Case 2020CM000489 Document 2 Filed 05-20-2020 Page 1 of 3

FILED
05-20-2020
STATE OF WISCONSIN CIRCUIT COURT WINNEBAGO COUNTY Clerk of Circuit Court
DA Case No.: 2020WN002043 Winnebago County, WI
STATE OF WISCONSIN Assigned DA/ADA: Amanda L Folger 2020CM000489
Plaintiff, Agency Case No.: L-FP-05-05-2020- Honorable Scott C Woldt
0000851 Branch 2
vs. Court Case No.:

LEONARD D KACHINSKY CRIMINAL COMPLAINT

832 NEFF CT
NEENAH, WI 54956
DOB: 02/17/1953
Sex/Race: M/W
Eye Color: Brown
Hair Color: Brown
Height: 5 ft 6 in
Weight: 144 lbs
Alias: Also Known As LEN
KACHINSKY
Defendant. For Official Use

CRIMINAL CHARGE

Count 1: KNOWINGLY VIOLATING A HARASSMENT RESTRAINING ORDER

The above-named defendant on or about Sunday, April 19, 2020, in the Village of Fox Crossing,
Winnebago County, Wisconsin, did knowingly violate an injunction issued under sec. 813.125(4),
contrary to sec. 813.125(7) Wis. Stats., a Misdemeanor, and upon conviction shall be fined not more
than $10,000 or imprisoned not more than 9 months or both.

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

The undersigned, being first duly sworn on oath and in that capacity has knowledge of the

following:

Your affiant is informed from the reports of the Fox Crossing Police Department kept in the

normal and ordinary course of business in which your affiant believes to be truthful and reliable and

have proven so on numerous occasions in the past that on or about April 30, 2020, Chief T. Seaver

was contacted by management at the Village of Fox Crossing regarding concerning open records

requests that had been made by a former municipal judge, LEONARD D. KACHINSKY, D.O.B.

02/17/1953. The Village of Fox Crossing municipal building is located within the Village of Fox

Crossing, Winnebago County, Wisconsin.

Chief Seaver reports that in March 2020, Kachinsky had sent a public records request to the

Village of Fox Crossing Clerk, Karen B. This records request asked for a copy of all citations issued

under Wisconsin Statute § 346.38. This request was forwarded onto the municipal court clerk, the

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STATE OF WISCONSIN - VS - LEONARD D KACHINSKY
victim. who responded to the Village Clerk that no citations were issued under that statute. Kachinsky

then asked for additional documents and on March 27, 2020, those additional documents were

provided. Within these documents, the Village Clerk included the email from the victim to the Clerk

regarding there being no citations under that statute.

On April 5, 2020, Kachinsky emailed the Village Clerk, contesting that his open records request

was completed. Kachinsky noted that the Village Clerk appeared “to have forwarded the request to [the

victim] who replied there were no records.” Kachinsky asked for copies of the citations, this time using

Wisconsin Statute § 346.48, and included names of those cited.

On April 19, 2020, Kachinsky emailed the Village Clerk again directing her to forward his

request to the victim. Kachinsky stated, “Dear Clerk: I sent an email below on April 5, 2020. I know a

lot has been going on over there. But this just needed to be forwarded to [the victim] and ask her to

find and send you the copies of the citations requested. Further attached is a new open records

request with one item addendum dated April 20, 2020. Thank you for your assistance in this matter.”

The new request sought information as to all legal services bills related to the operation of the

municipal court, and records related to the working hours for the victim on dates in 2017, 2018, and

2019.

Your affiant reports that a harassment injunction was issued in 2018 in Winnebago County Case

No. 2018CV102. Kachinsky is the respondent and the victim is the petitioner. Said injunction was

amended on April 30, 2019 and is effective through April 30, 2021. Conditions of this injunction were

that Kachinsky refrain from engaging in harassing behavior toward the victim, as well as have no

contact with the victim. Said injunction was in full force and effect on April 19, 2020.

All of the above incidents occurred in Winnebago County, Wisconsin.

WHEREFORE, as said affiant verily believes and prays that the said LEONARD D KACHINSKY might
be arrested and dealt with according to law.

Subscribed and sworn to before me on 05/20/20 Electronically Signed By:

Electronically Signed By: Inv. Steven Verwiel
Margaret J. Struve Complainant
Assistant District Attorney
State Bar #: 1096218

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STATE OF WISCONSIN - VS - LEONARD D KACHINSKY

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