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_________________________________________________________________

IN THE FOURTH DISTRICT COURT - ALL DEPARTMENT

IN AND FOR UTAH COUNTY, STATE OF UTAH

_________________________________________________

AFFIDAVIT FOR SEARCH WARRANT

STATE OF UTAH )
:ss
County of Utah )

The undersigned affiant, Detective DALLIN ROBIN TURNER of Utah County Sheriff's
Office, upon an oath or written affidavit subscribed under criminal penalty, declares:

That your affiant has reason to believe:

THAT

On the premises known as On the premises known as


https://www.facebook.com, further described as Facebook Inc, the social media
website company.;

On the item(s) described as: The Facebook account belonging to Adam Lake
which is https://www.facebook.com/Muddlake;

In the City of Spanish Fork, County of Utah, State of Utah, there is now certain property
or evidence described as:

1. All Facebook Messenger messages, all details on phone calls made using
Messenger, and all deleted messages relating to Facebook Messenger, and

contact lists associated with Messenger specific to Lehi City, Ben Johnson,
Wade Allred, Vinco Enterprises, as well as the distribution and obtaining funds
or products.

2. All lists of “Friends” and contacts associated through Facebook, specific


to Lehi City, Ben Johnson, Wade Allred, Vinco Enterprises, as well as the
distribution and obtaining funds or products.

3. All associated email addresses or account information specific to Lehi City,


Ben Johnson, Wade Allred, Vinco Enterprises, as well as the distribution and
obtaining funds or products.

- Page 1 of Affidavit for Search Warrant No. 1990401 -


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 Embezzlement- UCA 76-4-403- Felony 2 (Over $5000)..

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

I have been a law enforcement officer for 8 years. I began my career with the Salt
Lake County Sheriff's office where I was a corrections officer. While employed at
the jail, I was assigned to the booking an intake area of the jail. While working
in the facility, I searched multiple prisoners as they entered the jail. I located
marijuana on multiple prisoners and am knowledgeable of the appearance and
odor of marijuana.

After working for 4 years at the jail I was hired and employed by the West Jordan
Police Department where I was assigned to the patrol division. I responded on
multiple calls related to the use, sell and possession of illegal narcotics. I have
seized multiple types of illegal narcotics to include, marijuana, meth, herion and
have been trained on the appearance of all illegal narcotics. I also responded and
made many arrests in relation to thefts of property, firearms, and possession of
stolen property.

I have most recently been employed by the Utah County Sheriff's office where
I have continued to make multiple arrests involving illegal narcotics and thefts
while assigned to the patrol unit. I am currently assigned to the Investigations
division of the Sheriff's Office where I continue to investigate crimes related to
illegal narcotics, thefts, deception and possession of stolen property.

While employed as a Law Enforcement Officer, I have attended multiple training


related to the detection of illegal narcotics, their appearance and common items
used to ingest said controlled substances.

In working in my law enforcement career, I have had training and experience in


locating missing people. I have been trained and taught cell phones are a vital
tool in locating missing or individuals and ruling out foul play.

I met with Jason walker (Lehi City Administrator), Dave Dorman (Public Works
Director) and Sgt. J. Chappell. Dave told me that he has been the Public Works
Director for the past few years. Dave was alerted to a financial issue that

- Page 2 of Affidavit for Search Warrant No. 1990401 -


was brought to his attention by an employee. A work order didn’t match with
work performed, further investigation showed that labor and materials related to
the street department might never have received construction product that was
purchased by the city.

Dave Norman looked into the situation and found that all of the purchases went
through Wade Allred, the Streets Department Superintendent. Dave found that
there were orders made for road salting sand and other road related aggregate
ordered from Vinco Enterprises. Dave found this to be concerning since the City
contracted their road work through Geneva Rock. The invoices provided from
Vinco were not itemized; however, the reason for the use of Vinco was justified by
availability. Dave contacted Geneva Rock and asked them about their aggregate
stock and he was informed that they keep stock well beyond what the city of Lehi
could ever need.

Dave looked further into the company and discovered that Vinco is located in
Cedar City Utah and that it is owned by Wade Allred’s cousin, Adam Garth Lake.

I interviewed Wade Allred and he assured me that all of the loads were delivered
and accounted for. He went on to explain that he used Vinco and that his contact
is named Jim. Wade told me about how he used Vinco to deliver sand for salting
the roads, road salt and other aggregate for buildings and roadways. He told me
how the sand and salt was mixed and how his crew had to clean it up, as required
by state law.

I interviewed BJ Benson who is Wade Allred’s assistant. BJ told me that the city
does not mix the salt and the sand. He also told me that the city gets its road
salt from Robinson’s Trucking and that they get their salt from Redmond Salt. I
asked him if they had salt delivered from any other companies and he told me
no. I asked him if he had ever heard of Vinco and he told me no. I showed him
the list of purchases from Vinco and I asked him if any of them appeared to be
legitimate and he told me no.

I interviewed Kenneth Monson who is the heavy machinery operator for the City
of Lehi. Kenneth told me that he takes delivery of salt and opperates the heavy
loader to stack the salt in the city’s salt bay. I asked him who delivers the salt and
how is that done. He told me that Robinson trucking delivers salt from Redmond
salt. The trucks drop the salt in the bay with conveyer belt trailers and he stacks
the salt with his loader. He then would take the truckers ticket and it would get
returned to the city offices. I asked him if anyone else loaded the salt and he told
me that he nearly always loads the salt. I asked him if he had heard of Vinco and
he said no. I showed him the invoices and he told me that he didn’t believe that
any of the salt loads had been delivered. I asked him about mixing salt with sand
for the roadways and he told me that they hadn’t done that for over years.

- Page 3 of Affidavit for Search Warrant No. 1990401 -


I interviewed Ryan Brewster who informed me that he is the crew foreman for the
Lehi City Streets Department and he has been in that position for 3-4 months.
Prior to that he was over the concrete crew for about 5 years prior. I asked him if
he was aware of any other trucking company who delivered salt to the city and he
told me that he was only aware of Robinson Trucking. I asked him if he had ever
heard of Vinco and he told me no. I showed him the spreadsheet of the deliveries
from Vinco and asked him if he was aware of any of the deliveries and he told me
that he was not aware of anything from Vinco. Ryan saw the billing for the road
base and he told me that they produce their own road base and none of it gets
imported. He also said they produce their own millings. I asked him if the salt for
the roads was ever mixed with the sand and he told me no, not in the 5 years that
I've been there. I asked him if any of the Vinco deliveries were legitimate and he
told me no that he had never heard of the company. I asked him if he knew Adam
Lake and he told me no.

I spoke with Josh Jenson who is the superintendent with Geneva Rock who told
me that they have the streets contract with Lehi City. I asked Josh if he was
familiar with Vinco and he told me no. I showed Josh the invoices from Vinco that
showed to be delivered to his job sites. Josh told me that would not have happened
because they use their own road base. He told me that the amount shown (900
tons) would have been way more than the job would have even been required.

I met with Adam Lake who told me that he is the sole owner of Vinco Enterprises.
Adam told me that he had been doing business with Lehi City since 2014. Adam
told me that Wade is his cousin and that their mothers are sisters. Adam told me
that Wade would call him and request product. Adam would then subcontract to a
male known only as Ben Johnson. Adam would prepay for the product and then
pay Ben for the labor after the load was delivered. He said that Bed drove an old
dump truck and would deliver the product to Wade and Wade would verify that the
load was delivered. Adam paid Ben in cash or fuel and could only contact him via
facebook messenger or watts app. I asked for further information on Ben Johnson
but he could not produce anything further.

I have made attempts to identify Ben Johnson by using Facebook, local files and
DMV with negative results. It is my opinion that most, if not all, of the loads were
billed but not delivered. Lehi City showed that the total amount of business with
Vinco Enterprises is $791,582,20.

In my experience Facebook is commonly used for criminal conduct. Criminals


are able to meet, make contacts and conduct business. Facebook messenger
is commonly used as private communication between parties arranging criminal
conduct.

I am requesting access to Adam Lake's Facebook information so that I can verify


his contacts and business dealings as they relate to his communication with Ben

- Page 4 of Affidavit for Search Warrant No. 1990401 -


Johnson. Adam provided information that had done his business dealings with
Ben Johnson via Facebook Messenger and he showed me messages back to
the time when he was first interviewed by detectives (08/22/2019); However he
couldn't provide anything prior to that because his previous phone was destroyed.
I believe that obtaining Facebook information will prove that prior contact with Ben
Johnson did not occur and that an embezzlement was committed.

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: 18th day of September, 2019 @ 02:24 PM by /s/ DALLIN ROBIN
TURNER

- Page 5 of Affidavit for Search Warrant No. 1990401 -


_________________________________________________________________

IN THE FOURTH DISTRICT COURT - ALL DEPARTMENT

IN AND FOR UTAH COUNTY, STATE OF UTAH

_________________________________________________

SEARCH WARRANT

No. 1990401

COUNTY OF UTAH, 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 DALLIN ROBIN
TURNER of Utah County Sheriff's Office, this day, I am satisfied that there is probable
cause to believe

THAT

On the premises known as On the premises known as


https://www.facebook.com, further described as Facebook Inc, the social media
website company.;

On the items(s) described as: The Facebook account belonging to Adam Lake
which is https://www.facebook.com/Muddlake;

In the City of Spanish Fork, County of Utah, State of Utah, there is now certain property
or evidence described as:

1. All Facebook Messenger messages, all details on phone calls made using
Messenger, and all deleted messages relating to Facebook Messenger, and

contact lists associated with Messenger specific to Lehi City, Ben Johnson,
Wade Allred, Vinco Enterprises, as well as the distribution and obtaining funds
or products.

2. All lists of “Friends” and contacts associated through Facebook, specific


to Lehi City, Ben Johnson, Wade Allred, Vinco Enterprises, as well as the
distribution and obtaining funds or products.

- Page 1 of Search Warrant No. 1990401 -


3. All associated email addresses or account information specific to Lehi City,
Ben Johnson, Wade Allred, Vinco Enterprises, as well as the distribution and
obtaining funds or products.

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 Embezzlement- UCA 76-4-403- Felony 2 (Over $5000)..

YOU ARE THEREFORE COMMANDED:

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: 18th day of September, 2019 @ 04:03 PM /s/

- Page 2 of Search Warrant No. 1990401 -


RETURN TO SEARCH WARRANT

NO. 1990401

The personal property listed below or set out on the inventory attached hereto was
taken from the person of Facebook, by virtue of a search warrant dated the 18th day
of September, 2019, and issued by Magistrate DAROLD MCDADE of the FOURTH
DISTRICT COURT - ALL DEPARTMENT:

Pending

I, Detective DALLIN ROBIN TURNER of Utah County Sheriff's Office, 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 18th day of September, 2019.

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: 18th day of September, 2019 @ 04:17 PM by /s/ DALLIN ROBIN
TURNER

- Page 1 of Return of Service for Search Warrant No. 1990401 -

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