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The criminal complaint charging a Wisconsin man with abducting 13-year-old Jayme Closs and killing her parents laid out the case in detail and offered a possible road map for how prosecutors will seek a conviction in the girl's 88-day ordeal.

The 12-page complaint against Jake Thomas Patterson focused almost entirely on Jayme's abduction and her escape, without lingering on her time in captivity.

The decision to leave out a description of what happened in the remote cabin where Jayme was held for almost three months was probably intended to spare her more trauma, said Chris Madel, a prominent defense attorney in Minneapolis.

The details are also unnecessary, he said. Prosecutors already have evidence of two killings that that could put Patterson away for life. The complaint says 

The Jayme Closs case

JaneAnne Murray, another defense attorney and a professor at the University of Minnesota School of Law, wondered if the complaint was "designed to send a signal to the defense that the evidence against their client is overwhelming."

The prosecutor in the case, Barron County District Attorney Brian Wright, said after Patterson was charged Monday that a conviction in this case is important.

"We are seeking justice. We have two parents of a 13-year-old who are deceased. We have a 13-year-old who was abducted for 88 days against her will, forcibly. It doesn't get any more serious than that," he said.

Patterson's defense attorneys, Charles Glynn and Richard Jones, have said they might seek a change of venue.

According to the complaint, the 21-year-old suspect was working at a cheese factory west of Barron, Wis., when he stopped behind a school bus on his way to work and saw Jayme getting on. He decided then he would take her, the complaint said.

On Oct. 15, he went to her home dressed almost entirely in black, wearing a face mask and gloves and armed with a shotgun. He allegedly told authorities he shot Jayme's father, James Closs, through the front door, then went inside and found Jayme and her mother. He shot Denise Closs, then dragged Jayme to a car, the complaint said.

He took her to his cabin in Gordon, a township of 645 people in thickly forested Douglas County, according to the complaint. Not until Thursday did 

Keith Findley, co-founder of the Wisconsin Innocence Project, said it's important not to rush to judgment, noting that the complaint sets forth only one side.

"This is all very preliminary, and we all need to take a breath and not rush to judgment ... the process needs to work its way out," Findley said.

Murray said prosecutors will want a swift resolution, and that's one bargaining chip the defense has. The defense can drag the case out by raising a host of issues, or they could offer to plead guilty so prosecutors can resolve the case quickly.

Madel said the defense may try to suppress Patterson's statement to police, but it's unlikely that will succeed. They also might pursue an insanity-based defense, arguing that Patterson did not understand what he's accused of doing was wrong. But Madel doubts that would work either.

"He wore all black. He shaved his head. He took steps to conceal her in his home when people were over, and he was seemingly out looking for her when she was gone," Madel said. Those are indications that "he appreciated the criminality of what he was doing."

Jayme needs space, time to heal

Wright said he does not plan for Jayme to testify at any upcoming proceedings, but Madel said it should be up to her. He said it can be helpful for victims to testify, even if they undergo extensive cross-examination, because doing so helps them feel like they helped convict their attackers.

"I get what the prosecutors are saying: They don't need to call her. But I sure hope they are going to leave that up to her," Madel said.

Crime, Law and Justice

The Associated Press

Author

One defense attorney wondered if the complaint, which focused almost entirely on Jayme Closs' abduction and her escape, was "designed to send a signal to the defense that the evidence against their client is overwhelming."

Jake Thomas Patterson makes his first court appearance on video.

Complaint in Closs case could be road map for prosecution

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