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| YAVAPAI COUNTY ATTORNEY’S OFFICE "2S BM 02 Firm No. 00048700 | Susan L. Bazer, SBN 013525 S Deputy County Attorney 255 East Gurley Street -y. KMADDENT Prescott, AZ 86301 (928) 771-3344 yeao@yavapai.us Attorneys for STATE OF ARIZONA IN THE SUPERIOR COURT OF THE STATE OF ARIZONA. IN AND FOR THE COUNTY OF YAVAPAI STATE OF ARIZONA, | CAUSE NO. P1300CR201600966 Plaintiff, MOTION IN LIMINE REGARDING PASTOR LINBLAD vs, | Assigned to Hon. Bradly Astrowsky THOMAS JONATHAN CHANTRY, | | | | | Defendant. | | The State of Arizona, by and through Sheila Polk, Yavapai County Attomey, and her deputy undersigned, submits the following motion in limine regarding potential testimony of Pastor Don Linblad in order for this Court to make pretrial rulings about same if necessary, Pertinent Background Facts Because this Court is already fairly familiar with the facts of this case, the State will only address the primary facts most pertinent to defense witness Don Linblad’s testimony for purposes of this motion, The following background facts are intended to provide the Court with some of the information which led up to Don Linblad’s role in the case and the documents he provided to defense counsel which this Court may be asked to make rulings on prior to trial Defendant became a pastor at Miller Valley Baptist Church in June of 1995. Shortly woe we ee ae 10 12 13 14 15 16 7 18 19 20 21 22 23 24 thereafter, he began “tutoring” QIN who was 11 years old at the time. As the Court knows when the investigation began in 2015 reported multiple incidents of physical abuse, as well as molestation to the police. However, back in 1995, i only | told his parents of the physical abuse (though he alluded to perverted aspects of same) and that it was bare-bottomed, INI did not report the incidents right away, but once he did, QED parents, QD and QED immediately reported the conduct to the Elders of Miller Valley Baptist Church (MVBC). The Defendant was subsequently confronted and “counseled” about his conduct with QJM and the situation was | “handled” within the church. Shortly after that, QJ and his family moved to Phoenix. | In 1998, the Defendant began tutoring QD and began engaging in the be conduct as that which he had with QB two years earlier, to include molestation. In 1999, while still tutoring QIN the Defendant also began tutoring and | babysitting for QD and QUEEN and would often have all three children in his custody at the same time. According to all three children who were between the ages of 8- 10 years old at the time, the Defendant would frequently severely punish them for minor incidents. He would usually make the children pick their instrument for punishment, which | included a belt, a boat oar, a paddle, and a thick board. The children were terrified of the | Defendant and he frequently used religion to keep them from disclosing his acts. | In late July of 1999, after a very severe “spanking” episode and Qi finally | reported to their parents some, but not all, of what the Defendant had done to them. and MD immediately confronted the Defendant who, just as he had done wit a | 2nd @JNENP downplayed what had happened and told the parents it was nothing more than spankings for disciplinary purposes. The Defendant promised to never “spank” the children again, For reasons they regret now, the (MM did not report the matter to the | I ee fo) Oo 5 o 10 MW 12 13 14 15 16 7 18 19 20 21 22 church at that time, but subsequently did when the long-term abuse of SND was finally revealed. In 2000, after discovering severe bruising to her son's buttocks and upper thighs, (GERD !carned from her son that they were from the Defendant beating him with a thick board. The bruises were the size and shape of a two-by-four and were so severe that @liiBwas unable to sit down and was barely able to walk. He told his mother the beatings had been occurring frequently for quite some time, and were almost always bare~ bottomed. When asked at that time whether he had been touched on his privates paused, looked down and eventually said no, but had become so upset by this point that his, mother did not pursue the questioning further later contacted her niece, > {GBB and told her about what she had learned and reports were subsequently made to the | | MVBC about same. The Elders immediately confronted the Defendant about the allegation, and still not knowing the extent or severity of same, or that they would soon learn of similar abuse to aD: Elders suggested that the Defendant needed to apologize to Jand his mother for what he had done. Elder Eric Owens went with Defendant to the {GED homme the next day where Defendant half-heartedly apologized to QD for ‘disciplining him” and said he thought he was doing what was best for him.' The next day following the visit, the Defendant left the State in the middle of the night without notifying anyone, He later sent his sister to pack up his belongings. It was after this, that the Elders learned of the additional allegations of abuse of the {IM children and reached out to their association, the Association of Reformed Baptist Churches of America (*ARBCA”) and ‘The family would later tell police they did not feel like the Defendant was being truthful or remorseful and that he never admitted to what he had actually done tA. 3.