Criminal Complaint

Page: 1 of 8

Jason L Sam Co. Atty Petition No: 0620392735

STATE OF MINNESOTA SECOND JUDICIAL DISTRICT COURT COUNTY OF RAMSEY JUVENILE COURT DIVISION MNCIS Group No. ___________ D. C. File No. 62-JV-17-1964 C. A. File No. 0620392735

In the Matter of the Welfare of: Child’s name including, address, and phone number if different than parent:

Jason L Sam (DOB: 07/31/2001) 1575 Saint Paul Ave, Apt 18 St. Paul, MN 55116

FELONY JUVENILE PETITION ☐ Delinquency ☒ Delinquency Felony (age 16 and over) ☐ Juvenile Petty Offender

☐ Traffic

☐ Prosecutor parents/guardian/spouse/nearest relative, relative, including The Child’s parents/guardian/spouse/nearest relationship, address, and phone number:

Anne Agne Custodial Parent 1575 Saint Paul Ave, Apt 18 St. Paul, MN 55116 (612) 298-9130

Designated EJJ ☐ Motion for EJJ ☒ Presumptive Motion for Certification ☐ Non-Presumptive Motion for Certification ☒ Amended ☐ Warrant

Requested

The Petitioner, being duly sworn, makes complaint to the above-named Court and states that there is probable cause to believe that the Respondent committed the following offense(s): COUNT 1

On or about August 6, 2017, 20 17, in the County of Ramsey, Ram sey, Minnesota, Jason L Sam did assault ano ther and inflict great bodily harm. Said acts constituting the offense of Assault-1st Degree-Great Bodily Harm in violation of: §609.221.1.

Page: 2 of 8


COUNT 2

On or about August 6, 2017, in the County of Ramsey, Minnesota, Jason L Sam did assault another with a dangerous weapon consisting of a firearm. Said acts constituting the offense of Assault-2nd Degree-Dangerous Weapon in violation of: §609.222.1; 609.11.5(a). COUNT 3

On or about August 6, 2017, in the County of Ramsey, Minnesota, Jason L Sam did being under the age of 18 years, possess a pistol.

Said acts constituting the offense of Possess Ammo/Pistol/Assault Ammo/Pistol/Assault Weapon - Under 18 yrs Old in violation of: §624.713.1(1); 624.713.2(a). COUNT 4 On or about August 6, 2017, in the County of Ramsey, Minnesota, Jason L Sam did being under the age of 18 years, did possess a firearm/ammunition. Said acts constituting the offense of Possess Ammo/Any Firearm in violation of: §624.713.1(1); 624.713.2(a). COUNT 5

On or about August 6, 2017, in the County of Ramsey, Minnesota, Jason L Sam did having knowledge of not being entitled thereto, attempt to take from the person or in the presence of another personal property, and used or threatened the imminent use of force against a person to overcome resistance to or compel acquiescence in the taking or carrying away of the property, and while committing the robbery was armed with a dangerous weapon or an article used or fashioned in a manner to lead the victim to reasonably believe it to be a dangerous weapon. Said acts constituting the offense of attempted Aggravated Robbery-1st Degree in violation of: §609.245.1; 609.11.5(a), 609.17.1.

Page: 3 of 8


STATEMENT OF PROBABLE CAUSE

Petitioner states that the following facts establish probable cause: Petitioner is an Assistant Ramsey County Attorney who has reviewed the investigative reports submitted in this matter. The following facts establish establish probable cause for the offenses offenses charged. On August 6, 2017, at around 1755 hours, SPPD Officers responded to the Superday Gas Station at 2525 7th Street, City of St. Paul, and County of Ramsey on an aggravated assault. assault. The information aired was that that a male th parked in a neighbor’s driveway in the alley, put on a ski mask, pulled hood up, and walked toward 7 Street on foot. The suspect vehicle was was described as a maroon Dodge Durango. Durango. Additional information aired aired was that the victim was shot in the stomach. Officers arrived at an address on Sheridan and spoke with JG (1986). JG said he was at home and was grilling outside. JG said he was going going to the backyard to his grill grill when he saw a red Dodge Durango (MN (MN Lic. 364KME) KME) parked in his neighbor’s driveway. JG said he had never seen the car before in the neighborhood. While inside of his house, JG saw a male-wearing a black sweater, white shirt underneath, gray pants, ski mask-exit the rear driver side side seat and walk EB in the alley. JG saw the male pull down his ski mask. JG closed his doors, locked the front and back doors, doors, and went upstairs upstairs to monitor. JG called the police. JG then saw the Dodge Durango pull out of the driveway and drive WB in the alley, stop two garages west (Field Avenue). JG then saw the suspect run WB in the alley appearing to hold something in his left hand. JG saw the suspect get into the Dodge Durango. The Dodge Durango drove WB in the alley toward Edgecumbe Road. JG said he had the incident on his surveillance surveillance cameras. The video (JG video) provided details, including including the suspect running and getting back into the Dodge Durango. Officers radioed this information to assisting squads, providing that the shooter was was sitting behind the driver’s seat. Officers located a single, right foot blue crocs type shoe (with red on the bottom) where the Dodge Durango was parked in the driveway. driveway. A match to this shoe shoe was later recovered in the Dodge Durango. Officers responded responded to the Superday Gas. The victim, HS (1996) was located inside the business by the exit door, laying on his side. side. Medics provided care to HS and transported transported him to Regions Hospital. Officers spoke with LW (1968) who said he placed a 911 call after observing HS on the floor. LW said he went into the store to make a purchase when he saw HS laying laying on the floor. LW said that he saw saw that HS was injured. A 9mm WIN Luger casing was located in the business, by the exit door. Officers reviewed surveillance surveillance footage on CCTV cameras. Officers note that the CCTV footage is off by a couple of minutes. The footage starts at 17:56. Based on the footage, the suspect viewed viewed in the footage is described as 5’105’10-6’00, light skinned male, wearing a dark hoodie sweater, face sweater, face mask, white t-shirt, blue jeans, and used a handgun during the incident. The suspect walked into the business, pointed a firearm firearm at the victim (who was away from the register). register). The victim appears to walk around the suspect toward the exit door. The victim falls to the floor by the exit door and the suspect is seen running out of the business. business. The suspect in the Superday gas station is the same person that ex ited the Dodge Durango with the ski mask, and is later seen on video getting back into the Dodge Durango.


Page: 4 of 8

Nothing appears to have been taken from the business. A short time later, SPPD Central squads conducted a traffic stop of a vehicle matching the suspect vehicle (2006 Dodge Durango Lic. 364KME) in the area of 7th Street and Montreal. JASON LEE SAM III (07/31/2001) was arrested. He was the rear passenger. JASON LEE SAM III was not wearing shoes and was only wearing socks. JASON LEE SAM III informed Officer Buchin that he had a ''clip'' in his sock. Officer Buchin located a silver magazine which had the Smith and Wesson Wesson emblem on the bottom of it. Officer Buchin asked JASON LEE SAM III where the gun for the magazine was. He replied with “I plead the 5th.” Officer Buchin observed the magazine had seven rounds in it. The head stamp on the bottom of the case was ''Luger.'' The driver of the vehicle, J. Najera (1999) (1999) was also arrested. When arrested, J. Najera uttered ''I didn’t have anything to do with it. There’s cameras.'' The Durango registered to L. Najera (same address as J. Najera). There was a croc type shoe on the back passenger floor of the Dodge Durango. A microphone was located inside the Durango, near the driver’s seat. Marijuana was also recovered from the car. During a show-up, witness JG said that JASON LEE SAM III had the same physical features and structure of the suspect he saw in the alley of his home. JG said J. Najera had the same physical features and structures of the driver of the vehicle. The victim, HS, was taken to Regions Hospital. He was shot in the stomach. Nurses at Regions hospital informed police on 8/6/2017 that HS was stable, but had bleeding in his stomach. After a Miranda advisory, J. Najera spoke to Sgt. Bobrowski. J. Najera said he picked up suspect suspect in the area of Taco Bell (across (across from the the Superday Gas Station). They drove around and spent about ½ hour together. He then said he was pulled over at a gas station, but was not worried as he ''had not done anything wrong.'' J. Najera said that he drove the entire time. J. Najera denied seeing a gun or ammunition. Sgt. Bobrowski asked if he stopped anywhere. J. Najera was vague, but said said they may have stopped by a wooded area, suspect suspect got out, then returned to the Durango. Sgt. McAlpine conducted a follow up interview interview with J. Najera on 8/7/2017 around 1300 hours. J. Najera initially denied any involvement or knowledge of the robbery. At one point, J. Nejera explained that they circled the area after the shooting. J. Najera said they stopped stopped somewhere off of Shephard Road and suspect got out of the vehicle and then then returned. Sgt. Bobrowski later showed J. Najera Najera a part of the video in the alley where J. Najera parked the Dodge Durango, and suspect is seen exiting the vehicle, and putting on a mask. J. Najera started to cry. The video later shows N. Najera driving the Dodge Durango and waiting for suspect. J. Najera changed his story and said they stopped at an apartment complex in the area of Shephard/Homer (the area where vehicle stopped by squads). squads). J. Najera said suspect got out of Durango, ''took off his clothes…and threw it in a dumpster.'' J. Najera described a black colored dumpster in or near an apartment complex with an outside pool. J. Najera said he did not know about the gun, or where the suspect may have placed it. JASON LEE SAM III declined to speak to police. Sargeant Bobrowski interviewed the victim HS at Regions Hospital. HS said he saw the suspect go into the store and thought ''it was a joke or prank.'' HS said he was away from the cash register by the coffee when the suspect went to him and and demanded cash. HS said the suspect was pointing the gun at him and yelling yelling for money. HS said he thought thought the suspect was going to shoot him so he attempted to push him and run. run. HS said the suspect shot shot him once, and possibly twice. HS said he lay lay on the floor floor and was conscious. HS said a customer entered the store and helped him. HS said the suspect had a mask on that covered the bottom part part of his face. HS said his skin appeared to be White above the mask. HS said the gun was small. small. Sgt. Bobrowski viewed the surveillance surveillance video provided by witness JG and the gas station surveillance. surveillance. The suspect is the same person.

Page: 5 of 8


A medical opinion provided by Dr. Michael Micha el McGonigal, Regions Hospital, concludes that the level of injury sustained by HS is great bodily harm.

Being authorized to prosecute the offenses charge d, I approve this Petition as to form and verify that the contents are true to the best of my m y information and believe and that reasonable reason able grounds exist to support the Petition.

Date: August 8, 2017

PROSECUTING ATTORNEY’S SIGNATURE:

/s/ Rosita Severin Name: Rosita Severin 345 Wabasha Street North, Suite 120 St. Paul, MN 55102 651-266-3222/JG Attorney Registration # 26068X

Subscribed and sworn to before the undersigned u ndersigned this 8th day of August, 2017. NAME/TITLE:

____________________________________ ____________________________ ________

SIGNATURE:

____________________________________ ____________________________ ________

Page: 6 of 8


RESPONDENT DATA / CHARGE SHEET – ATTACHMENT A RESPONDENT NAME:

Jason L Sam

DOB: 07/31/2001

Respondent alias name(s):

Alias DOB(s):

Race: Hispanic/Latino Gender: Male Respondent last known address:

1575 Saint Paul Ave, Apt 18 St. Paul, MN 55116

State ID: Fingerprint ID: FBI ID: St. Paul PD ID:

17183895

Offender ID:

OTHER RESPONDENT / CASE IDENTIFIERS: Fingerprinted?

☐ No

☐ Yes

☐ No

☐ Yes

☐ No

☐

Photographed? Handgun permit?

Yes (Issuing Agency:

)

Location of violation: IF DRIVING OFFENSE: Driver's License

Number:

Issuing State:

License Plate

Number:

Issuing State:

Accident Type: check all that apply

☐ No

injury/no damage

☐ Personal

Injury

Blood Alcohol Concentration (BAC):

☐ Property ☐ Fatality

Damage

Page: 7 of 8

Jason L Sam Co. Atty Petition No: 0620392735 CT OFFENSE NO DATE

STATUTE STATUTE TYPE NBR

STATUTE DESCRIPTION

OFFENSE LEVEL

MOC

GOC

AGENCY ORI CN NBR FUNCTION

Charge 1

2

On or about August 6, 2017

Charge

609.221.1

Assault-1st Degree-Great Bodily Harm

Felony

A1123

N

St. Paul Police Dept. ORI - MN0620900 CN: 17183895


Charge

609.222.1

Assault 2 nd Degree Dangerous Weapon

Felony

A23232

A

St. Paul Police Dept ORI – MN MN 0620900 CN: 17183895

Felony

W162E

N


Penalty

3


Charge

Penalty

Minimum 609.11.5(a) Sentences of Imprisonment Firearm Use or Possession

624.713.1(1) Possess Ammo/Pistol/Assa ult Weapon Under 18 yrs Old

624.713.2(a)

Possess Ammo/Pistol Ammo/Pistol or Semi-Auto Assault Weapon - under 18 years old ineligible under 624.713.1(1)

Page: 8 of 8


4

5



Charge

624.713.1(1) Possess Ammo/Any Firearm -

Penalty

624.713.2(a)

Charge

609.245.1

Penalty

W169E

N


Felony

R1323

A


Possess Ammo/Pistol or Semi-Auto Assault Weapon - under 18 years old ineligible under 624.713.1(1)

Aggravated Robbery-1st Degree

609.11.5(a) Minimum Sentences of — Imprisonment — Firearm Use or Possession, 609.17.1

Felony

Anticipatory Crimes--Attempts

Criminal Complaint

Recommend Documents