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State of Wisconsin
STATE OF WISCONSIN

Circuit Court

Walworth Gounty
CRIMINAL COMPLAINT

Plaintiff,
-VS-

Craig M Seefeldt 534 W Whitewater St Whitewater, Wl 53190 DOB: 09/10/1963 Sex/Race: MAiV Eye Color: Blue Hair Color: Brown Height: 5ft11in Weight: 170 lbs AIias:

DA Case No.: 2013W1002339 Assigned DfuADA'Diane M Donohoo Agency Case No.: 13-034361 Court Case No.: 13CF q88

of the Watworrh County Sheriffs Office, being first duly sworn, on informatisn and belief, states tha*

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Count 1: HOMICIDE BY INTOXTCATED USE OF A VEHTCLE The above-named defendant on sunday, october 13, 2013, in the Town of whitewater, Walworth County, Wisconsin, did cause the death of Melissa J Patrick, by the operation of a vehicle while under the influence of an intoxicant, contrary to sec. g4O.0O(t ya; Wis. Stats., a Class D Felony, and upon conviction may be fined not more than One'Hundred

Thousand Dollars ($'100,000), or imprisoned not more than twenty five (25) years, or both.

And furthermore, invoking the provisions of Wisconsin Statute 343.31(SXc), upon conviction, the department shall revoke the defendant's operating privilege for five (5) years.

Count 2: SECOND DEGREE RECKLESS HOM|C|DE

The above-named defendant on Sunday, October 13, 2013, in the Town of Whitewater, Walworth County, Wisconsin, did recklessly cause the death of another human being, contrary to sec. 940.06(1) Wis. Stats., a Glass D Felony, and upon conviction ,.y be fined not more than One Hundred Thousand Dollars ($tOO,OOO), or imprisoned not more
than twenty five (25) years, or both.
COUNT 3: OPERATING WHILE INTOXIGATED CAUSING INJURY SUBSEQUENT OFFENSE

2ND

AND

The above-named defendant on Sunday, October 13, 2013, in the Town of Whitewater, Walworth County, Wisconsin, as a person having one or more prior convictions, suspensions, or revocations, as counted under s. 343.307 (1)since January 1, .1ggg, did cause injury to AJP DOB 06111/1999 by the operation of a vehicle whlle under the influence of an intoxicant, contrary to s. 346.65(3p) and, contrary to sec. 346.63(2)(a)1
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STATE OF WISCONSIN - VS

Craig M Seefeldt

Wis. Stats., a Class H Felony, and upon conviction may be fined not more than Ten Thousand Dollars ($10,000), or imprisoned not more than six (6) years, or both.
And furthermore, invoking the provisions of Wisconsin Statute 343.31(3)(e), upon conviction, the department shall revoke the defendant's operating privilege for not less than one (1) year nor more than two (2) years. ln addition, the defendant will be required to undertake an alcohol and drug abuse assessment, and follow through with treatment recommendations as a condition of reinstatement.

PROBABLE CAUSE: '1) Your complainant makes this complaint based upon the following, all of which your complainant believes to be reliable. The information in this complaint does not exhaust your complainant's knowledge of this incident.

2) Complainant has reviewed

the repofis of Deputy Juan Orliz, which reflect that on October 13,2013, Deputy Ortiz responded to a report of a vehicle crash on Highway 89, near lsland Road in the Town of Whitewater, Walwotlh County, Wisconsin. Deputy Otliz repofts that upon arrival, he observed a red Chevy Malibu parked diagonally facing southbound in the northbound lane of Highway 89 with severe front end damage. Deputy Ortiz further reports observing a grey Ford Freestyle SUV resting on its roof in the west side ditch line.

3) Deputy Orliz reports that he spoke to a juvenile female identified as AJP, DOB
0611111999. AJP stated that she was a passenger in the SUV and that Melissa J. Patrick, an adult female was driving the vehicle. AJP stated that they were about to pull into her father's residence on Highway 89. AJP stated that they were slowing down to turn into the driveway and the next thing she remembered was a car striking them from behind. AJP stated this caused the SUV to flip over into the ditch. AJP stated that her leg was hurting and Deputy Orliz further repofts observing several cuts on AJP's face.

Deputy Ortiz repods that he spoke to EMS personnel on the scene who reported that the adult driver, Melissa J" Patrick, had been pinned under the SUV, and that they requested additional equipment which they used to extract Melissa Patrick from under the vehicle. Deputy Orliz reports that an EMS worker asked him to contact the coroner as they were unable to revive Melissa Patrick and that she was deceased.

4)

Ortiz reports that he approached an adult male who was identified as Craig M. Seefeldt, hereinafter the defendant. Deputy Ortiz asked the defendant to tell him what happened. The defendant stated that he did not know what happened. He stated that he was just driving down the road and his airbags went off. Deputy Oftiz asked the defendant if he hit another car or if another car hit him. The defendant stated that another car hit him and that it must have been coming from the other direction. Deputy Ortiz reports that he asked the defendant if the defendant struck another vehicle from behind and the defendant stated that he did not because another car hit him. Oftiz reports that he detected a very strong odor of intoxicants coming from the defendant's breath durlng this conversation and noted that the defendant's eyes were glossy. Deputy Orliz reports that the defendant kept adjusting his feet as if to control his balance to prevent him from stumbling. The defendant stated that he had consumed three beers that day and was on his way tc a friend's house. Deputy Ortiz reports that he asked
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5) Deputy

6) Deputy

STATE OF WISCONSIN - VS

CraigM Seefeldt

the defendant to submit to field sobriety tests to make sure it was safe for him to be operating a motor vehicle and the defendant agreed to do the tests. Deputy Ortiz reports that he asked the defendant to submit to the Horizontal Gaze Nystagmus test" Deputy Ortiz reports that he explained the direetions to the defendant and the defendant performed the test. Deputy Ortiz reports observing six out of a possible six clues on the test which Deputy Ortiz reports indicates that the defendant showed impairment. Deputy Ortiz next asked the defendant to perform the walk-and-turn test. Deputy Ortiz explained the directions of the test to the defendant and asked the defendant to stand in a certain position while the directions were given" Deputy Ortiz reports that the defendant got into the starting position and quickly lost his balance stepping to the left two times. Deputy Ortiz continued to explain and demonstrate the remainder of the test to the defendant and then asked hirn to begin the test. Deputy Ortiz reports that the defendant performed the test and exhibited four clues on the test, which indicates impairment. Deputy Ortiz reports that he demonstrated the test to the defendant and askLd him to perform it. Deputy Ortiz reports that the defendant did perlorm the one leg stand test and exhibited two clues on the test which showed impairment. preliminary breath test. The defendant stated that he would perform the test. Deputy Ortiz reports that the defendant provided what he described as a very weak breath sample and that the result of the test was .200%. Homicide by lntoxicated Use of a Vehicle and Operating a Motor Vehicle while lntoxicated causing injury. Deputy Ortiz reporls that the defendant was transported to Lakeland Medical Center, that he read the lnforming the Accused Form to the defendant and that a blood sample was requested from the defendant. Deputy Ortiz reports that the defendant refused a chemical test of his blood. Deputy Ortiz reports that he applied for and obtained a search warrant to obtain a sample of the defendant's blood. Deputy Ortiz advised the defendant that there would be two blood draws taken from hirn. Deputy Ortiz reports that the defendant stated in an aggressive tone, "You are not taking my blood." Deputy Ortiz explained to the defendant that the Deputy had a signed warrant from a Circuit Court Judge allowing the blood draw to occur. The defendant responded that he did not care and that the Deputy was not getting his blood. Deputy Ortiz reports that the defendant continually stated that he was not letting anyone take his blood without the warrant being read to him. Deputy Ortiz repods that he called for assistance asking for additional deputies to arrive on the scene. Deputy Orliz reports that upon arrival of several more law enforcement officers, the defendant's attitude changed and he did allow the blood draw to occur without incident.

7)

B) Deputy Ortiz reports that he asked the defendant to submit to the one leg stand

test.

9) Deputy Ortiz then asked the defendant whether the defendant would submit to a

10) Deputy Orliz reports that the defendant was advised that he was under arrest for

11) Deputy Ortiz reports that he was advised that fellow members of the Walworth County Sheriff's Office were remaining on the scene conducting an investigation into the crash.
recorder recovered from the defendant's vehicle. According to Deputy Jonathan Albrecht who prepared the documents, the data reports reflect that at 2.5 seconds before impact,
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12) Complainant has reviewed pre-crash data reports prepared from the event data

STATE OF WISCONSIN - VS

Craig M Seefeldt

the defendant's vehicle was traveling at 91 mph. Complainant reports that the posted speed limit at that location is 55 mph. Additionally, the event data recorder information
reflects that at 0.5 seconds before impact, the defendant's vehicle was still traveling at rate of 63 mph.
a

a Walworth County Sergeant scene, Melloch observed Melissa Patrick's Deputy who was also on the Sheriff's vehicle while it was at rest on its roof. Sergeant Melloch repofts that the key was still in the vehicle and the engine was still engaged in the drive position. Sergeant Melloch reports that he could visibly see that the blinker indicating the turn was stillfunctioning.

13) Complainant repofts that according to Sergeant William Melloch,

Subscribed and sworn to before me, and approved for filing on:

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Assistant D State Bar No. for Assigned DtuADA' 1018090

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