State of Minnesota County of Washington Complaint District Court AMENDED COMPLAINT TAB CHARGE PREVIOUSLY FILED DATE FILED PROSECUTOR FILE NO. CR-2008-1522 Court File No. STATE OF MINNESOTA, PLAINTIFF, Order of Detention VS. NAME: First, Middle, Last Roger Lee Trice 1915 Margaret St St Paul, MN 55119 Date of Birth 05/26/1978 DEFENDANT Ct Statute Type Offense Date Statute Number & Description 1 Chrg/Penalty 609.582.1(b); 609.05, 609.11 Aiding and Abetting Burglary-1st Deg-Poss Dangerous Weapon/Explosive 2 Chrg/Penalty 609.582.1(c); 609.05, 609.11 Aiding and Abetting Burglary-1st Deg- Assault Person In Build/On Property 3 Chrg/Penalty 609.582.1(c); 609.05, 609.11 Aiding and Abetting Burglary-1st Deg- Assault Person In Build/On Property 4 Chrg/Penalty 609.222.1; 609.05, 609.11 Aiding and Abetting Assault-2nd Degree- Dangerous Weapon 5 Chrg/Penalty 609.222.1; 609.05, 609.11 Aiding and Abetting Assault-2nd Degree- Dangerous Weapon Offense Level MOC GOC Controlling Agencies Control Numbers F B1111 N MN0820000 108037491 F B111 N MN0820000 108037491 F B121 N MN0820000 108037491 F A1222 N MN0820000 108037491 F A1222 N MN0820000 108037491 Complaint The Complainant being duly sworn states that the following facts establish PROBABLE CAUSE: Your complainant is a licensed peace officer in the state of Minnesota, employed by the Washington County Sheriff's Office. Based on the reports relative to an incident that occurred on 11/19/08 involving Richard Paul Delrio, dob: 4/18/1963 and Richard David Koepke, dob: 5/9/1986 and Roger Lee Trice, dob: 5/26/78, complainant makes the following statement to establish probable cause:
Roger Lee Trice Complaint Supplement Page 2 On 11/19/2008 at approximately 9:22 a.m. Deputy Lake responded to 220 Lake Elmo Avenue North, Lake Elmo, Washington County, Minnesota, on a call regarding a home invasion. The caller reported that a green Ford Taurus had left the residence. Deputy Lake was informed the victims were claiming gasoline had been poured on them and one person had been shot. Upon arriving at the resident, Deputy Lake made contact with and identified Richard Allan Jacobson, dob: 11/11/1966, Dexter Alan Peltier, dob: 11/8/1989, M. A. C., dob: 2/4/1992 and Rachel Marie Olson, dob: 7/14/1968. Deputy Lake noted a strong odor of gasoline coming from Ms. Olson and Mr. Jacobson and Mr. Jacobson was bleeding from the back of his head. Deputy Lake had Mr. Jacobson sit in the back of his squad car until the ambulance arrived. Deputy Lake then waited for back up officers to arrive. Dispatch contacted the Woodbury and Cottage Grove police department and requested they check for a green Ford Taurus, without a rear license plate, driving in the vicinity. A Woodbury Police officer spotted the suspect vehicle on westbound 94 and 120 and requested back up to assist in stopping the vehicle. Multiple officers responded and the vehicle was stopped in the parking lot of the LivINN Suites at 283 Century Avenue North. There were three males in the vehicle and all were identified, taken into custody and transported to the Washington County jail. The men were identified as RICHARD PAUL DELRIO, DOB: 4/18/63 (hereinafter referred to as Defendant Delrio), RICHARD DAVID KOEPKE, DOB: 5/9/86 (hereinafter referred to as Defendant Koepke) and ROGER LEE TRICE, DOB: 5/26/78 (hereinafter referred to as Defendant Trice). A motor vehicle check of the license plate and VIN showed the vehicle was registered to Defendant Koepke. Deputy Lindholm, who transported Defendant Trice to the Washington County jail noted a strong odor of gasoline coming from Defendant Trice. Officers observed a camouflage purse on the floor of the front passenger side and a black jacket on the rear passenger side seat. Officer also found a handgun under the front passenger seat. During his ride to the hospital and after being released from the hospital, Mr. Jacobson spoke with Detective Reiter. Mr. Jacobson reported he was sleeping in his bedroom at his residence when he heard a noise in the hallway. Mr. Jacobson opened his bedroom door and observed two masked men in the hallway. The men were wearing black clothing, wearing masks and carrying handguns. Mr. Jacobson said he fought with both men at which point he was sprayed with a liquid he believed was gasoline and shot by one of the men in the head. Mr. Jacobson reported one of the men had what looked like a 20 ounce soda bottle containing liquid which he sprayed at Mr. Jacobson and Mr. Jacobson's girlfriend, Ms. Olson. Mr. Jacobson stated the men yelled " Where's the dope?" At that point one of the men attempted to enter the room across the hall from Mr. Jacobson's room. The man was unable to open the door. The room was Mr. Jacobson's daughter's room and Mr. Jacobson learned his daughter had been leaning against the door preventing anyone from opening the door. Mr. Jacobson reported during the fight he was pistol whipped and shot. He stated he heard a shot, felt pain in his head ad realized blood was running down his back. The doctor at the hospital indicated Mr. Jacobson suffered a scalp laceration. Detective Halvorson spoke with Ms. Olson, who is Mr. Jacobson's girlfriend. Ms. Olson reported she and Mr. Jacobson live at the 220 Lake Elmo Ave. residence. It is a duplex and they reside in the upper level. Mr. Jacobson's daughter, M.A.C. and her boyfriend, Dexter Peltier also reside at the residence. Ms. Olson stated she woke up at 7:30 a.m. on 11/19/08 to notify M.A.C.'s school that M.A.C. was sick that day. Ms. Olson then went back to the bedroom that she shares was Mr. Jacobson and fell back asleep. Ms. Olson woke up to commotion and noise coming from the hallway. She observed two men dressed in black wearing black face masks. One man was taller than the other man and she believed the taller man was white because she could see white skin around the taller man's eyes. The shorter man had what appeared to be a 20 ounce pop bottle and he poured gasoline on Ms. Olson and Mr. Jacobson. Ms. Olson stated the taller male dragged Mr. Jacobson out into the hallway and yelled "Gimme the money." Ms. Olson reported she broke the screen out of the south window in an effort to escape. Before attempting to leave the house she looked back into the hallway and she saw the taller of the two men holding a gun to Mr. Jacobson's head. Ms. Olson
Roger Lee Trice Complaint Supplement Page 3 then heard a vehicle departing the residence and she looked out the window and saw a green, 4-door, Ford Taurus tearing out of the driveway. Ms. Olson said the vehicle did not have a rear license plate. Ms. Olson's shirt was placed into evidence. When questioned regarding a camouflage purse, Ms. Olson said she had a camouflage purse and she had left it on the kitchen table. Detective Harris interview M.A.C. and Dexter Peltier. M.A.C. reported she and her boyfriend were asleep with the bedroom door shut when she heard yelling in the hallway. She heard loud banging and heard two men yelling. M.A.C. opened her door and saw two men dressed all in black wearing ski masks fighting with her father. M.A.C. shut the door. She heard someone yell "Give me the money." M.A.C. stated at one point her bedroom door was kicked and she pushed on the door to keep it shut. M.A.C. then called 9-1-1 on her cell phone. M.A.C. also reported she smelled what she believed to be gasoline. M.A.C. stated once the men had left she discovered her father was shot and gasoline was poured on him. Mr. Peltier stated he was in the bedroom he shares with M.A.C. when he heard yelling from the hallway and someone said "Give me the money." Mr. Peltier said someone kicked their bedroom door open and he was able to see two men in the hallway wearing black clothing, black masks and gloves. Mr. Peltier told Detective Harris Mr. Jacobson and Ms. Olson drive a red truck and a turquoise truck and that both vehicles were in the driveway. Officers conducted Miranda interviews with Defendant Delrio, Defendant Koepke and Defendant Trice. Defendants Delrio and Koepke exercised their Miranda rights and did not speak with officers. Defendant Trice agreed to speak with Detectives Gruber and Benson. Defendant Trice stated Defendant Delrio and Koepke picked up him and the three men were going job hunting and denied knowledge of any gun, shooting or break in. Upon further questioning and being told of the discovery of the gun Defendant Trice stated he didn't shoot anyone, although he had purchased the gun from a person named Tony in St. Paul approximately two day earlier. Defendant Trice stated that Defendant Delrio and Koepke drove to a house where one of Defendant Delrio's "guys" resided. Defendant Trice said he remembered passing a sign that said Cimarron by an Oasis and then they turned up a long driveway and pulled up to a "big ass house" with a garage and a burgundy or red pickup truck in the driveway. Defendant Koepke was driving. Once they had pulled up into the driveway Defendant Delrio and Defendant Koepke got out of the car and went into the house. The two men were wearing gloves. Defendant Trice said Defendant Delrio and Defendant Koepke were in the house for about five minutes and when they came out of the house they were in a rush. Defendant Delrio got behind the wheel and started driving. Defendant Delrio brought a purse back with him that he took from the house. Once they got on 94 they noticed a squad car pull in behind them. They pulled into the LivINN Suites and were taken into custody. Defendant Trice further stated that he had given the gun to Defendant Koepke about two days ago. The foregoing facts constitute your Complainant's basis for believing that on or about 11/19/2008 in Washington County, State of Minnesota, the defendant, Roger Lee Trice, (DOB: 05/26/1978), did wrongfully, unlawfully, Count 1 Charge: Aiding and Abetting Burglary-1st Deg-Poss Dangerous Weapon/Explosive In Violation of: 609.582.1(b); 609.05, 609.11 aiding and abetting and being aided and abetted by another enter a building located at (1), without consent and with intent to commit a crime or commits a crime while in said building either directly or as an accomplice and possessed a dangerous weapon when entering or at any time while in the building
Roger Lee Trice Complaint Supplement Page 4 Count 2 Charge: Aiding and Abetting Burglary-1st Deg-Assault Person In Build/On Property In Violation of: 609.582.1(c); 609.05, 609.11 aiding and abetting and being aided and abetted by another enter a building located at 220 Lake Elmo Avenue, without consent and with intent to commit a crime or commits a crime while in said building, either directly or as an accomplice and assaulted another, to wit: Richard Jacobson within the building or on the building's appurtenant property Count 3 Charge: Aiding and Abetting Burglary-1st Deg-Assault Person In Build/On Property In Violation of: 609.582.1(c); 609.05, 609.11 aiding and abetting and being aided and abetted by another enter a building located at 220 Lake Elmo Avenue North, without consent and with intent to commit a crime or commits a crime while in said building, either directly or as an accomplice and assaulted another, to wit: Rachel Olson within the building or on the building's appurtenant property Count 4 Charge: Aiding and Abetting Assault-2nd Degree-Dangerous Weapon In Violation of: 609.222.1; 609.05, 609.11 Penalty: 7 years and $14,000 aiding and abetting and being aided and abetted by another assault another, to-wit: Richard Jacobson, with a dangerous weapon Count 5 Charge: Aiding and Abetting Assault-2nd Degree-Dangerous Weapon In Violation of: 609.222.1; 609.05, 609.11 Penalty: 7 years and $14,000 aiding and abetting and being aided and abetted by another assault another, to-wit: Rachel Olson, with a dangerous weapon THEREFORE, Complainant requests that said Defendant, subject to bail or conditioned 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: COMPLAINANT'S SIGNATURE Washington County Sheriff s Office Being duly authorized to prosecute the offense(s) charged, I hereby approve this Complaint DATE: PROSECUTING ATTORNEY'S SIGNATURE 11/21/2008 PROSECUTING ATTORNEY: NAME/TITLE Wendy A. Murphy Assistant Washington County Attorney Attorney Registration #: 74378 ADDRESS/TELEPHONE PROSECUTING ATTORNEY'S SIGNATURE Washington County Government Center, 14949 62nd Street North Stillwater, MN 55082 (651)430-6115
Roger Lee Trice Complaint Supplement Page 5 Court Case #: This COMPLAINT was subscribed and sworn to before the undersigned this day of NAME: Signature: Title: 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. The Defendant(s) is/are thereof charged with the above stated offense(s) SUMMONS THEREFORE, You, THE ABOVE-NAMED DEFENDANT(S), ARE HEREBY SUMMONED to appear on the day of, at AM/PM 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 MINNESOTA 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(s) be apprehended and arrested without delay and brought promptly before the above-named 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 thereafter as such Judge or Judicial Officer is available) to be dealt with according to law. ORDER OF DETENTION Since the above-named Defendant(s) is/are already in custody; I hereby order; subject to bail or conditions of release, that the above-named Defendant(s) continue to be detained pending further proceedings. Bail: Conditions of Release: This Complaint is duly subscribed and sworn to, is issued by the undersigned Judicial Officer this day of NAME: Signature: TITLE: Judge of District Court Sworn testimony has been given before the Judicial Officer by the following witnesses: STATE OF MINNESOTA, COUNTY OF WASHINGTON Clerk's Signature or File Stamp: STATE OF MINNESOTA Plaintiff vs Roger Lee Trice Defendant(s) RETURN OF SERVICE I hereby Certify and Return that I have served a copy of this COMPLAINT upon the Defendant(s) herein-named. Signature of Authorized Agent: