Case 2023CF000057 Document 2 Filed 01-09-2023 Page 1 of 4

FILED
01-09-2023
Clerk of Circuit Court
Brown County, WI
STATE OF WISCONSIN CIRCUIT COURT BROWN COUNTY
2023CF000057
DA Case No.: 2023BR000192 Honorable Donald R.
Zuidmulder
STATE OF WISCONSIN Assigned DDA: Caleb Saunders
Plaintiff, Agency Case No.: 22-114525 Branch 1
Court Case No.: 2023CF___
vs. ATN:

MARY JO PEPIN
2405 Honey Lou Court #8 CRIMINAL COMPLAINT
Appleton, WI 54915
DOB: 01/17/1957
Sex/Race: F/W
Eye Color: Brown
Hair Color: Red
Height: 5 ft 0 in
Weight: 110 lbs
Alias: Also Known As Diane Foster
Defendant. For Official Use

Complainant, Caleb Saunders, a Deputy District Attorney, being first duly sworn on oath,
deposes and says that:

Count 1: BURGLARY OF A BUILDING

The above-named defendant, on or about Sunday, December 25, 2022, in the City of De Pere,
Brown County, Wisconsin, did intentionally enter a building, a church, without the consent of
the person in lawful possession of the place, and with intent to steal, contrary to sec.
943.10(1m)(a) Wis. Stats., a Class F Felony, and upon conviction may be fined not more than
Twenty Five Thousand Dollars ($25,000), or imprisoned not more than twelve (12) years and
six (6) months, or both.

Count 2: THEFT

The above-named defendant, on or about Sunday, December 25, 2022, in the City of De Pere,
Brown County, Wisconsin, did intentionally take and carry away the movable property of Our
Lady Of Lourdes Church, without consent and with intent to permanently deprive the owner of
possession of the property, contrary to sec. 943.20(1)(a)&(3)(a) Wis. Stats., a Class A
Misdemeanor, and upon conviction may be fined not more than Ten Thousand Dollars
($10,000), or imprisoned not more than nine (9) months, or both.

Complainant is a Deputy District Attorney with the Brown County District Attorney’s Office and
knows of the above offense(s) on information and belief based upon:

PROBABLE CAUSE:

The complainant, being duly sworn on oath, swears that he has had the opportunity to review
the police reports from officers of the De Pere Police Department, and other documents
supporting this complaint referenced herein, which are the types of reports and documents

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STATE OF WISCONSIN - VS - Mary Jo Pepin

kept in the ordinary course of business, which complainant believes to be truthful and reliable
because they have proven to be truthful and reliable on numerous occasions in the past. The
complainant further asserts that based upon his review of the referenced reports and/or
supporting documents, the incidents alleged occurred in Brown County, Wisconsin.

1. Your complainant’s review of the report of Sgt. Michael Vandenbush of the De Pere
Police Department, which indicates that on December 25, 2022, at about 4:59 p.m. Sgt.
Vandenbush reports he was dispatched to a church and school located on Lourdes Avenue in
the City of De Pere, Brown County, Wisconsin, for a possible burglary in progress. The
complaining witness, LF, stated that staff had placed Ring cameras throughout the building
due to recent break-ins/thefts/trespassing and saw a female on camera who should not be in
the building at that time. LF stated the female was believed to be the same female who had
been breaking in recently where money went missing. Sgt. Vandenbush contact LF and LF
stated there should be no staff members in the building for any reason that night. The camera
that was triggered was closest to the “Social Hall Door.” Officers observed one set of fresh
shoe prints in the snow going toward the door. No shoeprints were seen leaving the door. Due
to recent storms and windy conditions, it was believed the shoeprints were related to the
incident that night. No forced entry was observed. In past observations, staff believed the
female used an unauthorized key to make entry into the building. Sgt. Vandenbush observed
one set of shoeprints leaving the area of the school courtyard door on the south side of the
building. It was later determined the shoeprints entering and leaving appeared to be the same.
Officers searched the building with negative results. Sgt. Vandenbush was shown where the
camera which alerted LF was positioned and the camera was missing and only the wall
charger was left behind.

2. Your complainant’s review of the reports of Sgt. Aaron Hanson of the De Pere Police
Department, which indicates:

Sgt. Hanson was assigned to follow-up as he had knowledge of a similar incident in DPPD
Case #22-114005, wherein Officer Smith with his department investigated a trespassing
incident involving a female going into areas of the church where staff mailboxes are located.
Sgt. Hanson observed video from the church of a woman wearing a navy blue jacket and
stocking hat entering the mail room. The female began looking through items in individual
mailboxes before looking through pieces of paper sitting at the base of the mailboxes. While
doing this, the subject is holding what appeared to be a pair of medical gloves made of latex
which she used to make sure to touch the items with the latex gloves, including the light switch
and door handle when she leaves. Sgt. Hanson spoke with LF and instructed her to set up
additional cameras in the event the woman returned. LF advised the female typically comes to
the facility on Saturdays or Sundays. This pattern was observed dating back to November 12
and 13, 2022. LF sent Sgt. Hanson still photographs from November 13, November 20, and
November 26, 2022. In the photograph from November 26, a small blue SUV can be seen
going east on Lourdes Avenue at 4:33 p.m.

Sgt. Hanson confirmed with LF that the facility was not open when the suspect entered during
the Christmas incident (December 25). Sgt. Hanson was able to review the video surveillance
from that incident provided by LF. Sgt. Hanson observed at 4:34 p.m., a small blue SUV can
been seen going westbound on Lourdes Avenue. The vehicle turned around and goes past the
entrance of the church again before continuing east out of view of the camera. At 4:38 p.m.,
the female is seen walking in the back parking lot, walking up a set of stairs before walking off

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STATE OF WISCONSIN - VS - Mary Jo Pepin

camera. The female is wearing a dark jacket with the hood up. The hood had fur around the
ring of the hood. The female was wearing light boots with a black toe and it appeared the boots
had some type of fur around the top. The top of the boots reached the middle calf area of the
female’s legs. Based on the church layout, there is an entrance off camera which the female
used to enter the facility. At 4:42 p.m., the same female is seen walking in the gathering space
camera outside of the church entrance. She looked at documents on the table and then walked
into the church area off camera .The female can be seen at 4:48 p.m. carrying some type of
bag in the gathering space camera. The female goes off camera as she walks down a hallway
off the gathering area. At 4:52 p.m., the female is seen walking toward the front entrance and
exits through the north door. The female walks down the driveway to the sidewalk before the
camera feed cuts off. The color of the jacket was determine to be blue. The boots were beige
with a dark toe and white or beige fur on the top surrounding the calf.

Sgt. Hanson was also provided the video footage from the Ring recording device of the
suspect entering the social hall and leaving the hall. The date on the device showed December
25, 2022 with a recording time of 4:53 p.m. The device was purchased and installed by LF,
and she contacted police after this device recognized activity in the social hall. It was also the
device taken by the suspect after it was unplugged. Sgt. Hanson later received the recording of
the female manipulating and unplugging the device. Sgt. Hanson also met with the principal of
West De Pere Intermediate School to review video from the east parking lot at around 4:30
p.m. on December 25, 2022. Sgt. Hanson observed the blue SUV at about 4:36 p.m. coming
into the lot, turning around, and leaving the lot. The vehicle goes back to Lourdes Avenue. and
out of view of the camera. The vehicle is believed to be a Ford EcoSport based on the unique
description of the vehicle.

Still photographs of the suspect were disseminated publicly on social media. Sgt. Hanson
received a tip identifying the suspect as Mary J. Pepin, DOB: 01/17/1957. Sgt. Hanson found
Pepin had prior convictions for burglary in Outagamie and Brown Counties. Sgt. Hanson
reviewed the report associated with Brown County Case 11CF945 and observed GBPD
officers responded to a church for a trespassing complaint and located Pepin near the premise
and took her into custody. Property from the church was recovered in a bag carried by Pepin.
Sgt. Hanson conducted a search of Pepin through Wisconsin DOT for vehicles registered to
Pepin and learned a blue Ford EcoSport was registered to Pepin at an address on Honey Lou
Court in Appleton. Sgt. Hanson ran the registration plate through Wisconsin DOT and
confirmed it was registered to Pepin on a 2020 Ford Ecosport SUV, blue in color. Sgt. Hanson
traveled to the Honey Lou Court residence on December 29, 2022, and in the parking lot of the
complex he observed a Ford EcoSport with the same registration. Sgt. Hanson later observed
a female matching Pepin’s description exit the apartment complex and enter the Ford Ecosport
before leaving the complex in that vehicle.

On January 6, 2023, Sgt. Hanson reports he executed a search warrant for Pepin’s residence
with other law enforcement officers. Sgt. Hanson reports officers knocked on the door and
received no answer for over two minutes, so a key was used to unlock the apartment. Inside,
officers located Mary J. Pepin, DOB: 01/17/1957, sitting on the couch. Sgt. Hanson reports
Pepin had a laptop on her knees and headphones on top of her head and acted as though she
did not hear anyone yelling and was woken up by officers. Sgt. Hanson noted her behavior did
not seem consistent with someone surprised to see police or someone who had just woken up
from a nap. Sgt. Hanson reviewed with Pepin the items listed on the warrant and asked for

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STATE OF WISCONSIN - VS - Mary Jo Pepin

assistance in locating any keys for church buildings, specifically the church referred to in the
December 25 incident. Pepin laughed to herself and did not identify any keys.

A closet was located on the west side of the apartment, just past the entry door. Inside the
closet Sgt. Hanson located a pair of boot footwear, beige in color, with a black toe. Sgt.
Hanson looked at the bottom of the boots which had a shoe print that matched the shoe print
left in the snow the night officers responded to the church on Lourdes Avenue on Christmas.
Two winter stocking hats were recovered from a northwest bedroom, the only bedroom in the
apartment. One stocking hat was blue in color and was worn by the suspect on December 11
when she entered the mail area at the church. The other hat was grey in color and believed to
have been worn by the suspect on November 13 when she entered the church school. One
athletic shoe matching the description of the footwear worn by the suspect inside the church
on November 13, 2022, was recovered. The footwear was dark in color with dark laces and a
white sole. The same footwear was worn by the suspect on December 11, 2022. Several keys
were located inside a purse.

Based on the foregoing, the complainant believes this complaint to be true and correct.

Subscribed and sworn to before me on Electronically Signed By:

01/09/23 Caleb Saunders
Electronically Signed By: Complainant
David L Lasee
District Attorney
State Bar #: 1041798

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