Electronically Filed - LINCOLN COUNTY - December 20, 2022 - 01:46 PM
22L6-CR01655
IN THE CIRCUIT COURT OF LINCOLN COUNTY, MISSOURI
ASSOCIATE JUDGE DIVISION
45th JUDICIAL CIRCUIT
STATE OF MISSOURI, )
Plaintiff, )
)
vs. ) Case No.
)
) Karpel 113220802
MICHAEL MERKEL, )
Defendant. ) OCN:
FELONY COMPLAINT
Comes now, the Prosecuting Attorney of the County of Lincoln, State of Missouri, being
duly sworn upon my oath and upon information and belief, and states that there is probable cause
to believe that on or about March 14, 2022, the accused committed the following crimes:
COUNT I
HARASSMENT - 1ST DEGREE
The defendant, MICHAEL MERKEL, in violation of Section 565.090, RSMo,
committed the class E felony of harassment, punishable upon conviction under Sections 558.011
and 560.016, RSMo, in that on or about March 14, 2022, in the County of Lincoln, State of
Missouri, the defendant, acting in concert with others, knowingly frightened, intimidated and
caused emotional distress to Detective Randy Lambert, a law enforcement officer, by
anonymously texting threatening messages and cell phone photographs from an untraceable
''Burner'' phone, indicating he was being stalked, for the purpose of impeding an internal
investigation of wrongdoing being conducted by the victim.
The range punishment for a class E felony is imprisonment in the custody of the Missouri
Department of Corrections for a term of years not less than one (1) year and not to exceed four
(4) years; or by imprisonment for a special term not to exceed one (1) year in the county jail or
other authorized penal institution; or by a fine not to exceed ten thousand dollars ($10,000); or
by both imprisonment and a fine. If money or property has been gained through the commission
of the crime, any fine imposed may be not more than double the amount of the offender's gain
from the commission of the crime.
Missouri Charge Code: 565.090-003Y202053090
Electronically Filed - LINCOLN COUNTY - December 20, 2022 - 01:46 PM
COUNT II
STALKING - 2ND DEGREE - L/E OR RELATIVE
The defendant, MICHAEL MERKEL, in violation of Section 565.227, RSMo,
committed the class E felony of stalking in the second degree, punishable upon conviction under
Sections 558.002 and 558.011, RSMo, in that on or about March 14, 2022, in the County of
Lincoln, State of Missouri, the defendant, through defendant's course of conduct and acting in
concert with others, purposely disturbed Detective Randy Lambert, a law enforcement officer, by
anonymously texting threatening messages and cell phone photographs from an untraceable
''Burner'' phone further threatening that the victim was being watched closely and videotaped,
and thereby would have caused a reasonable person under the circumstances to be frightened,
intimidated, or emotionally distressed.
The range punishment for a class E felony is imprisonment in the custody of the Missouri
Department of Corrections for a term of years not less than one (1) year and not to exceed four
(4) years; or by imprisonment for a special term not to exceed one (1) year in the county jail or
other authorized penal institution; or by a fine not to exceed ten thousand dollars ($10,000); or
by both imprisonment and a fine. If money or property has been gained through the commission
of the crime, any fine imposed may be not more than double the amount of the offender's gain
from the commission of the crime.
Missouri Charge Code: 565.227-003Y202053090
The facts that form the basis for this information and belief are contained in the attached
statement of facts concerning this matter, which statement is made apart hereof and are
submitted herewith as a basis upon which this Court may find the existence of probable cause for
the issuance of the warrant.
WHEREFORE, the Prosecuting Attorney prays that an arrest warrant be issued as
provided by law.
DATED: December 20, 2022
/S/ Michael L. Wood___________
Michael L. Wood, Bar #60652
Prosecuting Attorney
P. O. Box 319
Troy, MO 63379
(636) 528-8571
