Electronic devices, including cellular telephones, computers, tablets, external storage media, and digital cameras, which may contain evidence of communications with the victim, location data, or documentation of the crime.
Written materials, journals, notebooks, or maps tending to show motive, planning, or knowledge of the crime scene area.
Personal papers, receipts, fuel purchases, or travel records consistent with trips to or from the Uinta Basin at or near the time of the homicide.
Footwear consistent in size and tread pattern with impressions recovered near the crime scene.
Vehicles located at the residence, including keys, registration documents, and contents of said vehicles, for trace evidence, soil/plant comparisons, and GPS/location data.
Photographs, video recordings, or digital files depicting the victim, the crime scene, or evidence of the suspect’s presence in the Uinta Basin.
Any items containing latent prints, hairs, fibers, or biological evidence belonging to the victim.
DNA reference samples from the suspect, to be collected via buccal swab for laboratory comparison with evidence recovered from the victim and crime scene.
“It’s insane,” Lucy said, hugging herself more tightly.Her whole body was locked on to the house, where, on the other side of the windows, uniformed men moved.“It’s got to be some kind of mistake.”Her shoulders moved once, unevenly, and she burst out, “He’s a police officer!”
But it wasn’t a mistake.The search warrant meant it wasn’t a mistake.
The probable cause statement ran to almost five pages of single-spaced text.And while some of it was clearly boilerplate, giving background information on Agent Trevino—literally going back to her completion of the Utah Police Officers Standards and Training, and then following her through each stage of her career until she was hired by the State Bureau of Investigation, including every degree, training, course, and certification she’d completed along the way—near the end, it got into the specifics, as Trevino attempted to convince a judge there was probable cause to search Ammon’s home.
On October 15, 2019, deputies of the Uintah County Sheriff’s Office responded to a report of a deceased male inside a mesa cave located in the Uinta Basin, Utah.The male was identified as Brennon Lee, age 42.Examination at the scene revealed multiple stab wounds to the back.The body was transported to the Utah Office of the Medical Examiner, where preliminary findings confirmed death by sharp-force trauma.
Your Affiant learned through the course of witness interviews that several days prior to his death, the victim was involved in a physical altercation with Ammon Young, age 37, a resident of South Jordan, Utah.Witnesses described the altercation as heated and physical in nature, during which Mr.Young struck the victim and made verbal threats, stating words to the effect that he would kill him.
Your Affiant further learned from witness statements that the victim had been engaged in an unlawful sexual relationship with Daniel Young, the fifteen-year-old son of the suspect.The existence of this relationship provides motive for Ammon Young to harm the victim.
Your Affiant believes, based on the above facts—the prior physical altercation, threats made by Ammon Young against the victim, and the existence of motive arising from the victim’s unlawful relationship with Daniel Young—that there is probable cause to believe that evidence of the homicide of Brennon Lee will be located within the residence, vehicles, and electronic devices of Ammon Young.
Oh God.The thought was attenuated, echoing in the vast, empty dark Tean suddenly found himself floating in.
Daniel.
“Excuse me,” a voice said.“Who are you?”
A woman stepped out of the house.She was Latina, with a broad face and dark hair that she wore up in a bun.Her dark windbreaker looked official, and where it hung open, the seal of the State Bureau of Investigation showed on her polo.Khakis and a pair of tactical boots completed the outfit.She strode across the lawn, a notebook forgotten in one hand.
“I’m a friend of the family,” Tean said.
If you’d turned Lucy’s smile on its side, it could have cut glass.
“What’s your name?”the woman said.
“Teancum Leon.Who are you?”
The woman fixed flat, dark eyes on him, but she spoke to Lucy.“This is the man your husband asked you to call?”
“Yes,” Lucy said.
“Are you representing Mr.Young?”
“I’m not an attorney,” Tean said.“Who are you?”
“Agent Trevino, SBI.”Dead eyes continued to hold him.“Why did Mr.Young ask his wife to call you?”
Lucy’s smile grew.
Tean tried not to look at her.“I’m a friend of the family.”