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State of Minnesota County of Hennepin

CCT LIST CHARGE STATUTE ONLY MOC GOC

District Court Fourth Judicial District


M8196 N
CTY ATTY FILE NO. CONTROLLING AGENCY CONTROL NO

___________________________________________________________________________________________ 1 343.31

13-2836
COURT CASE NO.

MN0271100

13386635

DATE FILED

Amended
if more than 6 counts (see attached) if Domestic Assault as defined by MS 518B01, sub2a,b

Tab Charge Previously Filed SUMMONS WARRANT ORDER OF DETENTION EXTRADITION

State of Minnesota,
PLAINTIFF, VS. NAME: first, middle, last LEROY LONGS JR DEFENDANT, 4942 EMERSON AVE N MINNEAPOLIS, MN 55430

SERIOUS FELONY FELONY GROSS MISDM DWI GROSS MISDM

Date of Birth 7/13/79

MNCIS #: LE#: SILS ID: TRACK ID:

27-CR13-27474 340719 2695986

___________________________________________________________________________________________

COMPLAINT
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). The complainant states that the following facts establish PROBABLE CAUSE:

___________________________________________________________________________________________ Your Complainant, Lindsay Herron, is a sergeant with the Minneapolis Police Department, and in that capacity has investigated this matter by reading and reviewing the reports of fellow officers, by conducting search warrants, and interviewing witnesses and reviewing evidence. Complainant reports that she is the Animal Crimes Investigator for the Minneapolis Police. Complainant reports that she received information from a Confidential Informant that LEROY NMN LONGS, JR., defendant herein was involved in fighting dogs and breeding dogs for dogfighting purposes. Complainant reports that she began investigating defendants activities and eventually interviewed Witness A. Witness A knows defendant and told Complainant that defendant has dogs all over Minneapolis. Witness A further stated that defendant is known as a dogfighter. Complainant reports that based on the information from the CI and Witness A, she obtained a GPS order for defendants vehicle. She placed a tracker on this vehicle to determine where defendant keeps the dogs. Based on that she was able to identify eight locations defendant visited on a regular basis. She confirmed that there were Pit Bull dogs at all eight locations that defendant fed, walked and cleaned up after. Based on this information, Complainant obtained search warrants for all eight locations on November 15, 2013. Complainant reports that the search warrants were executed nearly simultaneously and that Pit Bulls were found at all of the locations. Law enforcement seized the animals.

FORM-J

REV. 12/95

Page

Complainant reports that many of the dogs were inside an outdoor dog kennel. The kennel itself was chained to the ground with a heavy chain cemented deep underground. A chain was then padlocked to each dogs neck. A key would be required to open the padlock on the kennel and to unlock the dog. It appeared to Complainant as though the dogs lived 24 hours per day in these kennels. Complainant reports that the animals seized were taken to Animal Control. Several of them were seen noted to have scarring consistent with having been fought. Complainant further reports that while executing the search warrant they were able to determine which bedroom in the home belonged to defendant. Law enforcement found receipts showing bulk purchases of dog food, receipts showing payments to multiple people, payments made by Money Gram to different states, numerous boxes of animal medication and vaccines, a large key ring containing padlock boxes, boxes of syringes along with other dog paraphernalia. Complainant also found a stick with teeth marks on it which in her experience is known as a bite stick. A bite stick is used for training fighting dogs. Complainant further reports that at defendants childrens home in New Hope, she found a 240 page guide on how to be a successful dogfighter. Complainant reports that she interviewed a person she identifies as Witness B. Witness B stated that defendant has dogs in many places. Witness A stated that defendant owns a champion dog, which Complainant states is a three time winner then often used for breeding. Witness B states that defendant fights the dogs and breeds them for fighting. Complainant states that the total number of animals seized eighteen dogs, which included five puppies. One of the female Pit Bulls was pregnant, and the others looked as though they had recently had litters. Defendant is presently in custody.

Page COMPLAINT SUPPLEMENT


CCT SECTION/Subdivision M.O.C. GOC

OFFENSE COUNT 1: ANIMAL FIGHTING (FELONY) MINN. STAT. 343.31, SUBD. 1(a)4, 609.101, SUBD. 2 PENALTY: 0-5 YEARS AND/OR $3,000-$10,000 That on or about November 20, 2013, in Hennepin County, Minnesota, LEROY LONGS JR used, trains or possess a dog or other animal for the purpose of participating in, engaging in or the violent pitting of one pet or companion animal as defined in section 346.36, subdivision 6, against another of the same or a different kind.

NOTICE: You must appear for every court hearing on this charge. A failure to appear for court on this charge is a criminal offense and may be punished as provided in Minn. Stat. 609.49. THEREFORE, Complainant requests that said Defendant, subject to bail or conditions of release be: 1) arrested or that other lawful steps be taken to obtain defendants appearance in court; or 2) detained, if already in custody, pending further proceedings; and that said Defendant otherwise be dealt with according to law.
COMPLAINANTS NAME: COMPLAINANTS SIGNATURE:

Lindsay Herron
DATE: Being duly authorized to prosecute the offense(s) charged, I hereby approve this Complaint. PROSECUTING ATTORNEYS SIGNATURE:

November 21, 2013 PROSECUTING ATTORNEY:


NAME/TITLE:

rew
ADDRESS/TELEPHONE:

DIANE M. KRENZ (16821x) Assistant County Attorney

C2100 Government Center, Minneapolis, MN 55487 Telephone: 612-348-6919

Page
Court Case # ________________________ This COMPLAINT was subscribed and sworn to before the undersigned this ____ day of __________________, 20___. 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 his detention, if already in custody, pending further proceedings. The Defendant(s) is/are thereof charged with the above-stated offense.

SUMMONS
THEREFORE YOU, THE ABOVE-NAMED DEFENDANT(S), ARE HEREBY SUMMONED to appear on the _______ day of ____________________, 20_____ 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


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 already in custody; I hereby order, subject to bail or conditions of release, that the abovenamed Defendant(s) continue to be detained pending further proceedings. Bail: $15,000.00 Conditions of Release: No contact with victim(s); No contact with witness(es); No contact with address of the offense or home/work of victim(s) and witness(es)

This COMPLAINT- ORDER OF DETENTION duly subscribed and sworn to, is issued by the undersigned Judicial Officer this ____ day of _____________________________, 20____.

____________________________________________________________________________________________ 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 HENNEPIN Clerk's Signature or File Stamp:

STATE OF MINNESOTA Plaintiff vs. LEROY LONGS JR

RETURN OF SERVICE I hereby Certify and Return that I have served a copy of this COMPLAINT SUMMONS, WARRANT, ORDER OF DETENTION upon Defendant(s) herein-named. Signature of Authorized Service Agent:

Defendant(s).