StateofMinnesota DistrictCourt

CountyofScott 1stJudicialDistrict
14529214 ProsecutorFileNo.
70CR1415102 CourtFileNo.
StateofMinnesota, COMPLAINT
Plaintiff, OrderofDetention
vs.
DENNISERVINCARTERDOB:06/19/1989
241ButterworthSt.A
Mankato,MN56001
Defendant.
The Complainant submits this complaint to the Court and states that there is probable cause to believe
Defendantcommittedthefollowingoffense(s):
COUNTI
Charge:AttemptedMurder2ndDegreeWithIntentNotPremeditated
MinnesotaStatute:609.19.1(1),withreferenceto:609.11.5,609.19.1(1),609.17.1
MaximumSentence:320yearsinprison
OffenseLevel:Felony
OffenseDate(onorabout):08/20/2014
Control#(ICR#):14006298
Charge Description: On or about 8/20/2014, within the County of Scott, State of Minnesota, the
abovenamed defendant did attempt to cause the death of a human being with intent to effect the death of
thatpersonoranother,butwithoutpremeditation.
COUNTII
Charge:Assault1stDegreeGreatBodilyHarm
MinnesotaStatute:609.221.1,withreferenceto:609.221.1,609.11.5
MaximumSentence:320yearsinprison,a$30,000fine,orboth
OffenseLevel:Felony
OffenseDate(onorabout):08/20/2014
Control#(ICR#):14006298
Charge Description: On or about 8/20/2014, within the County of Scott , State of Minnesota, the
abovenamed defendant did assault another, towit: Diaa Ahmed Abdelhakim, and inflict great bodily
harm.
COUNTIII
Charge:FleeinginMV
MinnesotaStatute:609.487.3,withreferenceto:609.487.3
Maximum Sentence: Imprisonment for not more than three years and one day payment of a fine of not
morethan$5,000,orboth.
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Scott County, MN
OffenseLevel:Felony
OffenseDate(onorabout):08/20/2014
Control#(ICR#):14006298
Charge Description: On August 20, 2014 in Scott County, Minnesota, the Defendant did by means of a
motor vehicle flees or attempts to flee a peace officer who is acting in the lawful discharge of an official
duty,andthedefendantknowsorshouldreasonablyknowthesametobeapeaceofficer
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STATEMENTOFPROBABLECAUSE

TheComplainantstatesthatthefollowingfactsestablishprobablecause:

On August 20, 2014, at approximately 11:39 p.m. deputies from the Scott County Sheriffs Office and
officers from the Shakopee Police Department were dispatched to a report of a gunshot Victim at 12364
Chestnut Blvd in Scott County, State of Minnesota. Deputies were advised that the Victim had been shot in
the head and was currently at the Renaissance Festival campgrounds.

Deputy Schultz arrived shortly after Shakopee squads arrived. At the scene was an adult male with blood
on his clothing, face and hands. The male was lying on his back near the bumper of a white pickup truck.
Officers and another male at the scene were rendering aid to the male. The male was later more fully
identified as Diaa Ahmed Abdelhakim (hereinafter Victim). Witnesses at the scene said they were at the
campground getting ready to go to bed when they heard someone yelling, Help me! Help me! Ive been
shot. The witnesses at the scene said they assisted the Victim who was bleeding from the mouth and
appeared to have a possible gunshot wound to the neck area. He was assisted to his current location.

Shakopee Police Officer Goerish was speaking with the Victim who initially made inaudible noises and
could not talk. The Victim made hand gestures when he was unable to speak and nodded his head. The
Victim also wrote in the dirt with his hands when he was unable to speak. After a short time, the Victim
began to talk and stated he was shot by a friend whose name was Dennis Carter, later more fully identified
as DENNIS ERVIN CARTER, DOB: 6/19/89 (hereinafter Defendant). The Victim described the
Defendant as an African American male wearing a black shirt and driving a white car. The Victim stated
he met the Defendant at the SuperAmerica gas station off of Canterbury Road in Shakopee and they were
going to Mystic Lake. The Victim left his vehicle at SuperAmerica and got in his friends white four-door
passenger car. The Victim said they were going to pick up another friend and smoke a bluntprior to
going to Mystic. The Defendant drove to a dirt road near Hwy 41 where they were going to smoke. The
Victim said he then exited the vehicle and was walking away to go smoke when he heard a pop and a few
seconds later realized that he had been shot. The Victim said that after being shot he had a short physical
struggle with the Defendant. The Victim said he then ran from the scene until he located railroad tracks, ran
on the tracks for a while and then hid so the Defendant could not locate him. The Victim said that a short
time later (after running about a mile) he arrived at his current location where 911 was called and medics
began administering first aid. The Victim gave a description of the Defendant as a well-built black male
with a skinny build, 57to 58tall, with a shaved head, no facial hear, and wearing a tight black shirt with a
logo on it. The Victim said he did not know why the Defendant would shoot him and stated his wallet and
cell phone were inside the Defendants car. The Victim believed the gun was also still in the car.

Medics at the scene located what appeared to be an entrance wound on the rear of the Victims neck with
some tissue damage to his throat and did not see an exit wound. The Victim was airlifted to Hennepin
County Medical Center.

Early on the morning of August 21, 2014, Detective Carns interviewed Robert Wells, who stated he was in
his tent with his girlfriend at the Renaissance Festival employee campground when his girlfriend asked if
he had heard someone yelling for help. He did not hear anyone so he went outside his tent and heard
yelling. He then walked to the entrance of the campground where there is a culvert. He located the Victim
walking through some brush yelling for help. He carried the Victim back to the campground and laid him on
the ground. He assisted with his medical care until help arrived. He saw that the Victim was bleeding from
his mouth and nose. He said that the Victim said that he was shot by the Defendant, and the Defendant
was driving a white four-door sedan.

Detective Carns then spoke with Gregory Baker, who stated: He heard a guy scream for help. He went
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over to where Wells was lowering the Victim to the ground. He grabbed his medical bag to assist. He
heard the Victim say that the Defendant shot him and he was driving a white four-door vehicle. He also
heard the Victim state he was walking away when he heard and felt a shot on his face. He ran from the
Defendant.

A perimeter was set up to seal off any incoming and outgoing traffic. Shortly thereafter, Jordan Police Sgt.
Schultz, who was stationed near the perimeter, attempted to make contact with a vehicle matching the
description given by the Victim. Sgt. Schultz approached the vehicle and after instructing the Defendant to
put the vehicle in Park, noticed the Defendant was extremely nervous and was sweating profusely. The
Defendant said You cant stop me, I didnt do anything wrong. When Sgt. Schultz requested the
Defendant exit the vehicle, the Defendant fled from the scene in his vehicle. Sgt. Schultz pursued the
vehicle southbound on Hwy 169, pulled the vehicle over near 150th St and held the Defendant at gunpoint.
The Defendant was on his knees with his hands above his head but was not cooperating with officers
commands. The Defendant stated he did not do anything and asked why officers stopped him. Officers
pointed a taser at the Defendant and ordered him to lie on the ground, at which point he complied and was
placed into custody and transported to the Scott County Jail. Deputies observed what appeared to be
blood on the Defendants long-sleeved black shirt with a Cemblem located on the upper left quad. A
metal wire cutter was located in the Defendants waistband.

The Defendants vehicle, described as a 2005 white Pontiac G6, bearing MN license plate VXV080, was
towed for processing. Before towing, officers were able to observe what appeared to be blood between
the driver side door and on the drivers seat of the vehicle, and large blood spots on the passenger side V-
post of the vehicle. Red droplets were also observed on the front passenger and rear passenger doors.
Deputy Olson opened the trunk and observed a blue tarp which had been laid out with duct tape in place.

On August 21, 2014, Sgt. Ryan was told by the jail sergeant that the Defendant wanted to speak with
someone because he was concerned for his wifes safety. Detectives Carns and Ryan met with the
Defendant at the Scott County Jail. The Defendant was read the Miranda warning and agreed to make a
statement, in which the Defendant said: Last Sunday he flew to Stockton, California and met the Victim
there. On Monday he drove back to Minnesota and arrived on Wednesday; where he dropped off two
duffel bags that the Victim had given him, at 241 Butterworth Street, No. 4, Mankato. Over the past year
the Defendant had been selling marijuana in the Mankato area for the Victim. Six months ago he had sent
a package to the Victim in Stockton, California and it had been intercepted, and the currency was not
delivered to the Victim. The Defendant stated that the Victim told him he was partially responsible for the
loss and it needed to be paid back. The Defendant also stated that two or three months ago he was
jacked (robbed) of money that belonged to the Victim. He stated that he owed the Victim a lot of money
and he is afraid of the Victim.

The Defendant stated that the Victim had threatened him on several occasions and that he needed to pay
off the debt. The Defendant stated while they were in Stockton the Victim told him to buy a tarp, shovel and
gloves, which he did buy on the way back to Minnesota. When he arrived back in Minnesota on
Wednesday he called the Victim. He then met with him at the SuperAmerica off Canterbury Road in
Shakopee.

After picking the Victim up, they then drove to the area of 145th Street. The Victim told the Defendant he
was going to help him dig up some money and guns he had buried there. They parked by the Renaissance
Festival. The Victim got out of the passenger side, and Defendant also got out. The Defendant said the
Victim then taped a tarp down inside the trunk. They walked a short distance and the Victim told him to get
the shovel and he turned and started to walk toward the vehicle when he heard clicking noises. He turned
and saw the Victim point with something under his shirt, which he believed was a gun. He then walked
toward the Victim and they struggled over the possession of a handgun. He was able to get the handgun
away from the Victim. The Victim turned and appeared to be stepping over the gate to the entrance to the
Renaissance Festival. The Defendant then accidentally fired a round from the handgun. The Defendant ran
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back to the drivers side of the vehicle. The Victim then ran back to the vehicle and got inside and a
struggle ensued.

The Defendant was unsure if the handgun fell out on the ground or if it fell inside the vehicle. The Defendant
said he then ran towards Highway 169. After several minutes he went back to the car and started to leave,
but was stopped by Sgt. Schultz. The Defendant stated the reason he left after being stopped was that he
does not trust law enforcement.

On August 21, 2014 officers walked the ditch on Highway 169. Detective Sgt. Pirri located a firearm on the
right-hand shoulder of southbound Highway 169 about 1/4 mile south of 145th Street West. The firearm
was a Davis industries, Model P-32, with serial No. P165444. There were rounds in the magazine and a
round in the chamber.

Sgt. Haas located a beige colored Cadillac parked at the SuperAmerica off Canterbury Road. Sgt. Haas
spoke with an employee named Odovey, who stated that at about 8:50 p.m. on August 20, 2014, a male
had asked to leave the car in the lot as he was having vehicle problems.

On August 21, 2014, officers then went to 241 Butterworth Street, No. 4, Mankato, Minnesota and
executed a search warrant on the residence. Located inside a storage cabinet located off the kitchen were
two gray and black duffel bags. Inside the duffel bags were several vacuum sealed bags containing a
green leafy substance, later identified as marijuana (a Schedule I Controlled Substance). A total of 29
bags were seized.

On August 23, 2014, BCA Special Agent Olson and Detective Carns spoke with the victim at HCMC, who
stated: He has known the Defendant since the 8th grade. They were in California together where they both
bought marijuana. The Defendant owed him $3,500 from previous drug deals. The Defendant agreed to
bring the marijuana back to Minnesota. When they returned, the Defendant called him and told him to meet
him at a gas station in Shakopee. He believed the Defendant would be bringing him his marijuana. Instead
they drove to a remote area where the Defendant said they would meet someone. When he got out of the
car, the Defendant came up behind him and he heard a pop and blood started to come out of his mouth.
He believed the gun had jammed and the Defendant ran back to the car. He ran to the car and got inside
and they fought over the gun. He got outside and ran down the nearby rail road tracks. He laid down on the
tracks and watched, but the Defendant did not drive away. He then ran further down the tracks and yelled
for help. That is when the guy saved him.

A medical examination showed that a bullet entered the back of the victims neck and exited his cheek,
causing damage to his neck, jaw, sinuses, palate, knocking out numerous teeth, damaged his esophagus
and trachea. So far the victim has undergone two surgeries and will need reconstructive surgery in the
future. He cannot eat or swallow normally and will be on a liquid diet for the next six weeks.

Defendant is currently in custody and described as a black male, 510, weighing approximately 175
pounds with brown eyes.


PLEASE TAKE NOTICE: Pursuant to Minn. Stat. 609.49., intentional failure to appear for duly scheduled
court appearances may result in additional criminal charges, and in addition to any arrest warrant that may
otherwise be issued by the Court.
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SIGNATURESANDAPPROVALS
ComplainantrequeststhatDefendant,subjecttobailorconditionsofrelease,be:
(1)arrestedorthatotherlawfulstepsbetakentoobtainDefendant'sappearanceincourtor
(2)detained,ifalreadyincustody,pendingfurtherproceedingsandthatsaidDefendantotherwise
bedealtwithaccordingtolaw.
Complainant AdamPirri ElectronicallySigned:
08/25/201411:38AM 301FullerStreetS
Shakopee,MN553791220

Subscribedandsworntobeforetheundersigned.
NotaryPublicor
JudicialOfficial
Commissionexpires:01/13/2016
ElectronicallySigned:
08/25/201411:39AM
JuliaE.Gramling
RecordsAdmin,CountyofLe
Sueur
301FullerStreetS
Shakopee,MN553791220
NotaryID:6168593
Beingauthorizedtoprosecutetheoffensescharged,Iapprovethiscomplaint.
ProsecutingAttorney ElectronicallySigned:
08/25/201410:57AM
MichaelJ.Groh
AssistantCountyAttorney
2004thAvenueW
Shakopee,MN55379
(952)4968240
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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 200 4th Avenue W, Shakopee, MN 55379 to answer this complaint.
IFYOUFAILTOAPPEARinresponsetothisSUMMONS,aWARRANTFORYOURARRESTshallbeissued.
WARRANT
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 ExecuteNationwide ExecuteinBorderStates
ORDEROFDETENTION
X
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:August25,2014.
JudicialOfficer CarolineH.Lennon
DistrictCourtJudge
ElectronicallySigned:08/25/201411:56AM
SworntestimonyhasbeengivenbeforetheJudicialOfficerbythefollowingwitnesses:

COUNTYOFSCOTT
STATEOFMINNESOTA
StateofMinnesota
Plaintiff
vs.
DennisErvinCarter
Defendant
Clerk'sSignatureorFileStamp:
RETURNOFSERVICE
IherebyCertifyandReturnthatIhaveservedacopyofthisOrderof
DetentionupontheDefendanthereinnamed.
SignatureofAuthorizedServiceAgent:
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