Case 2022CF000230 Document 2 Filed 12-02-2022 Page 1 of 8

FILED
12-02-2022
Clerk of Courts
Oconto County WI
STATE OF WISCONSIN CIRCUIT COURT OCONTO COUNTY
2022CF000230
STATE OF WISCONSIN, Oconto County Sheriff's Department
DA Case No.: 2022OC000807
Plaintiff, Assigned DA/ADA: Hannah N Schuchart
Agency Case No.: 22-014446
vs.

HEIDI BARBARA DOROW CRIMINAL COMPLAINT

7507 EMOND LN
LENA, WI 54139
DOB: 07/18/1983,
Defendant. For Official Use

The undersigned, being first duly sworn, states that:

Count 1: SECOND DEGREE RECKLESSLY ENDANGERING SAFETY

The above-named defendant Between August 25, 2022 and November 13, 2022, in the Town
of Spruce, Oconto County, Wisconsin, did recklessly endanger the safety of RRM, MMZ, and
LF, contrary to sec. 941.30(2), 939.50(3)(g) Wis. Stats., a Class G Felony, and upon conviction
may be fined not more than Twenty Five Thousand Dollars ($25,000), or imprisoned not more
than ten (10) years, or both.

Count 2: FELONY INTIMIDATION OF A VICTIM

The above-named defendant on or about Sunday, November 13, 2022, in the Town of Spruce,
Oconto County, Wisconsin, knowingly and maliciously did attempt to dissuade LF, who has
been the victim of a crime, from making a report of the victimization to a law enforcement
agency, where the act is accompanied by any express or implied threat of force, violence,
injury or damage, contrary to sec. 940.45(3), 939.50(3)(g) Wis. Stats., a Class G Felony, and
upon conviction may be fined not more than Twenty Five Thousand Dollars ($25,000), or
imprisoned not more than ten (10) years, or both.

Complainant states he makes this complaint on information, belief, and personal knowledge,
his information is presumed reliable as a police informant, on information provided by the
Oconto County Sheriff's Department, which agency complainant believes to be reputable and
reliable, on information from , his information is presumed reliable as a citizen and victim
informant, on information obtained from the Oconto County Clerk of Courts Office, this
information is presumed reliable as being from records kept in the normal and ordinary course
of business, and on information provided by the defendant, his information is presumed to be
reliable because it is against his penal interest.

PROBABLE CAUSE:

1.Complainant’s review of the report of Lt. Paitl, which indicates in part that:

On 08-25-22 at approx. 12:00 P.M. I, Lt. B. Paitl, responded to 7511 Emond Lane, Lena,
Oconto County, WI reference to a dog bite that had occurred up the road from this address.

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Upon arrival I met with the complainant, MAM, and learned that his 13 year old daughter,
RRM, had been bitten by the neighbor’s dog while she was jogging on Emond Lane.

I spoke with RRM who advised that she was bitten in the upper leg area and she did have a
puncture wound as a result of the bite. I advised both MAM and RRM to consider going to the
hospital to have the bite looked at since the wound punctured the skin. MAM had
photographed the bite prior to my arrival by using his cell phone.

MAM stated when the bite took place, that RRM was some distance up Emond Lane from the
residence where the dogs belonged. MAM stated that the dog belongs to Heidi Dorow and the
dog that bit RRM was black and tan in color. MAM had texted Heidi prior to my arrival to advise
her of what had happened.

I also was able to speak to Wilbur L. Mahers who was a witness to this incident. Wilbur
advised that he was traveling down Emond Lane when he observed the dog jumping and
nipping at RRM. Wilbur advised that he was able to blow the horn on his vehicle and scare the
dog off enough for RRM to get into his SUV where he then gave her a ride home.

I was able to make contact with Heidi by phone and I advised Heidi that I needed her to sign a
quarantine form as a result of her dog biting RRM. I also completed a citation for Dogs running
at large and mailed the citation to Heidi's address.

2.The report of Deputy Steve Kessler, which indicates that on Thursday, August 25, 2022, he
conducted a follow up at 7507 Emond Ln, Town of Spruce, Oconto County, Wisconsin. Deputy
Kessler made contact with the dog's owner Heidi B. Dorow (07/18/83) at her residence.
Heidi signed the quarantine form. Deputy Kessler asked Heidi if she had any questions and
she said no.

3.The report of Deputy Lemens, which indicates that on August 26, 2022, he was informed that
Heidi Dorow’s dogs were running loose and not compliant with the quarantine order that
stemmed from the August 25, 2022 dog bite incident. Deputy Lemens responded to Dorow’s
residence, where she told Lemens that she has multiple dogs and the one that was involved in
the August 25, 2022 dog bite had been kept inside as required.

4.The report of Deputy Kessler, which indicates in part that:

On Saturday, October 15, 2022, I, Deputy Steve Kessler was in uniform operating a marked
patrol vehicle. At approximately 1:59 am, I was dispatched to an animal bite at 7507 Emond
Lane, Town of Spruce, Oconto County, Wisconsin. St. Clare Memorial Hospital reported that
MMZ was bitten multiple times by a family friend's dog. The bite took place at 7507 Emond
Lane. I was advised that the owner of the dog was Heidi B. Dorow F/W DOB 07/18/83.

Deputy Kasten spoke to MMZ at the hospital and took photos of her injuries. At around 6:15
pm, I arrived at 7507 Emond Lane. I made contact with Heidi. I knew Heidi from past
professional contacts. I asked Heidi what happened. Heidi stated about 11:00 pm (10/14/22),
she saw an intoxicated female playing with her dogs on the ground in her front yard. Heidi
stated the female pushed her dog away from her and Heidi’s one year old St. Bernard mix bit
the female. Heidi stated she helped the female up and brought the dogs inside. I asked Heidi
how she knows the female. Heidi stated the female came with another friend that is friends

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with her son. I asked Heidi if her dog had the rabies immunization. Heidi stated yes, sometime
in 2021 but she wasn't sure on the date. I reminded Heidi about making two visits to the
veterinarian. I asked Heidi if she had any questions and she said no. I filled out a Rabies/
Quarantine Order and had Heidi sign it.

I made contact via phone with MMZ's parents, MRZ and AMK. MMZ was also present during
the phone conversation. MRZ and AMK advised me that they were at St Vincent Hospital in
Green Bay. MRZ stated that MMZ was getting treated for the dog bites.

I asked MMZ what happened. MMZ stated she was in the front yard of 7507 Emond Lane.
MMZ stated she came with a friend that is friends with the people that live there. MMZ stated
she was bitten multiple times by multiple dogs in the yard of that residence. MMZ stated the
owner of the dogs came outside and helped her. MMZ stated she went to the hospital.

On 10/16/22, I conducted a follow up with Heidi in person. I told Heidi that MMZ was claiming
that she was bitten by all of her dogs. Heidi stated only one puppy bit MMZ. Heidi stated that
three of her five dogs were outside with MMZ in the front yard. Heidi stated she saw the puppy
bite MMZ and the other two dogs were running around the yard.. Heidi stated two of her dogs
are vaccinated and the other three dogs are puppies. Heidi stated her puppies are probably
due for their rabies booster vaccine soon.

5.The report of Deputy Marquardt, which indicates that:

On Monday, October 17, 2022, I, Deputy Austin Marquardt was in uniform operating a marked
patrol vehicle. At approximately 3:18pm, I was made aware of an animal problem complaint at
7680 Emond Lane, Town of Spruce, County of Oconto, and State of Wisconsin. Christine M
Pawlak reported she has had an ongoing issue with her neighbor's dog coming onto her
property. The dog owner is Heidi B Dorow (7/18/83), and resides at 7507 Edmond Lane. I
made phone contact with Christine, who reported that Heidi's dogs continue to come on their
property, and they have to "chase it off". Christine stated that she is concerned as her
grandchildren come over to visit, along with their dog, and she is worried about everyone's
safety, due to Heidi's dogs being aggressive. Christine advised that she wanted to start having
it documented and would potentially start to seek action in the future if it continues.

6.The report of Deputy Ruiz, which indicates that:

On Monday, October 17, 2022, I, Deputy Ruiz was in uniform operating a marked squad. At
approximately 6:37 PM, I was dispatched to 7507 Emond Ln, in the Town of Spruce, County of
Oconto, and State of Wisconsin for a dog not being properly quarantined.

I was able to make phone contact with ERM. ERM advised me that the dog located at 7507
Emond Ln is left running around the yard all day. She advised me that the owners are not
following the quarantine order. I arrived on scene a short time later and met with the dog owner
Heidi B. Dorow DOB 07/18/83. She advised me that she has five dogs including the one
involved in the incident on Friday. She stated that one of her dogs is very similar to the one
under the quarantine order. She also advised me that the dog is quarantined in her bedroom,
and that is not the one going out to the yard. When she takes that dog out, she has it on a
leash. I reminded Heidi of possible actions if she violates the quarantine order, and she stated
that she understood.

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7.The report of Deputy Christensen, which indicates that:

On 10/20/22, at approximately 4:00pm I, Deputy Christensen, was in full uniform operating a

marked patrol vehicle. I was made aware of an animal problem complaint that was occurring
on Emond Lane. ERM called and stated her neighbor Heidi Dorow was not complying with the
quarantine order following a dog bite of her child. Heidi also wanted to report a harassment
complaint against ERM.

I made phone contact with ERM. ERM advised that Heidi is constantly outside with her dogs
even though they need to be quarantined off the property. It appeared that there was a similar
complaint called in on 10/17/22 of similar nature handled by Deputy Ruiz. During that
complaint, it was found that Heidi has five dogs, some of which are similar in appearance. It
was also documented in the report that the dog that was involved in the incident was
quarantined in Heidi's bedroom and put on a leash when it has to go outside.

ERM told me that her daughter was bit by multiple dogs not just the one dog. After reviewing
the original animal bite complaint handled by Deputy Kessler, it appears that there were
conflicting stories as to if it was just one dog that bit multiple times or multiple dogs that bit the
individual.

Based on the information that I received from dispatch, I believe Heidi wanted to report ERM
and her husband driving past her house multiple times and also sending her harassing text
messages about going to the DA's office and telling everyone about the dog bite. ERM advised
that she has an attorney involved. I advised ERM that I would have a report with the
information provided to me on file.

8.The report of Deputy Kasten, which indicates in part that:

On Thursday, October 20, 2022 I, Deputy Kasten was in uniform operating a marked patrol
vehicle. I received an email from MMZ's father, MRZ. The email from MRZ contained a 42
second video of the dogs attacking MMZ.

The video appeared to be from a home surveillance camera at the residence. The video shows
MMZ on the ground and three dogs attacking her. At the beginning of the video, the dogs are
already attacking MMZ. Due to the video starting when the dogs are already attacking MMZ, it
is assumed there is more footage of the attack. When watching the video, it is not until the end
of the video that someone finally runs to MMZ's aid and gets the dogs to stop attacking her.

At approximately 6:54PM, I attempted contact with the dog's owner Heidi Dorow. The reason I
was attempting contact with Heidi is to obtain a written statement about the incident. I made
contact with MRZ so I could arrange a time to meet with MMZ to obtain a written statement. I
met with MMZ and MRZ at their residence in Michigan.

MMZ provided a written statement about the events of the night. MMZ's statement consisted of
the following: MMZ stated she heard about a party/fire that was occurring on Emond Road.
MMZ stated she and her friends went to the party and when they got there one of her friends
asked if they could pet the dogs and they were told yes. MMZ stated a short while later she
was walking by the dogs and one of the dogs jumped up on her. MMZ stated she did not think

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anything of it at first because they jumped on her friend when she petted them. MMZ stated the
dog then bit her arm and latched on. MMZ stated the dog became more aggressive and
dragged her to the ground. MMZ stated the other dogs then began to attack her. She stated
the dogs were biting her all over and dragging her around by her hair and limbs. MMZ stated
she was screaming as loud as she could for help because she was in fear the dogs were going
to continue hurting her. MMZ was still lying face down with her pants pulled down from the
dogs attacking her, and the adults started yelling and kicking the dogs. MMZ stated adults
eventually were able to the get the dogs off of her. MMZ stated after the dogs got off of her,
one of the adults started yelling at her to get up. MMZ was able to finally get up and she
stumbled to the door when one of the dogs again jumped on MMZ and again dragged her to
the ground. MMZ was finally able to get away, into the house, and collapsed on the stairs.
MMZ stated the adult stated this has never happened before.

MMZ stated she was begging to go to the hospital but the adults on scene found her friends
that she came to the residence with instead, and had all of those individuals leave. MMZ was
eventually taken to the Oconto Falls hospital by her friends. MMZ was sent to St. Vincent
Hospital in Green bay due to the injuries.

Due to MMZ's injuries she was having to use a cane to walk. MMZ also has to wear a wound
vac, which pulls fluids from a wound to reduce the swelling, for the rest of the week. MMZ
indicated that she had to get surgery on different places on her body due to the severity of the
dog bites.

On Monday, October 31, 2022 I was in uniform operating a marked patrol vehicle. I picked up
the written statements from Heidi Dorow about the dog bite incident from October 15, 2022.

Heidi's statement stated on the night of the incident she was woken up by her dogs barking.
She stated she looked out the window and saw three dogs running around her yard. Heidi
stated she could see someone in the front yard by the dogs. Heidi stated she opened the door
and yelled for them to get up and what are you doing out here. Heidi stated two dogs were
barking and one dog was grabbing the girl's clothes, her sleeves and hood and bottom of her
shirt. Heidi stated she did not know who the girl was and why she was at her house. Heidi
talked with the girl about why she was there. Heidi stated the girl was saying her knee and
back hurt but would not let anyone look at it. Heidi stated she was able to get the girl's friends
to get the girl and they talked about going to the hospital but the kids seemed leery about
going because they had been drinking. Heidi stated they kids left shortly after. Heidi indicated
that the group was not invited. Heidi indicated that her yard has an acre of invisible in ground
fence and her dogs have collars to keep them inside the perimeter. The dogs have use of an
extra-large dog door to go out at their own discretion.

9.The report of Investigator Ron Ripley, which indicates in part that:

On 11/15/2022 I was assigned this case by Lt. Brad Paitl who provided me with information
regarding the incident at which time I was informed there had been another dog attack by Heidi
Dorow's dogs.

I was familiar with the previous three recent ongoing complaints: 22-010757 where a 13 year
old female was attacked, #22-013034 where a 17 year old female was attacked, #22-10819
where Heidi's dogs were at large. I also knew that regarding complaint #22-010757, Heidi was

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ordered to quarantine the dogs. I personally know Heidi and know she resides at: 7507 Emond
lane. I also know that Heidi owns several large dogs as I have seen them in her yard
previously while I was in the neighborhood.

Lt. Paitl asked that I meet with the victim and his family who were en-route to the Sheriff's
Office to provide a formal statement. At approximately 9:25 am I met with Lt. Paitl, the victim:
L.F. (16 year old male) and his parents: ALF and ACF in the Sheriff's lobby.

Lt. Paitl had a discussion with L.F. regarding the fictitious report he had originally filed with the
DNR Warden (P. Hartrick) regarding the matter where he and his friend (D.W.) told the hospital
and DNR regarding being attacked by a coyote and where he had disposed of his
clothing, and regarding his concerns about under aged drinking at the residence.

While meeting with L.F. I observed bandages on his legs and ankles as he was wearing
shorts. I observed L.F. had trouble walking, he appeared to be in pain and he seemed to not
be able to move his right arm much when I shook his hand.

I then escorted LF, ALF, and ACF to the Investigator conference room and interviewed them.
The following is a summary of the interview which I audio recorded with their knowledge:

L.F. informed me on Saturday (11/12/22) he had been at Heidi's (Dorow) residence where
there was a party in the garage. L.F. informed me he is friends with Heidi's son: D.W. (14 year
old male). L.F. informed me they had been playing games in the garage, riding scooters, etc.
and there had been underage drinking going on. L.F. informed me he brought his own alcohol
to the party, Heidi did not provide them with any and he was unsure if she had knowledge of
the party. L.F. informed me at approximately 1 am he left to go to Kwik Trip for food and then
returned to the party. L.F. informed me at approximately 3 am he left again to go sleep at a
buddy's house and he returned at approximately 8 am Sunday morning (11/13/22).

L.F. informed me his friend: R.B. (15 year old male) had witnessed him being attacked by the
dogs when RB came out of the garage near the end of the attack, and RB saw it as it was
happening. L.F. informed me Heidi's daughter: P.F. (15 year old female) did not witness the
attack. L.F. informed me his friend/Heidi's son: D.W did not witness the attack and came
outside after it happened.

L.F. informed me on Saturday, the dogs had been locked up. Normally they are inside the
house or out in the yard. L.F. informed me he believes there is an underground electric fence.
L.F. informed me he was unsure how many dogs Heidi owns, usually he sees 4 and there
were 4 the day of his attack. L.F. informed me Heidi's dogs are large, perhaps St. Bernard -
Pitbull mixed.

L.F. informed me on Sunday when he arrived, the dogs were in the yard. LF had never had
problems with them before. L.F. informed me he is at Heidi's a lot and the dogs were familiar
with him. L.F. informed me the dogs came out to his truck and were sniffing him. One dog
jumped inside LF’s truck and he left it inside. L.F. informed me the 3 other dogs that were
nearby attacked LF as he was approaching the house and garage. L.F. Informed me the attack
lasted 2-3 minutes. LF first got bit in his legs and he tried to get into the garage but the dogs
kept dragging him down every time he'd get up. L.F. informed me he had been bitten on both
ankles, both knees, both arms, on the inside of his right thigh by his groin, on both of his sides,

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and his buttocks. L.F. informed me he had been bitten on his left forearm, left bicep, and left
armpit.

I was informed by ALF and ACF that L.F. had been brought to St. Clare Hospital in Oconto
Falls and later transported by ambulance to St. Vincent Hospital in Green Bay.

L.F. informed me he had been put on anesthesia and had drains put in both legs. L.F. informed
me he had also received sutures, staples, and drains placed in his right arm. ALF and ACF
informed me L.F. would be receiving 4 rabies shots as Heidi's dogs vaccinations were not up
to date. I was also informed that L.F. may need plastic surgery in the future and be receiving
ongoing treatment for possibly 6 to 8 weeks at $900 per week. I was informed that L.F. did
have medical insurance.

L.F. informed me that after the attack D.W. called Heidi and he took him to the hospital. L.F.
informed me he was present when MMZ had been attacked on October 14/15th, 2022. L.F.
informed me he didn't know what Heidi thought of this incident.

ALF informed me following the attack, at approximately 8:39 am on Sunday she had received
a phone call from D.W. who was using L.F.'s phone where he told her that he was driving L.F.
to the hospital. ALF informed me that D.W. told ALF that they had been small game hunting,
they hit something with the truck and when L.F. got out to see what it was, LF was attacked.
ALF informed me D.W. told ALF that the music was too loud in the truck at the time so he
didn't hear L.F. getting attacked.

L.F. informed me while at St. Clare he told the hospital staff that a coyote bit him and they
called the DNR Warden who met with him there. AMK informed me L.F. had been at St. Clare
for approximately 2 hours before being transported to St. Vincent.

L.F. informed me that a few minutes prior to D.W. transporting him to the Hospital, D.W. had
called his mother (Heidi) and came back from inside the house and said his mom was pissed.
L.F. informed me D.W. stated his mom told them what they had to say and if L.F. didn't do so
she'd shoot him. L.F. informed me D.W. received a text message from his mother who
coached him on what story to say. ALF and L.F. informed me the DNR Warden took photos of
his visible injuries before he was transported and the doctors at St. Clare took before and after
photos of his injuries.

ALF, ACF and L.F. informed me they had not communicated with Heidi or D.W. in any way
since the attack. ACF informed me a mutual friend of theirs and Heidi's and the children had
saved screenshots of the messages regarding the incident. ALF and ACF suspected Heidi and
her family would laugh about the incident as they had done so previously regarding the second
attack. L.F. informed me he does not plan on contacting D.W. or ever returning to the property
for fear of retaliation and fear of the dogs.

ALF and ACF expressed their concerns about Heidi retaliating against them. I informed them
that I would attempt to speak with Heidi regarding the matter. I advised them to contact law
enforcement if anyone shows up at their property and to retain any information if they are
harassed in the future.

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On 11/15/22 at approximately 3:30 pm Lt. Paitl and I attempted phone contact with Heidi at her
last known phone number. I was unable to leave a voice message.

Based on the foregoing, the complainant believes this complaint to be true and correct.

Subscribed and sworn to before me on 12/02/22 Electronically Signed By:

Electronically Signed By: Deputy Jess Keplinger
Hannah N Schuchart Complainant
District Attorney
State Bar #: 1097899