Daniel Erik Hubbard Wilson

*2134943-1*

Co. Atty. Complaint No.: 2134943-1

Court File No.:

Page: 1 of 7

STATE OF MINNESOTA

DISTRICT COURT

COUNTY OF RAMSEY

SECOND JUDICIAL DISTRICT

COURT FILE NO.: _____________
PROSECUTOR FILE NO.: 2134943

State of Minnesota,
Plaintiff,

v.
Daniel Erik Hubbard Wilson
(DOB: 05/23/1987)
2322 Stewart Ave.
St. Paul, MN 55116,

FELONY
CRIMINAL COMPLAINT
Summons
Warrant
Order of Detention
Amended
Certified Juvenile
EJJ

Defendant.
The Complainant, being duly sworn, makes complaint to the above-named Court and states that there is
probable cause to believe that the Defendant committed the following offense(s):
COUNT 1
On or about the 4th day of November, 2014 to the 10th day of November, 2014, in Ramsey County, Minnesota,
the defendant, DANIEL ERIK HUBBARD WILSON, did unlawfully and knowingly violate a harassment
restraining order against a victim under the age of 18, while the defendant was more than 36 months older than
the victim.HU
Said acts constituting the offense of Violation of Harassment Restraining Order in violation of MN Statute:
609.748.6(d)(6)
Maximum Sentence: 5 years or $10,000 fine, or both

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Co. Atty. Complaint No.: 2134943-1

Court File No.:

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STATEMENT OF PROBABLE CAUSE

The Complainant states that the following facts establish probable cause:
On October 6, 2014, the Ramsey County Attorney charged the defendant, DANIEL ERIC HUBBARD
WILSON, DOB: 05/23/1987, with Criminal Sexual Conduct in the First Degree and Criminal Sexual Conduct
in the Third Degree, based on a criminal sexual relationship with a female, MW, DOB 11/13/1997. That
criminal relationship occurred when the defendant was MWs school and personal tennis coach.
The court originally set bail on that complaint in the amount of $20,000 and the defendant was ordered to have
no contact with MW as a condition of release. The defendant posted bail and was released on October 6, 2014.
In addition, on October 6, 2014, the defendant was personally served with a harassment restraining order under
Ramsey County District Court file number 62-HR-CV-14-532. That order prohibits the defendant from having
any contact with MW either directly or through other means.
On October 23, 2014, the Ramsey County Attorney charged the defendant with a felony Violation of a
Harassment Restraining Order, based on continuing contact between the defendant and MW after the defendant
was released from custody. MW reported to police that the defendant continued to have direct contact with her
and that he communicated with her through electronic means. The court set bail on the new charges in the
amount of $25,000. Again the defendant was ordered to have no contact with MW as a condition of release.
The court raised the bail on the original criminal sexual conduct complaint to $50,000. The defendant was again
able to post bail and he was released.
On December 11, 2014, this investigator met with MWs parents. They discovered that MW was still receiving
communications from the defendant. MWs mother stated that she was watching MW while she sent some
emails to her high school on December 10, 2014, from her home in Ramsey County, Minnesota. She looked at
the periphery of the computer screen and noticed that there were two unread draft messages in the open email
account. She knew that this was a method used by the defendant to secretly communicate with MW in the past.
The defendant accessed MWs email account and created draft messages for MW to read. The messages were
never sent through standard email protocol.
MWs father opened the draft messages and recalled that one of the messages said, I love you, I will always
love you, Im going to go away for a while, dont believe your parents, dont believe the police, they are lying
to you, you need to wait for me, we will spend the rest of our lives together. While MWs father was reading
that message, another message popped up in the draft folder. It read, Hola, Im still here, where are you?
While MWs father was still looking at the draft messages, they suddenly disappeared, as if somebody had
entered the account and deleted them.
MWs parents confronted her and she admitted that the defendant was continuing to have contact with her by
communicating with draft email messages, which are never sent, but accessed through her email account by
entering her user name and password.
This investigator met with MW and she confirmed that the defendant has been having contact with her. She
stated that the contact started approximately a week earlier. They used unsent draft emails to communicate with
one another.

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Daniel Erik Hubbard Wilson

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Co. Atty. Complaint No.: 2134943-1

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

(1) arrested or that other lawful steps be taken to obtain Defendants appearance in court; or
(2) detained, if already in custody, pending further proceedings; and that said Defendant otherwise be dealt
with according to law.
COMPLAINANTS NAME:

COMPLAINANTS SIGNATURE:

Paul Cottingham

____________________________________

Subscribed and sworn to before the undersigned this ______ day of _________, 20_____.
NAME/TITLE:

SIGNATURE:

____________________________________

____________________________________

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

Date: 12/12/2014

PROSECUTING ATTORNEYS SIGNATURE:

____________________________________
Name: Steven R. Pfaffe
Assistant Ramsey County Attorney
345 Wabasha Street North, Suite 120
St. Paul, MN 55102
651-266-3222/js
Attorney Registration #169274

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Daniel Erik Hubbard Wilson

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Co. Atty. Complaint No.: 2134943-1

Court File No.:

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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, Defendants arrest or other lawful steps
be taken to obtain Defendants appearance in court, or Defendants detention, if already in custody, pending further proceedings.
Defendant is therefore charged with the above-stated offense.

SUMMONS
THEREFORE YOU, THE ABOVE-NAMED DEFENDANT, ARE HEREBY SUMMONED to appear on the ____ day of
____________, 20___ at _______ before the above-named court at _______________________________________________ to
answer this complaint.
IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued.

Execute in MN Only

WARRANT
Execute Nationwide

Execute in Border States

To the Sheriff of the above-named county; or other person authorized to execute this warrant: I hereby order, in the name of the State
of Minnesota, that the above-named Defendant be apprehended and arrested without delay and brought promptly before the abovenamed 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.

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

Bail: $100,000.00
Conditions of Release:
This complaint, duly subscribed and sworn to, is issued by the undersigned Judicial Officer this ______ day of _____________,
20_____.
JUDICIAL OFFICER:
NAME:
TITLE:

SIGNATURE:
___________________________________

Sworn testimony has been given before the Judicial Officer by the following witnesses:
COUNTY OF RAMSEY Clerks Signature or File Stamp:

STATE OF MINNESOTA
STATE OF MINNESOTA
Plaintiff,
vs.
DANIEL ERIK HUBBARD WILSON
Defendant.

RETURN OF SERVICE
I hereby Certify and Return that I have served a copy of this
COMPLAINT upon the Defendant herein named.
Signature of Authorized Service Agent:
_________________________________

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Daniel Erik Hubbard Wilson

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Co. Atty. Complaint No.: 2134943-1

Court File No.:

FINDINGS OF FACT
Probable cause found that defendant committed the offenses charged.
Ordered defendant's motion to dismiss denied.
Plea of not guilty to all counts entered.
Trial and hearing on all issues set.

Dated: ________________________

_______________________________________
JUDGE OF DISTRICT COURT

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Daniel Erik Hubbard Wilson

*2134943-1*

Co. Atty. Complaint No.: 2134943-1

Court File No.:

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DEFENDANT DATA / CHARGE SHEET ATTACHMENT A

DEFENDANT NAME: DANIEL ERIK HUBBARD WILSON

DOB: 05/23/1987

Defendant alias name(s):

Alias DOB(s):

Daniel Erik Hubbard-Wilson

Daniel Erik Hubbard Wilson

Defendant last known

address:

2322 Stewart Ave.

St. Paul, MN 55116

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

MN14HF6212
305550
460474AH9

OTHER DEFENDANT / CASE IDENTIFIERS:

Fingerprinted?

No

No
Handgun permit?
Location of violation:
IF DRIVING OFFENSE:
Driver's License
Number:
License Plate
Number:
Accident Type:
No injury/no damage
check all that apply
Personal Injury
Blood Alcohol Concentration (BAC):

Yes
Yes (Issuing Agency:

Issuing State:
Issuing State:
Property Damage
Fatality

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Daniel Erik Hubbard Wilson

*2134943-1*

Co. Atty. Complaint No.: 2134943-1

Court File No.:

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FELONY WARRANT AND ORDER OF DETENTION COMPLAINT

CT OFFENSE STATUTE STATUTE
NO DATE
TYPE
NBR

1 11/04/2014
to
11/10/2014

Charge

609.748.6(d)(6)

STATUTE
DESCRIPTION

Harassment; Restraining
Order - Violate - Victim
under 18 & Respondent
more than 36 mos Older

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OFFENSE
LEVEL

MOC

G
O
C

AGENCY
ORI
CN NBR
FUNCTION

N1380

N St. Paul Police Dept.

ORI - MN0620900
CN - 14267320
Charging