Electronically Filed

6/30/2020 12:58 PM
Seventh Judicial District, Fremont County
Abbie Mace, Clerk ofthe Court
By: Shannon Cook, Deputy Clerk

ROB H. WOOD # 8229

Madison County Prosecuting Attorney
rwoodflcomadisonidus

159 East Main Street

P.O. Box 350
Rexburg, Idaho 83440
(208) 356-7768
(208) 356-7839

IN THE DISTRICT COURT OF THE SEVENTH JUDICIAL DISTRICT OF

THE STATE 0F IDAHO, IN AND FOR THE COUNTY OF FREMONT
MAGISTRATE DIVISION

STATE OF IDAHO,

Plaintiff, Case No.2 CR22-20—0755

v.

PROBABLE CAUSE AFFIDAVIT 0F

CHAD GUY DAYBELL, DETECTIVE RON BALL

DOB: 1968,

Defendant.

STATE 0F IDAHO )

)ss.
County of Madison

I, Lt. Ron Ball, of the Rexburg Police Department, being first duly sworn under oath,
depose and state as follows:

1. The information contained herein is true and correct to the best ofmy knowledge and belief.

2. I am a Detective with the Rexburg Police Department and have been employed in Law
Enforcement for more than 27 years. I am currently the lieutenant over investigations for

the Rexburg Police Department. I currently hold an Advanced Certificate and a

Management Certificate fiom the Idaho Peace Officers Standards and Training Academy
and have over 2500 hours of training. I have attended multiple trainings and classes

AFFIDAVIT 1
 and have over 2500 hours of training. I have attended multiple trainings and classes

throughout my career, including graduating from the FBI National Academy in 2015. I

have received multiple hours of specialized training in investigations. I have also

conducted numerous investigations and interviews with suspects, victims and witnesses

involving narcotics, sex crimes and fraud. I have also received numerous hours oftraining

on traffic stops and detection 0f criminal behavior.

3. Since November 26, 201 9, the Rexburg Police Department has been involved in the search

for JJ Vallow, DOB: 5/25/2012, (hereinafter JJ) and Tylee Ryan, DOB: 9/24/2002

(hereinafter Tylee). The search for these children began when Kay Woodcock, JJ’s

grandmother, called Gilbert Arizona Police to report that she had not had any contact with

JJ for several months. Gilbert Police contacted the Detective Ray Hermosillo of the

Rexburg Police Depanment (RPD) due to the RPD helping the Gilben Police with an

investigation in which JJ’s and Tylee’s mother, cousin, and uncle were persons of interest.

4. JJ and Tylee’s mother, Vallow, (hereinafter Vallow) has been charged with two felony

counts of Desertion of a Minor Child, one misdemeanor count 0f Resisting and

Obstructing, one misdemeanor count of Solicitation to Commit a Crime and one

misdemeanor count of Contempt. The Contempt charge is for failing to comply with an
Order in a child protection action in Madison County, Idaho to produce JJ and Tylee to the

Rexburg Police or the Department of Health and Welfare. Vallow was required to produce
the children by January 30, 2020 and refused to do so.

5. Tylee was 16 years old at the time she went missing and JJ was 7 years old when he went
missing. Until this time law enforcement has stated that Tylee was 17 at the time she went

missing because we were not aware she was missing until several months after her

seventeenth birthday. However, we now have reason to believe she was killed before her

seventeenth birthday.

6. Chad Daybell (hereinafter Daybell) was present in Kauai, Hawaii on February 20th, 2020

when Vallow was arrested on the felony desertion charges. I was present at that

arrest. Daybel] was also present at Vallow’s March 6‘“ initial

appearance in Madison

AFFIDAVIT 2
 County, Idaho. As such, I know that Daybel] was aware 0f felony charges directly related

to the location, health, and well-being of the minor children named above.

7. Daybell and Vallow were married on November S, 2019. Daybell’s first wife, Tamara

(Tammy) Daybell, died the night ofOctober 19, 201 9 in Fremont County, Idaho. Tammy’s
death is still under investigation.

8. The last verifiable sighting of Tylee was on September 8, 2019, in Yellowstone National

Park. The last verifiable sighting ofJJ was September 22, 201 9, in his mother’s apartment,

located at 565 Pioneer Road, #175, Rexburg, Idaho, by Lori’s friend, Melani
Gibb
(Gibb) and David Warwick (Warwick) While the Rexburg Police and FBI have received

many tips of alleged sightings since the beginning ofthe case, none of these tips have led
to any verifiable or actionable information regarding the health, safety or location of the
minor children.

9. Vallow moved to Rexburg on or about September 1, 2019, with Tylee and JJ and her

brother, Alex Cox (Cox). Vallow resided with her children at 565 Pioneer Road, Unit
#175, Rexburg, Idaho. Cox resided in the same complex, initially living in the same unit

as Vallow and then moving into his own unit at 565 Pioneer Road, Unit #107, Rexburg,
Idaho.

10. On November 26, 2019, Detective Hermosillo and Detective Hope from the RPD went to

Vallow’s home located at 565 Pioneer Road, #1 75, Rexburg, Idaho, to conduct a welfare
check. Detectives Hermosillo and Hope met with Cox and Daybel] outside the

residence. Daybell acted as if he didn’t know Vallow very well and stated he didn’t know
her phone number. Cox told the detectives that JJ was with his grandma, Kay Woodcock,
in Louisiana, which was not likely to be true due to the fact that Kay was the individual

who first called in a missing child report to the Gilbert Police Department. Cox said Vallow
may be in apartment #1 07. Hermosillo and Hope went t0 apartment #1 07, but the apartment
was completely empty and vacant. At this time, they called me and Detective David Stubbs

and asked me to come to the premises to help search for JJ.

AFFIDAVIT 3
 ll. Shortly after calling me, Detective Hermosillo called me again and indicated that he saw
Daybell driving a black Chevrolet Equinox away from the residence. Detective

Hermosillo stopped Daybell and asked him again if he had seen JJ. Chad responded that

the last time he had seen JJ was in apartment #107 He

in October. also admitted he knew
Vallow’s phone number and provided it to Detective Hermosillo.

12. On that same day, myself and Detective Stubbs located and spoke with Vallow in her

apartment, #175. We identified ourselves as RPD officers. Vallow told us that JJ was in

Gilben, Arizona with a friend named Melanie Gibb. We obtained Gibb’s phone number

from Vallow. This encounter was recorded on body-cam. We ended our contact with
Vallow and immediately attempted to call Gibb. We were unable to contact or speak with
her at that time. Vallow also informed RPD that Tylee was attending BYU-Idaho and
living with Vallow.

13. Because Detective Stubbs and I were unable to contact Gibb we immediately contacted
Vallow again and we requested that she call Gibb. At this time Vallow told us that Gibb

and JJ were at the movie “Frozen 2” so it was unlikely Gibb would answer the phone. We
instructed Vallow to call Gibb and have Gibb contact us so we could verify the location 0f
JJ.

l4. By the evening ofNovember 26, 201 9, we had still not heard from Gibb, so RPD informed
Detective Ryan Pillar of the Gilbert Police Department of the information we had received

regarding the children being with Gibb. Detective Hermosillo was informed later that

evening around 9:30 pm. that Gilbert Police went to the home of Gibb. Gibb was not
home but Detective Pillar contacted her by phone and she stated that JJ was not staying at

her Arizona house and had not been there for several months.

15. On December 6, 201 9, Detective Hermosillo was contacted by Gibb and she informed us

that both Daybell and Vallow called Gibb on November 26, 2019 at separate times. She

was contacted first by Daybell who told her that she would probably be contacted by the
police in regards to JJ’s location and he then asked her to not answer the cal]. Gibb
informed RPD that she was confused by this request because she had been told by Vallow

AFFIDAVIT 4
 in late September or early October that JJ was living with Kay Woodcock, who is JJ’s

grandmother. Gibb asked Daybell ifJJ was living with Kay and he told her that JJ was not

with Kay.

l6. Gibb was soon thereafter contacted by Vallow on her phone. Vallow asked Gibb to tell

the police that she had JJ and asked Gibb to tell the police that she had taken JJ to the movie
“Frozen, 2.” Vallow further asked Gibb to take a picture 0f some children in a manner that

would make it appear that Gibb had JJ with her and to send that picture to the police. Gibb

informed Vallow that she would not lie to the police and Gibb did not comply with
Vallow’s request.

17. Gibb first met Vallow in the fall of 201 8. Gibb introduced Vallow to Daybell in St. George
Utah at a “Preparing a People” conference.

18. In early 2019, Gibb was present with Vallow during a telephone conversation between

Vallow and Daybell. This conversation was in response t0 a “vision” 0f Vallow that her

husband Charles Vallow and her son JJ were going to die in a car accident by January 1 or

2 of201 9, which did not happen. During and after the conversation, Vallow told Gibb that

Daybell had informed her that while Charles had not physically died in an accident, his

spirit had left his body and been replaced by another spirit which was a dark spirit. The
dark spirit was named Ned Schneider.

l9. Gibb has informed law enforcement that the word “zombie” was introduced weeks after

the initial conversation to describe an individual whose spirit has left their body and been
replaced by another spirit. The new spirit inhabiting a person’s, or “zombie’s” body was
always a “dark spirit.”

20. At some point after Gibb first learned this doctrine from Vallow and Daybell, she was

infonned by Vallow and Daybell that they believed it was their mission to rid the world of

zombies. When Vallow initially spoke to Gibb about getting rid of zombies she spoke

about saying prayers to remove dark spirits from the human bodies they had inhabited. This

AFFIDAVIT 5
 information has been corroborated by electronic communications made by Vallow and
Daybell.

2]. After the death of Daybell’s wife on October 19, 2019, Gibb was informed by Vallow that

when a person became a “zombie,” their original spin't left their body and entered “limbo”
and is trapped and cannot progress to “paradise.” Vallow then informed Gibb that for the

person’s original spirit to be freed from limbo the person’s physical body had t0

die. Despite the teaching that a physical body needed to die, Gibb reports she was never

told by Vallow or Daybell that they planned to carry out a physical killing themselves. At

the time Gibb was told this information by Vallow, she was still under the belief that JJ

was with his grandma Kay Woodcock and that Tylee was at BYU-Idaho.

22. Melani Gibb has further informed RPD that sometime in the spring of 2019, before the

death 0f Charles Vallow, that Lori Vallow called Tylee a zombie. Gibb was on the phone
with Lori and heard Lori call Tylee a zombie to which Tylee responded “not me, mom.”
(Upon the unsealing 0f my probable cause affidavit in State v. Daybell CR22-20-0755,

Gibb spoke with me and clarified that Lori herself told Gibb that Tylee responded to being

called a zombie by saying “not me, mom.” Gibb did not hear Tylee say these words

herself.) This arose out of Lori requiring Tylee t0 babysit JJ and Tylee did not want

to. Lori Vallow also told Gibb that Tylee had turned into a zombie when she was 12 or 13,

which was approximately the same time Tylee had become “difficult” to deal with.

23. Gibb has further informed me that she was told by Daybell and Vallow that they held the
religious belief that they were a part of the “Church of the Firstborn” and their mission in

that Church was to lead the “144,000” mentioned in the Book of Revelation.

24. On January 26, 2020, a search warrant was served on Chad Daybell and Lori Vallow in

Kauai, Hawaii where they were living and on their vehicle. The children were not found

with Chad and Lori in Hawaii and no evidence was found t0 suggest they were living with

Chad and Lori.

AFFIDAVIT 6
 25. Through this investigation, we have discovered that JJ Vallow was registered at Kennedy
Elementary School in Rexburg, the first week 0f September, 2019. Kennedy School was

informed that JJ had an individual education plan, (IEP) due to his autism. Kennedy
Elementary was in the process of creating a new IEP for JJ. On September 23, 2019, JJ

had an unexcused absence. (It should be noted that originally in our investigation we
believed that J] was in school on September 23’“, but upon review ofhis school records we
found that he was not and had the unexcused absence.) On September 24, 2020, Lori

Vallow called Vickie Barton of the Madison School District and informed her that JJ was
going to Louisiana with his grandparents and wouldn’t be home until the end 0f October
or maybe later. On October 29, Madison School District records indicate that JJ would be

homeschooled. During searches 0f Vallow’s apartment in Rexburg and subsequent

searches of her apartment in Kauai, no homeschooling materials were ever found.

26. As mentioned, the last verifiable sighting of Tylee was in Yellowstone National Park on
September 8, 2019. Photographs establish she was there with her mother Lori Vallow, her

brother JJ Vallow, and her uncle Alex Cox. They drove there in Alex’s silver Ford F-

150. This trip was further established by tracking the GPS, cell tower connections, ahd
Google account information on Alex Cox’s phone.

27. The Cellular Analysis Survey Team (hereinafter CAST), is an FBI unit that provides

analyses of cellphone records and presents the information to law enforcement. CAST has
analyzed Alex Cox’s phone and provided the location information mentioned in paragraph

25. The CAST analysis provides the location of Cox’s phone. Due to my training and

experience and common knowledge I am aware that most individuals now keep their cell—
phones with them at all times and the location of an individual’s phone can be used t0

establish the location of the owner of the phone. CAST uses a cellular devices’ GPS data

points, cell tower connections, wi-fi connections, and Google tracking information to

establish the location of a cell phone. The GPS data points used by CAST are considered

to be highly accurate and can place the device within a 6 meter radius.

28. CAST has further informed law enforcement that Cox’s phone exited the west entrance of

Yellowstone National Park at 18:40. His phone appeared to be at Buckaroo’s BBQ grill in
AFFIDAVIT 7
 West Yellowstone, Montana from 18:45 to 19:02. Cox then returned to Rexburg, Madison
County Idaho, at approximately 20:37. The phone was then at Lori’s Apartment number
175 until 21:35, at which time, Cox appeared to go to the Maverick on Main Street in

Rexburg at 21:43 until 21:53. Cox then went back to Lori’s apartment fiom 22:44 t0
23:15. At 23:44 Cox’s phone is located at his residence in Apartment 107.

29. On Monday, September 9, from 00:00 (12 am.) and 00:44 Cox’s phone was located at his

apartment (107.) However, at 02:42 (2:42 a.m.) to 03:37 (3:37 am.) Cox is located again

at Vallow’s apartment (l 75) where Vallow lived with Tylee and JJ. This is significant, not

only because he is there in the middle of the night, but also because this is the only time in

September he appears to go over to Vallow’s apartment between midnight and 6 am.

30. At 04:37, Cox went back to his own apartment, unit 107, until 08:59. At 09:21 he was
located at a property with the address 202 N 1900 E, Rexburg, which is the residence of

Daybell. (It should be noted that while Chad Daybell’s address is listed as Rexburg, it is

actually located in Fremont County, Idaho.) The 09:21 reading is a GPS data point and

places him behind the home on Daybell’s property east of the barn.

3 l. Cox’s phone was still at the Daybell residence at 10:39. At 10:47, his phone shows a hit at

the City of St. Anthony. At this time, we are unable t0 tell ifhe was actually inside the city

limits of St. Anthony, (St. Anthony is about a 5-minute drive from the Daybell residence)

or if this was a cell tower ping 0n his phone while he was still at the Daybell residence. At
10:57 t0 11:39 Cox is located at the Daybell property. At 11:52 to 12:02 he was at Dell

Taco in Rexburg. He appears to spend most of the rest of the day in his apartment.

32. Through this investigation, the Rexburg Police Department and FBI have seized, searched,

and analyzed multiple cellular devices pursuant to search warrants. On June 1, 2020, I was
informed by Special Agent Ricky Wright of the FBI that the FBI had been examining a

phone believed to be owned by Tamara (Tammy) Daybell. The FBI found a text

conversation between Tammy and Daybell on September 9, 201 9, which is the day after

the last known sighting of Tylee in Yellowstone National Park.

AFFIDAVIT 8
 33. That text conversation reads as follows:

P Daybell to Tammy at 11:53 am:

1. “Well, I've had an interesting morning! I felt I should burn all of the limb
debris by the fire pit before it got too soaked by the coming storms. While

I did so, I spotted a big racoon along the fence. I hurried and got my gun,

and he was still walking along. I got close enough that one shot did the trick.

He is now in our pet cemetery. Fun times!”

b. Daybell to Tammy at 11:56:

1. “Gonna shower now and then go write for a while at BYU. Love you!”

P Tammy to Daybell at 2:47 pm:

l. “Good for you!”

PI
Daybell to Tammy at 2:48 pm:
l.
“I’m back home now.”

34. I found the text suspicious because raccoons are normally nocturnal animals and are not

regularly out during the day. Matt and Reegan Price, Daybell’s neighbors, have informed
law enforcement that Daybell’s son Garth told them that Daybell had shot a raccoon

sometime between July and August of 2019 during the day. Garth told Matt Price about

the raccoon in response to a question from Matt about hearing a gunshot. The Price’s

informed me that the fire pit in the back of the Daybell property was hardly ever used until

the last few months. Reagan informed me that there appeared to be frequent bonfires in

the pit on the Daybell property over the last few months and the first one she noticed was
soon after Tammy’s death on October 19, 2019.

35. On June 2, 2020, Detective Bruce Mattingly of the Fremont County Sheriff Office

contacted Samantha Gwilliam, who is the sister 0f Tammy Daybell. He asked her if she
was aware 0f a pet cemetery on the Daybell’s property in Idaho. She informed him that she

was aware of the pet cemetery and stated that both she and Tammy were pet people and

that they had both had pet cemeteries. When asked the location of the pet cemetery 0n the

Daybell property she stated that it was east of the red barn and near the fire pit. On June
4, 2020, I spoke with Samantha and she informed me that she was aware of the location of

AFFIDAVIT 9
 the pet cemetery on the Daybell property because Tammy had shown it to her. Samantha
was then shown an aerial photograph ofthe Daybel] property and she pointed to the same

area near the fire pit where Alex Cox’s phone pinged on September 9, 201 9.

36. The above facts establish that Alex Cox appeared to be at the Daybel] property on

September 9, 201 9, until at least 11:39. Chad sent the text to Tammy about burning debris
and shooting and burying the raccoon in the pet cemetery only 14 minutes later at

11:53. The pet cemetery referenced by Chad Daybell is located at the same location as

most of the pings on Alex Cox’s phone on September 9, 2019.

37. On June 3, 2020, I again interviewed Gibb and her boyfriend David Warwick in Pleasant

Grove Utah. We discussed in depth the weekend of September 22 and 23, 2019, due to the
fact that both Gibb and Warwick stayed at Lori Vallow’s residence in Rexburg that

weekend. Gibb informed me (consistent with information she has previously given to law
enforcement) that she arrived in Rexburg on September 19, 2019. Soon after she arrived

Lori Vallow informed Gibb that JJ had become a “zombie” and pointed out behaviors such
as sitting still and watching tv, claiming JJ said he loved Satan, and an increased vocabulary

as evidence that JJ was now a zombie. Gibb observed JJ’s behavior and felt it to be the

same as she had always observed it.

38. The last time Gibb and Warwick verifiably saw JJ was the night of September 22,

2019. Warwick informed us that it was late and that Gibb, Vallow and Warwick were
going to d0 a podcast. Warwick said that Vallow told him that JJ was acting up and so Cox
took JJ to his apartment in the complex. When Cox returned later that night he was
carrying JJ who appeared t0 be asleep with his head on Cox’s shoulder. Warwick

specifically remembered this because he saw it as a tender moment.

39. Warwick funher informed us that when he woke up the morning of September 23, 20] 9,
he asked Vallow where JJ was. This was between 8 and 9 am. Vallow informed Warwick

and Gibb that JJ had been acting like a zombie and had been crawling on the kitchen

cabinetry and had gotten on top of the cabinetry in the space between the cabinetry and the

ceiling. She informed Warwick and Gibb that when JJ had climbed upon the cabinetry that

AFFIDAVIT 10
 he had knocked a picture 0f Jesus offthe refrigerator. Vallow then informed Warwick and

Gibb that Cox had come and taken JJ. At n0 time during this interaction with Vallow did

Gibb or Warwick believe that JJ was in danger. Vallow had not said anything about

banning JJ 0r having Cox harm JJ.

40. Approximately one week after Gibb’s September visit t0 Rexburg, Vallow informed Gibb

that she had arranged for JJ t0 g0 live with his grandma, Kay Woodcock. Vallow further

told Gibb she had told Kay that she had cancer in order to convince Kay Woodcock t0 take

JJ. Vallow further elaborated to Gibb that she had traveled with JJ and handed him off to

Kay in an airport.

41. The FBI CAST team has analyzed Alex Cox’s movements the morning of September 23,

2019 by his cellphone GPS. At 09:55 Alex is again on Chad Daybell’s property. He was
there until 10: 12. The pings on his phone locate Alex near the pond 0n Chad’s property at

the northern edge of his property. Chad Daybell’s property is located in Salem, Idaho in

Fremont County.

42. On June 3, 2020 I asked Special Agent Ricky Wright of the FBI to analyze the frequency

ofAlex Cox’s visits t0 Chad Daybell’s property during the month of September 2019. His
response was:

a. “Per your request, I checked the visits by Alex to Chad’s house again. There were

only four visits by Alex during the month of Sept. These were on 9/6 (1241 —

1253), 9/9, 9/23, and 9/25 (1005 -~

1022). During the two Visits on 9/6 and 9/25,
all the pings were in and around the house, and there were no pings anywhere in

the backyard near the firepit 0r pond. As you can see, these visits were also short,

about 11 minutes and 17 minutes, like the one on 9/23 (17 minutes). The visit on
9/9 was the only long visit, approximately 2.5 hours.

43. On June 9, 2020 a search warrant was executed at Daybell’s residence and property. With

the assistance 0f a local FBI ERT team we located at multiple sites 0f interest. These sites

AFFIDAVIT 11
 were identified and corresponded t0 the cellular data of Alex Cox’s phone when he was on

the property, mentioned in paragraphs 12-16.

44. Additionally, one of the possible sites correlated to a location on the property Chad had
texted his wife about, mentibned in paragraphs 17 and 18.

45. The first site of interest was located on the north side of the pond near the north edge 0f
the property. This site corresponded with the two GPS pings from Alex Cox’s phone on
September 23, 2019. A patch of ground was located that appeared to be disturbed. The
weed growth on top of the disturbed ground was shorter than the surrounding weed growth.
What appeared to be sod etching was also noticed. The disturbed area was approximately
4 feet by 2.5 feet.

46. Members of the FBI ERT team removed the top layer of sod. Underneath the layer 0f sod

were several large flat rocks. The rocks were removed and two pieces of flat paneling were

found. The paneling was removed and investigators exposed a round object covered in

black plastic. (Similar paneling was found in a barn located on the property.)

47. Upon exposing the round object covered in black plastic a strong odor was noticed. A FBI
ERT member used a small sharp instrument and made a small incision in the plastic and a

layer 0f white plastic was observed. An incision was made into the white layer 0f plastic

exposing what appeared to be human remains, the crown of a head covered in light brown

hair.

48. The remaining dirt around this object was methodically removed, exposing what appeared
to be a body wrapped in black plastic. The plastic appeared to be tightly wrapped around

the body and secured with gray duct tape.

49. Cheryl Anderson, associate professor of anthropology at Boise State University, was

present 0n scene and advised the remains found near the pond appeared to be human.

50. As noted above, the GPS on Alex Cox’s phone pinged twice on September 23, 2019 near

the first site where human remains were found. The GPS records indicate that Cox was at

AFFIDAVIT l2
 that location for a total of 17 minutes on September 23, 2019. Due to the depth and width

of the “grave” the body was located in, and the rocks and paneling found in the grave, it

would be impossible for one person to have dug that grave, placed a body in it, placed the

rocks and paneling in the grave, and covered it back up in l7 minutes.

5]. A second site 0f interest was located behind a red unattached out building located roughly

in the center 0f the property near a fire pit. Next to the fire pit is an area used as a pet

cemetery. This site correlated to several GPS pings of Alex Cox’s phone on September 9,

2019.

52. Ground in this area was probed with a steel pole and several areas of disturbed ground were
located. During a search of this ground, a buried cat and dog remains were found. No
raccoon remains were located. A backhoe was used to dig further layers of dirt. While
doing this, bricks were located approximately a foot below the ground.

53. Once the bricks were discovered the soil was examined and what appeared to be two bones
were located. Based on the condition 0f the first bones found, Cheryl Anderson was not

able to determine whether the bones were human.

54. Methodically, the dirt in this area was searched and several other items of interest were
found including other bones, charred tissue and charred bones. Cheryl Anderson indicated

these additional bones, both charred and un-charred, and tissue found were human
remains.

55. Investigators provided photos 0f some of the partial remains that were found at the pet

cemetery to Sara Getz, Ph.D., a forensic anthropologist. Dr. Getz was able to identify those

remains as being non-adult human remains.

56. Around the time the head mentioned in paragraphs 44 through 50 was discovered, Chad
Daybell was observed leaving his daughter’s residence in a grey SUV. I and other officers

pursued hjm in police vehicles, conducted a traffic stop and detained him due to the fact

that human remains were discovered on his property.

AFFIDAVIT l3
 57. On June I], 2020, I observed the autopsy of the body described in paragraphs 44-50. The

body had not yet been removed from the plastic covering it was found in. As the body was
uncovered and the face exposed it was clear to me that this was the body ofJJ Vallow. The
body was well preserved. While I had never met JJ Vallow during his life, I was familiar

with his face due to seeing many pictures and videos 0f him. I was further familiar with

his haircut in the pictures I had seen of him in Yellowstone, which was shaved on the sides

and back and longer on top. JJ was further identified by Brandon Boudreaux, who was
shown an autopsy photograph of the body and face and was able to verify the remains were
JJ.

58. On June 11, 2020, I also observed the autopsy of the human remains described in

paragraphs 51-55. It was not possible to identify those remains by simply looking at them
as they were too damaged by fire and dismemberment and no longer had any recognizable

features. However, Dr. Glen Smith, an orthodontist and Deputy Coroner in the Ada County
Coroner’s Office was able to identify these remains as belonging t0
Tylee Ryan by
matching an irregular jawline with an X-ray of Tylee when she was alive. Despite
identifying Tylee, law enforcement was advised that it would still be wise to obtain a DNA
verification. We were informed that sufficient soft tissue existed which was not burnt that
we would be able to test the DNA. We are in the process of having said tests performed.

59. On January 16, 2020, a Child Protection Action was filed by the State 0f Idaho in Madison

County on behalf 0f JJ and Tylee. The case number is CV33-20-0045. The Court ordered
Vallow t0 produce JJ and Tylee within 5 days of service of the order to the Rexburg Police

Department or the Idaho Department of Health and Welfare in Rexburg. Vallow was
served that order on Saturday, January 25, 2020, by Detective Chad Cataluna of the Kauai
Police Department. Vallow refused to produce the children and never complied with the

order of the Court.

60. Alex Cox died on December 12, 2019 in Maricopa County, Arizona. His death has been
ruled to have been caused by natural causes.

AFFIDAVIT 14
 6]. Due to the facts listed in this affidavit, probable cause exists that
Chad Daybell, Lori
Vallow, and Alex Cox conspired t0 commit the crime ofconcealing and destroying/altering

evidence they knew would be produced, used, or discovered as evidence in a trial,

proceeding, inquiry or investigation involving a felony.

62. Chad Daybell performed at least the following overt acts in furtherance of the
aforementioned conspiracy:

a. Texted Tammy Daybell and told her about burning debris and burying a dead

raccoon in the pet cemetery on September 9, 2019.

b. Deceptively acted as if he did not know Vallow very well and did not know
Vallow’s phone number when questioned by the Rexburg Police on November
26,
201 9, despite the fact they were married at that time.

63. Alex Cox performed at least the following overt acts in furtherance of the aforementioned

conspiracy:

a. Told Rexburg Police 0n or about November 26, 20] 9 that JJ was with his grandma

Kay Woodcock in Louisiana.

b. Transported JJ Vallow from Madison County, Idaho to Chad Daybell’s property in

Fremont County on September 23, 2019.

64. Lori Vallow performed at least the following overt acts in furtherance of the
aforementioned conspiracy:

a Telephoned Melani Gibb and asked her to lie to the police about the location ofJJ.

b. Asked Gibb to create false evidence 0f JJ’s existence and location.

c. Falsely informed the Rexburg Police that JJ was in Arizona with Melani Gibb.
d. Falsely informed the Rexburg Police Department that Tylee was attending BYU—
Idaho and living with Vallow.

e. Refused to produce the children t0 the Rexburg Police or the Idaho Department of

Health and Welfare as required by a Court Order.

AFFIDAVIT 15
 Further your affiant sayeth not.

DATED this 29th day ofJune, 2020.

#:263/
Lt. Ron Ball

Rexburg Police Department

SUBSCRIBED AND SWORN to before me this bf day ofJune, 2020.

ummmg 7
‘

qb‘
4, -

.53 . ’5 Notar Public

S
.

a
§-
:
a
8%“ .0

:
§- Resmdmg
_ .

at:
’
,l

‘ flap, /D
_
7
'

E '.
Exp m2; : .=. . . .
’

§ g Commmswn Exp1res:
4”"7/
3.; d, . ,0 0 / A; 7
?AEUBLA.’ Oi?
2 q > ..'-I.. Fé Q}
‘

447 6‘ \\\ / /
0F \0\\\~$~

PC Found. June 30, 2020

Signed: 6/30/2020 03:45 PM

AFFIDAVIT 16