Case 2024CF000048 Document 2 Filed 01-05-2024 Page 1 of 7

FILED
01-05-2024
Clerk of Circuit Court
Brown County, WI
STATE OF WISCONSIN CIRCUIT COURT BROWN COUNTY
2024CF000048
BRANCH
Honorable Beau G
Liegeois
STATE OF WISCONSIN DA Case No.: 2024BR000137
Plaintiff, Assigned ADA: Maggie R Crawford Branch 8
Agency Case No.: DTF23-475
vs. Court Case No.: 2024CF
ATN:
TATIANA ALEXIS QUINONES

De Pere, WI 54115
DOB: /2003
Sex/Race: F/B CRIMINAL COMPLAINT
Eye Color: Brown
Hair Color: Brown
Height: 5 ft 2 in
Weight: 180 lbs
Alias:
Defendant. For Official Use

Complainant, Maggie R Crawford, an Assistant District Attorney, being first duly sworn on oath,
deposes and says that:

Count 1: CONSPIRACY TO COMMIT DELIVER FENTANYL (<=10 G), POSSESSION WITH

INTENT TO DELIVER/DISTRIBUTE A CONTROLLED SUBSTANCE ON OR NEAR A
YOUTH CENTER

The above-named defendant on or about Wednesday, January 3, 2024, in the City of Green
Bay, Brown County, Wisconsin, conspired to deliver a controlled substance, to-wit: fentanyl, in
an amount of ten grams or less, contrary to sec. 961.41(1)(dm)1, 961.41(1x), 961.49(1m)(b)5
Wis. Stats., a Class E Felony, and upon conviction may be fined not more than Fifty Thousand
Dollars ($50,000), or imprisoned not more than fifteen (15) years, or both.

And further, invoking the provisions of sec. 961.49(1m)(b)5 Wis. Stats., because the above
offense occurred within 1000 feet of a youth center or a community center, Green Bay
Academy, the maximum term of imprisonment prescribed by law for that crime may be
increased by 5 years.

And the Court may suspend the defendant's operating privileges for not less than six (6)
months nor more than five (5) years. If the defendant's driving privileges are already
suspended, any suspension imposed must be served consecutively.

Count 2: POSSESSION WITH INTENT TO DELIVER FENTANYL (<=10 G)

The above-named defendant on or about Wednesday, January 3, 2024, in the City of De Pere,
Brown County, Wisconsin, did possess with intent to deliver a controlled substance, to-wit:
fentanyl, in an amount of ten grams or less, contrary to sec. 961.41(1m)(dm)1 Wis. Stats., a
Class E Felony, and upon conviction may be fined not more than Fifty Thousand Dollars
($50,000), or imprisoned not more than fifteen (15) years, or both.

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STATE OF WISCONSIN - VS - Tatiana Alexis Quinones

And the Court may suspend the defendant's operating privileges for not less than six (6)
months nor more than five (5) years. If the defendant's driving privileges are already
suspended, any suspension imposed must be served consecutively.

Count 3: POSSESSION OF TETRAHYDROCANNABINOLS (THC)

The above-named defendant on or about Wednesday, January 3, 2024, in the City of De Pere,
Brown County, Wisconsin, did knowingly possess a controlled substance,
Tetrahydrocannabinols (THC), contrary to sec. 961.41(3g)(e) Wis. Stats., a Misdemeanor, and
upon conviction may be fined not more than One Thousand Dollars ($1,000), or imprisoned for
not more than six (6) months, or both.

And the Court may suspend the defendant's operating privileges for not less than six (6)
months nor more than five (5) years. If the defendant's driving privileges are already
suspended, any suspension imposed must be served consecutively

Count 4: POSSESSION OF DRUG PARAPHERNALIA

The above-named defendant on or about Wednesday, January 3, 2024, in the City of De Pere,
Brown County, Wisconsin, did knowingly possess with primary intent to use drug paraphernalia
to ingest, inject, inhale, pack or store a controlled substance, contrary to sec. 961.573(1) Wis.
Stats., a Misdemeanor, and upon conviction may be fined not more than Five Hundred Dollars
($500), or imprisoned for not more than thirty (30) days, or both.

And the Court may suspend the defendant's operating privileges for not less than six (6)
months nor more than five (5) years. If the defendant's driving privileges are already
suspended, any suspension imposed must be served consecutively.

Complainant is an Assistant 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 Narcotics Investigators of the Brown County Drug Task Force, 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.

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STATE OF WISCONSIN - VS - Tatiana Alexis Quinones

As to Count 1

1. Your complainant’s review of the reports prepared by Narcotics Investigator Russell of

the Brown County Drug Task Force, which states in part:

On Wednesday January 3rd, 2024, at approximately 3:18 p.m., Narcotics Investigator (N/I)
Prokash and I met with CI #2227, hereafter referred to as “the CI” at a pre-arranged location.
The purpose of the meeting was to have the CI attempt to conduct a controlled purchase of
50 fentanyl pills from a person the CI knows as “Kid” for $350.00. The CI indicated that the CI
has known Kid for approximately 6 months, and they have purchased fentanyl from him in the
past. The CI indicated that Kid uses the phone number of ***-***-**** for communication.
Under my direction, the CI contacted Kid and set up the deal, and communication took place
via the aforementioned phone number through text and calls. The CI indicated that Kid told
the CI that a female would be selling the fentanyl pills on his behalf. I searched the CI’s
person for currency and contraband with negative results. N/I Prokash searched the CI’s
vehicle for currency and contraband with negative results. I provided the CI with $350.00 of
pre-recorded U.S. currency and recording equipment.

Under my direction, the CI called Kid ***-***-****, and Kid told the CI to proceed to the Green
Bay Academy, which is a child daycare facility, located at 2280 Finger Road, City of Green
Bay, Brown County, Wisconsin. Kid indicated to the CI that the CI would meet a female there.
Electronic surveillance revealed that after Kid spoke with the CI ***-***-**** called ***-***-****,
which belongs to TATIANA A. QUINONES, F/U, D.O.B: /2003.

At 3:46 p.m., the CI left the pre-arranged location to meet with the unknown female at 2280
Finger Road.
At 4:00 p.m., N/I Eickholt indicated that the CI arrived at 2280 Finger Road.
At 4:06 p.m., N/I Tompson indicated that female who was recognized as TATIANA A.
QUINONES, F/U, D.O.B: /2003 exited 2280 Finger road and went up to the CI vehicle.
Contact could be heard over the wire between QUINONES and the CI.
At 4:06 p.m. after the deal was done, I called the CI who indicated that they had the drugs in
hand. I remained on the phone with the CI and visual surveillance was also maintained of the
CI.
At 4:11 p.m., N/I Prokash and I met with the CI at a pre-arranged location. The CI immediately
handed me a small, clear plastic bag that contained small, round, blue pills with the inscription
“M 30” on them that CI believed was 50 fentanyl pills. I searched the CI’s person for currency
and contraband which yielded negative results. N/I Prokash searched the CI’s vehicle for
currency and contraband with negative results. The CI gave me the recording equipment.

The CI provided me with a written statement, which we both reviewed for accuracy, making
changes as needed. The CI’s written statement is summarized as: The CI contacted “Kid”
who the CI knows is a male black with dreads via the phone number of ***-***-**** to set up a
deal of 50 fentanyl pills for $350. This was done under the direction of N/I Russell. Kid told the
CI that he would have an unknown female sell the CI the fentanyl pills. The CI obtained $350
of pre-recorded U.S currency from N/I Russell and proceeded to the deal location. The CI was
met in the parking lot by a bi-racial female who handed the CI a small, clear, plastic bag that
the CI believed contained 50 fentanyl pills. The CI handed the bi-racial female the $350 of
pre-recorded U.S currency. The CI left the deal location, met with N/I Russell and N/I
Prokash, and surrendered the suspected fentanyl pills to N/I Russell.

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STATE OF WISCONSIN - VS - Tatiana Alexis Quinones

The CI was shown an unlabeled color photograph of “Kid,” who the CI stated with certainty
was person the contacted to set up the drug deal. Kid is identified as ULYSSES A. TALLIE,
M/U, D.O.B: /2002. The CI was shown an unlabeled color photograph of the bi-racial
female who the CI stated with certainty was the person that the CI exchanged $350.00 with
for 50 fentanyl pills. This female is identified as TATIANA A. QUINONES, F/U, D.O.B:
01/07/2003.

I maintained possession of the evidence which I transported to the Brown County Drug Task
Force for processing, and the evidence is as follows:
· SMALL, CLEAR, PLASTIC BAG THAT CONTAINED EXHIBIT 2 - EXHIBIT #1
· 5.82 GRAMS FENTANYL IN THE FORM OF 50 SMALL, BLUE ROUNDS PILLS WITH
THE INSCRIPTION "M 30" ON THEM, TESTING POSITIVE FOR FENTANYL - EXHIBIT #2

I took a sample of the suspect material from exhibit 1 and tested it using the Mobile Detect
Fentanyl Test. I observed the following. Using the cotton swab provided in the test, I rubbed a
sample of the suspect material on the cotton swab. I then put the cotton swab containing the
sample of the suspect material into the vial with the liquid solution provided via the test kit. I
then agitated the vial with the liquid solution, and then placed the Fentanyl test strip that came
with the test kit in the solution. The Fentanyl test strip remained in the solution for
approximately 1 minute per the test instructions. After a minute, I saw a single line appear on
the test strip, which indicates the suspect material is positive for containing fentanyl, a
controlled substance. Exhibit 1 consisted of 50 pills weighing 5.82 grams.

The drug transaction occurred in the parking lot Green Bay Academy (2280 Finger Road),
which is a daycare center for children. The drug transaction was well within 1000 feet of a
center responsible for the care of children since it was conducted on the property.

As to Count 2 – Count 4

2. Your complainant’s review of the report prepared by Narcotics Investigator Ronsman of

the Brown County Drug Task Force, which states in part:

On Monday, January 4, 2024, at approximately 3:53 PM, members of the Brown County Drug
Task Force conducted a Consent Search at 1234 S Erie St #1, in the City of De Pere, in
Brown County Wisconsin.

As part of an ongoing investigation, N/I Tompson was conducting a custodial interview of

TATIANA ALEXIS QUINONES F/B DOB: 2003, who was identified as living at
. QUINONES signed a consent to search form for her residence during
the interview with N/I Tompson.

Narcotics Investigators knocked on the door of and did not get a response.
Narcotics Investigators utilized a key located on QUINONES to enter the apartment. Upon
entry into the apartment is a living room. To the east of the living room is a small kitchen. Off
the living room to the north is a bathroom, QUINONES’s bedroom, and a child’s bedroom.

During the search of the residence, I acted as evidence custodian. When an item of
evidentiary value was located, it was turned over to me. I maintained custody of the items until

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STATE OF WISCONSIN - VS - Tatiana Alexis Quinones

I was able to process and secure the items into an evidence locker at the Brown County Drug
Task Force.

In QUINONES’s bedroom, in the nightstand, N/I Walters located a clear glass smoking pipe
with green leafy residue in the bowl, which is consistent with a marijuana pipe (Exhibit #1).
Next to this pipe was a clear plastic sandwich bag (Exhibit #2) which contained 3.06 grams of
a green leafy substance which field tested positive for THC (Exhibit #3). In the same drawer
with these items was a Wisconsin Driver’s License for QUINONES. Additional paperwork for
QUINONES was located in this bedroom.

In the kitchen, near the refrigerator, N/I Prokash located a clear plastic sandwich bag (Exhibit
#4) which contained 16 full blue round pills with imprint M30, plus 2 crushed up pills, totaling
2.06 grams, which field tested positive for Fentanyl (Exhibit #5).

FIELD TESTS:
I took a sample of the suspect material from Exhibit #3 and tested it using the Duquenois
Levine Reagent Test. I observed the following. After breaking the first ampoule, no color
change was observed. After breaking the second ampoule, I observed the liquid turn purple.
After breaking the third ampoule and rotating the packet one-quarter turn, I observed a
separation in the purple color, light over dark. These observations indicate a positive test for
THC, a controlled substance.

I took a sample of the suspect material from Exhibit #5 and tested it using the MobileDetect
Fentanyl Test Strip test kit. I observed the following. After gathering a sample of the suspect
material (Exhibit #5) on the provided cotton swab, and placing it into the buffer solution, I
placed the fentanyl test strip into the test tube. After waiting 60 seconds I removed the
fentanyl test strip from the buffer solution and observed one line, indicating a positive result
for fentanyl, a controlled substance.

POSSESSION WITH INTENT FENTANYL

I, Nicholas Ronsman, have been a deputy for the Brown County Sheriff’s Office since January
of 2017. I have been assigned to the Brown County Drug Task Force since January of 2022
as a Narcotics Investigator. I am also a sworn Task Force Officer with the United States Drug
Enforcement Administration (DEA). I have received on the job and formal training in drug
identification, evidence collection, video/visual surveillance, search warrant execution and
more. I have been involved in numerous investigations pertaining to the distribution of
controlled substance and am familiar with factors which are indicative of distribution such as
drug amounts, packaging materials, digital scales, electronics, and large sums of US
Currency.

Based on my training and experience, the Fentanyl, was possessed by QUINONES with the
intent to deliver due to the following reasons:

-The amount of Fentanyl (18 pills weighing 2.06 grams) can be an amount consistent with
distribution, not strictly personal use.
-Based on the totality of the investigation where the Brown County Drug Task Force utilized a
confidential informant to purchase Fentanyl M30 pills from QUINONES the day before the
consent search.

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STATE OF WISCONSIN - VS - Tatiana Alexis Quinones

-I know that a typical user smokes between 1-5 Fentanyl M30 pills per day depending on an
individual’s tolerance.
-According to the DEA, 7 out of 10 Fentanyl M30 pills contain a potentially lethal dose of
Fentanyl. This means that 12 of the Fentanyl Pills contained a potentially lethal dose of
Fentanyl.
-In a recorded interview, QUINONES admitted that she does not use Fentanyl M30 pills but
did admit to selling them.

3. Your complainant’s review of the reports prepared by Narcotics Investigator Prokash of

the Brown County Drug Task Force, which states in part:

On January 3, 2024, I met with VCL, who is the manager of Green Bay Academy, which is
located at 2280 Finger Road, in the City of Green Bay, Brown County, Wisconsin. I spoke with
her in reference to the controlled buy conducted at the location earlier in the day as I was
concerned investigators observed TATIANA A. QUINONES DOB: /2003 exit the daycare
facility in possession of fentanyl pills. VCL advised they had video surveillance of the day care
and allowed me to view the footage. I also later spoke with the owner, GL.

In reviewing the footage, I observed QUINONES supervising children in what is labeled "2.5
to 3 year old room". At approximately 3:59 pm, I observed QUINONES answer a telephone
call. QUINONES then speaks to another employee, who utilizes a radio. Another teacher
enters the room and QUINONES exits the room into a hallway. From the hallway, QUINONES
enters a room labeled "1 year old room." QUINONES enters a bathroom, which had a closed
door but no lock on it. The door also does not shut on its own and will remain open if not shut
by a person. In viewing the bathroom in person later, I observed numerous children’s toys,
containers from previous child activities, and two small child toilets in the bathroom.

Approximately 10 seconds after entering the bathroom, QUINONES exits it and then exits the
room into the hallway. QUINONES walks through the hallway and out the front doors of the
building. Upon exiting the front door, QUINONES immediately walks to the CI's vehicle and
meets with them at the driver's window. QUINONES does not stop any at other locations.
After a short-term meet lasting approximately 5 seconds, which based on my training and
experience is consistent with drug deals I have observed in the past, QUINONES goes back
inside the day care.

QUINONES goes in a bathroom and is in there for approximately 1 minute 44 seconds.

QUINONES returns to the "1 year old room" and again goes in the bathroom. QUINONES
then returns to the "2.5 to 3 year old room" and begins supervising young children again.

Based on the video evidence, I believe the fentanyl pills QUINONES sold to the CI were
stored inside the bathroom of the "1 year old room" inside the daycare. Based on my training
and experience, QUINONES put multiple children’s lives, whose care she was entrusted with,
at risk by storing the fentanyl pills in the daycare. If QUINONES were to drop even one of the
small pills, a child could have easily picked it up off the ground and swallowed it, causing
them to overdose and possibly die.

Based on my training and experience, it is imperative to protect children in drug abusing

environments. Whether it be the sale or use of controlled substances in the presence of
children they are exposed to many risks, which can be a detriment to their future physical and

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emotional development. Exposing children to surroundings where drugs are used or sold is an
abusive and hazardous environment. Lack of attention and supervision where caretakers are
under the influence of controlled substances only adds to the inability of children in their home
to develop and mature at socially acceptable levels. I also know through my training
experience that people who sell or use controlled substances may be at a higher risk of being
burglarized or robbed for those items and these crimes often go unreported, leaving the
children without the protection of the police.

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

Subscribed and sworn to before me on Electronically Signed By:

01/05/24 Maggie R Crawford
Electronically Signed By: Complainant
Natalie M Mulvey
Assistant District Attorney
State Bar #: 1129763

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