CASE NUMBER: 79D02-2308-MR-000008 FILED: 8/25/2023

STATE OF INDIANA ) IN THE TIPPECANOE COURT

) SS:
COUNTY OF TIPPECANOE )

STATE OF INDIANA

VS.
CAUSE NO: 79
MONTRELL DIONTE JOLLY
825 N 13th St #A
Lafayette, IN 47904
DOB: 12/20/1989
OLN:

AFFIDAVIT OF PROBABLE CAUSE

Comes now Affiant, and being duly sworn upon oath, deposes and states that Affiant is a law enforcement officer with the
Lafayette Police Department in Tippecanoe County, State of Indiana, and in said capacity was involved in an investigation
regarding a suspicious incident involving a four-year-old child. Affiant is aware this investigation began with a call at
approximately 4:27pm on July 28, 2023, regarding a child who was having a seizure. Affiant is aware personnel with the
Lafayette Fire Department (LFD) and Tippecanoe Emergency Ambulance Services (TEAS) were dispatched to 825 North 13th
Street Apartment A and upon arrival located a four-year-old who was unconscious. The four-year-old was identified as Ke’andre
Jolly. Affiant is aware LFD and TEAS personnel also located an adult female who was identified as Jasontinae Jolly, an adult male
who was identified as Montrell Jolly, and an infant child in the residence with Ke’andre. Affiant is aware Jasontinae is Ke’andre’s
mother. Affiant is further aware Montrell is Jasontinae’s cousin.

Affiant is aware Paul Reeder, a paramedic with TEAS, observed Ke’andre on the floor of the residence soaking wet. Reeder
further observed a smoky haze inside of the residence and what he believed to be the odor of marijuana. Reeder assessed Ke’andre
for injury and medical issues and medics removed all clothing from Ke’andre’s person. Reeder observed no visible signs of injury
on Ke’andre. Reeder further observed the child was unresponsive and observed Ke’andre’s pupils and observed one pupil appeared
constricted, and one pupil appeared blown, which Affiant is aware is indicative of a head injury.

Affiant is aware Ke’andre was transported to St. Elizabeth East for further treatment and ultimately airlifted to Riley
Children’s Hospital in Indianapolis, Indiana due to the severity of Ke’andre’s injuries. Affiant is aware the Lafayette Police
Department was contacted at approximately 5:43pm on July 28, 2023, by staff at St. Elizabeth East as medical personnel suspected
Ke’andre suffered non-accidental trauma. Affiant is aware Ke’andre did not regain consciousness from the point of arrival at
residence of emergency personnel until the time Ke’andre was pronounced deceased on August 1, 2023.

Affiant conducted a formal interview of Montrell Jolly, who advised he was disciplining Ke’andre by instructing Ke’andre to
do wall sits because Ke’andre had put his shoes on the incorrect feet. Montrell described the wall sits as having Ke’andre sit with
Ke’andre’s back against the wall in a squat position for a period of time while extending Ke’andre’s arms out in front of him.
Montrell advised Ke’andre does wall sits daily. Montrell expressed frustration with Ke’andre’s dependence on his mother. Montrell
advised Ke’andre was crying during the wall sits and was not doing them correctly, so Montrell moved Ke’andre to Montrell’s
bedroom to do the wall-sits there so Montrell could supervise the wall sits better. Montrell advised he let Ke’andre leave the wall
to use the bathroom, but Montrell got upset again because Ke’andre was going to sit on the toilet to urinate instead of standing
“like a regular boy.” Montrell made Ke’andre stand to use the restroom and then return to the wall to do wall sits. Montrell
described Ke’andre as continuing to cry and yell that he would put his shoes on the right feet. Montrell said he let Ke’andre
attempt to put his shoes on correctly, but he could not, so Montrell made Ke’andre do wall sits again. Montrell advised Ke’andre
continued to whine but then suddenly stopped making any noise, so Montrell looked at Ke’andre and observed he was on the
ground near the corner of the door frame with blood coming out of his mouth. Montrell advised Ke’andre would not wake up so
Montrell carried Ke’andre to the bathroom, put him in the bathtub, and showered cold water on Ke’andre in an attempt to wake him
up. Montrell advised Ke’andre would not wake up in the bathroom, so he removed Ke’andre from the bathtub, believed Ke’andre
to be experiencing a medical issue, and claimed he called 911 at that time. Affiant is aware the 911 call was made at approximately
4:27pm, so Affiant believes there was at least approximately a twenty-minute delay in either Montrell or Jasontinae calling 911.

Affiant also spoke with Jasontinae regarding the incident. Jasontinae advised she was aware Montrell was disciplining
Ke’andre because Ke’andre put his shoes on the incorrect feet. Jasontinae advised she observed Ke’andre against the wall in
Montrell’s bedroom performing a wall-sit when she returned from the grocery store and heard Ke’andre crying and saying he
would put his shoes on the right feet. Jasontinae advised she heard Montrell tell Ke’andre that Ke’andre needs to learn his ABC’s,
123’s, and how to put his shoes on the correct feet. Jasontinae claimed she asked Montrell about Ke’andre still doing wall sits, and
Montrell claimed Ke’andre was off the wall but put his shoes on the wrong feet again, so he put Ke’andre back to do more wall
sits. Jasontinae claimed she was then in and out of the house unloading the groceries, but when Jasontinae returned to the
residence, she observed Montrell placing Ke’andre in the bathtub putting cold water from the shower onto Ke’andre. Montrell
CASE NUMBER: 79D02-2308-MR-000008 FILED: 8/25/2023
advised Jasontinae that Ke’andre was having a seizure. Montrell then removed Ke’andre from the shower and moved him to the
living room floor. Jasontinae advised Montrell then called 911. Affiant is aware a message was sent from Jasontinae’s cellular
device to Ke’andre’s father, Andre Harris, at 4:07 pm saying Ke’andre had a seizure. Affiant is further aware a telephone call was
made from Jasontinae’s cellular device to Jasontinae’s mother at 4:12pm.

Affiant is aware officers searched the residence where Ke’andre was originally located and observed three small blunts
containing suspected marijuana. Officers weighed the suspected marijuana, and it had an approximate weight of 0.42 grams.
Officers observed blood on the counter and sink of the bathroom. Officers also observed damage to the outside of the bathroom
door. In the southwest bedroom of the residence, officers observed blood staining on the wall and damage to the outside of the
door. In the northwest bedroom, officers located two extension cords, a nylon belt, and a screwdriver on the floor. Officers located
a pair of black and yellow sandals on the floor near the south wall, multiple bloodstains on the south wall, and a bloodstain on the
west wall.

Affiant is aware Ke’andre received continuous treatment since July 28, 2023 when first responders responded to 825 North
13th Apartment A. Further, Affiant is aware Ke’andre began to display visible injuries at St. Elizabeth hospital personnel. Affiant
is aware officers and medical staff observed blood around Ke’andre’s mouth, a scratch on his neck, and significant bruising
throughout his arms, back, and buttocks. Affiant has reviewed medical records provided by Dr. Holloran and Dr. Leland of Riley’s
Children Hospital. Affiant is aware Ke’andre was found to have the following injuries: patterned bruising on his scalp; subdural
and subarachnoid hemorrhage; severe, diffuse hypoxic injury affecting the majority of his brain; torn upper lip frenulum with
bruising of the surrounding mucosa; bruising on arms; suspected laceration/contusion of the mid portion of the pancreas; possible
bowel contusion of the ascending colon; several possible rib fractures’ and patterned bruising to the back and diffuse bruising over
the right buttock. Affiant is further aware Dr. Holloran’s expert opinion as a child abuse pediatrician is that there is no underlying
medical condition that would cause Ke’andre’s pattern of injury. Further, Dr. Holloran’s findings include that Ke’andre’s head
injury would have been immediately symptomatic and that Ke’andre would not have appeared normal again after sustaining this
injury. Affiant is further aware Ke’andre was pronounced deceased at approximately 11:30am on August 1, 2023. On August 2,
2023, an autopsy of Ke’andre’s person was conducted and the preliminary determination of manner of death was homicide and the
cause of death was blunt force injuries of the head. Affiant is aware the additional anatomic findings of the autopsy include clinical
bilateral retinal hemorrhages, diffuse subgaleal hemorrhage, laceration to the lip, and abrasion to the jaw. Further autopsy results
are still pending.

Affiant is familiar with prior criminal history records for Montrell Jolly. Said records show Jolly was convicted on August 10,
2022, of Possession of Methamphetamine, a Level 6 Felony, under 79D05-2204-F6-318, which was committed on or about March
15, 2022. Jolly was also convicted on February 6, 2019, of Possession of a Synthetic Drug, a Level 6 Felony, under 79D04-1804-
F6-518, which was committed on or about March 23, 2018. Jolly was also convicted on or about February 22, 2012, of Assisting a
Criminal, a Class C Felony, under 45G04-1101-MR-1, which was committed on or about January 5, 2009. Affiant believes said
records to be reliable and credible as they are public records kept in the ordinary course of business.

Affiant believes Paul Reeder to be reliable and credible as he spoke from personal knowledge in the course of his duties as an
EMS emergency services provider.

Affiant believes Montrell Jolly and Jasontinae to be reliable and credible only in part, insofar as each admitted being the sole
caregivers for Ke’andre Jolly, and to the extent the information they provided was corroborated by police investigation.

Affiant believes Dr. Swiatkowski to be reliable and credible as he was acting in his professional capacity as a forensic
pathologist licensed in the State of Indiana.

Affiant believes Dr. Holloran and Dr. Leland to be reliable and credible as each was acting in their professional capacity as
medical doctors licensed in the State of Indiana.

Affiant believes Lieutenants Amor and Long, Sergeant Zambon, Detectives Carlisle, Hesher, Ransom, Savage, Schutter, and
Sinks, and Officers Ceballos, Hewitt, Maxwell, Santerre, and Smith to be reliable and credible as they were acting in their capacity
as law enforcement officers in Tippecanoe County, State of Indiana.

Affiant believes Forensic Investigators Huff, Feterick, and Storm-Justice to be reliable and credible as they have no known
reason to lie and were acting in their course of employment with the Lafayette Police Department.

Affiant believes records obtained from the Tippecanoe County Coroner’s Office, Riley Children’s Hospital, St. Elizabeth East,
Tippecanoe County Emergency Ambulance Services, and Indiana Department of Child Services to be reliable and credible as they
are regularly relied upon by law enforcement officers and are maintained and stored in the ordinary course of business.

Further Affiant saith not.

Affiant does swear or affirm, under penalties of perjury as specified under Indiana Code 35-44.1-2-1, that the foregoing
representations are true to the best of Affiant’s knowledge and belief.
CASE NUMBER: 79D02-2308-MR-000008 FILED: 8/25/2023
Dated:_August 25th________, 2023 Signed: _s/ Detective Sgt. Donna Rector_________________________