_________________________________________________________________

IN THE THIRD DISTRICT COURT - ALL DEPARTMENT

IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

_________________________________________________

AFFIDAVIT FOR SEARCH WARRANT

STATE OF UTAH )
:ss
County of Salt Lake )

The undersigned affiant, Detective STEPHANIE J WARDEN of Unified Police

Department, upon an oath or written affidavit subscribed under criminal penalty,
declares:

That your affiant has reason to believe:

THAT

On the premises known as 63 Market Street, Venice, CA 90291, further described

as of Records of Snap Inc. which is the records department of the application
Snapchat. Information for this data is located on servers within the Snapchat
premises that can be accessed by computer and/or cell phone application at
various cell site locations within or close proximity to Salt Lake County;

In the City of Salt Lake, County of Salt Lake, State of Utah, there is now certain property
or evidence described as:

1. Basic Subscriber information for the Snapchat accounts associated with the
user name wlfpkcari, consisting of the email address, phone number, account
creation date, and timestamps and IP address for account logins/logouts.

2. Logs, including sender, recipient date and time, concerning all snaps
including previous Snaps sent to or from the Snapchat accounts with the
username wlfpkcari, from August 17, 2019 - September 18, 2019.

Pursuant to Rule 40(c) of the Utah Rules of Criminal Procedure, Snapchat will
be protected against unreasonable interference and the search will be during
daytime hours. Based on law enforcement experience with Snapchat, your
Affiant knows that in order to obtain the above requested information, a search
warrant is required rather than a subpoena. This is because Snapchat requires

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 a probable cause finding. Therefore, the evidence desired cannot be obtained
through subpoena alone.

and that said property or evidence:

Was unlawfully acquired or is unlawfully possessed;

has been used or is possessed for the purpose of being used to commit or
conceal the commission of an offense; or

is evidence of illegal conduct.

Affiant believes the property and evidence described above is evidence of the crime
or crimes of discharge of a firearm causing serious bodily injury.

SNAPCHAT IS THEREFORE COMMANDED TO DELAY NOTIFICATION UNTIL

AUGUST 29, 2020, BASED ON PROBABLE CAUSE SHOWN THAT NOTIFICATION
WOULD JEOPARDIZE AN ONGOING INVESTIGATION.

The facts to establish the grounds for issuance of a Search Warrant are:

Your Affiant, Detective Stephanie Warden is an Officer employed with the Unified
Police Department of Greater Salt Lake, and is currently assigned to the Violent
Crimes Unit. Your Affiant has been given responsibility to investigate complaints
occurring in Salt Lake County involving violations of criminal matters. Your Affiant
is responsible to investigate homicides, unnatural deaths, violent assaults and
officer involved critical incidents.

Your Affiant is a Certified Peace Officer in the State of Utah, and has graduated
from the Utah Police Officer Standards and Training Academy. Your Affiant’s
specialized training includes drug identification and recognition courses taught by
the Utah Peace Officers Standard and Training and the Police Academy. Your
Affiant has had training in controlled substance(s) identification and investigation
of controlled substance related offenses. Your Affiant has also attended and
completed a forty (40) hour drug investigation course sponsored by Rocky
Mountain High Intensity Drug Trafficking Area. (H.I.D.T.A). Prior to being in the
Violent Crimes Unit, your Affiant was in the Millcreek Street Crimes Unit. While
in the Millcreek Street Crimes Unit, your Affiant was responsible for investigating
crimes involving narcotics, stolen vehicles, residential and business burglaries,
forgeries, fraud, identity theft and all property crimes that occur in the Millcreek
Area.

Your Affiant has also completed a 40 hour course at the University of Utah in the
field of substance abuse regarding prescription, illegal, illicit, and over the counter

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drugs. Your Affiant has completed C.I.T Crisis Intervention Team Training, in the
field of mental health. Your Affiant was employed by Salt Lake County Criminal
Justice Services in the Pretrial Division interviewing inmates to determine release
eligibility. Your Affiant attended the Annual Utah Gang Conference and attended
specialized training regarding human trafficking, drug pipeline, and gang culture.
Your Affiant has completed Pat McCarthy’s three day Street Crimes training. Your
Affiant completes an annual requirement of 40 hours of training through Unified
Police Department.

Your Affiant has made numerous drug related arrests involving the seizure of
controlled substances and interviewing suspects. Your Affiant has investigated
narcotic cases through trash covers, controlled buys, surveillance of suspected
drug sales operations, interrogation of suspects, and investigating intelligence
reports received by citizen. Your Affiant has made numerous arrests and
conducted interviews of burglary and forgery suspects, and suspects involved
in the possession or transfer of stolen property. Your Affiant has worked in an
undercover capacity with the High-Risk Victim’s Unit to help suppress prostitution
in Salt Lake County.

Your Affiant has had specialized training and has conducted several investigations
in regard to Identity Theft, Fraud, and Forgery. These types of crimes are
commonly used to quickly steal the identity of a person taken from stolen mail, I.D’s
and personal documents, and are then remanufactured into fraudulent documents
by use of a portable scanner, printer, and computer.

Your Affiant has had specialized training identifying and investigating

strangulation cases put on by the Training Institute on Strangulation Prevention,
Alliance for HOPE International. Your Affiant has attended the National Homicide
Investigator's Association Conference. Your Affiant also has specialized training
in conducting officer involved shootings and in-custody death investigations.

On August 24, 2019 Unified Police Department Officers responded to 3142 Havea
Circle in Taylorsville on a report of a shooting that had just occurred. The arriving
officers were told there was a female in the living room of the residence with a
gunshot wound to the head.

UPD officers arrived on scene and located three males inside the residence and
a deceased female. Two of the males claim they were in different rooms of the
residence. One male, identified as JS, stated he heard the female was playing
with a gun and it went off. JS stated there were four additional males and three
females in the residence. JS stated when the seven people left the residence,
they took the gun with them. JS stated three of the four males are roommates of

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the residence. JS stated his roommate, identified as Dillon Bullock, was hosting
the party at the residence.

UPD Detectives arrived on the scene of the shooting at 3142 Havea Circle. Your
Affiant could view the scene from the front door. There is an unidentified female
on the floor with a gunshot wound in the middle of the forehead. There is a spent
shell casing located approximately ten feet from the body, .380 caliber. The female
was identified as Kaylissa O’Leary after her ID was found during a search of the
residence.

Three males who reside at 3142 Havea Circle were sequestered on scene and
interviewed by detectives in the Violent Crimes Unit. The three residents helped
identify multiple party goers who left the residence after the shooting occurred.
Your Affiant interviewed Jorge Hernandez Espinoza who resides at the 3142
Havea Circle address. Jorge reported he observed two partygoers posing with
guns in their snapchat stories just prior to the shooting. Jorge stated he knew they
were at the residence because they were in the backyard of the residence when
they were posing with the guns. Jorge showed Your Affiant his snapchat account
and stated he believed the snapchats with the guns has been deleted since the
shooting. Jorge stated the story with the two partygoers posing was on either Nate
or Cari’s snapchat account. Nate has been identified as Nathan Neufeld and Cari
has been identified as Jacari Pate. Both males have been identified as being at
the party. Nathan’s snapchat username is “nateneufeld10” and Jacari’s Snapchat
username is “juuhcaree.”

Your Affiant spoke with Jacari who admitted to being at the residence when
the shooting occurred, Jacari also stated the “Juuhcaree” Snapchat username
belongs to him. During the interview with Jacari reported he has a second
Snapchat account, but he was not sure what the username was. Jacari stated he
believed it was wlfpakcari. Your affiant checked the wlfpakcari name on Snapchat
and found there were no results with that username, meaning it is an invalid
username.

Jorge showed your Affiant, a snapchat stories on the “dillonpbullock” snapchat

account. One of the videos was of three males drinking beers at the residence
prior to the shooting. Another story was Dillon Bullock in a vehicle and the rear
passenger in his vehicle pointed a firearm at the phone. Dillon Bullock has been
identified as one of the partygoers and actively used his Snapchat during the party.

Jorge also reported a male by the name of Jaxson was at the party. Jorge showed
me he was friends with Jaxson on Snapchat. Jaxson’s Snapchat username is
“xmasjaxinflaxin.” Jorge stated he had already opened up the snap pictures
Jaxson had sent him, so he was unable to retrieve them.

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 The Snapchat usernames of: xmasjaxinflaxin, dillonpbullock, kaylissa_9813,
Juuhcaree, and nateneufeld10 have all been identified as being used at the party
prior to the shooting which resulted in Kaylissa’s death. Your Affiant submitted
an Affidavit for Search Warrant on those five Snapchat usernames on August 29,
2019 and a Search Warrant was granted by the Honorable Judge Mrazik. Another
Affidavit for Search Warrant was authored on the Juuhcaree Snapchat username
on September 6, 2019 after Your Affiant realized username was mispelled. The
second Affidavit for Search Warrant on the Juuhcaree username was granted by
the Honorable Judge Trease on September 6, 2019.

On September 17, 2019, Your Affiant was provided another Snapchat username
for Jacari Pate’s second Snapchat account. As previously addressed, Jarcari
attempted to provide your Affiant with the account information but provided the
wrong spelling of wlfpakcari. The Snapchat account name of the second known
account for Jacari is “wlfpkcari.” This Snapchat account spelling is almost what
Jacari attempted to provide Your Affiant during his interview. The only difference
is he added the letter "A" to the spelling on the username. Detective Leslie was
provided the Snapchat username, wlfpkcari from a Detective in Plainfield, Illinois
who was familiar with Jacari Pate. Jacari Pate is originally from Illinois. Your Affiant
checked the wlfpkcari username and found it was a valid Snapchat account and
the display name on the account is Cari.

Based upon your Affiant’s training and experience, criminal activity is often times
arranged, planned, or recorded on cellular telephones. It is common place for
individuals who commit crimes, to not only carry a wireless device, but to also
use that device prior to, during, or immediately after the crime was committed.
Cellphones are also often used to take photographs during social events such as
parties. It is common place for individuals to use their cellphone to communicate
and share party details via texting, texting applications and social media profiles.

Your Affiant is praying another search warrant be granted to obtain the basic
subscriber information associated with the user name of: wlfpkcari, which has
been identified as Jacari Pate’s second Snapchat account. The basic subscriber
information consists of email addresses, phone number, account creation date,
time stamps, and IP addresses for logging in and out. Snapchat also retains the
logs to include sender, recipient date, and time, concerning the previous Snaps
sent to or from the Snapchat accounts with the username of: wlfpkcari. The
information held within Snapchat could assist investigators in this shooting and
death investigation.

This affidavit has been reviewed by Bradford Cooley of the Salt Lake District Attorney's
Office, and it has been approved for presentation to the court.

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WHEREFORE, your affiant prays that a Search Warrant be issued for the seizure of
said items in the daytime.

I declare under criminal penalty of the State of Utah that the foregoing is true
and correct.

Executed on: 18th day of September, 2019 @ 02:16 PM by /s/ STEPHANIE J

WARDEN

- Page 6 of Affidavit for Search Warrant No. 1992281 -

 _________________________________________________________________

IN THE THIRD DISTRICT COURT - ALL DEPARTMENT

IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

_________________________________________________

SEARCH WARRANT

No. 1992281

COUNTY OF SALT LAKE, STATE OF UTAH

To any peace officer in the State of Utah:

Proof by Affidavit made upon oath or written affirmation subscribed under criminal
penalty of the State of Utah having been made to me by Detective STEPHANIE J
WARDEN of Unified Police Department, this day, I am satisfied that there is probable
cause to believe

THAT

On the premises known as 63 Market Street, Venice, CA 90291, further described

as of Records of Snap Inc. which is the records department of the application
Snapchat. Information for this data is located on servers within the Snapchat
premises that can be accessed by computer and/or cell phone application at
various cell site locations within or close proximity to Salt Lake County;

In the City of Salt Lake, County of Salt Lake, State of Utah, there is now certain property
or evidence described as:

1. Basic Subscriber information for the Snapchat accounts associated with the
user name wlfpkcari, consisting of the email address, phone number, account
creation date, and timestamps and IP address for account logins/logouts.

2. Logs, including sender, recipient date and time, concerning all snaps
including previous Snaps sent to or from the Snapchat accounts with the
username wlfpkcari, from August 17, 2019 - September 18, 2019.

Pursuant to Rule 40(c) of the Utah Rules of Criminal Procedure, Snapchat will
be protected against unreasonable interference and the search will be during
daytime hours. Based on law enforcement experience with Snapchat, your

- Page 1 of Search Warrant No. 1992281 -

 Affiant knows that in order to obtain the above requested information, a search
warrant is required rather than a subpoena. This is because Snapchat requires
a probable cause finding. Therefore, the evidence desired cannot be obtained
through subpoena alone.

and that said property or evidence:

Was unlawfully acquired or is unlawfully possessed;

has been used or is possessed for the purpose of being used to commit or
conceal the commission of an offense; or

is evidence of illegal conduct.

Affiant believes the property and evidence described above is evidence of the crime
or crimes of discharge of a firearm causing serious bodily injury.

SNAPCHAT IS THEREFORE COMMANDED TO DELAY NOTIFICATION UNTIL

AUGUST 29, 2020, BASED ON PROBABLE CAUSE SHOWN THAT NOTIFICATION
WOULD JEOPARDIZE AN ONGOING INVESTIGATION.

YOU ARE THEREFORE COMMANDED:

to make a search in the daytime of the above-named or described person, vehicle,

item, and/or premises for the herein-above described property or evidence and if you
find the same or any part thereof, retain such property in your custody subject to the
direction of a prosecutor or an order of this Court.

Dated: 18th day of September, 2019 @ 02:21 PM /s/

- Page 2 of Search Warrant No. 1992281 -

 RETURN TO SEARCH WARRANT

NO. 1992281

The personal property listed below or set out on the inventory attached hereto was
taken from the person of Snapchat Inc., by virtue of a search warrant dated the 18th
day of September, 2019, and issued by Magistrate ROBERT FAUST of the THIRD
DISTRICT COURT - ALL DEPARTMENT:

Pending Data

I, Detective STEPHANIE J WARDEN of Unified Police Department, by whom this

warrant was executed, do swear that the above listed or below attached inventory
contains a true and detailed account of all the property taken by me under the warrant,
on the 18th day of September, 2019.

All of the property taken by virtue of said warrant will be retained in my custody subject
to the order of this Court or of any other court in which the offense in respect to which
the property, or things taken, is triable.

I declare under criminal penalty of the State of Utah that the foregoing is true
and correct.

Executed on: 26th day of September, 2019 @ 09:54 AM by /s/ STEPHANIE J

WARDEN

- Page 1 of Return of Service for Search Warrant No. 1992281 -