In re the Welfare of T.M., a Minor

CASE-FILE DOCUMENT · POLICE REPORT

Norsholm Police Department — Incident Report (EXHIBIT m08.exh.001)

Report No.: NPD-2026-041537 Reporting Officer: Officer Trent Bagley, Norsholm Police Department (Witness ID: m08.wit.bagley) Date/Time of Incident: Saturday, March 14, 2026, approx. 1642 hours Location: VoltHaus Electronics, Riverside Commons, Norsholm, Halden County Classification: Juvenile — theft; assault (fifth degree) referred to juvenile intake

SUMMARY

On the above date and time, I was dispatched to VoltHaus Electronics on a report of a retail theft and a store employee assaulted. On arrival I made contact with loss-prevention officer Curtis Vanderhoek, who was holding a juvenile male at the edge of the parking lot with the assistance of another store employee.

JUVENILE

The juvenile was identified through his mother as Tobias Merrow, DOB on file, age 15, of Norsholm. He had no identification on him. He was cooperative and visibly upset during contact.

STATEMENTS OBTAINED

Vanderhoek reported he observed a group of three male subjects near the gaming display; that one older subject removed a boxed Nexus X console from the display; that the box was transferred to the juvenile near the front doors; that two older subjects fled the store on foot; and that when he attempted to stop the juvenile in the entry vestibule, the juvenile pushed him, causing him to fall against a display and scrape his elbow. Vanderhoek declined medical attention.

The juvenile stated the two older subjects handed him the box and ran, that he panicked, and that he pushed past the officer trying to leave but did not intend to injure anyone.

A sales associate, N. Quintero, was identified as a partial witness and a separate statement was arranged.

PROPERTY

One (1) Nexus X gaming console, boxed, shelf value $549.99, recovered outside the first set of entry doors where the juvenile dropped it. Box scuffed; unit intact. Returned to store per manager.

DISPOSITION

The two older subjects were not located. The juvenile was released to his mother, Dana Merrow, at the scene. Matter referred to the Halden County juvenile intake unit for a charging decision. Store CCTV preserved by management and requested.

Officer T. Bagley, #4471 Norsholm Police Department

CASE-FILE DOCUMENT · LP INCIDENT REPORT

VoltHaus Loss-Prevention Incident Report (EXHIBIT m08.exh.002)

Store: VoltHaus Electronics #218, Riverside Commons, Norsholm Incident Date/Time: March 14, 2026, 4:38 p.m. Prepared By: Curtis Vanderhoek, Loss-Prevention Officer Report Date: March 14, 2026

INCIDENT TYPE: Grab-and-run theft; physical contact with LP officer

MERCHANDISE INVOLVED:

• 1 × Nexus X Gaming Console (SKU 4471-NX), shelf price $549.99
• Recovered: Yes — dropped at exterior of vestibule doors
• Condition on recovery: box scuffed, console unit undamaged; returned to sellable stock
• Net merchandise loss after recovery: $0.00

NARRATIVE: Observed three young male subjects loitering at the gaming endcap, exhibiting camera-checking behavior. Subject 1 (older, dark hooded sweatshirt) removed a boxed Nexus X from the display pallet. Group moved toward front entrance. Box was passed to Subject 3 (younger, gray jacket) near the vestibule; exact transfer partially obscured from my sightline by the seasonal endcap. Subjects 1 and 2 fled on foot through the north doors and were not apprehended.

I positioned myself in the vestibule and identified myself to Subject 3, directing him to stop and surrender the merchandise. Subject 3 did not comply and pushed past me with both hands, contacting my chest and causing me to lose balance and strike the freestanding accessory display, going down to one knee. Minor abrasion to right elbow; self-treated with store first-aid kit; no medical treatment sought; remained on shift.

Subject 3 dropped the merchandise at the exterior doors and fled into the lot, where he was detained by me and associate M. Reymann pending police arrival.

CCTV: Ceiling cameras 6 and 9 preserved. Camera 9 covers the vestibule contact. The merchandise handoff is partially blocked on both cameras by the endcap.

LAW ENFORCEMENT: Norsholm PD responded; Officer Bagley took custody of the scene. Juvenile released to parent.

C. Vanderhoek, LP #218-03

CASE-FILE DOCUMENT · DELINQUENCY PETITION

Delinquency Petition (EXHIBIT m08.exh.003)

``` STATE OF MERIDIAN DISTRICT COURT COUNTY OF HALDEN FIRST JUDICIAL DISTRICT JUVENILE DIVISION

In re the Welfare of T.M., a Minor. PETITION FOR DELINQUENCY

```

Petitioner: State of Meridian, by the Halden County Attorney

Child: T.M., a male child, age 15, residing in Norsholm, Halden County. (Identified by initials per Juvenile Division practice; records confidential.)

Parent/Guardian: Dana Merrow, mother.

COUNT I — Theft

The Petitioner alleges that on or about March 14, 2026, in Halden County, the above-named child took, and exercised control over, movable property of VoltHaus Electronics, namely one Nexus X gaming console of a value alleged to exceed the statutory threshold, without consent and with intent to deprive the owner permanently of possession — conduct that would constitute theft if committed by an adult.

COUNT II — Assault in the Fifth Degree

The Petitioner further alleges that on the same date and place, the above-named child intentionally inflicted, or attempted to inflict, bodily harm upon Curtis Vanderhoek — conduct that would constitute assault in the fifth degree if committed by an adult.

PRAYER FOR RELIEF

Petitioner requests that the child be adjudged delinquent and that the Court make such disposition as is in the child's best interests and the interests of public safety, or, in the alternative, that the child be referred to an approved diversion or accountability program.

Dated: March 27, 2026

/s/ Assistant Halden County Attorney Halden County Attorney's Office Norsholm, Meridian

Assigned: Hon. Consuela Escamilla, Juvenile Division.

CASE-FILE DOCUMENT · STORE INVENTORY RECORD

VoltHaus Inventory & Recovery Record (EXHIBIT m08.exh.004)

Store: VoltHaus Electronics #218, Riverside Commons, Norsholm Record Date: March 15, 2026 Prepared By: Store Operations Manager (on file)

NOTES: The console recovered outside the doors matches the single unit that reconciliation showed missing from the gaming pallet after the incident. Because the unit was recovered intact and returned to stock, the store's actual out-of-pocket loss is limited to the scuffed retail box, which the store values as negligible. Any restitution demand and any characterization of the theft value for charging purposes remain open questions for the parties.

This record is provided as a business record of the store's inventory reconciliation for the date in question.

CASE-FILE DOCUMENT · DIVERSION OFFER LETTER

Juvenile Diversion Offer Letter (EXHIBIT m08.exh.005)

Halden County Attorney's Office Juvenile Division — Diversion Unit Norsholm, Meridian

Date: April 20, 2026 Re: In re the Welfare of T.M., a Minor — Diversion Offer To: Counsel of record for the child; Dana Merrow, parent

Dear Counsel:

Following review of the referral in the above matter, our office is prepared to offer the child, T.M., placement in the county's juvenile diversion program in lieu of proceeding on the delinquency petition. The offer is as follows.

Terms of the diversion offer:

1. The child accepts responsibility for the underlying conduct in a written accountability statement.
2. The child completes an approved accountability and decision-making program (typically 6–8 sessions).
3. The child completes 30 hours of community service.
4. The child pays any restitution determined to be owed to the merchant. (We note the merchant has not yet submitted a fixed restitution figure; the merchandise was recovered.)
5. The child maintains school attendance and has no new offenses during the diversion period (approximately 90 days).

Effect of successful completion: Upon successful completion of all terms, the delinquency petition will be dismissed, and there will be no adjudication of delinquency entered against the child.

Effect of non-acceptance or non-completion: If the offer is declined, or if the child does not complete the program, the matter will proceed on the petition to a contested hearing in the Juvenile Division.

This offer remains open until May 15, 2026. Please contact the Diversion Unit to accept or to discuss the terms, including the restitution question.

Respectfully, Assistant Halden County Attorney Juvenile Diversion Unit

CASE-FILE DOCUMENT · CCTV STILLS DESCRIPTION

CCTV Still-Frame Description Log (EXHIBIT m08.exh.007)

Source: VoltHaus Electronics #218 ceiling surveillance, Cameras 6 and 9 Incident Date: March 14, 2026 Preserved By: Store management; provided to Norsholm PD Nature of exhibit: The video itself is preserved digitally. The frames below are described for the file; no legal conclusions are drawn.

Camera 6 — Gaming aisle / endcap (wide)

• 16:31:12 — Three young male subjects visible at the gaming display pallet. Two appear older/taller; one appears younger and shorter, standing slightly apart, hands in jacket pockets.
• 16:33:40 — Older subject in dark hooded sweatshirt lifts a large boxed item from the pallet. Younger subject is looking toward the front of the store, not at the pallet.
• 16:34:05 — Group begins moving toward the front entrance, older subjects leading, younger subject trailing by several feet.

Camera 9 — Front vestibule (angled)

• 16:37:50 — Two older subjects move quickly through frame toward the doors. A boxed item is at chest height between the trailing older subject and the younger subject; the seasonal endcap partially blocks the point of transfer — the frames do not clearly show the box being handed over or taken.
• 16:38:02 — Two older subjects exit through the north doors at a run.
• 16:38:06 — Younger subject stands alone just inside the vestibule holding the box; posture appears hesitant (stationary ~2 seconds).
• 16:38:11 — An adult male (LP officer) enters frame and positions in front of the younger subject.
• 16:38:14 — Contact occurs; the LP officer moves backward and downward out of the lower frame; the younger subject moves forward through the doors. The precise nature of the contact — the amount of force and the orientation of the hands — is not clearly resolvable at this frame rate and angle.
• 16:38:19 — Boxed item visible on the ground at the exterior doors. Younger subject out of frame.

Note for the file: The two evidentiary gaps a reviewer should mark are (1) the obscured handoff of the box and (2) the ambiguous doorway contact. Both bear on contested issues in the matter.

CASE FILE · WITNESS STATEMENT VANDERHOEK

Witness Statement — Curtis Vanderhoek

Witness ID: m08.wit.vanderhoek Role: Loss-Prevention Officer, VoltHaus Electronics, Riverside Commons, Norsholm Taken: March 16, 2026 Format: Signed written statement

My name is Curtis Vanderhoek. I have worked loss prevention at the VoltHaus store in Riverside Commons for about four years. On Saturday, March 14, I was on the floor in plain clothes, which is normal for my job.

Around 4:30 in the afternoon I noticed a group of three younger guys near the gaming display. Two of them looked older, maybe sixteen or seventeen, and one looked younger. They kept looking around and up at the ceiling, which is what people do when they're checking for cameras. I moved closer and kept an eye on them from the next aisle.

I saw one of the older ones lift a boxed Nexus X console off the display pallet. The whole group started drifting toward the front of the store. The way it looked to me, they were all in it together. Near the front doors the box ended up in the hands of the youngest one — I did not see exactly how it changed hands because an endcap was partly in the way — and the two older ones took off running out the doors.

I stepped in front of the younger one in the vestibule, right between the two sets of doors. I identified myself and told him to stop and hand me the box. He did not stop. He came right at me and shoved me with both hands, hard, in the chest. I went back into a display stand and down onto my knee and scraped my elbow. By the time I got up he had dropped the box outside the first doors and was running into the lot. Another associate and I caught up with him at the edge of the parking lot and held him there until the police came.

I want to be clear that in my view the push was not an accident. He drove into me to get past. My elbow was scraped and a little bloody. I cleaned it up with our first-aid kit and finished my shift. I did not go to a doctor.

The console box was scuffed but the unit was fine and went back into our stock. I gave the police the same account I am giving here.

Signed, Curtis Vanderhoek March 16, 2026

CASE FILE · WITNESS STATEMENT QUINTERO

Witness Statement — Naomi Quintero

Witness ID: m08.wit.quintero Role: Sales Associate, VoltHaus Electronics, Riverside Commons, Norsholm Taken: March 19, 2026 Format: Signed written statement

My name is Naomi Quintero and I work the registers at the VoltHaus in Riverside Commons. On Saturday afternoon, March 14, I was ringing up customers at register three, which faces the front doors from maybe thirty feet away.

I remember two older boys coming up toward the front kind of fast. There was a younger kid near the entrance, closer to the doors than they were. One of the older boys had a big boxed item — I'm pretty sure it was one of the console boxes, they're a distinctive size — and I saw him more or less push it into the younger kid's hands as he went by. Then both of the older boys just ran straight out the doors. It happened quick.

The younger kid stood there for a second like he did not know what to do. He was holding the box. Then he started walking toward the doors too. That is about when Curtis, from loss prevention, stepped in. I had a customer in front of me so I looked down, and when I looked back up there was some kind of scuffle in the doorway and Curtis was getting up off the floor. The younger kid was outside by then.

I want to be honest that I did not hear anything anyone said, and I did not have a clear look at the moment the two of them ran into each other in the doorway — I was at my register and there were people in the way. What I am sure about is that the older boys handed the box to the younger one and ran, and that the younger one looked confused, not like he was in charge of anything.

Signed, Naomi Quintero March 19, 2026

CASE FILE · WITNESS STATEMENT NWOSU

Witness Statement — Adaora Nwosu

Witness ID: m08.wit.nwosu Role: School Counselor, Larkmont High School, Norsholm Taken: April 8, 2026 Format: Signed letter to file / character statement

To whom it may concern:

My name is Adaora Nwosu. I am a licensed school counselor at Larkmont High School in Norsholm, and I have been Tobias Merrow's assigned counselor since he enrolled here as a freshman.

I have known Tobias for nearly two years. He is, at his core, a conscientious and respectful young person. He was a solid B student through most of freshman year and into this year, and he participates in class without causing problems. Teachers describe him as quiet and cooperative.

I will be candid that his grades slipped over the past year, and he has seemed more withdrawn. From my conversations with him and with his mother, I understand the household carries real financial pressure, and Tobias is often on his own after school because his mother works long and irregular hours. That kind of unsupervised time is a risk factor for a teenager, and I have raised it gently with the family.

I was surprised and saddened to learn of the incident at the store. It does not match the young man I know. In my professional judgment, Tobias is a strong candidate for a diversion or accountability program rather than a formal delinquency adjudication. He responds well to structure and to adults who take an interest in him. The school is prepared to put supports around him — a check-in schedule, tutoring, and a connection to an after-school program — if that would help keep him on track.

I am willing to speak further about Tobias's character and about the school's supports if it would assist.

Respectfully, Adaora Nwosu, School Counselor Larkmont High School April 8, 2026

BUSINESS EXHIBIT · ENGAGEMENT LETTER

Engagement Letter

Ellingboe & Ravndal LLP 310 Riverwalk Plaza, Suite 400, Norsholm, Meridian 55901 office@ellingboeravndal.example.com

March 19, 2026

Dana Merrow 1408 Cedarloft Lane, Apt. B Norsholm, Meridian 55902

Re: Representation of Tobias Merrow (a minor) — Juvenile Division delinquency matter

Dear Ms. Merrow:

Thank you for entrusting our firm with this matter. This letter confirms that Ellingboe & Ravndal LLP will represent your son, Tobias Merrow, in the delinquency proceeding pending in the Juvenile Division of the Meridian District Court, Halden County, captioned In re the Welfare of T.M., a Minor. This letter sets out the terms of our engagement.

Who our client is. Our client is Tobias. Although you are arranging and paying for the representation as his parent and guardian, our professional duties — including confidentiality and loyalty — run to Tobias. We will keep you closely involved and informed to the extent consistent with those duties, and we will explain how that works.

Scope of the work. We will represent Tobias through the investigation, the first appearance, pretrial matters, negotiation of a possible diversion or other resolution, and, if the matter is contested, an adjudicatory hearing. This engagement does not include any appeal or any separate matter, which would require a further agreement.

Fees. We bill on an hourly basis. Amara Ellingboe's time is billed at $250 per hour and Marcus Ravndal's at $225 per hour; any paralegal time is billed at $120 per hour. We record time in tenth-of-an-hour increments. We will send you an itemized statement approximately monthly, due within thirty days. You have made an initial payment toward fees, which is reflected on your first statement. Reasonable out-of-pocket costs — such as records copying and filing or service fees — will be billed as incurred.

Your responsibilities. Please keep us informed, respond promptly to our requests, ensure Tobias attends all scheduled meetings and court dates, and tell us the full story even when it is uncomfortable. Complete candor lets us protect Tobias effectively.

Ending the engagement. You may end our representation at any time, and we may withdraw as permitted by the rules governing lawyers, subject to any court approval required in a pending matter. On termination you remain responsible for fees and costs incurred through that date.

If these terms are acceptable, please sign below and return one copy. We are glad to help Tobias and your family through this.

Sincerely,

Amara Ellingboe Ellingboe & Ravndal LLP

Dana Merrow (parent/guardian of Tobias Merrow) Date: ____________

BUSINESS EXHIBIT · INTAKE & CONFLICTS

Intake (2026-03-18). Represent a 15-year-old in a Juvenile Division delinquency petition alleging theft and fifth-degree assault arising from a March 14, 2026 incident at a Norsholm electronics store; evaluate a diversion offer against a contested hearing.

Conflicts check (2026-03-18) — CLEAR. No current or former firm client appears among the parties or witnesses. The firm does not and will not represent the separately charged co-respondent, Kellan Dubourg, who has appointed counsel; noted to avoid any adverse-representation issue.

BUSINESS EXHIBIT · BILLING STATEMENT (9 TIME ENTRIES)

BUSINESS EXHIBIT · INVOICES