E-FILED 2019 OCT 28 3:25 PM JOHNSON - CLERK OF DISTRICT COURT IN THE IOWA DISTRICT COURT IN AND FOR JOHNSON COUNTY STATE OF IOWA, DCI Case No. 2019?009335 Plaintiff, v. Criminal No. ROY CARL BROWNING JR., COMPLAINT Address: 114 Green Mountain Dr. Iowa City, IA 52245 DOB: April 27, 1952 Defendant. STATE OF IOWA ss. JOHNSON COUNTY) 1, Derek Riessen, being ?rst duly sworn on oath or on af?rmation, accuse ROY CARL BROWNING JR., the Defendant, of the crime of MURDER IN THE FIRST DEGREE committed as follows: The said defendant, having malice aforethought, on or about APRIL 5, 2019, did will?Jlly, deliberately, and with premeditation kill JOELLEN WALL BROWNING, in the county of Johnson and State of Iowa in violation of Iowa Criminal Code Sections 707.] and COWLAINANT Address: 22365 20th Ave Stockton, IA 52769 Subscribed, sworn and acknowledged before me by Reagan Complainant, thisch8 day of 0mm 20 l? . A. (Magistrate) (District Court Clerk) 0 (District?oanC?QFli'S Deputy) (Notary Public) MARCIA Commission Number 728520 My 50377590" pll'ES- low .5 5? 65732 E-FILED 2019 OCT 28 3:25 PM JOHNSON - CLERK OF DISTRICT COURT AFFIDAVIT OF PROBABLE CAUSE STATE OF IOWA, COUNTY OF JOHNSON, SS: 1, Derek Ricssen of the Iowa Division of Criminal Investigation, state the following facts known by me or told to me by other reliable persons, form the basis for my belief that the Defendant committed the crime of MURDER in the 15? degree: On Friday, April 5, 2019, at 6:59 am, a 911 call was made by ROY CARL BROWNING .IR. who reported ?nding his wife, JOELLEN BROWNING, age 65, unresponsive. First responders found her deceased lying on her bedroom floor at her residence located at 114 Green Mountain Drive in Iowa City, Johnson County, IA at 7:07 AM. An autopsy showed she had been stabbed multiple times in the front and back of her torso and on her left hand. The forensic pathologist of the University of Iowa Decedent Care Center determined the cause of death was sharp force injuries and the manner was homicide. Investigators did not ?nd any signs of forced entry into the home. Blood evidence was found in areas in the home include outside the master bedroom and in the master bedroom shower. This evidence, along with evidence obtained at the autopsy, was collected by the Iowa City Police Department?s Crime Scene Team and was submitted to the Iowa DCI Laboratory in Ankeny, IA for testing. Results from testing indicated the presence of blood on the right hand nail clippings of JOELLEN BROWNING, which showed a mixture of DNA from two individuals. Assuming the DNA presence of JOELLEN BROWNING, the partial profile of the second contributor belongs to ROY BROWNING. The probability of ?nding this pro?le in a population of unrelated individuals, chosen at random, would be less than I out of 310 trillion. The DNA report showed JOELLEN profile was discovered in blood on the front storm door handle of the home and in the bathroom shower of her home. Photographs of multiple apparent banking records of JOBLLEN BROWNING and ROY BROWNING found at their home were compared to known records of the banks. There were numerous discrepancies between the documents, including a listing of a non-existent account in the photographed record. Another discrepancy in an account owned by JOELLEN and ROY BROWNING showed an account balance of $97,830.17 in the photographed apparent statement, dated December 31, 2013. The records provided by ?nancial institution for the same account showed an actual balance of $83.76 for the same statement period. The photographed statement was also missing the line ?Interest Paid This Year?. Further review of the actual bank account showed the money was removed from thisjoint account and placed into an account owned solely by ROY BROWING. A review of the cellular phones and email accounts belonging to ROY and JOELLBN BROWNING showed an email dated April 1, 2019 at 12:01 pm, sent from IOELLEN to ROY. In the email JOELLEN was questioning ROY as to why there were discrepancies in their bank accounts. In this email, .IOELLEN instructed ROY to contact their financial representative and make sure ROY could log on to the account so the could review those accounts that night. While reviewing cellular records, investigators discovered a text message sent from IOELLEN to ROY at 1:12pm on April 4, 2019, informing him of the meeting JOELLEN had scheduled for them with their ?nancial institution. JOELLEN asked ROY if he knew that they were able to meet with the institution on Friday April 5, 2019I at Sam. On April 4, 2019 at 1:33pm, Roy responded, ?Yes?1 to IOELLEN, indicating he was aware of the meeting. On April 4, 2019 ROY BROWNING went to an area paint supply store and purchased rubber palmed nitrile gloves, a package of six white towels and was given 8?10 latex gloves free of charge. The paint store only sold latex gloves in boxes of 100 and ROY BROWNING had stated he didn?t want that many so the employee just gave ROY BROWNING a few gloves from behind the desk. The employee provided the receipt for this purchase to investigators, which was dated April 4, 2019 at 1:51 pm. Video footage in the area of the store showed a vehicle matching ROY driving past the camera on April 4, 2019 at approximately 2:02 pm. E-FILED 2019 OCT 28 3:25 PM JOHNSON - CLERK OF DISTRICT COURT Multiple searches were conducted, beginning on April 5, 2019 and continued for the next several days of the BROWNING residence, vehicles, business and person and at no time did investigators locate the items determined to have been purchased by ROY BROWNING at the paint supply store. Records showed that ROY BROWNING took out separate loans for $4,000 on four different occasions from an Illinois area title and loan company. Each loan had an interest rate of 304.1 The last loan was paid off on April 2, 2019. Investigators found that ROY BROWNING informed the title company on February 13, 2018, they were not to contact his wife, JOELIJEN BROWNING, regarding the title loan. A representative of the financial institution used by the was scheduled to meet on Friday, April 5, 2019 at 3:00 AM with JOELLEN and ROY BROWNING. The meeting reportedly was set because JOELLEN was preparing for tax season and had found some problems with ROY and accounts and wanted to meet with the representative in order to ?gure things out. The representative was prepared to tell JOELLEN at this meeting that one of their savings accounts was depleted and ROY had taken out loans of which OELLEN was not aware. The representative was prepared to tell JOELLEN that an account JOELLEN thought was active never actually existed. While reviewing credit card records in a credit card in the name of JOELIEN BROWNING, investigators noticed one of the credit cards had a balance of $171,643.86 according to the March 7' April 6, 2019 statement. The following month?s statement, April 7 May 6, 2019, revealed that a payment of $17,643.86 was made by phone on April 12, 2019, to the credit card company from ROY individual checking account. The credit card statement also showed this credit card was continuing to be used even after funeral on April 11, 2019. JOELLEN BROWNING had a retirement account and life insurance policy worth in excess of $2 million. In reviewing ?nances, records show that JOELLEN BROWNING was ?nancially stable and ROY BROWNING did not have a revenue source. The above crime occurred in Iowa City, IA which is located in Johnson County and the State of Iowa. . .71 7' Signature {in Subscribed and sworn to before me on this 69.2 3 day of 52(? 2019 L12 ("Notary Publi?f (Deputy) Clerk 1? Magi?late Number T285211 . - My sio Expires moi $1263 6? ??35