Bond Court Proffer

Defendant(s):
DEFENDANT 1: MARVIN BAILEY, 34 year old male
aka: CARL JOHNSON
Charges: DEFENDANT 1: First Degree Murder
Date/Time: @ 3/15/19- 3/17/19
Location: 8530 S. Bennett, Chicago, Cook County Illinois
Victim 1 – Chaunti Bryla, 43 year old deceased female victim,
The people expect the evidence to Show
The Defendant, Marvin Bailey is the half-brother of Victim’s
son. The Victim had a child with the Defendant’s father. The
Defendant had been paroled from IDOC to the Victim’s address.
He was living in the Victim’s residence in February of 2019. On
February 28, 2019, the Defendant’s girlfriend got into a fight
with the Victim. After the fight, the Victim wanted the
Defendant to move out of her home.
On 3/14/19, V’s aunt, W1, dropped the Victim off outside of
her apartment at approximately 7:30 am. The Victim had
stayed with W1 the previous night. On 3/15/19, the Victim’s
regular cab driver, W2 , picked the Victim up at her residence.
W2 drove the Victim to a liquor store located at 8700 S.
Commercial. The Victim is captured on video using the ATM
and purchasing a bottle of alcohol with her card at
approximately 12:25 PM. W2 drove the Victim home and
watched the Victim walk back into her apartment building.
On 3/15/19, video surveillance shows the Defendant meet up
with W3 at the McDonalds located at 79th and Yates. They both
then left the McDonalds together. Later that evening, 3/15/19,
surveillance video captured the Defendant using the Victim’s
ATM card at approximately 11:02PM at 2401 E. 79th St. The
Victim’s bank records show 2 ATM withdrawals of $201 each.
This was the same card the Victim had been using earlier that
day. At approximately 12:19a.m., on 3/16/19, the Defendant
took an Uber from 14 W. 95th St. to 8528 S. Bennett, the
Victim’s residence.
On 3/16/2019, the Defendant and W3 met back at the
McDonald’s and at approximately 11:13am, the Defendant and
W3 took an Uber to the Walmart located at 8331 S. Stewart.
Surveillance video captured the Defendant and W3 purchasing
bungee cords and ties at 11:27 a.m. Lyft records showed the
Defendant ordered a Lyft at approximately 1:45pm from the
Victim's residence. At that time, the Defendant and W3 carried
a large and heavy blue bin out of the Victim’s apartment. It
took both the Defendant and W3 to carry the bin. The bin also
has small wheels on one end of it. W3 indicates that they both
removed the large bin from inside the apartment.
At approximately 3:53pm that same day, 3/16/19, surveillance
video captures W3 entering the Defendant’s green van in the
McDonalds parking lot. At approximately 5:04p.m, the
Defendant and W3 returned to the same Walmart and are
captured on surveillance video using the Victim's ATM card to
obtain $100 and 2 redbull drinks. At 5:50p.m., the Defendant
and W3 are captured on video surveillance at the Home Depot
at 200 W. 87th St. W3 is seen buying a dolly. At 6:23pm,
surveillance video captured the Defendant and W3 returning to
Walmart and buying more tie down straps.
At 7pm that same day, the Defendant and W3 are captured on
video surveillance at 3075 E. Cheltenham, an apartment
building comprised of mostly vacant units, arriving in the
Defendant’s green van. W3 got out of the van and walked the
empty dolly along the side of the building to a dumpster area.
The Defendant then drove away in his van. The Defendant
reappeared on foot and met up with W3. At 7:26 p.m., video
captured the Defendant and W3 dragging the dolly with a
large, heavy object on it. That object is the same size and shape
as the large bin and W3 tells police that it was the same bin.
Bothe Defendant and W3 appeared to be clearly struggling
with the weight of the bin. W4 lived at 3075 E. Cheltenham and
was acting as a caretaker for the building and saw the dolly in
the hallway of the building. W4 saw the Defendant and W3 in
the same hallway. W4 inquired about what the Defendant and
W3 were doing there. W4 saw the Defendant and W3 walking
with the dolly and the bin on the dolly. W4 positively ID'd both
the Defendant and W3 in photo arrays.

On 3/17/19 at 2:39 a.m., the Defendant is captured on video in

the Dunkin Donuts located at 1231 S. Wabash. The Defendant
used the Victim's ATM card at that Dunkin Donuts and made 2
withdrawals for $202.50 each. The Defendant stayed at the
Dunkin Donuts until 3:41 a.m.
Just after 10:00a.m., on 3/17/19, the police performed a traffic
stop on the Defendant’s green van at 7700 S. Coles. The
Defendant and W3 both flee from the green van that was
parked in a vacant lot. Both the Defendant and W3 were
detained by the police. The officers were told that the
Defendant and W3 were on their way to Home Depot to get a
chain saw. This was on body cam video. The Defendant and W3
were released without any citations and the green van was not
searched. Body worn camera captured the clothing that they
were both wearing and it was the same clothing that they were
wearing on the various surveillance videos.
At 1:06pm, the same day, 3/17/19, video surveillance captured
the Defendant using the Victim’s ATM card twice at the Days
Inn located at 128th and Ashland . The Defendant withdrew
$203.00 and $303.00. At 1:47pm, the Defendant checked into
the King’s Inn located at 12808 S. Ashland. W5 is the manager
at the King's Inn. She identified the Defendant as the person
who checked into the hotel. W5 maintained a copy of the
Defendant’s driver's license and a receipt. The Defendant was
told that the elevator was not working at the hotel.
At 7:45pm, W6, a Lyft driver, picked up the Defendant and W3
from 3075 E. Cheltenham Pl. and drove them to the King’s Inn
at 128th and Ashland. The Defendant and W3 had a dolly and
the large bin. W6 guessed the bin weighed over 100lbs. The
Defendant told W6 that he was evicted and had to take
everything including his meats.
At 8:10 pm, the Defendant and W3 are observed unloading the
dolly and the blue bin from the Lyft driver’s SUV. The
Defendant was told that the elevator at the hotel remained out
of order. W5 watched the Defendant and W3 drag the dolly
with the big blue bin up 3 flights of stairs. The weight of the bin
was such that it took both the Defendant and W3 to drag it up
the flights of stairs. W5 identified the Defendant in a photo
array.
On 3/18/19, at approximately 3:59 p.m, the Defendant is
captured on video surveillance at the Days Inn at 128th and
Ashland in the gaming area using the Victim's ATM card. The
Defendant withdrew $83. The Defendant remained at the
gaming area until 4:46pm.
On 3/19/19 at approximately 8:35pm, the Defendant is
captured on surveillance video walking through the parking lot
of Advance Auto, 12826 S. Ashland, through the alley towards
the dumpsters, and then back towards the hotel. The
Defendant was not carrying anything except his cell phone.

On 3/20/19, the Defendant was captured on video at

approximately 4:13 a.m. walking in the alley behind the same
Advance Auto pulling the blue bin on the dolly. The Defendant
was then captured walking in front of Advance Auto towards
the King’s Inn with the empty dolly. The Defendant did not
have the large blue bin at this time.

On 3/20/19, at approximately 9:07am, V's Aunt , W1,

reported the Victim missing to the police. W5 knocked on the
Defendant’s hotel room door at approximately 11:30a.m
because the Defendant had not yet checked out. The Defendant
opened the hotel room door a crack. W5 smelled an odor
coming from the room unlike the normal smells in the hotel.
She described it as a cleaner or air freshener type fragrance.
W5 knew the smell did not come from the hotel’s cleaning
products because she orders the supplies.
At 12:36pm, W7, an Uber driver, picked the Defendant up from
the King's Inn and drove him to 112th and Michigan.
On 3/20 19, at approximately 9:02 pm, the Defendant went to
a Sub and Gyro shop located at 2451 W. 63rd St attempting to
use the Victim's ATM card. The Defendant could not use the
card because it had insufficient funds.

On 3/22/19, W8, who worked at the Rent A Center that shares

the alley with Kings Inn and the Days Inn, took out the trash to
the regular dumpster and noticed a large blue bin near the
dumpster.
On 3/25/19, W8 took the trash out again and noticed the
dumpster that was only for flattened cardboard boxes was
unchained. W8 looked inside the dumpster and noticed a large
black bag upside down that was visibly weighing down all of
the cardboard boxes. W8 also noticed at that time that the
large blue bin was in the alley towards Kings Inn.

During the subsequent investigation, Police recovered the

large blue bin on 3/29/2019 in the alley near the dumpster.
The Defendant’s green van was recovered and processed on
4/8/2019. The Defendant’s hotel room at King's Inn was
processed on 4/9/2019. Police took DNA samples from the
Victim's tooth brush from her apartment and the Victim’s DNA
was a positive match to the DNA found inside the large blue
bin. Additionally, Chicago police brought a cadaver dog to the
alley behind the Rent a Center. The cadaver dog hit at the
location where the large bin was recovered which indicated
the presence of the odor of human remains. The cadaver dog
also hit in the Defendant’s hotel room at the King’s Inn. The dog
also hit on the large bin itself which was located at Forensic
Services. Cell tower records show the Defendant's phone was
in the areas where the video surveillance captured him over
the course of 3/14/19- 3/20/19. Chicago Police Crime Lab
personnel tested the Victim's apartment, the Defendant's green
van, and his room at the Kings Inn with a Blue Star testing
reagent. The front bedroom, bathroom, the floor outside of the
bathroom, and the kitchen floor of Victim’s home resulted in
positive reactions for human blood component. A penny on the
floor of the Defendant’s green van resulted in a positive
reaction for human blood component. The bathroom floor, wall
and carpet of the Defendant’s hotel room resulted in a positive
reaction for human blood component. Lyft and Uber records
corroborate surveillance video and witness statements.
The black bag in the dumpster was never recovered. Police
searched the land fill in Indiana that the dumpster was
emptied into with negative results. The Defendant was
arrested on 11/25/2019. The Defendant made no admissions
to his involvement in the Victim’s disappearance. However, he
gave no explanation as to the contents of the large bin when
confronted repeatedly by the Detectives. The Victim’s body has
not been recovered. No members of the Victim’s family,
including her 10 year old son, have heard from her or had
contact with her since W1, the Victim’s aunt, dropped her off
on 3/14/19. W1 also talked to the Victim on a daily basis.
There has been no activity on Victim’s cell phone, which was
recovered from her apartment by police. There has been no
activity on any of the Victim’s credit or bank cards since
3/15/19.

AGGRAVATION: MARVIN BAILEY-

1. 15CR-11246- Aggravated Battery Deadly Weapon;
4/19/17; 8 years IDOC; on parole at time
2. Misd. Domestic Battery and CDTP; 1/6/11; 364 days jail;
3. Aggravated Battery Deadly Weapon; Armed Robbery;
9/28/05; 5 years IDOC
4. Misd. Theft- 7/18/03; 7 days jail.