SIM GILL, Bar No. 6389 District Attomey for Salt Lake County ANNA L ROSSI ANDERSON, Bar No. 14099 Deputy District Attorney 35 East 500 South Salt Lake City, UT 84111 ‘Telephone: 385-468-7600 IN THE THIRD DISTRICT COURT, SALT LAKE DEPARTMENT IN AND FOR THE COUNTY OF SALT LAKE, STATE OF UTAH THE STATE OF UTAH Screened by: ANNA L ROSSI ANDERSON Assigned to: SPECIAL VICTIM Plaintiff, INFORMATION vs ALLISON BRIMHALL DAO # 21020427 DOB: 07/12/1982 10 Kingman Court NO BAIL Sacramento, CA 95835 SID# UNKNOWN Warrant/Release: IN JAIL: SAN DIEGO, CALIFORNIA Defendant. Case No. ‘The undersigned Wendy Barr - South Jordan Police Department, Agency Case No, sj21-36910, upon a written declaration states on information and belief that the defendant, ALLISON BRIMHALL, committed the crime(s) of: COUNT CHILD KIDNAPPING, 76-5-301.1 UCA, a First Degree Felony, as follows: That on or about December 11, 2021, in Salt Lake County, State of Utah, the defendant did intentionally or knowingly, without authority of law, by any means and in any manner, seize, confine, detain, or transport a child under the age of 14 without the consent of the victim's parent or guardian, or the consent of a person acting in loco parentis, To wit: ASB.STATE vs ALLISON BRIMHALL DAO # 21020427 Page 2 COUNT 2 CHILD KIDNAPPING, 76-5-301.1 UCA, a First Degree Felony, as follows: ‘That on or about December 11, 2021, in Salt Lake County, State of Utah, the defendant did intentionally or knowingly, without authority of law, by any means and in any manner, scize, confine, detain, or transport a child under the age of 14 without the consent of the victim's parent or guardian, or the consent of a person acting in loco parentis, To wit: AMB. ‘COUNT 3 CHILD KIDNAPPING, 76-5-301.1 UCA, a First Degree Felony, as follows: That on or about December 11, 2021, in Salt Lake County, State of Utah, the defendant did intentionally or knowingly, without authority of law, by any means and in any manner, seize, confine, detain, or transport a child under the age of 14 without the consent of the victim's parent or guardian, or the consent of a person acting in loco parentis, To wit: BB. COUNT 4 CHILD KIDNAPPING, 76-5-301.1 UCA, a First Degree Felony, as follows: That on or about December 11, 2021, in Salt Lake County, State of Utah, the defendant did intentionally or knowingly, without authority of law, by any means and in any manner, seize, confine, detain, or transport a child under the age of 14 without the consent of the victim's parent or guardian, or the ‘consent of a person acting in loco parentis. To wit: HB. THIS INFORMATION IS BASED ON EVIDENCE OBTAINED FROM THE FOLLOWING WITNESSES: Wendy Barr, K. B., H. B., B. B., A. B., A. B., Jonathan Campbell, Sean Phillips, Brett ‘Talbot and Nathan Thompson. DECLARATION OF PROBABLE CAUSE: ‘Your affiant bases probable cause on information and evidence collected by South Jordan Police Department, Case No. $J2021-36910 and the following: The statement of Claudia Santana, caseworker with the Division of Child and Family Services, that on June 28, 2021, Salt Lake County, in the Third District Juvenile Court, case numbers 11197459, 1197457, 1197458, and 1197456, 9-year-old A.S.B., 9-year-old A.M.B., 11- year-old B.B, and 12-year-old H.B., were taken into temporary custody of the division andSTATE vs ALLISON BRIMHALL DAO # 21020427 Page 3 placed with their father, K.B,, on a trial basis to determine official custody. The girls’ mother, ALLISON BRIMHALL, was granted supervised visitation with the girls. Ms, Santana stated that BRIMHALL has made dangerous comments in the past such as, “If I can’t have my girls, I will drive off. cliff with them in the car.” The statement of K.B. that on December 11, 2021, in Salt Lake County, he heard the tv on downstairs and heard his daughters, A.S.B, A.M.B, B.B. and H.B, talking about 9:00 am. K.B. stated that he was not fecling well, so he fell back to sleep and woke when he heard a knock on the door about 11:45 am. K.B. did not hear his daughters yell that someone was at the door. K.B. answered the door and it was a neighbor dropping off Christmas gifts for his daughters. K.B. stated that his daughters were not in the house, he checked with neighbors, the park and around the house, but could not locate them, K.B. noted that winter coats and shoes were still in the house, K.B, stated that he saw bare footprints in the snow, walking away from the house. K.B. believed that his ex-wife, BRIMALL, had taken the girls to California. ‘The statement of South Jordan Police Detective Houston that he learned that BRIMHALL was in California on December 7, 2021 and had told a friend she was going to Utah for some dental work. Records indicate that BRIMHALL rented a white Toyota Tacoma, A ping was done on BRIMHALL's phone, and it showed BRIMHALL was in San Diego California. An amber alert was issued for the girls. ‘The statement of South Jordan Police Detective J, Campbell that he was contacted by Sgt. Bainbridge with San Diego Police Department that on December 12, 2021, BRIMHALL and the girls were located in San Diego and BRIMHALL was taken into custody. MOTION FOR NO BAIL HOLD: Pursuant to Utah Code 77-20-201(1) the State requests that Defendant be held without bail until further notice in this matter on the following grounds: ‘The defendant is charged four First-Degree Felonies and based upon the above probable cause statement, there is substantial evidence supporting the charges and clear and convincing evidence that the defendant would constitute a substantial danger to any other individual or to the community or is likely to flee the jurisdiction of the court, if released on bail, During her investigation, Detective Barr learned that the minor children were taken into DCFS custody, and the children were temporarily placed with their father until a more permanent arrangement could be determined. During this time, the defendant was granted supervised visitation with the children. The children’s father woke to find the children missing. Detectives leamed that the defendant rented a vehicle and traveled to Utah and was located in San Diego California with the 4 children, The father noted that the children left the house without shoes and coats,STATE vs ALLISON BRIMHALL DAO # 21020427 Page 4 DCFS informed Detectives that the defendant had made threats that if she couldn’t have her children, then no one could, and she would drive off a cliff with the children in the car. DCFS has serious concerns about the mental stability of the defendant. ‘The defendant is a danger to the community, the children, and should be held without bail. to Utah Code Annotated § 78B-18a-106 (2018) I declare under criminal penalty under the law of Utah that the foregoing is true and correct. Signed on the 6 day of, Denke 1, in Salt Lake County, Utah LAM Wendy Barr Declarant Authorized for presentment and filing SIM GILL, District Attorney 13th fay of December, 2021 MM/ AN/DAO # 21020427STATE vs ALLISON BRIMHALL DAO # 21020427 Page 1 OTHER PENDING CASES FOR THE DEFENDANT. Court Court Case #f ‘Trial Judge DAQ#