Case 2023CF000663 Document 2 Filed 04-17-2023 Page 1 of 5

FILED
04-17-2023
Clerk of Circuit Court
Brown County, WI
STATE OF WISCONSIN CIRCUIT COURT BROWN COUNTY
2023CF000663
BRANCH
Honorable John P.
Zakowski
STATE OF WISCONSIN DA Case No.: 2023BR002586
Plaintiff, Assigned ADA: Eric R Enli Branch 6
Agency Case No.: 23-503242
vs. Court Case No.: 23CF

PAULA JEAN MEJIA

6459 Glenmore Road REFUSAL
Glenmore, WI 54208
DOB: 05/06/1975
Sex/Race: F/W CRIMINAL COMPLAINT
Eye Color: Green
Hair Color: Brown
Height: 5 ft 5 in
Weight: 145 lbs
Defendant. For Official Use

Complainant, an Assistant District Attorney, being first duly sworn on oath, deposes and says
that:

Count 1: HOMICIDE BY INTOXICATED USE OF A VEHICLE

The above-named defendant on or about Wednesday, April 12, 2023, in the Town of
Lawrence, Brown County, Wisconsin, did cause the death of BB, by the operation of a vehicle
while under the influence of an intoxicant, contrary to sec. 940.09(1)(a) Wis. Stats., a Class D
Felony, and upon conviction may be fined not more than One Hundred Thousand Dollars
($100,000), or imprisoned not more than twenty five (25) years, or both.

And furthermore, invoking the provisions of Wisconsin Statute 343.31(3)(c), upon conviction,
the department shall revoke the defendant's operating privilege for five (5) years.

And furthermore, invoking the provisions of Wisconsin Statute 940.09(1c)(a), upon conviction,
the court shall impose a bifurcated sentence under s. 973.01 and the term of confinement in
prison portion of the bifurcated sentence shall be at least 5 years except that a court may
impose a term of confinement that is less than 5 years if the court finds a compelling reason
and places its reason on the record.

Count 2: INJURY BY INTOXICATED USE OF A VEHICLE

The above-named defendant on or about Wednesday, April 12, 2023, in the Town of
Lawrence, Brown County, Wisconsin, did cause great bodily harm to GB, by the operation of a
vehicle while under the influence of an intoxicant, contrary to sec. 940.25(1)(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.

And the Department shall revoke the defendant's operating privilege for two (2) years.

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(OWI-3RD AND ABOVE) NOTICE: IT IS THE POLICY OF THE BROWN COUNTY CIRCUIT
COURT JUDGES THAT UPON CONVICTION AND SENTENCING FOR A THIRD OR
SUBSEQUENT OPERATING WHILE INTOXICATED OFFENSE YOU WILL BE REQUIRED
TO IMMEDIATELY REPORT TO JAIL.

Complainant is an Assistant District Attorney with the Brown County District Attorney's Office
and knows of the above offense(s) based upon:

1. Complainant’s review of the reports of Officer Cambray of the Hobart-Lawrence Police

Department, who indicates that on April 12, 2023, at approximately 9:16 P.M. in the Town of
Lawrence, Brown County, Wisconsin:

I, Officer Z. Cambray #516, was dispatched to respond to French Rd near Little Rapids Rd. in
reference to a 2-vehicle accident with injuries. Dispatch advised one of the vehicles was on
its roof and was beginning to catch fire. They also advised there was a person trapped in this
vehicle. Dispatch advised the driver of the second vehicle was unresponsive and there was a
child passenger in the second vehicle.

Upon my arrival I observed one vehicle engulfed in flames and was directed by a passerby
who had stopped to help that a female was trapped in the vehicle and the flames were
getting close to her. I grabbed my fire extinguisher from my patrol vehicle and ran to the
vehicle on fire. I observed a female partially trapped in the vehicle yelling for help. I began
spraying her immediate area with my fire extinguisher, with the help of a passerby, I was
able to remove the female, identified as Paula J Mejia (5/6/1975), the defendant, from the
vehicle before the flames were able to reach her. Paula was pulled to the east side of the
road away from the burning vehicle. Paula was conscious at this time but did not remember
anything.

I next moved onto the second vehicle, which was in the east ditch, the driver of the vehicle
was unresponsive and had obvious facial and upper body injuries. The driver of the vehicle
was identified as BB. I was also able to observe a young male in the front passenger seat
who was crushed between the dashboard and his seat. The male was identified as GB.
Rescue extricated BB and began to perform CPR on him as he was not breathing and had no
pulse. I began speaking with GB at what was left of the passenger window frame. GB was
able to provide me with his first name and asked me if we could put him to sleep because he
was in so much pain. I moved out of the way so fire personnel could begin extrication of GB.
When GB was extricated, he was Med flighted to St. Vincent 's Hospital for treatment.

I began identifying witnesses to the scene. The first witness that I identified was TS. TS was
one of the first people on scene after the crash and assisted with getting Paula out of the
vehicle. The second witness I identified was LV. LV was out at a work party at the Stoneyard
in Appleton, WI with Paula and also attended Macks Pub in Lawrence, WI. LV stated that
Paula had been seen drinking between the hours of 4:30 and 9:00 p.m. on 4/12/2023. The last
witness that I identified was RB. RB was also out to dinner and drinks with Paula on the same
date and times.

The Outagamie Sheriff 's office was sent to advise the wife of BB and mother of GB of their
condition and let her know her son was being treated at St. Vincent 's Hospital. The wife/mother

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was identified as JB. I was made aware by JB that GB had been intubated due to the amount of
pain he was in but he was stable at the time I spoke with her.

Upon extrication and transport of the patients, the Medical Examiner was notified and ME
Becky responded to the scene. Brown County Sheriffs Office Recon team responded to the
scene as well. I remained on scene while the medical examiner performed her assessment
and had Ryan funeral home come to the scene to remove the body of BB from the scene.
The Recon team completed their reconstruction and finished with the scene at approximately
3:15 a.m. At this time, Heavy Duty towing was called to the scene for vehicle removal. The
vehicles were transported back to the Brown County Sheriff 's Office and placed into their
secure storage.

Preliminary investigation indicates that the vehicle driven by Paula was traveling northbound
on French Road at the same time the vehicle driven by BB was traveling southbound on
French Road. It appears that Paula crossed the centerline on French Road just south of
Little Rapids Road and struck BB’s vehicle head on.

2. Complainant’s review of the reports of Officer Schiefelbein of the Hobart-Lawrence Police

Department, who indicates that on April 12, 2023, at approximately 9:16 P.M. in the Town of
Lawrence, Brown County, Wisconsin:

Officer C. Cambray #516 and I were directed by Brown County Dispatch to the area of French
Road and Little Rapids Road in the Town of Lawrence, Brown County, WI in regard to a two
vehicle accident. Dispatch informed us there was one vehicle on its hood, the vehicle was on
fire, and the driver was trapped. Officer Cambray arrived on scene first. See his report for
more details. Other officers also arrived on scene. I arrived on scene at approximately 9:30
PM. Lawrence Fire was already on scene. There was a dark SUV on the west side of French
road on its roof. The driver had been removed from the vehicle, was conscious and alert, and
the fire department was putting out the fire. The female was verbally identified as Paula and
later confirmed by DOT picture return on my squad computer. There was a gray sedan on the
east side of the road. Fire department personnel were doing CPR on the male driver, later
identified as BB. There was a younger male trapped in the front passenger seat of the sedan.
This male was later identified as GB.

I met up with Officer Cambray. Officer Cambray pointed to a female laying in the grass and
informed me that was the driver of the SUV. Officer Cambray told me she did not remember
anything and was not talking. I went over and confirmed she was conscious and alert. There
were two females with her, who said they were Paula's friends. There were two male good
Samaritans who came upon the accident and assisted with the initial actions. I asked State
Patrol Officers to obtain statements from them. I assisted the fire department and De Pere
rescue with tasks as they worked extricating GB from the car. Eagle 3 was requested and
responded. Rescue pronounced BB deceased at the scene. I put a blanket over him. I had
Officer Cambray go speak with Paula's friends to get some more information.

Officer Cambray informed me he spoke to LV. LV had told Officer Cambray that they had all
just came from a work dinner. LV informed Officer Cambray that Paula had been drinking.
Officer Cambray obtained a statement from LV which stated Paula was at a work dinner at
Stoneyard in Appleton, WI. Paula was observed drinking beer, left, and met back up with LV
at Mack 's Pub and Grill. According to the statement, LV observed Paula drinking more beer
at Mack's Pub and Grill. Ashwaubenon Rescue arrived on scene and transported Paula to

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Aurora Bay Care. The fire department was able to extricate GB who had life threatening
injuries. Eagle 3 landed and transported GB to St. Vincent Hospital in Green Bay, WI. Brown
County crash reconstruction was called in to assist. I went to Aurora Bay Care to conduct the
OWI investigation. Officer Cambray remained on scene.

I arrived at Aurora Bay Care. I had to wait approximately 15 minutes until Paula returned from
x-rays. Paula was lying in the hospital bed. I introduced myself to Paula. I confirmed with
Paula that prior to the accident, she had been at a work function. Paula confirmed she was. I
asked Paula if she had been drinking while at this function. Paula stated she did. I asked
Paula how many drinks she had. Paula told me she had two beers. Paula had her eyes
closed and was talking very quietly. Due to this and not being very close to Paula, I was
unable to smell intoxicants coming from Paula. I also was not able to observe her eyes due to
them being closed or mostly closed. I was unable to conduct Standard Field Sobriety Tests
due to the accident and Paula's injuries.

It is my opinion that Paula was under the influence of alcohol/drugs/both and was unable to
operate a motor vehicle safely. Based on the accident and witness statements that Paula was
drinking beer at two different establishments, I decided to place Paula under arrest for OWI-
Homicide. I informed Paula she was being placed under arrest for Homicide by Intoxicated
Use of Vehicle.

I read Paula the Informing the Accused form. I asked Paula if she would submit to an
evidentiary chemical test of her blood. Paula stated no at 11:00 PM.

Due to Paula 's refusal, I completed our OWI search warrant template. I emailed the warrant
to Judge Walsh of the Brown County Circuit Court. Judge Walsh signed the warrant and
emailed it back to me at approximately 11:53 PM.

Paula asked if a lawyer could delay or stop the blood draw. I informed Paula it would not stop
it because I had a warrant for her blood. The on-duty medical technician at Aurora Bay Care
hospital drew two vials of blood from Paula in my presence. The blood was placed in the
blood kit. The blood kit showed an expiration date of 6/30/2024. The blood kit was sealed and
kept in my possession at all times. I later took the blood to the Post Office where I mailed it.

I read Paula her Constitutional Rights. Paula did not waive her rights. No questions were
asked and I marked refusal on the Alcohol Influence Report form. I explained to Paula her
citation for Homicide by Intoxicated Use of Vehicle, the Notice of Intent to Revoke form, her
copy of Informing the Accused, and her copy of the search warrant. I explained to Paula her
copies would be placed in her property at the jail.

Paula was admitted to Aurora Bay Care and is currently being treated for her injuries. Paula is
in police custody. After Paula is released from Aurora Bay Care, she will be transported and
booked into the Brown County Jail on charges of Homicide by Intoxicated Use of Vehicle.

3. Complainant’s review of the reports of Captain Olson of the Hobart-Lawrence Police

Department, who indicates that on April 13, 2023, at approximately 11:00 A.M. in the City of
Green Bay, Brown County, Wisconsin:

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I met with JB at St. Vincent's Hospital to answer any questions I could about what had
happened. JB told me GB's femurs were broken in both legs, he had a broken elbow, and a
broken wrist. The first of a few needed surgeries had just been completed on one of GB's legs.

4. The written report of Officer Schiefelbein of the Hobart-Lawrence Police Department

indicates that on the above date and time, he had the defendant, after reading the “Informing
the Accused”, submit to a blood test at Aurora Hospital.

5. A radio check with the Wisconsin Department of Motor Vehicles revealed the defendant’s
operating privilege was valid.

Complainant believes the reports of Officer Cambray and Officer Schiefelbein because he has
relied on their reports in the past and has found them to be accurate. Complainant believes
the information from the Department of Motor Vehicles because it is kept in the ordinary course
of business and he knows that the Department regularly sends notices to each person whose
operation privilege has been revoked or suspended.

Subscribed and sworn to before me on Electronically Signed By:

04/17/23 Eric. R. Enli
Electronically Signed By: Complainant
Ryan M Spaude
Assistant District Attorney
State Bar #: 1119355