AFFIDAVIT OF PROBABLE CAUSE

APPLICATION FOR SEARCH WARRANT

of property 3011 W. 11th Street, Chester, Pa. typed verbatim

Commonwealth v. Leroy Evans

Sgt. Commodore S. Harris
Chester Police Department – Affiant

At 1000 HRS 11-11-80 I was detailed to 9th and Harwick St., City to
Investigate a Body that was supposed to be in the field behind MONTCO Cash and
CARRY. Upon my arrival the squad wagon was in the field in the read of
MONTCO CASH CARRY working on a white lady who had been badly beaten
about the face and head. At this time she was still breathing. At this time Off Tom
Boden came over to me and stated that a Mr. Jim Freeland W/M 29 of Kraft Food
Co., Philadelphia, Pa. was making a delivery at MONTCO CASH and CARRY
and when he pulled into the rear of the store he observed a young colored male,
medium brown skin, stocky build in the upper chest area, wearing a green sweat
shirt, throwing rocks at what he thought was rodents. This was in the field in the
rear of MONTCO Cash. He stated that all of a sudden he saw a woman or a man
pop up from the ground and the actor then threw another brick at the person and
the person went back down to the ground. At this time Mr. Freeland ran toward the
actor stated walking up the hill at a normal pace. The actor then pickup a metal
trash can which was sitting further up the hill and proceeded to the top of the hill.
The actor had a white shaggy mongrel dog with him and while the actor was
assaulting the person, the dog kept running up and down the hill. The actor then
walked normally in a diagonal direction in the field. Mr. Freeland then walked over
to where the person was lying and he saw that it was a woman. He then went into
MONTCO Cash and Carry and called for the police and ambulance. He stated that
he thought the woman was dead. At this time I did put this description out over the
air.

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 With this off. Shoates and Vincenzo started checking the area. When they
got to 10th and Harwick St., City they noticed a black male with a white dog, which
had stickers and bryers all over him. The dog was a white shaggy dog. They then
pulled up alongside of this black male and they were going to asked him if he
knew who owned the dog. This black male had both hands in his pockets as the
officers approached him. He then started to walk backwards. The actor then
started hollering in a nervous voice “I didn’t do nothing”. The closer they walked
towards him the faster he walked backwards. He then pulled his hands out of his
pants pockets and at this time the officers saw a red stain on his jacket which
appeared to be blood. This was on the sleeve of his jacket. When they saw the
stains, they attempted to reach for the actor and he started running. The officers
then chased the actor through McCafferty Village Projects and the actor ran into
3011 W. 11th Street, Chester, Pa. Off. Vincenzo then covered the front of this
house and Off. Shoates covered the back. While Off. Shoates was in the back of
the house he then noticed blood stains in the trash can in the rear of 3011 W. 11th
St., City. In the rear of the same house the actor ran Into. The metal trash can also
had 3011 w. 11th St., on the side of it.
Det. Hayes and myself after being outside of this house at 3011 W. 11th St.,
City for about 10 minutes trying to get the actor to let us in the house, he finally
with the help of Mrs. Patricia Ginyard of 3011 W. 11tyh St., City, a neighbor who
is a friend of the people who live at this address, the actor did let us into the house.
At this time we found one Anthony Jones C/M 17 of 3011 W. 11th St., City in the
front room of this home. He was the only person home. He was identified by Off.
Vincenzo as the person they were chasing. At this time Det. Haynes advised him of
his rights and asked him where was his mother. He stated that his mother was at
Sacred Heart Hospital. At about 10 minutes after our arrival inside of the house,
one of the neighbors had contacted Barbara Jackson, Anthony’s Mother and
occupant of this home, and she did arrive at the house. At this time we explain to
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her what had happened and Anthony hollered out mom “their was a woman inside
of the trash can this morning”, his mother then told him to shut up. Don’t say
anything. At this time we asked the mother to come to police headquarters and we
did take Anthony into custody.
The victim had a rope around her neck when she was found. While i was in
the back yard of this home I did notice the clothe line in the rear yard had been
freshly cut. Also at the scene where the victim was found as a green plastic trash
can liner full of blood inside and out. It did appear that the lady was placed inside
of the trash bag liner and put into the trash can and carried to the location at the
rear at MONTCO Cash and Carry.
At the hospital Det. Haynes did recover a Avon sheet with Eddy Jones 3011
W. 11th St., City and Patricia Ginyard of 3022 W. 11th Street, City on the back of it.
Later Off. Hayner was contacted by Off. Kaisner, formerly of the Chester Police
Department, that his wife’s aunt, one Emily Leo W/F 47 of 1206 Booth St., City is
an Avon Sells person and she did leave the house around 0900 HRS to walk over
to sell some customer who had just called her home, some Avon Products. She did
leave with her Avon kit. Off. Haynes gave him the description of the victim which
was found in the rear of MONTCO Cash and Carry and he stated that the
description fitted his aunt. He would come over to the hospital to see if the victim
was his Aunt. Off. Kaisner did identify the victim at the hospital as being his aunt,
one Emily Leo. The victim is in very critical condition at the hospital and
probably, if she lives will never being able to function as a normal person again.
It does appear that the victim was assaulted in the house that she visited and
was taken and dumped behind MONTCO Cash and Carry. Also since the victim
did have the address of Anthony Jones in her pocket plus she didn’t have to drive
her car for the appointment because she lived only two blocks from the jones house
and with the physical evidence found outside the home of Anthony Jones, that we

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be given permission to search this youths home for the items listed in the seizure
portion of this search warrant.
The shaggy dog also belongs to Anthony Jones and his family and the dog
did have blood on his feet and legs and on the side of his body. This was viewed by
Det. Haynes, Det. Crews, and myself. We tried to apprehend the dog but we
couldn’t catch him. The dog catcher also tried to get this dog but he did get away
from him.

Sgt. Commodore S. Harris