o.

STATEOF MONTANA.
Plaintiff,
MARY E. CQc..ltE."OJR
Anisfam A GmcnJ
Sp<cioI """""";1' ..... eo..., An.....,
P.O. Bw. 1'01401
Helma, MT S962l).I401
(406) 444..2026
COUNSEL fOR STATE
MONTANA TWENTI'..sECOND JUDICIAL OISTRJCTCOURT CARBON COCINTY
CwO< = ::0
STATI'S MOTION FOR LEAV[ TO
FIt[ INFORMATION AND
AFfIDAVIT IN SUPPORT
JASON SHELLER PRIEST,
Defendanl.
STATE OF MONTANA )
:l5.
County of and CI..... )
Mary E. Cocltmour. Assistant Attomc:y Gmenl for the SUIte of MonWlll Ind
SpeNI OqNty Carbon County Anoney. mova Ihc COUI1 for leave 10 fik an
InfonnM1Oll d\arP1ll1hc: Dcfmdaolt. Jason Shellet Pn$, with comminin, the follolooin,
olfCllSC:S III Carbon CowMy, Moa.....:
COUNT I: ASSAULT ON MINOR. a felony, as spec:jflCd III M-. Cook
Ann. t On onbool FdlnI.". I. 2014, the Dcfcndanl
commlncd an assault all delined in Moot. Code Ann. 45-S-l01( 1)(1) and
It the lime OftM thc vIctim, J.P., was 4 years old, and the
Defrndant wu 18 )'ClIn old or older, 10 wit: the DcfcndlllU or
lno.... illilly bodily injury to 4-)'car-old J.P., by 1IflIbb1n8 ncr Ind
causing bochl" inJuI')' to J.P.'s head.
This ofTmx is punilohablc by impri50llmmi in the SUIte prison for a term
IKIIIO cxucd 5 yon or be: flMd ... am<l\lnl lIOII10 exceed S5O.OOO. or both.
MorM. COIk Ann. 45-5-212(2) (2011).
COUNT II: PARTl\'R OR FAMILY MEMBER ASSAULT.
mlSd<meanor. II spa;ifio:dln Mon. Code. Ana. 4SoS206(IXc). On or
about F,bi_f I. 2014. the Dtfmdan purposely 01' knowingly cauKd
ITAlT1 MOTIO!< nJal.Lfl\'I: m lPoTOA/lU. IoMI Amo.o"" t'II A:PI'OIlT

reasonable apprehension of bodily injury in I panner, A.P.. when he
gJ'3bbed her shoulder and tried to push her off the: stairs of the: froot pon::h
while he was SCT'taming and yelling obicenitics at A.P.
Thi. offense i. punishable by imprisoomenl in the county jail for a term nO!
10 cJI;cecd I year and "Ol Jess than 24 hours and by a fine in an amount not
less than $100 or more !han $1,000. Mont Code Mn. 45-S-206(3);
COUNT III: ASSAULT. a misdemcllllQr, as specified in Mont Code
Ann. 45.5.201(1)(1). On or about Fehnury 1,2014, the Defendant
purposely or u\15Cd bodily injury to Jon Trapp when he tad:led
Mr. Trapp, causing lum to fall agaillJ!;11 fence and 10 tile ground, tllcrcby
breaking Mr. Trapp's rib, causing h1m pain llIId an open wound 10 his lono.
This offense is punishable by imprisonment in the coont)' jail for any term
not to el<cecd 6 month:! andfor II fine not 10 cxed $500. Mont. Code Ann.
145-5-201(2); and
COUNT IV, RESISTING ARREST, a misdemeanor, as spe.::ifJed in
Mon!. Code Ann. 4S-7-J01(1). On or aboul FebrullrY 1,2014, Ihe
prevemed or allemFlcd. 10 prevmt a pcace officer
from effectin& an arrest by using physica force or violence or VIOlence
peace officer or anolber.
off"ns<: is PUlli!itlllble by imprisonment in the ,;owl!} jail for allY lCflll
nOl to exceed 6 months and/or a fine not 10 $500. Mon!. Code Ann.
4S.7-l01 (3).
Mary E. Cochenour, after finl being sworn upon oath, dep0r6es and based on
informalion and belief, thai invesligalive informalion developed Ilfld provided 10 her by
Red Lodge Police Officer Man Grieshop and M<>nlllrLl. Division ofCriminal Investigalions
Agenl Jolin SulliVlln defl1Qllstnues probable cause 10 bdie\e that the Defendam liaS
commilled lhe offenses charged.
TIle facls cOllstilutilllt lhe offcll$Cs are Q follows:
On Fehroary 1,2014. al aboul 7:40 p,m., Red Lodge Police Officer Matt Grieshop
received a call from Jonathan Trapp, asking for police usistanee during the pickup of
children al Jason Sheller Priesl's house, Officer Grieshop 10/85 aware Ihal Pricsllllld his
wife. A.I'., were involved in an ongoing, contcntiou.'l divorce thlt included disputes about
cuslody oflhe hieslS' children. Trtlpp. A.I'.s boyfriend, staled that lhe childrm
wen: al Priest's house: On N. Word Street in Red Lodge on the evening of February I,
2014. and lhal Anna had rtCeived a phone call from 4-year-old J.P., who was crying and
saying lhal Prien lollS sayinllihings like Mfuck you" to her. Trapp u.id lhat Priest then got
ST"U'S IItOTJON FOR I.UV'; TO nuII<FO"''''' TJOIo/ "I'D"FFIIl.. vIr II< SUPf'OltT
'"ClI
011 the phone lind ,.id 10 A_P. '"'yOU fuckinJ CUlll, you mil Jon come oyer and let
yoor daughter riglll Due 10 Pncsl. beh.yior on phone, TrlflP I.Skcd that llw
enfortcmcnl observe lIIe child pick-up.
OffITGneshop arrived u the 200 block of N. Word SIfftt. Officer QriQhop
:Ill"" A.P.S \'dick: drin up Ind '*" ill fiollI of Priest'. IlouK. A.P. JOI OUI oltbc
vehicle and ....IUd up 10 the front 600r 110M. OfflCa" Griahop Ibm .... PrinI. come OUI
fronl door ofthe house and immedialCly call A.P, a "CURt. OfflCefGrieshop's
Yiew was ob!;uuclcd partially by Ute limbs and branc:he, bUI he could ue lhlll A.P. and
Prie!l "'ere mOyillll aroond 011 the (runl pon;h lLnd he cl)lIld hear Priesl eOl1linuin& to yell
u A P callinl her I IpIn, Officer Grieshop Ihm heard PriC!! Trapp. who
... IlO\OI SlaDIiIIlJJIl5t lIlSidc tbc &onl: pie ofPrics!'s ploperty. OffICU Oricsbop:lllw
Print run lim.>T1 from 1M Ironl porctl and knoek Tripp 10 tbc Jl'OUI'd,
Officer .... 10 l'rie$t, POLIO':., STOP POLICE!" 1'ricIl
WIS on lop of Trapp and punching Trapp. Officer Griesllop continued 10 demand lllal
Priesl !lop, 1M Priesl ilJ"l"C'l his command. and continued punchin! Trapp. Trapp was
l)11lI on Ihr: etuulc in a fNI POSllion, 1ry11ll1O protect hlluelfrrom
otTten' Gncshop pbbcd Pnc::sI-.:llIDd!hot IK'Ck and pulkd him offofTl1Ipp, Pnc::sI
COO!IJllielllo SlrUgle willi Officer Oricsbop. IJlIOI'UIK his COImIaIIds for PrieslIO S10p
resisling and 10 put hi. hands bdiind h. back, Priesl conlinued 10 II'} 10 gel It Trapp.
orneer Grin./lOp had to lake PrieSt dOWl1IO the ground lUId struggled with l'1iest to leI
him in handcuffs, Officer Grieshop desaibed Pries! as beinl in'" blind
After Pries! was detained iIlllanlkufTs. OfftCel" Qriesllop IVlIk:ed 1IW Pricslwas
..ami only socks evcn thou.. tl1mI was _ on !he sro-d and !tie ....
apprux"nalcly IG-dqrcc:s. Offoccr Qric::)hop look PricsI. inside the (ronlOoor 10 hIm
lIU1 nrlht cold md ,mmedtllely nnliced three children who wm: S1anding by the (ronl
window and cryinl. The childKn wen: later identified as tIM: Priests' thKe children:
/Ii
Sl". TY'5 MOTlOIO rooo ISJ,"": Tn m.r P.i_.... ..>iD .1TlllA\'lTrH
eLl
!Jyear-old c.J.1'.. 7year-old C.P., and 4-yearold J.I'. Priest put 00 a pair ofshocs alld a
jacket:md was detained in Officer Gricshop's patrol vehicle.
Officer Grieshop then asked A.P. what happellCd. A.P. explained thai she had
rttei\'ed a calt fium J.P.. she was crying and stated thaI Iter dad was using wo.ds like
"ruck" \0 he. Priest gOl on the phone, called A.P. names, and told A.P. and Trapp to
pick up J.P. A.P. 51ated she was fct:ling scared because of the way Priest Wa! acting lin
the phone and that he had been dUeItening to her before. A.P. Slated she drove to p.iest's
hou>c and went up to the front door to &<:1 J.P. She rang the doorbell and Priest came out
ufthe holl,,", ydlinll in her f""e IlItd at he. J.P. kept coming out ofthl' house, and
Pries! kept puming her back inside, !'riest told A.p. to leave. and A.P. said "you told me
lu COme he.e til get'" J.P. AI'. slated she was not Iloinlltu walk away from m,t kioh who
were II1lbe hou..'Ie and who we.e scared and crying, then Volbbed her arm
and tried to push her d<1WTlthe stairs of the porch. A.p. would have fallen down the stairs
but sIle stopped hcrsc:lfby clinging 0010 the bannister. At this point, J.P. had gotten put
Priest 011 the porch. A.P. stated that Priest then picked up J.P. like !he wasil. "5II.oCk of
potatoes" and threw her thlOUgh the open doorway and onlo the floor. AI'. further stated
Priest tan down the stairs andjumped on Trapp. A.p. stated that Priest did nOf obey
an)" commands from law enforcement 10 stop and put his hands 111 the air.
Officer Grieshop then interviewed Pricst. who agreed to a =orded interview
without an atloml:Y P'l:scnl. Pd""t stated thaI he and his children were at home and
having dinner when his youngest daughler, 4-year-old J.P., stane<! saying "mommy sleeps
with Jon. you arc not as strong lIS Jon, and I warn to be with Jon." Pries! staled that he
told JP. that;t hun his feclings when she said those things. J.P. asked p.icstto let her go
holllC to her 1Ill>lhc. p.iest !ltatro tlull he calle<! AlUla and told he. to pick up J.P. at his
house, He also told A.P. that site could hring Trnp(l with her Ul pick up J.P. Priest !taled
that the protocol is for A,P. to wait at the street for the pickup and that "he objected" to
A.p. beill& on his property. Priest stated he asked her to leave but she did not1eave the
ITAn's JoI0TIl:JN FOR U:.oVI: Tn l"lt,r, "F1'1lAVrT SUI'f'(lIlT
PAGr,.
porth. l'tieSl denied throwing his 4-year-old daughter, slllting thai he only quiekly picked
her up and put her inside the hoose. Priest also denied trying to push 1\.1'. down the slll;rs,
and stated that he grabbed her shoulder and asked her to lea"e. Priest Slaled that he
respondcd approprialely. and for<:ibly removed them from the property and that "he woold
flICking do il again. Priest stated he knew the officer WIS there at the Street and that he
should have asked !hi:: police to remove Trapp, but that "when Ihe man who is fucking
your wife and your wife is acting like white trash in front ofyoUf children it's not thai
easy to always ma;n\.llin your composure." Priesl slaled thai Trapp was about 10 feel onto
property, d<Jwn by the gate. whc:n he ""'ellt <!own th"re and knoo;kC'd the shil OUt of
him, which is what I will fucking do again if he ever gets 00 my p-operty." PriCSI
admillcd that he called A.P. a cun! and said IItal using profmity wun't ilkga!. Pricst also
admilled Ihat he should have complied with Officer cnmmllRd.to get offof
Trapp and to $lop resisting arreSI bUithat he "",as angry al a man who is fw;king my wife,
who is on my propet1y, who I asked three times 10 leave, "'ho wouldn'\."
T",pp was transported to the Beatlooth Billings Clinic in Red Lodge. "'here he
leamed he had suffered a broken rib during l'riesl'S auack. Ked Lodge Police Officer
ScOll Cope intervie"'ed Trapp 1I5 the hospilal. Trapp S\.llled that he and 1\.1'. went 10
Pricsfs house 10 pick up J.P. Trapp could see the kids in the window crying when the)'
arrived at the house. A,P. weot up to the front door while TlIlpP waited on the sidewalk.
Trapp SlIid Priest came OUt the fronl door, he ",as yelling and being very aggressi\'e
loward A.P, Trapp saw J.P. nut out Ihe front door loward her mother. Trapp slaled that
Priest grabbed J.P. and "pilChcd her" through the frOllt door. At tbis point, Trapp decided
10 slep the to Priest's property Trapp told Priesl that he was going to J'tCOI"d
tillS e\'cnt on hi5 phone. yelled at him to get out, bUI before Trapp could leave,
PriC!\t ch"gM at him and him againM a metal fence. PrieStlllCkled Trapp 10
the ground and began punching Trapp while Trapp look. defensive position to try to
III
SToff'S MOTION rnl IS... "" TO fit." r"roll."UION .. "n .. ro'l)A\'IT I'" SI'r1'OIT

prOlect himself from Priest's blows. Trapp staled that Priest looked "wild' &rid thaI
"somo:tlling didn't look right with him: it's not the way he nonnally presents in
Priesl was mesIC(! for Partrlcr Family Member Assault and Resisting Arrest.
Local authorities requested thllt the case be turned over to the Dep.artmenl ofJu.stice for
runher investigation and prosecution due 10 the appelll'llfl of impropriety since I'riest is
well known in tile community.
After the use WIl5 tumed over. tile PriestS' three children were forensically
intcn-iewed by Dawn Spencer ffQm the Monlanll Department of Justice. Spencer has
l)lCcific and specialized lraining in the techniques of fOl'ClIlic interviews of children. All
thn.-c children staled thaI Priest grabbcO their mOlher, A.P., by tile ann and tried to pll.'lh
her down tile that Priest had picked up J.P. and threw her into the house. causing
,njtJr)'; and that Priest had tadded Trapp in the front yard.
Specifically. 4yurold J.I'. stated that her dad started using bad words. saying
"fuckine" and "fuck off' to her while lhey ",ere at the house. J.P. staled lhal her dllc1
t.alked to her mom on the phone and her mom came to the lIouse to pick her up. J.P. said
she saw her dad push her "mommy and thaI she almost fell down tile stairs." J.P. Staled
"dad throwed [sic] me and a crash went on tile floor."
Seven-rear-old c.P. stated thaI she was walching oullhc window when her "dad lried
to pw;h lher) mom down the stain" outside on the front porcll. C.p, staled that J,P. wanted
to go to their mOthe,s house: and that "dad got mad" about J.P, waming to leave. c.P. stated
thaI her father said some bad wOl"ds and then called her mother and said aooliler "had word"
and told her to oome over and pick up your child. She said that her mom came to Ihe IIollSC,
and that h.,. dad tried to push h.,. mom down tile stairs but she held onto the railing Her dad
also pushed J.P. into the IIol,lse and that she heard a big bang and saw J.P. fall do.." onto the
noor J.P. W3'i crying. C.P. stated thaI her dad thm atlacked her mom's friend.
Nine-year old C,J,P. that the three children were at their dad', hoose,
watching the new Lone Ranger movie. J.P. wanted to go home so she called'their mom.
SfAU'UlOl1Ofi FOR tF.A"1: TO ntt lNFORIIIATlOI'I ANO AHUlA IN SUI'P(lRT
'ACt'
CJ.P. stated that their dad got on the poone Ind Slated '"you and Jon come over here, then
he said .. I am not going to repeat the word. c-u-n-t:' C.J.P. sWtl'll that his mom arrivcd
at the house shonly after the phone eonvcrsation and that J.P. rushed out the door to meet
their mother. C.1.P. staled that their father "physiully threw" J.P_into the hous<:. CJ.P.
stated he saw her "flying through the door" and that she landed on the noor inside the
fl'l)l\t doorway. J.P. got up from the floor and wu crying_ C.J.P, c.P., and J.P. watched
what was going OIl outside through the front window. C.J.P stated that he saw his dad
8,,.1\ his mother and that he tried to push heroffthe stain;. C.J.P. stated that his father
Ihcn tackled Trapp_
Trapp sustained a broken rib and abrasiOll!i in the attack from Priest. J.P.
complainetl of pain in Il<:r head. Ambulance medics 8S!>eSSed J.P. lllld disrovered she had
an area of 5welling about I-inch io diameter on her scalp. When mediC5l15ked J.P.
happened, J.P. told tIM:mlhat her dad threw her to the grQund.
Based on {hne foels, the afftant believes prohable l:/lUSC exists to charge the
Defendant. JlllIon Sh.lI.r l'riest, w'llllh. alleged offenses. Accordingly, the affiaot
moves this Court for leave to fik the requested Information.
DATED <h;, lL"',;.y ,FF,bru.ry,
MARY .' HENOUk
Assislalu AttllfmY Genenl
Special Deputy County Attorney
for Carbon County GeneTllI
SUBSCRIBED AND SWORN TO before OK' thisut:tay of february, 2014.
q",1a>,-----
ST.. .. FOIl Lil\"It TO FtL[ tNmRMATtO!O ..NO AFFID.. VIT I:" SUProRT
... Gt,