_________________________________________________________________

IN THE THIRD DISTRICT COURT - ALL DEPARTMENT

IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

_________________________________________________

AFFIDAVIT FOR SEARCH WARRANT

STATE OF UTAH )
:ss
County of Salt Lake )

The undersigned affiant, Detective KELLY ZIERSE of West Jordan Police Department,
upon an oath or written affidavit subscribed under criminal penalty, declares:

That your affiant has reason to believe:

THAT

On the person(s) described as: Kevin Jonathan Hernandez

DOB: 10/9/2004
further described as an Hispanic male, about 5'07" tall, 150 lbs, with brown hair
and brown eyes;

In the City of West Jordan, County of Salt Lake, State of Utah, there is now certain
property or evidence described as:

DNA buccal swabs

and that said property or evidence:

Was unlawfully acquired or is unlawfully possessed;

has been used or is possessed for the purpose of being used to commit or
conceal the commission of an offense; or

is evidence of illegal conduct.

Affiant believes the property and evidence described above is evidence of the crime
or crimes of Criminal Homicide 76-5-201.

The facts to establish the grounds for issuance of a Search Warrant are:

- Page 1 of Affidavit for Search Warrant No. 2259181 -

Your affiant is a detective with the West Jordan Police Department, assigned to
the Major Crimes Unit, and specializing as an investigator with the Utah Internet
Crimes Against Children (ICAC) Task Force. ICAC is a multi-jurisdictional task
force comprised of local, state and federal law enforcement officers. The task
force investigates Internet crimes against children, including state and federal
violations of laws, such as those dealing with enticement, child pornography and
dealing harmful material to minors, and submits their investigations to state and/or
federal entities for prosecution. Since becoming part of the ICAC Task Force
I have been leading and assisting investigations, writing and executing search
warrants, conducting undercover operations via the Internet, interviewing victims,
interviewing suspects and effecting arrests.

Your affiant graduated from the Arizona Law Enforcement Academy (ALEA) in
2005 and was certified by Utah POST in 2010. Your affiant has also worked
assignments with the Property Crimes Unit (investigating fraud and forgery cases),
Juvenile Unit (worked as an SRO at a high school), Patrol (assigned as a Field
Training Officer), Bike Patrol Unit, and as a SWAT team operator. Your affiant
earned a Bachelor's of Science degree from Broadview University in Criminal
Justice and received training and certificates as a first line supervisor, firearms
instructor, handcuffing instructor, baton/asp instructor, interview and interrogation
techniques, Voice Stress Analyzer certified, field training officer, drug identification
and detection, identity fraud, crimes involving children, and ICAC undercover chat
investigations.

I have successfully completed and continue to attend all the training required by
the Utah ICAC to initiate or follow-up on investigations involving the enticement
of minors, the sexual exploitation of children or dealing harmful materials to
minors over the Internet. Based on my training and experience, I know that
individuals who search for, download, and view child sex abuse imagery routinely
accumulate, store, and conceal collections of sexually explicit depictions of
children.

On May 9, 2021 at 2144 hours, Officer's responded to a vehicle crash at the

intersection of 7800 S and Redwood Road in West Jordan City, Utah. A gray 2012
Chevrolet Malibu, bearing Utah license plate 6M3WS, was traveling northbound
on Redwood Rd when a collision occurred between several vehicles. Several
callers reported to dispatch, stating gun shots were heard prior to the traffic
collision and the 2012 Chevrolet Malibu, bearing Utah license plate 6M3WS,
was reported to possibly have bullet holes to the passenger side of the vehicle.
Officers were advised by witnesses Chad Struckle, Stephen Fleenor, and Ivy
Taylor the possible suspect vehicle continued northbound on Redwood Road and
was described as a gray Chrysler 300.

Once Officers arrived on scene, they located the 2012 Chevrolet Malibu bearing
Utah license plate 6M3WS at the intersection of 7800 S and Redwood Road and

- Page 2 of Affidavit for Search Warrant No. 2259181 -

observed one male occupant in the driver seat of the vehicle. Officers observed
the vehicle to have several holes in the passenger side of the vehicle and
windows, which appeared to be caused by bullets. The male occupant was later
identified as Cesar Manenche (date of birth 10/03/2001). Officers found Cesar
had several gunshot wounds to his face and head region. Cesar was transported
to Intermountain Medical Center and was later pronounced deceased. While
interviewing family and friends of Cesar, Detectives found Cesar was speaking
with a friend, Benedict Rodriguez-Arellanes date of birth, June 19, 2000. Benedict
had stated he was talking on his cellphone with Cesar when he heard the gunshots
as this incident occurred.

On May 9, 2021, Cesar's mother Alma Gallardo, date of birth, 01/23/1979, was
interviewed by Sergeant Vargas regarding this incident. Alma provided several
names of the possible suspects and provided information regarding a possible
suspect vehicle, Chrysler 300, which matched the description of the suspect
vehicle that was called into dispatch by numerous witnesses when this incident
occurred. Alma also said she was aware that Cesar was an active gang member
and associated with the Cuaji gang. Alma said the possible suspects were known
to also be gang members and associated with a rival gang to the Cuaji gang,
known as Florencia 13 and Old Town Midvale gangs. Alma informed Sergeant
Vargas she was aware of this information in response to recent conversations
she had with Cesar. Alma provided the following names as possible suspect
individuals: Kevin Hernandez and Zahid Loya, later identified as Kevin Jonathan
Trinadad Hernandez (date of birth 09/12/2003) and Zahid Cruz (date of birth
11/17/2004). Alma stated Cesar had previously given her specific details that
Kevin and Zahid had made numerous threats to cause harm to Cesar to include
previously using firearms to threaten Cesar. Alma said that Kevin and Zahid often
use Zahid mother's boyfriend's Chrysler 300 vehicle. Alma described the Chrysler
300 vehicle to be grey in color.

Alma further explained that she had observed a grey Chrysler 300 earlier in the
day on May 9, 2021 driving through her apartment complex, 8870 S State Street
apartment G202 in Sandy, Utah. Alma again explained that she was familiar
with the vehicle and she believed the grey Chrysler to be the vehicle that Zahid
drives. Alma believed Kevin and Zahid were searching for Cesar. Alma provided
Sergeant Vargas with Zahid's mother's name of Angie Loya. Sergeant Vargas
located information for Angelina Loya, (date of birth 02/22/1984), and also located
a Facebook profile for Angelina. Sergeant Vargas discovered numerous videos
on Facebook that Angelina had posted. One of the videos located on Angelina's
Facebook page had a dark colored Chrysler 300 bearing Utah license plate
X033WG, parked in the driveway of the residence, 8829 S 500 E in Sandy, Utah.

Sergeant Vargas conducted a Utah database search for Utah license plate
X033WG and discovered the Utah license plate returned with information for a
grey 2008 Chrysler 300 that was registered to Francisco Contreras. It is believed

- Page 3 of Affidavit for Search Warrant No. 2259181 -

Francisco Contreras is the boyfriend of Angelina and Zahid's stepfather. Sergeant
Vargas discovered Francisco and Angelina currently reside at the same address.
It was also discovered Angelina had received a traffic citation in a 2008 grey
Chrysler 300, bearing Utah license plate X033WG, on 10/12/2017, Utah Citation
C153648241. It was also discovered a traffic stop was conducted on November
29,2020, for a broken taillight on a 2008 grey Chrysler 300, bearing Utah license
plate X033WG. The driver was identified by Sandy Police Department as Zahid
Cruz (date of birth 11/17/2004). The Sandy Police Department officers gave Zahid
a warning for the broken taillight and the traffic stop was documented under Sandy
Police Department Case SY2020-59673.

On May 9, 2021, Detective Holt conducted an interview with Alan Manenche,

who was identified as the 13 year old brother of Cesar. Alma gave Detective Holt
consent to speak with Alan regarding this incident prior to the interview being
conducted. Alan informed Detective Holt that Cesar identified himself as an active
Cuaji gang member. Alan also provided Detective Holt with the names of: Kevin
Hernandez and Zahid Loya later identified as Kevin Jonathan Trinadad Hernandez
(date of birth 09/12/2003) and Zahid Cruz (date of birth 11/17/2004), and said that
he believed Kevin and Zahid were responsible for Cesar's death. Alan was aware
that Kevin and Zahid are also active gang members of the Florencia 13 and Old
Town Midvale gangs. Alan said that Cesar had "dropped out" of the Florencia
13 gang and joined Cuaji gang which upset Kevin and Zahid and likely was the
cause of this incident. Alan also said he had witnessed Kevin and Zahid in a grey
Chrysler 300 on numerous occasions, which matched the description provided for
the suspect vehicle for this incident. Alan last observed Zahid in the grey Chrysler
300 earlier during the day on May 9, 2021, near Alan and Alma's residence, 8870
S State Street apartment G202 in Sandy, Utah. Alan believed Zahid was near
their residence in the grey Chrysler 300 for the purpose of attempting to locate
Cesar. Alan informed Detective Holt he believed the grey Chrysler 300 belonged
to Zahid's mother.

On May 10, 2021, at 0139 hours, Detectives Madsen and Ranney conducted
an interview with Cesar Manenche’s girlfriend Yajaira Yamilet Chavez. Yajaira
told Detectives that her and Cesar have been in a relationship off and on since
approximately 2018. They have a one-year-old child and are currently living
together. Yajaira said Cesar has been having problems with Kevin Hernandez and
“Zai”. Yajaira didn’t have further information on Kevin or Zai other than they are
known to drive a grey Chrysler 300. Yajaira stated “They” have been “Taunting”
Cesar for the last 2-3 years when he stepped away from their gang. Yajaira stated
Cesar would receive messages via Snapchat from Kevin, where Kevin would be
asking Cesar to come outside, or asking to meet Cesar, and were calling Cesar
"scared". Yajaira stated when Cesar would come to visit Cesar’s mother, “They”
would be waiting for Cesar in the Chrysler to tease and try to get Cesar to react.

- Page 4 of Affidavit for Search Warrant No. 2259181 -

On May 10, 2021 at about 0400 hours a gray in color Chrysler 300, bearing Utah
license plate X033WG, was located parked in front of 8829 S 500 E, Sandy, UT.
Detectives began working on securing a search warrant for the residence and
Chrysler 300 when they, at about 0730 hours, observed a juvenile male, believed
to be Zahid, exit the residence, and enter a parked vehicle. Two other subjects
entered the same vehicle with Zahid, an adult male, later identified as Francisco,
and a second juvenile male, later identified as Jaiden Cruz Loya (Zahid’s brother).

Detectives watching the residence made contact with all three individuals,
detained them, and later transported them to the West Jordan Police Department
for interviews. During a pat down search, a cell phone was located in Zahid’s
front right pant pocket. The cell phone, an Apple iPhone with IMEI number
356803111994601, was secured. Zahid stated the phone belonged to him and
Francisco verified Zahid's phone number of 385-343-7064.

On May 10, 2021 at about 0930 hours detectives conducted an interview

with Francisco. During the interview, Francisco stated that his stepson, Zahid,
took his Chrysler 300 without permission on 5/9/2021 at an unknown time.
Francisco stated that Zahid returned home with the Chrysler 300 on 5/9/2021 at
approximately 2211 hours with four other subjects. Francisco said he specifically
remembered the time they arrived home because he was cooking outside for a
party and looked at his phone when Zahid arrived home. Francisco described the
vehicle passengers as driver (Zahid), passenger (Kevin) Jonathan Hernandez,
and three unknown male subject passengers described as a white male, Hispanic
male with big hair, and another very small and thin Hispanic male.

On May 10, 2021 at approximately 1100 hours a search warrant was served at
Zahid's residence located at 8829 S 500 E, Sandy, UT. During the execution
of the search warrant, a firearm was located in a bedroom identified as Zahid's
bedroom. The firearm was hidden inside a vacuum canister in the bedroom. Zahid
had personal identifying information in the bedroom and his girlfriend (identified as
Trinity Dominguez) was in the bedroom as the search warrant was being served.
The firearm, a Sig Sauer 365, is a 9mm caliber gun. 9mm rounds were located
in the firearm magazine and matched the caliber of casings found at the crime
scene (7800 South Redwood Rd).

On May 10, 2021 Trinity Dominguez was interviewed at the West Jordan Police
Department. Trinity was in possession of an Apple iPhone, rose gold in color,
at the time she was detained. Trinity stated, post Miranda, that she was at
Zahid’s residence when he arrived home in the evening of 5/9/2021. Trinity told
investigators that when Zahid arrived home, he showed her a news story on
his cell phone of the shooting with the description of the “Chrysler 300”. Trinity
stated that Zahid told her “me and the homies did some shit.” Trinity admitted to
helping Zahid hide a firearm in a vacuum cannister in Zahid’s bedroom. During the
interview, Trinity stated that she had received a phone call from her friend's cell

- Page 5 of Affidavit for Search Warrant No. 2259181 -

 phone number. Trinity stated that the call was her friend Brisa Avila's boyfriend
who has been identified as Luis Quintana. Luis was identified as a friend of Zahid.
Zahid and Luis are seen in multiple photos together flashing gang signs. Luis
was identified by gang detectives as being in the same gang as Zahid. Trinity
stated that Luis called her to ask if Zahid was okay because he had not heard
from him in a while. Trinity stated that Luis asked about the whereabouts of the
Chrysler 300 several times. Based on the communication between Trinity and
Zahid's fellow gang associate (Luis), it is believed that Trinity may have received
other communication from Zahid and other possible suspects.

On May 12, 2021 investigators met with Francisco Javier Contreras-Cervantes

(Zahid’s father) to conduct a double-blind photo line-up regarding his statement of
seeing five people exit the Chrysler 300 on 5/9/2021 at approximately 2211 hours.
During the photo line-up review, Francisco positively identified Kevin Jonathan
Hernandez and Julio Reyes Gutierrez as two of the subjects seen exiting the
vehicle (Chrysler 300) at his residence located at 8829 S 500 E Sandy, Utah.

On May 12, 2021 the Honorable Judge Kouris approved and signed search
warrant no. 2258861 related to a DNA swab. The date of birth listed for Kevin
Hernandez was incorrect (9/12/2003) and the correct date of birth was discovered
on a juvenile record for Kevin (10/9/2004) and verified by Kevin. This search
warrant has the correct date of birth listed for Kevin.

Based on the aforementioned information, I submit that there is probable cause to

believe that Kevin Hernandez’s DNA profile may be in the Chrysler 300 and/or on
the firearm, ammunition, and magazine found in Zahid’s bedroom. I request that
DNA buccal swabs be taken and to have them forensically examined in connection
with the evidence located at the scene of the homicide, in the suspect vehicle,
and on the firearm.

This affidavit has been reviewed by Alex Stoedter of the District Attorney Office, and
it has been approved for presentation to the court.

WHEREFORE, your affiant prays that a Search Warrant be issued for the seizure of
said items in the daytime.

I declare under criminal penalty of the State of Utah that the foregoing is true
and correct.

Executed on: 12th day of May, 2021 @ 08:14 PM by /s/ KELLY ZIERSE

- Page 6 of Affidavit for Search Warrant No. 2259181 -

 _________________________________________________________________

IN THE THIRD DISTRICT COURT - ALL DEPARTMENT

IN AND FOR SALT LAKE COUNTY, STATE OF UTAH

_________________________________________________

SEARCH WARRANT

No. 2259181

COUNTY OF SALT LAKE, STATE OF UTAH

To any peace officer in the State of Utah:

Proof by Affidavit made upon oath or written affirmation subscribed under criminal
penalty of the State of Utah having been made to me by Detective KELLY ZIERSE of
West Jordan Police Department, this day, I am satisfied that there is probable cause
to believe

THAT

On the person(s) of: Kevin Jonathan Hernandez

DOB: 10/9/2004
further described as an Hispanic male, about 5'07" tall, 150 lbs, with brown hair
and brown eyes;

In the City of West Jordan, County of Salt Lake, State of Utah, there is now certain
property or evidence described as:

DNA buccal swabs

and that said property or evidence:

Was unlawfully acquired or is unlawfully possessed;

has been used or is possessed for the purpose of being used to commit or
conceal the commission of an offense; or

is evidence of illegal conduct.

Affiant believes the property and evidence described above is evidence of the crime
or crimes of Criminal Homicide 76-5-201.

YOU ARE THEREFORE COMMANDED:

- Page 1 of Search Warrant No. 2259181 -

to make a search in the daytime of the above-named or described person, vehicle,
item, and/or premises for the herein-above described property or evidence and if you
find the same or any part thereof, retain such property in your custody subject to the
direction of a prosecutor or an order of this Court.

Dated: 12th day of May, 2021 @ 08:44 PM /s/

- Page 2 of Search Warrant No. 2259181 -

 RETURN TO SEARCH WARRANT

NO. 2259181

The personal property listed below or set out on the inventory attached hereto was
taken from the person of Kevin Jonathan Hernandez
DOB: 10/9/2004
further described as an Hispanic male, about 5'07" tall, 150 lbs, with brown hair and
brown eyes, by virtue of a search warrant dated the 12th day of May, 2021, and issued
by Magistrate MARK KOURIS of the THIRD DISTRICT COURT - ALL DEPARTMENT:

DNA Buccal

I, Detective KELLY ZIERSE of West Jordan Police Department, by whom this warrant
was executed, do swear that the above listed or below attached inventory contains a
true and detailed account of all the property taken by me under the warrant, on the
12th day of May, 2021.

All of the property taken by virtue of said warrant will be retained in my custody subject
to the order of this Court or of any other court in which the offense in respect to which
the property, or things taken, is triable.

I declare under criminal penalty of the State of Utah that the foregoing is true
and correct.

Executed on: 28th day of June, 2021 @ 12:44 PM by /s/ KELLY ZIERSE

- Page 1 of Return of Service for Search Warrant No. 2259181 -