Criminal Complaint (Brown)

October 10, 1989

CRIMINAL COMPLAINT COMPLAINT # YEAR TYPE NUMBER   K 20467 89 F C-135-89 Ruth Mills DISTRICT JUSTICE Complaint Numbers if Other Participants MAGISTERIAL DISTRICT NO. 37-3-01  Warren, Pa 16365 INCIDENT # UCR NO. OTN   E6-470131   C 368583-56 COMMONWEALTH OF PENNSYLVANIA DEFENDANT VS NAME Michael Reuben Brown AND 266 Lister Avenue ADDRESS Falconer, N.Y.   DOB 6/01/71 R.S.A. ss# xxx-xx-xxxx A.K.A.           I, Tpr. John Herzog III Name of Affiant of Penna. State Police, Warren, PA do hereby state: X I accuse the above named defendant, who lives at the address set forth above or, I accuse an individual whose name is unknown to me but who is described as ________________   his nickname or popular designation is unknown to me and, therefore, I have designated him herein as John Doe; with violating the penal laws of the Commonwealth of Pennsylvania at approx. 80 ft to 180 ft off T 502 which is Lindell Road, an area located approx 1 mile from SR 0056,.   Farmington Township in Warren County on or about May 18,19, 2100 - 0200 hours Participant's were (if there were participants place their names here, repeating the name of above defendant)     Michael Reuben BROWN, Jay William BUCKLEY The acts committed by the accused were (A) Count # 1 Section 2501 CRIMINAL HOMICIDE - The actor Michael Reuben BROWN acted as an accomplice to Jay William BUCKLEY, who, during the course of the felonies of kidnapping and rape, intentionally, knowingly, recklessley, or negligently caused the death of another human being, specifically Kathy Ann Wilson. COUNT #2 Section 306/3121 ACCOMPLICE TO RAPE - Michael Reuben BROWN acted as an accomplice to Jay William BUCKLEY, who, after BROWN had helped to undress Kathy Ann Wilson, raped Kathy Ann Wilson. COUNT #3 Section 306/2901 ACCOMPLICE TO KIDNAPPING - Michael Reuben Brown unlawfully removed another person a substantial distance under the circumstances from the place she was found, or unlawfully confined, Kathy Ann Wilson, for a substantial period of time in a place of isolation with the intention of facilitating the commission of a felony or a flight thereafter, or to inflict bodily injury, or to terrorize, Kathy Ann Wilson all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly, in violation of 2501, 306/3121, 2901 of the Act of Pennsylvania Crimes Code or the _______________ Ordinance of _______________________. (3) I ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges I have made. (4) I verify the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C.S. 4904) relating to unsworn falsification to authorities. _____ October 10 ____, 19 _ 89__        ____ John Herzog___ (signed)                                                          (Signature of Complainant) AND NOW, on this date, __ October 10, __, 19 _89_ I certify the complaint has been properly completed and certified and that there is probable cause for the issuance of process.           37-3-01                                      ____ Ruth Mills ___ (SEAL)      Magisterial District                               (Issuing Authority)

Arrest Warrant Affidavit (Brown)

Oct 10, 1989

ARREST WARRANT AFFIDAVIT Police COMPLAINT # YEAR TYPE NUMBER K 20467 89 F C 135-89 Ruth Mills DISTRICT JUSTICE Complaint Numbers if Other Participants MAGISTERIAL DISTRICT NO. 37-3-01 919 Market Street INCIDENT # UCR NO. OTN  Warren, Pa 16365 E6-470131   C-368583-5 COMMONWEALTH OF PENNSYLVANIA COUNTY OF WARREN COMMONWEALTH OF PENNSYLVANIA DEFENDANT VS NAME Michael Reuben Brown AND 266 Lister Avenue ADDRESS Falconer, N.Y.         Tpr. John Herzog__       Penna State Police, Warren, PA____ _________________ (Name of Affiant) NNNNNN (Police Department or Address of Private Affiant)      (Telephone Number) being duly sworn (or affirmed) before me, according to law, deposes and says that there is probable cause to believe that: PROBABLE CAUSE BELIEF IS BASED ON THE FOLLOWING FACTS AND CIRCUMSTANCES: (see instruc below) On May 18, 1988 KATHY ANN WILSON, of Jamestown, New York, was reported missing by her family. Later on that date, her purse was found along Route 62 in Pine Grove Township, Warren County, Pennsylvania. On September 24, 1989 human skeletal remains were found in a wooded area in Farmington Township, Warren County, approximately 9.4 miles from the location where the purse was found. Dr. Ronald Kohl, Mrs. Wilson's dentist, examined the dental work of the remains and positively identified the remains as those of Mrs. Wilson. Your affiant personally interviewed Michael Reuben BROWN, who gave your affiant observations relating to Mrs. Wilson's transportation to Warren County and her demise. BROWN told your affiant the following: he was requested by Jay William BUCKLEY to drive BUCKLEY to a gravel pit near Hall Road in Chautauqua County, N.Y. BROWN drove BUCKLEY to this location and assisted BUCKLEY in loading Mrs. Wilson into BROWN'S van. BROWN then drove the van to a location in New York state where BUCKLEY took over driving. Once they had arrived at the location where the remains were found, BUCKLEY and BROWN removed Mrs. Wilson from the van. BUCKLEY, BROWN and Mrs. Wilson then walked into the woods. Once in the woods, Brown removed Mrs. Wilson's blouse and bra. Buckley then pushed Mrs. Wilson to the ground and removed her skirt. BUCKLEY then raped Mrs. Wilson while BROWN watched. Brown held the light and watched BUCKLEY stab Mrs. Wilson. BROWN stated that he felt, when they left the gravel pit, that BUCKLEY would eventually murder Mrs. Wilson. BROWN further advised your affiant that after he observed BUCKLEY rape Mrs. Wilson, he heard Mrs. Wilson plead with BUCKLEY not to hurt her. BROWN then heard Mrs. Wilson scream and beg BUCKLEY not to stab her again. BROWN then observed BUCKLEY to have blood on his hands and clothing. BUCKLEY and BROWN then left the area in BROWN'S van. _____________________________________________________________ PLEASE READ AND FOLLOW THESE INSTRUCTIONS CAREFULLY 1. If information was obtained from another person, e.g., an informant, a private citizen, or a fellow police officer, state specifically what information was received, and how and when such information was obtained. State also the factual basis for believing such other person to be reliable. 2. If surveillance was made, state what information was obtained by such surveillance, by whom it was obtained, and state date, time and place of such surveillance. 3. State other pertinent facts within personal knowledge of affiant. 4. State any additional information considered pertinent to justify this application.   TPR John Herzog III                                              1371           WARREN-1560    SIGNATURE OF AFFIANT             ADDRESS OF PRIVATE CITIZEN       Badge No.                      District - Unit Sworn to and subscribed before me this 10th day of October 1989     Ruth Mills Signature of Issuing Authority                        (SEAL) DISTRICT JUSTICE COURT NO. 37-3-01    OFFICE ADDRESS: 919 Market St. Ext., Warren, Pa Date Commission Expires     1-3-94     PHONE:   (814) 723-6750 FORM AWA REORDER FROM GARLITS INDUSTRIES, INC. 30 N. PENNSYLVANIA AVE. MORRISVILLE, PA 19607 (215) 736-2660