2011 10:43AM
Mar. 26.
_.__ State of Wisconsin BR6 we Reine County
State of Wiseonin, siti,
tersus
Samuel Curtis Johnson IT, DOB: 05/05/1955 CRIMENAT: COMPLAINT.
5726N Green Bay Rd Circuit Court File No: 2011CF00
Racine, WI53402
‘M_ W Blonde Bluc Weight: 175 Ibs Height: 5 #11 in
5525-7835-5165-00
defendant).
DACaseNe: 2011RA0OIBSS
Status: Walkein on March 24, 2011 at :30 0M
Prosecstor: Robert Replscha
Agency. Recas County Shenft —_11-007115
Officers) eater at
ineddennae: Kemi Deas
Count 1: REPEATED SEXUAL ASSAULT OF A CHILD
‘The above-named defendant between June, 2007-2010, in the Village of Caledonia, Racine County,
Wisconsin, did commit repeated sexual assaults involving the same child, TS, DOB 04/21/1995 where at
least three of the assaults were violations of sec. 948.02(1) or (2) Wis. Stats, contrary to see, 948.025(1)(€),
939.50)(o) Wis. Stats., a Class C Felony, and upon conviction may be fined not more than One Hundred
Thousand Dollar: ($100,000), or imprisoned not more then forty (40) years, or both.
The official records and files of the Racine County District Attorney's Office, the Wisconsin Department of Justice and/or
Department of Transportation reflect thatthe defendant has the following record o covietions:
‘The complainant, being fst dly sworn on eat, on information end belie, lleges and states that in the County of Racine,
Sate of Wisconsin, te defendants) did commit the above describ offense(s) and prays that said defendant(s) be deal wit
ccordng tothe lavs ofthe State of Wisconsa,
‘The complainant stats that he or she i an edu cian and has reviewed th offical law enforcement reports prrpated
under the above meatioued complaint numbers hy the above stated ofice(s), whose reports your complainant relies upon 5 trtifil
and accurate inasmuch a hey wert prepared dorig the course of an oficial law enforcement investigation. The complainant relies
pon the statements of the mentioned witnesses insmnch as lie ae ctzans an hat ststements are based on personal knowledge
or eyewitness observations; the complainant relics upon the statements ofthe defendant(s), any, inasmuch as they are contary to
the defendoas penal interests and ae, therefore, ob bellved,
‘The complainant thereby informs the court that the basi for the above charge(s) is as follows:
al of the Racine County Sheriff's Department reports that on March 16, 2021, she
assisted Inv. Dobesh withthe investigation of the sexual assault report. Inv. Madrigal reports thet on March
16,2011, a forensi interview was conducted with T'S. by a member of the Child Advocacy Center. During
the interview, T.S. indicated that ske had been sexually abused by her stepfather, whiom she referred to as
Curt. TS. advised that there was a "louching problem" with him and that Curt has a sex addiction and is
addicted to sex and is very sexval. lav. Madrigel roports thet during the interview, T.S. became very nervous
her voice began cracking and she got emotional and stated that she did not like taking about whet had
happened to her and bogen to cry. When asked by the forensic examainer what happened, T.S. reported, “He
molested me." TS. reported that it happened on more than one occasion. TS, reported that one of the
ingtances occurred in the kitchen oftheir residence on North Green Bay Road in the County of Racine, State
‘anoit2011 10:46AM RACINE CO DA 262-636-3346
STATE OF WISCONSIN - VS - Sa. .el Curtis Johnson I t
of Wisconsin, TS, reports that while in the kitchen, Curt tried touching her there and she ran into her
bedroom. T.S. reports that it scared her and made her feel uncomfortable. TS. further reported that regarding
the instances in her bedroom, she did not want to talk about the rest of it
‘The foreasic examiner asked what "molested! meant to her and T.S. explained that itis when adults
(ouch kids inappropriately. Blank body silhouettes were present to T.S. and T.S. was able to mark the arcas
‘on the body for the "private parts’, which included the breasts, the vaginal aree, andthe buttocks. T:S.
reported that sho was molested by Curt on the parts that she marked, which included the broasts, the vagina,
and the buttocks. T.S. reported that Curt used his ands and his mouth to molest her. TS, reported that he
had touched the front of her body and that he had touched her breasts and her “crotch. T.S. reported that the
incidents usuelly occurred in her bedroom located at the North Green Bay Road residence, located ia the
County of Racine, State 6f Wisconsin. TS. reported that on one occasion, Curt asked her “if they could have
sex" and T.S, told hin n0. On another occasion, T.S. reported that Curt took out his penis and T.S. pulled the
covers over her head. T.S. reported that Curt exposed his penis to her on one occasion, that he took his penis
‘out of his pajama pants and that she immediately went under the covers as she did not want (0 see it. TS.
reported that Curt would use his mouth to touch her mouth by kissing her and that he would use his hands to
touch her vagina, breasts, and buttocks under her clothes. TS. stated that she finally told her mother about
‘what was happening to her because she wanted to protect her younger sisters. T.S. reported that she was
unable at that time to remember the exact age that the sexual Contact occurred.
Inv, Madrigal reports that on March 18, 2011, she had an opportunity to interview Tracie SJ, the
mother of T.S. During the interview, Tracie stated that she first had aa intuition that something was incorrect
when the family was out to dinner in December of 2010. Tracie noticed that Curt was looking at T.S. at the
dinner table ina particular way and that it triggered Trace’s intuition. Tracie reported tht in January of
2011, she confronted Curt regarding her suspicions and Curt denied anything was going on. Tracie reported
that T.S. e-mailed her and disclosed that Cart had "tried to kiss her and touch her under her clothes." Tracie
reported at this time, she was in the Bahamas when she received the e-mail. Tracie reports that she and her
‘younger daughters retuned to Racine and that on January 30, 2011, she attempted to talk to Curtis alone. She
confronted Cur in person in their home and he denied any contact with T.S. Tracie reports that on February
2, 2011, she and Curtis were in Mexico vacationing when she roceived an e-mail from T:S. and indicated to
Tracie that Curt "did more to her.” Tracie reported that T.S. indicated that Curt had been in herbed ia the
moming and wouldn't leave, that he kissed her "boobs" and kissed "sort of down there" and then tried
sticking his fingers in me. TS. reported that she kicked him and then he would really get mad and it seared
the life out of her. T'S. further reported to Tracie that Curt asked her to have sex with him but:she said no and
told him to get out, Tracie reported that she asked TS. how many times that this had occurred and T.S.
replied, “anywhere betweca 15 and 20 times but she realy didnt know.” Tracie reported that TS. told her
that as far as she could remember, i started between the 6" and 7" grade ard that the lat incident occurred
before they went to Florida in Orlando, which would havo been in November of 2010. Trecie reports that she
confronted Curt again about the allegations and that Curt asked Tracie if she was "recording this. Tracie "+
indicated that she did not and Curtis admitted to "fondling T.S.'s breasts".
is atthe abuse stated between the Summer of her 6 and 7* year of school. Tracie indicated that
she is mostly hurtin that T.S, had taken "a vow of purity*to stay celibate until marriage and that Curt knew
this vow because T.S. had voiced the vow and that Tracie indicated that this hurt the most because he hurt
‘TS. in such a way and that this will now be part of T S's history. Tracie reported that since Curtis left
Arizona, he has not had any contact with T.S. but he has had contact Tracie and the other children and during
the conversations, Curtis has told Tracie thet he is sorry and "sorry for hurting (T.S.)" and sorry that he has
done this to their family and that he is “sorry that he has done thet to (T.S.)" Tracie reports that she sent Curt
book entitled, "Invisible Girls: The Truth About Sexual Abuse A book for Tecnage Girls, Young Women,
and Everyone Who Cares About Them" Tracie reports that Curt reported that he read the book and that after
reading the book, he was sorry for doing what he did to T.S. Tracie further reports that in her conversations
ap4n2001 2Mar. 25. 2011 10:49AM RACINE CO DA 262-636-3346 No. 1892 P. 4/8
STATE OF WISCONSIN V8- S...s.l Cuts Fohson I
with TS, T.S, reported thet Curt Lad tried to undress her and thet she would pull her pants back up or her
shirt back down and that at one time, Curt tried to make her grab him but she did not.
Subscribed and swoen to before me and approved for ting on 22 Yay of March, 2011.
\ i
ASUSTANT DI
COMPLAINANT
‘Michael E. Nieskes, \ctorney, State Bar No, 01002564
"730 Wisconsin Ave, ‘WH53403 (262) 636-3172
anon