PROBABLE CAUSE AFFIDAVIT

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THE STATE OF TEXAS) Date 12/20/2019 Case No. 19-1 21 035

COUNTY OF WICHITA) Time 2029 Booking No. M Q SOLO ’ZO
I, C. LaPlante #578 , do solemnly swear that I have good reason to
believe and do believe, that Migul Juliana Matthew , on or about the
20 day of DECEMBER , 2019 , unlawfully committed the offense(s) of
PC 49.08 Intoxication Manslaughter F/2 , such belief being based upon
the following facts, to wit:
On 12.20.2019, at approximately 1327 hrs, officers were dispatched to the 5000 blk of Henry S Grace,
In reference to a roll-over accident with multiple people being ejected.

Upon arrival, ofcers who were already on scene checked on four children and two adults. All had
minor physical injuries. Ofcers stated when they arrived on the scene, there was one child, four
years of age, deceased. Multiple ofcers, deputies, reghters, and bystanders who helped with the
children, stated that (OF) Migel Matthew, who was identied as the driver of the vehicle, had alcohol
emitting from her person. In the debris eld from the accident, there were multiple open and half
empty 2502 aluminum alcoholic beverages in cans and bottles along with liquor bottles. I, Ofcer
LaPlante #578, also saw one closed 2502 Natural Light can in the front passenger seat of the wrecked
vehicle. The vehicle was emitting a strong odor of alcohol as well.

All passengers and Matthew, minus the deceased, were transported to URl-lCS for medical treatment.
While at the hospital, the front passenger stated to ofcers that Matthew had been consuming
alcoholic beverages prior to operating the vehicle. Matthew was identied as the driver of the vehicle
by two of the vehicle’s passengers. Matthew also admitted, to Ofcer Schwaru at the hospital, that
she was operating the vehicle at the time of the accident.

Based on my training and experience, there appeared to be no reason for the crash except the
intoxication of Matthew. Ofcers were unable to locate any objects obstructing the roadway along
with the road being dry. Due to the above facts, I believe Matthew to have been operating a motor
vehicle in a public place and was intoxicated and by reason of that intoxication caused the death of
another (four-year-old child) by accident or mistake. Matthew was arrested without incident aer
being discharged from the hospital.

SUBSCRIBED AND SWORN TO BEFORE ME by C. LaPlante #578 , a

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credible person on this the 20 day of DECEMBER 2019
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A March 13, 2021
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On this day of , 20 , l examined the

attached aidavit and based thereon nd as indicated below by an "X".

that there is probable cause to believe that the accused has committed the above offense and hereby ORDER
D that the accused be committed to the Wichita County Jail and hereby set bail at $
_unless the accused has previously posted bail according to the schedule approved by the Judges
of the Wichita County Court and County Court at Law.

that there is not probable cause to believe that the accused committed the above offense and hereby ORDER that
D the accused be released.
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PROBABLE CAUSE AFFIDAVIT
y $0.51me
MAGISTRATE