Case 2023CF000153 Document 2 Filed 02-21-2023 Page 1 of 4

FILED
02-21-2023
STATE OF WISCONSIN CIRCUIT COURT WINNEBAGO COUNTY Clerk of Circuit Court
DA Case No.: 2023WN000962 Winnebago County, WI
STATE OF WISCONSIN Assigned DA/ADA: Amanda G Nash 2023CF000153
Plaintiff, Agency Case No.: L-OP-02-18-2023- Honorable Bryan D.
0006604 Keberlein
vs. Court Case No.: Branch 3

MORGAN TAYLOR LUND CRIMINAL COMPLAINT

514A JEFFERSON ST
OSHKOSH, WI 54901
DOB: 06/09/2001
Sex/Race: F/W
Eye Color: Hazel
Hair Color: Blonde
Height: 5 ft 4 in
Weight: 125 lbs
Defendant. For Official Use

CRIMINAL CHARGE

Count 1: ATTEMPT FIRST DEGREE INTENTIONAL HOMICIDE, DOMESTIC ABUSE

ASSESSMENTS
The above-named defendant on or about Saturday, February 18, 2023, in the City of Oshkosh,
Winnebago County, Wisconsin, attempted to cause the death of V1, with intent to kill that person,
contrary to sec. 940.01(1)(a), 939.50(3)(a), 939.32, 973.055(1) Wis. Stats., a Class B Felony, and upon
conviction may be sentenced to a term of imprisonment not to exceed sixty (60) years.
And further, invoking the provisions of sec. 973.055(1) Wis. Stats., because this charge is an act of
domestic abuse, and further, invoking sec. 973.055(1), Wis. Stats., the court shall impose the domestic
abuse assessment of $100 for this offense because this charge is an enumerated crime under sec.
973.055(1)(a)1, Wis. Stats., and the conduct constituting the violation involved an act by the defendant
against her or her spouse, against an adult with whom the defendant resides or formerly resided, or
against an adult with whom the defendant has created a child.

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

The undersigned, being first duly sworn on oath and in that capacity has knowledge of the

following:

Your affiant is informed from the reports of the Oshkosh Police Department kept in the normal

and ordinary course of business in which your affiant believes to be truthful and reliable and have

proven so on numerous occasions in the past that on or about the morning of 02/18/2023, just before

8:00 AM, Officer Bennett was dispatched to a disturbance at a residence on the 500 block of Jefferson

Street in the City of Oshkosh, Winnebago County, Wisconsin. The call was originally dispatched as

"sister freaked out and boyfriend is bleeding. Possibly stabbed in arms." As Officer Bennett ran up to

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STATE OF WISCONSIN - VS - MORGAN TAYLOR LUND
the address he saw a young male exit who directed Officer Bennett upstairs. When Officer Bennett

reached the top of the stairs he saw a younger blonde female who appeared to be wearing only an

oversized blue UCLA sweatshirt and had the appearance of blood coating both of her legs, her feet,

both forearms, and the back and front of her hands. She was leaning over the back of a black sectional

couch in a living room, applying pressure to a shirtless male's upper chest or right shoulder area. That

male is identified herein as V1. V1 said to the female, "What the fuck is wrong with you? Why in my

sleep, bro?" She responded, "I thought I saw something," and the male said, "No!" The female was

crying. The male reported that he was injured "All over, on my back on my chest, everywhere," and the

female who was still standing above him indicated a spot on his head and she told Officer Bennett he

was cut on the scalp as well.

The female was identified verbally as MORGAN TAYLOR LUND, DOB 6/9/2001, who resides

at the Jefferson Street location with V1, who is the father of her child. Morgan told Officer Bennett that

she thought she saw something and also that she was afraid there was "something wrong with my

head". She stated that for roughly six months to a year she had been seeing a "figure" that was dark in

color and clearly not a person. This morning she said that she remembers waking up at approximately

6:30 AM with the baby in the room. Because she was having trouble sleeping, she took the baby out to

a large playpen in the living room where V1 was laying on the couch. She returned to bed to fall back

asleep. She told Officer Bennett that she had no memory of waking up a second time that morning. She

had a muddled memory of something that might have been a dream, or her imagination, but she

thought V1 was yelling at their daughter. She remembers then being in the living room area and seeing

this dark, scary figure on top of V1, attacking him. She went over to the couch area and picked up a

pair of scissors laying there and began "trying to kill" the dark ominous figure attacking V1. It was not

until V1 was screaming at her and fighting back that she realized the figure was not there and she was,

in fact, injuring V1. She says that as soon as she realized what was happening she put down the

scissors and tried to render first aid to V1.

Officer Pechacek reports that there were copious amounts of blood all over the floor and couch

in the living room. V1 had numerous stab wounds in his back and additional wounds on the front side of

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STATE OF WISCONSIN - VS - MORGAN TAYLOR LUND
sleeping on the couch when she started stabbing him with a pair of scissors. He said that he and

Morgan were together for about three years. They recently ended their relationship about 1-2 months

ago. Since then, he has been sleeping on the couch and allowed her to have the bedroom. He stated

that nothing happened last night between the parties. He woke up on the couch to Morgan stabbing him

repeatedly. V1 remembered while she was stabbing him Morgan said, "Why would you do this to me?"

She said something to him about having a dream. V1 stated that he didn't really realize what happened

until he looked down at his body and observed blood squirting out of his body. He ultimately was able to

attempt to fight back and pinned her down to get the scissors away from her. V1 stated that once he

was able to fight the scissors out of her hands, Morgan stated that she did not know what was

happening, she had a dream. V1 then asked her to go get a towel and she was able to go and retrieve

a towel for him. She then said something about, "I don't want to lose custody."

V1 did not give permission for Morgan to stab him and he was in a lot of pain. V1 said Morgan

kept stabbing him and he lost power and a lot of blood. He said that he thought he was going to die. He

believes that Morgan was trying to kill him. V1 had stab wounds to his back, right shoulder, chest/side,

face, and both hands. Hospital medical staff counted a total of 19 stab wounds. V1 received stitches or

staples to treat each of his stab wounds.

V1 stated that throughout their relationship Morgan was very abusive, hitting him on several

occasions. He reported that they constantly fight and argue. V1 did not know what triggered this event.

He stated that he does not know why Morgan would do this to him, especially in front of his daughter.

He stated they argue on a daily basis, but V1 shuts the argument down because he does not want to

be involved with her any longer. She has threatened him in the past, but has never threatened to kill

him as far as he is aware.

In searching the residence, on the end of the couch, on the floor, which would be on the south

end of the couch, Detective Artus noted a pair of scissors located on top of some clothing. This scissors

did appear to have blood on it. It is a Scotch-brand scissors. The scissors is approximately just over 1

centimeter wide at its widest point of the two blades. The overall length of the blades themselves is

approximately 5 centimeters long.

All of the above incidents occurred in Winnebago County, Wisconsin.

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STATE OF WISCONSIN - VS - MORGAN TAYLOR LUND

WHEREFORE, as said affiant verily believes and prays that the said MORGAN TAYLOR LUND might
be arrested and dealt with according to law.

Subscribed and sworn to before me on 02/21/23 Electronically Signed By:

Electronically Signed By: Inv Steven Verwiel
Tracy A. Paider Complainant
Assistant District Attorney
State Bar #: 1053910

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