State of Minnesota District Court

County of Olmsted 3rd Judicial District

Prosecutor File No. 0550067348
Court File No. 55-CR-21-5573

State of Minnesota, COMPLAINT

Plaintiff, Summons
vs. [X] Amended

ANDRE LEON FRANKLIN DOB: 12/28/1971

8571st St SW
#2
Rochester, MN 55902
Defendant.

The Complainant submits this complaint to the Court and states that there is probable cause to believe
Defendant committed the following offense(s):
COUNT I
Charge: Promotes Prostitution of an Individual
Minnesota Statute: 609.322.1a(2)
Maximum Sentence: 15 years or $30,000 fine or both
Offense Level: Felony
Offense Date (on or about): 09/25/2021
Control #(ICR#): 21041255
Charge Description: On or about September 25, 2021, in the County of Olmsted, Minnesota, Andre Leon
Franklin did intentionally and while acting other than as a prostitute or patron promote the prostitution of
an individual.
COUNT II
Charge: Engages in the sex trafficking of an individual
Minnesota Statute: 609.322.1a(4)
Maximum Sentence: 15 Years or $30,000 fine or both.
Offense Level: Felony
Offense Date (on or about): 09/25/2021
Control #(ICR#): 21041255
Charge Description: On or about September 25, 2021, in the County of Olmsted, Minnesota, Andre Leon
Franklin did, intentionally and while acting other than as a prostitute or patron, engage in the sex
trafficking of an individual.
COUNT III
Charge: Solicit/Induce Individual to Practice Prostitution
1
Minnesota Statute: 609.322.1a(1)
Maximum Sentence: 15 years, $40,000 fine, or both
Offense Level: Felony
Offense Date (on or about): 09/25/2021
Control #(ICR#): 21041255
Charge Description: On or about September 25, 2021, in the County of Olmsted, Minnesota, Andre Leon
Franklin did intentionally and while acting other than as a prostitute or patron solicit or induce an individual
to practice prostitution.

2
 STATEMENT OF PROBABLE CAUSE

The Complainant states that the following facts establish probable cause:

Your complainant is a licensed peace officer employed by the Rochester Police Department. In that
capacity your Complainant has reviewed the police reports relating to Andre Leon Franklin, the above-
named defendant, and the allegations contained therein. Based upon that information, your complainant
believes the following to be true and correct.

On September 25, 2021, Officer Kruger of the Rochester Police Department was dispatched to a
residence in SW Rochester, MN, Olmsted County. Dispatch reported that a a female tried to stab a male
and that she was in the apartment and he was waiting outside. When Officer Kruger arrived, he spoke with
ANDRE LEON FRANKLIN (DOB 12/28/71). Franklin stated that he and Victim (adult female identified in
police reports) had spent the last few hours together and were having a good time before she flipped her
wig. Franklin thought Victim was drunk. Franklin has known Victim for a few days and she has stayed with
him for two. Franklin was unsure of Victim's name and said that she sold her body and Victim was mad at
him. Franklin denied telling Victim to sell her body.

Officers entered the residence and noted that Victim was showering. Victim got dressed and spoke with
Officer Kruger. She told Officer Kruger that she was in treatment, but left. Victim met Franklin and couple of
days prior and brought her home with him. Franklin sold Victim for sex with his upstairs neighbor for $100.
Franklin told her to go upstairs and bring a condom. When Victim went upstairs she opened the door. The
male, later identified as Witness 1 (adult male identified in police reports) was already laying on the bed
with no pants. Witness 1 was supposed to pay Franklin. Victim had sex with Witness 1. Victim said that
was her first time having sex with someone for money. Victim stated that when Franklin gets mad he beats
her up.

While waiting for Victim, Franklin said "I got 5 or 6 girls, one of them is trying to call me right now." He then
said he sells females.

At The ADC, Officer Kruger read Franklin the Miranda rights and he agreed to speak with Officer Kruger.
Franklin stated that Victim asked him if she can make some money by turning a date with the upstairs
neighbor. Franklin told her that if she goes to wear a condom. Franklin saw Victim and Witness 1 flirting on
a previous day. When Victim came back from seeing Witness 1 she was upset and told Franklin that he
sold her. He denied selling Victim. Franklin denied asking Witness 1 for money and said that Witness 1
asked him what he owed him. Franklin admitted that if Officer Kruger went through his phone he would see
a lot of stuff. He gave Officer Kruger his cell phone passcode. Franklin said "it won't about that bitch but it
will be about a whole lot of other bitches." "It is just what I do." Franklin went on to say that he has other
dates he has got to be with. "Dates" is a commonly refers to a sexual exchange between a victim and a
person buying sex. A.K.A a "John." Franklin also said that he turns tricks with other women, but not this one.
"Turn tricks" commonly means the sexual act or buying a person.
3
Witness 1 first sated that Victim randomly walked through the door, sat on his bed and talked to him about
having sex for money. Witness 1 told Victim that he only had $40-$50 and then they had sexual intercourse.
Witness 1 later said that when he got home that night Franklin was on the front porch of his house and
made a comment about sending a girl up to his apartment for $40-50. Witness 1 felt like Franklin meant he
would send a girl up to his apartment to have sex with him for money. Victim arrived a short time later. They
had sexual intercourse but no money was exchanged. After Victim left Witness 1 saw Franklin on the porch
and Franklin made a comment to him about paying his money.

Officer Kolb heard Franklin ask Witness 1 if he had his money. When Witness 1 said no Franklin said
"yeah you do, you better give me my money." Franklin made other utterances about "selling bitches."

PLEASE TAKE NOTICE: YOU MUST APPEAR FOR EVERY COURT HEARING REGARDING THIS
CASE. FAILURE TO APPEAR FOR COURT IS A CRIMINAL OFFENSE AND MAY RESULT IN
ADDITIONAL CRIMINAL CHARGES BEING IMPOSED AND PUNISHED AS PROVIDED IN MINNESOTA
STATUTES SECTION 609.49.

4
 SIGNATURES AND APPROVALS

Complainant requests that Defendant, subject to bail or conditions of release, be:

(1) arrested or that other lawful steps be taken to obtain Defendant's appearance in court; or
(2) detained, if already in custody, pending further proceedings; and that said Defendant otherwise
be dealt with according to law.
Complainant declares under penalty of perjury that everything stated in this document is true and
correct. Minn. Stat. § 358.116; Minn. R. Crim. P. 2.01, subds. 1, 2.

Complainant Madison Stearns Electronically Signed:

Police Officer 06/07/2023 06:10 AM
101 4th Street SE Olmsted County, Minnesota
Rochester, MN 55904-3761
Badge: 2465

Being authorized to prosecute the offenses charged, I approve this complaint.

Prosecuting Attorney Arianna Whitney Electronically Signed:

151 4th Street SE 06/06/2023 11:03 AM
Government Center - 3rd Floor
Rochester, MN 55904
(507) 328-7600

5
 FINDING OF PROBABLE CAUSE
From the above sworn facts, and any supporting affidavits or supplemental sworn testimony, I, the Issuing Officer, have
determined that probable cause exists to support, subject to bail or conditions of release where applicable, Defendant’s arrest
or other lawful steps be taken to obtain Defendant’s appearance in court, or Defendant’s detention, if already in custody,
pending further proceedings. Defendant is therefore charged with the above-stated offense(s).

X SUMMONS
THEREFORE YOU, THE DEFENDANT, ARE SUMMONED to appear as directed in the Notice of Hearing before the
above-named court to answer this complaint.
IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued.

WARRANT
To the Sheriff of the above-named county; or other person authorized to execute this warrant: I order, in the name of the State
of Minnesota, that the Defendant be apprehended and arrested without delay and brought promptly before the court (if in
session), and if not, before a Judge or Judicial Officer of such court without unnecessary delay, and in any event not later than
36 hours after the arrest or as soon as such Judge or Judicial Officer is available to be dealt with according to law.

Execute in MN Only Execute Nationwide Execute in Border States

ORDER OF DETENTION
Since the Defendant is already in custody, I order, subject to bail or conditions of release, that the Defendant continue to be
detained pending further proceedings.

Bail: $
Conditions of Release:

This complaint, duly subscribed and sworn to or signed under penalty of perjury, is issued by the undersigned Judicial Officer
as of the following date: June 7, 2023.

Judicial Officer Pamela King Electronically Signed: 06/07/2023 10:17 AM

Sworn testimony has been given before the Judicial Officer by the following witnesses:

COUNTY OF OLMSTED
STATE OF MINNESOTA

State of Minnesota
Plaintiff LAW ENFORCEMENT OFFICER RETURN OF SERVICE
I hereby Certify and Return that I have served a copy of this
vs. Summons upon the Defendant herein named.
Signature of Authorized Service Agent:
Andre Leon Franklin
Defendant

6
 DEFENDANT FACT SHEET

Name: Andre Leon Franklin

DOB: 12/28/1971
Address: 8571st St SW
#2
Rochester, MN 55902

Alias Names/DOB:
SID: MN94002415
Height:
Weight: 170lbs.
Eye Color:
Hair Color:
Gender:
Race:
Fingerprints Required per Statute: Yes
Fingerprint match to Criminal History Record: Yes
Driver's License #:
Case Scheduling Information: Added Count 3 (MOC: Z1583)
Alcohol Concentration:

7
 STATUTE AND OFFENSE GRID
Cnt Statute Offense Statute Nbrs and Descriptions Offense MOC GOC Controlling Case
Nbr Type Date(s) Level Agencies Numbers

1 Charge 9/25/2021 609.322.1a(2) Felony Z1383 MN0550100 21041255

Promotes Prostitution of an Individual

2 Charge 9/25/2021 609.322.1a(4) Felony Z1303 MN0550100 21041255

Engages in the sex trafficking of an
individual

3 Charge 9/25/2021 609.322.1a(1) Felony Z1583 MN0550100 21041255

Solicit/Induce Individual to Practice
Prostitution