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DIV #: CAUSE#: DESTINATION: GRAND JURY DEFENDANT INFORMATION ADDRESS: 32XX REX AVE Saint Louis, MO 63104 PEDIGREE:

RACE: W DOB: 09/XX/1980 HGT: 6'00" SEX: M AGE: 32 WGT: 270 ID #s: COMPLAINT#: 130019935 LID: ARREST#: 5130010544 DIST: OCN: C2068029 ALIASES: SSNs:

STATE OF MISSOURI VS MARLER, DAVID ALLEN CA#: 510647738

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: STATUTORY SODOMY 2ND DEG (Class C FELONY) RSMo 566.064 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 11077) The defendant, in violation of Section 566.064, RSMo, committed the class C felony of statutory sodomy in the second degree, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between April 21, 2013 at 3:00 PM and April 21, 2013 at 6:00 PM, in the City of St. Louis, State of Missouri, the defendant had deviate sexual intercourse with Student A, by putting his penis in the mouth of Student A, and at that time Student A was less than seventeen years old and the defendant was twenty-one years of age or older.

Count 2: STATUTORY SODOMY 2ND DEG (Class C FELONY) RSMo 566.064 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 11077) The defendant, in violation of Section 566.064, RSMo, committed the class C felony of statutory sodomy in the second degree, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between April 21, 2013 at 3:00 PM and April 21, 2013 at 6:00 PM, in the City of St. Louis, State of Missouri, the defendant had deviate sexual intercourse with Student A, by putting his mouth on Student A's penis, and at that time Student A was less than seventeen years old and the defendant was twenty-one years of age or older.

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Count 3: STATUTORY SODOMY 2ND DEG (Class C FELONY) RSMo 566.064 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 11077) The defendant, in violation of Section 566.064, RSMo, committed the class C felony of statutory sodomy in the second degree, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between April 21, 2013 at 3:00 PM and April 21, 2013 at 6:00 PM, in the City of St. Louis, State of Missouri, the defendant had deviate sexual intercourse with Student A, by inserting his finger into Student A's anus, and at that time Student A was less than seventeen years old and the defendant was twenty-one years of age or older.

Count 4: STATUTORY SODOMY 2ND DEG (Class C FELONY) RSMo 566.064 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 11077) The defendant, in violation of Section 566.064, RSMo, committed the class C felony of statutory sodomy in the second degree, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between April 21, 2013 at 3:00 PM and April 21, 2013 at 6:00 PM, in the City of St. Louis, State of Missouri, the defendant had deviate sexual intercourse with Student A, by inserting his penis into Student A's anus, and at that time Student A was less than seventeen years old and the defendant was twenty-one years of age or older.

Count 5: Statutory Sodomy 2nd Degree (Class C FELONY) RSMo 566.064 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union

(SCC 11077)

The defendant, in violation of Section 566.064, RSMo, committed the class C felony of statutory sodomy in the second degree, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between April 21, 2013 at 3:00 PM and April 21, 2013 at 6:00 PM, in the City of St. Louis, State of Missouri, the defendant had deviate sexual intercourse with Student A, by licking Student A's anus, and at that time Student A was less than seventeen years old and the defendant was twenty-one years of age or older.

Count 6: Sexual Contact With Student By Teacher, Student Teacher, Employee, Contract Employee, School Official Or Volunteer (Class D FELONY) RSMo 566.086 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 22023) The defendant, in violation of Section 566.086, RSMo, committed the class D felony of sexual contact with a student, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between April 21, 2013 at 3:00 PM and April 21, 2013 at 6:00 PM, in the City of St. Louis, State of
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Missouri, the defendant was a teacher for the St. Louis Public Schools at Soldan International Studies High School, and knowingly had sexual contact with Student A, a student of Soldan International Studies High School by engaging in the conduct described in Count I herein.

Count 7: Sexual Contact With Student By Teacher, Student Teacher, Employee, Contract Employee, School Official Or Volunteer (Class D FELONY) RSMo 566.086 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 22023) The defendant, in violation of Section 566.086, RSMo, committed the class D felony of sexual contact with a student, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between April 21, 2013 at 3:00 PM and April 21, 2013 at 6:00 PM, in the City of St. Louis, State of Missouri, the defendant was a teacher for the St. Louis Public Schools at Soldan International Studies High School, and knowingly had sexual contact with Student A, a student of Soldan International Studies High School by engaging in the conduct described in Count II herein.

Count 8: Sexual Contact With Student By Teacher, Student Teacher, Employee, Contract Employee, School Official Or Volunteer (Class D FELONY) RSMo 566.086 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 22023) The defendant, in violation of Section 566.086, RSMo, committed the class D felony of sexual contact with a student, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between April 21, 2013 at 3:00 PM and April 21, 2013 at 6:00 PM, in the City of St. Louis, State of Missouri, the defendant was a teacher for the St. Louis Public Schools at Soldan International Studies High School, and knowingly had sexual contact with Student A, a student of Soldan International Studies High School by engaging in the conduct described in Count III herein.

Count 9: Sexual Contact With Student By Teacher, Student Teacher, Employee, Contract Employee, School Official Or Volunteer (Class D FELONY) RSMo 566.086 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 22023) The defendant, in violation of Section 566.086, RSMo, committed the class D felony of sexual

contact with a student, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between April 21, 2013 at 3:00 PM and April 21, 2013 at 6:00 PM, in the City of St. Louis, State of Missouri, the defendant was a teacher for the St. Louis Public Schools at Soldan International Studies High School, and knowingly had sexual contact with Student A, a student of Soldan International Studies High School by engaging in the conduct described in Count IV herein.

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Count 10: Sexual Contact With Student By Teacher, Student Teacher, Employee, Contract Employee, School Official Or Volunteer (Class D FELONY) RSMo 566.086 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 22023) The defendant, in violation of Section 566.086, RSMo, committed the class D felony of sexual contact with a student, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between April 21, 2013 at 3:00 PM and April 21, 2013 at 6:00 PM, in the City of St. Louis, State of Missouri, the defendant was a teacher for the St. Louis Public Schools at Soldan International Studies High School, and knowingly had sexual contact with Student A, a student of Soldan International Studies High School by engaging in the conduct described in Count V herein.

Count 11: Endangering Welfare Of Child 1st Degree (Class C FELONY) RSMo 568.045 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 26045) The defendant, in violation of Section 568.045, RSMo, committed the class C felony of endangering the welfare of a child in the first degree, punishable upon conviction under Sections 558.011 and 560.011, RSMo, in that on or between April 21, 2013 at 3:00 PM and April 21, 2013 at 6:00 PM, in the City of St. Louis, State of Missouri, the defendant knowingly acted in a manner that created a substantial risk to the life and body and health of Student A, a child less than seventeen years old, by advising Student A to inhale and furnishing an inhalent to Student A that caused Student A to become dizzy and lightheaded.

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 _______________________________ Assistant Circuit Attorney

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PROBABLE CAUSE STATEMENT

DATE: April 30, 2013 I, Tonya Tanksley, DSN 7412 , 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 David Allen Marler, a White Male DOB: 9/XX/80 Age: 32, committed one or more criminal offense(s). Count 1: Statutory Sodomy In The Second Degree (Class C FELONY) RSMo 566.064 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 11077) Count 2: Statutory Sodomy In The Second Degree (Class C FELONY) RSMo 566.064 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 11077) Count 3: Statutory Sodomy In The Second Degree (Class C FELONY) RSMo 566.064 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 11077) Count 4: Statutory Sodomy In The Second Degree (Class C FELONY) RSMo 566.064 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 11077) Count 5: Statutory Sodomy In The Second Degree (Class C FELONY) RSMo 566.064 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 11077) Count 6: Sexual Contact With A Student On Public School Property (Class D FELONY) RSMo 566.086 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 22023) Count 7: Sexual Contact With A Student On Public School Property (Class D FELONY) RSMo 566.086 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 22023) Count 8: Sexual Contact With A Student On Public School Property (Class D FELONY) RSMo 566.086 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 22023) Count 9: Sexual Contact With A Student On Public School Property (Class D FELONY) RSMo 566.086 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 22023) Count 10: Sexual Contact With A Student On Public School Property (Class D FELONY) RSMo 566.086 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 22023) Count 11: Endangering Welfare Of A Child In The First Degree (Class C FELONY) RSMo 568.045 FROM 4/21/2013 at 3:00 PM TO 4/21/2013 at 6:00 PM Place: Cates near Union (SCC 26045) 2. The facts supporting this belief are as follows: I observed Student A, a male born in 199X, disclose to a trained forensic interviewer that on April 21, 2013 in a residence located very close to the intersection of Cates and Union defendant: inserted his penis into Student As mouth, put his mouth on Student As penis, inserted his finger into Student As anus, inserted his penis into Student As anus and licked Student As anus. Victim also disclosed that defendant provid ed Student A with some kind of inhalant and told Student A to inhale the fumes and that caused Student A to become dizzy and
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lightheaded. Student A is a student at Soldan International Studies High School, and defendant is a teacher at that same school.

Tonya Tanksley, Dsn 7412 PRINT NAME

SIGNATURE

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