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MADISON — Attorney General J.B. Van Hollen announced today that charges were filed against three Dane County men in connection with a drug investigation on July 27, 2013, at 1434 Northport Drive.  Dominic Lombardo of Madison and Bryan Brooks (a/k/a Christopher Johnson) of Middleton were charged with possession of heroin as party to a crime, and Ryan Spence of Madison was charged with delivery of heroin. All three made their initial appearance in Dane County Circuit Court this afternoon.  Preliminary hearings have been set on August 8, 2013, for Spence and Brooks, and September 23, 2013, for Lombardo.


According to the criminal complaint, Lombardo, Brooks, and Spence all had communications earlier in the day on July 27, 2013, regarding the purchase of heroin.  Lombardo allegedly drove Spence to the north side of Madison where Spence was able to purchase heroin.  Spence and Lombardo were then joined by Brooks, and heroin was consumed in the vehicle.  Police had contact with the three defendants in the parking lot of a business on Northport Drive.  Inside of the car, police recovered a small amount of heroin, used syringes containing suspected heroin, and various drug paraphernalia associated with the use of heroin.  The complaint indicates that all three defendants gave statements to police implicating themselves in the drug activity.


Possession of heroin is a Class I felony punishable by a fine of not more than $10,000 or imprisonment for not more than three years and six months, or both.  Delivery of heroin (less than three grams) is a Class F felony punishable by a fine of not more than $25,000 or imprisonment for not more than 12 years and six months, or both.


A criminal complaint is a document accusing a person of a violation of criminal law.  All defendants enjoy a presumption of innocence.  The prosecution must prove its allegations at trial beyond a reasonable doubt.


A copy of the criminal complaint is available here.


Assistant Attorney General David W. Maas is representing the State as special prosecutor for Dane County.  This case was investigated by the Madison Police Department.