Case 2023CF001084 Document 2 Filed 06-22-2023 Page 1 of 14

FILED
06-22-2023
Clerk of Circuit Court
Brown County, WI
STATE OF WISCONSIN CIRCUIT COURT BROWN COUNTY
2023CF001084
DA Case No.: 2023BR004226 Honorable John P.
Zakowski
STATE OF WISCONSIN Assigned DDA: Wendy W Lemkuil
Plaintiff, Agency Case No.: 22-044557 Branch 6

vs. Court Case No.: 23CF____

ATN:
SARAH JOANN DAHL
6147 Young Road
Oconto, WI 54153 CRIMINAL COMPLAINT
DOB: 04/11/1993
Sex/Race: F/W
Eye Color: Green
Hair Color: Brown
Height: 5 ft 2 in
Weight: 110 lbs For Official Use
Defendant.

Complainant, an Deputy District Attorney, being first duly sworn on oath, deposes and says
that:

Count 1: FIRST DEGREE RECKLESS HOMICIDE - AS A PARTY TO A CRIME

The above-named defendant on or between December 25, 2022 and December 26, 2022, in
the Town of Morrison, Brown County, Wisconsin, as a party to a crime, did cause the death of
DJT, by the delivery or manufacture of a Schedule I or II controlled substance, Fentanyl, in
violation of sec. 961.41 Wis. Stats., which DJT used, dying as a result of that use, contrary to
sec. 940.02(2)(a), 939.05 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.

Complainant is an Deputy District Attorney with the Brown County District Attorney’s Office and
knows of the above offense(s) on information and belief based upon:

PROBABLE CAUSE:

The complainant, being duly sworn on oath, swears that she has had the opportunity to review
the police reports from the Brown County Sheriff’s Department, and other documents
supporting this complaint referenced herein, which are the types of reports and documents
kept in the ordinary course of business, which complainant believes to be truthful and reliable
because they have proven to be truthful and reliable on numerous occasions in the past.

The complainant further asserts that based upon her review of the referenced reports and/or
supporting documents, the incidents alleged occurred in Brown County, Wisconsin.

1. Your complainant’s review of the report of Sgt. Marc Shield of the Brown County Sheriff’s
Department indicates the following information: On December 26, 2022 at approximately 2:11
am, a complainant called 911 to report his roommate D.J.T. DOB: 12/19/85 was pulseless and
not breathing at his residence located on Morrison Road in the Town of Morrison, Brown

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

County, Wisconsin. Medical personnel and Brown County sheriff's deputies responded to the
scene.

After attempting lifesaving measures, it was determined D.J.T. was deceased. In addition to
the complainant, D.J.T.'s girlfriend Sarah J. Dahl, DOB: 04/11/1993, was also on scene.

At approximately 6:57 am, a search warrant was obtained for the Morrison Road residence. I
acted as evidence custodian during the search warrant.

On D.J.T.'s person, Deputy Von Loh located a gray Apple iPhone (Exhibit #1) and a green
zippered container (Exhibit #2) which contained the following:
-An orange unlabeled prescription pill container (Exhibit #3) which contained a clear plastic
baggie (Exhibit #4) which contained 2.00 grams of a white crystal-like substance which field
tested positive for the presence of both methamphetamine and fentanyl (Exhibit #5). Based on
my training and experience, Exhibit #5 was consistent in appearance with methamphetamine.
-Purple glass pipe with residue consistent with a device used to smoke methamphetamine and
a cut plastic straw with residue designed to scoop controlled substances (Exhibit #6).

Exhibits #1-#6 were removed from D.J.T.'s person and remained inside the residence until
they were collected pursuant to the search warrant.

On Sarah Dahl’s person, Deputy Von Loh located a plastic cigarette wrapper (Exhibit #7)
which contained 1.03 grams of a green plant-like material consistent with marijuana which field
tested positive for THC (Exhibit #8). Deputy Von Loh also located a glass pipe with a bowl of
green plant-like material consistent with a marijuana pipe (Exhibit #9) and a purple glass pipe
with residue consistent with a device used to smoke methamphetamine (Exhibit #10).

Inside of Dahl's 2004 gray Pontiac Vibe parked in the driveway of the residence, Deputy Von
Loh located a functioning digital scale with residue consistent with methamphetamine, two
pipes with residue consistent with devices used to smoke marijuana, and a glass vial with an
unknown white residue (Exhibit #11).

On the wooden floor hallway between the living and dining room where D.J.T. was previously
located, I observed a red stain consistent with blood. I photographed the stain on the floor.
There was also a pair of winter gloves, winter cap, and D.J.T.'s wallet.

In the second floor bathroom on top of the counter, I located a metal spoon with an unknown
residue (Exhibit #12).

In the second floor bedroom on top of the bed, I located a Samsung Galaxy S10E model cell
phone which was identified as belonging to Dahl (Exhibit #13). Said reports indicate that this
bedroom was identified as being used by D.J.T. and Sarah Dahl.

In the second floor bedroom in the northeast corner organizer, I located a Wisconsin Quest
card for "SARAH J DAHL" (Exhibit #14), a black plastic piece with an unknown white powder
residue (Exhibit #15), and a clear plastic baggie, metallic marijuana grinder, plastic vial, glass
jar, and two devices consistent with methamphetamine "bongs" (Exhibit #16).

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

In the second floor bedroom in the northwest corner shelf, Deputy Von Loh located an Apple
iPhone box which contained multiple unused clear plastic baggies consistent with material
used to package controlled substances for distribution (Exhibit #17).

In the second floor bedroom in the northwest corner nightstand top drawer, Deputy Von Loh
located two pipes with residue consistent with methamphetamine pipes (Exhibit #18).

In the second floor bedroom in the northwest corner nightstand bottom drawer, Deputy Von
Loh located the following:
-A hard black zippered case (Exhibit #19) which contained a plastic tied baggie (Exhibit #20)
which contained 50.26 grams of a white crystal-like substance which field tested positive for
both the presence of methamphetamine and fentanyl (Exhibit #21). Based on my training and
experience, Exhibit #21 was consistent in appearance with methamphetamine.
-A container with multiple identifiers for D.J.T. There was also an employment identification
card for "Jared Drexler" at "A.B. PROCESS SYSTEMS (Exhibit #22).
-A functioning digital scale with residue consistent with a device used to weigh controlled
substances (Exhibit #23).
-An orange pipe with residue consistent with a device used to smoke methamphetamine
(Exhibit #24).
-Two plastic cylinders which contained multiple baggies with residue consistent with packaging
material for controlled substances (Exhibit #25).
-Unlabeled orange prescription bottle which contained multiple baggies with residue consistent
with packaging material for controlled substances (Exhibit #26).
-Hard black zippered case which contained multiple glass pipes with residue consistent with
devices used to smoke methamphetamine (Exhibit #27).

After searching the residence, vehicles, and associated outbuildings, Deputy Von Loh and I
attempted to interview Dahl at approximately 8:53 am. I read the Brown County Sheriff's Office
Rights Form to Dahl verbatim. Dahl stated she did not wish to speak with us without an
attorney present.

I took a sample of the suspect material from Exhibit #5 and #21 and tested it using a Marquis
Reagent Test and it tested positive for methamphetamine substance.

I took a sample of the suspect material from Exhibits #5 and #21 and tested it using the
Fentanyl Reagent Test and it tested positive for Acetyl-fentanyl, a Schedule I controlled
substance.

I took a sample of the suspect plant material from Exhibit #8 and tested it using the Duquenois
Levine Reagent Test and it tested positive for marijuana, which contains THC, a controlled
substance.

I, Marc A. Shield, am a sheriff's deputy with the Brown County Sheriff's Office, and have been
so employed since May of 2013. I was assigned to the Brown County Drug Task Force as a
narcotics investigator and K9 Handler from August 2015 to August of 2020. Since August of
2020, I have been assigned to the Investigative Division as a detective sergeant.

I have received specialized training to determine the distribution of controlled substances

versus simple possession. I have been involved in numerous investigations pertaining to the

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

distribution of controlled substances and am familiar with factors which are indicative of
distribution such as drug amounts, packaging material, digital scales, electronics, and large
sums of US currency.

Based on my training and experience, the 50.26 grams of suspected

methamphetamine/fentanyl substance was possessed with intent to deliver due to the
following factors:
-50.26 grams of ounce (approximately 28 grams) of methamphetamine has a wholesale street
value of approximately $700-$1000. The street value of 50.26 grams of methamphetamine is
at least $1,200.
-In close proximity to the 50.26 grams of methamphetamine was packaging material and a
digital scale which are both consistent with distribution. Drug traffickers use packaging material
to distribute controlled substances to other traffickers and/or users and use digital scales to
weigh controlled substances prior to distribution.

2. Your complainant’s review of the report of Deputy Kyle Vonloh of the Brown County Sheriff’s
Department indicates the following information: On December 26, 2022 at approximately
2:10am, I, Deputy K. Von Loh along with Sgt. N. Nerat and Deputy C. Walker were dispatched
to 8239 Morrison Road, Town of Morrison, Brown County, Wisconsin for a medical call.
Dispatch notes indicated that there was a male at this address who was pulseless non-
breathing (PNB). Dispatch notes also indicated that this male had a prior drug history.

Upon arrival, I observed a light on in a rear entryway. I entered the rear of the residence, and I
announced myself and heard a voice indicate that I could come in. I entered that door. This
entered to what appeared to be a kitchen area. Directly off that kitchen area was a transition to
a living room. There was a bathroom and bedroom off that transition area to the right as you
leave the kitchen.

In that transition area, I observed a male I believed to be deceased. I was told while enroute
that there was a first responder on scene who was advising no Cardiopulmonary Resuscitation
(CPR) efforts were being done. I was also advised on scene of the same thing. I was advised
by the first responder verbally identified to me as J.S. that the male had been down for
approximately forty-five minutes and that CPR was not going to be done. During this time, I
asked about occupants. I was advised that there were only three occupants, which were who I
later found to be the homeowner, Sarah J. Dahl (girlfriend of deceased) and the deceased,
D.J.T.

I then conducted a security sweep of the residence. Prior to doing a security sweep, Sarah
briefly explained to me that she thought she heard D.J.T. and his ex-yelling at each other, but
she was not sure if it was the television or not. Sarah explained that prior to finding D.J.T. on
the floor they were in the garage together and came into the house. Sarah explained that she
thought he was right behind her, but D.J.T. had gone to unplug the electricity for the garage
and that she was already upstairs. Sarah goes back and forth on this statement and her level
of certainty decreases. Sarah also later told me that she never actually saw another female to
support the voice she heard.

I brought Sarah to the back door landing area to speak to her. While speaking to Sarah,
County Rescue Staff worked D.J.T but he was pronounced deceased by rescue and hospital
medical staff by telephone at 2:58 am.

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

I felt a large stiff square object in D.J.T.'s right snow pants pocket. I removed that and found
there to be glass pipe with a glass bulb at the end. There was brown/black charring at the
bottom. There was also an orange/red bottle in there, which I later found to contain a white
powder like substance that appeared to be in an oval type of shape. Prior to removing this,
County Rescue, asked if anyone knew whether or not D.J.T. had used that evening (drugs).
We were unaware as we were gathering that information prior but did not get to it due to
beginning to work on D.J.T. I did not remove the powder like substance from the container as I
was not in the appropriate environment and did not want to contaminate myself or others. This
was placed in my squad car.

I then started a crime scene log that was turned over to Sgt. Nerat. I then asked Sarah if she
would be willing to give me a written statement, which she agreed to.

Sarah explained to me that she and D.J.T. had come back from Christmas with Sarah's
parents. Sarah told me that when they arrived back home she went to two of her friend’s
houses. Sarah stated that she came home awhile later and was in the garage with D.J.T.
Sarah told me that they were going inside and prior to that, D.J.T. grabbed some things from
his vehicle. However, Sarah was cold, so she went in. Sarah said that she waited for D.J.T. in
the backside of the house in the entry way. Sarah explained that he came in and she then
went upstairs while D.J.T. was turning off the electricity for the garage. This is when Sarah
stated that she heard what she believed to be a female voice yelling. Sarah said that after
about 20 minutes of it being silent, she went downstairs to check on D.J.T. Sarah said that she
came downstairs and found D.J.T. on the floor.

While taking this statement from Sarah, she indicated that she went to multiple friend’s houses
(two). However, only gave me one name initially which was "CC." I clarified if it was one or two
and she stated that she had also went to her friend Kristie's house as well.

I later attempted to get consent from Sarah to search the room that she and D.J.T. shared
upstairs. However, Sarah would not give consent. Sarah continually defaulted to whatever
DJT’s rommate had indicated about consent, and that whatever he wanted was what she
agreed to. I tried to explain to Sarah that she has an expectation of privacy to that room. Sarah
explained that she felt she could not give consent as it was not necessarily her room.
Ultimately a search warrant was applied for and granted.

I had heard over the radio that the search warrant was granted. I called Sgt. Shield to make
sure that the vehicles were included in that search warrant, which he told me they were. I then
began to search the vehicle that was owned by Sarah.

There were items in every passenger area of Sarah's vehicle. I had searched a bag in Sarah's
vehicle that I found on the passenger side. In that bag I found multiple knives, a set of brass
knuckles, and I also found a meat style cleaver with no handle on it.

I then spoke to Sarah explaining that we had a search warrant to search the house, her
vehicle, and D.J.T.'s vehicle. I explained to Sarah how our relationship was developing and
asked if it would be okay if I patted her down. Sarah indicated that it was. I then patted Sarah
down and while doing so I asked if she had any knives or anything on her.

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

Sarah stated that there was a pipe on her. Prior to her saying this I could smell what I believed
from training and experience to be the odor of fresh marijuana. I asked Sarah if I could get the
pipe and she stated I could. I found a pipe in Sarah's right coat pocket. I saw that the pipe
contained a green, unburned, leafy substance. Based on my training and experience, I
believed this to be marijuana. I then patted down Sarah's left pants pocket and felt something
that appeared to be long, cylindrical, and with something bulky at the end. I asked Sarah if I
could take it out and she said go ahead. I removed the item, and it was a glass pipe which in
my training and experience is a device commonly used to spoke methamphetamine.

In that same pocket with the glass pipe, I found a green leafy substance, that through my
training and experience, I believed to be marijuana. It was packaged in a cellophane wrapper
commonly used for packaging of cigarettes. Once I was done searching Sarah, she stated, “I
know that's not good to have.” I explained to Sarah that I was going to check her breast area
with the back of my hand. Sarah inquired about a female officer for that. I explained to her that
there was not one available. I placed Sarah back into my squad car and went back to
searching her vehicle. I checked on Sarah throughout the time I was away.

While continuing to search the vehicle I found what appeared to be a white box that is typically
used for first aid supplies. This box was found on the floor of the rear driver side area. Inside
that box I found a clear pipe that had brown and black staining. This pipe appeared to be,
through my training and experience, an item typically used to ingest drugs. In that same box I
found a digital scale that had white residue on it. Inside that same white box was a rose gold
box. Inside that rose gold box there was a smaller box that contained another pipe, which
appeared to be, through my training and experience, an item used to ingest drugs. These
items were later turned over to Sgt. Shield who took the role of evidence custodian.

3. Your complainant’s review of the additional report of Sgt. Shield of the Brown County
Sheriff’s Department indicates the following information:

On December 27, 2022, Brown County Circuit Court Judge Hammer signed a search warrant
for a cell phone identified as belonging to Sarah Dahl.

On December 28, 2022, Brown County Sheriff's Office Computer Forensics Analyst Frank
Angel extracted the content of the cell phone and I analyzed it.

The number assigned to the cell phone was 920-246-****. I observed numerous photos on the
camera roll of Sarah Dahl.

Based on my training and experience, when D.J.T. mentioned "mak(ing) a trip to see (his) guy"
he was referring to his source of supply for methamphetamine.

December 16, 2022

920-305-**** "CC" - "Half b? How much?"
DAHL to "CC": "I just woke up hold up let me ask"
DAHL to D.J.T.: "Hey sexy, jw if ur ok with selling a hb? N if so how much would u charge for
so"
D.J.T. to DAHL: "Can you measure what I have there? And who's it for?"
DAHL to D.J.T.: "My girl jenifer and where the calculator at?"
D.J.T. to DAHL: "Should be in bottom drawer somewhere. I think in black case"

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

DAHL to D.J.T.: "U got 11.64 with the bag."
D.J.T. to DAHL: "Is $100 fair price? I really don't know cuz I never buy small amounts."
D.J.T. to DAHL: "By saying hb your talking a shirt right?"
DAHL to D.J.T.: "I think 80 is bout average, ive gotten full shirts for 100 no problrem but the
smaller the shirt gets alil more pricey i think...."
D.J.T. to DAHL: "$80 is fine"
DAHL to "CC" - "Im here. Garage?"
"CC" to DAHL - "Nice. Be out there soon. Switching laundry."

Based on my training and experience, DAHL and D.J.T. worked in concert to deliver 1.75
grams of methamphetamine to "CC" for $80. D.J.T. directed DAHL to weigh the
methamphetamine with a scale ("calculator") and the total weight he had in the bedroom was
11.64 grams with packaging.

December 25, 2022 1:26 pm 920-858-**** "Girl Melissa Ds" - "Can you do $60 only"
DAHL 1:39 pm: "Im out in wayside itll be bout 20 mins b4 im that way"
DAHL 1:46 pm: "Im on the move"
"Girl Melissa Ds" 1:50 pm: "Can you meet me at express convenient center on Velp? By the
roundabout?"
"Girl Melissa Ds" 2:15 pm: "Close?"
DAHL 2:15 pm: "Yeah. Taking Velp exit now"
"Girl Melissa Ds" 2:25 pm: "Are you for real right now?!"
"Girl Melissa Ds" 2:27 pm: "Either I've been getting robbed blind for $60 for taht same amount
or you just hooked me the fuck up like that is ridiculous. I couldn't believe how much was in"
"Girl Melissa Ds" 2:27 pm: "That bag"
DAHL: 2:36 pm: "Its xmas? Lol how much do u normaly get for 60?"
"Girl Melissa Ds" 3:03 pm: "Like a 3rd or what you gave me"

DAHL to 920-227-**** "Mother" - "Be there soon"

Based on my training and experience, DAHL sold $60 worth of methamphetamine to "Girl
Melissa Ds" at Express Convenience Center, 1618 Velp Avenue in the Village of Howard,
Brown County, Wisconsin. Dahl then texted her mother she would "be there soon" for their
family Christmas which was consistent with the statement provided to law enforcement by
Dahl.

Dahl to "Cici" on Facebook messenger at 6:10 pm - "U home? Me n dav are outside my dav of
coursr. I got bag of food for u."

This is consistent with Dahl visiting "CC" or "Cici" after celebrating her family Christmas with
D.J.T.

Dahl to 920-808-**** "Mate Cc's" 10:34 pm - "Tell cc im in her garage plz n thank u. dose ed
have any cash?"

Based on my training and experience, "ed" likely owes Dahl and/or D.J.T. money from
previous methamphetamine sales.

DAHL to D.J.T. 11:13 pm: "Im on way back"

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

D.J.T. to DAHL 11:14 pm: "Mkay. I'm still messing with this snow blower"

December 26, 2022

DAHL to D.J.T. 1:22 am: "Thought u were coming in? Or did u want to be alone tonight? I
totally get it if u do, just gota let me know plz..."

There was no further activity on Dahl's cell phone following this text message. I entered a jump
drive of the cell phone extraction into evidence at the Brown County Sheriff's Office.

4. Your complainant's review of the reports of Sgt. Marc Shield of the Brown County Sheriff’s
Department, who indicates: On June 12, 2023 at approximately 4:45 pm, Sgt. Raska and I
arrived at 2130 Elmview Drive Apartment D in the Village of Ashwaubenon, Brown County,
Wisconsin to potentially interview C.C.T. and/or D.G. regarding information SARAH DAHL
reportedly disclosed to them about D.J.T.'s death.

I knocked on the door and it was answered by C.C.T. who stepped outside and agreed to
speak with us. I told C.C.T. I was following up on an investigation involving D.J.T..

I asked C.C.T. what she knew and she said she knew he "passed away." C.C.T. stated she
knew D.J.T. prior to his passing for about a year and D.J.T. dated one of her "good friends"
who she identified verbally as SARAH DAHL. I showed C.C.T. an unlabeled colored booking
photograph of SARAH DAHL and she positively identified her.

C.C.T. stated DAHL was last at her apartment a "couple weeks ago." C.C.T. stated she knew
DAHL had given D.J.T. a "couple pills" and it was an overdose death. I asked C.C.T. how she
knew this to be true and she stated DAHL told her.

C.C.T. stated DAHL stopped by her house the night before he died (consistent with phone
records). C.C.T. stated DAHL told her she had two "Oxy" pills for D.J.T. as a gift. C.C.T. stated
she knew D.J.T. was a recovering opiate addict. C.C.T. stated she smoked methamphetamine
that night with DAHL, which DAHL brought over. DAHL and D.J.T. were originally visiting with
C.C.T., but DAHL later returned that night by herself.

C.C.T. stated she did not actually see the pills, but that is what DAHL told her. C.C.T. stated
DAHL said she received the pills from "KRISTY" who works at a gas station. The female
source was later identified as KRISTY M. SOMMERS DOB:9-19-1986. SOMMERS was later
interviewed and admitted to providing five "Percocet" pills to DAHL on December 22, 2022 for
$100.

C.C.T. stated she was upset DAHL obtained pills for D.J.T. because he was clean for several
years, but C.C.T. stated DAHL got him the pills to "be a good girlfriend or something."

I inquired with C.C.T. about what DAHL disclosed following D.J.T.'s death. C.C.T. stated DAHL
came over that next morning and C.C.T. did her best to console DAHL. C.C.T. stated DAHL
said D.J.T. died.

C.C.T. stated DAHL told her she went upstairs to a bedroom and D.J.T. "stalled" downstairs.
C.C.T. stated DAHL said she went back downstairs at some point and "stumbled over him or
something." This version is consistent with what DAHL disclosed to law enforcement during the

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

death investigation. C.C.T. later stated the discrepancy in DAHL's stories involved whether
D.J.T. left the garage at the same time DAHL did or if D.J.T. stayed in the garage for some
time after DAHL left to go upstairs.

C.C.T. stated DAHL discusses D.J.T.'s death "about every time she stops by." C.C.T. stated
DAHL last stopped by a "couple weeks ago."

I asked C.C.T. if DAHL mentioned anything about not knowing the pills were fentanyl. C.C.T.
responded "Um, no. She said she trusted KRISTY so she didn't really question it at all."

C.C.T. then stated DAHL told her KRISTY SOMMERS obtained the pills DAHL gave to D.J.T.
from some "random girl that just walked into her workplace."

I asked C.C.T. if DAHL said she saw D.J.T. ingest the pills. C.C.T. said "she said she didn't
see him take 'em at all or anything like that." I asked C.C.T. if DAHL told her she gave the
pills to D.J.T. and C.C.T. said "Yes."

I asked C.C.T. specifically about a recent instance where DAHL disclosed D.J.T.'s death in the
presence of a group of people (consistent with the anonymous information). C.C.T. stated she
did not specifically recall. C.C.T. stated D.G. also has information regarding DAHL disclosing
the fact she provided fentanyl pills to D.J.T.. C.C.T. stated she knew D.G. knew this
information through both C.C.T. and DAHL.

C.C.T. stated her new phone number is 920-227-****. She stated D.G. does not have an active
phone. I asked C.C.T. about DAHL's whereabouts and she stated DAHL is homeless and she
was unaware of her whereabouts.

Review of DAHL's Phone Analysis

Information from C.C.T. is consistent with DAHL's phone data which indicated DAHL texted
920-808-4001 under the name "Mate CC's" on December 25, 2022 at 10:34 pm and stated
"Tell cc in her garage plz n thank u.dose ed have any cash?"

On December 25, 2022 at 11:13 pm, she messaged D.J.T. (920-413-0789) "Im on my way
back." At 11:14 pm, DJT responded "Mkay. I'm still messing with this snow blower."

I also observed messages between DAHL and KRISTY M. SOMMERS (09-19-1986)

consistent with a drug transaction (fentanyl pills) which is further corroborated by information
provided by C.C.T..

On December 21, 2022 at 7:57 pm, DAHL texted "Kristy" (920-664-****) - "So jw if those things
are still around."

According to law enforcement records, 920-664-**** is associated with KRISTY M. SOMMERS

(09-19-1986).

On December 21, 2022 at 7:58 pm, SOMMERS replied "Im sorry I completely forgot... Its been
a very hectic day."

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

On December 21, 2022 at 7:59 pm, SOMMERS texted "I'll see her 2mro..."

On December 21, 2022 at 8:00 pm, DAHL replied "Ok. Lmk plz."

Based on my training and experience, this is consistent with SOMMERS telling DAHL she
could obtain additional fentanyl pills from her source of supply "2mro...."

On December 22, 2022 at 6:55 pm, SOMMERS texted DAHL "I am closing tonight... R u
around."

According to an open source search of SOMMERS' Facebook profile, she is employed at a

gas stations. Based on my training and experience, this message was consistent with
SOMMERS arranging the fentanyl pills deal with DAHL. There were no additional messages or
calls between SOMMERS and DAHL.

5. Your complainant's review of the reports of Sgt. Marc Shield of the Brown County Sheriff’s
Department, who indicates: On June 14, 2023, I spoke with D.G. by phone. The call was
recorded on my body worn camera. D.G. stated D.J.T. was his friend and D.J.T. recently
started dating SARAH DAHL.

D.G. stated he knew D.J.T. was a recovering opiate addict and was using methamphetamine.
D.G. stated he was suspicious of DAHL and her potential involvement in D.J.T.'s death. D.G.
stated he knew DAHL disclosed details regarding her involvement in D.J.T.'s death. D.G.
stated he did not listen intently during many of DAHL and C.C.T.'s conversations.

D.G. stated DAHL told her the events of the evening how they were working on a snowblower
and then went into the house to go to bed. D.G. stated DAHL's story was a bit suspicious
because the story changed whether they walked into the house together or D.J.T. remained in
the garage while DAHL went inside.

D.G. stated he continuously questioned DAHL after D.J.T.'s death and she admitted to
providing two pills to D.J.T. the night prior to his death. This upset D.G. because they knew
D.J.T. was a recovering opia.te addict. D.G. stated he heard "KRISTY" was the source of
supply, but he did not have any specific information on "KRISTY." D.G. also stated DAHL
came over to his apartment shortly after D.J.T.'s death with the same type of pills which
resulted in D.J.T.'s death. D.G. described these pills as blue which is consistent with fentanyl
pills (counterfeit Percocet). D.G. stated DAHL asked her to use a fentanyl test strip to test the
pills.

6. Your complainant's review of the reports of Sgt. Marc Shield of the Brown County Sheriff’s
Department, who indicates: On June 14, 2023 at approximately 5:43 pm, Sgt. Raska and I
met with R.J. at the Brown County Sheriff's Office after R.J. agreed to come in and provide
information involving the overdose death of D.J.T..

I previously spoke to R.J. by phone and he only identified himself by his first name. During the
initial phone interview, he stated he initially overheard SARAH DAHL telling C.C.T. and D.G.
she gave two pills to D.J.T. which resulted in his death. R.J. stated he actually heard this
information directly form DAHL and told this story initially because he thought he would
possibly get in trouble.

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

R.J. stated he dated DAHL for approximately six months and they broke up about three weeks
ago following DAHL's arrest.

R.J. stated on two occasions at R.J.'s apartment while they have dated DAHL told him about
the overdose death of D.J.T., who R.J. never met. He stated DAHL said she obtained two pills
around Christmas from "KRISTI" (KRISTI SOMMERS) who worked at a gas station. DAHL
stated KRISTI organized the transaction and the pills were purchased from a "petite black
woman." R.J. stated he believed the pills were $10 or $20 each.

R.J. stated DAHL complained about the entire situation and said "This is what I get for doing
something nice" and "I accidentally killed my boyfriend." DAHL also expressed concern to R.J.
about her phone being in police custody because it may reveal her involvement in D.J.T.'s
death.

I asked R.J. how he knew DAHL disclosed this information regarding her involvement in
D.J.T.'s death to C.C.T. and D.G.. R.J. stated D.G. constantly accused DAHL of killing his
friend D.J.T.. DAHL also expressed concern to R.J. that C.C.T. and D.G. would "bring it to
light."

R.J. stated DAHL also expressed concerned that C.H. would also bring the situation out and
get her in trouble.

R.J. positively identified DAHL, C.C.T., D.G., C.H., and the apartment where C.C.T. and D.G.
reside in the Village of Ashwaubenon.

I asked R.J. about drugs DAHL used and to his knowledge she smoked methamphetamine
and marijuana. He stated DAHL's last known phone number is 920-246-4*** (the only number
she used while they were dating). R.J. stated he was concerned DAHL was going to leave
the state while on bond because she told him she was packing her bags for Wyoming
because they do not have extradition. Additionally, R.J. said he snooped through DAHL's
phone and there were searches on DAHL's phone regarding Wyoming extradition laws.

7. Your complainant's review of the reports of Sgt. Marc Shield of the Brown County Sheriff’s
Department, who indicates: On June 14, 2023 at approximately 12:28 pm, Sgt. Raska and I
arrived at Jackson Point Citgo, 2710 Packerland Drive in the Village of Ashwaubenon, Brown
County, Wisconsin to speak with KRISTY M. SOMMERS DOB:9-19-1986 who is employed at
this location as an assistant manager.

Sgt. Raska and I arrived inside the store and observed SOMMERS working behind the
counter. SOMMERS had a co-worker relieve her at the counter and escorted us to a back area
after she agreed to speak with us.

I told SOMMERS we wished to speak with her about SARAH DAHL. SOMMERS stated she
used to work with DAHL at the gas station. SOMMERS confirmed her phone number was 920-
664-2*** which was the same number she used to coordinate the pill transaction with DAHL on
December 22, 2023 according to DAHL's phone records.

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

I told SOMMERS we knew DAHL obtained pills from her around Christmas. SOMMERS
confirmed this was the case and said the source was a stranger and it was a "fluke" with how it
transpired. SOMMERS stated she does not use any illegal drugs or pills other than marijuana.
SOMMERS stated she was told the pills were "Percocet" or something.

Based on my training and experience, counterfeit blu M-30 Percocet pills are prevalent and is
actually fentanyl. I showed SOMMERS a photograph of a Perocet pill (M Box 30) and she
confirmed this is what the pills looked like.

SOMMERS stated an unknown black female in her mid 30s and a male with dreadlocks came
into the store and the male smelled like marijuana. SOMMERS stated they were driving a red
SUV. SOMMERS told them they smelled really good and the female inquired if she knew
anyone who wanted the "Percocet" pills.

SOMMERS stated she then asked DAHL if she knew anyone who wanted "Percocet."
SOMMERS stated DAHL was interested and SOMMERS obtained five "Percocet" pills from
the unknown female for $100 cash ($20 a pill). SOMMERS stated they were packaged in a
plastic corner baggie.

SOMMERS stated on that same day (December 22, 2022), DAHL arrived at the gas station
and SOMMERS provided her with the five "Percocet" pills she previously purchased from the
unknown black female. SOMMERS "fronted" the pills to DAHL and she was unsure if DAHL
officially paid her back because she regularly loans money out to DAHL.

I asked SOMMERS if she spoke to DAHL since the "Percocet" transaction and she indicated
she did. SOMMERS stated DAHL said her boyfriend passed away. SOMMERS stated she
never met D.J.T..

I asked SOMMERS what DAHL told her and she stated DAHL said she was waiting for D.J.T.
to come upstairs and he never came upstairs. SOMMERS stated DAHL said she then found
D.J.T. dead and she "didn't know if he had taken them (the pills) or not." SOMMERS stated the
conversation with DAHL regarding this occurred at SOMMERS' house in the Village of
Ashwaubenon.

I asked SOMMERS if DAHL said the "Percocet" pills were specifically for D.J.T. and she stated
DAHL did not specify who the pills were for. SOMMERS stated DAHL told her she did not
know if D.J.T. took any of the pills or not. SOMMERS stated DAHL "thought he (D.J.T.) put
them (the pills) in a drawer in the garage or something, so she wasn't sure if he took 'em or
not."

SOMMERS stated this was a one-time thing and she would never do this again. She stated
she regrets participating in the transaction and was nervous during the transaction.
SOMMERS stated she has not seen the unknown black female source of supply since January
of 2023. In the past, SOMMERS purchased marijuana from the female.

SOMMERS stated she is not aware of DAHL's whereabouts currently, but has spoken to her
via text message as recently as Saturday. In the conversation, SOMMERS stated DAHL said
she ran out of gas and SOMMERS loaned her $20. SOMMERS did not wish to provide DAHL's
current phone number.

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

SOMMERS insisted she was not aware the pills contained fentanyl.

8. Your complainant's review of the reports of Sgt. Marc Shield of the Brown County Sheriff’s
Department, who indicates: On June 21, 2023 at approximately 11:00 am, SARAH DAHL
arrived at ADL Monitoring Solutions, 107 South Madison Street in the City of Green Bay for a
drug patch appointment.

Sgt. O'Connell and Sgt. Z. Roush arrived on scene before I arrived and spoke with DAHL in a
room. I entered the room and advised DAHL she was under arrest for Reckless
Homicide. Dahl said she did not want to speak to officers.

Despite that, DAHL continued to speak and attempt to inquire about the investigation. DAHL
stated the claims against her were mere hearsay and there was a lack of evidence of her
involvement in D.J.T.'s death. DAHL stated she wished she had taken whatever D.J.T. took
that evening so she could be dead as well.

DAHL was handcuffed behind her back and I took custody of her cracked Samsung Galaxy
S10e cell phone FCC ID: A3LSMG970U, IMEI: 352066105678580 (Exhibit #1324029). I
requested DAHL's PIN and told her I would apply for a search warrant. DAHL denied consent
to search.

Deputy Stonebraker and Deputy Mleziva then arrived on scene to transport DAHL to the
Brown County Jail. During the transport to jail, DAHL indicated she started to feel suicidal.
DAHL was transported to the Crisis Center for an evaluation and then the Brown County Jail.
During my contact with DAHL, she indicated she was not suicidal -- particularly in the moments
prior to her arrest.

Sgt. O'Connell provided me with a "Clinical Reference Laboratory" sheet from DAHL's drug
patch which he was provided by ADL Monitoring Solutions. The test was positive for the
presence of amphetamine and methamphetamine.

9. Her review of the Autopsy report of DJT DOB: 12/19/85 which was performed on December
27, 2022 by Forensic Pathologist Dr. Elizabeth Douglas who opines that DJT died of the toxic
effects of multiple substances including methamphetamine and fentanyl. Dr. Douglas did
indicate in a telephone conversation on June 22, 2023 that the fentanyl would have been a
substantial factor in causing DJT’s death.

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

Subscribed and sworn to before me on Electronically Signed By:

06/22/23 Wendy W. Lemkuil
Electronically Signed By: Complainant
Caleb J Saunders
Deputy District Attorney
State Bar #: 1094077

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STATE OF WISCONSIN - VS - Sarah Joann Dahl

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