Case 2021CF000885 Document 2 Filed 06-04-2021 Page 1 of 13

FILED
06-04-2021
Clerk of Circuit Court
Waukesha County
2021CF000885
STATE OF WISCONSIN CIRCUIT COURT WAUKESHA COUNTY
DA Case No.: 2019WK000743
STATE OF WISCONSIN Assigned DA/ADA: Ted S. Szczupakiewicz
Plaintiff, Agency Case No.: W18072134
Court Case No.:
vs. ATN:

Jessy R Kurczewski
10562 W Cortez Circle #26 CRIMINAL COMPLAINT
Franklin, WI 53132
DOB: 02/18/1984
Sex/Race: F/W
Eye Color: Hazel
Hair Color: Brown
Height: 5 ft 2 in
Weight: 110 lbs
Alias:

Defendant.

The undersigned, of the Waukesha County Sheriff's Department being first duly sworn on oath,
upon information and belief, states that:

Count 1: FIRST DEGREE INTENTIONAL HOMICIDE

The above-named defendant on or about Wednesday, October 3, 2018, at N16 W26543
Meadow Grass Circle, in the City of Pewaukee, Waukesha County, Wisconsin, did cause the
death of Victim A, with intent to kill that person, contrary to sec. 940.01(1)(a), 939.50(3)(a) Wis.
Stats., a Class A Felony, and upon conviction shall be sentenced to imprisonment for life.

Count 2: THEFT - MOVABLE PROPERTY ( > $10,000)

The above-named defendant between approximately January 1, 2016 and October 3, 2018, at
N16 W26543 Meadowgrass Circle #A, in the City of Pewaukee, Waukesha County, Wisconsin,
did intentionally transfer movable property of Victim A, to wit: money, having a value greater
than $10,000, without consent, and with intent to permanently deprive the owner of possession
of the property, contrary to sec. 943.20(1)(a) and (3)(c), 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 3: THEFT - MOVABLE PROPERTY ( > $10,000 - $100,000)

The above-named defendant between approximately October 4, 2018 and July 9, 2019, at N16
W26543 Meadowgrass Circle #A, in the City of Pewaukee, Waukesha County, Wisconsin, did
intentionally transfer movable property of the estate of Victim A, to wit: money, having a value
greater than $10,000 but does not exceed $100,000, without consent, and with intent to
permanently deprive the owner of possession of the property, contrary to sec. 943.20(1)(a) and
(3)(c), 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.

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STATE OF WISCONSIN - VS - Jessy R Kurczewski

PROBABLE CAUSE:
And prays that the defendant be dealt with according to law; that the basis for complainant’s
charge of such offense is: Your complainant bases this complaint upon his review of the
investigative reports of various personnel of the Waukesha County Sheriff’s Department, all of
whom are believed to be truthful and reliable in this instance.

The reports of Deputy Miksch indicate that on Wednesday, October 3, 2018, he was
dispatched to N16 W26543 Meadow Grass Circle at approximately 4:55 pm when a caller,
Jessy Kurczewski, the above named defendant, indicated the resident of that address, her
friend, Victim A, was not conscious and not breathing. Upon arrival, Deputy Miksch noticed a
pale unconscious female subject later identified as Victim A lying in a recliner in the living
room. Deputy Miksch indicated he noticed a large amount of crushed medication on her chest
and a plate directly to the left of her with a large amount of what appeared to be crushed up
medication still on the plate. Deputy Miksch further noted a large number of prescription
medication bottles on the table on either side of her. Pewaukee Fire personnel also responded
and confirmed Victim A to be deceased. Based on the initial observations investigators
believed this could have been a drug overdose.

The reports of Deputy Miksch further indicate speaking to a neighbor of Victim A identified as
Witness A who advised that she had visited Victim A in the hospital on the preceding Saturday
or Sunday. Witness A stated after visiting Victim A in the hospital, Victim A was released from
the hospital the next day. Once Victim A was at home, Witness A advised she received a
phone call from Victim A, stating Victim A had fallen inside of her home and could not get up.
Witness A indicated she and Kurczewski responded to Victim A’s address and assisted Victim
A off the floor. Witness A indicated she did not believe Victim A was suicidal and had never
been given the impression that Victim A was suicidal.

The reports of Deputy Miksch further indicate additional investigation that day revealed that
Kurczewski had keys for the residence due to providing recent care for Victim A. Kurczewski
further advised that she was the only one who provided care for Victim A and Kurczewski was
unaware of any family of Victim A.

The reports of Deputy Jacobi indicate obtaining a statement from Kurczewski on October 3,
2018 in which Kurczewski indicated she checks in on Victim A two to three times daily to take
care of her. Kurczewski stated Victim A was released from the hospital on Friday, September
28, 2018. According to Kurczewski, at that time, the hospital wanted Victim A to stay as an
inpatient for rehabilitation but Victim A refused. Further, according to Kurczewski, Victim A was
supposed to have home health care visit her on October 1, 2018 but Victim A pushed back the
appointment until Friday October 5, 2018. Kurczewski also advised that she believed Victim
A’s behavior throughout the week was odd including throwing out bills and stating that the
hospital won’t get her money. Kurczewski stated Victim A’s pills were off when Kurczewski
checked them which included having either too many pills or not enough pills. According to
Kurczewski, Victim A kept assuring Kurczewski where Victim A’s important papers were and
was repeatedly telling Kurczewski what she wanted done with her cats informing Kurczewski
that she did not want to go into a nursing home. Kurczewski stated that Victim A was
constantly worrying if she would end up having to leave her home for medical reasons.
Kurczewski indicated she believed there was a possibility that Victim A was suicidal but also
stated she believed Victim A really loved her cats, often worried about them and wouldn’t want

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STATE OF WISCONSIN - VS - Jessy R Kurczewski

to leave them behind. Kurczewski again reiterated that Victim A had no family and didn’t really
have any contact with anyone besides Kurczewski. Kurczewski indicated she was a family
friend of Victim A and also the power of attorney for Victim A.

The reports of Deputy Estes indicate that on December 19, 2018 she met with Witness C, who
stated Victim A was a good friend of his. He stated that he did not believe her death was a
drug overdose but believed that Jennifer Flower, the mother of Kurczewski, and Jessy
Kurczewski were involved in the death. Witness C stated he has known Victim A for a long
time and does not believe Victim A would intentionally or unintentionally overdose. He believed
Flower and Kurczewski were somehow involved based on the fact that they entered Victim A’s
life, lived in her home, used her things and then, after her death, they were selling her property
and using her Jeep which Witness C believed was supposed to go to Victim A’s nephew.

The reports of Detective Kohl indicate that on January 24, 2019 he met with Witness B.
Witness B stated he contacted the Waukesha County Medical Examiner’s Office inquiring
about the death of his cousin, Victim A. Witness B indicated he had concerns about the
circumstances of Victim A’s death. Witness B stated that Victim A was his cousin and that
Victim A was somewhat close with Witness B’s mother, who is deceased. Witness B found it
suspicious that Victim A would leave her entire estate to Jessy Kurczewski. Witness B stated
he did a CCAP check of Kurczewski and noticed she had several convictions for forgery and
fraud. Witness B wanted to make sure that the will filed in probate was authentic and wanted to
make sure there was nothing suspicious about the death of Victim A in the medical examiner’s
autopsy report.

The reports of Detective Kohl further indicate that in January, 2019, he was contacted by
Waukesha County Medical Examiner Dr. Linda Biedrzycki who advised that toxicology results
from the autopsy of Victim A showed that Victim A had a fatal dose of Tetrahydrozoline in her
system. Detective Kohl noted Tetrahydrozoline is the main ingredient in eye drops. Dr.
Biedrzycki advised that there should not be any Tetrahydrozoline in someone’s blood but that
Victim A had 160ng per milliliter of Tetrahydrozoline in her blood. Dr. Biedrzycki did advise that
Tetrahydrozoline could be considered poisonous to the human body and it would be
impossible to have that level of Tetrahydrozoline in the blood just by using it in the eyes. The
reports of Detective Kohl indicate that after that meeting the investigation was reopened and
continued.

Your complainant further notes that in an autopsy protocol completed by Dr. Biedrzycki and in
an attached letter dated September 27, 2019, Dr. Biedrzycki listed the cause of Victim A’s
death as Tetrahydrozoline poisoning and concluded that the manner of Victim A’s death was a
homicide, not a suicide or an accident.

Your complainant is further aware that on March 9, 2019, Detectives Kohl and Hoppe met with
Kurczewski and her mother, Jennifer Flower, at the Waukesha County Sheriff’s Department.
Kurczewski indicated she had been calling the Medical Examiner’s office multiple times asking
about the toxicology results for Victim A, and showed a great deal of interest and curiosity in
those toxicology results. Kurczewski described many medical ailments that Victim A had prior
to her death and told the detectives how frustrating it was that doctors could never diagnose or
assist Victim A with her ailments. Kurczewski questioned whether Victim A died of medical

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STATE OF WISCONSIN - VS - Jessy R Kurczewski

reasons or whether the death was a suicide. The toxicology results were not shared with
Kurczewski at that time.

Kurczewski said she became Victim A’s caregiver because Flower was busy, and stated she
had been at the residence every other day for the last six months of Victim A’s life, but in the
two weeks prior to death Kurczewski would be at the residence twice a day assisting Victim A.
Kurczewski claims that hospital staff and doctors were so concerned about Victim A that they
placed cameras in her hospital room. Kurczewski talked about Victim A not taking her
medications appropriately when she was in the hospital and not getting her Xanax. Victim A
made Kurczewski go to the residence to bring the Xanax back to the hospital even though
Victim A wasn’t supposed to have it there. Kurczewski stated that toward the end of her life,
Victim A stopped allowing anyone else in her life to see her, that she was embarrassed and
wouldn’t even want friends to visit or know when Victim A was hospitalized. Kurczewski spoke
about how Victim A turned into a different person toward the end of her life based on these
medical ailments and wouldn’t let others see her anymore. During the discussion, Flower
offered that she believed the death was a suicide, at which point Kurczewski indicated Victim A
was sick of being sick and having no answers.

The reports of Detective Toole indicate on July 9, 2019 he spoke to Witness D who advised
that he and his girlfriend, Jessy Kurczewski had lived together for approximately a year and
one half. Witness D stated that Kurczewski would see Victim A approximately one to two
times a month, going over there and smoking cigarettes. He further stated Kurczewski and
Victim A would talk everyday on the phone. Kurczewski would help with Victim A’s shopping
and, according to Witness D, when Victim A got sick, Kurczewski would pay her bills. Witness
D indicated he was advised by Kurczewski that Victim A had become very sick and was in a
coma for approximately five months at Froedtert Hospital before she passed away. He
indicated he had never met Victim A and never saw any mail or applications for credit cards at
his house but believed that Kurczewski was in control of a post office box in Hales Corners
where Kurczewski would pick up Victim A’s mail. Witness D again stated Kurczewski spent
more time with Victim A near the end of Victim A’s life while Victim A was in a coma and stated
that Kurczewski then visited Victim A quite often, approximately two to three times a week.
This Investigation revealed that Victim A was never in a coma or hospitalized for a five month
period of time at Froedtert prior to her death, directly contrary to what Kurczewksi told Witness
D.

The reports of Detective Toole further indicate that Witness D stated that Kurczewski had
power of attorney for health care over Victim A and was the executor of Victim A’s will.
Witness D stated Kurczewski earned approximately $20.00 an hour or less at her job at a
dental office yet Witness D stated that in their free time, they went to Potawatomi Casino
probably two times a month on average and spent roughly $500 a night per person. Witness D
stated that it was hit or miss as far as their winnings but indicated approximately a year and
one half ago he won $70,000. Witness D stated that Kurczewski actually claimed the $70,000
and put it on her taxes. He indicated later that they were both sitting at the machine and split
the money. He said $20,000 was put into a savings account for Kurczewski for taxes and he
got $20,000. He stated he paid off a $16,000 credit card debt with the money.

An additional interview was conducted with Witness D on July 16, 2019 during which Witness
D indicated that Kurczewski had actually provided Witness D with information leading him to

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STATE OF WISCONSIN - VS - Jessy R Kurczewski

believe that Victim A had been hospitalized and in a coma for approximately 4 to 5 months
prior to her death. Until Kurczewski shared information that Victim A was in a coma, she had
not mentioned much about Victim A’s health. On October 3, 2018, Witness D stated
Kurczewski sent him a text message later in the morning about Victim A dying and stated that
she was going to the hospital. He indicated he remembered that he was at work at the time.
That was not consistent with when Kurczewski actually called 911. When Witness D saw
Kurczewski that evening she appeared to be somewhat distraught and crying. However, due to
Victim A having been hospitalized and in a coma for months, it was somewhat expected that
Victim A would pass away at some point. Witness D believed that Victim A’s cause of death
was related to the coma she was in for approximately 4 to 5 months prior to her passing.

Witness D also provided information related to Kurczewski having claimed that she,
Kurczewski, had been poisoned with Visine. He stated he looked back and the exact
date of the incident was Saturday, January 12th, 2019. Witness D stated that Kurczewski had
gone out with a few friends to see a Rebel Grace concert at Pistol Pete's. Witness D recalls
being irritated because when she came home that night she was a little loud while making
herself some food. He believes it may have been around 1 am, and he was trying to sleep.
Witness D stated he asked Kurczewski to keep it down. He thought she may have been a little
"buzzed up" because of all the noise she was making. At some point she told him she did not
feel well. He did not recall her throwing up or anything like that, but she was up for some time.
She got in her car and said she drove herself to the hospital around 6 am. She drove herself
home at approximately 9am. Kurczewski told Witness D that she went to the doctor and that
they tested her and she said they told her that she had been drugged with Visine. She further
stated to him that the police had been notified. Kurczewski stated that the doctor was required
to notify the police due to believing she had been drugged. When Witness D contacted friends
she had been out with, he was inquiring if anyone had been switching drinks. No one indicated
seeing anything suspicious or switching drinks. He said in the back of his mind he could not
see any of his friends doing such a thing. Kurczewski did not talk about any follow up with the
police and, after that day, the issue was done and never talked about again.

Upon Witness D learning that Victim A was never hospitalized long term in a coma, he was in
shock.

Witness D further stated he was once told by Kurczewski that Victim A had a do not
resuscitate request in her will and that according to Kurczewski, approximately four to six
weeks before Victim A’s death, the hospital resuscitated Victim A against her wishes.
Kurczewski stated to Witness D that Kurczewski contacted an attorney regarding the issue and
the attorney was taking care of it. Witness D then indicated that Kurczewski had a lot of
elaborate stories. Witness D stated that because he believed Victim A was hospitalized in a
coma and believed that all of the things Kurczewski had said about it were true, he actually
commended Kurczewski for taking care of Victim A and told Kurczewski that Victim A was
lucky to have Kurczewski and all that Kurczewski did for her.

Witness D’s ex-wife, Witness E, thought that Kurczewski’s gift giving was a little weird.
She stated that Kurczewski would give her gifts of $100.00 spa gift certificates. She felt it was
odd behavior and believed that Kurczewski had to be charging all of these expensive gifts. She
believed that Kurczewski was a habitual spender and must have had large amounts of credit
card debt. Witness E made reference to Christmas gifts provided to her children such as

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STATE OF WISCONSIN - VS - Jessy R Kurczewski

laptops and Gameboys. She was not sure where the money was coming from to purchase
such large gifts. Witness E questioned if the elaborate gifts were all coming from Victim A's
accounts. She felt that this would make the most sense to her stating that Witness D makes
normal money, and Kurczewski wouldn't be working. She felt as though Kurczewski was
excessively using credit cards for the purchases.

Witness D’s and Witness E’s daughter, Witness F, also felt as though Kurczewski’s gift giving
was excessive. She stated that because she was older, she would ask Kurczewski where
these gifts were coming from. Witness F provided an example of Kurczewski’s ability to spend
money out of her range when Witness F was studying abroad. While she was studying in
Thailand, Kurczewski had offered to purchase plane tickets for Witness E to go to Thailand to
be with Witness F. Witness F stated that they were not used to gifts of such nature.

Witness F also stated that Kurczewski made mention of a hospital malpractice issue. She
asked if Kurczewski was going to sue the hospital to which Kurczewski stated that they settled
out of court by clearing all of Victim A’s hospital fees.

Witness E also provided information regarding what Kurczewski had shared with her.
Witness E stated they would see each other at the children's sporting events, and
Kurczewski told them that Victim A was in a coma. According to Witness E, it appeared that
Kurczewski was telling multiple people different variations of the story. Kurczewski also told
Witness E that the hospital was going to clear out all of Victim A's hospital fees and
there would be no charge for her care and treatment.

On July 9, 2019 a search warrant was conducted at Witness D and Kurczewski’s residence.
Kurczewski was arrested and placed on a probation and parole hold after the warrant
execution. Kurczewski was transported to the Waukesha County Jail due to the probation and
parole hold. Between July 9, 2019 and July 19, 2019, detectives spoke with Kurczewski six
times, some at her request. Each interview took place at the Waukesha County Sheriff’s
Department, and Kurczewski was Mirandized each time. Each time Kurczewski waived her
Miranda rights and indicated she wished to talk with Detective Hoppe and whatever other
detective was present for the interview that day.

On July 9, 2019, Kurczewski again offered frustration that there were not any answers yet
about how Victim A died, whether it was a medical event or a suicide. Kurczewski talked about
the illegal and legal controlled substances that she claimed Victim A would use and abuse
throughout her life. Kurczewski indicated that Victim A was able to function on her own, handle
most of her own finances, and had good days and bad days but Kurczewski would assist her.

Kurczewski said there was no official payment arrangement with Victim A for her caregiving,
but stated Victim A would give her checks or a credit card to use or cover Kurczewski and
Flower’s rent or car payments. Kurczewski stated Victim A was always helping ‘everyone’
financially and giving money to everyone. Kurczewski said that Victim A firmly believed she
wanted to spend all of her own money, because one day she would die, and then that would
be it.

Detectives shared with Kurczewski the anomaly in the toxicology results with the
Tetrahydrozoline, at which point Kurczewski begins explaining how frequently Victim A used

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STATE OF WISCONSIN - VS - Jessy R Kurczewski

eye drops, saying she was “known” for eye drops and that she purchased them in great
volume and there would be bottles and boxes from eye drops all over the residence.
Kurczewski stated Victim A would buy 6 bottles at a time, any time she was at a store, and
would make Kurczewski buy her bottles all the time as well, even bringing them into the
hospital. Kurczewski said she never saw Victim A squeeze any drops into her mouth.

Kurczewski talked about how Victim A would drink alcohol to excess, as she was abusing her
medications, and become very impaired at times. Kurczewski then discussed that three times
Victim A told her “.. don’t want to do this anymore” and suggested Victim A asked Kurczewski
for “help” and Kurczewski would tell her no. Kurczewski said Victim A was “sick of being sick”
and gave up. Kurczewski then said Victim A wouldn’t eat and her body was shutting down.

Kurczewski denied ever crushing up any pills for Victim A before she left Victim A’s residence
on October 3, 2018, but claimed that Victim A had such a hard time swallowing that sometimes
the medications did need to be crushed up. Kurczewski stated they even argued about Victim
A abusing her medications. Detectives then tell Kurczewski that the medications listed in
Victim A’s toxicology results were all within the therapeutic ranges but that it was the
Tetrahydrozoline that actually killed Victim A. Kurczewski stated “this is what [Victim A]
wanted.”

Kurczewski then proceeded to tell detectives that Victim A had looked at methods of suicide
before, long ago and stated that Victim A must have known what she was doing, and wanted
to go out her own way. Kurczewski repeated that Victim A always did things her own way and
no one was ever able to change her behaviors or mind about things.

Detectives then tell Kurczewski that the medical examiner thinks that someone poisoned
Victim A because there were no eye drop bottles near Victim A, and Kurczewski tells
detectives how there were eye drop bottles all over the house. Detectives then indicate that the
levels were not consistent with eye drop use in the eyes, but consumption. Kurczewski says
she had never seen Victim A drink eye drops and questions who would do that and comments
on how odd it was that the other toxicology results for Victim A’s medications were normal. The
detectives tell Kurczewski that the medical examiner thinks the pills and scene near Victim A
was staged, and Kurczewski says that she was the only one there, and that she didn’t stage
anything.

Kurczewski adamantly denied killing Victim A, and adamantly denied assisting Victim A in her
death. Kurczewski says she didn’t give Victim A any eye drops. Kurczewski did not recall
calling her mother and talking for four minutes prior to calling 911 the day Victim A was found,
after being asked by Detective Hoppe. Kurczewski offered that Victim A must have staged her
own suicide with the crushed pills because Kurczewski maintained that she did not.
Kurczewski also says she had never heard of “Visine poisoning” before.

During the interview on July 10, 2019, Kurczewski again denies ever hearing of someone
dying from Visine poisoning and denies ever putting eye drops into anything for Victim A to
drink. Kurczewski again denies either intentionally killing Victim A, or assisting her suicide.

Detective Hoppe confronts Kurczewski with information obtained from Witness D who stated at
one time Kurczewski went to the hospital after a night out drinking, and Kurczewski told

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Witness D that the hospital doctor told Kurczewski she had been poisoned with Visine.
Kurczewski denies that and says Witness D got that wrong, that someone else she had been
with had actually been poisoned with Visine that night.

Kurczewski states she isn’t “buying” what the medical examiner is saying.

Kurczewski then says that she actually had seen Victim A drink Visine with vodka before her
death and tells Detective Hoppe that the day before Victim A died she was drinking vodka and
Visine. Kurczewski had no rational explanation for not disclosing this information to detectives
during either of the prior two interviews.

Kurczewski then says that once Victim A started having so much Visine at the house she
researched it. Kurczewski said Victim A “tried pills twice” but it didn’t work. Kurczewski then
says that Victim A had Visine dumped into a bottle of vodka for days prior to her death.
Kurczewski claimed Victim A had become very ill twice before her death from drinking Visine
and she was “shitting all over.”

Kurczewski then says Victim A had been trying to kill herself by drinking Visine in vodka.
Kurczewski said Victim A would try different doses in water bottles or vodka and she would get
very sick. Kurczewski denied ever mixing any Visine in any water bottle or vodka for Victim A,
but said she continued to purchase the Visine for Victim A even though she didn’t agree with it.
Despite this, Kurczewski said she would regularly throw bottles of water away because she
suspected they had Visine in them.

Kurczewski then said Victim A had used her phone to search for suicide methods and looked
into buying a pill online, the “hood” method, and even purchased a gun on the internet which
Kurczewski said she disposed of. Kurczewski said she had “saved” Victim A from herself
numerous times including walking in on Victim A twice with a gun in her hand. Kurczewski
indicated she does not agree with suicide.

Detective Hoppe then revisits the information from Witness D about Kurczewski’s poisoning
with Visine one night. Kurczewski ultimately says that she voluntarily drank some Visine that
night to “see what it was like” and indicated she was so mad at Victim A for taking the easy
way out. Kurczewski said that this made her ill.

Kurczewski maintained that the last time she knew Victim A had Visine in vodka was the night
prior to her death, not on October 3, 2018.

During the interview on July 11 2019, Kurczewski continued to state she never gave any Visine
to Victim A the morning of her death on October 3, 2018. An hour later, Kurczewski says that
the water bottle in the photograph from the scene of Victim A’s death had six bottles of Visine
in it. Kurczewski said Victim A told her it had six bottles of Visine in it, and when Victim A told
Kurczewski that she wanted that bottle, Kurczewski brought it to her, knowing that it had Visine
in it. Kurczewski said she didn’t think it would kill Victim A because it hadn’t killed her yet and
Victim A had been drinking it regularly for so long. Kurczewski said her and Victim A fought
about it for an hour prior to Kurczewski leaving the residence that morning and she finally gave
in and gave the water bottle with 6 Visine bottles in it to Victim A. Kurczewski said it was “her
choice.” Kurczewski states she knows she’s probably going to prison for the rest of her life for

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STATE OF WISCONSIN - VS - Jessy R Kurczewski

helping Victim A do what she wanted, and then Kurczewski said she finally told the detectives
everything.

In the interview on July 12, 2019, Kurczewski tells detectives that she has items in a storage
unit under someone else’s name like recordings of Victim A’s wishes, a partial firearm, dated
Visine bottles, and papers that Victim A signed somewhere but she won’t release the items
until she’s ready. Kurczewski tells the detectives to have her probation agent lift the hold for
one to two weeks so she can get things in order and assures them she will not run and hide
and would wear an electronic monitor. Detective Hoppe comments how it seems mind
boggling that Kurczewski has information that would assist her but she is withholding it.
Kurczewski says she kept this hoard of items for her own benefit, in case anything happened.

Ultimately Kurczewski says the items are not in a storage shed, they are buried several feet
underground at Whitnall Park in freezer bags.

Your complainant is aware that officers used a map that Kurczewski assisted in creating to
attempt to locate the burial site and the above mentioned items but these efforts were fruitless
and none of these items were ever located.

In the interview on July 16, 2019, Kurczewski assures detectives she could find the buried
items if they let her go to the park herself. Kurczewski was ultimately allowed to watch
detectives at Whitnall Park via video call so she could direct them to where she allegedly
buried her hoard of evidence. This was, again, fruitless. Sometime after Kurczewski sees
detectives using a metal detector to locate the buried firearm pieces, she tells them that the
gun might have actually been made of plastic pieces and that none of the metal firing parts are
buried.

Kurczewski also indicates that any financial transactions that were done were with Victim A’s
consent, and stated she was absolutely certain she never wrote herself a check from Victim
A’s accounts and only ever signed Victim A’s name on a check if it was for a bill and Victim A
was sitting right there. Kurczewski claimed that Victim A was someone who wrote more checks
than she’d ever seen before, and gave a lot of people large amounts of money, as much as
$40,000-$50,000 in one instance. Kurczewski also offered that she is right handed and Victim
A was left handed. Kurczewski also offered that her mother, Flower, was left handed.

In the interview on July 19, 2019, Detective Hoppe briefly discusses things with Kurczewski for
the last time, and she maintains that she has things buried that would assist her claim that the
death was a suicide.

Your Complainant further bases this complaint on a review of criminal complaints filed in
Milwaukee county cases, 2010CF4998, 2010CF3513, 2010CF1484 and 2010CF5532, all
entitled State of Wisconsin vs. Jessy R. Kurczewski, DOB: 02/18/1984, the above named
defendant, and the associated investigative reports of the various Milwaukee county police
agencies where those offenses occurred. Said information is relevant other acts evidence as
this evidence is offered as proof of motive, intent, preparation, knowledge and method of
operation.

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STATE OF WISCONSIN - VS - Jessy R Kurczewski

In 2010CF1484, the investigation revealed that between approximately November 30, 2009
and approximately February 1, 2010, a business, Quick Click Loans, had received eight loan
applications submitted in a short period of time from the same computer IP address which
listed to Westside Healthcare clinic in Milwaukee. Two of those applications resulted in credit
having been obtained in the names of two victims totaling $4000.00. Both victims indicated no
one had their permission or consent to use any of their identifying information or to obtain
loans or money in their names. Detective Rosenstein interviewed Kurczewski regarding these
offenses and she admitted that through her employment at Westside Healthcare clinic she took
patients personal identifying information and began to submit applications for online loans
through both Quick Click Loans and CheckCity.com. Kurczewski stated that she thought she
would just use the loans for her rent since she had been out of work before starting to work for
Westside Healthcare. She admitted that she received money from two loans totaling $4000.
Further investigation determined that Kurczewski obtained the information of one of the two
victims through Westside Healthcare but obtained the information of the second victim from
when she worked with that victim at Wheaton Franciscan.

The reports of Detective Rosenstein indicate that on April 26th, 2010, he received a report
from the Forest County Potawatomi Community regarding the usage of a Potawatomi Bingo
Casino Firekeeper’s Club card registered to Jessy Kurczewski revealing that from January 1,
2010 until April 22, 2010, Kurczewski had a total loss of $44,065.00.

In 2010CF3513, on or about July 16, 2010, Kurczewski appeared at a Pay Day Loan store in
West Allis, in violation of an earlier bail prohibiting such contact, attempting to get a car title
loan. Kurczewski presented a loan application form made out in the name of her mother,
Jennifer Flower and had with her a replacement title to her mother’s 2008 Ford, a photocopy of
Flower’s Social Security card and a copy of a check from Flower’s bank account. Kurczewski
represented herself as Jennifer Flower and requested that she receive $2500 in cash and a
check for $6350 for the remaining part of the loan. When officers came to the scene,
Kurczewski told them she was Jennifer Flower. However, the West Allis officers checked with
Detective Todd Rosenstein of MCSD who was familiar with Kurczewski, described her and
knew she was out on bail for a felony. Kurczewski then stated she was there with permission
from her mother to apply for a loan.

Jennifer Flower was interviewed in 2010 as part of the above investigation and was obviously
upset with Kurczewski and stated that Jessy has been ruining the entire family’s lives. Flower
stated she has reached the end of her rope in dealing with Jessy’s antics. She stated she was
missing her Social Security card, identification, a book of personal checks and the title to her
2008 Ford. Jennifer stated that these items had been locked up in a file cabinet and that Jessy
broke into the cabinet to obtain the documents. Jennifer further stated she has been calling
Potawatomi to see if Jessy has been gambling again and she was advised that Jessy remains
on the “ban” and cannot gamble or enter the premises.

Kurczewski was interviewed regarding this incident and indicated she used to have a gambling
addiction and that is why she began obtaining money fraudulently from Pay Day Loan stores.

Further investigation determined that a fraudulent title loan in the name of Jennifer Flower on
her 2008 Ford was successfully obtained from Cottonwood Financial on June 18th, 2010,

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STATE OF WISCONSIN - VS - Jessy R Kurczewski

initially for $6600 but became delinquent and the balance owed was $8,393.00. Said loan was
obtained without the permission or consent of Jennifer Flower.

In 2010CF4998, on or about September 16, 2010, Kurczewski created a fraudulent savings

account in the name of a friend’s mother by stealing that victim’s identifying information while
living with the victim’s daughter. Kurczewski created the fraudulent account by sending the
credit union copies of the victim’s Social Security card and Wisconsin Driver’s License altering
the information on the face of both documents. Kurczewski then purported to be the victim and
tried to have herself, Kurczewski, added to the account. At the time this offense was
committed, Kurczewski was already out on bail in 2010CF1484 and 2010CF3513.

In 2010CF5532, on or about October 18, 2010, Kurczewski attempted to pay an outstanding

hotel bill with a fraudulent cashier’s check. Reports indicated that Kurczewski was living at a
Main Stay Suites in Oak Creek under the name of Jennifer Flower. When officers confronted
her about the check, she lied about who she was and identified herself as Jennifer Flower.
She admitted she lied because she knew she had three warrants for her arrest. In her
possession were four blank checks three of which were duplicates of each other and had the
number 110 in the upper right corner. Kurczewski later stated she had printed the checks
herself and there was no good reason why all three had the same number. She went on to
explain that she used check printing software based off of a CD at a computer located in the
library or other locations to print these checks. Kurczewski explained that this check writing
software was commonplace and easy to obtain. An employee from the bank from which the
fraudulent cashier’s check was purported to have originated indicated that it was not proper for
anyone to print any checks with their logo on. They further stated that the account the check
referred to was opened two weeks earlier and was already overdrawn. It was identified as a
business account of Jessy Kurczewski.

The reports of Detective Kohl indicate speaking to Witness G, an inmate at Taycheedah

Correctional institution. Witness G stated that while she was the roommate of Jessy
Kurczewski, Kurczewski had an emotional breakdown and stated that she gave Victim A
several bottles of Visine to kill her and Kurczewski’s mother wanted Kurczewski to keep quiet
about it and that everyone thinks she did it for money, but she did it to stop Victim A’s
suffering. Witness G stated that Kurczewski said she put the Visine in Victim A’s water bottle
and that she had bought it at different stores. She also stated that Kurczewski used her phone
to look it up online and that she had her friend delete the search from her phone. Witness G
stated that Kurczewski said her mom used some old paperwork to obtain Victim A’s medical
records. Witness G stated that Kurczewski said she gave Victim A the Visine in the morning
and came back later that night. Witness G finally indicated that Kurczewski stated that a
caregiving service was going to start soon and that Kurczewski was not going to take care of
her anymore.

The reports of Detective Loberg indicate that his investigation revealed that when analyzing
responses of financial institutions, it was apparent that Victim A’s financial activities changed
over time as contact with Kurczewski increased. The activity of Victim A’s finances began to
reflect what was revealed to more closely resemble the normal financial activity of Kurczewski
and her financial accounts. In addition, after Victim A’s death, Kurczewski was in control of
Victim A’s estate and, in that capacity, Kurczewski created false documents showing that
payments were made towards some of Victim A’s debts. However, it was determined that

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STATE OF WISCONSIN - VS - Jessy R Kurczewski

receipts showing those payments, were fabricated and the alleged debts that were being paid
with the assets of the estate, were on accounts that never belonged to Victim A and were not
in fact debts of the estate. Approximately $15,933.11 was taken from Victim A’s estate in this
manner when Kurczewski created fraudulent documents to suggest that those monies were
used to pay debts. However, because those debts never existed, those monies are
unaccounted for and believed stolen by Kurczewski.

The reports of Detective O’Toole and an analysis of financial records indicate that Victim A’s
pattern of spending changed drastically over time going from having and using very few credit
cards and making few credit card purchases which were paid off each month, to a pattern of
using many different credit cards and those credit cards being maxed out to the credit limit with
very little payment being made for many months. Detective O’Toole believes said records
establish fraudulent activity on the accounts beginning on most in approximately June, 2018.
One account has such activity beginning as early as 2016. The total fraud believed committed
is approximately $290,210.06. Approximately $130,204.40 was believed to have been
transferred fraudulently by check from Victim A to Kurczewski. The amount was arrived at
based on the different places of credit card activity, the amounts, the frequency of use and
based on the continued activity after Victim A’s death.

This investigation further reveals that at or near the time of Victim A’s death, the total cash
assets available to her in her three accounts had diminished to only approximately $4221.11.
Her incurred debts at or near the time of her death had risen to approximately $72,216.45.

The financial records of Kurczewski also show continued spending at gambling

establishments. Her Landmark Credit account revealed that between August 28, 2018, when
the account was opened, and July 9, 2019, when she was taken into custody, Kurczewski
spent approximately $23,455.86 between the Potawatomi Casino in Milwaukee and the Ho
Chunk casino in Baraboo. One of Kurczewski’s Wells Fargo accounts shows that between
July 19, 2016 and May 7, 2018 the purchases and/or withdrawals at Potawatomi Casino total
approximately $31,095.11. During these periods of time Kurczewski was on extended
supervision through the Department of Corrections and as a condition of that supervision, she
was not allowed to gamble or have contact with casinos.

Given the deteriorating financial circumstances of Victim A caused by Kurczewski, the theft of
monies from Victim A’s estate by Kurczewski, the long term and admitted gambling addiction
of Kurczewski with substantial monetary losses and the demonstrated other acts evidence of
identity theft, forgery and uttering committed by Kurczewski, your complainant believes
Kurczewski had a motive, the method and the opportunity to intentionally cause the death of
Victim A.

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

TSS:rm
EXT=CODE 1

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STATE OF WISCONSIN - VS - Jessy R Kurczewski

Subscribed and sworn to before me on Electronically Signed By:

06/04/21 Captain Aaron I. Bogie
Electronically Signed By: Complainant
Claudia P. Ayala Tabares
Assistant District Attorney
State Bar #: 1117650

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