STATE OF WISCONSIN CIRCUIT COURT LA CROSSE COUNTY

CIRCUIT COURT LA CROSSE COUNTY STATE OF WISCONSIN -vs- Plaintiff, KAHLA A MARTIN, DOB: 04/10/1987 1804 Loomis Street La Crosse, WI 54603 Defendant, CASE NO.: 16CF575 DA Case No. 2016LC002852 Assigned DA/ADA: Emily E Hynek Agency Referral: 10-16-29858 ATN: SEX: F RACE: W Height: 5 ft 07 in Weight: 159 lbs HAIR: Blonde EYES: Blue OTHER: Craig Teff, City of La Crosse Police Department, being first duly sworn on oath says that on information and belief: Count 1: MANUFACTURE/DELIVER HEROIN (<= 3G), REPEATER, SECOND AND SUBSEQUENT OFFENSE (Buy #1) The above-named defendant on or about Monday, August 01, 2016, in the City of La Crosse, La Crosse County, Wisconsin, did deliver a controlled substance, to-wit: Heroin, in an amount of 3 grams or less, contrary to sec. 961.41(1)(d)1, 939.50(3)(f), 939.62(1)(c), 961.48(1)(b) Wis. Stats., a Class F Felony, and upon conviction may be fined not more than Twenty Five Thousand Dollars ($25,000), or imprisoned not more than twelve (12) years and six (6) months, or both. And further, invoking the provisions of sec. 939.62(1)(c) Wis. Stats., because the defendant is a immediately preceding the commission of this offense, consisting of at least one felony, so the maximum term of imprisonment for the underlying crime may be increased by not more than six And further, invoking the provisions of sec. 961.48(1)(b) Wis. Stats., because the defendant is a subsequent offender, having been convicted of possession of narcotic drugs, which conviction(s) remain of record and unreversed, the maximum term of imprisonment for the underlying crime may be increased by not more than 4 more than five (5) If the defendant's driving privileges are already suspended, any suspension Count 2: MANUFACTURE/DELIVER HEROIN (<= 3G), REPEATER, SECOND AND SUBSEQUENT OFFENSE (Buy #2) The above-named defendant on or about Monday, August 01, 2016, in the City of La Crosse, La Crosse County, Wisconsin, did deliver a controlled substance, to-wit: Heroin, in an amount of 3 grams or less, contrary to sec. 961.41(1)(d)1, 939.50(3)(f), 939.62(1)(c), 961.48(1)(b) Wis. Stats., a Class F Felony, and upon conviction may be fined not more than Twenty Five Thousand Dollars ($25,000), or imprisoned not more than twelve (12) years and six (6) months, or both. And further, invoking the provisions of sec. 939.62(1)(c) Wis. Stats., because the defendant is a

Kahla A Martin Page 2 of 8 immediately preceding the commission of this offense, consisting of at least one felony, so the maximum term of imprisonment for the underlying crime may be increased by not more than six And further, invoking the provisions of sec. 961.48(1)(b) Wis. Stats., because the defendant is a subsequent offender, having been convicted of possession of narcotic drugs, which conviction(s) remain of record and unreversed, the maximum term of imprisonment for the underlying crime may be increased by not more than 4 more than five (5) If the defendant's driving privileges are already suspended, any suspension Count 3: POSSESSION OF A FIREARM BY A FELON - PTAC, AS A PARTY TO A CRIME, REPEATER The above-named defendant on or about Wednesday, August 03, 2016, at 1804 Loomis Street, in the City of La Crosse, La Crosse County, Wisconsin, as a party to a crime, did possess a firearm, having been convicted of a felony in this state, contrary to sec. 941.29(1m)(a), 939.50(3)(g), 939.05, 939.62(1)(b) 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. And further, invoking the provisions of sec. 939.62(1)(b) Wis. Stats., because the defendant is a immediately preceding the commission of this offense, consisting of at least one felony, so the maximum term of imprisonment for the underlying crime may be increased by not more than four Count 4: POSSESSION OF A CONTROLLED SUBSTANCE - PTAC, AS A PARTY TO A CRIME, REPEATER The above-named defendant on or about Wednesday, August 03, 2016, at 1804 Loomis Street, in the City of La Crosse, La Crosse County, Wisconsin, as a party to a crime, did knowingly possess MDMA, a controlled substance, contrary to sec. 961.41(3g)(b), 939.61(2), 939.05, 939.62(1)(a) Wis. Stats., a Misdemeanor, and upon conviction may be fined not more than $500 or imprisoned not more than 30 days or both. And further, invoking the provisions of sec. 939.62(1)(a) Wis. Stats., because the defendant is a immediately preceding the commission of this offense, consisting of at least one felony, so the maximum term of imprisonment for the underlying crime may be increased to not more than two more than five (5) If the defendant's driving privileges are already suspended, any suspension

Kahla A Martin Page 3 of 8 Count 5: POSSESSION OF THC (TETRAHYDROCANNABINOLS) - 2ND AND SUBSEQUENT OFFENSE - PTAC, AS A PARTY TO A CRIME, REPEATER The above-named defendant on or about Wednesday, August 03, 2016, at 1804 Loomis Street, in the City of La Crosse, La Crosse County, Wisconsin, as a party to a crime, having previously been convicted of a criminal offense relating to controlled substances, did knowingly possess a controlled substance, Tetrahydrocannabinols (THC), contrary to sec. 961.41(3g)(e), 939.50(3)(i), 939.05, 939.62(1)(b) Wis. Stats., a Class I Felony, and upon conviction may be fined not more than Ten Thousand Dollars ($10,000), or imprisoned not more than three (3) years and six (6) months, or both. And further, invoking the provisions of sec. 939.62(1)(b) Wis. Stats., because the defendant is a immediately preceding the commission of this offense, consisting of at least one felony, so the maximum term of imprisonment for the underlying crime may be increased by not more than four more than five (5) If the defendant's driving privileges are already suspended, any suspension Count 6: POSSESSION OF DRUG PARAPHERNALIA - PTAC, AS A PARTY TO A CRIME, REPEATER The above-named defendant on or about Wednesday, August 03, 2016, at 1804 Loomis Street, in the City of La Crosse, La Crosse County, Wisconsin, as a party to a crime, did knowingly possess with primary intent to use drug paraphernalia to inhale a controlled substance or a controlled substance analog in violation of Chap. 961,, contrary to sec. 961.573(1), 939.05, 939.62(1)(a) Wis. Stats., a Misdemeanor, and upon conviction may be fined not more than Five Hundred Dollars ($500), or imprisoned for not more than thirty (30) days, or both. And further, invoking the provisions of sec. 939.62(1)(a) Wis. Stats., because the defendant is a immediately preceding the commission of this offense, consisting of at least one felony, so the maximum term of imprisonment for the underlying crime may be increased to not more than two more than five (5) If the defendant's driving privileges are already suspended, any suspension and prays that the defendant be dealt with according to law; that the basis for complainant s charge of such offense is:

Kahla A Martin Page 4 of 8 CONVICTION RECORD OF DEFENDANT: Your complainant is informed by the National Crime Information Bureau and the Wisconsin Criminal Information Bureau official teletypes; the Wisconsin Circuit Court Automated Programs; and the La Crosse County District Attorney s Office files, when available, the defendant has the following convictions and related sentence abstracts: CON DATE OFF. DATE JURISDICTION CASE NUMBER SE OFFENSE/SENTENCE 05-30-2014 02-15-2014 La Crosse 2014CF000127 Fel.I Poss. Narcotic Drugs (PTAC) Jail 9 mos. 01-16-2014 10-15-2013 La Crosse 2013CF000797 Misd.A Theft-Movable Property<=$2500 (Rptr) Probation 2 yrs / Jail 10 days (Rvkd 7-21-14 - Jail 9 mos.) 01-16-2014 09-13-2013 La Crosse 2013CF000789 Misd.A Retail Theft-Take<=$500(Rptr) Probation 2 yrs / Jail 10 days (Rvkd 7-21-14 - Jail 9 mos.) 01-16-2014 07-21-2013 La Crosse 2013CF000494 Misd.A Intimidate Victim/Dissuade Reporting Probation 2 yrs / Jail 10 days (Rvkd 7-21-14 - Jail 9 mos.) Fel I Possession of Narcotic Drugs Diversion-revoked-4y WSP 07-19-2011 02-11-2011 La Crosse 2011CF000111 Misd.A Deliver Illegal Articles to Inmate(Atmpt) Probation 1 yr (Rvkd 5-31-12 - Jail 4 mos.) 01-28-2011 12-26-2010 La Crosse 2010CM002169 Misd.A Theft-Movable Property<=$2500 Probation 24 mos. (Rvkd 5-25-12 - Jail 194 days) Misd.U Poss. Controlled Substance Jail 20 days - Time Served 01-28-2011 11-14-2010 La Crosse 2010CM001909 Misd.A Resisting/Obstructing Probation 24 mos. (Rvkd 5-25-12 - Jail 194 days) 01-28-2011 10-31-2010 La Crosse 2010CM001909 Misd.U Operate w/ PAC (2nd) Probation 2 yrs / Jail 9 days / Fine (Rvkd 5-25-12 - Jail 9 days) 11-10-2010 08-01-2010 La Crosse-Muni NA Forf.U OWI (1st) Forf/Fine Your complainant has reviewed the defendant s criminal conviction history above which reveals that the defendant is a habitual criminal having at least one felony conviction or three misdemeanor convictions, which remain of record and unreversed, dated within 5 years of the above alleged offenses and excluding time which the defendant spent in actual confinement serving a criminal sentence. She also has a separate felony conviction under Chapter 961, Wis. Stats. Your complainant has reviewed the official reports of officers and investigators of the La Crosse Police Department. These reports provide basis for this complaint. Investigator James Mancuso reports that on August 1, 2016, he had contact with a Confidential Informant given the number 746, and hereinafter referred to CI-746. CI-746 indicated that he/she could purchase a gram of heroin from an individual identified as Kahla Martin. Investigator Mancuso reports that CI-746 was searched and no items of illegal contraband were located. CI-746 was provided with $350 dollars of pre-recorded police buy money, to be used for paying off a prior debt and also for purchasing the heroin. CI-746 indicated that he/she could make contact with Martin using the phone number 608-881-9634. Investigator Mancuso observed text messages between CI-746 and Kahla Martin. The messages indicate that at the time CI-746 initially reached out to purchase heroin, Martin did not have a sufficient quantity, and arrangements were made for them to meet later. Investigator Mancuso reports that other investigators were assigned the task of surveilling Kahla Martin and she was observed leaving a north side location and traveling to the target location to meet

Kahla A Martin Page 5 of 8 with CI-746. During this time, Investigator Mancuso maintained contact with CI-746, who never left his presence. Kahla Martin s vehicle, a black Lexus SUV, arrived at the target location. Investigator Mancuso reports that CI-746 was provided with an audio/video recording device. CI-746 made contact with Kahla Martin, then came back and met with Investigator Mancuso and indicated that Martin indicated that she did not have the full amount, but could go get some more. Martin indicated that she did have some heroin on her and wanted to know if CI-746 wanted the quantity that she had. Investigator Mancuso informed CI-746 that he/she should purchase the quantity Martin had on her and come back later to pick up the rest of it. CI-746 returned to Martin s vehicle for approximately five minutes, then got out and Martin drove away. CI-746 immediately walked to Investigator Mancuso and turned over a small knotted corner baggie containing a brown/gray substance that Investigator Mancuso recognized as heroin from his training and experience. CI-746 also turned over the remaining police recorded buy money. CI-746 indicated Martin was the only person inside the vehicle and had been driving. CI-746 provided Martin the $100 dollars pre-recorded buy money that paid off a prior drug debt, then gave Martin another $90 dollars for the knotted corner baggie. CI-746 indicated that Martin stated she was going to go pick up more heroin, then come back to meet CI-746. Investigator Mancuso again searched CI-746 and did not locate any items of evidentiary value. Investigator Mancuso reports that CI-746 remained in his presence until Martin returned to the location. He searched CI-746 again and did not locate any items of evidentiary value or illegal contraband. Investigator Mancuso issued CI-746 $100 dollars of pre-recorded police buy money. CI- 746 received a Facebook message from Martin indicating that Martin had to go north, but would be there soon. Approximately 17 minutes later, the black Nexus arrived at the target location. CI-746 was again provided with an audio/visual recording device. CI-746 made contact inside Martin s vehicle. Approximately eight minutes later, CI-746 left the vehicle and returned to Investigator Mancuso. He/she immediately turned over a wrapped up one dollar bill that contained a substance CI-746 identified as heroin. CI-746 did not have any more pre-recorded police buy money. CI-746 indicated Martin was by herself in the vehicle. Investigator Mancuso again searched CI-746 s person and did not locate any items of evidentiary value. Investigator Mancuso reports that he reviewed the video captured by the CI s recording device and confirmed that the defendant is the Kahla Martin to whom the CI referred when speaking about purchasing heroin. Investigator Mancuso reports that the suspected heroin was turned over to Investigator Martin at the La Crosse Police Department. Investigator Martin advised that the total package weight from the first buy was.9 grams and the substance produced a positive result for the presence of heroin. The second purchase of suspected heroin had a total package weight of 1.5 grams and the substance tested positive for the presence of heroin. Investigator Hansen later informed Investigator Mancuso that a different one dollar bill was weighed and produced a weight of one gram. Investigator Mancuso reports that CI-746 also informed him that Kahla Martin has been dating Dameon Hendricks and they live on the north side of La Crosse. CI-746 indicated that he/she had witnessed their vehicle on the north side of La Crosse. CI-746 described Kahla s vehicle as being the black Lexus and the other vehicle as being a white Volvo. CI-746 indicated that he/she had purchased heroin from Martin out of both the Volvo and the Lexus in the past two months, and he/she had also witnessed Dameon Hendricks with two black handguns in his possession. Investigator Mancuso reports that he and other law enforcement officers conducted surveillance at the suspected address of Martin and Hendricks, and were able to confirm that their residence was 1804 Loomis

Kahla A Martin Page 6 of 8 Street in the City and County of La Crosse, Wisconsin. With this information, along with other information available to the officers, Investigator Mancuso applied for a search warrant for 1804 Loomis Street. Investigator Mancuso reports that prior to testifying for the warrant, he was advised that Kahla Martin had been stopped while driving the Lexus and was arrested, and Dameon Hendricks left the residence in the white Volvo and was also arrested without incident. Investigator Mancuso reports that after Martin s arrest, she was transported to the La Crosse Police Department and agreed to speak with Detective Anderson of the Trempealeau County regarding an ongoing drug investigation he had with her, then with Investigator Mancuso, regarding these incidents. Martin confirmed for Investigator Mancuso that her phone number was 608 881-9634. She stated she was staying with friends at 1804 Loomis Street. Martin advised that there would be guns found in that residence. Martin stated that Hendricks kept guns inside the house and she believed he had three. She did not know exactly what kind they were, but called them maybe a High Point and an AR. She did not know what the third gun might be. She was aware that both she and Hendricks were felons, and she does not want Hendricks to keep guns in the house but she thought he believed it was cool to have them. She stated she had been dating Hendricks for a couple of months. She stated she and Hendricks had moved in to the apartment on July 31 st when Megan Rasmussen and her boyfriend Isiah Thomas moved out. Martin stated that she had been selling heroin since she got out of prison. She identified that time as March 2016. When informed by Investigator Mancuso that they had conducted two controlled buys for heroin from her, she said, Okay. Investigator Mancuso asked Martin about the Lexus she drove. She stated that Hendricks bought it because he had gotten his native money on June 15 th. She stated the vehicle was in the name of Dallas Raisbeck, because Hendricks does not have a valid driver s license. She stated Dallas did not live with them but agreed that he was a heroin addict who she supplied. Martin indicated that she had sold heroin already that day, and that she sold heroin every day. She stated she is using a couple of points of heroin a day, but she uses more methamphetamine than heroin. She denied selling methamphetamine. She indicated she sold heroin in half gram to one gram amounts, but described it as not being big into it as she had been previously. She indicated law enforcement would probably not find heroin at the apartment because she did not have any left, and if there was any left, Hendricks probably had it on him. Investigator Mancuso indicated that Kahla Martin was polite, cooperative, and respectful during his interview with her. Investigator Tom Hansen reports that he assisted in searching 1804 Loomis Street and the vehicle of Dameon Hendricks pursuant to a search warrant after he was stopped in that vehicle. Investigator Hansen reports that in the vehicle he located a magazine for a handgun with six 9 mm rounds and Hendricks identification card in the center console. Officer Tolvstad advised that he had located another magazine to a handgun in the glove compartment which had six.380 caliber rounds inside. Inside the residence, Investigator Hansen began searching the southwest bedroom that appeared to be occupy ed by Hendricks and Martin based on credit cards in teach of their names located in the room, along with male and female clothing, and photos of both of them. Investigator Hansen reports that he started searching the bed, and when he removed a single blanket from the top of the bed he observed a black handgun identified as a 9 mm Beretta. The magazine was missing and there was not a round inside the chamber. Next to the gun was a BMO credit card belonging to Dameon Hendricks. On the nights stand next to the bed, he located paperwork belonging to a Volvo. In a small plastic storage container next to the night stand was a handwritten note, the top line of which stated, People who owe me. Below that header was a list of names and dollar amounts.

Kahla A Martin Page 7 of 8 Investigator Hansen reports that Officer Tolvstad located a glass pipe commonly used to smoke methamphetamine in the bedroom closet The pipe contained residue that was tested by Investigator Hansen and produced a positive result for the presence of methamphetamine. Investigator Hansen reports that when he returned to the police department, Investigator Mancuso advised tha the wanted to give Kahla Martin the personal belongings from her purse and the purse itself. Investigator Hansen retrieved the purse from her vehicle, which had been secured in garage no. 1. He searched the contents of the purse prior to turning it over to Martin. He located a large amount of US currency in the wallet. He also located 9 Suboxone strips and paperwork for the Lexus, along with a digital scale and several used syringes. Investigator Martin reports that he assisted in the surveillance of 1804 Loomis Street after Kahla Martin was arrested. He reports that he observed a male outside on his phone that he recognized as Dameon Hendricks. Hendricks went inside the residence, then exited again with a small child. Hendricks appeared to be in a hurry and was looking in all different directions. He put the child into the car and then began to drive away. Investigator Martin informed Officer Ulrich and Officer Tolvstad they should stop the vehicle. Investigator Martin continued watching the residence while Investigator Mancuso obtained a search warrant. At 8:13 p.m., Investigator Martin observed a white Ford Taurus occupied by Megan Rasmussen and Isiah Thomas pull up in front of the address and Thomas quickly went inside. Several minutes later, Thomas exited the residence carrying something long and black in his hand. As he went to place the item into the trunk, Investigator Martin recognized the item as a rifle similar to an AR-15. Investigator Martin notified Sgt. Dittman about what he had observed and Sgt. Dittman subsequently stopped the vehicle. Investigator Martin reports that he later returned to the La Crosse Police Department to assist with processing evidence. He weighed and tested a white powdery substance that had been located in the bedroom closet by Officer Tolvstad. The substance had a total package weight of 2.4 grams and tested positive for the presence of MDMA. Investigator Mancuso confirmed that Martin identified that this substance would be Ecstasy. Investigator Martin weighed and tested a green leafy substance that Sgt. Dittman located in the kitchen cabinet and received a total package weight of 5.8 grams and a positive result for the presence of THC. Investigator Martin counted the money recovered from Martin s purse and found a total amount of $1546 dollars. He located a ten dollar bill that had been pre-recorded police buy money from the heroin buy. Officer Tolvstad reports that he assisted with the search of the residence. He searched the closet next to the living room and located a navy box containing 20 to 35 founds of.380 ammunition. In the closet in the bedroom, he located a digital scale on the top drawer of a container in the closet that also contained a plastic bag containing a white powdery substance. He located several used needles, filters, and other items from drug paraphernalia. In the second drawer of the same container, he located a bag full of sandwich bags and another digital scale, alcohol pads, tie-offs, cookers, and several other items commonly used for drug use and packaging. A third drawer contained needles. Other items located included a metal grinder and a clear glass smoking pipe, and several white round pills and white and red capsules. On the top shelf of the closet he located a brown gun cardboard box. As he pulled the box down, a small black handgun fell from the top of it and onto the floor. The gun was identified as a Taurus.380 handgun. Officer Tolvstad reports that he ran the serial number and it did not come back as stolen. Sgt. Dittman reports that he had contact with Isiah Thomas and Megal Rasmussen after their vehicle was stopped. In the back seat of the vehicle was a female identified as Kristina Neve. Rasmussen

Kahla A Martin Page 8 of 8 stated that she knew her boyfriend Isiah had removed a gun from 1804 Loomis and placed it in the trunk of her car. She popped the trunk to allow Sgt. Dittman to retrieve the rifle, which he recognized as an AR-15. He also located underneath the rifle a magazine containing several rounds of ammunition for the AR. Thomas conceded that he removed the rifle form 1804 Loomis, but stated the rifle did not belong to Dameon Hendricks, it belonged to his cousin Seth Hendricks, and he was going to return it to him. Thomas denied knowing that Hendricks and Martin were dealing heroin. He denied knowing anything else about the other guns in the apartment. When asked why he made the decision to go to the apartment and get the rifle, Thomas responded, I was only going to go up there to see what else we had left. He stated he did not know how the rifle had ever come to be at the apartment in the first place. Subscribed and sworn to before me and approved for filing. Dated August 09, 2016 Officer Craig Teff City of La Crosse Police Department COMPLAINANT Emily E Hynek, State Bar No. 1072106 Assistant District Attorney La Crosse County, Wisconsin