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The above-named defendant on Friday, January 24,2014, in the City of Sweet Dreams, Heaven County, Wisconsin, did intentionally steal movable property of Ace Hardware, Sweet


The above-named defendant on Friday, January 24,2014, in the City of Sweet Dreams, Heaven County, Wisconsin, did intentionally steal movable property of Ace Hardware, Sweet Dreams. havinga valuegreaterthan$2500 butlessthan$5000, without consent. and with intent toper manently deprive the owner of possession of the property, contrary to sec. 943.20(1)(a) and (3)(bf) Wis.Stats.,a ClassIFelony,and upon conviction may beflnednot morethanTen Thousand Dollars($10,000), orimprisonednotmore than three (3) years and six (6)months. or both.





STATEOFWCSCONSTN-YS-


PROBABLECAUSE:


  1. Your complainant makesthis complaint based upon thefollowing,all of whichyour complainant believestobereliable.Theinformationinthiscomplaintdoesnotexhaustyour complainan1's knowledge of thisincident.


  1. Complainanthas reviewed the reports of the City ofSweet DreamsPolice Department whichreflect that on January 24,2014,atapproximately1:39a.m.,Officers Bice, Meyer,and RaskinweredispatchedtotheAceHardwarebuilding,locatedat 840EastAchillesStreet intheCityofSweet Dreams,HeavenCounty,Wisconsin, fora reportof glassbreakingand an alarmthat had been reportedbythealarmcompany.


  1. OfficerBicereports he observedthemosteastdooronthenorthsideofthebuilding had the entire glass portion broken out,without permission.Officer Bice reports he observedagrey/creamcoloredbrickorrockinsideof the storethatwasaboutthesizeofa baseball,which appeared to havebeenused tobreakthe window and which also appeared tohavehitanewspaperstand,whichcaused thepaperstoscatter.OfficerBice reportstheofficersspoke totheOwnerof thebuilding,Michael Cox,who statednothing appearedto bemissing.


  1. Officer Richmond reports that on January 24, 2014, at approximately10:00a.m.,he spoketoDeanBrandner, aManagerforAceHardware,whosaidhedidawall

$580,MS211C$320,MS362$740,MS461$1080,MS311$540 andachopsawTS420

$1050,


  1. OfficerRichmond reportsRussellFrinzi,a taxidriver,saidthatatapproximately1:35a.m.,he drove pastAce Hardware,in Sweet Dreams, and saw anewerwhiteford pickup truck parked in front of the store, closeto thefrontdoors,andthatwhen hedrove bylaterhesawpolice carsat thestore.


  1. OfficerDeSciato reports that he reviewed video surveillance from the Community Bank, whichislocated near the AceHardware storein Sweet Dreams, andobservedthaton January 24, 2014, at approximately 1:28 a.m., awhitepickup truck with four doors and dark colored molding on thesideof thetruck, drove intothe same complex wheretheAce Hardware and Community Bankare located.Officer DeSciato reportshe wentto the MobilMart neartheAceHardware andobtained video surveillancefromJanuary24,2014, and at approximately 1:23 a.m-,he observed the same whitepickup truck drive in thedirectionof theAceHardware Store.OfficerDeSciatoreportshe sloweddownthe video surveillance and observed thatthe white truck appeared to bea1999 to 2004model ChevroletSilverado,whichwaslifted and havecustomrights,a custom hoodscoop,brush guards andlights thatwere not standard options.


  1. CityofSweet DreamsDispatcher Thundercloud,reportsheutilizedcomputerprogramsto view photographs of the truck observed nearAce Hardware and he sawthe vehicle registration from Wisconsln endedin 5629 and appeared to have aJ_DispatcherThundercloud reports Sand County registratlon showed a vehicle withregistrationABC123 with an

02/05/2014 2



STATEOFW!SCONSIN-VS- nM.Bowers


ownerJimM.Bowers, hereinafter the defendant, and thatthevehicleregisteredwasa 2002 Chevrolet Silverado 2500 white _pickup truck.


  1. Detective Smith reports he spoketothe defendant andthedefendant admittedheownedthepickup truck the officersidentifiedand admittedhewasinSweet Dreams on January 23, 2014, at approximately11:00p.m.The defendant saidnoone else drives his pickuptruck.


  1. DetectiveSmithreportsthedefendantpawnedtwoofthechainsawsthathadbeen stolenfromtheSweet DreamsAceHardware,onJanuary24,2014,inLake Placid, Illinois,andin BoltonLakeBeach,llinois,andthatthedefendantshowedhisWisconsindriverslicensewhenhepawnedthestolenchainsaws.DetectiveAlonzoreportsthatthedefendanthadtextmessagesonhisphonewhichshowedthathewastryingtosell sixbrandnewSTlHL chainsawsonthemorningofJanuary24,2014.


You are preparing for trial. Review the criminal complaint (attached) and I NEED a list of voir dire questions that you would want to ask the jury to ensure that the jury is not biased.



General Questions that Court will ask:

  1. What is your name?
  2. What area of the County do you live in?
  3. What is your profession or employment or former employment (if retired)?
  4. Have you ever served on a jury?
  5. If you have served on a jury, did it reach a verdict?
  6. Do you have any friends or relatives in law enforcement?
  7. Do you know anyone connected to this case?



I NEED at least 5 questions designed to get at general bias, other than those above.

Then I NEED at least 10 questions designed to get at issues that may be present in the case.





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