CHAD E.

DOTSON (#15834)
Deputy Iron County Attorney
82 North 100 East, Suite 201
P.O. Box 428
Cedar City, Utah 84720
Telephone: (435) 865-5310

IN THE FIFTH JUDICIAL DISTRICT COURT, IN AND FOR IRON COUNTY,

STATE OF UTAH

STATE OF UTAH,

Plaintiff, INFORMATION
VS.
Criminal No.
BRITTANY JUANITA HALL,
DOB: 03/17/1993, Judge

Defendant. OTN No.

Based upon his review and screening of the investigative materials in this matter, the
undersigned complainant, Chad E. Dotson, Deputy Iron County Attorney, under oath, states on
information and belief that the above-named Defendant, BRITTANY JUANITA HALL,
committed the following crimes, to wit:
COUNT 1: CHILD ABUSE, a Second Degree Felony, in violation of Utah
Code Ann. §76-5-109(2)(a), as follows: That the defendant, on or about June
12, 2018, in Iron County, State of Utah, did (a) intentionally or knowingly
inflict serious physical injury upon a child; or (b) having the care or custody
of such child, intentionally or knowingly cause or permit another to inflict
serious physical injury upon a child.
COUNT 2: OBSTRUCTING JUSTICE, a Second Degree Felony, in
violation of Utah Code Ann. §76-8-306(1), as follows: That the defendant, on
or about June 12, 2018, in Iron County, State of Utah, did, with intent to
hinder, delay, or prevent the investigation, apprehension, prosecution,
conviction, or punishment of any person regarding conduct that constituted a
criminal offense, (1)(a) provide any person with a weapon; (b) prevent by
force, intimidation, or deception, any person from performing any act that
might aid in the discovery, apprehension, prosecution, conviction, or
punishment of any person; (c) alter, destroy, conceal, or remove any item or
other thing; (d) make, present, or use any item or thing known by the actor to
 be false; (e) harbor or conceal a person; (f) provide a person with
transportation, disguise, or other means of avoiding discovery or
apprehension; (g) warn any person of impending discovery or apprehension;
(h) warn any person of an order authorizing the interception of wire
communications or of a pending application for an order authorizing the
interception of wire communications; (i) conceal information that was not
privileged and that concerned the offense, after a judge or magistrate had
ordered the actor to provide the information; or (j) provide false information
regarding a suspect, a witness, the conduct constituting an offense, or any
other material aspect of the investigation; and (2) the conduct which
constituted a criminal offense would be a capital felony or first degree felony.
COUNT 3: CHILD ABUSE, a Third Degree Felony, in violation of Utah
Code Ann. §76-5-109(2)(b), as follows: That the defendant, on or about June
10, 2018, in Iron County, State of Utah, did (a) recklessly inflict serious
physical injury upon a child; or (b) having the care or custody of such child,
recklessly cause or permit another to inflict serious physical injury upon a
child.
Probable Cause Statement:
Your affiant, Detective Matt Topham of the Cedar City Police Department, asserts on
information and belief that there is probable cause to believe that Brittany Juanita Hall has
committed the crimes of Child Abuse, a Second-Degree Felony; Obstruction of Justice, a
Second-Degree Felony; and Child Abuse, a Third-Degree Felony; as more specifically set forth
herein.
C.L. was born on December 3, 2015, with no known health problems or conditions.
Brittany Juanita Hall (hereinafter "Hall") is the biological mother of C.L. At all times relevant
to this information, Hall was residing with her child C.L. Hall and her boyfriend Gavin Michael
Haar (hereinafter "Haar") lived together and cared for C.L. during the relevant time frames in
this information. Hall and Haar would live in the homes of different friends or family members
with C.L. in Iron County, Utah.

In the early hours of June 12, 2018, Hall was working the graveyard shift at Lin's
Grocery store. Haar was unemployed and stayed home with C.L. At 00:36:40, Haar sent a text
message to Hall while she was at work. The text message from Haar's cell phone stated "Get
home now. Emergency Chris not breathing" Hall replied, "Okay." About one minute later, at
00:37:59, Haar messaged "Anyone ask about the bruises we got them four wheeling." Then at
00:39:35, Haar messages Hall, "I am calling the cops."

Law Enforcement and paramedics responded to the residence and C.L. was transported to
the Cedar City Hospital. C.L. was pronounced dead at the hospital at 01:49 hours, after
lifesaving efforts were unsuccessful. C.L.'s body was covered with numerous bruises on his
forehead, eyes, ears, mouth, and several circular bruises on the chest and abdomen.
 The Medical Examiner conducted an autopsy and issued findings as to the cause and
manner of death. The Medical Examiner concluded that C.L. died of blunt force injuries to the
abdomen resulting in the mesenteric contusions and lacerations, laceration of the small bowel,
and blood loss resulting in a 200 ml hemoperitoneum. The Medical Examiner determined the
manner of death was homicide.

At the hospital on June 12, 2018, Hall and Haar were asked how C.L. was hurt. Haar
explained that he and C.L. crashed on a four-wheeler on Saturday, June 9, 2018, while camping
near Duck Creek. Haar stated that the family, including Hall, went camping and that he took
C.L. for a ride on the four-wheeler. Haar reported that he was going too fast, lost control, and
rolled the machine. Haar stated he was thrown from the four-wheeler and that when he got up he
found C.L. was pinned under the four-wheeler where the gas tank was on his chest and the
handle bars across his face. Haar reported that he lifted the four-wheeler off of C.L. and that he
and Hall checked him for injuries. They determined C.L. was fine and did not take him to the
doctor. Haar also stated that the next morning on Sunday, June 10, 2018, he took C.L. to the
park to play. Haar stated that C.L. fell off of some playground equipment and hit his face and
hurt his mouth.

Hall also reported that she, Haar, and C.L. went camping Saturday night near Duck
Creek. She reported that it was during this camping trip that she witnessed the four-wheeler
crash while she was following behind in their Bronco. Hall said she ran to help and saw that
C.L. was pinned under the four-wheeler. She said once the four-wheeler was removed C.L. cried
because he was scared but that he did not complain of any pain. There were stark
inconsistencies between Hall's version of events and Haar's version as to the time of day of the
crash, and the details of the camping trip.

During the course of the investigation, your affiant learned that Hall was working at
Lin's Grocery store the night of June 9, 2018, and could not have been on the mountain camping
when she reportedly witnessed the four-wheeler accident. Your affiant also spoke with Codi
Perkins, who was letting Hall, Haar, and C.L. live with her temporarily. Perkins stated that she
worked on Saturday, June 9, from 11:00 to 22:30 and that Hall, Haar, and C.L. were all home
before and after she went to work.

Your affiant confronted Hall about the fact that she was not camping Saturday night.
Hall responded, "OK." Your affiant asked Hall why she told the story about camping and the
four-wheeler accident. Hall replied, "Because that is what he tells me and that's all I have to go
off of." Your affiant then asked Hall whose idea it was to tell the story about the four-wheeler
accident. Hall replied, "It's him if he is telling me. I'm not the one coming up with it; he is
telling me what is going on."

Prior to the events that lead to C.L.'s death, Hall, Haar, and C.L. were living with Jenni
Leader temporarily. Leader is C.L.'s aunt. Leader reported that she had to tell Haar that he was
no longer welcome to live at her home due to his bad temper and the abusive manner in which he
treated both Hall and C.L. Jenni Leader reported that both she and Hall once confronted Haar
about his abusive behavior toward C.L. and that Haar became angry. When Haar was kicked out
of Jenni's home, Hall left with him and took C.L.

Hall reported that she had taken C.L. to the Lake on the Hill in Cedar City, on Sunday,
June 10, 2018. She stated C.L. had a cough for a few days but was otherwise healthy. Hall
stated that at the Lake on the Hill on Sunday, C.L. was playing and having fun. Photos from the
day show C.L. smiling and playing in the sand with his shirt off In the photos from the lake, a
bruise under C.L.'s eye, forehead, and back are visible. However, the bruises on his chest and
abdomen that were present the following day when he was pronounced dead in the hospital were
not present.

Hall reports that on Monday June 11, 2018, C.L. was not feeling well. She stated that she
went to Wal-Mart to get some Tylenol and Pedialite for him. She said C.L. wanted to sleep and
lay in bed most of the day. Additional text messages from Haar's cell phone to Hall were
discovered, approximately 61/2 hours before C.L. was taken to the hospital, at 17:12:01, Haar
messaged Hall, "You need to get home now." Haar then messaged at 17:28:10, "You fucking
went further then you were supposed to. Get the fuck home now. Your done with the truck
never again. I'm fucking livid. And your son is about to get an ass beating."

Hall reports that she left for work at Lin's Grocery Store at 11:45 PM Monday night.
Haar was left to care for C.L. at this time. It was approximately 45 minutes later that Haar
messaged Hall that C.L. was not breathing.

Based on the foregoing, and the fact that C.L. was under the custody and control of
Brittany Hall and Gavin Haar, and Hall had knowledge of abuse taking place, and gave false
information about a camping trip and four-wheeler accident after C.L.'s death, your affiant
asserts there is probable cause to believe that Defendant Brittany Hall has committed the
offenses of Child Abuse, a Second-Degree Felony; Obstructing Justice, a Second-Degree
Felony; and Child Abuse, a Third-Degree Felony; and a warrant for her arrest is respectfully
requested.

DATED this ell day of October, 2018.

DETECTIVE MATT TOPHAM

Cedar City Police Department

This Information is based on evidence provided by Detective Matt Topham of the Cedar

City Police Department.

 DATED this 1° day of October, 2018.

By
CHAD E. DOTSON
Deputy Iron County Attorney

SUBSCRIBED AND SWORN to before me on this 10' day of October, 2018, by

Chad E. Dotson.

AMY ROBINSON
~iU TARY P HUG -STitTE
My Comm. E.,:p 06/01 ,'7020
Commission 4 66:)055
NOTi PUBLIC
Residing in Iron County, State of Utah