StateofMinnesota DistrictCourtCountyofWashington 10thJudicialDistrict

CR2014538ProsecutorFileNo.82CR142020CourtFileNo.

StateofMinnesota, COMPLAINTPlaintiff, Warrant

vs.ALEXANDERLEECLAUSSENDOB:09/19/19944194thStreetS#2SaintCloud,MN56301

Defendant.

The Complainant submits this complaint to the Court and states that there is probable cause to believeDefendantcommittedthefollowingoffense(s):

COUNTI

Charge:Murder3rdDegreeSell/Give/DistributeControlledSubstanceSchedules1and2MinnesotaStatute:609.195(b)MaximumSentence:25yearsand$40,000OffenseLevel:Felony

OffenseDate(onorabout):09/01/2013to10/31/2013

Control#(ICR#):14600836

Charge Description: without intent to cause death, proximately cause the death of T.E.F. by, directly orindirectly,unlawfullysellingascheduleIcontrolledsubstance

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STATEMENTOFPROBABLECAUSE

TheComplainantstatesthatthefollowingfactsestablishprobablecause:

Your Complainant is a licensed peace officer in the State of Minnesota and is employed by the Woodbury Police Department. In that capacity, your Complainant states that the following to establish probable cause: On 1/11/2014, at approximately 0910 hours, Officers from the Woodbury Police Department and medical crew from the Woodbury Fire Department were dispatched to 3430 Commonwealth Avenue, Woodbury, Washington County, Minnesota, 55125, upon report of a 16 year old female, Victim T.E.F., who was not breathing and unresponsive after reportedly experimenting with a substance similar to LSD or LSD. Upon arrival, efforts were made to resuscitate the Victim T.E.F. The Victim T.E.F. was transported to Regions Hospital, where she was pronounced dead. While at 3430 Commonwealth Avenue, Officers spoke with a female juvenile, who reported that last night, she and the Victim T.E.F. had taken a substance they thought to be LSD. A.R.H. reported that they purchased and obtained the substance from another classmate named "Brian", a 17 year-old male who also attends Woodbury High School. A.R.H. described the LSD as being packaged in a tinfoil wrapper and containing two small square pieces of paper, which was light pink in color. A.R.H. described how she and the Victim T.E.F. both took the LSD at approximately 0000 hours the night before, while at the Victim T.E.F.'s house, by placing it on their own tongues for approximately 20 minutes. Both the Victim T.E.F. and A.R.H. swallowed the dosage. Cell phones from both T.E.F. and A.R.H. were collected from the scene. Both cell phones contained images and videos of T.E.H. and A.R.H. under the influence of the substance they had ingested earlier. A.R.H. described the Victim T.E.F. as moaning and appeared to be experiencing muscle spasms or shaking. At approximately 0200 hours, A.R.H. texted female juvenile C.A.D. because A.R.H. felt something was wrong with the Victim T.E.F. C.A.D. arrived at the residence at approximately 0210 hours. C.A.D. left the residence at approximately 0330 hours. Between 0800 and 0845 hours, A.R.H. heard Victim T.E.F. moaning. Victim T.E.F. was breathing but still unresponsive and experiencing muscle spasms. A.R.H. tried to wake up T.E.F., but then called her father and mother. A.R.H.'s mother responded to the residence and called 911 at approximately 0910 hours. On 1/11/2014, a School Resource Officer currently assigned to Woodbury High School determined that an individual by the name of Brian Phillip Norlander (DOB: 8/19/1996), Defendant Norlander herein, was in A.R.H.'s sixth hour class at Woodbury High School. The Officer also reviewed various social media sites and determined that the Victim T.E.F., Norlander, A.R.H., and C.A.D. all "followed" each other on Twitter. Defendant Norlander was arrested and transported to the Woodbury Police Department. Defendant Norlander stated that Victim T.E.F. obtained the drug, LSD, from him approximately one week ago. Defendant Norlander admitted that he gave Victim T.E.F. two tablets that were wrapped in tin foil. Defendant Norlander admitted that he was in possession of another dose. Officers were able to recover the suspected narcotic from Defendant Norlander's vehicle. The drug recovered from Norlander's vehicle was submitted to the Minnesota Bureau of Criminal Apprehension (BCA) for analysis. The BCA determined that the drug submitted was comprised of 25i-NBOMe and 25C-NBOMe. 25i-NBOMe is a Schedule I Controlled Substance. Defendant Norlander stated that he got the drugs from Alistair Curtis Berg (DOB: 10/22/1996), Defendant Berg herein. Defendant Berg is a student at Woodbury High School. Norlander stated that he purchased the drugs from Defendant Berg approximately a week and a half ago, and that the transaction took place before first hour in school. Officers spoke with Defendant Berg. Defendant Berg stated that he knew of the

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Victim T.E.F. Defendant Berg admitted that he possessed the LSD for "a little bit." Defendant Berg stated that he purchased three tabs of the drug from Sydney Johnson, later determined to be Sydney Claire Johnson (DOB: 7/1/1996), Defendant Johnson herein. Berg stated that he sold the narcotic to Defendant Norlander for $30, which is the same price Defendant Berg paid Defendant Johnson for the drugs. Defendant Johnson also attends Woodbury High School. Officers spoke with Defendant Johnson. Defendant Johnson initially denied knowing about the LSD obtained from her by Defendant Berg. Defendant Johnson stated that she knows the Victim T.E.F. died, and that Defendant Norlander provided the LSD to her. Defendant Johnson stated that Defendant Berg sold the LSD to Defendant Norlander. Defendant Johnson admitted that she purchased 3 doses of LSD from an individual named "Cole" in October for a total of $30, and then she sold the LSD directly to Berg for a total of $30. Johnson believed she sold the drugs to Defendant Berg in October. Defendant Johnson stated that she knows the drug is not good for you and is a hallucinogenic. When asked if she felt responsible for the Victim T.E.F.'s death, Defendant Johnson stated yes because she is connected to the people who gave it to her. Defendant Johnson admitted to being a drug dealer. Defendant Johnson stated that she has purchased LSD from "Cole" approximately 6 or 7 times, and that she would purchase 3 or 4 doses per time. Defendant Johnson stated that "Cole" had "a lot" of LSD and explained that Cole had "sheets" of the drug, but did not know how many doses were on a "sheet." Johnson stated that Cole's girlfriend, D.M., has been asking people who "ratted" him out. Officers were able to identify "Cole" as Cole Alexander Matenaer (DOB: 4/11/1995), Defendant Matenaer herein. On 1/13/2014, Officers arrested Defendant Matenaer while he was driving a black Audi. Inside the vehicle, Officers located 34 dosage units of a substance that was similar to the other substances already collected. Officers also confiscated Defendant Maetnaer's cell phone. Defendant Matenaer stated that he received the LSD from a male by the name of "Alex" in Inver Grove Heights in the early part of December. Defendant Matenaer stated that "Alex" currently lives in St. Cloud, MN. Defendant Matenaer stated that "Alex's" number would be in his phone. Defendant Matenaer admitted that he sold doses for approximately $10 each. When asked how many doses he sold in Woodbury, Defendant Matenaer stated "a lot." Defendant Matenaer stated that he personally cut the paper for the doses and would place more than one dose in a piece of tinfoil. Defendant Matenaer explained that he would place the number of doses ordered from the person in a piece of tinfoil. Defendant Matenaer stated that he sold to Defendant Johnson. Defendant Matenaer stated that Defendant Johnson goes to Woodbury High School with his girlfriend D.M. Defendant Matenaer stated that it was likely his LSD the Victim T.E.F. had received. Officers requested and listened to the telephone calls in which Matenaer participated while incarcerated in Washington County Jail. In a telephone call with an individual believed to be his mother on 1/14/2014, when told "what you did is a crime, Cole," Defendant Matenaer responded, "I know." In another telephone call on 1/14/2014 with an individual believed to be his girlfriend, D.M., Matenaer stated "it's my fault" and "Yeah, I sold drugs." In another phone call on 1/14/2014 with an individual believed to be his girlfriend, D.M., Matenaer stated, "if you see Sydney, just beat her ass". On 2/10/2014, Officers seized D.M.'s phone. Law enforcement reviewed the data extracted from the phones of both Matenaer and his girlfriend D.M. Law enforcement discovered numerous communications regarding drugs deals and references to the death of victim T.E.F. Law enforcement also recovered deleted data from D.M.'s phone, including messages exchanged with a cell phone believed to be used by Defendant Matenaer's mother. D.M. wrote: "I don't think he is emotionally able to tell you what happened. Um, he may be charged for murder. A girl he did not sell to died this weekend and they want to charge him because it came from him even though it went through other people to the girl." The drugs recovered from Matenaer's vehicle were submitted to the BCA for analysis. The BCA determined that the drugs analyzed were comprised of 25i-NBOMe.

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An Officer identified a contact in Matenaer's phone named "Alex" with a phone number of 320-333-1747. An Officer learned that many, if not all, text messages between Matenaer's phone and the phone associated with his contact "Alex" had been deleted. Many of the deleted messages consisted of drug talk about LSD. On 3/20/14, Officers obtained a court order authorizing the use of a pen register for the phone number associated with the contact "Alex" in Matenaer's phone. Thereafter, Officers determined that the phone was registered to Tree Top Nursery and Landscaping in Sauk Centre, MN, and Martin Claussen as the CEO of that company. Officers determined that Alexander Lee Claussen (DOB: 9/19/94), Defendant Claussen herein, was the likely user of that phone. Officers conducted a criminal history check of Defendant Claussen and learned that he had been arrested by the Nebraska State Patrol on 1/25/14 for possession of 1 oz. of marijuana. The report from the Nebraska State Patrol regarding that incident identified Defendant Claussen's phone number as the same number, 320-333-1747, identified in Defendant Matenaer's phone as his contact "Alex." Thereafter, Officers tracked Defendant Claussen to a residence in St. Cloud, Minnesota, 419 4th St. S., St. Cloud, MN. Officers then set up a controlled drug purchase by a Confidential Informant at the same residence. The Confidential Informant contacted Defendant Claussen and requested to purchase "LSD." Defendant Claussen directed the Confidential Informant to meet him at the "castle," which the Confidential Informant knew to be a residence located at 5th Ave. and 4th St. in St. Cloud, consistent with the address to which law enforcement tracked Defendant Claussen. The Confidential Informant was provided with narcotics buy funds for the transaction. After meeting Claussen at that location, the Confidential Informant entered the residence, and came out approximately 1 minute later. The Confidential Informant provided Officers with the substance he purchased as "LSD," which Officers believed to be 5 doses of 25I-NBOMe. Thereafter, Officers obtained a warrant to search Defendant Claussen's residence. On 4/3/2014, Officers searched Claussen's residence and located 305 suspected doses of 25i-NBOMe. The drugs recovered from Claussen's residence were submitted to the BCA for analysis. The BCA determined that the drugs analyzed were comprised of 25i-NBOMe. On 5/14/14, the Final Autopsy Report for Victim T.E.F. was issued by the Ramsey County Medical Examiner's Office. Victim T.E.F died as a result of complications of 25i-NBOMe toxicity.

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SIGNATURESANDAPPROVALS

ComplainantrequeststhatDefendant,subjecttobailorconditionsofrelease,be:(1)arrestedorthatotherlawfulstepsbetakentoobtainDefendant'sappearanceincourtor(2)detained,ifalreadyincustody,pendingfurtherproceedingsandthatsaidDefendantotherwisebedealtwithaccordingtolaw.

Complainant MichelleMFrascone ElectronicallySigned:5/27/2014Detective2100RadioDriveWoodbury,MN55125Badge:96

Subscribedandsworntobeforetheundersigned.

NotaryPublicorJudicialOfficial

Commissionexpires:01/31/2017ElectronicallySigned:5/27/2014

JaneODonnellAdministrativeAssistant,CountyofWashington2100RadioDriveWoodbury,MN55125NotaryID:6171653

Beingauthorizedtoprosecutetheoffensescharged,Iapprovethiscomplaint.

ProsecutingAttorney ElectronicallySigned:5/27/2014ImranAliPOBox61501562ndStreetNorthStillwater,MN55082(651)4306115

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FINDINGOFPROBABLECAUSEFrom the above sworn facts, and any supporting affidavits or supplemental sworn testimony, I, the Issuing Officer, havedetermined that probable cause exists to support, subject to bail or conditions of release where applicable, Defendants arrestor other lawful steps be taken to obtain Defendants appearance in court, or Defendants detention, if already in custody,pendingfurtherproceedings.Defendantisthereforechargedwiththeabovestatedoffense(s).

SUMMONS

THEREFORE YOU, THE DEFENDANT, ARE SUMMONED to appear on ________ ___, _____ at _____ AM/PM before the above-named court at 14949 62nd Street N PO Box 3802, Stillwater, MN 55082-3802 to answer this complaint.

IFYOUFAILTOAPPEARinresponsetothisSUMMONS,aWARRANTFORYOURARRESTshallbeissued.

WARRANTXTo the Sheriff of the abovenamed county or other person authorized to execute this warrant: I order, in the name of the Stateof Minnesota, that the Defendant be apprehended and arrested without delay and brought promptly before the court (if insession), and if not, before a Judge or Judicial Officer of such court without unnecessary delay, and in any event not later than36hoursafterthearrestorassoonassuchJudgeorJudicialOfficerisavailabletobedealtwithaccordingtolaw.

ExecuteinMNOnlyX ExecuteNationwide ExecuteinBorderStates

ORDEROFDETENTIONSince the Defendant is already in custody, I order, subject to bail or conditions of release, that the Defendant continue to bedetainedpendingfurtherproceedings.

Bail:$ConditionsofRelease:

ThiscomplaintisissuedbytheundersignedJudgeasofthefollowingdate:May27,2014.

JudicialOfficer RichardIlkkaJudgeofDistrictCourt

ElectronicallySigned:5/27/2014

SworntestimonyhasbeengivenbeforetheJudicialOfficerbythefollowingwitnesses:

COUNTYOFWASHINGTONSTATEOFMINNESOTA

StateofMinnesotaPlaintiff

vs.

AlexanderLeeClaussenDefendant

Clerk'sSignatureorFileStamp:

RETURNOFSERVICEIherebyCertifyandReturnthatIhaveservedacopyofthisWarrant

upontheDefendanthereinnamed.

SignatureofAuthorizedServiceAgent:

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