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State of Minnesota
County of Ramsey
District Court
2nd Judicial District
Prosecutor File No.
Court File No.
State of Minnesota,
17-317528
62-CR-17-2144
COMPLAINT
Plaintiff,
Summons
vs.
MICHAEL SHANE DEAL DOB: 07/16/1970
830 Capwood Avenue
Litchfield, MN 55335
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: Prostitution - Engage in Prostitution in a Public Place (Patron)
Minnesota Statute: 609.324.2(1)
Maximum Sentence: 0 to 1 year imprisonment; $0 to $3000 fine.
Offense Level: Gross Misdemeanor
Offense Date (on or about): 03/07/2017
Control #(ICR#): 17049610
Charge Description: Defendant, while acting as a patron, did intentionally engage in prostitution with an
individual 18 years of age or older while in a public place.
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STATEMENT OF PROBABLE CAUSE
The Complainant having reviewed the applicable reports believes the following facts to be true:
On March 7, 2017 at approximately 11:30 a.m., St. Paul police conducted an undercover vice detail at a
hotel located in the city of St. Paul, Minnesota. As a part of the detail, St. Paul police posted an
advertisement on an internet web site advertising sexual services in exchange for money. The ad was
placed in a section of the website often used for advertising prostitution services. The ad used slang or
street language to explain the offer. Shortly after the ad was posted, St. Paul police received several calls from men inquiring as to when the
female pictured in the ad was available and how much she charged for specific sexual services. Michael
Shane Deal, dob. 7/16/70, defendant herein, was one of the males that responded to the ad posted by the
St. Paul Police Department. Defendant began a text conversation with an undercover St. Paul police officer at approximately 10:00 a.m.
on March 7, 2017. In that conversation defendant asked about a time and place they could meet and
indicated specific sexual preferences. The officer replied it was a good time now and asked if $100 for a
half hour would work. Defendant replied yes and they arranged to meet after defendant's work meetings. Once near the hotel, defendant was given the exact address of the hotel and the room number. Defendant
arrived at the hotel room at approximately 3:00 p.m. Once at the door, defendant and the officer exchanged
a hug. Defendant then tried to kiss the officer before removing his suit coat, socks and shoes. The officer
then inquired whether defendant was willing to wear a condom. Defendant responded that he would wear a
condom. The officer then directed defendant to place the $100 "donation" on the dresser which he did. The officer then gave a verbal and non- verbal signal to the arrest team that she had a sex for money
agreement. Defendant was subsequently arrested. The entire audio exchange between defendant and the
undercover officer was recorded by the St. Paul Police Department as a part of the undercover detail.
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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
Nikkole M Peterson
Sergeant
367 Grove St
St Paul, MN 55101
Badge: 116
Electronically Signed:
03/24/2017 08:52 AM
Ramsey County, MN
Being authorized to prosecute the offenses charged, I approve this complaint.
Prosecuting Attorney Maria DeWolf
Assistant St. Paul City Attorney
15 Kellogg Blvd W., Suite 500
St Paul, MN 55102
(651) 266-8740
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Electronically Signed:
03/23/2017 02:19 PM
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 on June 9, 2017 at 8:15 AM before the
above-named court at 15 W Kellogg Blvd, St Paul, MN 55102 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.
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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: March 27, 2017.
Judicial Officer
Joy D. Bartscher
Electronically Signed: 03/27/2017 09:43 AM
Sworn testimony has been given before the Judicial Officer by the following witnesses:
COUNTY OF RAMSEY
STATE OF MINNESOTA
State of Minnesota
LAW ENFORCEMENT OFFICER RETURN OF SERVICE
Plaintiff
I hereby Certify and Return that I have served a copy of this
Summons upon the Defendant herein named.
vs.
Signature of Authorized Service Agent:
Michael Shane Deal
Defendant
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