STATE OF MINNESOTA COUNTY OF RAMSEY Page: 1 of 8 DISTRICT COURT SECOND JUDICIAL DISTRICT COURT FILE NO.: PROSECUTOR FILE NO.: 2129908 State of Minnesota, Plaintiff, v. Paula Anne Zumberge (DOB: 01/15/1964) 2510 Knollwood Dr. New Brighton, MN 55112, FELONY CRIMINAL COMPLAINT Summons Warrant Order of Detention Amended Certified Juvenile EJJ Defendant. 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): COUNT 1 On or about the 5th day of May, 2014, in Ramsey County, Minnesota, the defendant, PAULA ANNE ZUMBERGE, aiding and abetting and being aided and abetted by another, did unlawfully cause the death of T.G.S., with intent to effect the death of T.G.S. and/or another, and an accomplice possessed or used a firearm. Said acts constituting the offense of Murder in the Second Degree in violation of MN Statute: 609.19.1(1); 609.05.1; 609.11.5 Maximum Sentence: 40 years COUNT 2 On or about the 5th day of May, 2014, in Ramsey County, Minnesota, the defendant, PAULA ANNE ZUMBERGE, aiding and abetting and being aided and abetted by another, did unlawfully attempt to cause the death of J.D.-C., with intent to effect the death of J.D.-C., and or another, and an accomplice possessed or used a firearm. Said acts constituting the offense of Attempted Murder in the Second Degree in violation of MN Statute: 609.19.1(1); 609.17.1; 609.05.1 Maximum Sentence: 20 years
STATEMENT OF PROBABLE CAUSE Page: 2 of 8 The Complainant states that the following facts establish probable cause: On May 5, 2014, at 2032 hours, New Brighton Police responded to a call about two gunshot victims at 2521 Knollwood Drive in New Brighton, Ramsey County, Minnesota. Officers were familiar with this address and knew that the residents had an ongoing dispute with the neighbors directly across Knollwood Drive. Officers arrived and saw the male resident, T.G.S., DOB: 07/31/1967, down on the front steps. He had several bullet wounds in the area of his upper body. He was without signs of life. Medics later pronounced that he was dead at the scene. Police located the female resident, J.D.-C., DOB: 12/13/1955. She was inside the home and bleeding from 2 bullet wounds to her abdomen. She exclaimed, "He shot us, I knew he was going to do this!" She identified the shooter as their neighbor, Neal Curtis Zumberge, DOB: 01/20/1957, 2510 Knollwood Drive, New Brighton, Minnesota. Officers called Neal Zumberge out of his residence and took him into custody. After treatment at Hennepin County Medical Center, J.D.-C. told police that she saw her neighbor's son at the Acapulco Restaurant in New Brighton earlier that evening. He was wanted by the Spring Lake Park Police because he had threatened J.D.-C. and T.G.S. on April 29 at a VFW in that city. He accused them of causing his father to contract Lyme disease because they feed the deer in their yard. He threatened to burn down their house. J.D.-C. called police, who arrested the defendant's son at 1756 hours on May 5. J.D.-C. then drove home. As she walked up to her house, the defendant, PAULA ANNE ZUMBERGE, DOB: 01/15/1964, confronted her and said, "You fucking bitch, you put my son in jail." T.G.S. heard the confrontation and came outside. Suddenly, Neal Zumberge appeared with a shotgun from around the corner of the house and started shooting several rounds at them. T.G.S. fell to the ground. J.D.-C. was hit in the stomach but she managed to enter the house where she called police. She hid around the corner as the shots were coming into the house. She heard Paula Zumberge yelling, "Shoot, shoot, shoot, keep shooting," while Neal Zumberge was shooting the shotgun. Police did observe apparent gunshot damage to the front door. Paula Zumberge was not on scene when police arrived. A neighbor stated that she heard the argument and the gunshots, and then she saw a woman drive off in a white vehicle. In a post-miranda interview, Neal Zumberge told special agents from the Minnesota Bureau of Criminal Apprehension that he had a tumultuous relationship with T.G.S. dating back 15 years. He acknowledged that he left his basement through an egress window and he shot T.G.S. with a 12-gauge shotgun, loaded with buckshot. He claimed that he did not intend to shoot J.D.-C. He said that he left the shotgun in the basement of his home.
Page: 3 of 8 Agents entered the Zumberge home and recovered a Browning 12-gauge, semi-automatic shotgun in the basement. It was consistent with the shotgun described by Neal Zumberge. When recovered, it did not contain any ammunition. Officers did recover 4 spent, 12-gauge, shotgun shells at the scene. In a provisional report, dated May 07, 2014, The Office of the Ramsey County Medical Examiner noted that T.G.S. suffered cerebral lacerations and contusions and shotgun wounds to the head, chest, abdomen and extremities. The report notes that the cause of death is exsanguination and cerebral lacerations due to shotgun wounds to the body. The manner of death is deemed a homicide.
Page: 4 of 8 Complainant requests that 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: Steven R. Pfaffe COMPLAINANT S SIGNATURE: Subscribed and sworn to before the undersigned this day of, 20. NAME/TITLE: SIGNATURE: Being authorized to prosecute the offenses charged, I approve this complaint. Date: 05/08/2014 PROSECUTING ATTORNEY S SIGNATURE: Name: Steven R. Pfaffe Assistant Ramsey County Attorney 345 Wabasha Street North, Suite 120 St. Paul, MN 55102 651-266-3222/mc Attorney Registration #169274
Page: 5 of 8 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 Defendant s detention, if already in custody, pending further proceedings. Defendant is therefore charged with the above-stated offense. SUMMONS THEREFORE YOU, THE ABOVE-NAMED DEFENDANT, ARE HEREBY SUMMONED to appear on the day of, 20 at 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. WARRANT Execute in MN Only Execute Nationwide Execute in Border States 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 be apprehended and arrested without delay and brought promptly before the abovenamed 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 as such Judge or Judicial Officer is available to be dealt with according to law. ORDER OF DETENTION Since the above-named Defendant is already in custody, I hereby order, subject to bail or conditions of release, that the above-named Defendant continue to be detained pending further proceedings. Bail: $1,500,000.00 Conditions of Release: No contact with J.D.-C. and stay away from 2521 Knollwood Drive, New Brighotn, MN, or wherever she resides. This complaint, duly subscribed and sworn to, is issued by the undersigned Judicial Officer this day of, 20. JUDICIAL OFFICER: NAME: TITLE: SIGNATURE: Sworn testimony has been given before the Judicial Officer by the following witnesses: Clerk s Signature or File Stamp: COUNTY OF RAMSEY STATE OF MINNESOTA STATE OF MINNESOTA vs. PAULA ANNE ZUMBERGE Plaintiff, Defendant. RETURN OF SERVICE I hereby Certify and Return that I have served a copy of this COMPLAINT upon the Defendant herein named. Signature of Authorized Service Agent:
FINDINGS OF FACT Page: 6 of 8 Probable cause found that defendant committed the offenses charged. Ordered defendant's motion to dismiss denied. Plea of not guilty to all counts entered. Trial and hearing on all issues set. Dated: JUDGE OF DISTRICT COURT
DEFENDANT DATA / CHARGE SHEET ATTACHMENT A Page: 7 of 8 DEFENDANT NAME: PAULA ANNE ZUMBERGE DOB: 01/15/1964 Defendant alias name(s): Alias DOB(s): 01/20/1957 Defendant last known address: 2510 Knollwood Dr. New Brighton, MN 55112 State ID: Fingerprint ID: FBI ID: St. Paul PD ID: Offender ID: OTHER DEFENDANT / CASE IDENTIFIERS: Fingerprinted? No Yes Handgun permit? No Yes (Issuing Agency: ) Location of violation: IF DRIVING OFFENSE: Driver's License Number: Issuing State: License Plate Number: Issuing State: Accident Type: No injury/no damage check all that apply Personal Injury Blood Alcohol Concentration (BAC): Property Damage Fatality
Page: 8 of 8 FELONY COMPLAINT AMENDED CT OFFENSE NO DATE STATUTE TYPE STATUTE NBR STATUTE DESCRIPTION OFFENSE LEVEL MOC G O C AGENCY ORI CN NBR FUNCTION 1 05/05/2014 Charge 609.19.1(1) Murder - 2nd Degree - With Intent-Not Premeditated Definition 609.05.1 Liability for Crimes of Another-Intentional Penalty 609.11.5 Minimum Sentences of Imprisonment-Firearm 2 05/05/2014 Charge 609.19.1(1) Murder - 2nd Degree - With Intent-Not Premeditated Definition 609.17.1 Anticipatory Crimes- Attempts Definition 609.05.1 Liability for Crimes of Another-Intentional F H2012 X New Brighton Police Dept ORI - MN0620600 CN - 14005198 Charging F H2012 A New Brighton Police Dept ORI - MN0620600 CN - 14005198 Charging