PEACE OFFICER'S AFFIDAVIT FOR WARRANT OF ARREST STATE OF TEXAS =X COUNTY OF DALLAS X GITY OF IRVING. x "IN THE NAME AND BY THE AUTHORITY OF THE STATE OF TEXAS" | KEVIN BURKLEO #845, A PEACE OFFICER OF THE CITY OF IRVING, DALLAS. COUNTY, TEXAS, 00 SOLEMNLY SWEAR THAT | HAVE GOOD REASON TO BELIEVE AND DO BELIEVE THAT PATRICIA DENISE ALLEN, HEREIN CALLED. ‘THE DEFENDANT, ON THE 24TH DAY OF JUNE, 2016, IN DALLAS COUNTY, ‘TEXAS, DID THEN AND THERE COMMIT THE OFFENSE OF INJURY TO A CHILD / ‘SERIOUS BODILY INJURY, P.C. 22.04, A SECOND DEGREE FELONY, AFFIANT'S BELIEF IS BASED UPON THE FOLLOWING FACTS: (On 06/24/2015 at approximately 1545 hours, three children drowned while in a community pool at 2346 N. MacArthur Bivd., Irving, Dallas County, Texas. All three children were pronounced deceased at the hospital. The investigation into the incident has found that the mother of the three children, the defendant, decided to take her five young children to the pool by herself. The deceased children were Anthony Smith (11 years of age), August Smith (10 years of age), and Treshawn Smith (9 years of age). The defendant also brought her other daughter, Genisus (6 years of age}, and her other son, King (3 years of age), to the pool. The defendant said that she cannot swim other than to float and tread. water and that none of her children can swim other than to float on their backs or tread water. None of the six of them have had any type of swimming lessons according to the defendant. The pool was very dirty and murky making the bottom of the deep end of the pool invisible, A.witness that was at the pool prior to the drownings said that he believed the defendant to be texting and using her phone while she was attending to the 3- year-old on the side of the pool. The witness said that the 3-year-old was crying a lot. The witness also said that none of the children had on atm floaties or any other flotation devices. ‘Two other witnesses said that they observed the defendant sitting in the pool, on the steps, facing the deep end with the 3-year-old and 6-year-old, but that they could not see the 3 other children as they were walking from their car to the pool area. They said thatas they wore walking up, the water was calm and there were ‘no bubbles or splashing from the deep end, leading them to believe there were no children in distress. They indicated that even though the defendant was facing her children, she did not recognize that her childron had disappeared under the surface of the water until the witnesses had came inside the pool area, which was, when she realized they wore missing, ‘Tho affiant believes that the dofendant recklessly caused the serious bodily injury resulting in the death of 3 of her 5 children by taking them to the pool under the above circumstances. Based upon the above facts and circumstances, the Affiant requests that aTRS #. warrant of arrest be issued for the defendant, PATRICIA DENISE ALLEN, for the oftanae of MAURY TO ACHILD SERIOUS BODLY INJURY, Pc. 22.084 SEconn nraRee ret on lenlff AFFIANT ‘SWORN TO AND SUBSCRIBED BEFORE ME BY K. Burkdco #845. ‘ON THIS THE _\O)_ DAY OF 2018 Brie. Key WaeTRRTESR be) esse ASSISTANT CRIMINAL DISTRICT __ “irate” ATTORNEY OF DALLAS COUNTY, TEXAS