STATE OF WISCONSIN CIRCUIT COURT SHEBOYGAN COUNTY

cMatthew Walsh cg

STATE OF WISCONSIN

CIRCUIT COURT

SHEBOYGAN COUNTY

STATE OF WISCONSIN

CRIMINAL COMPLAINT

-vs-

Mark J Pandolfo 71 S Front Street Middleton, CT 06457 DOB: 01/26/1986 Sex/Race: M/W Alias:

Defendant.

DA Case No.: 2011SB001677 Assigned DA/ADA: Joel Urmanski Agency Case No.: C11-00210 Court Case No.: 2011 CF

Kristine Thurs, Sheboygan Police Department, being first duly sworn on oath deposes and says on information and belief:

Count 1: SOLICITATION OF PROSTITUTES

The above-named defendant on Wednesday, May 11, 2011, in the City of Sheboygan, Sheboygan County, Wisconsin, did intentionally solicit a person Jessica R.B., d.o.b. 10/27/1981 to practice prostitution, contrary to sec. 944.32, 939.50(3)(h) Wis. Stats.

Upon conviction for this offense, a Class H Felony, the defendant may be fined not more than Ten Thousand Dollars ($10,000), or imprisoned not more than six (6) years, or both.

The basis of complainant's charge of such offense is: Official reports prepared by Detective Matthew Walsh and Officer Trisha Saeger both of the Sheboygan Police Department, which reports indicate that on May 10, 2011, Detective Walsh was assigned to investigate an individual on Craigslist who was pandering prostitution by offering one night and stating that he was willing to pay $1,000.00. The Craigslist posting was located in the personals portion of the website and listed Sheboygan, Wisconsin.

Detective Walsh made contact with the complainant and victim, who will be identified for purposes of this criminal complaint as Jessica R.B., d.o.b. 10-27-81. Jessica informed Detective Walsh that she was alerted to the posting on Craigslist by a former relative who had a Craigslist account. When Jessica observed the posting, she contacted Craigslist to file a complaint and get the ad removed. Jessica provided Detective Walsh with a link to the ad.

STATE OF WISCONSIN - VS -.Mark J Pandolfo

CRIMINAL COMPLAINT Page 2

Detective Walsh read the Craigslist posting, which was titled "Looking for Jessica" and included Jessica's last name. The title further indicated "male for woman, 26, Sheboygan." The posting read as follows: "Jessica, I met you in Sheboygan today where you work. You are the most beautiful woman ever. I would love to have one night with you. In return, I am willing to compensate you 1K. If you per chance read this and are interested, please get in contact with me and provide me with a picture to prove that it is you."

Jessica informed Detective Walsh that the original Craigslist posting was taken down, however, the previous evening, May 10, 2011, a new ad replaced it. The new ad was entitled, "Looking for J." and included Jessica's last name. The title further indicated, "male for woman, 24, Sheboygan." The ad read as follows: "Looking for a girl that I met today at work whose name is Jessica. You are by far the sexiest woman I have ever seen. If you happen to come upon this ad, let me know as I will compensate you very well for your time."

Jessica informed Detective Walsh that she worked at a bank in the US Bank building at 604 N 8th Street, City of Sheboygan, County of Sheboygan, State of Wisconsin. She later informed Detective Walsh that an auditing company from Connecticut was in town for a few days during the seek and believed that one of the auditors may be the responsible party for the posting.

Detective Walsh established an e-mail account purporting to belong to Jessica and responded to the Craigslist posting as though he were Jessica. His response to the Craigslist add was made May 10, 2011, at 3:39 p.m.

After responding to the Craigslist posting, Detective Walsh received multiple replies in rapid succession on May 10, 2011, to the account Detective Walsh created. Within one of the e-mail replies, the Craigslist poster, later identified as Mark J. Pandolfo, d.o.b. 0126-86, stated, "To show you that I am serious, I will give you even more money than I stated in my ad. I am only in Sheboygan for a short time and would love to meet up with you." Pandolfo later replied with e-mails advising that he was only in town for a short while before he would return home, was very serious about the ad, stated his first name is Mark, and provided a phone number. Detective Walsh confirmed that Pandolfo was a member of the audit staff at Jessica's place of employment and worked out of Hartford, Connecticut.

STATE OF WISCONSIN - VS -.Mark J Pandolfo

CRIMINAL COMPLAINT Page 3

After corresponding via e-mails with Pandolfo, who discussed the sexual acts he was willing to perform on Jessica and inquired what acts Jessica would be willing to perform on him or would request, phone contact was ultimately made between Pandolfo and Officer Trisha Saeger of the Sheboygan Police Department, who aided in an undercover capacity by purporting to be Jessica. The phone contact was made on May 11, 2011. Within the first phone contact, in which Pandolfo made phone contact with Officer Saeger, Pandolfo identified himself as Mark and stated that he was at a restaurant in Sheboygan with his co-workers and would be leaving shortly. Pandolfo stated that he would need to go back to his hotel room to change before meeting. It was ultimately determined that at approximately 9:00 p.m. on May 11, 2011, Officer Saeger, who Pandolfo believed was Jessica, would arrive at Pandolfo's hotel, the Blue Harbor Resort in the City of Sheboygan, County of Sheboygan, State of Wisconsin, and contact Pandolfo who would meet her at her vehicle. The two would then make their way to the Grand Stay Hotel in the City of Sheboygan.

Officer Saeger traveled in an undercover capacity to the Blue Harbor Resort. At the Resort, Officer Saeger, posing as Jessica, made a phone call to Pandolfo. Pandolfo stated that he was in the front lobby area of the hotel. Officer Saeger advised that she would be pulling up to the hotel in a black vehicle.

Detective Walsh was in the lobby at the Blue Harbor Resort keeping visual contact on Pandolfo, who he identified based on photos Pandolfo sent to the e-mail account Detective Walsh created and purported to belong to Jessica. After Officer Saeger, in her undercover capacity as Jessica, placed a phone call to Pandolfo, Detective Walsh observed Pandolfo exit the Blue Harbor Resort. Pandolfo walked towards Officer Saeger's undercover vehicle. As Pandolfo got to the front bumper of Officer Saeger's undercover vehicle, Detective Walsh placed him into police custody.

Pandolfo was transported to the Sheboygan Police Department where Detective Walsh provided him with his Miranda Rights. Pandolfo indicated that he understood his Miranda Rights and was willing to waive them to answer questions. Pandolfo told Detective Walsh that he was in Sheboygan on business from Connecticut working at HSA Bank where he met Jessica. Pandolfo advised that he hardly spoke with Jessica, but was attracted to her. He admitted that he placed the two ads on Craigslist, either Monday or Tuesday, soliciting Jessica for sex and offered to pay her money. He also admitted to writing

STATE OF WISCONSIN - VS -.Mark J Pandolfo

CRIMINAL COMPLAINT Page 4

e-mails offering sex for money. Pandolfo acknowledged knowing that what he did was against the law. He further told Detective Walsh that he has done this before and nothing has happened.

Subscribed and sworn to before me this _____ day of May, 2011 and approved for filing:

______________________________ Assistant District Attorney Sheboygan County, Wisconsin

_____________________ Complainant

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