Criminal Complaint For Christian James Enwright

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STATE OF WISCONSIN CIRCUIT COURT KENOSHA COUNTY

STATE OF Wisconsin CRIMINAL COMPLAINT


Plaintiff,

vs. DA Case #: 2024KN002058

CHRISTIAN JAMES ENWRIGHT Agency Case #: KPD 2024-00005295


5710 32nd Avenue
Kenosha, WI 53144 Mandatory date: 05/15/24 at 1:00PM
DOB: 11/23/1994
Sex/Race: M/W
Eye Color: Blue
Hair Color: Brown
Height: 5 ft 11 in
Weight: 185 lbs
Alias: Also Known As Christian J
Enwright
Defendant. For Official Use

The undersigned, being first duly sworn, states that:

Count 1: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 2: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 3: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.
Count 4: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 5: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 6: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 7: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 8: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 9: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 10: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 11: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 12: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 13: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 14: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.
Count 15: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 16: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 17: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 18: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 19: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.
Count 20: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 21: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

Count 22: DISORDERLY CONDUCT

The above-named defendant between June of 2023, and February of 2024, in the City of Kenosha,
Kenosha County, Wisconsin, while in a public or private place, did engage in violent, abusive,
indecent, profane, boisterous, unreasonably loud or otherwise disorderly conduct, under
circumstances in which such conduct tended to cause or provoke a disturbance, contrary to sec.
947.01(1), 939.51(3)(b) Wis. Stats., a Class B Misdemeanor, and upon conviction may be fined not
more than One Thousand Dollars ($1,000), or imprisoned not more than ninety (90) days, or both.

PROBABLE CAUSE:

On February 5, 2024, Kenosha Police Department Detective Kunz was assigned to investigate an
anonymous report made to the Kenosha County Department of Family Services (DCFS) on
February 2, 2024.

The information provided to DCFS was that Kenosha Unified School District (KUSD) was made
aware of an inappropriate texting relationship between a 14-year-old female student identified for
the purposes of this complaint as KG and her teacher at Kenosha School of Technology (KTEC)
West Middle School, Christian Enwright, hereinafter referred to as the Defendant. Per the report,
school staff had already spoken to KG, who admitted to being friends with the Defendant on
SnapChat and TikTok since June of 2023, and conversing with the Defendant daily since
Christmas of 2023. However, she denied anything inappropriate ever occurred.

Per the report, KG was then released from the school office, with her cell phone still in her
possession, and then deleted all the communication between her and the Defendant. KG’s mother
Megan G. was notified, at which time Megan requested staff take possession of KG’s cell phone,
which they did. The Defendant was then placed on administrative leave.

On February 6, 2024, Detective Kunz made contact with KG’s mother Megan, who confirmed the
information provided in the DCFS report. Megan also provided a screen shot she found in KG’s
phone of a SnapChat conversation between KG and “Christian Enwright,” which took place on
February 4, 2024, at 12:13AM, which is the last day of their communication (COUNT 22). It reads,
in part, as follows:

KG:
omggggggg
are you mad at me

Christian:
kinda

KG:
why????

Christian:
you know why
[name of male classmate with the first initial C]

KG:
i don’t like him.
i tell you stuff all the time how would i like him

Christian:
okay

KG:
why do you think that

On February 7, 2024, Megan gave Detective Kunz permission to forensically download KG’s cell
phone, which was still in the possession of KTEC West. On February 8, 2024, Detective Kunz
retrieved KG’s cell phone from KTEC West and brought it to the Kenosha Police Department to be
forensically downloaded.

In reviewing the download of KG’s cell phone, Detective Kunz located images which were saved
from KG’s SnapChat conversations with the Defendant. These images included “selfies” the
Defendant took of himself and sent to KG, which also included text consistent with the Defendant
responding to dialogue or images or videos sent to him by KG. (COUNTS 3-21). Based on
Detective Kunz’s training and experience, he is familiar with SnapChat and knows that people who
often send each other short video clips or image with text on it as a way to communicate, in
addition to written messages. Detective Kunz also located two images sent to KG by the
Defendant of his lower body, which also included text. (COUNTS 1-2) Detective Kunz was able to
locate the creation date and time of the images on KG’s cell phone, but was unable to determine
which of KG’s messages/videos/images that the Defendant’s photographs were in response to.

Those images are as follows:


Count 1:

Date created: Friday, December 29, 2023, at 9:27:48 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Count 2:

Date created: Friday, December 29, 2023, at 8:37:05 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat

Context: KG advised multiple friends via SnapChat that the Defendant liked a particular pair of
shorts she wears and has commented on them in the past. In one video, KG tells her friend that
she is going to wear them and hopes he likes it.
Count 3:

Date created: Sunday, January 7, 2024, at 10:53:33 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Count 4:

Date created: Sunday, January 7, 2024, at 11:05:11 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Count 5:

Date created: Sunday, January 7, 2024, at 11:13:41 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Count 6:

Date created: Wednesday, January 10, 2024, at 10:44:36 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Count 7:

Date created: Thursday, January 11, 2024, at 8:39:08 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Count 8:

Date created: Thursday, January 11, 2024, at 8:56:36 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Count 9:

Date created: Monday, January 15, 2024, at 8:34:17 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Count 10:

Date created: Saturday, January 20, 2024, at 1:18:59 AM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Emojis: Four emergency light emojis
Count 11:

Date created: Saturday, January 20, 2024, at 1:40:37 AM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat

Context: During her forensic interview on February 29, 2024, KG told Ms. Kohl about a
conversation she and the Defendant had, where the Defendant told her how, in another universe,
he thought they would be together. He also told her things like “I think about you all the time” and “I
miss you.”
Count 12:

Date created: Saturday, January 20, 2024, at 1:40:37 AM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat

Context: During her forensic interview on February 29, 2024, KG told Ms. Kohl how the Defendant
would compliment her body. If she sent him a picture that included her legs, he would bring that up
and say those pictures were his “fave.”
Count 13:

Date created: Saturday, January 20, 2024, at 1:40:37 AM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat

Context: During her forensic interview on February 29, 2024, KG told Ms. Kohl how the Defendant
once stated that they were in the “same boat together” because he slept with his girlfriend’s mother
when he was in middle school. KG said he brought this up one day and mentioned how “that’s why
it would be okay.” KG believed the Defendant was referring to them sleeping together. She advised
this conversation took place approximately a month prior to her forensic interview.
Count 14:

Date sent: Thursday, January 25, 2024, at 8:40:25 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Emojis: Fifteen emergency light emojis
Count 15:

Date created: Thursday, January 25, 2024, at 8:57:47 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Emojis: Four emergency light emojis
Count 16:

Date created: Thursday, January 25, 2024, at 11:02:55 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Emojis: Seven emergency light emojis, a face blowing a kiss emoji
Count 17:

Date created: Thursday, January 25, 2024, at 11:15:09 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Count 18:

Date created: Thursday, January 25, 2024, at 11:16:53 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Emojis: Two face blowing a kiss emojis
Count 19:

Date created: Thursday, January 25, 2024, at 11:20:41 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Count 20:

Date created: Friday, January 26, 2024, at 11:21:56 PM CST


From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Emojis: Smiling face with heart eyes emoji, emergency light emoji
Count 21:

Date created: Sunday, January 28, 2024, at 8:56:14 PM CST


:56:14 PM CST
From: Christian Enwright, the Defendant
To: KG
Via Snapchat
Detective Kunz also located 603 deleted SnapChat messages from the Defendant to KG between
January 26, 2024, and February 1, 2024. These messages occurred throughout the day, including
as late as 12:19 AM and as early as 6:37 AM. Although the date and time of the messages were
visible, the content of the messages were not due to them being deleted.

On February 16, 2024, KG was forensically interviewed at the Kenosha County Child Advocacy
Center by Taume Kohl. KG was reluctant to provide any information, but did state that she and the
Defendant were friends on SnapChat and TikTok. She and the Defendant would use TikTok
sporadically to share videos and make small talk, but mostly communicated via SnapChat. KG
advised that messages between her and the Defendant began to occur more often around
December of 2023. KG admitted to deleting the Defendant’s SnapChat account from her phone the
day this was reported to her school because she was afraid of getting in trouble.

When asked about her messages with the Defendant, KG mentioned how the Defendant recently
got up with her because he thought she liked another guy named [same name as in the SnapChat
messages above] (Count 22). When asked how she felt about that, KG said, “it wasn’t right.”

Detective Kunz then spoke to Megan and coordinated with her in order to obtain all SnapChat data
from KG’s account via a user request, which Detective Kunz knows based on his training and
experience to be a better way to get SnapChat data rather than via warrant. Megan did this and
forwarded the data to the Kenosha Police Department. Detective Kunz reviewed this information
and observed that KG became SnapChat friends with the Defendant (enwright23) on June 13,
2023, and that KG deleted the Defendant from her account on February 1, 2024.

On February 29, 2024. KG was once again forensically interviewed by Ms. Kohl after asking her
mom if she could go back to provide more information. KG advised that things started between her
and the Defendant when the Defendant would complement her. He would tell her, “you look cute”
or “you look good.” He would also complement her on her eyes and legs. Their hugs also changed
from normal hugs to hugs around the waist.

KG said her and the Defendant would message all day, but not during school hours. The constant
messaging started at the end of November of 2023 or possibility in December of 2023. KG advised
that they discussed not telling people about their communications, but that he never said it directly,
only “implied it.” The Defendant would also, once a week, delete KG off of his SnapChat. He did
this because she was “getting too high up on his friend’s list.”

KG mentioned how the Defendant would get mad at her when he found out she was talking to
another guy from school. KG said one time she was talking about to him about it and he told her
she “better watch what she said.” The Defendant also got mad at KG when she mentioned how
another teacher was cute.

KG denied sending the Defendant any nude photographs or videos, or being sent any nude
photographs or videos by the Defendant. She did mention one picture she got from the Defendant
where he was sitting on the couch with a hoodie. KG said he didn’t have any pants on, only a
towel, and when she asked what he was doing, the Defendant replied, “I can’t say.”

On March 26, 2024, Detective Kunz interviewed the Defendant at the Kenosha Police Department
with his wife Leah Enwright present in the interview room. The Defendant advised he was aware of
the investigation and denied he had done anything wrong. The Defendant admitted to
communicating with KG via SnapChat. He said at first it was small talk, but acknowledged that the
frequency of their communication grew over the past few months. He said they would both
exchange still images and short video clips on SnapChat. Detective Kunz then showed the
Defendant the images Detective Kunz located on KG’s phone that appeared to be of the
Defendant (COUNTS 1-21). The Defendant admitted that those were of him and that he sent them
to KG, but said he was only trying to raise her confidence and make her feel better about herself.

Detective Kunz referred his investigation to the Kenosha County District Attorney’s Office on April
23, 2024.

In summary, between June of 2023, and February of 2024, while the Defendant was a 7th Grade
teacher at KTEC West Middle School, he communicated with a 13-14 year old student of his via
SnapChat. That communication occurred on a daily basis, so frequently to the point that in only a
one week period, the Defendant sent 608 messages to KG. These messages occurred on school
days and weekends, throughout the day, including as late as 12:19 AM and as early as 6:37 AM.
These communications included messages, short videos, and photographs, some of which were
sexually charged (COUNTS 1-21). Based on Detective Kunz’s training and experience, he
recognized the Defendant’s behavior as manipulation, otherwise known as grooming. This
included developing trust with KG, giving her special attention, developing secrets, desensitizing
and normalizing sexual topics, and pushing personal boundaries. This behavior corrupts the public
morales and outrages the sense of public decency.

Your complainant is an attorney with the Kenosha County District Attorney’s Office, who bases her
knowledge of this complaint on:

➢ The official law enforcement agency reports of the Kenosha Police Department prepared by
Detective Kunz, which reports were prepared in the normal course of law enforcement
duties;
➢ Statements by citizen informant(s) KG, Megan G.; who are eyewitnesses to the facts they
relate;
➢ Statements by the defendant, which were made contrary to his penal interests;

Subscribed and sworn to before me on 05/10/24 Electronically Signed By:


Electronically Signed By: Alexandra K Smathers
Jessica L. Krejcarek Complainant
Assistant District Attorney
State Bar #: 1083091

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