SIM GILL, BarNo.

6389
District Attorney for Salt Lake County
COLLEEN K. MAGEE, Bar No. 12716
BRIAN J. WILLIAMS, BarNo. 10779
Deputy District Attorneys
35 East 500 South
Salt Lake City, Utah 84111
Telephone: (385) 468-7600

IN THE THIRD DISTRICT COURT, WEST JORDAN DEPARTMENT

IN AND FOR THE COUNTY OF SALT LAKE, STATE OF UTAH

THE STATE OF UTAH, Screened by: HOMICIDE UNIT

Assigned to: COLLEEN K. MAGEE and
Plaintiff, BRIAN J. WILLIAMS

vs.
DOMESTIC VIOLENCE
CHELSEA WATROUS COOK, INFORMATION
DOB: 10/04/1986,
AKA: CHELSEA WATROUS,
11855 SOUTH MUSK DEER LANE BAIL NOT ALLOWED
HERRIMAN, UTAH 84096
D.L.# 169917150 Warrant/Release: IN SALT LAKE COUNTY
OTN 56777543 JAIL
S0#412234
Booldng# 180595018 Case No.

Defendant. DA Case No. 18028237

The undersigned Detective J. Flores with the Salt Lake City Police Department, in
reference to agency case no. 18-216038, upon a written declaration states on information and
belief that the defendant, CHELSEA WATROUS COOK, committed the crimes of:

COUNT 1
CRIMINAL HOMICIDE, AGORAVATED MURDER, 76-5-202 UCA, First Degree Felony, as
follows: That on or about November 25, 2018 at 7690 South Center Square, in Salt Lake
County, State of Utah, the defendant intentionally or knowingly caused the death of Lisa
Williams under any of the following circumstances: The actor knowingly created a great risk of
death to a person other than the victim and the actor; or the homicide was committed incident to
an act, scheme, course of conduct, or criminal episode during which the actor committed or
attempted to commit Aggravated Burglary or Burglary.
COUNT2
AGGRAVATED BURGLARY (DV), 76-6-203 UCA, First Degree Felony, as follows: That on
or about November 25, 2018 at 7690 South Center Square, in Salt Lake County, State of Utah,
the defendant attempted, committed, or fled from a burglary and while doing so the defendant, or
another participant in the crime, caused bodily injury to any person who was not a participant in
the crime; or used or threatened the immediate use of a dangerous weapon against any person
who was not a participant in the crime; or possessed or attempted to use any dangerous weapon.
Furthermore the defendant was a cohabitant of the victim.

COUNT3
FELONY DISCHARGE OF A FIREARM WITH SERIOUS BODILY INJURY, 76-10-508.1
UCA, First Degree Felony, as follows: That on or about November 25, 2018 at 7690 South
Center Square, in Salt Lake County, State of Utah, the defendant, knowing or having reason to
believe that any person may be endangered by the discharge of a firearm, discharged a firearm in
the direction of any person or persons; or with the intent to intimidate or harass another or with
intent to damage a habitable structure, discharged a firearm in the direction of any person or
habitable structure.
Furthermore, the aforementioned violation caused serious bodily injury to Lisa Williams.

COUNT4
FELONY DISCHARGE OF A FIREARM WITH INJURY, 76-10-508.1 UCA, Second Degree
Felony, as follows: That on or about November 25, 2018 at 7690 South Center Square, in Salt
Lake County, State of Utah, the defendant, knowing or having reason to believe that any person
may be endangered by the discharge of a firearm, discharged a firearm in the direction of any
person or persons; or with the intent to intimidate or harass another or with intent to damage a
habitable structure, discharged a firearm in the direction of any person or habitable structure.
Furthermore, the aforementioned violation caused injury to Lisa Williams.

COUNTS
FELONY DISCHARGE OF A FIREARM, 76-10-508.1 UCA, Third Degree Felony, as follows:
That on or about November 25,2018 at 7690 South Center Square, in Salt Lake County, State of
Utah, the defendant, knowing or having reason to believe that any person may be endangered by
the discharge of a firearm, discharged a firearm in the direction of any person or persons; or with
the intent to intimidate or harass another or with intent to damage a habitable structure,
discharged a firearm in the direction of any person or habitable structure.

COUNT6
VIOLENT OFFENSE COMMITTED IN PRESENCE OF CHILD, 76-3-203.10(2) UCA, Class
B Misdemeanor, as follows: That on or about November 25, 2018 at 7690 South Center Square,
in Salt Lake County, State of Utah, the defendant committed or attempted to commit criminal
homicide, as defined in Utah Code Section 76-5-201, against a third party in the presence of a
child; or intentionally caused or attempted to cause serious bodily injury to a third party or used a
dangerous weapon, as defined in Utah Code Section 76-1-601, or other means or force likely to
produce death or serious bodily injury, against a third party in the presence of a child; or under
circumstances not amounting to a violation above, committed a violent criminal offense in the
presence of a child.
COUNT?
VIOLENT OFFENSE COMMITTED IN PRESENCE OF CHILD, 76-3-203.10(2) UCA, Class
B Misdemeanor, as follows: That on or about November 25, 2018 at 7690 South Center Square,
in Salt Lake County, State of Utah, the defendant committed or attempted to commit criminal
homicide, as defined in Utah Code Section 76-5-201, against a third party in the presence of a
child; or intentionally caused or attempted to cause serious bodily injury to a third party or used a
dangerous weapon, as defined in Utah Code Section 76-1-601, or other means or force likely to
produce death or serious bodily injury, against a third party in the presence of a child; or under
circumstances not amounting to a violation above, committed a violent criminal offense in the
presence of a child.

THIS INFORMATION IS BASED ON EVIDENCE OBTAINED FROM THE FOLLOWING

WITNESSES:

J. Flores, W. Ahmad, A. Altameerni, H. Argoello, C. Bobo, B. Broadhead, R. Carlisle, C.

Contreras, T. Cook, J. C., A. C., S. Curtis, E. Dahms, T. Duran, H. Fadaws, K. Flinton, J. Goode,
A. Hargrove, W. Isom, D. Leggroan, R. Martinez, M. Mathews, T. Mitchell, H. Mount, R.
Quezada, T. Sayes, M. Schauerhamer, J. Smith, B. Sousley, J. Spangenberg, J. Stilson, R. Torres,
and P. Ulmer.

DECLARATION OF PROBABLE CAUSE:

Your declarant bases this information upon the following:

The statement ofT. Cook that on November 25, 2018, in Salt Lake County he was home
with his girlfriend, Lisa Vilate Williams, and his twin three-year-old children, A. C. and J.C. Mr.
Cook's ex-wife and mother of the twins, CHELSEA WATROUS COOK, texted him that she
was going to stop by and drop off some cold medicine for A. C. Mr. Cook told her to text him
when she arrived and he would meet her downstairs. After receiving a text from COOK stating
that she was there, Mr. Cook left the apartment, leaving the door unlocked, and went downstairs
to meet COOK. When Mr. Cook was unable to locate COOK, he went back up to his apartment
and found COOK in the apartment living room where Ms. Williams and both children were. Mr.
Cook told COOK to leave numerous times and COOK refused to leave.

Mr. Cook picked up the phone to call 911 and COOK walked into the bathroom and
locked the door. Approximately fifteen seconds later, COOK came out of the bathroom and
walked towards her coat. Mr. Cook was behind COOK when he heard multiple gunshots and saw
COOK pointing a gun at Ms. Williams. Mr. Cook grabbed the gun from COOK and COOK sat
down with the two children, who were present in the living room during the shooting. While Mr.
Cook was back on the phone with the 911 operator, COOK got up and walked towards her coat.
Unsure if COOK had another gun hidden in her coat, Mr. Cook pinned COOK up against the
wall until officers arrived. While waiting for police, Mr. Cook told J.C. and A. C. to go to their
bedroom and lock their door.
 The statement of Officer Flores with the Salt Lake City Police Department that he
obtained video surveillance from the apartment complex that shows COOK entering the hallway
where Mr. Cook's apartment is located. While standing in the hallway, COOK is seen on her
phone and appears to be texting. Shortly thereafter, Mr. Cook exits his apartment and once he is
out of sight COOK enters the apartment without knocking.

The statement of Officer Mount that four 9mm casings were found in the apartment.
Two projectiles were found in the couch in the living room and one projectile was found in the
south wall above the window. Officers recovered a 9mm Taurus G2C from Mr. Cook that was
used in the shooting.

The statement of Deputy Medical Examiner, Dr. Pamela S. Ulmer, that the fatal gunshot
entered Ms. Williams' right chest, bruised the right lung, and perforated the heart and left lung.
The bullet traveled from right to left and was recovered from the left chest wall. A second shot
went through her right hip and exited her back just above her buttocks. A third shot entered and
exited the back of her right thigh. The cause of death was preliminarily determined to be
multiple gunshot wounds, and the manner of death was homicide.

REQUEST FOR ISSUANCE OF A WARRANT:

The State hereby requests that the Court issue a Warrant of Arrest in this case due to the
nature of the offenses and facts as alleged in the probable cause statement. Additionally, the
defendant is incarcerated in the Salt Lake County Jail. A Warrant of Arrest is necessary to
prevent risk of injury to a person or property, to protect the public safety and welfare of the
community or an individual and to secure the appearance of the accused.

Pursuant to Utah Code Annotated § 78B-5-705

(2008) I declare under criminal penalty of the State
of Utah that the foregoing is true and correct to the
best of my belief and knowledge.

Executed on: ILj/5 / ('3

rL
12~~y 2

Authorized for presentment and filing

sw&:::?t-1~
Deputy District Attorney
5th day ofDecember, 2018
EG/CKM IDA Case No. 18028237
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