Alina+N+Caminiti[1]

8/7/2019 Alina+N+Caminiti[1]

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STATE OF WISCONSIN CIRCUIT COURTSTATE OF WISCONSIN Plaintiff,-vs- COURT CASE #:DA Case #: 2011DA001195

Agency Case #: DCSD 10-325602ALINA N CAMINITIB09 Center stBlack Earth, WI 53515D08: 07103/19B6Sex/Race: FIWEye Color:Hair Coior:Height:Weight:Alias:

Defendant( s).SUMMONS

CONTRARY TO WIS. STAT(S).:94B.03 (2 )(~) ; 939.0594B.03(2)(b); 939.0594B.03(2)(b); 939.05

THE STATE OF WISCONSIN TO SAID DEFENDANT;A complaint, a copy of which is attached, having been made accusing the defendant of committingthe crime(s) of: ' .THE CRIME(S) OF: OFFENSE DATE:Intentional Child Abuse - Bodily Harm; PTAC on or betweenIntentional Child Abuse - Bodily Harm; PTAC August 1B,200BIntentional Child Abuse - Bodily Harm; PTAC through December31,200Bon or betweenJanuary 1, 2009through June 30,2009on or betweenFebruary 21,2010through November1,2010The original of such complaint has been filed in the office of the Clerk of Courts for Dane County.. ~You, the defendant, are therefore summoned to appear before the Circuit Court of Dane Cpunty, atthe Dane County Courthouse, 215 S. Hamilton Street Madison, WI 53703 in courtroom 1A on:DATEITIME: Thursday March 24, 2011 at 10:30 a.m.

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,STATE OF WISCONSIN - VS - Alina N Caminiti

CERTIFICATE OF SERVICEI hereby certify that I served a copy of the Summons' and Criminal Complaint upon the withinnamed defendant by:( ? { ) Personal service ( ) Substitute service by leaving with: _---'- _( ) Attempted ' ( ') Not FoundDate: D b / I S / I i By DCSO'Dep.: ~J\.U) K O J ( + I ' Y l P . f ' iIF YOU REQUIRE THE ASSISTANCE OF AUXILIARY AIDS OR SERVICES BECAUSE OF ADISABILITY, CALL '(608) 266-4678 (TDD (608) 266-4625) AND ASK FOR THE COURT ADACOORDINATOR '

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STATE OF WISCONSIN CIRCUIT COURTCRIMINAL COMPLAINT

DANE COUNTY

STATE OF WISCONSIN Plaintiff,-vs-ALINA N CAMINITI809 Center StBlack Earth, WI 53515DOB: 07/03/1986Sex/Race: FIWEye Color:Hair Color:Height:WE?ight:Alias:

DA Case No.: 2011 DA001195. Assigned ADA:Agency Case No.:. DCSD 10-325602Court Case No.:ATN:

MATTHEW B CAMINITI809 Center StBlack Earth, WI 53515DOB: 05/12/1983Sex/Race: MIW. Eye Color:Hair Color:Height:Weight:Alias:

DA Case No.: 2011 DA001195Asslqned ADA:, Agency Case No.: DCSD 10-325602Court Case No.:ATN:

Defendants,COMPLAINING WITNESSMary Butler, William Hendrickson

The above-named complaining witness being first duiy sworn states the foilowing:Count 1: INTENTIONAL CHILD ABUSE - BODILY HARM - PTAC (As to defendantsAlina N Caminiti and Matthew B Caminiti)The above-named defendants on or between August 18, 2008 through December 31,2008, in the VHlage of Black Earth, Dane County, Wisconsin, as a party to a crime, didintentionally cause bodily harm' to a child, ANC, DOB 06/18/2008, contrary to sec ..948.03(2)(b), 939.50(3)(h), 939.05 Wis. Stats., a Class H Felony, and upon conviction maybe fined not more than Ten Thousand Dollars ($10,000), or imprisoned not more than six(6) years, or both. .Count 2: INTENTIONAL CHILD ABUSE - BODILY HARM - PTAC (As to defendantsAlina N Caminiti and Matthew B Caminiti)The above-named defendants on or between January 1, 2009 throuqh June 30, 2009, inthe Village of Black Earth, Dane County, Wisconsin, as a party to a crime, did intentionallycause bodily harm to a child, ANC, DOB 06/18/2008, contrary to sec. 948.03(2)(b),939.50(3)(h), 939.05 Wis. 8tats., a Class H Felony, and upon conviction may be fined not2/25/2011


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STATE OF WISCONSIN - VS - Alina N Caminiti, Matthew B Caminitimore than Ten Thousand Dollars ($10,000), or imprisoned not more than six (6) years, orboth.Count 3: INTENTIONAL CHILD ABUSE - BODILY HARM (As to defendant Matthew BCaminiti)The above-named defendant on or between July 1, 2009 through December 1, 2009, inthe Village of Black Earth, Dane County, Wisconsin, did intentionally cause bodily harm toa child, ANC, DOB 06/18/2008, contrary to sec. 948.03(2)(b), 939.50(3)(h) Wis. Stats., aClass H Felony, and upon conviction may be fined not more than Ten Thousand Do11ars($10,000), or imprisoned not more than six (6) years, or both.Count 4: INTENTIONAL CHILD ABUSE - BODILY HARM (As to defendant Matthew BCaminiti)The above-named defendant on or between April 1, 2010 through July 1, 2010, in theVillage of Black Earth, Dane County, Wisconsin, did intentionally cause bodily harm to achild, ANC, DOB 06/18/2008, contrary to sec. 948.03(2)(b), 939.50(3)(h) Wis. Stats., aClass H Felony, and upon conviction may be fined not more than Ten Thousand Dollars, ($10,000), or imprisoned not more than six (6) years, or both.Count 5: INTENTIONAL CHILD ABUSE - BODILY HARM -' PTAC (As to defendantsAlina N Caminiti and Matthew B Caminiti)The above-named defendants on or between February 21, 2010 through November 1,2010, in the Village of Black Earth, Dane County, Wisconsin, 'as a party to a crime, didintentionally' cause bodily harm to a child, DB9, DOB 12/21/2009, contrary to sec:948.03(2)(b), 939.50(3)(h), 939.05 Wis. Stats., a Class H Felony, and upon conviction maybe fined not more than Ten Thousand Dollars ($10,000), or imprisoned, not 'more than six(6) years, or both.FACTS:Background: Aleitheia Bible Church (ABC)

In November 2010, the Dane County Sheriffs Department (DCSO) commenced aninvestigation of possible child abuse occurring within a religious group in the Mazomaniearea known as the Aleltheia Bible Church (hereinafter ABC). ,Numerous DCSO Detectivesand Deputies investigated and learned that the ABC was formed in 2006 as a result of abreak within -the Curtis Street Bible Fellowship (CSBF) in Mazomanie, WI. BetweenDecember 2010 and February 2011, the DCSO submitted approximately 450 pages ofreports to the District Attorney's Office for review.Det. Mary Butler interviewed Mark Cymbalak on 11/18/2010 who is the present full-time pastor at the CSBF. Pastor Cymbalak advised that before the split ih 2006, the boardof directors at the CSBF consisted of 11 elders including himself, Phil Caminiti, JohnCaminiti, Todd Barsness, Darwin Parman and Bob Wick. Pastor Cymbalak explained thatthe board was supposed to work together to share decision-making; however Phil Caminitiwanted to be in charge and asserted that he had better qualifications than the others.Pastor Cymbalak recalled that Phil Caminiti wrote two papers describing why beshould bethe church's leader. In March 2006, Phil Caminiti left the CSBF along with Todd Barsness,Darwin Parman and Bob ~ick and their families. Phil Caminiti then formed the ABC.Pastor Cymbalak stated that Phil teaches' "shunning" and that members of the ABC

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.STATE OF WISCONSIN - VS - Alina N Caminiti, Matthew B Caminitiactively shun members of the CSBF by ignoring them and refusing to interact with them ortheir children in any meaningful way .. Phillip CaminitiPhil Caminiti resides at 835 Blue Mounds St., in Black Earth along with his wife,Denise (Parman) Caminiti and seven of their nine children: Andrew Caminiti, OOB:03/20/1985, Carissa Caminiti, OOB: 06/18/1987, Lydia Caminiti, DOB: 03/26/1990, Elisa,DOB: 12/28/1992, MOC, a male, DOB: 05/09/1995, AJC, a male, DOB: 09/01/1997, andCJC, a male, DOB: 12/07/2000. The youngest, CJC is homeschooled, while EMC, MDC .and AJC attend Wisconsin Heights School. Phil Caminiti's eldest, Maria (Caminiti)Stephenson, OOB: 10/27/1981, is married to Timothy Stephenson. They have two young'sons and belong to the ABC. Phil Caminiti's second eldest, Matthew B. Caminiti, is anABC elder who is married to Alina (Harrison) Caminiti. They have two young children,namely ANC, a female, DaB: 06/18/2008 and OBC, a male, DaB: 12/21/2009. They aremembers of ABC.Alina Caminiti

Alina Caminiti resides with her husband Matt Caminiti and their two children, ANC,a 2% year old, DOB: 06/18/2008 and OBC, an11-month old, DaB: 12/21/2009, at 809Center st. in Black Earth; Wisconsin. Deputy Josalyn Longley and Detective SteveWenger interviewed Alina Caminiti (hereinafter Alina) in her home on 11/30/2010. Alinaadvised that she met Matt after she started going to Emmaus College i n 2004 and leftbefore graduation in 2006. She and Matt were married 'in June 2007 and moved to theirpresent area. Alina stated that she then joined the ABC in the fall of 2006. Alina statedthat he husband Matt was a co-elder at ABC.Alina admitted to spanking her daughter ANC with a wooden spoon and a dowel;and admitted to spanking her son D.BCwith a wooden spoon from the time they were two

to three months of age. Alina stated that either she or Matt would do the spanking,depending upon who was with the children at the. time. Alina saw bruising on both of herchildren as a result of these spanking incidents. Alina stated that the last time she spankedher children was at least three to four weeks ago ..VVhenAlina discussed spanking ANC beginning at two to three months of age, sheexplained that she would only spank if she could see that ANC was getting "angry" aboutsomething or not listening. As an example, Alina described being at church when ANCwas young and trying to hand her to other members of the church, however, ANC wouldcry when she went to other people. For this, Alina took ANC to another room and spankedher. She stated that the church service spankings took place in Phil Caminiti's house.

Alina said she used a flat wooden stir fry spoon to spank when ANC was younqer andexplained that the purpose is to inflict pain on the child.

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Alina 'stated that she spanked ANC around once every two weeks when ANC wasbetween two and six months of age and there was probably bruising but she didn'tremember. Orice ANC turned six months, until about one year old, (12/18/2008-0611812009), Alina believed she was spanking ANC two to five times a week, because they. were working on her listening and training during this period. Alina could not rememberspecific times when she saw bruising but knew that it was very common to see bruising.Alina stated that she and Matt W041d usually not spank an already-sore areas on ANC'sback side and would switch to striking another side of her buttock or thigh. Alina described


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Alina stated that she and Matt started spanking their son, DBC, DOB: 12/21/2009when he.was about two months old, (02/21/2010). They would spank DBC on the barebutt with a wooden spoon and Alina recalled seeing bruising on his buttocks "areaapproximately five times. Alina stated that her son "bruises easily so he probably bruisedevery time he was spanked." Alina explained that they graduate from using a woodenspoon to a wooden dowel when the child is older and' "meatier enough" to handle it.

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STATE OF WISCONSIN - VS - Alina N Caminiti, Matthew B Caminitithe injury as usually red or light purple bruising in the locations where they would spank;and believed that around one out of every three spankings would result in a bruise. Alinarecalled a time when ANC was about 10 months old and they were using the woodenspoon to discipline her. ANC was having a tough time sitting. She and Matt felt that it waspossibly a result of their spanking. . .According to Alina, most of the members of the ABC spank their children. Phil. would usually hold small meetings for couples with young children and would give themideas and tips on parenting. Alina knew that Phil showed members of the church how touse the wooden dowel for training their children and Alina has seen Phil hit his own legwith a wooden dowel while showing members how to use it. According to Alina, Phildescribed these spankings to the members as "inflicting pain so the kids don't do the actsagain."

Matthew CaminitiDetective Steve Wenger and Deputy Josalyn Longley interviewed Matthew Caminiti(hereinafter Matt) in his home on 11/30/2010. Matt advised that he is currently an "elder,iwith ABC, which is a full-time paid position which he shares with two other "elders"including his father, Phil. and Todd Barsness. In addition, Matt is the appointed treasurerof the church.When asked about discipline, Matt acknowledged that he and his wife spank theirchildren. Matt stated that corporal punishment is the best way to show that disobedienceis not allowed, quoting the Biblical reference "the rod." ..Matt explained that the rod is usedon a "bare butt" or thigh and that the spanking should hurt and be painful. Matt stated thatwhile spanking can occur over clothing or a diaper, it wouldn't be productive as it needs tohurt; and the pain needs to remind them that they cannot do the wrong. Matt said that theABC explains the Biblical reasoning of spanking to its members, however, encouragesmore of it to take place at home.

When asked about the last time any of the children were spanked, Matt said thatDBC was spanked a couple of weeks ago or even longer. Matt said that he spanksanywhere from one to thre'e strikes on their bottom or upper thigh and are "hard enough toinflict pain." Matt said that the spankings need to hurt and be painful.2/25/2011 4

Regarding his own children, two-year old ANC, DOB: 06/18/2008 and 11-month.oldDBC, DOB: 12/21/2009, Matt said that they started spanking both children when they wereboth around two months old, with a flat wooden spoon. Matt acknowledged that on someoccasions, the spankings would leave some bruising on their bottoms. When asked, Mattestimated that he has seen bruising around five times in the past on his son DBC, whichbruising consisted of a red mark or a purple discoloration on the surface about the size of aflat wooden spoon. He said that the bruise would only last a day or less. Matt said thatbruising was more 'prevalent on his daughter ANC than his son.


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~~~ASSISTANT/D P DISTRICT ATTORNEYDANE COUNTY, WISCONSIN

STATE OF WISCONSIN - VS - Alina N Caminiti, Matthew B Caminiti. Chuck an,d Cynthia were present for the birth of their granddaughter, ANC, on

06/18/2008. Tiley returned for a visit when ANC was between two and four months old.At this time Cynlhla told him that she had seen bruising on ANC while changing a diaper,and that he and Cynthia were concerned. Chuck said that they were aware that manyfamilies at the ABC used a wooden spoon and believed it was Biblical.Chuck stated over the next year they were not involved in much of Alina's life andfelt that they were losing her. In the winter of 2009, Chuck stated that Alina wrote him aletter saying that she had not been submitting to Matt and now intended to fully submit,which concerned him. Chuck relayed that he believed Phil Caminiti's preaching and powerhad a lot to do with the fact that they were not seeing their daughter or grandchildren. InFebruary 2010. Chuck stated that he called Alina and expressed concerns about thebruising that Cynthia had seen on ANC. Alina told Chuck that "this" is their practice andshe is committed to it. On 02/02/2010 Alina emailed her father, stating "we believe theway that we discipline is what scripture requires to achieve that goaL"

Affiant, Your affiant is a Detective with the Dane County Sheriffs Department (DCSO) whohas knowledge of these facts from readlnq: 1) the official law enforcement agency reportsof the DCSO prepared by Deputies Josalyn Longley; Timothy Blanke, James Kartman,Stacy Dura-Jacobs, Cindy Holmes, Leslie Fox, Clint Selzner, Todd Dosher, RichardBennett and Brooke Gagner; as well as the reports of DCSO Detectives WilliamHendrickson, Mary Butler, Janet Boehnen, Dawn Johnson, Steve Wegner, Peter Hanson,Gwen Ruppert, Brian Lukens, Ron Dorn and Katherine Wessel, whose reports are reliableas they were prepared in the normal, course of law enforcement duties; 2) the statementsof Phillip, Matthew and Alina Caminiti who provided their statements contrary to their penal

interests; and 3) the statements make by citizens including Charles and Cynthia Harrisonwho are eyewitnesses to the facts they relate.

Subscribed and sworn to before me,and approved for filing on:Thisftday of March, 2011

, l.

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Alina+N+Caminiti[1]