Paul M. Schneider, 31, of Terry Road in Hartford on Thursday, February 25,2016, in the City of West Bend,
Washington County, Wisconsin, did, by use of force or threat of imminent force take from
an individual or the presence of an individual money that is under the custody or control of
a financial institution, Westbury Bank, contrary to sec. 943.87,939.50(3)(c) Wis. Stats., a
Class C Felony, and upon conviction may be fined not more than One Hundred Thousand
Dollars ($100,000), or imprisoned not more than forty (40) years, or both.
Details in this complaint were relayed by Brian T. McAndrews, of the West Bend Police Department.
PROBABLE CAUSE:
Complainant prays that said defendant be dealt with according to law. The basis for the
complainant’s charge of such offense is he is a Detective with the City of West Bend police
Department and bases his information upon his review of the official police reports
prepared by officers of the City of West Bend Police Department, his personal knowledge
of this case, and his review of his own official police reports with regard to investigation of
this matter. Your complainant is aware based upon his personal investigation of this
matter that on February 25,2016, at approximately 5:00 p.m.
West Bend police officers were dispatched to the Westbury Bank located at2501W. Washington Street, City of West
Bend, Washington County, Wisconsin, for the report of a robbery that had just occurred.
Your complainant is aware that it was reported that the suspect was fleeing eastbound on
Washington Street, City of West Bend, Washington County, Wisconsin, in a black Ford
pick-up truck with Wisconsin plate JR3264. Your complainant is aware that based upon
his investigations of this matter that on February 25, 2016, he met with JNM, an adult
citizen witness whom your complainant believes is truthful and reliable, who indicated that
she is a Westbury Bank employee and was workíng at the Westbury Bank located at2501
W. Washington Street, City of West Bend, Washington County, Wisconsin on February 25,
2016. JNM indicated that on February 25,2}16,just before 5:00 p.m. she was working as
a teller at Westbury Bank when two males entered the lobby area of the bank and lhe
moved to a lobby teller window to assist them. JNM stated that the first person, later
identified as Paul M. Schneider (the above-named defendant) stopped at the customer
island where deposit slips/withdrawals and other bank papenruork is kept. JNM stated that
it appeared that the above-named defendant motioned to the other person to go ahead of
him. JNM indicated that she completed a transaction with the other customer. JNM stated
that the other individual (later identífied as the above-named defendant) was a white male
approximately 30 years old and was wearing a green hooded sweatshirt. JNM stated that
the person had light brown scruffy looking facíal hair and she thought the person was
wearing some type of eye glasses. JNM stated that this person had some type of
headphones around his neck near his ears and she thought she heard noise like a police
type scanner speak. JNM stated that when this person (later identified as the abovenamed
defendant) approached her at the counter, he put a deposit ticket on the counter
between them. JNM stated that she slid the deposit slip toward herself and saw it had
something written on it different than the typical deposít form. JNM stated that she looked
at the form and saw that it said “Give me the money and nobody gets hurt. No Bait. No
alarms. I’m listening to the scanner.” JNM stated that is what her recollection of the note
was w¡thout looking at it again.
JNM stated that the bank teller window that she was at d¡d
not have a cash drawer because it was not actually an open teller window position at that
particular time. JNM stated that her cash drawer was located at the drive-thru window.
JNM stated that after reading the note she became afraid and fearful for her life. JNM
stated she thought she needed to give the person money or he would hurt her as the note
implied. JNM stated that she turned toward the drive-thru area to go to her cash drawer.
JNM stated that as she walked toward her drawer she crossed paths with GEM, a male
adult cítizen witness who is an employee at Westbury Bank. JNM stated that she told
GEM quietly that she was being robbed and asked what she should do. JNM stated that
GEM told her to give the person money. JNM stated that she grabbed a packet of $100
bills, a few $50 bills, a few $20 bills, a few $1 bills and she could not recall if she grabbed a
few $5 bills as well. JNM thought either the $100 bilrs or the $10 biils werswrapped
together in a rubber band while the other was in an actual money seal. JNM stated that
she gave the money to the person (the above-named defendant) and he turned and
walked away without saying anything. JNM stated that as soon as the person was out of
the bank she announced for her co-workers to hear that she had just been robbed. JNM
stated that GEM followed the person out of the bank within moments after the abovenamed
defendant exited. JNM indicated that she counted the remaining contents of her
cash drawer in relation to what she was supposed to have. JNM indicated that her drawer
was short $1,599. JNM told your complainant that she feared for her life and thought she
had no choice but to give the person (later identified as the above-named defendant)
money. JNM indicated that the above-named defendant did not have permission to take
money from Westbury Bank. Your complainant is aware that all bank employees indicated
to your complainant that no one had permission to take money from Westbury Bank.
Your complainant is further aware that pursuant to his investigations of this matter, your
complainant went to the teller counter where the robbery occurred and found the deposit
ticket that JNM referred to. Complainant is aware that written on the deposit ticket are the
following words “Give me the money and nobody gets hurt. No Dye Packs. no alarms. tm
listening to the scanner.”
Your complainant is further aware that pursuant to his investigations of this matter, on
February 25,2016, he met with GEM, an adult citizen witness whom complainant believes
is truthful and reliable, who is an employee at Westbury Bank located on W. Washington
Street, City of West Bend, Washington County, Wisconsin. GEM indicated that on
February 25,2016, just before 5:00 p.m. he was in the back room of the drive-thru teller
area performing some bank work. GEM stated that as he was exiting the side office area
JNM was stepping back moving toward the drive-thru area. GEM stated that JNM looked
at him and said she was being robbed and quietly asked what she should do. GEM stated
that he quietly told JNM to give the person the money. GEM stated JNM went to her drivethru
drawer and removed some of the cash from inside of it and turned to go back to the
lobby teller window. GEM stated that while JNM did this he tried to circle around the side
office to put himself on the customer side of the lobby area. GEM stated that he saw JNM
hand the person who was at her teller window (later identified as Paul Schneider, the
above-named defendant) a small stack of cash. GEM stated that he thought the abovenamed
defendant had his right hand in is sweatshirt pocket as if he might be trying to
conceal a weapon. GEM stated that at no point did he see a weapon displayed. GEM
described the person (later identified as the above-named defendant) as a wh¡te male with
light brown scruffy facial hair. GEM stated that the person was in his early 30’s and
approximately 6 feet tall. GEM stated that the person was wearing a green hooded
sweatshirt without writing on it. GEM stated that the above-named defendant walked past
him as he exited the bank. GEM stated that he grabbed his car keys off his desk and
followed out the door shortly after the above-named defendant so he could call 911 and
follow the person. GEM stated that as he exited the bank he saw the above-named
defendant walking north toward Washington Street. GEM stated that the person started to
cross the street and go toward the Applebee’s parking lot. GEM stated that he was in his
vehícle and he observed the above-named defendant go into a black Ford F150 pick-up
truck and drive toward Washington Street. GEM indicated that he followed the above described
pick-up truck and called 911 to report that he was following the above-named
defendant. GEM stated that he was disconnected from his first attempt at calling g11 and
called back a second time. GEM stated that he followed the above-described Ford pick-up
truck and was on the phone with police dispatch and he told the dispatcher what the
license plate number was (Wisconsin plate JR3264). GEM stated that he followed the
above-named defendant’s vehicle and as they were nearing Washington Street and
Highway 45, a police car came up behind him with its red and blue lights turned on. GEM
stated that he pulled his vehicle in front of the above-described pick-up truck hoping he
would be able to block the truck in from taking off. GEM stated that the pick-up truck drove
around him and continued on Washington Street with a marked police car with red and
blue lights and an activated siren following the above-described vehicle. GEM stated that
he continued to follow and at Washington StreeUlSth Avenue, he saw a uniformed police
officer in the intersection throw a tire deflation device at the pick-up truck. GEM stated that
the pick-up truck drove around the device and turned right (south) onto 18th Avenue. GEM
stated that the pick-up truck turned into the Fleet Farm parking lot (located at 1637 W.
Washington Street, City of West Bend, Washington County, Wisconsin) and he observed
the vehicle come to a stop in the driveway. GEM stated that he was still following and
stated that he stopped in the middle of 18tn Avenue behind a number of police cars to see
how things would turn out.
GEM stated that after a minute the person (later identified as the above-name defendant)
got out of the pick-up truck. GEM stated that he thought the person was holding
something up to the right side of his neck and had his left hand in the pick-up truck or in his
pocket. GEM stated that after another minute he saw the person fall to the ground and the
police approached him. GEM stated that at this point he returned to the bank to wait to
talk to the police. GEM stated that from the time the person left the bank to the time the
police made contact with him on Washington Street in the Fleet Farm parking lot he
maintained continued visual site of the person. GEM stated that the person in the Fleet
Farm parking lot taken into custody (later identified as Paul Schneider, the above-named
defendant) was absolutely the same person that had robbed the Westbury Bank earlier on
February 25,2016.
Complainant further bases his information upon his review of the official police report
prepared by City of West Bend Police Officer Stacie Bruss who indicates that on February
02/29/2016
STATE OF WISCONSIN – VS – Paul M Schneider
25,2016, at approximately 5:00 p.m. dispatch advised that a robbery had just occurred at
the Westbury Bank located at2501W. Washington Street, City of West Bend, Washington
County, Wisconsin. Officer Bruss indicates that at that time she was working as a City of
West Bend police officer and was operating her fully marked police squad eastbound on
the 2300 block of W. Washington Street. Offícer Bruss indicates that she turned her squad
around and continued westbound on W. Washington Street. Officer Bruss indicates that
she received information that dispatch indicated that a witness was followíng a suspect
who was operating a black truck eastbound and the witness was in a siver Nissan
automobile. Officer Bruss indicates that she turned her squad around in the 2SOO block of
W. Washington Street and continued eastbound on W. Washington Street. Officer Bruss
indicates that she continued eastbound on W. Washington Street with the emergency
lights and sirens activated on her marked squad car. Officer Bruss indicates thal she
received information that the truck involved in the robbery was a Ford F150 pick-up truck.
Officer Bruss indicates that she observed a silver Níssan in front of Officer Bruss; squad
and a dark colored Ford pick-up truck in front of the Nissan automobile. Officer Bruss
indicates thatthe Ford F150 pick-up truck (the operatorwhich was laterdetermined to be
Paul Schneider, the above-named defendant) moved to the right side of the road under US
Highway 45 on W. Washington Street. Officer Bruss indicates that she observed the
Nissan automobile continue eastbound and stop in front of the Ford truck. Officer Bruss
indicates that the Ford truck then pulled back out into the traffic and continued eastbound
on W, Washington Street. Officer Bruss indicates that she continued to pursue the abovedescribed
vehicle with her emergency lights and sirens activated on her marked squad car.
Officer Bruss indicates that while the vehicle continued eastbound, she observed the sole
male occupant in the driver seat and the male (later identified as the above-named
defendant) appeared to be moving a jacket or an item in the passenger area. Officer
Bruss indicates that the truck continued eastbound at approximately 45 miles per hour
while emergency lights and sirens were still activated. Your complaÍnant is aware that the
speed limit in this area is 35 miles per hour. Officer Bruss indicates that as the truck
approached N. 18th Avenue and W. Washington Street, the truck slowed down and began
to turn right. Officer Bruss índicates that she observed City of West Bend Police Officer
Schotzko deploy road spikes into the southbound lanes of N. 18th Avenue at W.
Washington Street. Offícer Bruss indicates that the Ford pick-up truck passed right before
Officer Schotzko was able to deploy the spikes. Officer Bruss indicates that she
maneuvered her squad around the spikes and continued southbound on N. 18th Avenue.
Officer Bruss indicates that the truck continued southbound and then turned left (east) into
the southern-most driveway of the Fleet Farm store located at 1637 W. Washington Sireet,
City of West Bend, Washington County, Wisconsin. Officer Bruss indicates thãt while she
was pursuing the above-described vehicle, Officer Becker was following her squad in his
fully marked police squad car with his emergency lights and sirens activaled.
Officer Bruss indicates that the Ford pick-up truck came to a complete stop approximately
52 feet into the driveway facing east in the Fleet Farm parking lot. Officer Bruss indicates
that also on the scene was City of West Bend Police Officer Becker and Officer
Lichtensteiger. Officer Bruss indicates that she immediately exited the driver’s side door of
her vehicle and drew her handgun and pointed her handgun at the driver side of the Ford
pick-up truck. Officer Bruss indicates that a male subject (later identified as the above-
02/2912016
STATE OF WISCONSIN – VS – Paul M Schneider
named defendant) exited the driver side door and sat on the driver seat facing outside the
truck. Officer Bruss indicates the above-named defendant then stood up on the running
board of the vehicle and faced Officer Bruss’ squad car. Officer Bruss indicates that she
yelled commands to the above-named defendant and told the above-named defendant to
put his hands in the air and to get on the ground. Officer Bruss indicates that the abovenamed
defendant remained standing on the running board and facing officers. Officer
Bruss indicates that the above-named defendant had an item which she could not see and
at that time the above-named defendant’s right hand was near his neck. Officer Bruss
indicates the above-named defendant’s left hand remained inside the driver’s compartment
of the truck. Officer Bruss indicates that she, Officer Becker and Officer Lichtensteiger
continued to command the above-named defendant to drop what was in his hands, put his
hands in the air and to get on the ground. Officer Bruss indicates that she reupholstered
her handgun and drew her Taser. Officer Bruss indicates that she told the above-named
defendant it was okay and they could work through whatever was occurring. Officer Bruss
indicates the above-named defendant did not answer her and she asked what happened.
Officer Bruss indicates that above-named defendant did not say anything and continued to
hold what she could now see as a utility knife near the above-named defendant’s neck.
Officer Bruss indicates the above-named defendant was holding a smartphone in his left
hand he appeared to be using the phone.
Officer Bruss indicates that above-named defendant still did not follow any of the
commands to drop the knife, to get down on the ground or put his hands in the air. Officer
Bruss indicates the above-named defendant then stepped off the truck and immediately
cut the right side of his neck with the knife in his right hand. Officer Bruss indicates that
the above-named defendant appeared to slash at his neck four times with the knife that
was in his right hand. Officer Bruss indicates that Officer Becker, Officer Lichtensteiger
and herself immediately ran toward the above-named defendant and commanded him to
get on the ground. Officer Bruss indicates that as she was running towards the abovenamed
defendant she activated her Taser and pulled the trigger. Officer Bruss indicates
that Officer Becker directed the above-named defendant to the ground and after she
applied gloves to herself she kneeled to the ground and applied direct pressure to the
above-named defendant’s neck. She observed blood coming from the above-named
defendant’s neck and continued to hold pressure. Officer Bruss indicates that Washington
County Sheriff’s Department Deputy Vanderheiden arrived and provided medical supplies
to Officer Bruss. Officer Bruss indicates that she applied numerous pieces of gauze to the
above-named defendant’s neck while maintaining pressure. Officer Bruss indicates that
West Bend Fire and Rescue arrived on scene and took over medical attention. The driver
of the vehicle was later identified as Paul Schneider (the above-named defendant).
Officer Bruss indicates that it was later determined from the point she observed the abovenamed
defendant’s pick-up truck and W. Washington Street at US Highway 45 until W.
Washington at N. 1B’n Avenue was approximately.4 miles. Officer Bruss indicates that the
distance from N. 18th Avenue intersection at W. Washington Street until the Fleet Farm
entrance on N. 18th Avenue was approximately 200 feet.
02/29/2016
STATE OF WISCONSIN – VS – paut M Schneider
Your complainant is aware that at all times material hereto that Officer Bruss, Officer
Becker and Officer Lichtensteiger were duly appointed and acting police officers with the
City of West Bend Police Department, were attired in the standard duty uniform of the
agency of the West Bend Police Department and were performing an act in their official
capacity and with lawful authority.
Your complainant further bases his information upon his review of the official police report
qçpgJed by City of West Bend Police Officer Justin Becker who indicates that on February
25, 2016, at approximately 5:02 p.m. díspatch advised that a robbery just occurred at
Westbury Bank located on W. Washington Street, City of West Bend, Washington County,
Wisconsin. Officer Becker indicates that he followed Officer Bruss who was following a
Ford truck near the area of W. Washington Street underneath the US Highway 45
underpass. Officer Becker indicates that the above-described vehicle eventually went to
the Fleet Farm parking lot located on W. Washington Street, City of West Bend,
Washington County, Wisconsin. Officer Becker indicates that the driver of the Ford vehicle
was later identified as the above-named defendant. Officer Becker indicates that after the
above-named defendant was taken into custody the above-described Ford truck with
Wisconsin plate JR3264 contained several items of evidentiary interest including a Husky
utility knife, which was approximately four to five inches long when extended-. Officer
Becker indicates that the blade portion is about one inch long. Officer Becker indicates
that the knife was covered in blood. Officer Becker indicates that also inside the vehicle
was $1,599 in cash in the following denominations, six $1 bills, six $50 bills, twelve $20
bills, 42 $10 bills, five $5 bills and 14 $1 bilts.
With regard to Count 4, complainant further bases his information upon his review of
Washington County Circuít Court Case No. 15-CF-495, wherein Paul M. Schneider, the
above-named defendant, was charged with three counts of Receiving a Stolen Firearm,
contrary to Section 943.34(1Xbm) Wis. Stats., a felony, that on January 22, 2016, the
above-named defendant was admitted to a $1,500 cash bond, one of the conditions which
is the defendant shall not commit any crimes, that said bond was amended on February 1,
2016, to a $500 cash bond also with the condition that defendant shall not commit âny
crimes, the above-named defendant was in court and signed said bond on February 1,
2016, that said bond was in full force and effect on February 25,2016, and that a copy of
February 1,2106, bond is attached hereto and incorporated herein by reference.
With regard to Count 5, complainant bases his information upon his revíew of Washington
County Circuit Court Access Program records (CCAP) which records your complainant has
relied upon in the past and found to be truthful and reliable, which records indicate that in
Milwaukee County Case No. 2015-CF-3900, Paul M. Schneider, the above-named
defendant was charged with the felony offense of Possession of Narcotic Drug, contrary to
Section 961.41(39)(am), the above-named defendant was admitted to a $750 sígnaiure
bond on September 2, 2015, standard condition which bond was that the defendant shall
not commit any crimes, that said bond was amended on November 5, 2015, to a $250
cash bond, standard condition of which is that the defendant shall not commit any crime,
the defendant was in court and signed said bond on November 5, 2015, and that said bond
02/29120t6
STATE OF WISCONSIN – VS – Paul M Schneider
was ¡n full force and effect on February 25, 2016, and that a copy of said CCAP records
are attached hereto and incorporated herein by reference.
Based on the foregoing, the complaínant believes this complaint to be true and correct.
Subscribed and sworn to before me. ,!
and approved for filing on:
This 29th day of February, 2016.
Schneider is due back in Washington County Court on April 13, 2016 for a hearing before Judge James Muehlbauer.