E-FILED IN COUNTY CLERK'S OFFICE PIERCE COUNTY, WASHINGTON May 03 2012 9:25 AM

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vs. SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY STATE OF WASHINGTON, Plaintiff, CAUSE NO. 12-1-01566-1

KEVIN STOCK COUNTY CLERK

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DECLARATION FOR DETERMINATION OF PROBABLE CAUSE -1
Office of the Prosecuting Attorney 930 Tacoma Avenue South, Room 946 Tacoma, WA 98402-2171 Main Office (253) 798-7400

JAYSON STEVEN LEWIS BRODERSONMATTHAI,

DECLARATION FOR DETERMINATION OF PROBABLE CAUSE

Defendant. ROSIE MARTINELLI, declares under penalty of perjury: That I am a deputy prosecuting attorney for Pierce County and I am familiar with the police report and/or investigation conducted by the EDGEWOOD POLICE DEPARTMENT, incident numbers 120590153, 120590273, and 120590493; That the police report and/or investigation provided me the following information; That in Pierce County, Washington, on or about the 28th day of February, 2012, the defendant, JAYSON STEVEN LEWIS BRODERSON-MATTHAI, did commit IDENTITY THEFT IN THE SECOND DEGREE (7 COUNTS), POSSESSION OF STOLEN PROPERTY IN THE SECOND DEGREE (2 COUNTS), and POSSESSION OF STOLEN PROPERTY IN THE THIRD DEGREE. On February 28, 2012, at approx. 0551 hours Brittney Henry reported to the Edgewood Police Department that sometime between 2300 hours on February 27, 2012, and 0400 hours on February 28, 2012, someone stole her leased vehicle, a 2011 GMC SUV. While a deputy was on his way to Ms. Henrys residence in Edgewood, he was advised that Onstar had located the vehicle behind a building at Spencer Road and Meridian Avenue East in Puyallup. The deputy arrived and contacted Ms. Henry who stated that her vehicle was parked in her driveway overnight. The vehicle was unlocked and the keys were in the center console. Ms. Henry stated that several items were inside the vehicle including four pageant-type gowns, a box containing a Miss Washington crown and two Miss Washington sashes, an iPad, a Bank of America checkbook, two Bank of America debit cards, one Bank of America VISA credit card, and miscellaneous shoes and other items. Puyallup Police recovered the unoccupied stolen vehicle. It was parked behind a motel and locked. It appeared drivable. The vehicle was released to Ms. Henry who took it to a dealership in Renton. Forensics processed the vehicle at the dealership and recovered one latent print but no candidates were found for manual comparison. At 1156 hours on February 28, 2012, Ms. Henry reported to police that someone used her stolen debit card at Lowes in Federal Way at approx. 0624 hours for a $74.00 purchase. Ms. Henry also reported that her card was used at Squeaky Clean Car Wash in Federal Way at 0737 hours for $10.00, Wal-Mart in Federal Way at 0648 hours for $45.83, a Redbox DVD Kiosk, and a Bank of America ATM in Federal Way. No money was taken from the ATM due to an invalid PIN.

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On February 29, 2012, Pierce County Sheriffs Det. Simmelink was assigned the case for review and follow-up. Other detectives assisted in the investigation and began by contacting the locations where Ms. Henrys debit/credit cards were used. Det. Simmelink contacted a Bank of America investigator who stated that there were eight transactions or attempted transactions with Ms. Henrys debit card ending in 5800. All were done on February 28, 2012: 1. 0649 hours - ATM at Twin Lakes Branch transaction denied for invalid PIN. Surveillance photos depict a male subject wearing a black and red Tacoma Fire jacket with the hood up. The images are of poor quality with limited detail. (COUNTS 1 and 2) 0624 hours Lowes in Federal Way for $74.00. Surveillance video shows two white males wearing black jackets, jeans, and baseball hats. The taller subjects (later identified as Jayson BRODERSON) hat has a patch on the front of it and the jacket he is wearing appears to have an emblem or badge on the left chest. The hat and jacket are similar to what is worn by law enforcement and fire fighters. The shorter subject (later identified as Robert Broderson) is wearing an Under Armor hat with logo on front of the hat. The hat is worn backwards and he has sunglasses on his head. Det. Simmelink later opines that Jayson and Robert BRODERSON carry items to the self-checkout station. Robert and Jayson both use the touch screen computer and are involved in the transaction. It appears that Jayson is the one who actually slides the credit card for use and uses the electronic pen to sign for the transaction. (COUNT 3) 0636 hours Red Box for $4.82. Red Box located inside a Wal-Mart store in Federal Way. Video surveillance shows the same two subjects from the Lowes video. The video also depicted a black vehicle that the suspects left in. The images are of poor quality. It is unclear to Det. Simmelink who uses the credit card for the transaction. (COUNT 4) 0648 hours Wal-Mart in Federal Way for $45.83. Video surveillance is of poor quality. Det. Simmelink stated that the video shows Jayson BRODERSON making a purchase that includes a yellow duck stuffed animal and he uses a credit card for the transaction. (COUNT 5) 0651 hours Wal-Mart in Federal Way for $85.96 transaction denied. Video surveillance is of poor quality. 0737 hours Squeaky Clean Car Wash in SeaTac. No valuable video surveillance obtained. 2016 hours Shell Gas Station in Puyallup for $1.00 transaction denied. No video surveillance available. 2019 hours Blockbuster Express for $2.18 transactions denied. No video surveillance available.

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Ms. Henry advised the detective that additional transactions occurred with credit card ending in 0498: 9. 0311 hours Shell Gas Station in Puyallup. Unknown charge amount. No video surveillance available. 0510 hours Shell Gas Station in Tacoma. Unknown charge amount. No useful video surveillance. 0545 hours ATM at Twin Lakes transaction denied. Surveillance photos
Office of the Prosecuting Attorney 930 Tacoma Avenue South, Room 946 Tacoma, WA 98402-2171 Main Office (253) 798-7400

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DECLARATION FOR DETERMINATION OF PROBABLE CAUSE -2

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depict the same subject wearing Tacoma Fire jacket mentioned above. (COUNTS 6 and 7) 0640 hours Red Box for $4.82. Red Box located inside Wal-Mart store in Federal Way. Video surveillance mentioned above but includes the same two suspects at the Red Box. (COUNT 8) 0654 hours Wal-Mart in Federal Way for $218.85 transaction denied. Video surveillance noted above. Taller suspect (Jayson) is depicted attempting to make the transaction. (COUNT 9) Unknown time Squeaky Clean Car Wash in SeaTac for $10.00 transaction denied. No valuable video surveillance available.

Ms. Henry also reported the use of her debit card ending in 6736:

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0656 hours 76 Gas Station in Federal Way for $1.00. No additional location information available. Unknown time Squeaky Clean Car Wash in SeaTac for $10.00 transaction denied. No valuable video surveillance available.

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Det. Simmelink contacted the Tacoma Fire Department to inquire about possible stolen fire department property. She was advised that an employee who lives in Edgewood had been the victim of a vehicle prowl and theft where a Tacoma Fire Department jacket and other items were stolen. (COUNT 10) The victim in that case, Robert Schiemer, reported that between 2300 hours on February 27, 2012, and 0545 hours on February 28, 2012, someone entered his van and stole his TFD jacket with full decals, a Bluetooth, a gold necklace, a first aid kit, a small flashlight, and a shoe cleaning kit. The vehicle was processed by forensics. No latent prints were located. Based on the video, Pierce County Sheriffs Department created and distributed a Crime Stoppers bulletin to law enforcement and media. The bulletin generated several tips from the media release. One tip identified the two suspects as Jayson BRODERSON and his cousin Robert Broderson. Additional information received identified Jayson BRODERSONs girlfriend as Cassie Hamilton and that Hamilton had Miss Washingtons crown and dresses. Both BRODERSONs had felony warrants for their arrest. On March 16, 2012, Jayson BRODERSON was arrested while he was driving a stolen 2008 Ford Escape. This vehicle looked to Det. Simmelink to be similar to the vehicle the suspects left Lowes in after completing a fraudulent transaction on Ms. Henrys stolen credit card. In continuing her investigation, Det. Simmelink later went to a Federal Way residence associated with BRODERSON. Paula Pries was at the house. Pries stated that Jayson was not at the house. When asked if she knew why police might be looking for Jayson, Pries stated it was because of Crime Stoppers. Pries stated that Jayson was wanted on Crime Stoppers for the Miss Washington incident. Pries stated that Jayson moved in with her two days before Miss Washingtons vehicle was stolen. Jayson never paid rent but said he was going to. Pries stated that Jaysons girlfriend, Cassie, stayed at the house for about seven days with Jayson before she moved to Sumner. When asked what she knew about the Miss Washington incident, Pries stated that Jayson and Bobby (later identified as Robert Broderson) and Cassie were looking at a photograph on their phones. It was the Crime Stoppers photograph. Preis stated she heard them talking about it and based on their conversation it was obvious it was them in the photograph. Pries stated that she met BRODERSON through a friend and BRODERSON stated that he found a couple bags with Miss Washington items, a fire suit, and a fire hat by a dumpster. Pries stated that BRODERSON was laughing about finding the fire coat and hat. BRODERSON put it on and went into DECLARATION FOR DETERMINATION OF PROBABLE CAUSE -3
Office of the Prosecuting Attorney 930 Tacoma Avenue South, Room 946 Tacoma, WA 98402-2171 Main Office (253) 798-7400

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the Shell Gas Station. Pries stated that a little guy named Bobby was with BRODERSON. Pries stated that BRODERSON told her the crown and dresses were not with the property they found. Pries stated that BRODERSON told her they used Miss Washingtons credit card. Pries also stated that BRODERSON used a Swiffer Sweeper that he purchased with Miss Washingtons credit card. Det. Simmelink noted that a Swiffer Sweeper was purchased with the stolen credit card at Lowes. Det. Simmelink showed Pries the Crime Stoppers Bulletin. Pries identified the taller subject as Jayson and the shorter subject as his cousin Robert. Another person in the residence was interviewed by police. That person stated that one evening he was at Priess house when BRODERSON arrived at around 3:00 or 4:00 in the morning. He was driving an SUV and it was backed up to the garage. BRODERSON had someone with him that he referred to as his cousin. BRODERSON was wearing a Tacoma Fire jacket and he was unloading stuff from the back of the SUV. The interviewee also remembered a Tacoma Fire hat but couldnt recall if BRODERSON was wearing it. Det. Simmelink showed the Crime Stoppers Bulletin to the interviewee who identified the two subjects as the same two he saw at Priess house. On March 19, 2012, Det. Simmelink contacted Jayson BRODERSONs girlfriend, Cassie Hamilton. Hamilton stated that shes been dating Jayson BRODERSON since September 2011. She met him the day he got out of prison. Hamilton told the detective about their relationship. During the interview, Hamilton stated that she saw the Crime Stoppers bulletin and people were saying it was Jayson. Hamilton confronted BRODERSON and he denied taking Miss Washingtons stuff. Hamilton denied seeing the crown or the dresses. Hamilton denied seeing any firefighter clothing. BRODERSON did tell Hamilton that he found a bag with a credit card in it and he used it. Hamilton told police that BRODERSON had been driving a dark colored SUV that he said was a company vehicle. Hamilton stated that he never parked in the driveway, but would park down the street. Hamilton allowed police to search her residence. On the top shelf of Hamiltons bedroom closet police found a yellow duck stuffed animal with the tag still attached. The tag indicated the animal was purchased at Wal-Mart. Det. Simmelink recalled a plush toy being on the receipt from the fraudulent purchase made on Ms. Henrys credit card from Wal-Mart. The detective later compared the number on the merchandise to the number on the receipt and it matched. Hamilton stated that BRODERSON gave her the stuffed duck. Det. Simmelink later viewed the Wal-Mart video surveillance and observed a yellow duck stuffed animal as one of the items purchased using Ms. Henrys credit card. Police looked in the garage and noted a bag or something closed in the access to the attic area. Hamilton stated that she wasnt sure what was in the garage as she never goes in there. Hamilton stated that two weeks prior, BRODERSON said he cleaned up the garage for her and he put some boxes in the attic. Hamilton stated that she had no idea what was there and invited police to look. Hamilton repeatedly stated to police that she didnt want any stolen property in her house. Police opened the attic and discovered two black wallets placed along with several boxes. The boxes contained nothing of evidentiary value. One of the wallets contained identification in the name of Jayson BRODERSON. There was a Department of Corrections card, a Teamster Local 117 card, a Wells Fargo VISA debit card, and a Turbo Tax VISA debit card with his name on them. There was also a WalMart Money Card Master Card with the name Valued Customer on it. The other black wallet contained a Washington drivers license and a Costco card with the name Nancy Bartholomew on them, a copy of a high school diploma with the name Rosalie Nielsen, a Cascade Regional Blood Service card in the name of Shelley Louderback, a King County voter registration card in the name of Shelley Louderback, a Washington drivers license in the name of Paul Louderback, and a passport services card and a GSA VISA card in the name of Donald Huerta. Det. Simmelink contacted Shelley Louderback who stated that they were the victim of a burglary on February 18, 2012, and they filed a report with the King County Sheriffs Department. Louderback stated that her jewelry box was taken which contained the cards found in Hamiltons attic. Louderback stated that she does not know Hamilton or either BRODERSON and did not give them permission to have her property. DECLARATION FOR DETERMINATION OF PROBABLE CAUSE -4
Office of the Prosecuting Attorney 930 Tacoma Avenue South, Room 946 Tacoma, WA 98402-2171 Main Office (253) 798-7400

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Det. Simmelink contacted Nancy Bartholomew who stated that on March 12, 2012, at 0730 hours her purse was stolen from inside her garage in Bonney Lake. The garage door was open. Bartholomew stated that she does not know Hamilton or either BRODERSON and did not give them permission to possess her property. Bartholomew stated that numerous items were stolen from her vehicle. Det. Simmelink was unable to locate contact information for Nielsen or Huerta. On April 24, 2012, Det. Simmelink was able to locate Robert Broderson in Renton. After being read his Miranda warnings, Broderson was asked if he knew why police might be contacting him. Broderson stated the Miss Washington thing. When asked what he knew about it, Broderson stated that he went to the store with his cousin Jayson BRODERSON and that Jayson purchased a Swiffer Sweeper at either Home Depot or Lowes. Robert stated that it hit the news and he recognized the Crime Stoppers photograph of him and Jayson in the store. Robert stated that was when he learned that Jayson used Miss Washingtons credit card. Robert Broderson denied any involvement with the theft of Miss Washingtons vehicle and said he did not know where the stolen property was. He stated that he felt bad for Miss Washington after hearing about all the things she does to help children. When talking about the specific incident, Robert stated that Jayson BRODERSON picked him up early in the morning around 0530 to 0600 hours. Jayson picked up Robert in the Ford Escape. They went to a Chevron gas station and Jayson put gas in the vehicle. Robert did not see how Jayson paid for the gas. They then went to Lowes where Jayson purchased a Swiffer Sweeper and a door lock. They went back to Jaysons house in Federal Way where he lived with Paula Pries. Robert helped Jayson unload the stuff and Jayson gave him a ride back home. Robert stated that he never used the credit cards, did not select any items to be purchased. Robert recalled Jayson having two firefighter hats and wearing a fire department coat. Robert knew Jayson was not employed but did not ask him where he got the items. Robert stated that he did not know where the items went. Robert also stated that he did not know what happened to the crown or dresses. Robert stated that Jayson stated that he was going to put the Miss Washington stuff in a bag and drop it off at her door but they were afraid the police might be down the street watching the house. Robert admitted doing pills with Jayson and they were using Percocet. Robert then provided a tape-recorded statement and after being advised of his Miranda warnings, Robert stated that he was the shorter subject in the Crime Stoppers bulletin. Prior to the recording, Robert identified the taller subject as Jayson BRODERSON. Det. Simmelink contacted Ms. Henry who stated that she did not know either Robert or Jayson BRODERSON and she did not give them permission to have her property or use her debit/credit cards. NOTE: Additional investigation is pending. Additional charges may be added. I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE OF WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT. DATED: May 3, 2012 PLACE: TACOMA, WA

/s/ ROSIE MARTINELLI ROSIE MARTINELLI, WSB# 25078

DECLARATION FOR DETERMINATION OF PROBABLE CAUSE -5

Office of the Prosecuting Attorney 930 Tacoma Avenue South, Room 946 Tacoma, WA 98402-2171 Main Office (253) 798-7400