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Case 1:24-cr-10259-DJC Document 9-1 Filed 08/28/24 Page 1 of 45

AFFIDAVIT OF SPECIAL AGENT CHENEE CASTRUITA IN SUPPORT OF


GOVERNMENT’S MOTION FOR DETENTION

I, Chenee Castruita, having been sworn, state:

Introduction and Agent Background

1. I have been a Special Agent with the Federal Bureau of Investigation since June of

2022. I am currently assigned to the Public Corruption and Civil Rights Squad of FBI’s Boston

Division, where I investigate public corruption and civil rights offenses. I am a graduate of the

FBI Academy in Quantico, Virginia, and I have received on-the-job training and attended courses

sponsored by the FBI and Department of Justice on how to conduct investigations regarding

violations of various federal laws. I am a “federal law enforcement officer” within the meaning

of Federal Rule of Criminal Procedure 41(a)(2)(C).

2. The facts in this affidavit come from my personal observations and review of

records, my training and experience, and information obtained from other agents and witnesses.

This affidavit is filed in connection with the government’s motion for detention. Therefore, it does

not set forth all of my own and the other investigators’ knowledge about this matter.

3. I submit this affidavit in connection with the government’s motion to detain

defendant MATTHEW FARWELL pending trial. As alleged in the indictment charging

FARWELL with violating 18 U.S.C. § 1512(a)(1)(C), and as further described below, on February

1, 2021, FARWELL killed Sandra Birchmore with the intent to prevent her from communicating

to law enforcement certain information regarding FARWELL’s commission or possible

commission of the following federal crimes:

a. Using a facility or means of interstate commerce to persuade, induce, entice,

or coerce then-15-year-old Birchmore to engage in unlawful sexual intercourse, in violation of 18

U.S.C. § 2422(b) (coercion and enticement);

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Case 1:24-cr-10259-DJC Document 9-1 Filed 08/28/24 Page 2 of 45

b. Depriving Birchmore of certain rights secured by the United States

Constitution by committing statutory rape while acting under color of law, in violation of 18 U.S.C.

§ 242; and

c. Participating in a scheme to defraud the Stoughton Police Department and

Town of Stoughton through false representations, or material omissions, about the hours

FARWELL worked in order to receive compensation for official time when he was, in fact,

engaging in sexual intercourse with Birchmore, in violation of 18 U.S.C. § 1343.

Overview of the Investigation

4. On February 1, 2021, then-Stoughton Police Detective MATTHEW FARWELL

killed Sandra Birchmore. FARWELL committed this murder, at least in part, to prevent Birchmore

from disclosing to authorities information regarding his commission or possible commission of

one or more crimes, including coercion and enticement in violation of 18 U.S.C. § 2422(b),

deprivation of rights under color of law in violation of 18 U.S.C. § 242, and a then-ongoing wire

fraud scheme in violation of 18 U.S.C. § 1343. FARWELL’s murder of Birchmore was the

culmination of FARWELL’s years-long pattern of abuse targeting Birchmore.

5. When she was a young girl, Sandra Birchmore was interested in pursuing a career

in law enforcement, and eventually joined the Stoughton Police Explorers Academy (hereinafter,

“Police Explorers”) to learn more about law enforcement careers. While Birchmore was in the

program, FARWELL was involved as both a volunteer and an instructor. FARWELL used his

authority and access to groom, sexually exploit, and ultimately sexually abuse then-15-year-old

Birchmore. FARWELL continued this sexual abuse after Birchmore became an adult, and he

continued to engage in an extramarital sexual relationship with Birchmore until he killed her on

February 1, 2021.

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6. There are signs that, in late 2020 and early 2021, FARWELL was losing control of

Birchmore and the information she possessed about his past and then-ongoing conduct. In or

around December 2020, Birchmore became pregnant. Soon thereafter, Birchmore told FARWELL

that he was the father of her child and she wanted him to be more involved in the planning for the

impending birth. In January 2021, Birchmore’s friend contacted FARWELL’s employer, the

Stoughton Police Department, and during that call referenced FARWELL and Birchmore’s illicit

sexual relationship. Shortly thereafter, a Stoughton Police Department employee told FARWELL

about that call.

7. By the end of January 2021, FARWELL faced the specter of additional disclosures

to law enforcement regarding his prior sexual abuse of Birchmore and his then-ongoing efforts to

defraud the Stoughton Police Department and Town of Stoughton by meeting her for sex when he

was supposed to be on duty as a police officer. On February 1, 2021, FARWELL went to

Birchmore’s apartment in Canton, Massachusetts wearing a COVID-19/medical facemask. Once

inside, he killed her and staged her body and apartment to make it appear that Birchmore had died

by suicide.

8. On February 4, 2021, three days after the murder, members of the Canton Police

Department went to Birchmore’s apartment to conduct a well-being check. When police officers

entered Birchmore’s apartment, they found her body. A paramedic determined that Birchmore

was dead, and her body was transported to the Office of the Chief Medical Examiner (hereinafter,

the “OCME”).

9. In early May 2021, an OCME pathologist ruled Birchmore’s manner of death to be

suicide.

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I. Evidence that Farwell committed federal offenses or possibly committed


federal offenses by sexually abusing Birchmore when she was a minor.

10. MATTHEW FARWELL started sexually exploiting Sandra Birchmore no later

than 2013, when she was 15 years old.1 At that time, Birchmore was enrolled in the Police

Explorers. FARWELL used his position of trust and authority as a sworn police officer and

instructor in the Police Explorers to groom Birchmore. Ultimately, FARWELL sexually abused

Birchmore, including by engaging in sexual intercourse with her.

11. The Explorer Program is a vocational education program that enables youth to

explore career paths, such as careers in law enforcement. Police departments throughout the

country partner with the Explorer Program to create what are commonly known as local Police

Explorers Programs. The Stoughton Police Department chartered and facilitated the Stoughton

Police Explorers. It was a quasi-paramilitary program designed to expose youth participants to

various aspects of policing.

12. FARWELL became a sworn member of the Wellesley Police Department in 2008.

On March 27, 2012, he was hired by the Stoughton Police Department, where he worked until he

resigned on April 1, 2022. Prior to joining Stoughton Police Department in 2012, he was a Police

Explorers volunteer. After joining the Stoughton Police Department, he served as a Police

Explorers instructor. He had several roles as an instructor, including teaching firearms and

explosives safety and conducting canine demonstrations. At the time, FARWELL was already

familiar with the Police Explorers because he had also been a participant as a teenager.

1
FARWELL was born in 1985.

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13. In March 2010, Sandra Birchmore applied to be a Police Explorers participant. At

the time, Birchmore was 12 years old. She began participating in the program in the spring of

2010, and she remained in the program through 2016.

14. FARWELL began to groom Birchmore when she was a child. 2 This grooming

culminated in FARWELL raping Birchmore in April 2013, when she was only 15 years old. 3 At

the time of this assault, FARWELL was 27 years old. FARWELL continued to sexually abuse

Birchmore prior to her eighteenth birthday. After Birchmore turned 18 years old, FARWELL

continued cultivating a sexual relationship with her that lasted until her death on February 1, 2021.

A. Electronic messages between Farwell and Birchmore indicate that


Farwell sexually abused Birchmore when she was a child.

15. After Birchmore’s death, law enforcement agents obtained Birchmore’s cell

phones, both Apple iPhones, and laptop and reviewed the data on those devices. During that

review, agents discovered messages between FARWELL and Birchmore. The messages

confirmed that FARWELL frequently communicated with Birchmore for years. The messages

also indicate that FARWELL had sex with Birchmore when she was a minor, starting in or around

April 2013, when Birchmore was 15 and FARWELL was 27.

2
Based on my training and experience, “grooming” is the process of a predator building a
relationship with a child or vulnerable adult in order to gain their trust, enabling the groomer to
ultimately exploit the child or otherwise vulnerable person.
3
Under Massachusetts law, any intercourse with a person under the age of 16 is unlawful
and constitutes sexual abuse, specifically, statutory rape. M.G.L. ch. 265 § 23. Furthermore, any
person who has sex with a child under the age of 16, being at least 10 years older than that child
at the time of the intercourse is guilty of Aggravated Statutory Rape. M.G.L. ch. 265 § 23A (b).
Finally, any mandated reporter who has sex with a child under 16 years old is guilty of Aggravated
Statutory Rape. M.G.L. ch. 265 § 23A (c). During the relevant time period, as a Stoughton police
officer, FARWELL was a mandatory reporter under Massachusetts law.

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16. Data from Birchmore’s Facebook account reveals aspects of the beginning of

FARWELL and Birchmore’s online communications. Specifically, Facebook data indicates that

FARWELL sent Birchmore a Facebook “friend request” on October 28, 2012. At that time,

Birchmore was 15 years old and a participant in the Police Explorers. FARWELL was her 26-

year-old instructor.

17. On February 21, 2019, Birchmore and FARWELL had a text message conversation

about FARWELL taking Birchmore’s virginity. Birchmore told FARWELL that she was happy

that he “took it.” Later in the same conversation, FARWELL acknowledged that it was “a big

thing to get to be the first.”

18. In the same text conversation, FARWELL also reminisced about the first time he

digitally penetrated Birchmore’s vagina. Discussing the day that occurred, FARWELL asked

Birchmore what she would have done if he (FARWELL) told her he wanted her that day.

Birchmore responded that she would have told him that he could have sex with her “after school.”

She also recalled the specific class and seat that she was in when she realized that she was going

to lose her virginity to FARWELL. Based on my investigation, I believe that this occurred during

the 2012-2013 school year when Birchmore was 15 years old.

19. Additionally, on March 19, 2019, FARWELL asked Birchmore, “what would you

have done if we never used a condom and I never pulled out . . .” Birchmore reassured FARWELL

that she “wouldve [sic] still finished school :)” Birchmore then told FARWELL, “I loved prom

night! It was worth not going to prom.”

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20. On February 11, 2020, Birchmore and FARWELL discussed the exact day that

FARWELL took then 15-year-old Birchmore’s virginity:

BIRCHMORE: I had butterflies so bad the day you took my virginity

FARWELL: Me too it was such a big day

BIRCHMORE: Still know the date to this day

FARWELL: Really?

BIRCHMORE: Yes.

FARWELL: :)

BIRCHMORE: Thats not a date I’ll ever forget

BIRCHMORE: It was april 10, 2013

FARWELL: :)

BIRCHMORE: Best day of my life [face with heart emoji]

FARWELL: Me too

21. On June 19, 2020, Birchmore and FARWELL had the following conversation in

which FARWELL reminisced about his past criminal sexual abuse of Birchmore:

BIRCHMORE: I’m glad you agreed to take my virginity though

FARWELL: Me too

* * *

FARWELL: Lol if I pushed I absolutely could’ve fucked you


without condoms from day one

BIRCHMORE: Probably if you really pushed it.

BIRCHMORE: I was kinda scared to say no in the beginning not


knowing how you’d take it so yeah you wouldve got
no comdoms [sic] lol.

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B. Other electronic messages confirm that Farwell sexually abused


Birchmore when she was a child.

22. Text messages between Birchmore and others confirm that FARWELL sexually

abused Birchmore as a child and continued a sexual relationship with her until her death. For

example, on October 5, 2020, Birchmore texted one of her friends (hereinafter, “Person 1”) that

FARWELL had been having sex with her for “the last almost 10 years” and that FARWELL had

taken her virginity “before [she] was 16.” On May 20, 2020, Birchmore told another friend that

she had lost her virginity five days before the Boston Marathon bombing. 4

23. Also on October 5, 2020, Birchmore prepared a draft text message to FARWELL’s

wife. Birchmore sent this draft text to Person 1. The text states, in part: “I am just messaging to

inform you that your husband Matthew has been out cheating on you since before you guys were

even married.” I am aware that FARWELL and his wife got married in May 2013, shortly before

Birchmore turned 16 years old. There is no known record indicating the draft message was sent

to FARWELL’s wife.

24. Other text messages between FARWELL and Birchmore demonstrate his sexual

interest in minors. On June 15, 2019, FARWELL and Birchmore exchanged text messages in

which they discussed role-playing during their next sexual encounter. FARWELL asked

Birchmore how old she was going to pretend to be during that encounter. When Birchmore

responded “14,” FARWELL replied with a smiley face emoji. In another conversation between

FARWELL and Birchmore on February 21, 2020, FARWELL describes pinning Birchmore down

during sex and asks her: “Will you say Matt stop I’m 13 I’m not ready for this omfg please stop.”

4
I am aware that this event took place on April 15, 2013.

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25. I have also reviewed several text messages from 2020 in which FARWELL

instructs Birchmore to act as if he were her older brother coming into her room at night to have

sex with her.

C. Witnesses confirm that Farwell cultivated a close relationship with


Birchmore when she was a child.

26. Agents have interviewed one of Birchmore’s friends (hereinafter, “Person 2”)

regarding Birchmore’s relationship with FARWELL. Person 2 indicated that shortly before her

death, Birchmore revealed to him/her that FARWELL started having sex with Birchmore when

she was 15 years old.

27. Agents have also interviewed one of Birchmore’s relatives, who described being

aware that Birchmore would meet with FARWELL when Birchmore was a minor. Specifically,

this family member indicated that around the time Birchmore was a freshman in high school, 5 she

would tell him/her that she was meeting with FARWELL so he could help her with homework.

28. I have reviewed a text message exchange between FARWELL and Birchmore from

June 17, 2019, where the two discuss how FARWELL had helped her “test prep” at the library.

FARWELL told Birchmore that she should have told him that she was interested in having sex

with him that day. Birchmore told him that she was scared to speak up. FARWELL then asked

her, “did you think I wouldn’t want to fuck you?” Birchmore responded, “Yes and like cause of

my age I didnt want you to be like uhhh no wtf.” FARWELL then told her, “I understand that.”

29. In a conversation from April 5, 2020, FARWELL told Birchmore that he knew he

wanted to take her virginity when he “started helping [her] with school work.” Additionally, on

5
Birchmore was a freshman in high school from September 2011 – June 2012.

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February 21, 2020, Birchmore and FARWELL reminisced about when they first became sexually

active:

BIRCHMORE: I listened better back then tho

FARWELL: I wish it had been a year sooner after helping you study at
the library

FARWELL: You still listen and give me whatever I want baby

BIRCHMORE: I didnt even make you wait a year after that

BIRCHMORE: And good. But I dont think your gonna get what you want
next time so

FARWELL: Of course I will I’ll just take it

BIRCHMORE: That’s what you think. Good luck with that

FARWELL: What was the first day you said omg I want this guy to be
my first I want to feel him inside me

BIRCHMORE: Yeah so 2012 I finally decided that I was gonna try and find
a way to fuck you and just wasnt sure how.

BIRCHMORE: How did you feel when I asked to make your dream come
true

FARWELL: Amazing!

BIRCHMORE: Good

FARWELL: I absolutely would’ve fucked you in 12

BIRCHMORE: In 12?

FARWELL: 2012

30. Agents have also interviewed one of Birchmore’s childhood friends (hereinafter,

Person 3”). Person 3 confirmed that Birchmore would meet FARWELL to “help with her

homework.” Moreover, Person 3 indicated that Birchmore confided in him/her that she was

meeting with FARWELL in early high school to have sex with him in his police car or his truck.

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II. Evidence that Farwell committed federal offenses or possibly committed


federal offenses by submitting false information to obtain wages for time
spent engaging in sex acts with Birchmore.

A. Farwell defrauded the Stoughton Police Department and Town of


Stoughton.

31. On multiple occasions, FARWELL engaged in sex acts with Birchmore while on

duty as a Stoughton police officer. To cover this up, FARWELL falsely represented that he had

worked certain hours, when in truth and in fact, he was not working. Rather, he was engaging in

sex acts or spending time with Birchmore. Accordingly, FARWELL’s misconduct was also part

of a scheme to obtain wages from the Stoughton Police Department, an agency of the Town of

Stoughton, through false statements or material omissions regarding the hours he was on duty and

working as a police officer.

B. Farwell’s text messages with Birchmore indicate that he had sex with
Birchmore while he was on duty as a Stoughton police officer.

32. Text messages between FARWELL and Birchmore indicate that, on multiple

occasions, FARWELL left work during his shifts to meet and, at times, engage in sexual activity

with Birchmore. These encounters occurred at various locations, including Birchmore’s previous

home in Stoughton, her more recent apartment in Canton, a Costco parking lot in Stoughton, and

a Five Guys parking lot in Canton. Examples of dates and approximate start times of these

encounters are listed here:

Date Approximate Start Time

April 10, 2020 11:46pm

May 1, 2020 11:10pm

May 20, 2020 7:14pm

July 1, 2020 9:36pm

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September 22, 2020 7:32pm

September 24, 2020 8:56pm

September 28, 2020 8:28pm

October 5, 2020 7:03pm

October 6, 2020 7:09pm

October 12, 2020 7:31pm

October 19, 2020 9:44pm

October 23, 2020 8:01pm

October 25, 2020 10:43pm

November 6, 2020 10:27pm

November 18, 2020 9:46pm

November 24, 2020 9:22pm

November 28, 2020 10:26pm

November 28, 2020 10:40pm

December 11, 2020 10:52pm

December 29, 2020 7:49pm

December 30, 2020 11:01pm

January 8, 2021 10:09pm

January 16, 2021 10:02pm

January 23, 2021 10:08pm

January 29, 2021 10:07pm

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33. I have reviewed messages that reveal that both FARWELL and Birchmore knew

that some of their encounters occurred while FARWELL was on duty. For example, on April 10,

2020, FARWELL wrote, “I’m going to sneak away from work quick.” On November 24, 2020,

Birchmore asked if FARWELL would be on duty when the two were scheduled to meet.

FARWELL responded, “Yes I will be on the clock”.

34. The text messages between FARWELL and Birchmore, which precede several of

the above-listed encounters, contain statements indicating that the purpose for at least some of the

encounters was to engage in sex acts. For example, on several occasions, FARWELL sent

Birchmore text messages directing her to act as if she was being raped during the ensuing

encounter.

C. Farwell’s scheme to defraud caused interstate wire communications.

35. The Town of Stoughton pays Stoughton police officers on a bi-weekly basis. In or

around 2020 and January 2021, FARWELL received his paychecks via direct deposit to his

account at USAA Federal Savings Bank. The paycheck funds originated with Rockland Trust

Bank, and were deposited in FARWELL’s account via an Automated Clearing House (“ACH”)

transfer. Each ACH transfer originated outside of Massachusetts, and/or traveled through another

state before terminating in FARWELL’s account.

36. Accordingly, it appears that by engaging in sexual conduct when he should have

been performing official duties as a police officer, and obtaining pay for that time, FARWELL

may have committed wire fraud in violation of 18 U.S.C. § 1343.

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III. Farwell killed Birchmore to prevent her from disclosing information about his
commission of federal crimes and possible commission of federal crimes.

37. As described in detail below, there is evidence that FARWELL killed Birchmore

on February 1, 2021 to prevent her from disclosing information about his possible commission of

the federal crimes listed above.

A. Birchmore’s Pregnancy

38. On October 5, 2020, Person 1 told Birchmore that FARWELL’s wife was pregnant

with the couple’s third child. Person 1 indicated that the baby was due in February 2021.

Birchmore responded that she was going to tell FARWELL’s wife that he had been having sex

with her (Birchmore) for nearly ten years.

39. In summary, electronic messages between FARWELL and Birchmore for the

period beginning on or about October 5, 2020, through January 2021, indicate that Birchmore

presented FARWELL with an ultimatum: FARWELL would have to agree to engage in

unprotected sex with Birchmore with the goal of conceiving a child; and in return, Birchmore

would not disclose their relationship. Birchmore had already told others that FARWELL had been

having sex with her since before she was 16 years old, which she knew was a crime, and Birchmore

knew that FARWELL was leaving work to have sex with her while he was on duty as a Stoughton

police officer.

40. According to text messages between FARWELL and Birchmore, Birchmore sent

FARWELL a photo of her ovulation schedule and the two started discussing timing their sexual

encounters around specific times in Birchmore’s cycle.

41. Approximately one week after FARWELL agreed to have unprotected sex in order

to conceive a child, FARWELL and Birchmore had a disagreement about the terms of their

agreement. The following is an excerpt from a text conversation on October 12, 2020:

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FARWELL: I said the agreement was once that was our


compromise

BIRCHMORE: I asked if we could try this month, didn’t realize that


meant you fuck me once lol. And Then I asked if we
could try through this year and you said I’d think
about it.

42. The conversation continued on October 13, 2020:

FARWELL: Our compromise was try once.

BIRCHMORE: Yeah it was to try this month

BIRCHMORE: So your thinking about the second thing I said as far


as the rest of the year?

FARWELL: You said try once this month if it happens it’s meant
to be those are the exact words.

43. Text messages indicate that a few weeks later, Birchmore continued to discuss

trying to get pregnant. On November 3, 2020, she asked FARWELL if they could try again that

month or whether they would need to talk “in person about that.” FARWELL responded, “that’s

an in person discussion.” On November 5, 2020, Birchmore asked FARWELL if he had given

any more thought to their prior conversation and told him that she thought of a way they could

both be happy:

BIRCHMORE: How would you feel about us having a baby, you


being there AND signing the birth certificate (theres
never gonna be a need for your information anyway
so youll be safe there) and I wont talk shit about her
or your kids. That way we both get what we want.

BIRCHMORE: You asked me the other day what I wanted and I


didn’t want to give it to you in the form of an
ultimatum so I am trying to do it with you as a
compromise type of thing Can you tell me what you
thought of?

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BIRCHMORE: I’m down for discussing it in person but the more I


thought about it you signing it really isn’t going to
have an impact on you cause of the way things are
going to fall in the future.

FARWELL: ok that’s an in person discussion

44. In November 2020, after Birchmore learned that she was not yet pregnant, she

asked FARWELL about continuing to try to conceive for another month. On multiple occasions,

FARWELL told Birchmore that they would need to discuss that topic in person. FARWELL

continued to meet with Birchmore in person and text messages suggest that they remained sexually

active.

45. On December 28, 2020, Birchmore sent FARWELL a text message informing him

that she was pregnant. She sent him a photo of a poster she had made to celebrate the pregnancy:

46. FARWELL’s immediate response to Birchmore’s disclosure about the pregnancy

was, “I literally have nothing to say right now how could you express that in text when I said I

don’t appreciate it.” FARWELL and Birchmore then argued about the pregnancy in the following

text conversation:

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FARWELL: How far are you?

BIRCHMORE: Regardless of how far we’re keeping it…

BIRCHMORE: but 3.5 weeks

* * *

BIRCHMORE: Which means I concieved [sic] this month

* * *

FARWELL: Ok well we need to talk then.

BIRCHMORE: No shit. That’s obvious

BIRCHMORE: And the birth certificate is being signed

BIRCHMORE: Or hers isn’t. 6

* * *

BIRCHMORE: No I’m mad your acting how you are over a CHOICE
WE BOTH MADE

FARWELL: I’m mad you act like you gave anyone a choice

BIRCHMORE: Lmao oh so you didn’t have a choice

BIRCHMORE: ?

FARWELL: Per usual you make and do whatever you want

BIRCHMORE: All I did was say can I have it you said have what and
I said you know what im asking for and you stood up
and said yeah

BIRCHMORE: You’ve been doing that. You mad shes due in


February and I am in September and you dont know
how your gonna be there for both of us.

BIRCHMORE: And you need to be there during labor for me too

6
At the time of these text messages, I know that FARWELL’s wife was 8 months pregnant
with his third child. Based on the context of these texts and prior messages, I believe Birchmore
was referring to the birth certificate for the child that Farwell’s wife was then carrying.

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BIRCHMORE: Becuase [sic] your kid should matter

BIRCHMORE: Late august-early September**

FARWELL: You are truly the worst person on the face of the
earth…

47. After the foregoing conversation, Birchmore again threatened to expose the truth

about FARWELL’s prior sexual abuse and their ongoing relationship. FARWELL responded by

indicating that Birchmore had threatened him, causing him to agree to impregnate her.

FARWELL: For the past week and half the doctor wasn’t right but now
she was and you just throw it at me cause now you’ve got
me. You honestly have absolutely no idea how to treat
people. I have fucking bent over backwards for you. Now
you want to act like this was some free will decision. You
have threatened me from the word go if I didn’t do and give
you what you wanted you would ruin me. I made a deal with
you and you changed the terms at every turn. We will deal
with this tomorrow.

B. Farwell’s Escalating Physical Violence.

48. On December 29, 2020, FARWELL and Birchmore met to talk in person. After

this meeting, Birchmore sent FARWELL a text alluding to a physical encounter.

BIRCHMORE: it made me really uncomfortable and stressed out and scared


when you were next to me because I thought you were gonna
hit me after you said what you said and took things out of
my hand. That’s why I was crying. I know you wouldn’t
but it still scared me.

49. At least three witnesses have disclosed that, in the weeks before her death,

Birchmore told them that FARWELL was physically violent when Birchmore and Farwell

discussed the pregnancy. According to death records, Birchmore was 4 feet, 10 inches tall.

Military records indicate that FARWELL is 6 feet, 4 inches tall.

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50. Person 2 reported that, in the weeks prior to Birchmore’s death, she was “over the

moon” about her pregnancy. According to Person 2, Birchmore had decreased her coffee

consumption, discussed winter clothes for her future baby, and engaged in FaceTime calls with

Person 2 while selecting baby clothes. Person 2 indicated that Birchmore was nervous about telling

FARWELL about the pregnancy but that she eventually did. In January 2021, Birchmore called

Person 2 and stated that, after telling FARWELL about the baby, FARWELL told her that “he

wished [she] just would die and he wants nothing to do with the baby.” According to the

information Birchmore shared with Person 2, FARWELL put Birchmore in a headlock and

grabbed her cell phone from her hand. Person 2 told Birchmore to distance herself from

FARWELL, given that he was dangerous, a police officer, and obviously did not care about the

law. However, Person 2 was also aware that Birchmore appeared to be attached to FARWELL

because he had taken her virginity when she was 15 years old.

51. Person 3 also indicated that, in the days before her death, Birchmore disclosed that

FARWELL had been violent. Approximately 10 days before Birchmore’s death, Birchmore and

Person 3 went to Walmart to buy a baby stroller for Birchmore’s future child. Birchmore was

excited about the baby and asked Person 3 to be the child’s godmother. Birchmore told Person 3

that the day prior, FARWELL had gotten angry with her for showing him a fetal sonogram.

According to Birchmore, FARWELL told her, “that’s not my child. I don’t want anything really

to do with you,” and then FARWELL pushed her to the ground. Person 3 told Birchmore to end

the relationship with FARWELL. Person 3 indicated that Birchmore seemed scared but not ready

to leave FARWELL because FARWELL had been such a big part of Birchmore’s life for several

years.

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52. Additionally, Person 7, Birchmore’s long-time therapist, reported that, in the weeks

before Birchmore’s death, Birchmore reported to her that FARWELL got upset about the

impending pregnancy and “shoved” her.

53. In addition to these descriptions of FARWELL’s violence targeting Birchmore

from Person 2, Person 3, and Person 7, Birchmore’s text messages to Person 1 further confirm

FARWELL’s escalating violence. On January 10, 2021, Birchmore sent Person 1 a text message

indicating that she had recently argued with FARWELL. Birchmore told Person 1 that, during the

argument, FARWELL took her cell phone out of her hand three times and refused to give it back

to her. Birchmore also indicated that FARWELL took her computer out of her hand and used his

body to shove her.

C. In January 2021, there was increasing pressure on Farwell.

54. In January 2021, the pressure on FARWELL increased as a result of Birchmore’s

pregnancy. Birchmore tried to communicate with FARWELL regarding her due date, ultrasounds,

genetic testing, gender reveals, and doctor appointments. In his text responses, FARWELL was

unresponsive to or dismissive of those topics, or he appeared to ignore them. On January 4, 2021,

Birchmore told FARWELL that she was going to the doctor the next day and asked if he wanted

to know how the appointment went. FARWELL did not directly respond to that question.

55. On January 5, 2021, Birchmore asked FARWELL to come over so they could

discuss her estimated due date, the week of her first ultrasound, her conversation with her doctor,

and her first appointment. FARWELL did not respond directly to that request.

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56. Text messages from January 3, 2021 show that Birchmore asked FARWELL if

their child could have his last name. However, he told her he would not discuss that issue via text

message.7

BIRCHMORE: So I have a compromise for you

BIRCHMORE: You don’t need to sign the bc if the baby can have your last
name…

* * *

FARWELL: Not discussing in text. We can talk in person.

57. In another text message on January 6, 2021, Birchmore began to ask FARWELL

what their family would look like.

BIRCHMORE: 1. You don’t have to sign the bc if I’m allowed to at least list
you and they can have your name and I won’t move to
Stoughton or [the town where FARWELL’s family resides.]

BIRCHMORE: 2. I won’t bitch about holidays- but I would like you to come
a few days before Christmas and Easter so you can see what
they get from me and I don’t want you to leave them out.
And 3. If you want to try and support them, we can talk about
that. But I do want you to see them.

BIRCHMORE: I feel like I’m trying to be as fair as I can. And I want you
there for labor… That I’m standing my ground on.

BIRCHMORE: Last name**

FARWELL: ok we can discuss this more in person.

BIRCHMORE: Okay. I figured. Does it kinda sound ok to you?

7
FARWELL’s reluctance to discuss the pregnancy via text message is significant because
it is inconsistent with FARWELL and Birchmore’s long history of text message discussions
regarding seemingly private topics. For example, there are thousands of text messages between
FARWELL and Birchmore in which FARWELL discusses details regarding his work as a police
officer, his sexual fantasies that were predominantly violent and included many references to
choking and rape, and graphic details about their previous sexual encounters.

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FARWELL: It a lot to think about it’s so much more than you have ever
asked for.

* * *

BIRCHMORE: And still less than what any other girl would ask for

58. On January 20, 2021, Person 2 called the Stoughton Police Department, and in that

call referenced the sexual relationship between Birchmore and FARWELL. After learning about

this call—the fact of which suggested at least some aspects of FARWELL’s illicit conduct may

have been exposed to the Stoughton Police Department—FARWELL sent Birchmore text

messages revealing his extreme anger. He sent her a series of text messages with expletives, telling

Birchmore that he thought no one knew about their relationship, that she had no clue how bad this

was, and indicating that he does not know if he needs to worry about other disclosures.

FARWELL: Dude your fucking friend called my job Sandra wtf

BIRCHMORE: ?

FARWELL: You’re [sic] friend [Person 2’s name] just called my fucking
work to complain about me wtf

BIRCHMORE: Idk

FARWELL: What do you mean you don’t know

BIRCHMORE: I literally just woke up

FARWELL: Did you steal from her?

BIRCHMORE: Nope

FARWELL: What is going on?

FARWELL: You also told me that no one knew about us yet she claimed
we are fucking

* * *

BIRCHMORE: It’s literally nothing

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FARWELL: It’s not nothing she called my job that’s insane.

* * *

FARWELL: Why would she call and drop my fucking name Sandra? Like
what do I have to do with you not giving her something?

* * *

FARWELL: Like you have no idea how bad what she did is

* * *

FARWELL: I literally can’t believe this is even real life like what else do
I have to worry about now? Which other friend will do
something tomorrow?

59. During this investigation, I have interviewed Person 5, an employee of the

Stoughton Police Department, who received the call from Person 2 on January 20, 2021. 8 Person

5 indicated that he/she took down Person 2’s name and information and gave it to FARWELL.

Person 5 indicated that FARWELL immediately got angry and “pissed off” and ordered Person 5

“not to speak about this to anyone and to never talk about it again.” Person 5 described

FARWELL’s reaction as atypical and not consistent with his normal behavior.

D. Birchmore’s Final Days

60. On January 24, 2021, approximately one week prior to Birchmore’s death, she

communicated with Person 8 about FARWELL.

BIRCHMORE: Soo the father came by last night it was like a complete 360
change

PERSON 8: 180?

BIRCHMORE: Yeah lol

8
Person 5 did not have an independent memory of the date of the call, but I have confirmed
such date through business records.

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PERSON 8: Good or bad?

BIRCHMORE: Good, but unexpected. So it kinda threw me off and made


me a little uncomfortable but that’s cause of how things were
going. He asked me if I’d give him a key and said that if I
keep it a secret he’ll be around and see them and all that. So
its somewhere. Then he looked in my closet and then the
bathroom but idk why haven’t figured that out.

BIRCHMORE: We started to heart to heart then work called him so he had


to leave.

BIRCHMORE: Oh and he brought me a ginger ale because I ran out

PERSON 8: What about the birth certificate?

BIRCHMORE: I think he’s signing it not sure

BIRCHMORE: Hes coming back again this week

BIRCHMORE: But it was like a complete like 180 from where we were at

61. Based on my training and experience, I believe that FARWELL’s shift in demeanor

on or about this date was his attempt to appease Birchmore until he could kill her. Additionally,

the foregoing text messages, considered in light of the other evidence, suggests that FARWELL

was making a plan to kill Birchmore. Part of that plan included asking Birchmore to give him a

key and keep it secret. Another part of that plan was inspecting various rooms of Birchmore’s

apartment, including the closet, to determine whether they contained items or presented options

for how and when to kill Birchmore.9

62. FARWELL’s request for a key for Birchmore’s apartment in the week leading up

to her death is corroborated by other evidence. I have reviewed text messages between FARWELL

and Birchmore from January 24, 2021, in which Birchmore gave FARWELL the passcode to her

9
On February 4, 2021, Canton Police found Birchmore’s body next to the closet door with
a duffle bag strap around her neck. The strap was wrapped around the closet door handle.

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building’s front door and told him, “I have your key too when you want it”. Additionally, I have

reviewed records from Walmart that suggest that Birchmore did, in fact, pay approximately $2.00

to have a key copied at approximately 11:10 a.m. on January 24, 2021.

63. According to text messages Birchmore and FARWELL exchanged on January 29,

2021, Birchmore again gave FARWELL the passcode to her building’s front door and FARWELL

verified that the code was the general one given to the entire building, not just one assigned to her.

64. FARWELL requesting or accepting a key to Birchmore’s apartment was a sudden

change from recent conversations. I have reviewed text messages between FARWELL and

Birchmore—one as recent as October 14, 2020—in which FARWELL told her that he did not

think it was a good idea for him to keep a key to her new (Canton) apartment. In a conversation

with her friend, Person 9, on January 24, 2021, Birchmore indicated that she was surprised that

FARWELL was now requesting a key to her apartment:

PERSON 9: Did it go good with him

BIRCHMORE: I got hit with a shocker question. Can I call you

BIRCHMORE: So what really well surprisingly him he asked if he could


have a key I am basically said he’ll be around as long as I
keep it a secret and don’t tell anybody

BIRCHMORE: But he did admit that I do have the upper hand in the situation
Which isn’t a good thing but I’m trying to and not be that
person if you know what I mean

PERSON 9: I get it are you gonna give him a key

BIRCHMORE: I just made a copy of it yeah

PERSON 9: That’s good

BIRCHMORE: I’m not gonna give it to him yet but he also brought me a
Ginger ale last night like I asked him to

PERSON 9: He’s coming around

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BIRCHMORE: A lot more than I thought he was going to yes

BIRCHMORE: I still have to verify the pin for him to get into the apartment
if he rings me and I don’t answer

BIRCHMORE: But like last night he open my closet door for some thing and
then he went in my bathroom looking at my bathroom and
then I have a dolly in my living room that he asked why I
had it was just really odd he started looking around I don’t
know

PERSON 9: That’s weird

BIRCHMORE: Yeah it was really weird

65. According to text messages between FARWELL and Birchmore two days before

Birchmore’s death, she continued to engage FARWELL about planning for the birth of their child.

On January 30, 2021, Birchmore asked FARWELL if she could tell him the baby names she was

considering. FARWELL told her he would rather discuss that topic in person.

66. Leading up to February 1, 2021, Birchmore planned for other important baby-

related events, such as who would care for her cats when she went into labor. 10 She ordered baby

items and conducted Google searches related to her pregnancy and future child-rearing decisions.

She also planned for newborn baby photos, an official pregnancy announcement, which she

planned to do on Valentine’s Day, as well as a gender reveal. 11 She also made plans for her more

immediate future, scheduling an OBGYN appointment for February 10, 2021, and asking

FARWELL to help shovel out her car during the impending snowstorm.

10
This planning is of note because it indicates that shortly before her death, Birchmore was
doing things that indicated her plans for the future. It is also important because it reveals a level
of care for her pets that is inconsistent with the circumstances of her death. Specifically, when
police found Birchmore’s body in her apartment on February 4, 2021, her cats were present. She
had made no arrangements for the animals.
11
During the investigation, agents also learned that Birchmore had been taking classes in
preparation for applying to nursing school.

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E. The day Birchmore died.

67. On February 1, 2021, at 12:19 p.m., Birchmore sent FARWELL text messages

indicating that she was going to be released early (at 12:35 p.m.) from her job at the Sharon Public

Schools. FARWELL told her that he would not be in the area that day.

68. Later in the afternoon of February 1, 2021, Birchmore told FARWELL that she had

received an early gift in the mail and that she was not planning to have a baby shower until late

March because of the then-ongoing COVID-19 pandemic. She told FARWELL that once she

learned whether they were having a boy or a girl, she wanted him to purchase clothes for the child

to wear when he or she came home from the hospital.

69. Investigators have reviewed surveillance videos from Birchmore’s Canton

apartment building.12 On February 1, 2021, she is seen on the video at approximately 5:01 p.m.,

accepting a DoorDash order, and then again going outside briefly and returning with a snow brush

at 5:31 p.m, and 5:33 p.m., respectively. The last time Birchmore is seen alive on the video is on

February 1, 2021, at 5:33 p.m..

70. Later that evening, at approximately 9:08 p.m., FARWELL sent Birchmore a text

message asking whether he could “come by for a second.” At approximately 9:10 p.m., Birchmore

sent FARWELL a text message indicating that when he arrived at her apartment, the door would

be open for him. This is the last known outgoing message sent from Birchmore’s cell phone.

71. Surveillance video shows FARWELL entering Birchmore’s Canton apartment

building at 9:14 p.m.13 In the surveillance video, FARWELL is wearing street clothes, a hoodie

12
I am aware that the electronic timestamp on the apartment complex’s video surveillance
system was off by approximately 13 minutes. The surveillance video times set forth in this affidavit
account for this 13-minute difference and are therefore the approximate real times of the events.
13
I have reviewed Massachusetts State Police investigative reports which tentatively
identify FARWELL as the person on surveillance footage entering Birchmore’s apartment on
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with the hood up, and a facemask that is similar to the medical facemasks that many people used

during the COVID-19 pandemic. I have interviewed multiple witnesses who have each indicated

that FARWELL resisted wearing a mask during the pandemic. One of these witnesses stated that

FARWELL would only wear a mask when on duty and required by department policy to do so.

The video surveillance recording shows that FARWELL left Birchmore’s apartment at 9:43 p.m.

F. Canton police officers found Birchmore’s body on February 4, 2021.

72. On February 4, 2021, Canton police officers conducted a well-being check at

Birchmore’s apartment. One of Birchmore’s co-workers called the police because Birchmore had

failed to show up for work that day. When officers arrived, they found Birchmore’s body seated

on the floor in a reclined position with a duffle bag strap tied around her neck. That strap was

connected to her closet doorknob—the closet that FARWELL had inspected approximately one

week earlier. At least one first responder quickly concluded that Birchmore had been deceased for

“days.”

73. I have reviewed crime scene photographs that depict Birchmore wearing the same

clothing that she was wearing when she is seen on video entering her apartment on February 1,

2021, at approximately 5:33p.m. This is consistent with Birchmore having died later that same

evening.

74. According to police reports, when Birchmore’s body was found, her cell phone was

on the floor located approximately 12 inches from her right hand and 6 inches from her bent right

knee.

February 1, 2021. I have also reviewed a report regarding State Police detectives’ interview of
FARWELL, in which FARWELL admitted that he went to Birchmore’s apartment on February 1,
2021. In that interview, FARWELL stated that he had been there between approximately 9:10
p.m. and 9:30 p.m.

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75. I have reviewed the data on Birchmore’s phone. A log report indicates that the

phone was locked from 9:13 p.m. on February 1, 2021, until the device powered off because of

battery loss on February 3, 2021. On February 1, 2021, while still locked, Birchmore’s phone

recorded a screenshot of a black screen at 9:18 p.m. In other words, after sending a final text

message to FARWELL to tell him the door was unlocked, Birchmore’s phone locked and was not

unlocked until after the device was recovered by police.

76. Health data on Birchmore’s phone indicates that the last movement recorded by the

phone on February 1, 2021, occurred at 9:40 p.m. 14 That was 3 minutes before FARWELL was

captured on surveillance video leaving Birchmore’s apartment. Specifically, this data indicates

that the mechanism that Apple uses to record movement registered eight steps at approximately

9:40 p.m. These recorded steps occurred while FARWELL was still in Birchmore’s apartment.

The phone recorded no additional steps between 9:40 p.m. and the time it was recovered by first

responders on February 4, 2021. As noted above, first responders ultimately found the phone next

to Birchmore’s body. Based on my review of the frequency of Birchmore’s phone use over weeks,

months, and years leading up to her death, her failure to access her phone is inconsistent with her

usual habits when alive and awake.15

77. I reviewed Birchmore’s phone use from the hours leading up to her death on

February 1, 2021. The following are some of the items in Birchmore’s phone data from the hours

14
Based on my training and experience, I am aware that Apple iPhones can be used to
track and retain health-related data of the user, including but not limited to “steps” taken.
15
I have also interviewed multiple witnesses who have reported on Birchmore’s frequent,
almost incessant, phone use. In fact, one witness referred to Birchmore’s phone as her “third
hand.”

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before her death. This is evidence that appears to be inconsistent with Birchmore, a pregnant

woman, choosing to die by suicide that day:

Time Event

1:25p.m. - Birchmore communicated with a photographer regarding the timeline for


1:31p.m. booking a newborn photography shoot
7:57 p.m. Birchmore texted a friend to obtain baby clothes from her

8:25 p.m. Birchmore performed a Google search for “Cubby Kids” furniture

G. The condition of, and items found in, Birchmore’s apartment were
inconsistent with Birchmore dying by suicide.

78. I have interviewed family members who helped clean Birchmore’s apartment in the

days following her death. Some of the things they observed were also inconsistent with Birchmore

deciding to die by suicide. For example, during their first visit, they noted that Birchmore had

been in the middle of doing laundry when she died, with a load of wet clothes in the washing

machine and another load dry in the dryer. Additionally, they observed a homemade sign saying,

“Congratulations you’re going to be a father.” That sign had an ultrasound photo on it and was

sprinkled with glitter.

79. Additionally, in Birchmore’s apartment, family members observed a new baby

stroller that was still in its package. They also observed homemade and store-bought onesies for

a baby. One onesie read, “We’re going to be PARENTS!” with a set of footprints underneath.

Birchmore had packages that had been delivered recently, including clothing and other supplies

for her baby. Birchmore had ordered items shortly before her death and packages continued to

arrive in the days following her death.

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80. Finally, family members found a necklace that belonged to Birchmore lying on the

floor of her bedroom. This necklace consisted of a thin gold chain with a pink flamingo charm. 16

The family members observed that the necklace’s chain was broken, but not at the clasp. There

was also a large clump of hair on the chain. From my review of the crime scene photos, I observed

that, while the strap was still around Birchmore’s neck, the necklace was broken and hanging from

the left side of her neck. The necklace’s charm was on the right side of her abdomen.

H. Autopsy and Medical Evidence

81. An OCME pathologist (hereinafter, the “Medical Examiner”) performed an autopsy

on Birchmore’s body. The Medical Examiner determined that Birchmore’s cause of death was

asphyxia by hanging. The Medical Examiner ruled Birchmore’s manner of death a suicide. The

Medical Examiner’s written autopsy report noted that Birchmore’s hyoid bone (a U-shaped bone

at the front of the neck) was fractured on the right side and that she suffered from petechial

hemorrhages of the bulbar and palpebral conjunctivae. Additionally, the Medical Examiner

concluded that Birchmore had a hemorrhage of her left sternothyroid muscle.

82. The Medical Examiner’s autopsy report further confirmed that Birchmore was

approximately 8 to 10 weeks pregnant at the time of her death. The autopsy included toxicology

testing. The results of the toxicology tests were negative for all substances except for sertraline,

which was likely explained by the antidepressants Birchmore had been prescribed.

83. As part of this investigation, the government retained Dr. William Smock as an

expert to independently review the crime scene photos, autopsy photos, and the Medical

Examiner’s autopsy report. Dr. Smock is an emergency medicine residency and forensic

16
In my review of Birchmore’s phone data, I noticed several photos of Birchmore in which
she is wearing this necklace.

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fellowship trained physician with more than 40-years of experience in the forensic evaluation of

injuries, crime scenes, the forensic evaluation and reconstruction of wounds, including asphyxia-

related deaths. His training, experience and position as a Police Surgeon, Instructor at the

Louisville Metro Police Academy, Instructor for the U.S. Department of Justice, a Professor of

Emergency Medicine, Medical Director of an EMS service, Physician and Medical Advisor to the

FBI and U.S. Marshals Service, and an Assistant Medical Examiner with the Kentucky Medical

Examiner’s includes the emergency treatment, investigation, and reconstruction of asphyxia-

related deaths and the analysis of crime scene for evidence of alteration. He has treated and

evaluated thousands of patients, both fatally and non-fatally injured, who have experienced the

physiological consequences of asphyxia, including strangulation. Dr. Smock has written, lectured

extensively and trained thousands of law enforcement officers, physicians, nurses, judges and

attorneys on evidence collection, crime scene investigation, the analysis and reconstruction of

wounds, injury mechanisms, and the medical risks and consequences of asphyxia.

84. Based on his review of the evidence, Dr. Smock has made several observations and

conclusions that call into question the prior finding that Birchmore’s cause of death was suicide

and instead further confirm that Birchmore’s cause of death was homicide.

85. First, Dr. Smock concluded that the fracture of the right superior horn of

Birchmore’s hyoid bone is not consistent with the position in which first responders found her:

sitting. A sitting hanging is called “an incomplete hanging,” meaning only partial body weight is

applied to the neck ligature. Dr. Smock’s review of hundreds of cases of hangings in the forensic

medical literature found no reported cases of hyoid bone fractures in seated women. Fractures of

the hyoid bone are more commonly seen in strangulation assaults and in hangings with full body

weight applied to the ligature, but not seated hangings.

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86. Second, Dr. Smock noted that, during the autopsy, a pattern imprint was

documented on Birchmore’s right upper chest. The pattern imprint was the consequence of a

buckle or buckles from the ligature strap being forced downward into Ms. Birchmore’s chest. The

presence of this pattern imprint is not consistent with a ligature hanging. Rather, the presence of

the pattern is consistent with blunt force trauma from an assault. When first responders found

Birchmore’s body, the buckle responsible for this imprint was observed just below her right ear.

However, the location of the imprint on her chest is not consistent with an incomplete ligature

hanging.

87. Third, Dr. Smock reviewed the autopsy photos that depict Birchmore with areas of

skin missing from the inferior and lateral aspects of her nose consistent with abrasions. These

types of injuries are commonly seen in cases of suffocation when the victim moves their nose back

and forth in an effort to breathe.

88. Fourth, Dr. Smock noted that Birchmore was in the habit of always wearing a chain

necklace with a flamingo pendant. The chain was found broken around Birchmore’s neck. The

breaking of Birchmore’s chain necklace is consistent with a struggle.

89. Dr. Smock, based on his education, experience, training and his review of the

materials in this case opined, with a reasonable degree of medical and scientific certainty, that the

cause of Ms. Birchmore’s death is asphyxia and that the manner of her death is homicide.

I. Massachusetts State Police Interview of Matthew Farwell

90. On February 6, 2021, two days after police found Birchmore’s body in her

apartment, Massachusetts State Police detectives interviewed FARWELL. The interview occurred

in the parking lot of a Stoughton elementary school. During this interview, FARWELL made

several false statements about his relationship with Birchmore.

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91. FARWELL told officers that he was involved in a sexual relationship with

Birchmore, but he claimed the relationship only began in 2020. Based on this investigation,

FARWELL’s statement to detectives was false. As described above, FARWELL began having

sex with Birchmore in 2013 and continued to have sex with her until near her death.

92. FARWELL told detectives that he had only had sex with Birchmore two or three

times in the previous year. This statement was also false. Based on text messages between

FARWELL and Birchmore, FARWELL had sexual intercourse with Birchmore on at least 10

occasions between January 1, 2020, and February 1, 2021.

93. FARWELL also told detectives that he could not have been the father of

Birchmore’s unborn child because the last time he had intercourse with her was October 2020.

This statement was also false. Set forth below is a text message conversation between FARWELL

and Birchmore on November 18, 2020, in which they discussed an upcoming sexual encounter:

FARWELL: I’m going to try for tonight I’ve been in interviews


all day from the murder Sorry

BIRCHMORE: Exciting. Okay. I’m running to the store and doing


something for you then. I hope you can come

FARWELL: What are you doing for me?

BIRCHMORE: Lol shaving.

BIRCHMORE: Are you planning on rolling me over? I need to know


what you want if you come?

FARWELL: If you want me to roll you

* * *

FARWELL: Would you want me to use a condom if I roll you?

BIRCHMORE: I dont have any lol. I never picked any up.

* * *

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BIRCHMORE: Do you want me to just take what you do or try and


say no? I know being told no is your favorite

FARWELL: Say no

BIRCHMORE: 😉 I can do that

94. Approximately 21 minutes after the foregoing text messages, FARWELL told

Birchmore that he was at her apartment and subsequent text messages indicate that she let him in.

Approximately 25 minutes later, Birchmore asked FARWELL via text message whether he

enjoyed having vaginal sex with her again and he responded, “yeah.”

95. During the February 6, 2021, interview, FARWELL told detectives that he had been

at Birchmore’s apartment on the night of February 1, 2021. However, he denied having anything

to do with her death. He told detectives that he had arrived around 9:10 p.m. and left around 9:30

p.m. I am aware from my review of surveillance footage from Birchmore’s apartment building

that FARWELL actually left at 9:43 p.m. That was after Birchmore’s phone stopped sending

messages or recording movement. Within approximately 13 hours of FARWELL’s visit to

Birchmore apartment on February 1, 2021, his wife gave birth to their third child at Newton

Wellesley Hospital, adding to the intensifying pressure to ensure that Birchmore would not

disclose information regarding FARWELL’s conduct.

96. FARWELL told detectives that he had not seen Birchmore at all in the week leading

up to her death, except during the visit to her apartment on February 1, 2021. Based on my review

of the text messages between FARWELL and Birchmore, FARWELL visited Birchmore at her

apartment on January 29, 2021.

97. FARWELL told detectives that Birchmore had been “sectioned” many times.

Based on my training and experience, “sectioned” is a term that Massachusetts law enforcement

officers often use to refer to the practice of involuntarily hospitalizing, on a temporary basis,

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Case 1:24-cr-10259-DJC Document 9-1 Filed 08/28/24 Page 36 of 45

persons with severe mental health issues. However, the Stoughton Police Department, the law

enforcement agency in the town where Birchmore lived her whole life before moving to Canton

on or about December 1, 2020, has a record of Birchmore being subject to this temporary mental

health hospitalization only one time, in May of 2020. According to police records and information

disclosed by Person 7, on that day, Birchmore had gotten into a fight with a family member, who

called the police and reported Birchmore was going to harm herself. The police took Birchmore

to the hospital, where she was evaluated and deemed not at risk for self-harm. She was released a

few hours later. According to Person 7, Birchmore stated that she was not suicidal, just angry at

her family member. Additionally, I am aware that, minutes after Birchmore’s release from this

unfounded “section,” FARWELL and Birchmore engaged in a graphic sexual conversation. Later,

Birchmore apologized for worrying FARWELL and FARWELL replied, “I wasn’t worried. I

know you are fine.”

98. The Canton Police Department has no record of Birchmore being subject to

temporary mental health hospitalization. While there is evidence that indicates that Birchmore

may have had suicidal ideations on a few occasions between 2016-2018, which FARWELL likely

knew about because he was exploiting her during that time, I am not aware of credible evidence

of any suicidal ideations in the approximately three years leading up to her death. In fact, all of

the witnesses who agents interviewed about their interactions with Birchmore in the weeks leading

up to her death suggested that, during that period, she was excited, optimistic, and involved in

future planning.

99. Person 7 had a therapy session with Birchmore on January 31, 2021. During that

meeting, Person 7 screened Birchmore for any signs of depression or suicidal ideation. He/she

found none. Person 7 had regular sessions with Birchmore and noted no signs of depression or

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Case 1:24-cr-10259-DJC Document 9-1 Filed 08/28/24 Page 37 of 45

suicidal ideation in the months leading up to Birchmore’s death, and had her next appointment

scheduled with Birchmore for February 4, 2021.

100. Additionally, FARWELL told detectives that he “had been trying to distance

himself” from Birchmore. This is inconsistent with evidence that in Birchmore’s final days,

FARWELL asked for a key to her apartment. I have also reviewed a text message from January

28, 2021, just days before Birchmore’s death, in which FARWELL told her that when he came

over that night, he would give her “hugs.” In that same conversation, he told her that he may not

be able to visit her because he was “at a death” but that it was all good because “we do them all

the time.”17 In addition, I have reviewed a text message exchange between Birchmore and

FARWELL from January 29, 2021, in which Birchmore expressed joy at FARWELL agreeing to

engage in sexual activity with her again.

J. Farwell’s post interview conduct

101. Following Birchmore’s death, the Stoughton Police Department placed FARWELL

on administrative leave. Around that time, FARWELL met a co-worker, Person 4, at a local bar.

During that meeting, FARWELL told Person 4 that he had a sexual relationship with Birchmore.

However, according to Person 4, at no point during that conversation did FARWELL express any

sadness, grief, or remorse about Birchmore’s death. FARWELL told Person 4 that he was “angry

with MSP for looking into him.”

102. At some point during the summer of 2021, Person 4 attended a social gathering

with FARWELL during which FARWELL participated in a joke about Birchmore being “hung on

the door.”

17
I am aware that in FARWELL’s time as a Stoughton Police officer and then detective,
he responded to unattended deaths.

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III. Additional Evidence Relevant to Detention

A. Farwell had a history of choking Birchmore.

103. Through this investigation, agents have identified evidence that FARWELL

expressed an interest in violent sex and has a history of choking Birchmore. On more than one

occasion, FARWELL asked Birchmore to perform his rape fantasies during sex, whereby

Birchmore would pretend to be the victim of FARWELL’s simulated sexual assaults.

104. Moreover, I have reviewed text messages that indicate that over the course of their

relationship, FARWELL initiated the concept of choking Birchmore on numerous occasions. In

2020, the year preceding her death, text messages reveal that FARWELL told Birchmore on at

least 20 separate occasions that he would grab her throat, pin her down by her throat, squeeze her

throat, or choke her during sexual activity. These messages were sent on the following dates:

January 29, 2020; February 10, 2020; February 21, 2020; March 9, 2020; March 23, 2020; March

30, 2020; April 2, 2020; May 11, 2020; May 14, 2020; May 15, 2020; June 4, 2020; June 7, 2020;

June 13, 2020; June 27, 2020; August 5, 2020; August 14, 2020; September 25, 2020; October 14,

2020; October 15, 2020; and November 13, 2020.

105. Based on my review of Birchmore’s journal entries, as early as 2013 (when

Birchmore was just 16 years old), FARWELL introduced the idea of choking during their sexual

encounters and discussions.

106. One such example of FARWELL promising to choke Birchmore occurred on

October 14, 2020, when FARWELL told Birchmore that he was going to “cover her mouth” during

sex and “maybe I’ll choke you a little.” In that same conversation, FARWELL told Birchmore,

“I’ll grab your throat and say you wont’ [sic] say a word to anyone.”

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107. On October 15, 2020, FARWELL told Birchmore that, during their next sexual

encounter, he was going to “grab [her] throat and say stfu now or I won’t pull out.” 18

108. On November 13, 2020, FARWELL and Birchmore again discussed choking. In

that conversation, FARWELL told Birchmore, “Maybe I’ll hold you down by your throat while I

pound you…” He asked her “how tight” he should squeeze and then stated that he wanted her to

feel like “omg this is really happening and I can’t stop it.”

B. Farwell used violent sex as a form of punishment.

109. Birchmore’s journal entries from 2013 through 2020 detail a continuous and

sometimes violent sexual relationship with FARWELL. Birchmore often journaled about

FARWELL using sex acts to punish her. According to her journal entries, FARWELL would

engage in forceful oral, vaginal, and anal sex acts to punish her for her mistakes such as getting

bad grades, having intercourse with other people, and failing to share her cell phone location with

him. I have reviewed numerous text messages that FARWELL sent Birchmore, including some

from March of 2019, which are consistent with FARWELL’s practice of using certain sex acts to

punish her for lying or being intimate with someone else. For example, in a text conversation on

March 7, 2019, FARWELL said:

FARWELL: You would have to take a serious pounding to make


me happy

* * *

BIRCHMORE: Is it for everything?

FARWELL: No.
* * *

FARWELL: You owe me 3

18
Based on my training and experience, I know that the acronym “stfu” means “shut the
fuck up.”

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Case 1:24-cr-10259-DJC Document 9-1 Filed 08/28/24 Page 40 of 45

* * *

FARWELL: I’ll give you a break and spread them out

BIRCHMORE: Please not all the same day

FARWELL: No I’ll give you like a week so you can feel it and
then as soon as it goes away you’ll get it again so you
feel it for like a whole month

* * *

BIRCHMORE: Not gonna be a fun month

FARWELL: Not for you

C. Farwell’s fixation with rape fantasies.

110. Text messages between FARWELL and Birchmore reveal FARWELL’s interest in

sexual assault. For example, in one text conversation on November 8, 2020, FARWELL told

Birchmore that he enjoyed having sex with her. When Birchmore asked what would be perfect

for him, FARWELL replied, “you say no and make me take it. Full r word.” 19 When Birchmore

indicated that she was amenable to that, FARWELL responded, “doesn’t matter I’ll do whatever I

want anyways.”

111. During another text message conversation between FARWELL and Birchmore,

FARWELL instructed Birchmore to call him “daddy” during sexual encounters. In that

conversation on October 18, 2020, FARWELL told Birchmore that “daddy” was going to engage

in anal sex with her. He also indicated that when he was done, he was going to grab her hair, pull

her head back, and tell her to “keep [her] fucking mouth shut do you understand me.”

19
Based on my review of the text messages between FARWELL and Birchmore, I believe
FARWELL is referring to rape as the “r word” in this message.

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D. Farwell has obsessive and controlling tendencies.

112. Text messages between FARWELL and Birchmore include FARWELL’s repeated

demands that Birchmore set her phone’s location sharing settings to allow him to always view her

location. In these text conversations, FARWELL indicated Birchmore needed to share this

information in order to gain back his trust for her alleged lies and infidelity.

a. On March 11, 2019, FARWELL asked Birchmore why her location was off

and why he can no longer see it.

b. On March 22, 2019, FARWELL asked Birchmore to reveal her location.

When she responded that she was at “7-11,” FARWELL told her that he knew she was in Abington,

and he asked multiple times why she would go there when “Stoughton has 100 convenience

stores.”

c. On April 22, 2019, FARWELL sent Birchmore a text message stating, “I

know your [sic] hiding shit your location is off again.”

d. On June 22, 2019, FARWELL sent Birchmore a text message asking why

she turned off her location data “the other day.”

e. On July 5, 2019, FARWELL again reached out to Birchmore saying, “I see

your location is off again.”

113. In July of 2020, FARWELL apparently transitioned from wanting to track

Birchmore’s location to prioritizing secrecy.

FARWELL: You can turn your location back off if you want

BIRCHMORE: It wasn’t off. Thats why I wasnt sure why it wasnt showing
up. Then I just unshared and reshared it with you. You can
have it. Its been a thing for years lol.

FARWELL: Lol ok

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BIRCHMORE: Idc if you know where I am. Im not doing anything I


shouldn’t be. My legs shaking a shit ton rn. Im feeling that
tmrw

FARWELL: lol I know that I just don’t really like any of that stuff big
brother is always watching

BIRCHMORE: I don’t understand what you mean.

FARWELL: I’m just saying iPhones keep track of way too much stuff I
don’t mean anything by it.

E. Farwell’s iCloud account contains disturbing images regarding


violence and necrophilia.

114. During this investigation, pursuant to a federal search warrant, agents obtained and

reviewed data from FARWELL’s iCloud account. Located in FARWELL’s iCloud were several

memes that indicate his interest in sexual intercourse with dead bodies:

a. A meme that states, “what does a pulse and an orgasm have in common? I

don’t care if she has either.” Another meme states, “if you fuck a corpse on a waterbed, it feels

like they are participating.”

b. A meme glorifying a person who kills and sexually abuses someone who

“no one will miss.”

115. FARWELL’s iCloud data also contains images that reveal his interest in domestic

and sexual violence:

a. A meme containing a photo of a woman with tape over her mouth that states,

“Duct tape turning ‘no, no, no’ into ‘mmm, mmm, mmm’ since 1942.”

116. FARWELL’s iCloud data also includes images that could reveal his interest in

strangulation. For example, one such image states, “When she says ‘choke me daddy’ and you get

carried away and now she’s dead.” There is also a screenshot of an image of a woman saying that

she could not sleep, followed by a man choking her saying, “goodnight bitch.”

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IV. FARWELL’s Efforts to Conceal His Crimes.

117. On February 9, 2021, after giving his personal cell phone to State Police detectives,

FARWELL used his Stoughton Police-issued cell phone to make and delete two Google searches.

First, FARWELL searched for and deleted: “can delete [sic] imessage be recovered hy [sic]

cellebrite.” He then searched for and deleted: “can you revoke consent in massachusetts.”

118. I have identified text messages between FARWELL and Birchmore in which

FARWELL directed Birchmore to destroy evidence of their sexual relationship:

a. On March 11, 2019, FARWELL sent Birchmore a text reminding her to

“Make sure you clear all this out.”

b. On March 19, 2019, FARWELL sent Birchmore texts about his desire to

use sexual violence and to pretend to rape her. At the end of this conversation, FARWELL sent

her a text indicating that he was going to bed and instructed her to “Clear out this text.”

c. On June 5, 2019, FARWELL directed Birchmore to make sure all of their

text messages and Facebook messages had been deleted.

119. There are also text messages between FARWELL and Birchmore in which

FARWELL directed Birchmore to destroy evidence regarding the beginning of their relationship.

This would be evidence of FARWELL’s efforts to coerce and entice Birchmore to engage in sexual

intercourse when she was 15 years old:

FARWELL: Wish we had just done it for real the first time

BIRCHMORE: I know you do baby : (

FARWELL: it would’ve been perfect

BIRCHMORE: Yes!
* * *

BIRCHMORE: Was it still perfect the first time?

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FARWELL: Of course it was baby

BIRCHMORE: :)

* * *
FARWELL: I never thought you’d let me

BIRCHMORE: I never thought you would.

FARWELL: I wanted it so bad

BIRCHMORE: So did I! I knew the day we made eye contact I


wasnted [sic] you to fuck me

BIRCHMORE: Wanted*

FARWELL: You should’ve told me we could’ve fucked so much


sooner

BIRCHMORE: :)

FARWELL: Clear that out part out baby

BIRCHMORE: I did

FARWELL: Good girl

[The remainder of this page is blank.]

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Conclusion

The information set forth above supports the government’s motion to detain Matthew

Farwell pending trial in this case.

Sworn to under the pains and penalties of perjury,

/s/ Chenee Castruita


Chenee Castruita
Special Agent
Federal Bureau of Investigation

August 28, 2024

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