Todd s. Whipple, Chief Deputy County Attorney Gallatin County Attorney's Office Judge Guenther Memorial Center 1709 West College Bozeman, Montana 59715 Telephone: (406} 582-3745 GALLATIN CCU~HY CLEr:K OF DISTf{ICT C8URT.!:::~i HFER ERt.'iOON 2012 OCT 18 Prl 3 53 F1LEt1t MONTANA EIGHTEENTH JUDICIAL DISTRICT COURT,G.&tUzTIN COUNTY l:le pun THE STATE OF MONTANA, v. Plaintiff, SHANE LEONARD JAEGER, Defendant. * * * * * * * * * * * * COMES NOW Todd S. Whipple, Chief Deputy County Attorney, and being first duly sworn upon oath, deposes and says as follows: 1. That your affiant is a Deputy Gallatin County Attorney, and by law one of the attorneys to prosecute criminal matters in the State of Montana. 2. Pursuant to a report of investigation prepared by Detective Robert Vanuka of the Bozeman Police Department and a report of investigation prepared by Officer Jonathan Ogden of the Bozeman Police Department, your affiant is aware of the following. 3. On or about October 3, 2012, at approximately 0113 hours, Jacob Hogan reported a male wearing a ski mask, gray coat with a hood and black pants had brandished a firearm and demanded money from him while he was working at the Loaf and Jug located at 1910 West Main Street, Bozeman, Montana. Hogan reported the suspect racked the weapon, which caused a 9mm round to be ejected.
Hogan stated he believed the suspect racked the firearm to show that it was real. Hogan stated the suspect used a black backpack to prop open the door of the Loaf and Jug and that the suspect exited the store on foot without any money. 4. Officer Ogden responded to the area of the Loaf and Jug and observed an SUV driving at a high rate of speed traveling southbound through the alley on the west side of South 19 th Avenue between Babcock and Olive Street and south of the Loaf and Jug. Officer Ogden followed the SUV and attempted to catch up to it as it traveled west on Koch and into the Wagon Wheel Trailer Park located on 23 w Avenue. Officer Ogden observed that the SUV was a Red Ford Explorer and had a Montana License Plate number 642254A. Officer Ogden learned that the Explorer was registered to Naomi Huidekoper who resided at 2220 West Main Street in Bozeman, Montana. 5. Officer Ogden activated his emergency lights and initiated a traffic stop. The Explorer came to a stop outside of Trailer 92 and the driver, later identified as Shane Leonard Jaeger (hereinafter the defendant), exited the driver's side door and began to run westbound. Officer Ogden observed the defendant was Caucasian, wearing black pants and a gray coat and matched the description of the robbery suspect. Officer Ogden observed that the defendant was the sole occupant and drew his Taser and instructed the defendant to stop. The defendant looked behind him and ran between Trailer 92 and Trailer 93. Officer Ogden ran after the defendant through a creek that divides the 2220 West
Main Street trailer park and the 2405 West College Street trailer park. As Officer Ogden came around a corner of a trailer, he lost sight of the defendant. 6. Officer Ogden crossed back over the creek and back into the 2220 West Main Street Wagon Wheel Trailer Park and continued to walk north while attempting to locate the defendant. Officer Ogden walked between Trailer 96 and Trailer 97 to the driveway that runs parallel to 23 rd Avenue and began walking toward his patrol vehicle. Officer Ogden heard the sound of movement through the bushes along the creek and shined his flashlight at the area and observed a male wearing all black clothing walking quickly up the west bank of the creek. Officer Ogden again announced himself a police officer and commanded the defendant to stop. The defendant glanced at Officer Ogden and again began running north along the west side of the creek. 7. Officer Ogden again ran after the defendant and instructed him to stop numerous times. Officer Ogden continued running after the defendant and eventually observed the defendant trip. Officer Ogden drew his pistol and instructed the defendant not to move. Officer Bryan Moen of the Bozeman Police Department arrived on scene and secured the defendant to the ground. The defendant was detained and transported to the Gallatin County Detention Center. a. Officers on scene observed a black backpack, a knit hat and/or ski mask, a black glove and bullets and casings on the passenger seat and center console of the Explorer in plain view.
The Explorer was secured and transported to the Montana State University impound lot. 9. Officer Marek Ziegler of the Bozeman Police Department and Officer Moen, with their K-9 partners Taco and Nyah, performed a search for evidence. During the K-9 search, a black fingerless glove was found in the alley between 19 th Avenue and 20 th Avenue, approximately two blocks from the Loaf and Jug. Officer Tracy Senenfelder of the Bozeman Police Department searched the area and located a water soaked jacket lying on the ground adjacent to 2405 West College, Trailer 3, approximately 100 feet from the location the defendant was taken into custody. 10. On or about October 3, 2012, at approximately 0308 hours, Detective Vanuka conducted an interview with Sam Hanssler at the Law and Justice Center. Hanssler stated he walked into the Loaf and Jug earlier in the night to purchase a six pack of beer. Hanssler stated he did not see any vehicles parked behind the Loaf and Jug or vehicles appearing to be waiting. Hanssler reported as he entered the store, he observed a black backpack keeping the door open. Hanssler stated as he entered the store he observed a male standing adjacent to the cash register pointing a weapon at the cashier. Hanssler estimated he was approximately seven feet away from the male and described him as Caucasian, 5'9" in height with an average build, wearing a dark colored ski mask, light to medium gray hooded sweatshirt and black pants. Hanssler stated he observed the male was holding a small black sub compact semi automatic weapon with a banana clip in both of his hands.
Hanssler stated the male turned toward him, sweeping him with the barrel of the weapon before the male left the store and took the backpack. 11. On or about October 3 J 2012, at approximately 0323 hours, Detective Vanuka conducted an interview with Charles Vanausdoll at the Law and Justice Center. Vanausdoll stated he was inside the Loaf and Jug when a male entered the store. Vanausdall stated the male was wearing a black "hoodie", a mask that covered his mouth and nose and a gray coat. Vanausdall stated the male brandished a gun and told the cashier to "give me the money". Vanausdall stated he observed the male point the weapon at the cashier, manipulate the weapon with both hands and eject a round from the weapon. Vanausdall described the weapon as a black and/or gray machine gun pistol approximately 12 inches in length. Vanausdall stated another male entered the store and the male with the gun exited the store. Vanausdall indicated the male did not enter or leave in a vehicle after exiting the store. Vanausdoll stated he walked to the counter and called the police. 12. On or about October 3, 2012, Detective Vanuka conducted an interview with Hogan. Hogan stated he was the night cashier for the Loaf and Jug the early morning of October 3, 2012, when a male entered the store wearing a heavy coat, carrying a black duffle bag and holding a gun in his right hand. Hogan stated the male left the duffle bag at the door and approached Hogan, stopping approximately two feet from him. Hogan stated he could see that the male was wearing a heavy gray jacket, a hood,
synthetic fabric ski mask that covered his mouth and nose and heavy fabric black pants. Hogan stated the male stated "give me the money". Hogan stated at first he did not think it was "real" and thought the gun was fake. Hogan stated the male did two things that convinced him the gun was real. Hogan stated the male pressed the barrel of the gun against his chest when he activated the alarm instead of opening the cash register and the male, using his left hand, racked the slide that ejected a live round. Hogan stated the male slapped the cash register with his left hand. Hogan stated he did not give the male any money and the male turned around and left the store taking the duffle bag. 13. On or about October 3, 2012, Detective Vanuka conducted an interview with the defendant at the Gallatin county Detention Center. Miranda, Detective Vanuka advised the defendant of his rights per to which the defendant waived his rights and agreed to speak with Detective Vanuka without an attorney. The defendant denied any involvement in the robbery of the Loaf and Jug and claimed he was fishing for Bass at the Bozeman Ponds prior to being stopped by officers. The defendant stated he parked in the mall parking lot adjacent to Macy's and stated he was by himself and spoke with no one while at the ponds. The defendant estimated he was at the ponds for approximately two hours and stated he was on his way home when he was stopped by officers. 14. The defendant stated he has a warrant from the State of Florida and did not want to answer to the charges and as a result, ran from the officers. The defendant stated he ran and jumped
into a river and across a creek. The defendant stated he was wearing a black pair of Dickee pants, a black tank top, a black shirt and Nike athletic shoes. The defendant den:ed wearing a jacket or discarding any form of clothing while he ran from officers. Detective Vanuka requested verbal and wr"ltten consent from the defendant to search the Explorer but the defendant refused. 15. Detective Vanuka traveled to 2220 West Main Street, Trailer 92 and conducted an interview with Naomi Huidekoper. Huidekoper stated she is the girlfriend of the defendant and mother of the defendant's child. Huidekoper is the sole registered owner of the Explorer that the defendant was driving when he was stopped by officers. Huidekoper gave Detective Vanuka written and verbal consent to search the Explorer. Huidekoper stated the defendant does fish at the ponds but stated he did not fish the night of the incident. Huidekoper stated the defendant was watching television in the living room before she went to bed at approximately 2230 hours. Huidekoper stated it was her understanding that the defendant did not have plans and was not going out that evening. 16. Detective Vanuka and Officer Joel Hiester of the Bozeman Police Department traveled to the Montana State University impound lot and performed a search on the Explorer. Detective Vanuka located and seb;ed a black knit, fingerless glove that matched the glove found by Officer Ziegler and Officer Moen, a knit cap, a variety of bullets and casings and a black ES
backpack. Officer Senenfelder contacted Huidekoper who confirmed she does not own a black ES backpack. 16. Detective Vanuka applied for and received a search warrant for the black backpack. In the backpack, Detective Vanuka found a black Intratec 9mm semi-automatic assault type pistol with a round in the chamber. Detective Vanuka also found a note with the name "Shane" on it that contained several telephone numbers. Based upon the foregoing facts I the undersigned moves this court to find that probable cause exists to file an information charging the above-named defendant with the offense of COUNT 1: Robbery, a Felony, in violation of Section 45-5-401, MCA. f- DATED this ~ day of o~ 1 2012. ~~ Todd 'S. Whipple Chief Deputy county Attorney and SWORN to before me this 10 day of I 2012. _--I~~~L-P""""''''''''''----,.,"""'.,' Jae Hoskins,~. \o\oslfl'" '.~-{.-"'" :.I,~.. Nol8ry Public,,')'F. '.'\1'.. ta! ;' 01ARI,,', \ for the State of Mon na! : ~ _.- ~: ~ Residing at: ~ t,'" SEAL;' 11j Bozeman, Montana \~~.,,;;~fl My Commission expires: """",~""""" March 27, 2014 N STATE OF MONTANA