SIM GILL, Bar No. 6389 District Attorney for Salt Lake County R, JOSH PLAYER, Bar No. 7768 STEVEN J. GREEN, Bar No, 11895 JARED W. RASBAND, Bat No, 12633 Deputy District Attomey 8080 $ Redwood Road, Ste. 1100 ‘West Jordan, UT 84088 Tetephone: (385) 468-7550 IN THE THIRD DISTRICT COURT, WEST JORDAN DEPARTMENT IN AND FOR THE COUNTY OF SALT LAKE, STATE OF UTAH ‘THE STATE OF UTAH Screened by: R. JOSH PLAYER STEVEN J. GREEN, JARED RASBAND Plaintiff, Assigned to: R. JOSH PLAYER vs. INFORMATION KAIN BLACKWING DAO # 17003641 DOB: 03/21/1969, AKA: Initial Appearance: Beaver County Jail D.L# BAIL: NO BAIL, OTN so# ‘Warrant/Release: PRISON Booking# Case No. Defendant. ‘The undersigned Detective R. Golding - WEST JORDAN POLICE DEPARTMENT, Agency Case No. 14H013033, upon a written declaration states on information and belief that the defendant, KAIN BLACKWING , committed the crime(s) of: COUNT 1 SOLICITATION FOR AGGRAVATED MURDER, 76-5-203 UCA, First Degree Felony, as follows: That on, about, or between July 07, 2014 and September 19, 2014, in Salt Lake County, State of Utah, the defendant, a party to the offense, did criminally solicit another to intentionally ot knowingly cause the death of another under any of the following circumstances: (2) the homicide was to be committed incident to one act, scheme, or course of conduct, or criminal episode during which two or more persons were to be killed, or during which the actor ‘was to attempt to Kill one or more persons in addition to the victim who was to be killed;STATE vs KAIN BLACKWING DAO # 17003641 Page 2 (b) the actor was to knowingly create a great risk of death to @ person other than the vietim and the actor; (©) the homicide was to be committed incident to one act, scheme, or course of conduct, or criminal episode during which the actor was to commit or attempt to commit aggravated burglary, burglary, aggravated arson, or arson; (@_ the homicide was to be committed for the purpose of (1) preventing a witness from testifying, (2) preventing a person from providing evidence or participating in any legal proceedings, or (3) disrupting or hindering any lawful governmental function or enforcement of laws; and/or (©) the homicide was to be committed by means of the administration of a poison or of any lethal substance or of any substance administered in a lethal amount, dosage, or quantity. COUNT 2 SOLICITATION FOR AGGRAVATED MURDER, 76-5-203 UCA, First Degree Felony, as follows: That on, about, or between July 07, 2014 and September 19, 2014, in Salt Lake County, State of Utah, the defendant, a party to the offense, did criminally solicit another to intentionally or knowingly cause the death of another under any of the following circumstances: (@) the homicide was to be committed incident to one act, scheme, or course of conduct, or criminal episode during which two or more persons were to be killed, or during which the actor ‘was to attempt to kill one ot more persons in addition to the victim who was to be killed; (b) the actor was to knowingly create a great risk of death to a person other than the victim and the actor; (©) the homicide was to be committed incident to one act, scheme, or course of conduct, or criminal episode during which the actor was to commit or attempt to commit aggravated burglary, burglary, aggravated arson, or arson; @ the homicide was to be committed for the purpose of (1) preventing a witness from testifying, (2) preventing a person from providing evidence or participating in any legal proceedings, or (3) disrupting or hindering any lawful governmental function or enforcement of laws; and/or (©) the homicide was to be committed by means of the administration of a poison or of any lethal substance or of any substance administered in a lethal amount, dosage, or quantity, COUNT 3 SOLICITATION FOR AGGRAVATED MURDER, 76-5-203 UCA, First Degree Felony, as follows: That on, about, or between July 07, 2014 and September 19, 2014, in Salt Lake County, State of Utah, the defendant, a party to the offense, did criminally solicit another to intentionally or knowingly cause the death of another under any of the following cireumstances: (@) the homicide was to be committed incident to one act, scheme, or course of conduct, or criminal episode during which two or more persons were to be killed, or during which the actor ‘was to attempt to kill one or more persons in addition to the victim who was to be killed; (©) the actor was to knowingly create a great risk of death to a person other than the victim and the actor;STATE vs KAIN BLACKWING DAO # 17003641 Page 3 (©) the homicide was to be committed incident to one act, scheme, or course of conduct, or criminal episode during which the actor was to commit or attempt to commit aggravated burglary, burglary, aggravated arson, or arson; (@_ the homicide was to be committed for the purpose of (1) preventing a witness from testifying, (2) preventing @ person from providing evidence or participating in any legal proceedings, or (3) disrupting or hindering any lawful governmental function or enforcement of laws; and/or (©) the homicide was to be committed by means of the administration of a poison or of any lethal substance or of any substance administered in a lethal amount, dosage, or quantity. COUNT 4 CONSPIRACY TO COMMIT AGGRAVATED MURDER, 76-5-203 UCA, First Degree Felony, as follows: That on, ebout, or between July 07, 2014 and September 19, 2014, in Salt Lake County, State of Utah, the defendant, a party to the offense, did conspire to intentionally or knowingly cause the death of another under any of the following circumstances: (a) the homicide was to be committed incident to one act, scheme, or course of conduct, or criminal episode during which two or more persons were to be killed, or during which the actor ‘was to attempt to kill one or more persons in addition to the vietim who was to be killed; (b) the actor was to knowingly create a great risk of death to a person other than the victim and the actor; (©) the homicide was to be committed incident to one act, scheme, or course of conduct, or criminal episode during which the actor was to commit or attempt to commit aggravated burglary, burglary, aggravated arson, of arson; (a) the homicide was to be committed for the purpose of (1) preventing a witness from testifying, (2) preventing a person from providing evidence or participating in any legal proceedings, or (3) disrupting or hindering any lawful governmental function or enforcement of Jaws; and/or (©) the homicide wes to be committed by means of the administration of a poison or of any lethal substance or of any substance administered in a lethal amount, dosage, or quantity. COUNT 5 ATTEMPTED AGGRAVATED MURDER, 76-5-203 UCA, First Degree Felony, as follows: ‘That on, about, or between July 07, 2014 and September 19, 2014, the defendant did attempt to intentionally cause the death of another under any of the following circumstances; (@) the homicide was to be committed incident to one act, scheme, or course of conduct, ot criminal episode during which two or more persons were to be killed, or during which the actor ‘was to attempt to kill one or more persons in addition to the victim who was to be killed; ()) the actor was to knowingly ereate a great risk of death to a person other than the victim and the actor; (c) the homicide was to be committed incident to one act, scheme, or course of conduct, or criminal episode during which the actor wes to commit or atlempt to commit aggravated burglary, burglary, aggravated arson, or arson;STATE vs KAIN BLACKWING DAO # 17003641 Page 4 (@ the homicide was to be committed for the purpose of (1) preventing a witness from testifying, (2) preventing a person from providing evidence or participating in any legal proceedings, or (3) disrupting or hindering any lawful governmental function or enforcement of laws; and/or (©) the homicide was to be committed by means of the administration of a poison or of any lethal substance or of any substance administered in a lethal amount, dosage, or quantity. THIS INFORMATION IS BASED ON EVIDENCE OBTAINED FROM THE FOLLOWING WITNESSES: Detective R. Golding, C.G., E.G,, R.B., KB, and J.B. DECLARATION OF PROBABLE CAUSE: ‘Your declarant bases this information upon the followin, Based on information from Detective Golding’s investigation, conversations from jail phone calls, and making reasonable inferences to events known to have occurred. Kain Blackwing, and Theresa Baker, parties to the offense, did conspire, solicit, and attempt to commit aggravated murder. On July 7, 2014 Kain Blackwing (“Kain”), was arrested for the Rape of C.G., a 14 year old girl, On September 19, 2014, at approximately 03:54 Raven Blackwing (“Raven”), and Tylynn Southwick (“Tylynn”) were arrested for Aggravated Burglary, Retaliation Against a Witness, and Aggravated Assault, when they broke into 9349 S. Copper Lane, the house where C.G, Elizabeth Griogo (“Elizabeth”), and Jeromy Beck (“Jeremy”) wore residents, At the time of arrest, Raven and Tylynn were dressed in black clothing and black gloves, Furthermore, they had in their possession syringes with fake heroin, an arm tourniquet, folding ‘knife, wooden matches, Plastic jar with formalin, saran wrap, and a Sabre taser (stun gun). In addition, located in the car they had used was a backpack containing 2 glass cutting tools, small black pry bar, and medical supplies. Also, there was two cell phones end a GPS,STATE vs KAIN BLACKWING DAO it 17003641 Page 5 According to the statement of Tylyna to Detective Golding, Kain told Theresa, Raven and Tylyna in person that he wanted Raven and Tylynn to break into the home of C.G. and murder C.G., Elizabeth, and Jeremy, because he was convinced that if C.G were dead, the authorities would have to release him, Over the course of eleven weeks, Kain developed the plan where Raven and ‘Tyiynn were to break into the residence and suffocate C.G, with plastic wrap, and mufile the noise with a pillow. To ensure C.G."s death, Tylynn was to acquire formalin (a chloroform type chemical), heroin, and syringes so that Raven could incapacitate Elizabeth and Jeremy using the formalin, and then inject Elizabeth and Jeremy, who had a history of drug use, with a lethal dose of heroin, Phone calls collected by Detective Golding established that Kain and the women always spoke in code on the phone wien discussing the break in and murders. Kain would refer to the surveillance for the break-in/murders as “playing a video game.” See phone call where Raven tells Kain that she is playing her “video game” every night. There are at least 10 other references to the game, Tylynn also discussed watching the house for several weeks before they broke in. Jeremy reported to police that he observed a suspicious incident about two weeks prior to the break in, Jeremy reported that he went out to his garage around 0400 hours in the morning to smoke a cigarette. Jeremy observed a vehicle parked on the street two houses down that didn’t belong to the neighbor that it was parked in front of. Jeremy walked towards the vehicle and it sped off, As the vehicle passed by him, he recognized the driver as Tylynn. Kain would refer to Jeremy as the “Juggemaut” or the “Boss” in the game, Elizabeth as one of the “guards”, and C.G. as the “target.” During one phone call, Kain tells Raven to take out the Juggemaut to male taking out everyone easier. During another call, Kain asks Raven if she is having issues with the boss. Raven states that the problem isn’t the “boss” it’s getting in, According to Tylynn, Raven was to smother C.G, by wrapping her head in plastic wrap, and then use a pillow to mufile the sound, ‘Theresa participated in planning meetings, communicating information, and taking other ‘measures in support of the plan to kill C.G., Blizabeth, and Jeremy. In fact, during one phone call, Theresa told Kain that she would refocus the women’s attention on taking care of the “main business.” The “main business” was the code phrase used to reference the plan to kill C.G., Elizabeth, and Jeremy.STATE vs KAIN BLACKWING DAO # 17003641 Page 6 REQUEST FOR ISSUANCE OF A WARRANT: ‘The State hereby request that the Court issue a No Bail Warrant of Arrest in the Above- entitled case for the following reason(s). ‘The Defendant is currently in Prison. Pursuant to Utah Code Annotated § 78B-5-705 (2008) I declare under criminal penalty of the State of Utah that the foregoing is true and correct to the best of my belief and knowledge. Brecuted on;_ Od 1-17] Detective R. wall Y Deelarant Authorized for presentment and filing SIM GILL, District Attorney RuP4LO / DAO #1703641IN THE THIRD DISTRICT COURT OF THE STATE OF UTAH IN AND FOR THE COUNTY OF SALT LAKE. ‘THE STATE OF UTAH, WARRANT OF ARREST Plaintift ve Case No. KAIN BLACKWING DOB: 03/21/1969 Beaver County Jail Sst Booking# Defendant ‘THE STATE OF UTAH; ‘To any Peace Officer in the State of Utah, Greetings: An Information, based upon a written declaration having been declared by Detective R. Golding — ‘WEST JORDAN POLICE DEPARTMENT, Agency Case No. 14H013033 and it appears from the Information or Declaration filed with the Information, that there is probable cause to believe the public offense(s) off SOLICITED MURDER, First Degree Felony, CONSPIRED MURDER, First Degree Felony, ATTEMPTED MURDER, First Degree Felony, has been committed, and that KAIN BLACKWING has committed them. FURTHER, the Cout finds, based upon information provided in the Declaration of Probable ‘Cause and the State’s Request for Issuance of a Werrant, that a warrant is necessary in this ease to: prevent risk of injury to a person or property; and/or secure the appearance of the accused; and/or ‘protect the public safety and welfare of the community or an individual, YOU ARE THEREFORE COMMANDED to artest the above named defendant forthwith and bring the defendant before this Court, or before the nearest or most accessible magistrate for setting bail. Ifthe defendant has fled justice, you shell pursue the defendant into any other county ofthis state and there artes the defendant. The Cout finds reasonable grounds to believe defendant will not appear upon ‘a summons. Bail is set in the amount of NO BAIL, ‘This Warrant may be served day or night.