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IN THE ST. JOSEPH SUPERIOR COURT CAUSE NO. 71DO ~ -12 D

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STATE OF INDIANA VS. OWEN "BUTCH" MORGAN, JR. DOB: XX-XX-1949

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INFORMATION IN FOUR COUNTS: COUNT I: CONSPIRACY TO COMMIT PETITION FRAUD, CLASS D FELONY COUNT II: CONSPIRACY TO COMMIT PETITION FRAUD, CLASS D FELONY COUNT III: CONSPIRACY TO COMMIT FORGERY,CLASSCFELONY COUNT IV: CONSPIRACY TO COMMIT FORGERY, CLASS C FELONY COUNT!.

JOEL R. GABRIELSE, upon information and belief, affirms under the penalty of perjury that: On or about January and February, 2008, in St. Joseph County, State ofIndiana, OWEN "BUTCH" MORGAN, JR. acting with the intent to commit the crime of petition fraud, agreed with Lucas Burkett and/or Pamela Brunette and/or Dustin Blythe and/or Beverly Shelton to commit the crime of petition fraud, and overt acts in further of the agreement were performed by one or more of the conspirators when forged ballot petitions for Presidential Candidate Barack Obama were created. All of which is contrary to the form of the statute in such cases made and provided, to wit: Indiana Code 35-41-5-2 and 3-14-1-1 and 35-41-2-4, and against the peace and dignity of the State of Indiana. COUNT II. JOEL R. GABRIELSE, upon information and belief, affirms under the penalty of perjury that:
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On or about January-arid'F'ebruary, 2008, in St. Joseph County, State ofIndiana, OWEN "BUTCH" MORGAN, JR. acting with the intent to commit the crime of petition fraud, agreed with Lucas Burkett and/or Pamela Brunette and/or Dustin Blythe and/or Beverly Shelton to commit the crime of petition fraud, and overt acts in furtherance of the agreement were performed by one or more of the conspirators when forged ballot petitions for Presidential Candidate Hillary Clinton were created. All of which is contrary to the form of the statute in such cases made and provided, to wit: Indiana Code 35-41-5-2 AND 3-14-1-1 and 35-41-2-4, and against the peace and dignity of the State of Indiana. COUNT III. JOEL R. GABRIELSE, upon information and belief, affirms under the penalty of perjury that: On or about January and February, 2008, in St. Joseph County, State ofIndiana, OWEN "BUTCH" MORGAN, JR. acting wIth the intent to commit the crime of forgery, which is knowingly uttering a written instrument that purports to have been made by another person or by authority of one who did not give authority, with the intent to defraud, agreed with Lucas Burkette and/or Pamela Brunette and/or Dustin Blyth_eand/or Beverly Shelton to commit the crime of forgery, and overts acts in furtherance of the agreement were performed by one or more

of the conspirators when forged ballot petitions for Presidential Candidate Barack Obama were created. All of which is contrary to the form of the statute in such cases made and provided, to
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wit: Indiana Code 35-41-5-2 and 35-43-5-2 and 35-41-2-4, and against the peace and dignity of the State of Indiana.

JOEL R. GABRIELSE, upon information and belief, affirms under the penalty of perjury that: On or about January and February, 2008,in 81. Joseph County, State ofIndiana, OWEN "BUTCH" MORGAN, JR. acting with the intent to commit the crime of forgery, which is knowingly uttering a written instrument that purports to have been made by another person or by authority of one who did not give authority, with the intent to defraud, agreed with Lucas Burkett and/or Pamela Brunette and/or Dustin Blythe and/or Beverly Shelton to commit the crime of forgery, and overt acts in furtherance of the agreement were performed by one or more of the conspirators when forged ballot petitions for Presidential Candidate Hillary Clinton were created. All of which is contrary to the form of the statute in such cases made and provided, to wit: Indiana Code 35-41-5-2 and 35-43-5-2 and 35-41-2-4, and againstthe peace and dignity of the State of Indiana. I affirm under the penalties for perjury, that the foregoing representations are true.

JOEL~ DEPUTY PROSECUTING Probable cause found . Arrest warrant ordered issued. Bond set
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STATE OF INDIANA ST. JOSEPH COUNTY STATE OF INDIANA VS. OWEN "BUTCH'! MORGAN, JR. DOB: XX-XX-1949

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IN THE ST. JOSEPH SUPERIOR COURT CAUSE NO. 71DO ~ -12

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SUPPLEMENTAL AFFIDA VIT IN.-~4P,f SUPPORT OF PROBABLE CAUSE

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THOMAS LITTLEFIELD, perjury that:

upon information and belief, affirms under the penalties for

I am a Detective with the Indiana State Police. I have been conducting an investigation into the circumstances of the ballot petition process in St. Joseph County, Indiana, for the elections held in 2008. I make this affidavit upon personal knowledge and from information gained from other law enforcement officers participating in the investigation. In 2008 there were primary elections for various offices, including President of the United States, held throughout the country. Indiana participated in that election process. Pursuant to Indiana law, potential Presidential candidates are only placed on the Indiana ballots if a sufficient number of signatures (from registered, valid voters) are collected on petitions. After the signatures are collected, the petitions are turned in to the St. Joseph County Voter Registration Office for verification that all signatures correspond to registered, valid voters. Receipts are generated, showing who brought the petitions into that office. Following verification by that local office, the petitions are then turned in to the State Voter Registration Office in Indianapolis, and the ballot process continues. During this process in 2008, petitions with signatures from St. Joseph County were required for candidates Barack Obama and Hillary Clinton to be placed on Indiana ballots .
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Petitions for these"candidates were turned in to the St. Joseph County Voter Registration"Office, and were subsequently forwarded to Indianapolis after verification. In 2011, Mr. Lucas Burkett came forward to law enforcement with information about forged signatures on these petitions in 2008. I interviewed Mr. Burkett at length on multiple occasions, and he explained to me that in 2007 and 2008 he was heavily involved in St. Joseph County political activities with the local Democratic Party, and that he was an employee of the County Voter Registration Office. He was appointed to his position by OWEN "BUTCH" MORGAN, JR., who was the local Democratic Party Chairman. Mr. Burkett's supervisor at the office was Pamela Brunette, who also served at the pleasure of OWEN "BUTCH" MORGAN, JR. Mr. Burkett said that in January 2008, he and several others (including Dustin Blythe, Pamela Brunette and Beverly Shelton, who was another employee from the Voter Registration Office) had meetings with OWEN "BUTCH" MORGAN, JR. at the local Democratic Party Headquarters in South Bend, St. Joseph County, Indiana. At these meetings, OWEN "BUTCH" MORGAN, JR. instructed Mr. Burkett, Pamela Brunette, Beverly Shelton, and Dustin Blythe to forge ballot petitions for presidential candidates. Mr. Burkett said that all of them agreed to follow these instructions. Mr. Burkett said that OWEN "BUTCH" MORGAN, JR. then handed out copies of completed, valid petitions for an unrelated gubernatorial election (for Democratic candidate Jim Schellinger). OWEN "BUTCH" MORGAN, JR. said that these were to be used for pattern or "source" documents for forging petitions.
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Mr. Burkett explained that he (Burkett) was assigned to forge petitions for candidate Barack Obama. He said that Beverly Shelton was assigned to forge petitions for candidate

Hillary Clinton, and that DustinBlythe'was Edwards.

assigned to forge petitions for candidate John

Mr. Burkett admitted to me that he began to participate in the forging process, and that he had personally forged several signatures on.petitions. I obtained copies of the St. Joseph County Presidential candidate petitions that were eventually forwarded to the Indianapolis Office as described above. Mr. Burkett reviewed those petitions with me, and pointed out several signatures that he himself had forged on Barack Obama petitions. He also described how he had personally seen Beverly Shelton forging petitions for Hillary Clinton. Mr. Burkett said, however, that toward the end of January, he decided that he could not participate in the scheme anymore, so he told his supervisor, Pamela Brunette, that he would no longer forge any signatures. He said that Pamela Brunette was very upset and made him ~peak to OWEN "BUTCH" MORGAN, JR. personally on the phone, and that OWEN "BUTCH" MORGAN, JR. was also very upset with him. Mr. Burkett explained that candidate John Edwards dropped out of the race at approximately that time. As a result of that, in conjunction with Mr. Burkett's unwillingness to participate any longer, OWEN "BUTCH" MORGAN, JR. instructed Dustin Blythe to begin forging petitions for candidate Barack Obama. Along with other Detectives from the Indiana State Police, I reviewed all of the petitions for candidates Hillary Clinton and Barack Obama that were submitted to Indianapolis. I found

multiple groups of petitions that immediately appeared to be forged. In each group, all of the "signatures" on the multiple pages of petitions appeared to have been written in the same handwriting (consistent within the group, but different than the handwriting for the other suspicious groups).

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One of the groups of apparent forged petitions was'.for candidate Barack Obama. That group contained 9 apparent forged petitions (each with multiple entries). Another group of apparent forged petitions was for candidate Hillary Clinton. That group contained at least 13 apparent forged petitions (each with multiple entries). --- " -.-

Along with other Detectives, I compared many of the "signatures" to known signatures on record for the actual individuals, and found that the "signatures" on the petitions did not match actual signatures. We also selected names at random from each of the petition pages and

contacted those people directly. We found at least one person (and often multiple people) from each page who confirmed that they had not signed that petition or given consent for their name and/or signature to appear on the petition. This confirmed that everyone of these 22 suspicious petitions did contain forged entries. Further, because ofMr. Burkett's explanation regarding valid gubernatorial petitions being used as "source" documents, I obtained copies of those valid gubernatorial petitions and compared them to the forged petitions. I found that the information on all of those forged petitions could indeed be traced back to valid gubernatorial petitions. I also found that everyone of these 22 forged petitions was turned in to Pamela Brunette in the St. Joseph County Voter Registration Office and certified by her during January and February, 2008. The dates on all of the documents I reviewed also corresponded to the details in the description of events given to me by Mr. Burkett. Copies of these 22 petitions are attached as Exhibits 1 to 22. I interviewed Ms. Linda Silcott, the Republican party supervisor in the St. Joseph County Voter Registration Office. She explained that she and Pamela Brunette had equivalent positions in the Voter Registration Office in 2008. I showed Ms. Silcott the 22 forged petitions, and she

>.,told'me that she recognized Dustin Blythe's handwriting on one group of'forgeries, and Beverly Shelton's handwriting on another group of forgeries. She said that she is familiar with both of their handwriting styles after working with them for several years in the same office. Ms. Silcott also identified Pamela Brunette's initials on the. front of each of the forged .petitions and Pamela Brunette's signature on the back of each forged petition. All of the events described above happened in St. Joseph County, Indiana. I affirm, under the penalties for perjury, that the fore oing representations are true.

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