STATE OF INDIANA ST. JOSEPH COUNTY SS: 'I' #... f. -I.,...... 4: '. 4c " <010 IN THE ST. JOSEPH SUPERIOR- ~~~... ~ "".~; C "~"r. "'::-f CAUSE NO. 71 DO~312F~q '-(flirt STATE OF INDIANA VS. DOB: XX-XX-1959 INFORMATION FOR VOLUNTARY MANSLAUGHTER. a Class A Felony KENNETH P. COTTER, upon information and belief, affirms under the penalty of peijury that: On or about the 18 th day of December, 2013, in St. Joseph County, State ofindiana,., by means of a deadly weapon, to wit: a handgun, did knowingly kill Wayne Alexander while acting under sudden heat. All of which is contrary to the form of the statute in such cases e and provided, to-wit: Indiana Code 35-42-1-3 and against the peace and dignity of the State of Inmana. I affirm under the penalties for peijury, tha1 ~7orego' g representatil>ns are true. "" '. KENNETH P. COTTER CHIEF DEPUTY PROSECUTING AITORNEY Probable Cause Found. Warrant ordered issued. Bond setin the amount of Ic;O,OCl? - corporate surety or!t?,pol - cash. So found, this J..O flo day of December, 2013 at l:q7 ~~4f'f/l/m&L ~iajhdvhd.~fv. JUDGE, ST. JOSEPH SUPERIOR COURT.
WITNESSES: Sgt. Tony Bontrager, CMHU Det. Brian Cook, CMHU Sgt. Alex Arendt, CMHU.Pet. Lance Anderson, CMHU Sgt. James Andrews, CMHU Barbara Nelson Jermaine ljennett Officers with the South Bend Police Department Medical Personnel Lab Personnel Any witness named in Discovery
STATE OF INDIANA ST. JOSEPH COUNTY STATE OF INDIANA VS. DOB: XX-XX-1959 SS: CAUSE NO. 71 DO<:. 1312 MR umd8.. -,... ". /.-'/.,,""', O{'fl..:... ~<'.. '" ~ c;~;r... OIOI.J IN THE ST. JOSEPH SUPERIOR coa~ta, ~<';:' f' AFFIDAVIT IN SUPPORT OF PROBABLE CAUSE ~'i".1',::~":.f <#11 Anthony Bontrager, upon information and belief, affinns under the penalty of perjury that: I.am a police officer with the City of South Bend and have been so employed for the past 15 years. Currently, I have been assigned as an investigator with the County Metro Iiomicide Unit (CMHU. I have been assigned to the death investigation of Wayne Anderson and make this affidavit based upon my own personal knowledge and reports from other officers. All events occurred in St. Joseph County, Indiana. On December 18, 2013. at approximately 11:57 pm, officers with the South Bend Police Department were dispatched to 315 S Chestnut in reference a Domestic. When they arrived. they found Wayne Anderson lying on the front porch of the residence was suffering from an obvious gunshot wound to the chest area. He was transported to Memorial Hospital. Despite resuscitation attempts by both officers at the scene and medicalpersonnel,.wayne Anderson died as a result of a gunshot wound to the body. The CMHU was therefore activated to investigate this shooting death. I was one of the officers assigned to this case. During the course of the investigation, detectives spoke with a number of witnesses. I learned that both Wayne Anderson and are brothers. I further learned
advised tbey went backto 315 S Chestnut. Ms. Nelson stated that told her that he had firearms hidden around bis residence. Dwing the course of the evening, Wayne Anderson and WILLIAML ANDERSON began to argue. Ms. Nelson said that she and Wayne Anderson therefore decided they wanted to leave the home ofwiliam L ANDERSON. Ms. Nelson advised that before they were able to leave, the argument between WILLIAM L ANDERSON and Wayne Anderson became physical, with both brothers grappling with each other and striking each other. During the course of the fight in the bedroom. Ms. Nelson saw WILLIAM L ANDERSON began to look for something and appeared extremely angry with his brother. She. then heard acknowledge that he was searching for a gun. Fearing for her safety, Ms. Nelson advised that she then fled the residence. As she began to walk away from the location, she heard a total of three (3 gunshots coming from inside the home. Ms. Nelson indicated that the only occupants inside the residence were, Mr. Wayne Anderson, and Debra Anderson.. Detectives spoke with. After advising him of his rights, stated he and Mr. Wayne Anderson went and picked up a female from the airport. He did not know her name. stated that after they brought her back to his home, he.made dinner. stated that the female and his brother, Mr. Wayne Anderson wanted to use his car. refused this request. stated that he and Mr; Wayne Anderson got into a verbal argument. denied any physical altercation. Instead, he stated that they "chest bumped" as "that is what the men in our family do."
stated that after the "chest bumping", the female left the home. He stated that Wayne Anderson walked out the door, shortly thereafter. WILLIAM L ANDERSON "firecracker". stated that after Wayne Anderson walked out the door, he heard a sound like a He stated that he looked outside and saw his brother lying on the front porch. stated that he checked on his brother and found that it appeared that he had been shot. He is not sure who called the police. admitted that he had a couple long guns inside the residence. However, he denied having any handguns in the home, despite the officers finding two (2 of them hidden in his home. Additionally, denied that any gunshots had been fired inside the residence, despite the two (2 gunshot holes (one in the bedroom where the fight between WILLIAM ANDERSON and Wayne Anderson occurred and the other in the living room. I afftnn under the penalties for perjury, that the foregoing representations are true.