SUPERIOR COURT OF THE STATE OF RIDGEWAY
STATE OF RIDGEWAY
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CASE NO. 0000-00000Z
CRIMINAL INFORMATION
Plaintiff
v.
TOOLAN10101
Defendant
CRIMINAL INFORMATION
Comes forth the State of Ridgeway to seek justice and preserve the dignity of the state and
therein charge the defendant as follows;
COUNT ONE - 3 S.C.C § 10 - FIRST-DEGREE MURDER
OFFENSE TYPE - FELONY
The act of committing murder in the course of committing or attempting to commit kidnapping,
burglary, robbery, arson, obstruction or retaliation; or of committing murder of a peace officer or civil
department employee discharging a lawful and official duty, with the knowledge of the person being a
peace officer or civil department employee; or of committing murder with malice aforethought. On or
about February 11, 2024, the Defendant intentionally caused the death of Aspenfun, an RCTA civil
department employee discharging a lawful and official duty patrolling Ridgeway County in a marked
RCTA Tow Truck wearing a marked RCTA uniform by shooting at them using a Stetson M2-A rifle.
COUNT TWO - 5 S.C.C § 03 - UNLAWFUL DISCHARGE OF A FIREARM
OFFENSE TYPE - MISDEMEANOR
The act of discharging a firearm while within city limits / residential areas without legal means to do
such as a proper permit or for self defense. On or about February 11, 2024, the Defendant did discharge
their Stetson M2-A firearm within Palmer City Limits without legal means to do so and while not acting
in self defense.
COUNT THREE - 5 S.C.C § 08 - UNLAWFUL POSSESSION OF GOVERNMENT-ISSUED
EQUIPMENT
OFFENSE TYPE - FELONY
The act of unlawfully possessing any police-grade equipment in any off-duty or civilian storage device,
capacity, or other inventory not mentioned of which is not authorized by law or relevant departmental
policy. On or about February 11, 2024, the Defendant was in possession of a Stetson M2-A, a
police-grade firearm, in their civilian inventory not authorized by law or relevant departmental policy.
STATEMENT OF PROBABLE CAUSE
I, Marinify, being duly sworn, state as follows:
INTRODUCTION AND OFFICER BACKGROUND
I am a Deputy in the Ridgeway County Sheriff’s Office and a Detective in the Criminal Investigations
Division (hereinafter “CID”). As a law enforcement officer, I am empowered to conduct investigations.
I have been employed with the Sheriff’s Office since the 28th of June, 2021.
I have investigated a multitude of cases involving organized crime, homicides, firearms crime, and
distribution of illegal firearms and equipment.
This affidavit is being submitted in support of a criminal complaint alleging that TOOLAN10101
violated the following state criminal laws: 3 S.C.C § 10 (First-Degree Murder), 5 S.C.C § 03 (Unlawful
Discharge of a Firearm) and 5 S.C.C § 08 (Unlawful Possession of Government-Issued Equipment).
This affidavit is based on my personal knowledge, information provided to me by other law enforcement
agents, law enforcement records, witness interviews, and my training and experience, as well as the
training and experience of other law enforcement agents.
Because this affidavit is being submitted for the limited purpose of establishing probable cause in
support of a criminal complaint, I have not included each and every fact known to me concerning this
investigation. I have only set forth the facts that I believe are necessary to establish probable cause that
the defendant violated the state criminal laws set forth herein.
PROBABLE CAUSE
On the 11th of February, 2024, aspenfun was on duty as a tow operator for the Ridgeway County
Transport Authority.
While driving on the US-395 Eastbound by exit 23, Aspenfun was forced to a stop by a pink Actila.
Moments later, a light grey Actila abruptly collided with the back of the tow truck. At that moment,
TOOLAN10101 exited the vehicle and climbed on top of the tow truck bed. TOOLAN10101 then
opened fire upon the transit employee using a Stetson M2-A rifle. In the process, numerous shots were
fired, most of which struck the tow truck’s frame. In an attempt to flee, transit employee Aspenfun drove
down the exit ramp. Despite his attempt to flee for his life, he was fatally shot by TOOLAN10101.
At the time of the incident, Aspenfun was in a marked uniform, driving a marked tow truck, indicating
that he was a civil department employee.
I swear that all statements made in this statement of probable cause are true and correct to the
best of my knowledge under the pains and penalties of perjury.
Affiant Marinify
Detective, Criminal Investigations Division
Ridgeway County Sheriff’s Office
Executed:
03/06/2024
Being authorized to prosecute the offenses charged, I approve this information
Prosecutor /s/ Techiey
Attorney General
Ridgeway Department of Justice
Executed:
03/06/2024
