.UW 15 ked Cases f5 m2 7/201 I NDICTMENT EWCROO Manslaughter if c. 265, ?13 00 I SUFFOLK, SS At the SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT FOR CRIMINAL BUSINESS, begun and holden at the CITY OF BOSTON, within and for the County of Suffolk, on the ?rst Monday of October in the year of our Lord two thousand nineteen - THE URORS for the COMMONWEALTH OF MASSACHUSETTS on their oath present that INYOUNG YOU on May 20, 2019, did assault and beat Alexander Urtula, and by such assault and beating did kill Alexander Urtula. A TRUE BILL 99/0 3. Members of the family of Inyoung YOU reside locally. A public indictment would allow the family members to communicate the information to the Defendant. 4. A Sealed Indictment and Warrant are necessary to ensure that the Defendant does not learn of the charges before arrest, thereby causing her to remain out of the country or leave the country if she has returned. If made public, this information could also prevent police 'from ascertaining her exact whereabouts in South Korea. The District Attorney?s Office along with the Boston'Police' Department will investigate the proper process to secure the arrest of the Defendant and is prepared to effectuate an arrest in a manner that will minimize the risk of any further ?ight and danger to of?cers and the public, but these plans would be jeopardized by the arrest warrant going into the warrant management system. Respectfully submitted For the Commonwealth, RACHAEL ROLLINS . . DISTRICT 4 ?9 . #2 SuffolkCountyDiwICtAmrB 9 .. One Bul?nch Piece . Boston MA 02114:' (517) 51194900 6,3341?3? l?lw: . COMMONWEALTH OF SUFFOLK, SS SUPERIOR COURT DEPARTMENT TRIAL COURT DIVISION GRAND JURY AFFIDAVIT OF COMMONWEALTH (1) I am the Assistant District Attorney assigned to this investigation. (2) After revieWing all of the'evidence, charges, and any records of the suspect, I believe that there would be a further risk of ?ight or concealment if the indictment is made public prior to the arrest of the suspect. (3) I have discussed a plan to execute the arrest warrant with members of the Boston Police Department. I believe that this execution, which may include Extradition, is only possible with secret] impounded warrants, and will be the safest and - most effective way to procure the suspect's presence before the Court to answer on these indictments. Respectfully submitted For the Commonwealth, RACHAEL ROLLINS DISTRICT ATTORNEY summons To mm: Trlal court of Massachusetts DEFENDANT 1mgoos17 The Court ORIGINAL IN THE or: on; NO. coums Maura A, Henni . Clerk of Court Commit: v. Inyourg You {39,13,19ng 1 m: ADDRESS OF DEFENDANT Data-mm; a ADDRESS Invounn You Suffolk County Supei'ior Court - Criminal 99 Street Su?dk Countv Courthouse. 14th Floor MA 02135 Throe Pombe?nn Square Boston, MA 02108 ?Tum YOUHUBT META pouce 1 112212019 09:00 AM ?goat?. ABOVE SCHEDULE) EVENT comm on 11113 DATE Amimment W's Session FIRST FIVE OFFENSE com 9mm rm: mm 1 265mm MANSLAUGHTER c255 ?13 W019 TO THE ABOVE-NAMED DEFENDANT: You are tun-by amend toappurln this com-ton til-date and-time alumna) IWYW- hrbetontho schedulademt. :11erch Tom Ifyoufa?toappearin Yourwll?ul'fallureto appear Is a contempt by??eortmp?s?ahmem. as a resultd yourdefault maybeassessed againstyou ascosts. FURTHH ORDERS OFTHE GMT 333mg DOCKET NUMBER MITTIMUS IN LIEU OF BAIL Trial Court of Massachusetts The Superior Court r? a COURT FILE COPY 19840R00617 DEFENDANT NAME lnyoung You DEFENDANT DOB GENDER PCP Maura A. Hennigan. Clerk of Court 09f16/1998 Female 5514265 NAME 8- ADDRESS OF COURT NAME 8- ADDRESS Suffolk House of Correction (South Bay) Suffolk County Superior Court - Criminal 20 Bradston Street Suffolk County Courthouse. 14th Floor 30533?- MA 021 1 3 Three Pemberton Square Boston, MA 02108 FIRST FIVE OFFENSE COUNTS scum cone mam 1 265f13fA MANSLAUGHTER c265 ?13 053012019 BAIL SET BY COURT $5,000.00 CASH $50,000.00 SURETY TO THE SHERIFF OF THE SEVERAL COUNTIES: The defendant named above has failed to recognize for his or her next court appearance in the amount ordered by the Court The Court has therefore ORDERED that the defendant be committed to the above institution in lieu of posting the bail indicated above. and there await his or her next court appearance at the court location of next event. Any duly authorized officer rs hereby ORDERED to convey and deliver the defendant safely to such institution and to make return thereon The of?cial "1 charge of such institution is hereby ORDERED to receive the defendant into custody, to keep the defendant safely unless the defendant posts ball as ordered or is otherwise legally discharged before such date. FURTHER ORDERS OF THE COURT: COB: 1. Surrender Passport prior to release DATE ISSUED OF CLERK-MAGISTRATE i ASST. CLERK CHIEF JUSTICE WITNESS: Hon. Judith Fabricant conveying o?cerhereby certifies that he or she has conveyed the defendant to the institution named above. along the original of this .The receiving omcer hereby certi?es that he or she has received the defendant on behalf of the of?cial in charge of such When will. a . .. .- . sromwseornecswmeorriow. mums A?mm Wm Wm mammal?! mes-worm mm I DPeti?mf ofEh? UChangedC?rcumstancea A?nrhming. 5/ Missgats cash,m'$ smety W1 .Qma'- - mam In 40.5 CI agda?a- c.276, calamor?mcommunity. ?ue Pay (check allthat aHiy) topostbailof$?1000 cash. This?ndingisbasedupon: ProbMintake anescnm?onof: El Other: - El Regan: tor'Set?ngnaiL 1 ?ndthat: appearanceat?rture ifany. l3 ?xmrecom-tproceedhg andnoaltema?ve, [as defmdam's presence at future count proceedings. In setting I have cansidued the following factors: The charged offense (strength of case/nature and circmtances/pmn'nl pmahy). Iain: - defendant's ?eslres?ence in commitylumal iilwaslsuhstance Etphin: Th: frh?nalhimry (cpnvic?ons/crimw while on bail on: court alpavisimlproba?on vialations). mm; no amr [4:5an :1 Restra'ming min (alleged conduct is "abhse" areslraining afresh-ailing ordas). poem). mm;- ?ml: b- mbyihecmdim gamma: and. :1 . . r??A A ?1lill. BY March of 2019, the defendant succeeded in isolating Urtula from all of his friends from Boston College, individuals whom the defendant viewed as a threat to their relationship. She required Urtula to block their telephone numbers and on social media and to send her screenshots and screen recordings of both his blocked caller list and text messaging history to prove he was not communicating with them. Within the text messages themselves, the defendant was the one constantly driving the talk of suicide (both her desire to harm herself and for Urtula to kill himself). Starting in mid to late March 2019 until the time of Urtula?s death, the defendant repeatedly texted him to ?go kill yourself,? ?go die,? and told him that her life, his family?s life, and the world would be better off without him in it. For example the defendant wrote: I ?do everyone a favor and go fucking kill yourself, you?re such a fucking stupid ass worthless just fucking do everybody a favor and go fucking kill yourself honestly. Fucking WORTHLESS ASS FUCKING PIECE OF SHIT DESERVE NOTHING IN THE FUCKING (5/5/2019, 10:49 am) In particular, much of this talk stemmed ?'om the defendant?s ?xation with Urtula?s upcoming graduation ceremony and the fact that he may interact with friends, including his ex-girl?iend, writing: GONNA LITERALLY FUCKING SEE ALL OF MAN FUCKING PIECE OF SHIT GO FUCKING DIE IN HELL YOU DESERVE TO GO FUCKING KILL YOURSELF. . A MAIN CEREMONY WITH ALL OF YOU AND YOU LIE AND SAY YOU SEE THEM AT YOU FUCKING GO KILL YOURSELF LEAVE ME THE FUCK ALONE AND IF YOU DIE GONNA FUCKING KILL YOU STILL TELL ME ABOUT THE MAIN CEREMONY EYENAFTER THE 1 LITERALLY FUCKING FOINTED IT - MY GOD YOU LITERALLY I WANT TO BASH YOUR HEAD AGAINST - .. YOU GO FUCKING HIT YOUR FUCKING HEAD ON THE SINK g; '6 ma LITERALLY A PIECE OF FUCKING SHIT YOU n. I FUCKING DIE BC OR ELSE LIIEKALLY GONNA I 7 -: AGAIN HOW FUCKING YOU ARE LIKE IF ,4 MET SOMEONEBODY As FUCKING TO GO KILL - t? limits? And again, in a text to Urtula four days before his suicide, the defendant wrote: It 13 gema take at graduation is for someone to come up to you and pull you aside or come running to you and hugging you and you will just fucking do everything again to disreSpect me and break your promise FUCK YOU GO FUCKING KILL YOURSELF AND EVERYONE THAT TOXIC GROUP THEY ALL DESERVE TO FUCKING (5/16/2019, 1:28 PM). The defendant also repeatedly usedof threats of self-harm and suicide to get Urtula to do something; i.e. she would threaten that if Urtula did not do she would harm and/or kill herself, often going into great detail about the manner and means in which she intended to commit suicide. The defendant would make these threats when Urtula wasn?t responding fast enough to her phone calls or texts, when he was asking for space during an argument or for permission to go to sleep, or when Urtula was expressing reluctance to agree to certain unreasonable demands such as cutting off communications with all of his ?iends from Boston College. While making these threats, the defendant would tell Urtula that he was the sole reason or cause. For example, two days before Urtula?s death, the defendant wrote: ?u can?t ?gure it out? wanna make me livid again? want me to slash my throat? Is that what want? like why do I have to threaten my own fucking life for to ?nally do something? did I NOT FUCKING TELL TO READ NOW IF YOU DO NOT FUCKING READ IT RIGHT NOW LITERALLY GOING TO FUCKING SLASH MY THROAT AND TAKE A VIDEO SAYING IT WAS BECAUSE OF YOU AND THAT I WANT YOU TO SEE IT IS THAT WHAT YOU FUCKING WANT YOU IDIOTIC WORTI-ILESS FUCKING SHITHEAD is that what you want? I have to fucking threaten my life for to listen to me?. . .you literally end up doing what I fucking want fight (5/18/2019, 1:25 pm) Theeh?cienoe also establishes that the defendant was aware that her conduct was both vpunishable. For example, in one text message, the defendant told -. 1.2- a suicide note behind, blaming Urtula, and expressed her hdpe - ?lth 5.: It also told Urtula that she would 1min sure ha? A ., by publicany ?mung? mm mm. VideOtaPed suicide note or social media post, and that he would be banned from attending her funeral. In reSponse to these text messages, Urtula repeatedly told the defendant that he would do anything she told him to do in order to make her happy and to get her to stop harming herself and/ or prevent her from committing suicide, even if it was taking his own life. For example, Urtula told her: ?Inyoung please I?ll give you whatever you want. .1?11 leave this fucking earth just please don do anything don?t hurt yourself anymore. . . .so please I?ll get out of your life I?ll go d1e like you I?ll erase myself from this probably be better off and I 11 go I?ll do don?t have anything anymore anyways if I don?t have whatever you own literally do whatever you just don?t ?icking hurt yourself anymore. . . .Please. . . .I?ll go die for you. . . .whatever will make you happy? (4/11/19, 11:39 pm). Medical records revealed that prior to his relationship with the defendant, Urtula had no documented mental health issues nor did he exhibit or express any signs of depression of suicidal thoughts. Family and friends of Urtula would also testify that to their knowledge, Urtula had never been treated for any mental health disorder and had never exhibited any suicidal ideations or suicidal behaviors. His handwritten journal entries prior to January 2018 contain no references to depression or thoughts of self-harm/suicide. In stark contrast, Urtula?s journal entries from March of 2019 demonstrate the profound effect the defendant had on Urtula?s mental health: we argue it always reverts back to the past her before and how she doesn?t believe that it won?t happen again Then I when I agree to end it because she says she?s done with me because I?m a horrible retarded ?ick up that is just a burden on everyone ?s lije,? she in turn threatens to kill herself because of me. (3/26/2019) an the two demonstrate the defendant?s knowledge of Urmla:s ?She attacks my self-war and how I lied and hurt . . I :tn'm ?701.115. g0 i In). he ?wasn?t the victim" and to ?stop making himself seem like a victim?. For example, the defendant told Urtula: THINK I ABUSE WANNA SAY I ABUSE THAT FUCKING IDIOTIC AND STUPID REALLY COURSE A VICTIM OF SHITTING ME what?s wrong with you you?re actually that fucking worthless you wanna act like a victim and call it abuse is that what tell your brother? ur friends? Or is that what they?ve told please I?m cmious I?m so tell me how you?re the victim here please enlighten me FUCKING ANSWER WORTHLESS FUCKING PIECE OF (4/29/2019, 11:42 AM) The defendant continued to pursue talk of self-harm and/or suicide, even when Urtula would repeatedly ask her to stop and told her that this behavior was causing him to experience panic- attacks and damaging his self-worth, and, in turn, develop his own thoughts of suicide. For example, Urtula told her: asked you to stop so many times. . .you don?t even know what?s going on in my head really can?t talk to breaking doWn and I?m if you want to keep shitting on me you have every right having the worst anxiety attack of my life. shaking on the couch. . .huddled up into a ball. . .biting a pillow so Brian and the kids don?t wake up from my the voices are so' fucking loud and they all have your person I love most in the all telling me to so did want you and the voices to stop telling me how worthless and pathetic I am. . .and how much I deserve to die.? (3/3 112019, 11:07 pm). The defendant was present on the roof of the Renaissance Parking Garage when Urtula committed suicide, and that location had signi?cance within the context of their relationship, as the defendant had previously threatened to harm herself at that very location in late'2018. Despite being aware of both Urtula?s intentions and the Signi?cance ofthat location, theSmestigators that she had ?no idea? Why Urtul?a would have gone to ?mt garageammonia-1 ., if" .ww1thpohce,thedefend%6m a a" a ., . the Commonwealth will establish causation through the testimony of an expert in the Finally, ?eld 0f mental disorders and Suicidology who reviewed all the evidence in the case Includlng but not limited to Urtula?s medical and academic records, his journal entries, and his and the defendant?s text messages, and conducted a autopsy of Urtula. The expert opined that Urtula had virtually no risk factors for suicide, other than being a young male prior to his relationship with the defendant nor did behave common risk factors seen in completed suicides such as a major illness, substance abuse, personality disorder, family history of suicide nor prior evidence of suicidal thinking or behavior. The expert further opined that the abuswe nature of relationship between the defendant and Urtula, and the abuse that the defendant in?icted on Urtula, overbore Urtula?s will to live and was the cause of his suicide (2) Failure to Act In the context of their personal relationship, the defendant?s abuse of Urtula created a life-threatening condition that gave rise to a duty to takeireasonable steps to allev1ate the risk created and her failure to do so rises to the level of recklessness necessary for involuntary manslaughter The defendant had urged Urtula to kill-himself on numerous occasions and on the morning of Urtula?s death, she knew exactly where to ?ndhim?she had his GPS location approxrmately 55 minutes before his death?what his intentions were, and the signi?cance of the Rmmasance i?arking Garage in the context of threatened suicide, but the evidence establishes he expressed his intentions via text I . l- 2000 Commonwealth Avenue in 1 ?.1167;