OF WISCONSIN, 77 CIRCUIT co RT JEFFERSON COUNTY STATE OF WISCONSIN Plaintiff, CRIMINAL COMPLAINT VS CHARISSE ELIZABETH DANIELS Clrcult Courl Case No 1510 Ulah SIreeI Walenawn, WI 53094 I LED -- Sex/Race Black/Female. DEC14 1m Defendant. Jam-man County THE COMPLAINING WITNESS. SERGEANT LEON RUDER, BEING FIRST DULY SWORN STATES THAT: FALSIFICATION OF INFORMATION REGARDING A NOMINATION PAPER On and between May 2018 and June 2018, In Ihe City of Waleflown, Jefferson County, Wlsconsln, Ihe defendant, Chansse Damels, lnformallan nomlnatlon papers Io WII dId cemfy IhaI the persons Ilsled on Ihe papers had personally slgned and ma she had personaIIy oblamed all of We slgnaIureS on ten pages 0' nomlnallon papers for herself, Charlsse DanIeIs' (or Representahve Is the Assembly 7 37th when In fad She had MOI cinema! 3" the slgnalures and mi all Ihe persons had Slgned the (arms In vloIalIon DIWKS Stat 12 13(3)(a) and I2 Upon ui oflense' a class I Ielony' Ihe delerldanl may be flned not more than 510 000 or Ior not more Ihan 3 years and monms or both FACTUAL BASIS The abovernamed complamlng IS a (My CV Walenown Police DetecIIve Sergeant and bases compIalnI upon Informallon and beIIeHhaI I am currenlly employed as a delecllve sergeanl wuh Ihe Watenown POIlce Department As pan of my the Walenown Ponce Depanmenl I supervlse Ihe work of other delecuves In the depanmenl Delectlve Wackcl of (he Walerlown PoIIce deparlmem was assgned Invesllgate aIIegatlonS OI lreud (0 nomlnatlon papers of CharISse Represenlanve In the 37th Assembly District. As part of that investigation, I reviewed reports prepared by Detective Wacker and documents obtained from the State of Wisconsin Elections Commission. I believe the documents received from the State of Wisconsin Elections Commission are accurate and reliable because they are maintarned by the agency pursuant to law in the ordinary course of their operations. I believe the reporls prepared by Detective Wacker are accurate and reliable because they were prepared in the course of his official duties. Part of the investigative materials included a verified sworn complaint with the Wisconsin Elections Commission submitted by Jenny Toftness on June 4, 2018, and an amendment to that complaint dated June 6, 2018. I believe this complaint and amendment and the attached documents are accurate and reliable because she is a citizen witness who had personal knowledge of the information provided. I also believe the affidavits submitted with that complaint are accurate and reliable as they are sworn to under oath from citizens who have personal knowledge of the information provided. Based upon my review of records I know that the defendant, Charisse Daniels, D.O.B. 7l\l1gB7, completed and filed in Madison, Wisconsin, a notarized Declaration of Candidacy on June 1, 20'18, as candrdate for Representative for the 37th Assembly district for the State of Wisconsin for an election to be held on November 6, 2018. On that Declaration of Candidacy Charisse Daniels listed her current address as 1510 Utah Street, Watertown, Wisconsin. Ms. Daniels also certified that she did orwould meet all requirements to hold office. Pursuant to Wisconsin Statute section 8.15(6Xb), a candidate for a state assembly seat must submit not less than 200 nor more than 400 valid signatures of electors from the specific assembly district On June 1, 2018, the deadline for submitting nomination papers under Wisconsin Statute section 8.15(1), the Wisconsin Elections Commission received 31 pages of nomination signatures for certifrcation from Ms Daniels as a candidate for the 37th Assembly district. These pages listed 21g signatures. After revtew the State of Wisconsin Elections Commlssion determined that 201 of the signatures were valid Rejection of the other signatures was based primarily on signatures being dated after the certificatron signature date of the circulator. _) of the 31 pages submitted by Ms. Daniels, she was listed as the circulator on 10 of those pages which listed 78 signatures On each of those 10 pages Ms. Daniels certified that l, charisse Daniels, certify: lreside at 1510 Utah street, watertown, wl. I further certify that I am either a qualified elector of Wisconsin, or a U.S. citizen, age 1B or older who, if I were a resident of this state, would not be disqualified from voting JnOei Wis' Stat. I personally circulated this nomination paper and personally obtained each of the signatures on this paper. I know that the signers are electors of the jurisdiction or district that the candidate seeks to represent. I know that each person signed the paper with full knowledge of its content on the date indicated opposite his or her name I know their respective residences given. I intend to support this candidate. ! am aware that falsifying this certification is punishable under Wis. Stat. s.12.13(3)(a). (Emphasis added). on June 4,2018, Ms. Toftness submitted to the Wisconsin Elections Commission affidavits from 20 people who stated they did not sign the nomination papers on pages circulated by Ms. Daniels. ln addition, there were three duplicate signatures. As a result of the lack of valid signatures Ms. Daniels name was not placed on the ballot for the November 6, 2018, election. Detective wacker made efforts to contact every person whose name appeared on the nomination papers submitted by Ms. Daniels. Detective wacker obtained affidavits from 24 0f the people named on the nomination papers submitted by Ms. Daniels which stated they did not sign the nomination papers even though the nomination form purported to show their names and signatures. ln addition, he also spoke to an additional '10 people who stated that they did not sign the forms but did not want to pursue charges. Furlhermore, the wrong name was used for people at two separate residences and one signature listed the address of a vacant lot. There were also others who did not respond Lastly, Detective wacker found 25 people who confirmed signing the nomination forms and also frequently heard people state that they would have willingly signed the forms if they had been asked. )- 1 Attached to this complaint as Exhibit 1 as examples of the 10 pages of nomination papers submitted by Ms Daniels, are copies of pages five and eight of the nomination papers which were certified by Ms' Daniels The names of people who are not blacked out are those who specifically told Detective wacker, and in one case in an affidavit submitted to the wisconsin Elections commission, that they had not signed the nominatton papers. 1 B of the 20 people whose names appear on those two pages have affirmativery stated that they did not sign their name to the forms. Subscribed and sworn to before me and r filing on this 14th day of 18 S I Prosecutor for Jefferson County Complaining Witness My commission is permanent. Wisconsin Depafiment of Justice Post Office BoxTBST Madison, Wisconsin 53707 -7 BS7 (608) 266-3067 -4 r c, ) o 'a') a 1l o)o (UC'd; Z :oJq J t_- c) o_ ro,-*or f .: f0 Clr O. ti ^O 0r;o 1l0iO :) i0)Y L ,\ -.* ro) Y:ou o o li e c I (] al :] : rL L' Z z !, c .9 il i I -. Ol*6 o o a .{ .J = cu-u , lu o q 6a* '' o .:: 5! I o r;F- s :5N; .lFm: F 6-, E{ .- ^1 3!P s:-( --.1 E5 !ota u g I ->lL()NJO a o n e L' f- ,.tl (y o U.@I o tlu r) ;:: oi fi-;F: E:UJ! u_l o, _. 0_ Z o ; u < am ?;uu1: DII 5,lmr a< ,inu-t; E= Oltt AJ :TJ .p a>cE s p .( OJ F 3 [f a 3.- Z & c b.r; ,,, s t- icl io); ; P( SJ: b 5E i'io o 1" HHI llc -.-tb 0l E. aot'Y'\ LJ* ftz i; 6 :. .-@llU ftL- P'E o rc p E: l-: 6'; i€ G 5 o F 3l ;tF ![.t o o: -l l.{ Z !r? K-X ilJ _:38 c -ur-! x -n) qse !w gfi; u t uu: o- p;^: pl B? a a b si.? !.0! Z i i! d:s s v I S!, I D,6: ii I j I E C) =1 ts8 x^c! Isrr r/x E;rn J s;<; u o. !9I--. !6 o o 6 iIr i s 9n-il1! Lt) _9 l f -d H# ()Er&+ i ""3 i ,.rEI LLI Ll- -"P - (ar rj R+ 6i i , t !:ar'\ t,=ro Hr<-I tr [;3 t,l t- ! s B.i ), e:>-r !2 t9s_i; i\n q Q7, U] -odq ( Z --pr o;'f.^ !r^ 6 3 Q 9i;nP -* LJ: N-Y N (.1 3EffrY o:L* b;tn; o u\ o vlt: PE \--l o ts\T 3 'il "\.1; t't'"1\) '-' LT L ')S: [':n9 irl] o a o ) @ c.) ! ooJ N.cE =.1r3 :!og COJ z o I q l.0J- 5 or0 >,nc 0);;6 !;,io q o o J i ^.* Hmu ! o) 0* () t of- @ \5 o rQ -/\ .^/1 lli L_r,l Pia riil SI(! t.\ -9;-, sSids g.q r() r6 r]\ o 5 *t-6 z kcl r 2 r\1) ft 6 EE9* i,irr3 !5l,.&G :51:.- rr\ ! ) ) ij. -t ,i ,- r: (.:i 4 (-r a>l! (rGJO 1.Y ,], g (-) iir ) i or9q -) h P t.t ,J ! il.s t.rir fl.p 9(j iep ii+ ! nlr -) e.:.- 11 !.. i\ eHdHFu:; ,9,-v .3*-,"' ft I .*r"- 5 ,i t-lJ r t!? g;,; tl; :!-q .-\ v ZEH'-:;LN.: ' -