StateofMinnesota DistrictCourt

CountyofWashington 10thJudicialDistrict
CR2014538 ProsecutorFileNo.
82CR142020 CourtFileNo.
StateofMinnesota, COMPLAINT
Plaintiff, Warrant
vs.
ALEXANDERLEECLAUSSENDOB:09/19/1994
4194thStreetS
#2
SaintCloud,MN56301
Defendant.
The Complainant submits this complaint to the Court and states that there is probable cause to believe
Defendantcommittedthefollowingoffense(s):
COUNTI
Charge:Murder3rdDegreeSell/Give/DistributeControlledSubstanceSchedules1and2
MinnesotaStatute:609.195(b)
MaximumSentence:25yearsand$40,000
OffenseLevel:Felony
OffenseDate(onorabout):09/01/2013to10/31/2013
Control#(ICR#):14600836
Charge Description: without intent to cause death, proximately cause the death of T.E.F. by, directly or
indirectly,unlawfullysellingascheduleIcontrolledsubstance
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STATEMENTOFPROBABLECAUSE

TheComplainantstatesthatthefollowingfactsestablishprobablecause:

Your Complainant is a licensed peace officer in the State of Minnesota and is employed by the Woodbury
Police Department. In that capacity, your Complainant states that the following to establish probable
cause:

On 1/11/2014, at approximately 0910 hours, Officers from the Woodbury Police Department and medical
crew from the Woodbury Fire Department were dispatched to 3430 Commonwealth Avenue, Woodbury,
Washington County, Minnesota, 55125, upon report of a 16 year old female, Victim T.E.F., who was not
breathing and unresponsive after reportedly experimenting with a substance similar to LSD or LSD. Upon
arrival, efforts were made to resuscitate the Victim T.E.F. The Victim T.E.F. was transported to Regions
Hospital, where she was pronounced dead.

While at 3430 Commonwealth Avenue, Officers spoke with a female juvenile, who reported that last night,
she and the Victim T.E.F. had taken a substance they thought to be LSD. A.R.H. reported that they
purchased and obtained the substance from another classmate named "Brian", a 17 year-old male who
also attends Woodbury High School. A.R.H. described the LSD as being packaged in a tinfoil wrapper
and containing two small square pieces of paper, which was light pink in color. A.R.H. described how she
and the Victim T.E.F. both took the LSD at approximately 0000 hours the night before, while at the Victim
T.E.F.'s house, by placing it on their own tongues for approximately 20 minutes. Both the Victim T.E.F. and
A.R.H. swallowed the dosage. Cell phones from both T.E.F. and A.R.H. were collected from the scene.
Both cell phones contained images and videos of T.E.H. and A.R.H. under the influence of the substance
they had ingested earlier.

A.R.H. described the Victim T.E.F. as moaning and appeared to be experiencing muscle spasms or
shaking. At approximately 0200 hours, A.R.H. texted female juvenile C.A.D. because A.R.H. felt something
was wrong with the Victim T.E.F. C.A.D. arrived at the residence at approximately 0210 hours. C.A.D. left
the residence at approximately 0330 hours. Between 0800 and 0845 hours, A.R.H. heard Victim T.E.F.
moaning. Victim T.E.F. was breathing but still unresponsive and experiencing muscle spasms. A.R.H. tried
to wake up T.E.F., but then called her father and mother. A.R.H.'s mother responded to the residence and
called 911 at approximately 0910 hours.

On 1/11/2014, a School Resource Officer currently assigned to Woodbury High School determined that an
individual by the name of Brian Phillip Norlander (DOB: 8/19/1996), Defendant Norlander herein, was in
A.R.H.'s sixth hour class at Woodbury High School. The Officer also reviewed various social media sites
and determined that the Victim T.E.F., Norlander, A.R.H., and C.A.D. all "followed" each other on Twitter.
Defendant Norlander was arrested and transported to the Woodbury Police Department. Defendant
Norlander stated that Victim T.E.F. obtained the drug, LSD, from him approximately one week ago.
Defendant Norlander admitted that he gave Victim T.E.F. two tablets that were wrapped in tin foil.
Defendant Norlander admitted that he was in possession of another dose. Officers were able to recover
the suspected narcotic from Defendant Norlander's vehicle. The drug recovered from Norlander's vehicle
was submitted to the Minnesota Bureau of Criminal Apprehension (BCA) for analysis. The BCA
determined that the drug submitted was comprised of 25i-NBOMe and 25C-NBOMe. 25i-NBOMe is a
Schedule I Controlled Substance.

Defendant Norlander stated that he got the drugs from Alistair Curtis Berg (DOB: 10/22/1996), Defendant
Berg herein. Defendant Berg is a student at Woodbury High School. Norlander stated that he purchased
the drugs from Defendant Berg approximately a week and a half ago, and that the transaction took place
before first hour in school. Officers spoke with Defendant Berg. Defendant Berg stated that he knew of the
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Victim T.E.F. Defendant Berg admitted that he possessed the LSD for "a little bit." Defendant Berg stated
that he purchased three tabs of the drug from Sydney Johnson, later determined to be Sydney Claire
Johnson (DOB: 7/1/1996), Defendant Johnson herein. Berg stated that he sold the narcotic to Defendant
Norlander for $30, which is the same price Defendant Berg paid Defendant Johnson for the drugs.
Defendant Johnson also attends Woodbury High School.

Officers spoke with Defendant Johnson. Defendant Johnson initially denied knowing about the LSD
obtained from her by Defendant Berg. Defendant Johnson stated that she knows the Victim T.E.F. died,
and that Defendant Norlander provided the LSD to her. Defendant Johnson stated that Defendant Berg
sold the LSD to Defendant Norlander. Defendant Johnson admitted that she purchased 3 doses of LSD
from an individual named "Cole" in October for a total of $30, and then she sold the LSD directly to Berg
for a total of $30. Johnson believed she sold the drugs to Defendant Berg in October. Defendant Johnson
stated that she knows the drug is not good for you and is a hallucinogenic. When asked if she felt
responsible for the Victim T.E.F.'s death, Defendant Johnson stated yes because she is connected to the
people who gave it to her. Defendant Johnson admitted to being a drug dealer.

Defendant Johnson stated that she has purchased LSD from "Cole" approximately 6 or 7 times, and that
she would purchase 3 or 4 doses per time. Defendant Johnson stated that "Cole" had "a lot" of LSD and
explained that Cole had "sheets" of the drug, but did not know how many doses were on a "sheet."
Johnson stated that Cole's girlfriend, D.M., has been asking people who "ratted" him out. Officers were
able to identify "Cole" as Cole Alexander Matenaer (DOB: 4/11/1995), Defendant Matenaer herein.

On 1/13/2014, Officers arrested Defendant Matenaer while he was driving a black Audi. Inside the vehicle,
Officers located 34 dosage units of a substance that was similar to the other substances already collected.
Officers also confiscated Defendant Maetnaer's cell phone. Defendant Matenaer stated that he received
the LSD from a male by the name of "Alex" in Inver Grove Heights in the early part of December.
Defendant Matenaer stated that "Alex" currently lives in St. Cloud, MN. Defendant Matenaer stated that
"Alex's" number would be in his phone.

Defendant Matenaer admitted that he sold doses for approximately $10 each. When asked how many
doses he sold in Woodbury, Defendant Matenaer stated "a lot." Defendant Matenaer stated that he
personally cut the paper for the doses and would place more than one dose in a piece of tinfoil. Defendant
Matenaer explained that he would place the number of doses ordered from the person in a piece of tinfoil.
Defendant Matenaer stated that he sold to Defendant Johnson. Defendant Matenaer stated that Defendant
Johnson goes to Woodbury High School with his girlfriend D.M. Defendant Matenaer stated that it was
likely his LSD the Victim T.E.F. had received.

Officers requested and listened to the telephone calls in which Matenaer participated while incarcerated in
Washington County Jail. In a telephone call with an individual believed to be his mother on 1/14/2014,
when told "what you did is a crime, Cole," Defendant Matenaer responded, "I know." In another telephone
call on 1/14/2014 with an individual believed to be his girlfriend, D.M., Matenaer stated "it's my fault" and
"Yeah, I sold drugs." In another phone call on 1/14/2014 with an individual believed to be his girlfriend,
D.M., Matenaer stated, "if you see Sydney, just beat her ass". On 2/10/2014, Officers seized D.M.'s
phone. Law enforcement reviewed the data extracted from the phones of both Matenaer and his girlfriend
D.M. Law enforcement discovered numerous communications regarding drugs deals and references to
the death of victim T.E.F. Law enforcement also recovered deleted data from D.M.'s phone, including
messages exchanged with a cell phone believed to be used by Defendant Matenaer's mother. D.M. wrote:
"I don't think he is emotionally able to tell you what happened. Um, he may be charged for murder. A girl he
did not sell to died this weekend and they want to charge him because it came from him even though it
went through other people to the girl."

The drugs recovered from Matenaer's vehicle were submitted to the BCA for analysis. The BCA
determined that the drugs analyzed were comprised of 25i-NBOMe.

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An Officer identified a contact in Matenaer's phone named "Alex" with a phone number of 320-333-1747.
An Officer learned that many, if not all, text messages between Matenaer's phone and the phone
associated with his contact "Alex" had been deleted. Many of the deleted messages consisted of drug talk
about LSD.

On 3/20/14, Officers obtained a court order authorizing the use of a pen register for the phone number
associated with the contact "Alex" in Matenaer's phone. Thereafter, Officers determined that the phone
was registered to Tree Top Nursery and Landscaping in Sauk Centre, MN, and Martin Claussen as the
CEO of that company. Officers determined that Alexander Lee Claussen (DOB: 9/19/94), Defendant
Claussen herein, was the likely user of that phone. Officers conducted a criminal history check of
Defendant Claussen and learned that he had been arrested by the Nebraska State Patrol on 1/25/14 for
possession of 1 oz. of marijuana. The report from the Nebraska State Patrol regarding that incident
identified Defendant Claussen's phone number as the same number, 320-333-1747, identified in
Defendant Matenaer's phone as his contact "Alex."

Thereafter, Officers tracked Defendant Claussen to a residence in St. Cloud, Minnesota, 419 4th St. S.,
St. Cloud, MN. Officers then set up a controlled drug purchase by a Confidential Informant at the same
residence. The Confidential Informant contacted Defendant Claussen and requested to purchase "LSD."
Defendant Claussen directed the Confidential Informant to meet him at the "castle," which the Confidential
Informant knew to be a residence located at 5th Ave. and 4th St. in St. Cloud, consistent with the address
to which law enforcement tracked Defendant Claussen. The Confidential Informant was provided with
narcotics buy funds for the transaction. After meeting Claussen at that location, the Confidential Informant
entered the residence, and came out approximately 1 minute later. The Confidential Informant provided
Officers with the substance he purchased as "LSD," which Officers believed to be 5 doses of 25I-NBOMe.
Thereafter, Officers obtained a warrant to search Defendant Claussen's residence. On 4/3/2014, Officers
searched Claussen's residence and located 305 suspected doses of 25i-NBOMe.

The drugs recovered from Claussen's residence were submitted to the BCA for analysis. The BCA
determined that the drugs analyzed were comprised of 25i-NBOMe.

On 5/14/14, the Final Autopsy Report for Victim T.E.F. was issued by the Ramsey County Medical
Examiner's Office. Victim T.E.F died as a result of complications of 25i-NBOMe toxicity.
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SIGNATURESANDAPPROVALS
ComplainantrequeststhatDefendant,subjecttobailorconditionsofrelease,be:
(1)arrestedorthatotherlawfulstepsbetakentoobtainDefendant'sappearanceincourtor
(2)detained,ifalreadyincustody,pendingfurtherproceedingsandthatsaidDefendantotherwise
bedealtwithaccordingtolaw.
Complainant MichelleMFrascone ElectronicallySigned:5/27/2014
Detective
2100RadioDrive
Woodbury,MN55125
Badge:96
Subscribedandsworntobeforetheundersigned.
NotaryPublicor
JudicialOfficial
Commissionexpires:01/31/2017
ElectronicallySigned:5/27/2014
JaneODonnell
AdministrativeAssistant,County
ofWashington
2100RadioDrive
Woodbury,MN55125
NotaryID:6171653
Beingauthorizedtoprosecutetheoffensescharged,Iapprovethiscomplaint.
ProsecutingAttorney ElectronicallySigned:5/27/2014 ImranAli
POBox6
1501562ndStreetNorth
Stillwater,MN55082
(651)4306115
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FINDINGOFPROBABLECAUSE
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,
pendingfurtherproceedings.Defendantisthereforechargedwiththeabovestatedoffense(s).
SUMMONS
THEREFORE YOU, THE DEFENDANT, ARE SUMMONED to appear on ________ ___, _____ at _____ AM/PM
before the above-named court at 14949 62nd Street N PO Box 3802, Stillwater, MN 55082-3802 to answer this
complaint.
IFYOUFAILTOAPPEARinresponsetothisSUMMONS,aWARRANTFORYOURARRESTshallbeissued.
WARRANT
X
To the Sheriff of the abovenamed 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
36hoursafterthearrestorassoonassuchJudgeorJudicialOfficerisavailabletobedealtwithaccordingtolaw.
ExecuteinMNOnly X ExecuteNationwide ExecuteinBorderStates
ORDEROFDETENTION
Since the Defendant is already in custody, I order, subject to bail or conditions of release, that the Defendant continue to be
detainedpendingfurtherproceedings.
Bail:$
ConditionsofRelease:
ThiscomplaintisissuedbytheundersignedJudgeasofthefollowingdate:May27,2014.
JudicialOfficer RichardIlkka
JudgeofDistrictCourt
ElectronicallySigned:5/27/2014
SworntestimonyhasbeengivenbeforetheJudicialOfficerbythefollowingwitnesses:

COUNTYOFWASHINGTON
STATEOFMINNESOTA
StateofMinnesota
Plaintiff
vs.
AlexanderLeeClaussen
Defendant
Clerk'sSignatureorFileStamp:
RETURNOFSERVICE
IherebyCertifyandReturnthatIhaveservedacopyofthisWarrant
upontheDefendanthereinnamed.
SignatureofAuthorizedServiceAgent:
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