E-FILED

IN COUNTY CLERK'S OFFICE

PIERCE COUNTY, WASHINGTON

May 11 2011 10:38 AM

1 SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY
KEVIN STOCK
COUNTY CLERK
2 STATE OF WASHINGTON,

3 Plaintiff, CAUSE NO. 11-1-01977-4

vs.
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CHARLES CHRISTOPHER MANN, DECLARATION FOR DETERMINATION OF
5 PROBABLE CAUSE

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Defendant.
7
GERALD T. COSTELLO, declares under penalty of perjury:
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That I am a deputy prosecuting attorney for Pierce County and I am familiar with the police
report and/or investigation conducted by the PIERCE COUNTY SHERIFF, incident number 111291205;
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That the police report and/or investigation provided me the following information;
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That in Pierce County, Washington, on or about the 9th day of May, 2011, the defendant,
11 CHARLES CHRISTOPHER MANN, did strike two year old Najaila Lowe in the abdomen with great
force, causing massive internal bleeding, which killed the child.
12 Deputy Sheriffs responded at approximately 8:00 p.m. on May 9th to the 1600 block of 74th St. Ct.
E because of an emergency call from the mother of the victim. had been at
13 work at a location close to her home, when Defendant called her about the victim being in distress.
Defendant was the caretaker for the victim and an infant. The adults have been in a romantic relationship,
14 but are not married. rushed home and found that her two year old toddler was not breathing
and had vomited, so she called for help.
Deputy Zurfluh was close by and upon arriving found Defendant, very distraught, holding the
15 unconscious, apparently lifeless victim. Defendant told him that the victim had apparently drowned in the
bathtub, while Defendant was tending to the infant in another room. Deputy Zurfluh attempted CPR and
16 called for medical aid. He noted that the child was wearing a diaper that was dry and there was no
indication of water on the child’s hair or skin. Medics rushed the child to Mary Bridge Hospital, but her
17 life could not be saved.
Defendant told Deputy Zurfluh that he was the only adult in the home when the problems
18 happened. He stated that the victim had vomited while in bed, and Defendant put her in the bathtub to
clean vomit from her hair. He said that he left the bathroom for about 45 seconds to tend to the infant.
19 When he returned he found the toddler under water. Defendant said he took the victim into his bedroom
and began “pumping her stomach” to try to remove water. He claimed to be unsure if the victim was
breathing, so rather than calling for emergency aid, he called Ms.
20
On May 10th the County Medical Examiner performed an autopsy on the victim. A large amount
of blood was found in the victim’s abdominal cavity. Dr. Clark’s opinion is that the manner of death is
21 homicide, and that blunt force trauma to the victim’s abdomen caused the fatal bleeding. Four to five
roughly circular shaped, dime-size bruises were seen on the victim’s skin of her abdomen, spread out over
22 a five to six inch area. His opinion is that the child died within three hours of being struck. Dr. Clark
found no water in the child’s lungs.
23 Ms. earned from the Medical Examiner’s office that her child died from blunt force
trauma and she confronted Defendant (who is not the victim’s father). Defendant then changed his story.
24 He told Ms. that he accidentally struck the victim in the abdomen through a pillow that the child
Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -1 Tacoma, WA 98402-2171
Main Office (253) 798-7400
 11-1-01977-4

1 was clutching, and this happened while the two were playing a game. He maintained that while cleaning
vomit from the child’s hair she accidentally drowned.
2 Defendant met with detectives in the evening of May 10th and after “Miranda” warnings, and after
being told he was under arrest, chose to speak with them. Defendant maintained that he found the victim
3 underwater in the bathtub. He offered another version of how the victim was struck in the abdomen. He
said that the child was standing on a couch, leaning back on the seat-back, and Defendant was trying to
entertain her with a version of shadow boxing. He said that he forcefully struck the seat-back on both
4 sides of the victim, deliberately avoiding striking the child, and pretending that he was boxing with the
girl. He said that the impact to the couch caused the girl to lose her balance and that while she toppled to
5 one side he accidentally struck her with a closed fist one time on her abdomen. He claimed that this
caused the victim to fall to a seated position, but that she seemed to be o.k. He said that about thirty
6 minutes later she became ill, and vomited, which led to the scenario of the victim accidentally drowning
in the bathtub.
7 Dr. Clark’s opinion is that the bruising found on the victim’s abdomen is not consistent with a
single blow from a closed fist because the bruises are too diffuse.
8
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE OF
WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.
9
DATED: May 11, 2011
10 PLACE: TACOMA, WA

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/s/ GERALD T. COSTELLO
12 GERALD T. COSTELLO, WSB# 15738

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Office of the Prosecuting Attorney
DECLARATION FOR DETERMINATION 930 Tacoma Avenue South, Room 946
OF PROBABLE CAUSE -2 Tacoma, WA 98402-2171
Main Office (253) 798-7400