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JEFFREY R.

BUHMAN #7041
Utah County Attorney
JARED PERKINS #11246
Deputy Utah County Attorney
100 East Center, Suite 2100
Provo, Utah 84606
Email: dcourt@utahcounty.gov
Phone: (801) 851-8026
Fax: (801) 851-8051

IN THE FOURTH JUDICIAL DISTRICT COURT

UTAH COUNTY, STATE OF UTAH

STATE OF UTAH, INFORMATION

Plaintiff,

vs.

SETH STEPHEN PATTERSON


91 W 1700 S Case No. _________________
Bountiful, UT 84010
DOB: 09/09/1981 Judge: ___________________

Defendant. OTN: ____________________

The State of Utah, by and through Jared Perkins, Deputy Utah County Attorney,
charges the defendant with the commission of the following offenses:

COUNT 1: STALKING (DOMESTIC VIOLENCE), a third degree felony, in


violation of Utah Code § 76-5-106.5, in that on or about April 27, 2018 through October
1, 2018, in Utah County, the Defendant, Seth Stephen Patterson did intentionally or
knowingly engage in a course of conduct directed at a specific person and knew or should
have known that the course of conduct would cause a reasonable person: (i) to fear for the
person’s own safety or the safety of a third person; or (ii) to suffer other emotional
distress; and at the time of the commission of the offense the Defendant had been or was
a cohabitant of the victim.
COUNT 2: VIOLATION OF A PROTECTIVE ORDER (DOMESTIC
VIOLENCE), a class A misdemeanor, in violation of Utah Code § 76-5-108, in that on or
about September 1, 2018 through September 30, 2018, in Utah County, the Defendant,
Seth Stephen Patterson, being subject to a protective order, child protective order, ex
parte protective order, or ex parte child protective order issued under Utah Code Title
78B, Chapter 7, Part 1, Cohabitant Abuse Act, or Title 78A, Chapter 6, Juvenile Court
Act of 1996, Title 77, Chapter 36, Cohabitant Abuse Procedures Act, or a foreign
protection order enforceable under Title 78B, Chapter 7, Part 3, Uniform Interstate
Enforcement of Domestic Violence Protection Orders Act, did intentionally or knowingly
violate that order after having been properly served; and the defendant was a cohabitant
of the victim.

COUNT 3: VIOLATION OF A PROTECTIVE ORDER (DOMESTIC


VIOLENCE), a class A misdemeanor, in violation of Utah Code § 76-5-108, in that on or
about September 1, 2018 through September 30, 2018, in Utah County, the Defendant,
Seth Stephen Patterson, being subject to a protective order, child protective order, ex
parte protective order, or ex parte child protective order issued under Utah Code Title
78B, Chapter 7, Part 1, Cohabitant Abuse Act, or Title 78A, Chapter 6, Juvenile Court
Act of 1996, Title 77, Chapter 36, Cohabitant Abuse Procedures Act, or a foreign
protection order enforceable under Title 78B, Chapter 7, Part 3, Uniform Interstate
Enforcement of Domestic Violence Protection Orders Act, did intentionally or knowingly
violate that order after having been properly served; and the defendant was a cohabitant
of the victim.

COUNT 4: VIOLATION OF A PROTECTIVE ORDER (DOMESTIC


VIOLENCE), a class A misdemeanor, in violation of Utah Code § 76-5-108, in that on or
about September 1, 2018 through September 30, 2018, in Utah County, the Defendant,
Seth Stephen Patterson, being subject to a protective order, child protective order, ex
parte protective order, or ex parte child protective order issued under Utah Code Title
78B, Chapter 7, Part 1, Cohabitant Abuse Act, or Title 78A, Chapter 6, Juvenile Court
Act of 1996, Title 77, Chapter 36, Cohabitant Abuse Procedures Act, or a foreign
protection order enforceable under Title 78B, Chapter 7, Part 3, Uniform Interstate
Enforcement of Domestic Violence Protection Orders Act, did intentionally or knowingly
violate that order after having been properly served; and the defendant was a cohabitant
of the victim.

COUNT 5: VIOLATION OF A PROTECTIVE ORDER (DOMESTIC


VIOLENCE), a class A misdemeanor, in violation of Utah Code § 76-5-108, in that on or
about September 1, 2018 through September 30, 2018, in Utah County, the Defendant,
Seth Stephen Patterson, being subject to a protective order, child protective order, ex
parte protective order, or ex parte child protective order issued under Utah Code Title
78B, Chapter 7, Part 1, Cohabitant Abuse Act, or Title 78A, Chapter 6, Juvenile Court
Act of 1996, Title 77, Chapter 36, Cohabitant Abuse Procedures Act, or a foreign
protection order enforceable under Title 78B, Chapter 7, Part 3, Uniform Interstate
Enforcement of Domestic Violence Protection Orders Act, did intentionally or knowingly
violate that order after having been properly served; and the defendant was a cohabitant
of the victim.

COUNT 6: VIOLATION OF A PROTECTIVE ORDER (DOMESTIC


VIOLENCE), a class A misdemeanor, in violation of Utah Code § 76-5-108, in that on or
about October 1, 2018, in Utah County, the Defendant, Seth Stephen Patterson, being
subject to a protective order, child protective order, ex parte protective order, or ex parte
child protective order issued under Utah Code Title 78B, Chapter 7, Part 1, Cohabitant
Abuse Act, or Title 78A, Chapter 6, Juvenile Court Act of 1996, Title 77, Chapter 36,
Cohabitant Abuse Procedures Act, or a foreign protection order enforceable under Title
78B, Chapter 7, Part 3, Uniform Interstate Enforcement of Domestic Violence Protection
Orders Act, did intentionally or knowingly violate that order after having been properly
served; and the defendant was a cohabitant of the victim.

PROBABLE CAUSE STATEMENT: Cameron Paul of the American Fork Police


Department, having probable cause to believe that the defendant committed the above-
listed offenses, submitted the following evidence in support of the filing of this
Information: On January 29, 2017, police responded to a domestic violence incident in
progress at Seth and Kimberly Patterson’s residence in American Fork. One police
officer responded and waited for back-up. Mr. Patterson is alleged to have left the
residence in his car, approached the police officer’s vehicle from behind, and fired
several surprise shots at the officer. The State also has alleged that he assaulted Kimberly
in the presence of their minor children on that day. He stands accused of these offenses
before this court in pending case 171400372. Because of the danger he poses to Kimberly
and their children, Judge Davis ordered that Seth have no contact, direct or indirect, with
Kimberly, and that his visits with their children be supervised through ACAFS at the
Utah Family Academy in Provo. Seth stipulated to this Criminal No Contact Order and it
was served to him in open court on April 26, 2017.
Since that time, Kimberly has divorced Seth, moved to an undisclosed new
residence, and remarried. Nevertheless, Seth has intentionally pursued a course of
conduct directed at Kimberly that has both caused her to fear for her and her children’s
safety, and caused her emotional distress.
On April 27, 2018, Seth left flowers at the Utah Family Academy and instructed
employees there to deliver the flowers to Kimberly, which they did. This caused
Kimberly distress.
On May 8, 2018, Seth gave flowers to his children, instructing them to deliver
them to Kimberly for Mother’s Day. This too caused Kimberly distress. Both of these
indirect contacts violated Judge Davis’s no contact order and Seth now stands accused of
these offenses in pending case 181402787.
On August 15, 2018, Seth admitted himself to a psychiatric facility and disclosed
to a crisis counselor that he thought there was a “7 out of 10 chance” he would hurt or kill
Kimberly if he were released. Under her duty to report, this counselor reported the risk
Seth poses to Kimberly’s safety to police, who in turn informed Kimberly. This
information naturally increased her alarm and fear of Seth. Eventually, Seth was released
from psychiatric care.
In September of 2018, Kimberly received four telephone calls in quick succession
from a blocked number. On the first two calls, the caller discontinued the call after
Kimberly answered. On the third call, Kimberly identified the caller as Seth and he
asked, “Did you ever love me?” On the fourth call, Kimberly again identified the caller as
Seth and he began trying to persuade her to drop the protective order. This again caused
her distress and fear, especially knowing that he was still willing to violate Judge Davis’s
no contact order.
On October 1, 2018, Seth was facing a hearing on October 3 to address the State’s
request to further protect Kimberly and her children, and to address his bail amount and
custody status. That morning, Kimberly reported to police that personnel from her child’s
elementary school called her to tell her that an unidentified male had called the school
trying to procure the child’s – and Kimberly’s – new address. When asked to identify
himself, the man told the school employee that he was Kimberly’s new husband.
Kimberly’s husband denies calling the school to ask for his own address.
When Kimberly reported this incident to police, they became very concerned for
her safety and mobilized their patrol officers in a search for Seth. One officer observed
Seth’s car driving in American Fork and, while awaiting back-up, followed the car as it
drove to American Fork Junior High School and parked illegally directly in front of the
school. School was in session and another of Seth’s and Kimberly’s children was in class
there. October 1 is that child’s birthday.
Once back-up officers arrived, police stopped Seth’s car as he drove to the east
side of the school and identified him as the driver. He was arrested on suspicion of
multiple crimes and his car was impounded and inventoried. During the inventory, police
found a plastic BB handgun that had been painted black recently (the paint was still wet)
to make a facsimile of a firearm, an envelope containing letters addressed to two of
Seth’s and Kimberly’s children (one of which was the student at the junior high school), a
photograph, and a stuffed animal. Police obtained a search warrant and seized these items
as evidence.
These acts by Seth Patterson and directed at his ex-wife, a victim in previous
charged offenses, caused and continue to cause Kimberly significant fear for her and her
children’s safety, and severe emotional distress. Seth Patterson knows, or should know,
that these acts would cause such fear and distress given that Kimberly is his alleged
victim of domestic violence assault, that he stipulated to a court order in which she
requested that he have no contact whatsoever with her and only supervised visits with
their children, that she pressed more charges of violation of a protective order against him
for contacts in April and May, that she has remarried, moved, and hidden her address
from him, that he has expressed a threat against her life, that he approached their child’s
school with a facsimile of a firearm, and that she has reported several violations to police
when he made or tried to make contact with her.
Based upon evidence received from Cameron Paul of the American Fork Police
Department, I have reason to believe the defendant committed the offenses as charged
herein.

Authorized for presentment and filing this 2nd day of October, 2018.

UTAH COUNTY ATTORNEY’S OFFICE

/s/ Jared Perkins


JARED PERKINS
Deputy Utah County Attorney