STATE OF SOUTH DAKOTA IN CIRCUIT COURT SECOND JUDICIAL CIRCUIT COUNTY OF MINNEHAHA Defendant. STATE OF SOUTH DAKOTA AFFIDAVIT IN SUPPORT vs. OF ARREST WARRANT Alzoubaidi, Julia Jacquelyn DOB: 03/23/1984 11* Detective of the Sioux Falls Police Department and states that he is one of the of?cers in charge of the investigation of the above?styled matter. That your Affiant makes this Affidavit in support of the State?s Attorney's request for a warrant for the arrest of the above?named Defendant(s), and in compliance with SDCL and states as follows: 1. On 10ft 6/18 at 03:34 hours, Troopers from the Highway Patrol were dispatched to Minnesota Ave and I-229 in reference to a vehicle crash. Troopers soon discovered the crash was likely not the result of an accident and requested the assistance of the Sioux Falls Police Department. Based on this call for service, case number 2018-36290 was generated. 2. Responding of?cers were advised a white SUV was in the ditch and it appeared that it rolled during the crash. 3. South Dakota Highway Troopers Lord and Knutson were first on scene. As they made their way to the SUV, they heard splashing and meaning near the river. Trooper Lord located the Defendant face down in the water under a bridge that crossed a culvert, and pulled her to shore. The Defendant was I unresponsive; however, she was breathing and shivering. The temperature was 37 degrees with a wind chill of 32 degrees. 5 . .. 4. The Troopers located the victim. the Defendant's male child -- on the bank of the river, near the culvert. The child appeared to not be breathing and CPR was initiated. CPR continued until the arnval of Sioux Falls Fire. Trooper Lord noted - was wet and cold. - and his mother. the Defendant, were transported to Avera McKennan for treatment. As a result of assisting and the victim. Trooper Lord became fully submerged under water as he attempted to locate any other possible passengers in the vehicle. 5. Troopers noted that it was their impression, based on the location of the Defendant. the victim and me fact that they found the doors to the SUV to be closed except for the rear passenger's door (door next to child seat), that election from the vehicle into the river seemed unlikely. 6. A handwritten letter was discovered in the SUV. located on the center console. The letter was written by the Defendant and addressed to her husband. The Defendant wrote," i can't believe I'm doing this, but I left myself/us no other choice. We been continuing to research and -has mostly all of the signs of Reactive Attachment Disorder (RAD). The prognosis is poor and couldn't let him live a life of misery and pain, Most kiddos I know w/ the disorder are instutionalized, suicidal and homicidal and tortured souls. -doesn't deserve that. Please move on with your life. i have done nothing but caused you pain and been 7 At Avera McKennan ER. the Defendant was treated by staff. Officers present heard the Defendant describe to medical staff that she planned to kill the baby and herself. The Defendant described that she believed the baby had an attachment disorderand did not like to be held. When she picked the baby up, he would cry. The Defendant told the ER staff that her solution was to kill the baby and herself. The Defendant reported she was driving interstate speeds when the crash occurred and she has felt suicidal for the past two days. 8. -was moved from the ER to Pediatric intensive Care Unit for treatment of hypothermia. Additionally, ER staff reported the baby had water in its lungs. 9, Detectives spoke to medical staff caring for .who reported they warmed the baby's core temperature. Additionally, they were treating -for "Aspiration Pneumonia" or water in the lungs. Arrest Amazvit doc 1o. Detectives interviewed the Defendant's husband, -- --reported he was aware that the Defendant suffered from depression and anxiety and had not been taking medication during her recent pregnancy and period of breastfeeding. 11. According to _the Defendant would commonly awake at about 2 am. to "pump" breast milk. did not think it was unusual that when he woke up, the Defendant was not in bed. _then fell back to sleep and was woken up by Police Officers knocking at the door at about 4 am. Additionally; reported he and the Defendant had a good weekend. He was aware the Defendant was concerned about Reactive Attachment Disorder, as it related to their child. He stated he did his best to calm the Defendant and rte--direct her thoughts. stated he was unaware of any plans the Defendant may have had to hurt herself or their child. 12 Detectives interviewed the Defendant at Avera McKennan. The Defendant reported she has thought of suicide recently and began to think of driving a car off the road to kill herself and her child. The Defendant stated she did not think her child was bonding with her and she felt inadequate as a mother. The Defendant, a Clinical Phycologisl. sought assistance and advice from her peers and colleagues, This intervention helped for a time, and then she stated her thoughts would eventually turn to ending her life. 13. On the morning of Tuesday, October 16, 2018, the Defendant stated she awake and gathered her child. She got into her 2010 Mazda CX-5 and drove on the interstate. As she passed Minnesota Ave on I-229, she intentionally drove into the ditch on the south side of the roadway in an attempt to kill herself and her child. 14. Computer data from the vehicle indicate the vehicle accelerated from 50 to 70 just prior to the crash. with no braking. 15. The Defendant recalled coming too after crashing the car and opening the rear passenger's door. She stated she thinks she removed her child and carried the baby. The Defendant believed she might have walked toward the river. where she tripped, She stated the baby might have fallen into the water at that time. Arrest Amt-vii doc 16. Detectives challenged the Defendant?s comment, explaining that she just attempted to kill her child. and she discovered the child was not dead. The Defendant was asked if she carried the child to the water to place the child in water. The Defendant reported her recollection. of this incident was fuzzy, however she stated it may have been possible. 17. The Defendant said she then placed the child on the bank of the river and went to a near-by high spot and jumped into the water, attempting to end her life. The water was shallow, about two feet deep. The Defendant said she may have jumped two separate times, subsequently injuring her leg. Medical staff reported the Defendant's right leg might be broken at the ankle. 18. The Defendant remained in the water, under a bridge on the bike path, until 19. Your af?ant swears that these eyents occurred in the City of Sioux Falls, Minnehaha County, State of South Dakota. Jonathan Carda Subscribed and sworn before me this day of gammy 20 Via i-Weemwweag: 5: Angela McVay NOTARY PUBLIC {we ,1 .i SOUTH DAKOTA ~54: iW W21 My commission Emmi: - . .D . Clerk Circuit Court 82018