E-FILED

IN COUNTY CLERK'S OFFICE

PIERCE COUNTY, WASHINGTON

May 13 2019 11:51 AM

KEVIN STOCK
COUNTY CLERK

SUPERIOR COURT OF WASHINGTON FOR PIERCE COUNTY

STATE OF WASHINGTON, CAUSE NO. 19-1-01772-6

Plaintiff,
vs. DECLARATION FOR DETERMINATION
MATTHEW ALLEN FARRAR, OF PROBABLE CAUSE
(ADPC)

Defendant.
DOB: 08/31/1991

SCOTT HARLASS declares under penalty of perjury:

That I am a deputy prosecuting attorney for Pierce County and I am familiar with the police
report and/or investigation conducted by the LAKEWOOD POLICE DEPARTMENT, incident number
1913201832;

That the police report and/or investigation provided me the following information;

That in Pierce County, Washington, on or about May 12, 2019, the defendant, MATTHEW
ALLEN FARRAR, did commit assault child second degree and assault child third degree

C.F. (DOB 5/24/11) is the 7 year-old biological daughter of the defendant, Matthew Farrar (DOB
8/31/1991).

Officers responded to the 711 on 108th Ave SW after a report from Ms. J. Jenson that her
boyfriend, the defendant, had "waterboarded" his seven year-old daughter. Officer's learned that
Ms. Jenson was dating and living with the defendant at the residence where this incident took
place. She explained that the defendant was separated from his wife and they had split custody of
their child, C.F.

Ms. Jenson appeared to be in shock and stunned when officers spoke to her. She explained that
earlier, C.F. got into trouble with the defendant for lying and talking back. The defendant grabbed
his belt and violently spanked C.F. approximately 13 times. Ms. Jenson stated the defendant was
using "too much power and too many strikes," and that it was "way overboard." She said that C.F.
was screaming "bloody murder." The defendant then drug C.F. into the bathroom and Ms. Jenson
followed to see what he was doing.

DECLARATION FOR DETERMINATION OF PROBABLE CAUSE 1 of 2 Office of the Prosecuting Attorney

declaration.rptdesign 930 Tacoma Avenue South, Room 946
Tacoma, WA 98402-2171
Main Office (253) 798-7400
 The defendant grabbed a red colored wash towel and wetted it with water. He then took an
approximate 17 oz plastic water bottle and filled it with water as well. He took C.F. .and bent her
over the bathtub, leaning her face up, and he held the water drenched rag over/on C.F.'s face. He
slowly started pouring water onto the hand towel that was held on C.F.'s face, over her mouth
and nose. Ms. Jenson believed he poured water for approximately 15-20 seconds. Ms. Jenson
could hear C.F. gagging, crying, and gasping for air while yelling "I can't breathe." The defendant
responded, "That's the point, shut up before the neighbors hear." Once the defendant finished, he
yelled at C.F. to go change her clothes. Ms. Jenson believed they were no longer safe so she
grabbed C.F. and fled the area to the 711 where she called 911.

Officer's then spoke to C.F., who said she did get into trouble today and that her dad spanked her
a lot and put a towel over her face and poured water all over her face. She said she could not
breathe and was afraid because she was coughing a lot while he did it.

C.F's biological mother arrived on scene and when EMS arrived, officer's did a quick visual
inspection of C.F.'s buttocks and legs, observing clearly visible bruises on her buttocks.

Officer's then learned that the defendant was en route to the 711. They intercepted him walking
towards the location. Post-Miranda, the defendant admitted he "spanked" C.F. and used "water."
When asked how he used the water, the defendant stated, "just water." The defendant said he
struck C.F. with his belt around 8 times and stated, "I think it could have been a little too much."

Eventually, the defendant admitted to placing the wet towel over C.F.'s face and pouring water on
her face. The defendant said he poured water for 2-3 seconds and stopped when C.F. yelled, "I
don't want to die." When asked where he had learned to punish C.F. this way, he said, "I saw it
once." The defendant stated in hindsight, he believed it was not appropriate and he would not do
it again.

Officers recovered from the apartment the red hand towel, the water bottle, and the dress C.F.
was wearing, which was soaked with water from the top to the bottom all over the front side and
partially on the back.

Officer's learned that preliminary tests believed C.F. did not get any water into her lungs but
more conclusive testing was being completed.
I DECLARE UNDER PENALTY OF PERJURY UNDER THE LAWS OF THE STATE OF
WASHINGTON THAT THE FOREGOING IS TRUE AND CORRECT.
DATED: May 13, 2019.
PLACE: TACOMA, WA
/s/ SCOTT HARLASS
SCOTT HARLASS, WSB# 44131
Deputy Prosecuting Attorney

DECLARATION FOR DETERMINATION OF PROBABLE CAUSE 2 of 2 Office of the Prosecuting Attorney

declaration.rptdesign 930 Tacoma Avenue South, Room 946
Tacoma, WA 98402-2171
Main Office (253) 798-7400