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PASE, 20/08
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State of Wisconsin Circuit Court Walworth Gounty
STATE OF WISCONSIN CRIMINAL COMPLAINT
Plaintf,
“vs DA Case No: 2044WL001675
Donald L. Mielke ‘Assigned DA/ADA: Valerian A. Powell
279 Mielke Lane ‘Agency Case No.: TDE2014-00805
Wiliams Bay, W15319%
—_zz Court Case No: 140° 315°
Sex/Race: MW
Eye Color: Hazel ATN:
Hair Color: Gray
Height: 6.00 In
‘Weight: 185 tbs
Defendant,
Haley J, Rea of the Walworth County District Attomey’s Office, being first duly sworn, on
information and belief, states that:
Count 4: CAPTURE AN IMAGE OF NUDITY WITHOUT CONSENT
‘The above-named defendant on or about and between June 1, 2013, and August 30, 2013, in the
‘Town of Delavan, Walworth County, Wisconsin, did knowingly make a motion picture which motion
picture depicts nudity, without the knowadge and consent of the person depicted nude under
tircumstances where the person so depicted has a reasonable expectation of privacy, contrary to
sec, 942,09(2\{am)1 Wis. Stats. a Class | 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.
Count 2; CAPTURE AN IMAGE OF NUDITY WITHOUT CONSENT
‘The above-named defendant on or about and between June 1, 2013, and August 30, 2013, in the
‘Town of Delavan, Walworth County, Wisconsin, did knowingly make a motion picture which motion
picture depicts nudity, without the knowledge and consent of the person depicted nude under
‘circumstances where the person so depicted has a reasonable expectation of privacy, contrary to
‘sec, 947.09(2)(am)1 Wis, Stats., a Class | 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 (8) months,
or both. °
PROBABLE CAUSE:
4) Your complainant makes this complaint based upon the following, all of which your complainant
beligves to be reliable. The information in this complaint does not exhaust your complainant's
knowledge of this incident.
2) Complainant has reviewed the reports of the Town of Delavan Police Department, which show
that January 30, 2014, Det. Sgt. Clark went to 285 Mielke Lane, in the Town of Delavan, Walworth
County, Wisconsin, and spoke with Karen Mislke,
8) Karen Mielke said that a few years earlier, she discovered a homemade wooden box on the
doar frame above the door to her bedroom. Karen said that she checked inside the box and found
a video camera inside that was pointing:into the bathroom. Karen said that she checked the video
and saw her daughter KDG, DOB 1/16/1996, who was about 14 at the time, on the recording,
Karen said that KDG was clothed in the video, but Karen was upset. Keren sald that she
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Pace 03/06
[STATE OF WISCONSIN - VS - Donald L. Mielke
confronted her husband Don Mielke, the defendant, who sald he put he camera there besa
they were having marital issues. Karen sald she had the defendant destroy ‘the tape and they went
to counseling.
44) Karen Mieke further reported that January 28, 2014, she found a Min OV video cassette that
7 tla bo used in the video camera, on the top shelf ofthe defendants closet, Faren ‘said that
Toul Oe fhe video and found It contained several ferent shower scenes of KDG, wth Koa
ane aren raported thatthe video alco contained a video of the defendant giving KOG oe
“jnappropriate massage" with KDG only wearing @ towel. Karen reported that after the massage,
the defendant had KDG perform lunges only covered by 8 towel
5) Clark reports that he spoke to KDG who stated that she first noticed the camer & couple of
years ago when she was around 18 years old and she would see the camera while she was
aarecng "a lotoF timos.”_KDG stated she did not know ifthe camers was reodraing but
srosumed that twas. KDG elso stated that she never gave enyono permissin ie video record her
Poeing a shower or any other fime when she was naked or partially naked. KCC stated that when
reir «Feud out about the cemora she tied not to tink about tor who put here ane pushit
See ee ud, KDG. said that the defendant always tied to give.het a massage and hat when
She Stee younger she was ok wth it but when she got older she thought twas 2 file weird. KDG
ae Nac he defendant would glve her massages when she got out of the shower and one He
searing a towel. KDG sald that she did riot want the massages but the defendant would make her
Heer tout not allowing him fo do and would be so persistent that she would finaly io hi.
HOG cals that the defendant would massage her legs, arms and back, and would by fo Pale the
Ho aan tor KDG sald that she caught tho defendant trying to take petures of her wih his cell
hone during one of the massages. She stated that this was the very last time she let the
Gefendant do this because she was “freaked out” by this.
6) Clark reports that he viewed the contents of the video and saw the defend putting the
oo eaaa ip and than saw videos of KDG getting undressed and geting naked into the Short.
caret her reports that he also viewed a video of the defendant massaging KDG with loon.
rubbing her calves and thighs while he is stradaing her. Clark reports that he, viewed a video of
te ietondant teaching KDG how to do lunges while she isin towel. The video shows KDG's
putt not covered by the towel while she is doing lunges:
7 Clerk reports that he spoke tothe defendant who admitted that ne took video oF KDG getting in
eee he shower about 8 Umes and that it stated about 4 years ago when KDG Was The
ao omitted that he bull a box to house the camera and also bult@ ramp forthe carera 0
coterie correct angle. The defendant said that al the videos on the camera Ciark hae wore
ethan denng the summer of 2013, The defendant said that he chose fo ove KDG the sero ay
Hee ewes his wife. ‘The dofondart admitted to receving pleasure from watching the videos of
Hoe The defendant was asked how ho thought videotaping KDG naked without het permission
would not have a negative effect on her, and he responded thet he h itwould naver be
found out.
‘Subscribed and swom to before me,
and approved for filing on:
ae day of July, 2014,
State Bar No. for Assigned DA/ADA: 1059003,
o7nsi2o14 211/10/2814 8:25 2627284743 TDPD PASE 24/06
State of Wisconsin Circuit Court Walworth County; | 9
STATE OF WISCONSIN CRIMINAL COMPLAINT e y
; dct
Plaintiff,
ove DA Gase No.: 2014WL000485
Assigned DA/ADA: Joshua P Grube
Donald L. Mielke Agency Case No.: CDE2014-00305
DOB:
Court Case No. 2014 0F LAL
270 Mielke Lane
Wiliams Bay, WI53194
Sex/Race: MW
Eye Color: Hazel
Hair Color: Gray
Height: 6 ft 00 in
Weight: 185 Ibs
Defendant,
Raymond Clark of the Town of Delavan Police Department, being first duly swom, on
information and belief, states that:
Count 1: SEXUAL EXPLOITATION OF A CHILD - FILMING
The above-named defendant on or about and between June 1, 2043 and August 30, 2013,
In the Town of Delavan, Walworth County, Wisconsin, with knowledge of the character and
content of the sexually explicit conduct involving the child, recorded a child engaged in
sexually explicit conduct, contrary to sec, 948.05(1)(b) and (2p)(a) Wis. Stats., a Class C
Felony, and upon conviction may be fined not more than One Hundred Thousand Dollars
($100,000), or imprisoned not more than forty (40) years, or both.
And furthermore, invoking the provisions of Wisconsin Statute 973.042(2), upon conviction
for a crime under 948.05 or 948.12 and the defendant Is at least 18 years of age at the
time of the commission of the crime, the Court shall impose @ surcharge of $500.00 for
each image or each copy of an image, as defined in 973.042(1), associated with the crime.
The court shall determine the number of images or copies of images associated with the
crime by a preponderance of the evidence and without a jury.
‘And furthermore, invoking the provisions of Wisconsin Statute Section @39.617(1), upon
conviction the Court shall impose a bifurcsted sentence including a term of initial
confinement for at least five years,
PROBABLE CAUSE:
1) Your complainant makes this complaint based upon the following, all of which your
complainant believes to be reliable. The information in this complaint does not exhaust
your complainant's knowledge of this incident.
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STATE OF WISCONSIN - VS- Donald L. Mielke
2) Complainant has reviewed the reports of the Town of Delavan Police Department,
which show that January 30, 2014, Det. Sgt. Clark went to 285 Mielke Lane, in the Town
of Delavan, Walworth County, Wisconsin, and spoke with Karen Mielke.
3) Karen Mielke said that a few years earlier, she discovered a homemade wooden box
‘on the door frame above the door to her bedroom. Karen said that she checked inside the
box and found a video camera inside that was pointing into the bathroom. Karen said that
she checked the video and saw her daughter KDG, DOB 1/16/1996, who was about 14 at
the time, on the recording. Karen said that KDG was clothed in the video, but Karen was
upset. ‘Karen said that she confronted her husband Don Mielke, the defendant, who said
he put the camera there because they were having marital issues. Karen said she had the
defendant destroy the tape and they went to counseling.
4) Karen Mieike further reported that January 28, 2014, she found a Mini DV video
cassette that would be used in their video camera, on the top sheff of the defendant's
closet. Karen said that she viewed the video and found it contained several different
shower scenes of KDG, with KDG naked. Karen reported that the video also contained a
video of the defendant giving KDG an “inappropriate massage’ with KDG only wearing a
towel. Karen reported that after the massage, the defendant had KDG perform lunges only
coverad by a towel.
5) Clark reports that he spoke to KDG who stated that she first noticed the camera a
couple of years ago when she was around 15 years old and she would see the camera
while she was showering "a lot of times.” KDG sald that the defendant always tried to
give her a massage and that when she was younger she was ok with it but when she gat
older she thought il was a little waird. KDG said that the defendant would give her
massages when she got out of the shower and she was wearing a towel. KDG said that
she did not want the massages but the defendant would make her feel bad about not
allowing him to do it and would be so persistent that she would finally jet him. KDG said
that the defendant would massage her legs, arms and back, and would try to move the
towel to see her. KDG said that she caught the defendant trying to take pictures of her
with his cell phone during one of the massages.
6) Clark reports that he viewed the contents of the video and saw the defendant putting
the camera up and then saw videos of KDG getting undressed and getting naked into the,
shower. Clark further reports that he also viewed a video of the defendant massaging
KDG with lotion, rubbing her calves and thighs while he is straddling her. Clark reports
that he viewed a video of the defendant teaching KDG how to do lunges while she is ina
towel, The video shows KDG's butt not covered by the towel while she is doing lunges.
7) Clark reports that he spoke to the defendant who admitted that he took video of KDG
getting in and out of the shower about 8 times and thet it started about 4 years ago when
KDG was 14. The defendant admitted that he built a box to house the camera and also
built a ramp for the camera to sit at the correct angle. The defendant said that all the
videos on the camera Clark had were taken during the summer of 2013. The defendant
said that he chase to love KDG the same way that he loves his wife. The defendant
admitted to receiving pleasure from watching the videos of KDG.
o3as/2014 2Pace 05/26
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STATS OF WISCONSIN-V5~ Donald L. Mists
‘Subscitbed and sworn to before ma,
and approved for filing on:
iplahart
This 2c day of March, 2014,
C—O
for Assigned DAIADA: 1036996
cansno1s 3