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State of Minnesota District Court County of Washington 10th Judicial District CR-2015-221 Prosecutor File No. 82-CR-15-1075 Court File No. State of Minnesota, COMPLAINT Plaintiff, Summons vs. DAVID WEBSTER ECKBERG DOB: 08/31/1951 5055 Normandale Avenue N Stillwater, MN 55082 Defendant. The Complainant submits this complaint to the Court and states that there is probable cause to believe Defendant committed the following offense(s): COUNT I Charge: Taxes-failure to pay or collect-F Minnesota Statute: 289A.63.1(b), with reference to: 289A.63.1(b) Maximum Sentence: 5 years, $10,000 or both Offense Level: Felony Offense Date (on or about): 02/28/2010 to 02/05/2012 Control #(ICR#): 20120014 Charge Description: willfully attempt to evade or defeat a tax law by failing to remit a tax when required to do so; Sales and Alcohol Tax due to be collected and remitted on or before February 5, 2011 COUNT II Charge: Taxes-failure to pay or collect-F Minnesota Statute: 289A.63.1(b), with reference to: 289A.63.1(b) Maximum Sentence: 5 years, $10,000 or both Offense Level: Felony Offense Date (on or about): 02/28/2010 to 02/05/2012 Control #(ICR#): 20120014 Charge Description: willfully attempt to evade or defeat a tax law by failing to remit a tax when required to do so; Sales and Alcohol Tax due to be collected and remitted on or before February 5, 2012 COUNT III Charge: Taxes-failure to pay or collect-F Minnesota Statute: 289A.63.1(b), with reference to: 289A.63.1(b) Maximum Sentence: 5 years, $10,000 or both Offense Level: Felony Offense Date (on or about): 02/28/2010 to 02/05/2012 1

Dave Eckberg Criminal Complaint

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Dave Eckberg was charged with tax evasion this week in Washington County District Court relating to his work as promoter of Lumberjack Days.

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Page 1: Dave Eckberg Criminal Complaint

State of Minnesota District CourtCounty of Washington 10th Judicial District

CR-2015-221Prosecutor File No.82-CR-15-1075Court File No.

State of Minnesota, COMPLAINT

Plaintiff, Summons

vs.

DAVID WEBSTER ECKBERG DOB: 08/31/1951

5055 Normandale Avenue NStillwater, MN 55082

Defendant.

The Complainant submits this complaint to the Court and states that there is probable cause to believeDefendant committed the following offense(s):

COUNT I

Charge: Taxes-failure to pay or collect-FMinnesota Statute: 289A.63.1(b), with reference to: 289A.63.1(b)Maximum Sentence: 5 years, $10,000 or bothOffense Level: Felony

Offense Date (on or about): 02/28/2010 to 02/05/2012

Control #(ICR#): 20120014

Charge Description: willfully attempt to evade or defeat a tax law by failing to remit a tax when required todo so; Sales and Alcohol Tax due to be collected and remitted on or before February 5, 2011

COUNT II

Charge: Taxes-failure to pay or collect-FMinnesota Statute: 289A.63.1(b), with reference to: 289A.63.1(b)Maximum Sentence: 5 years, $10,000 or bothOffense Level: Felony

Offense Date (on or about): 02/28/2010 to 02/05/2012

Control #(ICR#): 20120014

Charge Description: willfully attempt to evade or defeat a tax law by failing to remit a tax when required todo so; Sales and Alcohol Tax due to be collected and remitted on or before February 5, 2012

COUNT III

Charge: Taxes-failure to pay or collect-FMinnesota Statute: 289A.63.1(b), with reference to: 289A.63.1(b)Maximum Sentence: 5 years, $10,000 or bothOffense Level: Felony

Offense Date (on or about): 02/28/2010 to 02/05/2012

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Control #(ICR#): 20120014

Charge Description: willfully attempt to evade or defeat a tax law by failing to remit a tax when required todo so; Non-Resident Entertainment Tax due to be collected and remitted on or before February 28, 2010

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STATEMENT OF PROBABLE CAUSE

The Complainant states that the following facts establish probable cause:

I, Jeff Slater, am a manager and supervisor for the Minnesota Department of Revenue. My duties includeresponsibility for the Criminal Investigation Division (CID) of the Minnesota Department of Revenue(MNDOR). MNDOR/CID is responsible for criminal investigations into alleged violations of the tax laws ofthe State of Minnesota. In January 2012, the Office of the Washington County Attorney in Stillwater,Minnesota sought the assistance of MNDOR/CID for possible felony tax violations committed by DavidWebster Eckberg, the Defendant herein by and through corporate entities of which he was the principal.Those corporate entities included the Lumberjack Days Festival Association (LDFA) and St. Croix Events,Inc. (SCE). Possible tax violations had come to light as a result of an investigation by the Stillwater PoliceDepartment and the Washington County Sheriff's Office into events and activities of the Defendantsurrounding the operation by the Defendant of a large community festival in Stillwater, Minnesota known asLumberjack Days that was operated by and with these business entities run by the Defendant. As part ofthat investigation the Washington County Attorney's Office also retained the service of a private forensicaccounting entity. The MNDOR case was assigned to Investigator Michael Morehead of CID. Moreheadconducted an extensive investigation of many aspects of the operation of the Lumberjack Days activitiesby the Defendant. Morehead put several aspects of the criminal revenue investigation on hiatussubsequent to the Defendant being criminally charged with multiple felony counts in Washington CountyDistrict Court. Upon conclusion of that prosecution with the Defendant's conviction for felony issuance ofworthless checks Morehead resumed the investigation. I have reviewed the files, records and research of the investigation conducted by Agent Morehead. Basedupon the investigation of Morehead and the files and records referenced in this Complaint, I believe thefollowing information to be true and correct.

TRUST TAXES GENERALLY Sales Tax, Alcohol Tax and Non-Resident Entertainment (NRE) Taxes are trust taxes. Any entity that hassales or activities subject to trust taxes must register with the Minnesota Department of Revenue. MNDORassigns a business ID number and sets up filing and remitting periods. Both the business and businessowners are responsible for meeting all filing and remittance obligations. MNDOR effectively partners with abusiness and "trusts" the business to collect taxes and turn them over to MNDOR. The tax arises themoment a taxable sale is made or a transaction occurs and immediately becomes the property of theMinnesota Department of Revenue. The taxes are to be set aside and held in trust by the vendor untilremitted to MNDOR. For NRE Taxes the tax is generally withheld from the advance payment made to theentertainer by the promoter. Most entertainment contracts list the NRE Tax as withheld causing the NRE taxto come into existence the moment the contract payment is made. Trust tax money belongs to the State ofMinnesota the moment it comes into existence. The failure to remit a trust tax is akin to felony theft ofgovernment funds. Willful failure to remit trust taxes is a felony violation of Minn. Stat. 289A.63(l)(b).

LDFA was a 501(c)(4) non-profit entity that conducted activities subject to Minnesota Sales Tax, AlcoholTax, and NRE Tax. It had a legal duty to register with MNDOR and comply with all MNDOR requirementsincluding filing and remitting requirements. LDFA never registered with MNDOR. It contracted with SCE asits agent or otherwise simply allowed SCE to handle its affairs. Delegation of duties to SCE did not relieveLDFA and its officers from liability for taxes. SCE, a professional event management business, isregistered with MNDOR for a variety of taxes including Sales Tax. It took on LDFA's tax filing duties asevidenced by its filing of LDFA's Federal Form 990's and multiple requests for legal tax advice regardingSCE's need to collect and remit Sales Tax for LDFA events. LDFA, SCE, and their representative theDefendant were required to remit all taxes when due. Both organizations and the Defendant failed to meet

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this obligation.

SALES AND ALCOHOL TAX INVESTIGATION MNDOR/CID has found through experience large festivals operated by promoters are rarely exempt fromSales and Alcohol Taxes. While reviewing items seized from the Defendant's home with a search warrantMorehead noted a 1999 letter to Defendant from his attorney Cass Weil. A copy of that letter was sent tothe Defendant with a request he waive attorney/client privilege so Morehead could interview his attorney.The waiver was signed by the Defendant. This led to an interview of the attorneys by Morehead.

Weil was given a copy of his 1999 letter regarding Sales Tax. Weil strongly denied his letter was a legalopinion that LDFA was not subject to Sales Tax. He stated he was never given enough information aboutthe operation of LDFA to render a legal opinion. He stated the letter did not state Lumberjack Days Festivalwas exempt from Minnesota Sales Tax. When he was asked for a new Sales Tax opinion in 2011 hereferred the request to Yuri Berndt, a tax expert attorney. Yuri Berndt was shown by Morehead his 2011 letter regarding Sales Tax for LDFA. He stated he was neverasked for a full legal opinion as to the Sales Tax liability of LDFA in 2011. He indicated he was never givenenough information to render a legal analysis of LDFA's liability for Sales Tax. Neither Mr. Berndt nor Mr.Weil knew the Defendant was filing Federal Form 990's listing LDFA as a 501(c)(4) non-profit rather thanas 501(c)(3) non-profit. Morehead gave Berndt some facts about the operation of Lumberjack DaysFestival and its relationship with St. Croix Events, Inc. Based on that information Berndt stated LumberjackDays Festival Association would be subject to Sales Tax. Sales Tax Audit Activity DOR employee Demko conducted a Sales Tax audit of St. Croix Events, Inc. for tax years 2008 through2010 starting in February 2011. She was interviewed as part of the investigation. She interviewed theDefendant and corresponded with him via phone, mail and e-mails from February 2011 until the auditclosed on 10-24-2011. Demko was told by or led to believe by comments made by the Defendant anySales Taxes for events managed by St. Croix Events, Inc. were the responsibility of vendors at the eventsor customers of St. Croix Events, Inc. The Defendant specifically told her that there were no admissioncharges for LDFA. Her notes indicate she was led to believe Lumberjack Days Festival Association was a501(c)(3) non-profit. During her audit she raised issues about the difference between 2009 deposits andrevenues. 2009 total revenues were at least $200,000 lower than total deposits. The Defendant suggestedshort term loans from credit cards might explain the difference. She concluded her audit finding $899.48 intaxes along with interest and other charges for a total of $1,114.57. This amount was assessed to St. CroixEvents, Inc. on 10-14-2011. Based on the Defendant's statements she never looked at Sales Taxes forbeverage sales or admissions. The Defendant wrote a letter to MNDOR seeking an abatement ofpenalties. He also stated he now fully understood his tax obligations and would comply with them in thefuture. His request for penalty abatement was granted. The debt from the Demko Sales Tax audit remainsoutstanding. Demko was contacted shortly after the CID investigation started. She was surprised to learnLDFA charged admission to some of its events, sold beer and pop, that it relied upon St. Croix Events, Inc.to handle all of its tax matters and it was not a 501(c)(3).

Sales Tax Analysis and Conclusions Both the 1999 and the 2011 legal opinion letter discuss aspects of Minnesota Statute 297A. The statutewas rewritten after 1999 and the pertinent references made in the 1999 letter were recodified under297A(14). The basic requirements remained the same. 297A(14) (a) (1-2) requires a non-profit keep its own books and use all net proceeds for charitable,religious or educational purposes. That later part of the statute describes a 501(c)(3) non-profit. LDFA wasa 501(c)(4) non-profit and had no restrictions on funding only charitable, religious or educational entities.LDFA was created primarily by Stillwater business people for the purpose of holding a festival to bringpeople and money to Stillwater. 297A(14)(b)(2) states all profits must be used exclusively for charitable, religious, or educational purposes.

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LDFA board members described the LDFA/SCE contract as a risk and reward contract. SCE took inwhatever profits could be made from the event. There is no record of any money ever going to anycharitable, religious or educational entity or ever being intended to go to such entities. 297A(14)(b)(3) requires separate accounting records. No such records for LDFA have been found to exist.The various records discovered to date are so comingled with other records as to make a realisticaccounting of any entity nearly impossible.

297A(14)(b)(7) makes LDFA ineligible for Sales Tax exemption since it entered into a risk and rewardcontract with SCE and its annual benefits were less than the taxes that would have been generated.

297A(14)(c) excludes non-profits that share net earnings with private individuals. LDFA clearly intended toshare profits with SCE. LDFA sold beer and other beverages at its festivals. MNDOR files associated with this case have copiesof liquor permits, information from beer vendors, excerpts from a criminal complaint and testimony frommany witnesses. Fanfare Attractions records show how much money was collected from booths makingtaxable sales. Using this information the Sales Tax Division staff was able to make estimates of taxesowed. The Defendant is a business person who has been in the promotion business for decades and whoroutinely filed Federal Form 990's for his client. He failed to file and remit Sales and Alcohol Taxes for allyears that SCE operated the Lumberjack Days Festival. SCE's tax obligations transfer personally to theDefendant since he is an officer and owner. The Sales and Alcohol Tax debt exceeds $100,000 and maybe more than $121,000 for the years covered by MNDOR's investigation. NON-RESIDENT ENTERTAINERS TAX INVESTIGATION Non-Resident Entertainer Tax Audit Activity Review of St. Croix Events, Inc. files noted an outstanding debt for Non-Resident Entertainer Tax (NRE). AnNRE audit was started in 2008 after the MNDOR Withholding Division was alerted to NRE problems withSt. Croix Events, Inc. Non-Resident Entertainers Tax is mandated by MN Stat. 290.920. It is a 2% tax on thegross amount of money paid to entertainers from outside of Minnesota. Subd. 7 of the Statute mandatesthe tax be withheld at the time of payment by the person or entity making the payment to the non-residententertainer. It is therefore a Withholding tax and the MNDOR Withholding Division administers it. Sudb. 7states MN Stat. 289A.63, the criminal penalties statute, applies to MN. Stat. 290.9201. Sudb. 8 states thatNRE Tax must be deposited with the Commissioner of Revenue. As a trust tax it automatically comes intoexistence the moment the entertainer agrees to a contract, payment is made and money is deducted. Thetax is withheld from the contract payment like any other withholding trust tax and is legally the property ofMNDOR. The promoter is "trusted" to retain the tax and remit it according to MNDOR required deadlines.

An NRE deposit form and the NRE Tax must be deposited with MNDOR by the last day of the monthfollowing any performance. The promoter is required to give each entertainer a Form 1099-MISC. Thepromoter must file an annual form summarizing the previous year's NRE withholding for all events. Thepromoter is required to list all 1099-MISCs issued on annual form. The form is due by February 28. An NRE audit began after entertainers filed for their NRE 2007 tax refunds and no NRE forms were foundfor either Lumberjack Days Festival Association or St. Croix Events, Inc. Messages were left with St. CroixEvents, Inc. on June 8, 2008, January 8, 2009, and February 11, 2009. The Defendant was finally contactedon February 12, 2009. He indicated he would be meeting with his accountants on 2-17-2009. On 4-25-2009 an auditor's note states the Defendant admitted St. Croix Events, Inc. paid entertainers. The notestates Defendant admitted learning in 2008 that St. Croix Events, Inc. was responsible for NRE Taxes. Mr.Eckberg retained attorney Yuri Berndt to handle the NRE matters effective 5-12-2009. Twelve more notesafter Mr. Berndt was retained until 6-7-2010 document repeated efforts by the auditors to bring theDefendant into compliance. The Withholding Division completed a NRE audit on St. Croix Events for tax years 2006 through 2009. Theaudit resulted in a tax debt of $14,780.70, including penalties and interest, effective October 14, 2010. The

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Defendant filed an appeal asking the overall debt be reduced. The taxes were not remitted and on April 22,2011, a Collections Division Demand to Pay letter was issued to St. Croix Events, Inc. The Collectionsletter offered a payment plan for the NRE Tax and it appears that St. Croix Events, Inc. entered into apayment plan shortly thereafter. The Defendant's appeal letter stated he was now aware of his NREobligations and would comply with all future NRE obligations. On March 1, 2011, the Defendant's appealwas denied. The 2011 festival was held and NRE Taxes for that year were withheld. No required formswere filed and no NRE Taxes were remitted for 2011. In November 2011 St. Croix Events, Inc. was indefault for its 2006-2009 NRE taxes and the payment plan was terminated. The NRE debt for those yearsremains outstanding. St. Croix Events, Inc. did file and remit required NRE related forms and taxes for tax year 2010. Thisestablished the Defendant knew of his obligations. No filings or tax remittances have been received for taxyear 2011, the last year St. Croix Events, Inc. held a Lumberjack Days Festival using out of stateentertainers.

T.E.A. Productions is owned and operated by Jack Thibault. He was issued a subpoena for testimony andrecords and was interviewed. He described himself as a talent buyer who helps pair up entertainers withevents. He has worked with the Defendant for many years lining up musical acts to perform at LumberjackDays. He provided some records covering contracts for Lumberjack Days Festivals in 2008, 2009 and2011. He was shown flyers for Lumberjack Days Festivals in 2009 and 2011. He pointed out the musicalgroups he arranged. In 2009 Creedence Clearwater Revisited played on Friday night July 24th. Thecontract was for $55,000 less 2% Minnesota State Entertainers Tax. He furnished a copy of the contractthat included the 2% Withholding. On Saturday July 25, 2009 The Wallflowers performed as the main act.He thought their contract was for $50,000 and 2% would have been withheld. He also arranged a smalleract, the Bottle Rockets, for a fee of $2,500. The 2% Tax would also have been withheld from their contract. In 2010, the band Chicago performed on July 24th. Their fee was $100,000 and the contract clearly stateda 2% MN Entertainers Tax was withheld. Mr. Thibault provided a copy of the contract listing the 2%Withholding. the Defendant filed and remitted NRE forms and taxes for 2010 performers. This establisheshe knew of his filing and remitting obligations. In 2011 Collective Soul was the main act on Friday July 22nd. Their fee was $50,000 less the 2% MNEntertainers Tax. Mr. Thibault supplied a copy of the contract showing the withholding. That act was rainedout. The status of the NRE is not known at this time. On Saturday July 23 the main act was Smash Mouth.Mr. Thibault recalled their fee was $50,000 and there would have been a 2% MN Entertainment Taxwithholding. Mr. Thibault was shown various NRE forms. He stated his office manager always made sure the promoterhad these forms and if they did not have them she would send them out. Mr. Thibault stated the Defendantknew about the Minnesota Non-Resident Entertainers Tax requirements for many years.

Attorney Interview Relating to NRE Tax One of the topics discussed with defendant's attorneys was NRE Taxes. Mr. Berndt confirmed he wasretained in about May of 2009 by the Defendant to represent him before the Minnesota Department ofRevenue regarding issues related to Non-Resident Entertainer Taxes. He indicated he fully briefed theDefendant on the topic and the Defendant understood his Non-Resident Entertainer Tax obligations. Evidence shows the NRE forms for 2009 were never filed and NRE Taxes were never remitted for 2009.The Defendant admits he knew in 2008 of his NRE obligations. He was represented by a competentattorney prior to the 2009 festival who stated the Defendant was fully informed of his NRE obligations.

The Defendant as a shareholder and operator of St. Croix Events, Inc., a Minnesota S-Corporationoperating as a promotion business, willfully failed to remit annual Sales Tax with the Minnesota Departmentof Revenue for the years 2010 and 2011 in violation of MN Stat. 289A.63Subd. 1(b). MN Stat. 289A.63ASubd. 1(b) states "A person required to pay or to collect and remit a tax, who willfully attempts to evade ordefeat a tax law by failing to do so when required, is guilty of a felony." The Defendant is personally

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responsible for remitting all taxes associated with the S-Corporation, St. Croix Events, Inc. The Defendanttook on responsibility for handling the tax related matters of Lumberjack Days Festival Association. Everyyear the Defendant operated a festival he had Sales Tax obligations. Each year that sales taxes are notremitted is considered a separate crime. At a minimum he was required to remit, by February 5th all SalesTaxes and related Alcohol Taxes for the previous year. For the year 2010 the Defendant operated a Minnesota S-Corporation known as St. Croix Events, Inc.,whose primary offices, like Defendant's home address, were located in Washington County. St. CroixEvents, Inc. acted as promoter for various events including Lumberjack Days Festival held in Stillwater,Minnesota. St. Croix Events, Inc. handled all key aspects of the operation of Lumberjack Days Festivalincluding tax matters. More than $204,000 in sales subject to Minnesota Sales Tax and more than$119,000 in sales subject to Alcohol Taxes were made during Lumberjack Days in 2010. St. Croix Events,Inc. knew or should have known as a professional promoter the sales made by Lumberjack Days Festivalwere subject to Minnesota Sales Tax and related Alcohol Tax, thereby requiring the Defendant to remit anestimated $17,255 in annual Sales and Alcohol Taxes no later than February 5, 2011 to the MinnesotaDepartment of Revenue. The Defendant willfully failed to remit any Sales or Alcohol Taxes for 2010 by thedue date in violation of MN Stat. 289A.63 Subd. 1(a).

For the year 2011 the Defendant operated a Minnesota S-Corporation known as St. Croix Events, Inc.,whose primary offices, like the Defendant's home address, were located in Washington County. St. CroixEvents, Inc. acted as promoter for various events including the annual Lumberjack Days held in Stillwater,Minnesota. St. Croix Events, Inc. handled all key aspects of the operation of Lumberjack Days including taxmatters. More than $102,000 in sales subject to Minnesota Sales Tax and more than $50,000 in salessubject to Alcohol Taxes were made during Lumberjack Days in 2011. St. Croix Events, Inc. knew or shouldhave known as a professional promoter the sales made by Lumberjack Days Festival were subject toMinnesota Sales Tax and related Alcohol Tax, thereby requiring the Defendant to remit an estimated$8,390 in annual Sales and Alcohol Taxes no later than February 5, 2012, with the Minnesota Departmentof Revenue. The Defendant willfully failed to remit any Sales or Alcohol taxes for 2011 by the due date inviolation of MN Stat. 289A.63 Subd. 1(a).

The Defendant as shareholder and operator of St. Croix Events, Inc., operating as a promotion business,willfully failed to file required Non-Resident Entertainers' Tax returns with the Minnesota Department ofRevenue for the year 2009 in violation of MN Statutes 290.9201 and 289A.63 Subd. 1(a), as a felony. MNStat. 289A.63 Subd. 1(a) states "A person required to file a return, report or other document who willfullyattempts in any manner to evade or defeat a tax by failing to file it when required, is guilty of a felony." TheDefendant was personally responsible for filing all tax returns for his S-Corporation, St. Croix Events, Inc.,including required Non-Resident Entertainers' Tax returns (NRE) required pursuant to MN Stat. 290.9201.St. Croix Events, Inc.'s oldest NRE tax filing obligation for Lumberjack Days events that is within the sixyear statute of limitations is for tax year 2009. The form ETD was due on August 31, 2009, the end of themonth following the July 2009 Lumberjack Days performances. Promoters are also required to file FormETA, Promoters Annual Reconciliation, at the end of every tax year. The filing deadline is February 28 afterthe close of a tax year. Form ETA for tax year 2009 was due on Feb. 28, 2010. The Defendant as shareholder and operator of St. Croix Events, Inc., a Minnesota S-Corporation operatingas a promotion business, willfully failed to remit required Non-Resident Entertainers' Taxes with theMinnesota Department of Revenue for the year 2009 in violation of MN Statutes 290.9201 and 289A.63Subd 1, as a felony. MN Stat. 289A.63A Subd. 1(b) states "A person required to pay or collect and remit atax, who willfully attempts to evade or defeat a tax law by failing to do so when required, is guilty of a felony."The Defendant is personally responsible for remitting all taxes associated with St. Croix Events, Inc. As apromoter his company took on responsibility for handling the tax related matters of the clients. At aminimum he was required to remit NRE Tax the month following a performance in Minnesota. He wasrequired to remit NRE Taxes annually by the following February 28th of each tax year. St. Croix Events,Inc.'s oldest NRE Tax remittance obligation that is within the six year statute of limitations is for tax year

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2009. Taxes for Lumberjack Days Festival July 2009 performances were due on August 31, 2009.Promoters are also required to remit NRE Taxes using form ETA, Promoters Annual Reconciliation, at theend of every tax year. The filing deadline is February 28 after the close of a tax year. Form ETA for tax year2009 was due on Feb. 28, 2010. For the year 2009 the Defendant operated a Minnesota S-Corporation known as St. Croix Events, Inc.,whose primary offices were located in Washington County. The 2009 Minnesota Non-ResidentEntertainers' Tax remittance (ETA), for entertainers paid by St. Croix Events, Inc. in 2009, was due no laterthan February 28, 2010. The Defendant willfully failed to timely remit the Non-Resident Entertainers' Taxes(ETA) by the due date of February 28, 2010 in violation of MN Statutes 290.9201 and 289A.63 Subd. 1(b).

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SIGNATURES AND APPROVALS

Complainant requests that Defendant, subject to bail or conditions of release, be:(1) arrested or that other lawful steps be taken to obtain Defendant's appearance in court; or(2) detained, if already in custody, pending further proceedings; and that said Defendant otherwisebe dealt with according to law.

Complainant Jeff Slater Electronically Signed:03/17/2015 08:48 AMRevenue Special Investigator

600 Robert Street NSt. Paul, MN 55146-6590

Subscribed and sworn to before the undersigned.

Notary Public orJudicial Official

Commission expires: 01/31/2017Electronically Signed:03/17/2015 08:54 AM

Cindy Glaser-OBrienNotary Public, County of Ramsey600 Robert Street NSt. Paul, MN 55146-6590Notary ID: 31051833

Being authorized to prosecute the offenses charged, I approve this complaint.

Prosecuting Attorney Electronically Signed:03/16/2015 02:10 PM

Richard D. HodsdonAssistant Washington CountyArttorneyPO Box 615015 62nd Street NorthStillwater, MN 55082(651) 430-6115

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FINDING OF PROBABLE CAUSEFrom the above sworn facts, and any supporting affidavits or supplemental sworn testimony, I, the Issuing Officer, have

determined that probable cause exists to support, subject to bail or conditions of release where applicable, Defendant’s arrest

or other lawful steps be taken to obtain Defendant’s appearance in court, or Defendant’s detention, if already in custody,

pending further proceedings. Defendant is therefore charged with the above-stated offense(s).

SUMMONSXTHEREFORE YOU, THE DEFENDANT, ARE SUMMONED to appear on ________ ___, _____ at _____ AM/PMbefore the above-named court at 14949 62nd Street N PO Box 3802, Stillwater, MN 55082-3802 to answer thiscomplaint.

IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued.

WARRANT

To the Sheriff of the above-named county; or other person authorized to execute this warrant: I order, in the name of the State

of Minnesota, that the Defendant be apprehended and arrested without delay and brought promptly before the court (if in

session), and if not, before a Judge or Judicial Officer of such court without unnecessary delay, and in any event not later than

36 hours after the arrest or as soon as such Judge or Judicial Officer is available to be dealt with according to law.

Execute in MN Only Execute Nationwide Execute in Border States

ORDER OF DETENTION

Since the Defendant is already in custody, I order, subject to bail or conditions of release, that the Defendant continue to bedetained pending further proceedings.

Bail: $Conditions of Release:

This complaint is issued by the undersigned Judge as of the following date: March 17, 2015.

Judicial Officer Gary Schurrerjudge

Electronically Signed: 03/17/2015 10:08 AM

Sworn testimony has been given before the Judicial Officer by the following witnesses:

COUNTY OF WASHINGTONSTATE OF MINNESOTA

State of MinnesotaPlaintiff

vs.

David Webster EckbergDefendant

Clerk's Signature or File Stamp:

RETURN OF SERVICEI hereby Certify and Return that I have served a copy of this

Summons upon the Defendant herein named.

Signature of Authorized Service Agent:

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