MISSOURI CIRCUIT COURT - TWENTY-SECOND JUDICIAL CIRCUIT STATE OF MISSOURI VS RODGERS, STEPHANIE DELORES DIV #: CA#: 510529961 CAUSE#:

DESTINATION: GRAND JURY (AT LARGE) DEFENDANT INFORMATION ADDRESS: 14XX E GENO ST LOUIS, MO 63107 PEDIGREE: RACE: B DOB: XX/XX/1980 HGT: 5'04" SEX: F AGE: 31 WGT: 165 ID #s: COMPLAINT#: 120002741 LID: 347827 ARREST#: DIST: SLMPD OCN: ALIASES: SSNs:

STATE OF MISSOURI ) CITY OF ST. LOUIS )SS

COMPLAINT

The Circuit Attorney of the City of St. Louis, State of Missouri, upon information and belief, charges that Count 1: Sexual Contact With Prisoner By Employee Of A Jail (Class D FELONY) RSMo 566.145 FROM 1/24/2011 TO 2/1/2011 Place: 200 S Tucker (SCC 22130) The defendant, in violation of Section 566.145, RSMo, committed the class D felony of sexual contact with an inmate, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between January 24, 2011 and February 1, 2011, in the City of St. Louis, State of Missouri, the defendant was assigned to work in the City of St. Louis Justice Center, a jail, and knowingly had sexual intercourse with F.I., an inmate of the jail, on the stairway to the bubble on the fifth floor of the jail.

Count 2: Sexual Contact With Prisoner By Employee Of A Jail (Class D FELONY) RSMo 566.145 FROM 1/24/2011 TO 2/1/2011 Place: 200 S Tucker (SCC 22130) The defendant, in violation of Section 566.145, RSMo, committed the class D felony of sexual contact with an inmate, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between January 24, 2011 and February 1, 2011, in the City of St. Louis, State of Missouri, the defendant was assigned to work in the City of St. Louis Justice Center, a jail, and knowingly had sexual intercourse with F.I., an inmate of the jail, on the floor of the bubble on the fifth floor of the jail.

529961

Page 1

03/19/2012

Count 3: Sexual Contact With Prisoner By Employee Of A Jail (Class D FELONY) RSMo 566.145 FROM 2/2/2011 TO 3/27/2011 Place: 200 S Tucker (SCC 22130) The defendant, in violation of Section 566.145, RSMo, committed the class D felony of sexual contact with an inmate, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between February 2, 2011 and March 27, 2011, in the City of St. Louis, State of Missouri, the defendant was assigned to work in the City of St. Louis Justice Center, a jail, and knowingly had sexual intercourse on the floor of the bubble located on the fifth floor of the jail, underneath and with F.I., an inmate of the jail.

Count 4: Sexual Contact With Prisoner By Employee Of A Jail (Class D FELONY) RSMo 566.145 FROM 1/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) The defendant, in violation of Section 566.145, RSMo, committed the class D felony of sexual contact with an inmate, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between January 28, 2011 and March 30, 2011, in the City of St. Louis, State of Missouri, the defendant was assigned to work in the City of St. Louis Justice Center, a jail, and knowingly had deviate sexual intercourse with F.I., an inmate of the jail, in F.I.s cell while F.I. was on his bed.

Count 5: Sexual Contact With Prisoner By Employee Of A Jail (Class D FELONY) RSMo 566.145 FROM 1/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) The defendant, in violation of Section 566.145, RSMo, committed the class D felony of sexual contact with an inmate, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between January 28, 2011 and March 30, 2011, in the City of St. Louis, State of Missouri, the defendant was assigned to work in the City of St. Louis Justice Center, a jail, and knowingly had deviate sexual intercourse with F.I., an inmate of the jail, in F.I.'s cell while F.I. was standing. Count 6: Sexual Contact With Prisoner By Employee Of A Jail (Class D FELONY) RSMo 566.145 FROM 1/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) The defendant, in violation of Section 566.145, RSMo, committed the class D felony of sexual contact with an inmate, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between January 28, 2011 and March 30, 2011, in the City of St. Louis, State of Missouri, the defendant was assigned to work in the City of St. Louis Justice Center, a jail, and knowingly had deviate sexual intercourse with F.I., an inmate of the jail, in the bubble located on the fifth floor of the jail, by putting F.I.s penis in the defendants mouth.

529961

Page 2

03/19/2012

Count 7: Sexual Contact With Prisoner By Employee Of A Jail (Class D FELONY) RSMo 566.145 FROM 1/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) The defendant, in violation of Section 566.145, RSMo, committed the class D felony of sexual contact with an inmate, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between January 28, 2011 and March 30, 2011, in the City of St. Louis, State of Missouri, the defendant was assigned to work in the City of St. Louis Justice Center, a jail , and knowingly had deviate sexual intercourse with F.I., an inmate of the jail, by allowing F.I. to put F.I.s mouth on the defendants genitals.

Count 8: Sexual Contact With Prisoner By Employee Of A Jail (Class D FELONY) RSMo 566.145 FROM 1/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) The defendant, in violation of Section 566.145, RSMo, committed the class D felony of sexual contact with an inmate, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between January 28, 2011 and March 30, 2011, in the City of St. Louis, State of Missouri, the defendant was assigned to work in the City of St. Louis Justice Center, a jail, and knowingly had deviate sexual intercourse with F.I., an inmate of the jail, by allowing F.I. to touch the defendants genitals with F.I.s hand.

Count 9: Sexual Contact With Prisoner By Employee Of A Jail (Class D FELONY) RSMo 566.145 ON 2/14/2011 Time: Place: 200 S Tucker (SCC 22130) The defendant, in violation of Section 566.145, RSMo, committed the class D felony of sexual contact with an inmate, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about February 14, 2011, in the City of St. Louis, State of Missouri, the defendant was assigned to work in the City of St. Louis Justice Center, a jail, and knowingly had sexual intercourse with F.I., an inmate of the jail, on the floor of the bubble on the fifth floor of the jail.

Count 10: Sexual Contact With Prisoner By Employee Of A Jail (Class D FELONY) RSMo 566.145 FROM 3/28/2011 Time: Place: 200 S Tucker (SCC 22130) The defendant, in violation of Section 566.145, RSMo, committed the class D felony of sexual contact with an inmate, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about March 28, 2011, in the City of St. Louis, State of Missouri, the defendant was assigned to work in the City of St. Louis Justice Center, a jail, and knowingly had sexual intercourse with F.I., an inmate of the jail, on the floor of the bubble on the fifth floor of the jail.
529961 Page 3 03/19/2012

Count 11: Sexual Contact With Prisoner By Employee Of A Jail (Class D FELONY) RSMo 566.145 ON 4/15/2011 Time: Place: 1426 East Geno (SCC 22130) The defendant, in violation of Section 566.145, RSMo, committed the class D felony of sexual contact with an inmate, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or about April 15, 2011, in the City of St. Louis, State of Missouri, the defendant was assigned to work in the City of St. Louis Justice Center, a jail, and knowingly had deviate sexual intercourse with F.I., an inmate of the jail.

The facts that form the basis for this information and belief are contained in the attached statement(s) of facts, made a part hereof and submitted as a basis upon which this court may find the existence of probable cause. Wherefore, the Circuit Attorney prays that an arrest warrant be issued as provided by law. Jennifer M. Joyce Circuit Attorney of the City of St. Louis, State of Missouri By _____Original Signed___________ Assistant Circuit Attorney

529961

Page 4

03/19/2012

PROBABLE CAUSE STATEMENT DATE: March 19, 2012 I, Patrick Drennan, a law enforcement officer for the City of St. Louis, State of Missouri,, knowing that false statements on this form are punishable by law, state that the facts contained herein are true. 1. I have probable cause to believe that Stephanie Delores Rodgers, a Black Female DOB: XX/XX/80 Age: 31, committed one or more criminal offense(s). Count 1: Sexual Contact With Prisoner Or Offender By Probation/parole Officer/employee Of A Jail, Prison Or Correctional Facility (Class D FELONY) RSMo 566.145 FROM 1/24/2011 TO 2/1/2011 Place: 200 S Tucker (SCC 22130) Count 2: Sexual Contact With Prisoner Or Offender By Probation/parole Officer/employee Of A Jail, Prison Or Correctional Facility (Class D FELONY) RSMo 566.145 FROM 1/24/2011 TO 2/1/2011 Place: 200 S Tucker (SCC 22130) Count 3: Sexual Contact With Prisoner Or Offender By Probation/parole Officer/employee Of A Jail, Prison Or Correctional Facility (Class D FELONY) RSMo 566.145 FROM 1/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) Count 4: Sexual Contact With Prisoner Or Offender By Probation/parole Officer/employee Of A Jail, Prison Or Correctional Facility (Class D FELONY) RSMo 566.145 FROM 1/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) Count 5: Sexual Contact With Prisoner Or Offender By Probation/parole Officer/employee Of A Jail, Prison Or Correctional Facility (Class D FELONY) RSMo 566.145 FROM 1/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) Count 6: Sexual Contact With Prisoner Or Offender By Probation/parole Officer/employee Of A Jail, Prison Or Correctional Facility (Class D FELONY) RSMo 566.145 FROM 1/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) Count 7: Sexual Contact With Prisoner Or Offender By Probation/parole Officer/employee Of A Jail, Prison Or Correctional Facility (Class D FELONY) RSMo 566.145 FROM 1/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) Count 8: Sexual Contact With Prisoner Or Offender By Probation/parole Officer/employee Of A Jail, Prison Or Correctional Facility (Class D FELONY) RSMo 566.145 FROM 1/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) Count 9: Sexual Contact With Prisoner Or Offender By Probation/parole Officer/employee Of A Jail, Prison Or Correctional Facility (Class D FELONY) RSMo 566.145 ON 2/14/2011 Time: Place: 200 S Tucker (SCC 22130) Count 10: Sexual Contact With Prisoner Or Offender By Probation/parole Officer/employee Of A Jail, Prison Or Correctional Facility (Class D FELONY) RSMo 566.145 FROM 3/28/2011 TO 3/30/2011 Place: 200 S Tucker (SCC 22130) Count 11: Sexual Contact With Prisoner Or Offender By Probation/parole Officer/employee Of A Jail, Prison Or Correctional Facility (Class D FELONY) RSMo 566.145 ON 4/15/2011 Time: Place: 200 S Tucker (SCC 22130)

529961

3/19/12

2. The facts supporting this belief are as follows: As referenced in the probable cause statement of cause number 1122-CR02924, in early 2012, Stephanie Rodgers was a Corrections Officer for the City of St. Louis assigned to help guard and maintain safety and security at the City of St. Louis Justice Center (Justice Center), a county jail. On March 30, 2012, Corrections Officer C.G. observed Justice Center inmate L.G. texting on a cellular telephone. L.G. was awaiting trial on the charge of Murder in the First Degree. C.G. contacted his supervisor, Lt. K.W., and informed her of the situation after which Justice Center personnel responded to search L.G.s cell for the cellular telephone. The cell phone was not found. However, Corrections Officers located, among other items of contraband, a black case, cellular phone charger, and cellular phone ear plugs. Following this incident, Justice Center employees began listening to inmate L.G.s recorded jail conversations in an attempt to determine who had smuggled the items of contraband into the Justice Center. During this process, employees listened to calls between L.G. and Rodgers discussing Rodgers orchestrating the process of obtaining a cellular telephone and delivering it to L.G. L.G. was calling Rodgers cell phone number at the time, (314) xxx-0538. Employees further determined from the calls that Rodgers was assisting another inmate, F.I., with obtaining a cellular telephone. On April 22, 2011, Corrections Officers searched F.I.s cell and found a cellular phone, cellular phone battery, and a cellular phone charger. Rodgers admitted to St. Louis Metropolitan police officers that, on or about March 25, 2011, she accepted $300.00 from C.G. in exchange for accepting and transporting a cellular telephone into the Justice Center for the use of C.G.s husband, L.G., a Justice Center inmate awaiting trial on the charge of Murder in the First Degree. Rodgers further admitted that on or about March 26, 2011, she took a cellular telephone into the Justice Center and gave it to L.G. for his use in his cell. Finally, Rodgers explained that she was aware F.I, was in possession of a cellular telephone and that she charged the telephone for F.I. on several occasions when she was working in F.I.s pod. During the course of their investigation, law enforcement officials reviewed voluminous recordings of telephone calls between F.I. and Stephanie Rodgers which indicated, among other things, that the two were in a sexual relationship. Some of the calls reviewed contained extremely graphic sexual conversations between Rodgers and F.I. The two discussed marriage, as well as the possibility, in mid-April, that Rodgers was pregnant. The two further talked about Rodgers making it happen with respect to their meeting and having sexual interludes stating, among other things, that it really be good when youre sneaking it. On April 15, 2011, the two engaged in sexual activity over the telephone, with Rodgers masturbating for F.I., specifically indicating she was penetrating her genitals with her finger. After the nine minute event, F.I. questioned Rodgers: You want me to wait to release myself or wait for you to get it? Rodgers replied, It could be days before I get it. From these calls, it became evident that the two were or had been engaging in sexual activity at the Justice Center. On two occasions in January, 2012, law enforcement officials met and spoke with F.I. who was confined at the time in the St. Louis County jail. During these meetings, F.I. indicated he had met Rodgers in December, 2010, while confined at the Justice Center. In January, 2011, F.I. was transported to Bonne Terre on a writ, after which he returned to the Justice Center around January 24, 2011. At this time, F.I. asked a Corrections Officer to smuggle a cellular phone to him at which point that Corrections Officer approached Rodgers, who ultimately brought the cellular phone to F.I. F.I. utilized this cellular telephone to contact many individuals, including both Rodgers and the other corrections officer who had
529961 3/19/12

assisted Rodgers in procuring the telephone. F.I. stated he had this cellular phone until April 22, 2011, when corrections officers caught him with it. F.I. stated that from January to March, 2011, he had sexual intercourse with Rodgers twenty-eight times, not including other sexual contact which also occurred during this time period. The sexual activity occurred in two locations on the fifth floor of the Justice Center where F.I. was housed under protective custody. The first location was F.I.s cell. He did not have a cellmate. The second location was an area known as the bubble, which is an enclosed security tower located in the center of the cells located in Five Charlie on the fifth floor. The bubble is accessible only by corrections officers via an enforced, solid door. Once inside, stairs lead up to the watch area bubble floor. During a normal shift, two corrections officers would work in 5 Charlie, the location of both F.I.s cell and the bubble. One corrections officer would work on the floor and the other inside the bubble. Visiting booths were located in close proximity to the bubble so, when Rodgers wished to have sex, she would announce that F.I. had a visitor. At this point, F.I. would leave his cell to walk, unescorted, to the visiting booth area, at which point he would continue to the door of the bubble where Rodgers would let him in. F.I. recalled several specific sexual encounters. The first time he had sexual intercourse with Rodgers was around January 29, 2011. The two had intercourse while on the stairs leading up to the main floor of the bubble, after which they had intercourse a second time with F.I. on top on the floor of the bubble. Between January 29, 2011 and March 28, 2011, they had sexual intercourse at least one additional time on the bubble floor with F.I. on top. During the same period, they also had sexual intercourse at least one additional time on the bubble floor with Rodgers on top. During this period, the two also engaged in oral sex. Rodgers performed oral sex on F.I. in F.I.s cell both with F.I. sitting on his bed and with F.I. standing up. Rodgers also performed oral sex on F.I. in the bubble. Finally, F.I. performed oral sex on Rodgers in the bubble. During this period, F.I. also penetrated Rodgers genitals with his finger. F.I. specifically recalled having sexual intercourse with Rodgers on additional dates. The two had sexual intercourse on the floor of the bubble on Valentines Day. Also, the last time the two had sexual intercourse was on March 28, 2011, on the floor of the bubble.

Patrick Drennan PRINT NAME

Original Signed SIGNATURE

529961

3/19/12