alias: Also Known As Douglas Myers
Mcbride-Gill
Also Known As Douglas Myers Mcbride
Also Known As Douglas Myers Mcbride Gill
Also Known As Douglas Myers Mcbridegill
Defendant,

Ref. Agency: UW - Madison Police
Department
DA Case No.: 2014DA004236
Assigned DA/ADA:
Agency Case No.: UWPD 14-912
Court Case No.: 14CF
A TN :13081405100277

COMPLAINING WITNESS
Julie Dahmen/Andrew Nielsen/Robert Glejf
The above-named complaining witness being first duly sworn states the following:
Count 1: THIRD DEGREE SEXUAL ASSAULT
The above-named defendant on or about Saturday, May 10, 2014, in the City of Madison,
Dane County, Wisconsin, did have sexual intercourse with ALE, without that person's
consent, contrary to sec. 940.225(3), 939.50(3)(g) Wis. Stats., a Class G Felony, and upon
conviction may be fined not more than Twenty Five Thousand Dollars ($25,000), or
imprisoned not more than ten (10) years, or both.
Count 2: FALSE IMPRISONMENT
The above-named defendant on or about Saturday, May 10, 2014, in the City of Madison,
Dane County, Wisconsin, did intentionally restrain Alexa L Everson, without that person's
consent, and with the knowledge that he had no lawful authority to do so, contrary to sec.
940.30, 939.50(3)(h) Wis. Stats., a Class H Felony, and upon conviction may be fined not
more than Ten Thousand Dollars ($10,000), or imprisoned not more than six (6) years, or
both.
FACTS:
Your complainant is a Court Officer with the UW-Police Department and has reviewed the
written police report of UW Police Officer Terry Evans. Officer Evans reports that on May
05/ 13/2014

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 STATE OF WISCONSIN - VS - Douglas Myers Gill

10, 2014 at approximately 3:40 pm, she was dispatched to Witte Hall in reference to a
sexual assault which had occurred the previous Friday. Officer Evans responded to Witte
Hall, Room 217A in the City of Madison, Dane County, Wisconsin, where she met a
subject who identified herself by a Minnesota Driver’s license by a name whose initials are
ALE, date of birth, 5/23/1995. ALE advised that she had been sexually assaulted on
5/2/14 by a subject she knew as Doug Gill, a UW student who lives on the same floor as
her. ALE advised that on 5/2/14 at approximately 10:00 pm, she was on her floor going
back and forth between her room and Gill’s room just down the hall. ALE stated that a
group of friends were in Gill’s room watching the Minnesota hockey game. She stated she
spent some time in Gill’s room watching the game, occasionally going back to her room to
do other things. She advised that she observed Gill was snorting lines of cocaine and
consuming alcohol in his room while they were all watching the game. ALE reports that
she knew Gill did drugs but stated she did not consume any drugs or alcohol that evening.
She stated that at 10:24 pm, Gill sent her a text message stating, “Babe I’ll make you
quiver.” She stated that it was an odd text as she and Gill had not had any sort of physical
relationship in the past. She stated she had met Gill the first semester and they had
become friends during the second semester and had mutual friends on the floor. She
stated she had not dated or had sex with Gill in the past, adding once that they had “made
out” for ten seconds, but that was the extent of their physical relationship. ALE reported
that at approximately 11:00 pm, she was in her room standing in the doorway when Gill
saw her from his room and that Gill ran down the hall to her room, grabbed her and threw
her on her futon. She stated that Gill laid on top of her and began kissing her neck and
feeling her body when a floor mate and friend came into the room. Gill got up, acted
casual and went back into his room. ALE reported that she knows Gill gets touchy feely
and is always excessively flirty, especially when he is on drugs, but that this was
unexpected. She stated a short while later, at approximately 11:30 or so, friends that were
in Gill’s room went out for the night and ALE remained in her room. She stated that Gill
subsequently came into her room and sat behind her on the floor. She stated that Gill was
“full of energy” and “coked up”. ALE advised that she was only wearing sweatpants and a
bathrobe, with no underwear, bra or t-shirt. She stated that Gill put his hands inside her
bathrobe and began to fondle her breasts. She stated she told Gill, “Stop” and “Don’t do
that” and “No” many times. She stated she did not reciprocate in any way and did not
initially feel threatened as Gill is known to get “handsy” when high and she was grossed
out by his actions. She stated she got off the floor and Gill picked her up and put her on
her futon, face down and straddled her thighs. She stated that Gill laid on top of her,
kissed her neck and moved her bathrobe up to her shoulders, exposing her bare back.
ALE stated that Gill continued to kiss and fondle her. She told him, “No”, “Stop”, and
“What about Suzy?” ALE stated that Suzy was someone Gill had told her he was
interested in a few days ago and she tried to use that to remind him of Suzy to get him off
of her.
ALE advised that Gill was saying words to the effect of, “shhhhhhhh” and “I want to make
you feel good”, ‘You know you want if, and “Just let me make you feel good.” ALE stated
she tried to get up but couldn’t. ALE reported that Gill began to pull her sweatpants down
to the top of her thighs and kissing her bare butt. ALE stated she was struggling and kept
trying to pull her pants up.
ALE stated she could not move and Gill began to thrust his hips at which time she believed
his penis to be erect. ALE stated that Gill was, and remained, fully clothed during this.
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 STATE OF WISCONSIN - VS - Douglas Myers GiU

ALE advised that Gill continued kissing her neck and cheek and fondling her and she
repeatedly said, “No”, “Get off”, and said she was not a willing participant in any way.
ALE advised that Gill stated something to the effect of, “Let me give you a massage.” ALE
stated she agreed, but said that he could for two minutes but then had to leave. ALE
stated she was able to get an arm free and pulled up her pants, but remained face down,
back exposed with Gill on top of her. ALE stated that Gill began to rub her back and the
sides of her breasts. She stated that she told Gill approximately 15 seconds into the
massage that he had one minute left in an effort to speed things up in an effort to get him
away from her.
ALE reports that Gill became more aggressive, pulled her pants down and inserted his
finger into her vagina. ALE believed Gill used his right hand, but was unsure if it was just
one finger or more than one finger put inside of her. ALE advised that she immediately
said, “Stop” and “Doug, what are you doing?” ALE stated she was moving around trying to
get him off of her and then stated, “I have my period.” She stated she was not having her
period but only said so to make him stop. She stated that Gill hesitated when she said
this, pulled his finger out, and she was able to get off of the futon. ALE advised that she
stood up in shock and yelled, “What are you doing” to him. ALE stated that Gill then left he
room. ALE advised that she subsequently called friends and told them what had
happened. She further advised that during this time Gill was texting her, admitting what
happened and apologizing. Officer Evans was able to observe the texts, including a text
received at 12:13 on 5/3/14 which states, “Wtf, Idk what came over me. I’m embarrassed.
I’m sorry. Like you prolly won’t even look at me the same way ever again. I’m just gonna
take a lot of drugs n pass out, sorry for literally raping you that was so not cool.”
Your complainant has reviewed the written police reports of UW Police Officer Megan
Donnelly. Officer Donnelly reports that she subsequently contacted ALE and used her
phone to send messages to Gill to get him to meet with her. Officer Donnelly reports that
-. at approximately 9:50 pm on May 10, she arrived at the second floor of Witte Hall A Tower.
Officer Donnelly recognized the male from a student identification photograph she had
looked up earlier. She then asked the male his name and he told her it was Doug Gill.
She asked him if he knew why she was there and he stated, “I have a good idea.” Gill
agreed to go to the police department to talk to the detective. After being transported to
the police department while waiting for the detective to arrive for the interview. Officer
Donnelly observed Gill with a cell phone in his hand. She still had possession of Everson’s
cell phone and saw that he was sending a text that read, “I’m sorry”. Gill was asked not to
be on his cell phone for the remainder of the interview.
**THIS COMPLAINT IS BASED ON the information and belief of your complainant, who is
a Court Officer for the UW Madison Police Department, and who learned of the above
offense from the reports of UW Madison Police Officer(s) Terry Evans and Megan
Donnelly, which report(s) your complainant believes to be truthful and reliable inasmuch as
they were prepared during the course of the officer(s) official duties.

Further, your complainant believes the information furnished by ALE, date of birth
5/23/1995 to be truthful and reliable inasmuch as she is a citizen informant(s) and
witnessed the events described.
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 STATE OF WISCONSIN -VS - Douglas Myers Gill

Subscribed and sworn to before me,
and approved for filing on:
This_____ day of May, 2013.

ASSISTANT/DEP DISTRICT ATTORNEY
DANE COUNTY, WISCONSIN

COMPLAINANT

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