The Complainant submits this complaint to the Court and states that there is probable cause to believe Defendant committed the following offense(s):

(1)

State of Minnesota District Court

County of Ramsey 2nd Judicial District

0620422924 Prosecutor File No.

62-CR-19-9747 Court File No.

State of Minnesota, COMPLAINT

Plaintiff, Order of Detention

vs.

DEMONE GREGORY IVORY DOB: 03/11/1983 9840 Nicollet Ave. So., #7

Minneapolis, MN 55112 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: Aggravated Robbery-2nd Degree

Minnesota Statute: 609.245.2

Maximum Sentence: 15 years or $30,000 fine or both Offense Level: Felony

Offense Date (on or about): 12/29/2019 Control #(ICR#): 19287456

Charge Description: On or about December 29, 2019, in the County of Ramsey, Minnesota, the defendant, Demone Gregory Ivory, did having knowledge of not being entitled thereto, take from the person or in the presence of another personal property, and used or threatened the imminent use of force against a person to overcome resistance to or compel acquiescence in the taking or carrying away of the property, and while committing the robbery implied, by word or act, possession of a dangerous weapon.

COUNT II

Charge: Assault - 4th Degree - Peace Officer - Demonstrable bodily harm Minnesota Statute: 609.2231.1(c)(1)

Maximum Sentence: 3 years or $6,000 fine, or both Offense Level: Felony

Offense Date (on or about): 12/29/2019 Control #(ICR#): 19287456

Charge Description: On or about December 29, 2019, in the County of Ramsey, Minnesota, the defendant, Demone Gregory Ivory, did physically assault and inflict demonstrable bodily harm upon a peace officer licensed under state law who was effecting a lawful arrest or executing any other duty imposed by law.

State of Minnesota 12/30/2019

(2)

STATEMENT OF PROBABLE CAUSE

On December 29, 2019, officers went to the Metro PCS store located at 825 Maryland Avenue East, Saint Paul, Ramsey County on a robbery. Dispatch had received a text that read, “Help gun on me 825 Maryland hurry.”

Officer Corcoran entered the store through the rear entrance while his partner, Officer O’Halloran, entered through the main front door. Officer Corcoran saw DEMONE GREGORY IVORY (DOB: 03/11/1983) standing behind the counter extremely close to a store employee. Ivory had his hands in his pockets. Upon seeing Officer Corcoran Ivory immediately walked towards the front door at a fast pace. Ivory ran into Officer O’Halloran and retreated back into the store. Officer O’Halloran asked the employee if Ivory was the man with the gun, and the employee nodded in the affirmative.

Ivory refused to follow officers’ directions and broke free when officers tried to place handcuffs on him.

Ivory began to damage a cell phone with his mouth. Officers ended up outside the store with Ivory where they struggled to take him into custody. Ivory yelled, “Somebody call Melvin [Carter]. Somebody call the mayor – I’m getting paid.” Other officers arrived and Ivory was placed in a squad.

Ivory refused to put his feet in the squad when asked. Ivory slid onto the ground and under the squad.

Officers pulled him out from under the squad and stood Ivory up. While pushing Ivory into the squad, Ivory kicked Officer Rhiel’s leg twice and he flailed his head hitting Officer Rhiel’s nose causing it to bleed.

The cell phone Ivory damaged with his mouth was the phone he had received from the employee.

Officers spoke to the store employee about the incident. The employee said Ivory came into the store and said, “Hey, man, I need you to fix my phone.” The employee asked Ivory for his phone number. The

employee was not able to access the account and told Ivory so. Ivory said, “Stop playing with me. I’ve caught a couple bodies.” Ivory put his hand in his jacket and gestured as if it were a gun. The employee tried to reach for an alarm under the counter. Ivory asked the employee, “What are you reaching for? I got something for you,” while gesturing to the hand in his pocket. Ivory said, “I need a new phone and I need a little extra. I need my math right.” The employee feared getting shot so he gave Ivory a phone. Ivory then went behind the counter and stood directly next to the employee. When another customer walked in, Ivory got distracted and the employee was able to send the text to 911.

When the customer left, Ivory went behind the counter again and he said, “I’m trying to get a little extra – you are gonna take the cut for me.” The employee saw the outline of what he thought was a gun in the pocket where Ivory’s hand was. The employee was very scared and thought Ivory was going to shoot him. Just after that the employee saw Officer Corcoran enter the store.

Ivory declined a custodial statement.

(3)

required with respect to the charge or conviction, is guilty of a crime for failure to appear and may be sentenced to not more than one-half of the maximum term of imprisonment or fine, or both, provided for the underlying crime for which the person failed to appear, but this maximum sentence shall, in no case, be less than a term of imprisonment of one year and one day or a fine of $1,500, or both.

(4)

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 Todd Feroni Electronically Signed:

12/30/2019 03:50 PM

Ramsey County, Minnesota Sergeant

367 Grove St St Paul, MN 55101 Badge: 111

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

Prosecuting Attorney Electronically Signed:

12/30/2019 03:18 PM Derek Fitch

Assistant County Attorney 345 Wabasha Street N Suite 120

St Paul, MN 55102 (651) 266-3222

(5)

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).

SUMMONS

THEREFORE YOU, THE DEFENDANT, ARE SUMMONED to appear on ________ ___, _____ at _____ AM/PM 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.

Execute in MN Only Execute Nationwide Execute in Border States

ORDER OF DETENTION

X

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: $75,000.00 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: December 30, 2019.

Judicial Officer Reynaldo Aligada Jr Judge

Electronically Signed: 12/30/2019 04:01 PM

Sworn testimony has been given before the Judicial Officer by the following witnesses:

COUNTY OF RAMSEY STATE OF MINNESOTA

State of Minnesota

Plaintiff vs.

Demone Gregory Ivory

Defendant

LAW ENFORCEMENT OFFICER RETURN OF SERVICE I hereby Certify and Return that I have served a copy of this Order of

Detention upon the Defendant herein named.

Signature of Authorized Service Agent:

(6)

DEFENDANT FACT SHEET

Name: Demone Gregory Ivory

DOB: 03/11/1983

Address: 9840 Nicollet Ave. So., #7

Minneapolis, MN 55112

Alias Names/DOB:

SID: MN02404704

Height:

Weight: 0lbs.

Eye Color:

Hair Color:

Gender:

Race:

Fingerprints Required per Statute: Yes Fingerprint match to Criminal History Record: Yes

Driver's License #:

Alcohol Concentration:

(7)

STATUTE AND OFFENSE GRID

Cnt Nbr

Statute Type

Offense Date(s)

Statute Nbrs and Descriptions Offense Level

MOC GOC Controlling Agencies

Case Numbers

1 Charge 12/29/2019 609.245.2

Aggravated Robbery-2nd Degree

Felony R2283 N MN0620900 19287456

2 Charge 12/29/2019 609.2231.1(c)(1)

Assault - 4th Degree - Peace Officer - Demonstrable bodily harm

Felony A4357 N MN0620900 19287456