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i\RREST WARRANT ,l\PPLiCAT10N

JD·CR·64b Rev, 10-04

\--~-'-FORcoQFn USE'ONLY-- , !--SUP-PORTING AFFiDAViTS SEALED'-

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STATE OF CONNECTICUT SUPERIOR COURT !:~l~!:yjud. state. ct us

! AC;ENCY N/l.J\Jl[ 1- /\C~;'f.N'(·~y r,!~~:;-

l CONNECTICUT STATE POLICE CFS-09-00 157651

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... _. __ .. J e~i fer 12 U~!.1J~_C_l!~~:~'.?C)~·i_~?.9:~tt\;Ulf?!~~. 9T~._ ... __ l 2/31 ~.~_96 8 . .1._ ._.__!·i~\Y Haven APPLICATION FOR ARREST WARRANT

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TO: A Judge of the Superior Court

The undersigned hereby applies for a wk toe arrest o.fj:heabove-named accused on the basis of the facts set

forth in the: rxJ AFFIDAVIT IE -'-0 AFFtDAVITiS) ATTAC~~:~,/,~

~~T~A2~~E Ib2~ti{;fL~~!=g~-"-O---'!'<_ .. ;;"'_~= __ &:~-f~o~:2-.·~_"·-~~_- __ -~~_-==-~T ::f~lt'2'SE~:N~A":,O' ,"

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AFFIDAVIT

The ,underSigned Affiant, being duly sworn, deposes and says:

The amant, Detective Christopher Consorte, is a regular sworn member of the Connecticut State Police Department and has been since 1997. The affiant is presently assigned to the Central District Major Crime Squad. The affiant has investigated numerous criminal cases and conducted interviews of suspects and witnesses who have been involved in criminal cases. The affiant has received specialized training in these matters from the Connecticut State Police.

That at all pertinent times mentioned herein, the affiant was acting in his official capacity as a law enforcement officer of the State of Connecticut, That the following facts and circumstances are related from personal knowledge and/or observations and include information related to the affiant by persons with personal knowledge of the facts and circumstances contained herein and / or information learned by the affiant from reading reports and/or writings furnished or made available to the affiant by state' agencies, state employees, private citizens or fellow law enforcement officers.

On Thursday, March 26th, 2009, Troop-I personnel and Central District Major Crime Squad personnel responded to Platt Regional Vocational Technical High School located at 600 Orange Avenue, Milford, CT for a reported sexual assault complaint. That, in order to comply with Section 54-iJ6e of the Connecticut General Statue, the name and address of the sexual assault victim is not ~eing disclosed in this affidavit.

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of a 5 page A ffida vii)

DATE AND I DATE

SIGNATURE I

JURAT

considered oy Ui-C~ u!l(_-je~-·slgrlecL the Ul"tde(S19r"H::d rinds rrom said affidavit.s) thattnere is probable caUSE-: to bei!e\j~~ that an offense has t,,:;en committed and that the accused committed it and, therefore, that probable cause eXit<; tor tiw issuance

of a warrant for the arrest of tile above-named accused. "~j ". /"

m:nt~~_~I=Z~~L:~I~~~ .. ' '~~~:~~=t::t1"l#~~~~~e~~~~-~

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ARRES~;- WARRANT AFFIDAVIT CONTINUATION PAGE

INSTRUCTIONS: STATE OF CONNECTICUT

The jural is to be completed for eect, page or {he afficiavil SU PERIOR COUr~n

l 'u: pJ"osecutoria( off/c.';::! Bjhj judge! judge [(ia! r(J(o(ee are to elate

JD-CR-B4a R.:J~ C'-04

Jennifer Dllnl\_$L<::r.~?!~'Q0982_~g,M5~!2Eg2~~T __ ~ci_:Q_._!?: 12/31/1968j New Haven

AFFIDAVIT

The undersigned Affiant, being duly sworn, deposes and says

That, upon arrival at the school, this Affiant spoke with school Principal Gene Laporta (d.o.b. 0611211951). In a sworn written statement, Laporta noted that he had recently been made aware by his Assistant Principal of a rumor within the school involving a staff member and a senior student. Laporta noted that, after questioning staff and students, it was determined that the individuals involved were Jennifer Dunn, a non-certified educational assistant (part-time), and the victim, a male senior student.

Laporta noted that he spoke to the victim regarding the hearsay and he (the victim) denied having spent any time outside of school with Mrs. Dunn. Laporta noted that he inquired if the victim called or texted Dunn on his cell phone and the victim claimed he hadn't nor had Dunn ever done the same (cell phone calls 1 text messages) to him. Laporta noted that when he confronted Dunn regarding cell phone calls / text messages to the victim, Dunn acknowledged calling and texting the victim. Laporta noted that on Thursday morning (March 26th, 2009) he again spoke with the victim regarding the discrepancies between his and Dunn's story about sending andlor receiving cell phone calls and text messages to each other. Laporta noted that after being confronted about the discrepancies in their (the victim's and Dunn's) stories, the victim admitted to reciprocal calls and texts between the two. Laporta noted that when he asked the victim the nature of the communication between him (the victim) and Mrs. DU1ll1, the victim indicated that Dunn had arranged to get a room at the Day's Inn in New Haven where the victim met Dunn for sex. At this time, Laporta noted that he then re-interviewed Mrs. Dunn based upon the victim's statement (revelation of the victim and Dunn meeting for sex) and informed Dunn that the situation was extremely serious and would be under investigation. Laporta noted that Dunn then expressed concern for her children and told him (Laporta) that it was the worst mistake of her life. Laporta noted that he then informed Dunn that she was being placed on administrative leave until the investigation was completed.

After being advised of the facts and circumstance reported by Principal Laporta, Det. ~udwitz and this Affiant interviewed and obtained a sworn written statement from the victim. It should be noted that prior to Del. Budwitz and this Affaint interviewing the victim, the victim also provided a detailed written statement to Tfc, Butkevicius of Troop-I. That, the facts reported in the victim's statement to Tfc. Butkevicius are similar to the facts reported to this Affiant. Amongst other things in his statement to Det. Budwitz and me, the victim reported that he knows Mrs. Dunn (Jennifer Dunn) as being a library assistant and working in the lunch room at his high school I Platt Technical High School. The victim reported that Mrs. Dunn is friendly and that he and most other students call her by the nickname "Momma Dunn".

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ARREST WARRANT AFFIDAVIT CONTINUATION PAGE

JO,CR'o4a Rev 10-0", C GS § 54,2a

P r Gk Sec 36·, 35 2 Jii~;

INSTRUCTiONS:

riw jura/Is to be completed for each page of the afficlavl!.

"t:e prosecutoriet otticie! am! judge I judge Ina! refelf)c' ate 10 (1i:1/" am! signee! or initiet eecn page to indicet« lila! Illey ilave reVlelver!

STATE OF CONNECTICUT SUPERIOR COURT

N !\Mt= AN 0 f\ ES fO E NC t:'!7:~~~~OF""}\C~r:us ED==~--~~=-~:_==~~-=====--=--==-==-'=- ._ --~~:\~::-COURTl·:O-=-8l~_::Hf~~'·:I~~:)~~~~~~· ::~~',~~0:-~~~~l~:-:~G~~;:;N?i~-----

__ '!~~!lif~~l?~~1~?2 Crestwood Roa~i,.M~l_ford, ~_I ~~.:_~:_1~/31/1968 1\!~\V Haven ___~ 23

AFFIDAVIT

The undersigned Affiant, being duly sworn, deposes and says

The victim reported that after talking to Dunn in the lunch room and around school, Dunn one day asked him for his cell phone number. The victim reported that he gave Dunn his cell phone number and she in return gave him hers. The victim reported that he and Dunn exchanged cell phone numbers around Christmas / December 2008. The victim reported that he never before gave another teacher or school employee his phone number. After exchanging cell phone numbers, the victim reported that Dunn one day texted him a message "are you interested in me". The victim reported that Dunn would text him a lot (three or more times a day) at all hours of the day and night. The victim reported that Dunn also texted him the message "would you ever do stuff with me". The victim reported that he didn't reply to the aforementioned text and simply thought DUIDl meant that she wanted to hang-out. The victim reported that then Dunn texted him the message "do you want to get a room" he (the victim) replied back texting "yes". The victim reported that Dunn then texted him back the message "where do you want to go" and he replied / texted back "the Day's Inn" "Rt.80 in New Haven".

The victim reported that he met Mrs. Dunn at the Day's Inn around January of2009. The victim reported that the two (2) times he met Dunn at the Day's Inn in New Haven she made him do the same thing. The victim reported that first Dunn would text him the key code to her car which contained inside it the hotel room key. The victim reported that the key code to Dunn's car is a five (5) digit code and believed the first two (2) digits were 0,6. The victim reported that he didn't remember the rest of the key code to Dunn's vehicle. The victim reported that Dunn would then text him the hotel room number once he texted Dunn confirmation that he had the hotel room key. The victim reported that when Dunn asked him if he wanted to get a "room" with her, he pretty much figured that Dunn wanted to have sex. The victim reported that when he entered the hotel room, Mrs. Dunn was lying on the bed wearing blue jeans and a T-shirt. The victim reported that after entering the room and talking for about 10-20 minutes, Dunn began to remove her clothes and so did he. The victim reported that the first time he met DUIDl in the hotel, Dunn performed oral sex on him. The victim reported that both times he met Dunn at the Day's Inn, the

both of them (the victim and Dunn) removed all their clothing. /

The victim reported that the second time he met and had sex with Dunn at the Day's 11m was approximately two w-eeks after the first time the two met. The victim reported that the second time he met Dunn at the Day's Inn, the two (the victim and Dunn) had both oral sex and intercourse.

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3

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L;.~·\·([~

ARREST WARRANT AFfIDAVIT CONTINUATION PAGE

jiJ-CR-64a Rev. 10-04 C G S. § 54-2a

Pr Bx Sec 35·1 36-2 ~j;J3

INSTRUCTIONS:

The jural IS 10 be completed (01 each page of the ettidevt!

Tiw PIGsecu/oria/ official ane! judge! judge ttie! referee am (0 dale ami slC//}ee! or 1!lI/ial each page to indicate tne! they have revievlied

STATE OF CONNECTICUT SUPER!OR COURT

NAi\;iE !'IND RESIDENCE ((0"'.'1)) OF I\CCUSED··"~'==c,,,.,=,c,=-=-=,oc,.o,,,,,~ . -'=f"coli'fi"rm BE HEl'oi;T;"" .. '='7_7"O":~.;, r';c;=~='

__ J ~0ni_fer Dunn, .~~~'est\~0()9 __ I\o~_c!: .. ~/1 i I forc!_,_<=:'I.~..:()J?:__ 12/3111 9§J_j_ ~~:.~_I~i_~\~~I~

AFFIDAVIT

The undersigned Affiant, being duly sworn, deposes and says

This Affiant notes that in the statement the victim provided to Tfc. Butkevicius, the victim reported that Mrs. Dunn (Jennifer Dunn) drove a 2008 Ford Edge, color dark blue, and indicated that the aforementioned vehicle was the vehicle in which Dunn would leave the hotel room key prior to meeting Dunn for sex. That, when checked within NCIC, Christopher Dunn (d.o.b. 10/26/1962) of 82 Crestwood Road, Milford, CT, believed husband of Jennifer Dunn, did once have a 2007 Ford Edge, color purple (CT.Reg.286WKR, expiration date: 09/24/09) leased in his name, but presently the vehicle's registration status is cancelled. In the victim's statement to Tfc. Butkevicius, the victim reported thatthe sex between he and Dunn was consensual and that Dunn had not promised him anything nor had Dunn paid or given him anything,

The victim reported that about two weeks after he had intercourse 1 sex with Dunn, he was hanging out with his friends, two (2) former students of Platt Technical High School. At this time, the victim reports that both former students claimed to have had sexual relations with Dunn during their senior year (2008). That documented in sworn statements, each of the former students independently confirms having had sexual relations with Dunn shortly after graduating from Platt Technical High School in June of 2008. That both former students also confirm exchanging cellular text messages with Dunn.

The victim reported that the first time he had sexual relations with Dunn, at the Day's Inn on Route 80 in New Haven, CT was around January 2009. The victim further reported that the second time he and Dunn met for sex at the Day's Inn (Route 80, New Haven, CT) was approximately two weeks after their first meeting. During the course of this investigation this Affiant has obtained hotel records from the Day's Inn on Route 80 in New Haven, CT. The records obtained indicate that a hotel room at the Day's Inn on Route 80 in New Haven, CT was rented by Jennifer Dunn of 82 Crestwood Road, Milford, CT 06460 on both January 13t\ 2009 and January 23rd, 2009. The aforementioned records (Day's Inn, Route 80 New Haven) also contains Dunn's Connecticut driver's license number (CT operator # 244990113) as well as a photocopy of Dunn's photo Connecticut Driver License, expiration date 12/31/201.t. From reviewing the hotel's records it appears that, on both dates in question (January 13th, 2009 and January 23rd, 2009), Dunn paid cash for the rooms rented.

That in a sworn statement, Day's Inn Hotel owner, Jagdishchandra B. Patel (d.o.b. 03/07/1959) confirmed the information provided in said hotel records pertaining to Jennifer Dunn (d.o.b. 12/31/1968). Patel further reported that hotel records date back for a period of approximately 3 or 4 years and that the two aforementioned dates (01/13/09 & 01/23/09) are the only two dates on record indicating that Dunn purchased a room at the Day's Inn.

(This is page 4

5 page Affldav/t )

,:;;

ARREST WARRANT AFFIDAVIT CONTINUATION PAGE

JDCI~~64a Rev. 10-0':

CC S § 54-2cl

F\- Bl\_ Sec 3l), 1 3(3-2. JG-.3

lNSTRUCTiONS:

Tile jura! IS to be completed for each pflge of tile ettkievi:

The prosccutcnet official Cine! jUO'Wl / ju(lge triet referee are to ctete <lilci slgnf:Je! or milial each pDge to ioc'ic.:-lle (/w! lilfly have reviewed II

STATE OF CONNECTICUT SUPER10R COURT

~tJ;\I~~CA N 0 RE-SiriEN-EF~'T-;;;·:~~c(';'F'AccusED=====c~~c=~==~~==~~=~==-cc_=c""-",,,c'CC~~"=c_==~:COUfrT TO BE H E Ll)t~T':\~:;':!~';'''' . (;~, NC'

~~ -re!):~!if~~~P~~!!~c_~_~.c:'l:~~~yv'_()5ld RO(l~?._M_i!j!?E9:9:I . _sL~~·_b: .. 1)/}_I/).2~L __ L ~~}~'_lj~y_?11 23

AFFIDAVIT

The undersigned Affiant, being duly sworn, deposes and says

That, cellular telephone records confirm text messages sent and/or received from Dunn, to the victim as well as both former Platt Technical High School students on numerous dates, often multiple times a day. On January 1311\ 2009 and January 23rd, 2009, the dates on which hotel records confirm DUlU1 rented a room at the Day's Inn (270 Foxon Blvd, New Haven), cellular records confirm text messages sent and lor received between Dunn and the victim. Cellular records indicate that on January 13t\ 2009 approximately twenty-nine (29) text message communications were sent and/or received between Dunn and the victim. Cellular records also indicate that both parties (Dunn and the victim) sent andlor received text messages on January 23rd, 2009 approximately thirty-one (31) times. The aforementioned cellular telephone records are consistent with the statement of the victim. Upon further review of the requested cellular telephone records, said records indicate countless communications between Dunn, the victim as well as both former Platt Technical High School students. That on occasion the records shows text message communications between Dunn and all three other parties on the same day.

On Thursday, March 26th, 2009, after initially being notified of this complaint, this Affiant accompanied by Det. Budwitz and Sgt. Thomas (CDMCS) attempt to speak with the accused, Jennifer Dunn (d.o.b. 12/31/1968) regarding a criminal complaint that had been reported to the State Police by officials at Platt Technical High School which involved her (Dunn). That prior to being asking any questions regarding to the aforementioned complaint, Dunn indicated that at the advice of her attorney she was not willing to speak with the police at this time. It should be noted that as of this date neither Jennifer Dunn (d.o.b.

12/3 1/1968) nor any legal counsel representing her has indicated to State Police Officials a desire to discuss the sexual assault allegation involving her (Dunn).

That based on the above-mentioned facts and circumstances, the Affiant has probable cause to believe that Jennifer Dunn (d.o.b. 12/3111968) has committed the crime of Sexual Assault in the Second Degree

C.G_S. 53a-71 (Two Counts). I

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That this affidavit has not been presented before any other Court or Judge.

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