IN THE SUPERIOR COURT FOR THE STATE OF ALASKA THIRD JUDICIAL DISTRICT AT ANCHORAGE STATE OF ALASKA, Plaintiff, vs. GABRIELLE LEDOUX Defendant 2 l- I. CASE NO. BAN-204 I ?22: CR - - SUMMONS To: GABRIELLE LEDOUX Home Phone: Work phone: Home Address: 8859 Cross Point Loop Work Address: 120 4th Street Anchorage, AK 99504 You are summoned to appear before the District/Superior Court at: Court Address: Anchorage-Nesbett Courthouse, 825 4th Ave, Anchorage, AK 99501 Date and Time: to answer to: the attached charging document. a petition to revoke probation. a notice of reinstatement of prosecution. a charge that you have failed to satisfy your judgment by Original Charge: If you fail to appear, a warrant will be issued for your arrest (limb 13 20 20 4% Judge 4 all/m. Type or Print Judge?s Name . RETURN OF SUMMONS I received this summons 2020, and served it 2020, at in Alaska, by delivering (address) (city) a c0py of it and a copy of the charging document to the defendant or a person of suitable age and discretion residing at the defendant?s home or usual place of residence. Return Date Signature of Peace Of?cer Type or Print Name CRIOS Crim. R. 4(6) 85 9 SUMMONS Mun-nun?. IN THE SUPERIOR COURT FOR THE STATE OF ALASKA THIRD JUDICIAL DISTRICT AT ANCHORAGE STATE OF ALASKA, Plainti??, vs. LISA SIMPSON Defendant I- .- CASE NO. 23 CR - SUMMONS To: LISA SIMPSON Home Phone: Work phone: Home Address: 1221 Boston St. Apt Work Address: PO Box 241367 Anchorage, AK 99504 You are summoned to appear before the District/Superior Court at: Court Address: Anehorage-Nesbett Courthouse, 825 4th Ave, Anchorage, AK 99501 Date and Time: to answer to: the attached charging document. a petition to revoke probation. a notice of reinstatement of prosecution. a charge that you have failed to satisfy your judgment by Original Charge: If you fail to appear, a warrant will be issued for your arrest. @lealw Jud-g! . [Ajax/46a Type or Print Judge?s Name . . RETURN OF SUMMONS I received this summons 2020, and served it 2020, at in Alaska, by delivering (address) (city) a copy of it and a copy of the charging document to the defendant or a person of suitable age and discretion residing at the defendant?s home or usual place of residence. Return Date Signature of Peace Of?cer Type or Print Name cmos Crim. R. 4(c) 9 SUMMONS IN THE SUPERIOR COURT FOR THE STATE OF ALASKA THIRD JUDICIAL DISTRICT AT ANCHORAGE STATE OF ALASKA, Plaintiff, vs. CADEN VAUGHT Defendant l- I. CASE NO. 2 CR - SUMMONS To: CADEN VAUGHT Home Phone: Work phone: Home Address: 12731 Brandon St. Work Address: Amhorage, AK 99515 You are summoned to appear before the District/Superior Court at: Court Address: Anchorage-Nesbett Courthouse, 825 4th Ave, Anchorage, AK 99501 Date and Time: to answer to: IE the attached charging document. a petition to revoke probation. a notice of reinstatement of prosecution. a charge that you have failed to satisfy your judgment by Original Charge: If you fail to appear, a warrant will be issued for your arrest. . MUM. Type or Print Judge?s Name . A RETURN OF SUMMONS I received this summons 2020, and served it 2020, at in Alaska, by delivering (address) (city) a c0py of it and a copy of the charging document to the defendant or a person of suitable age and discretion residing at the defendant?s home or usual place of residence. Return Date Signature of Peace Of?cer Type or Print Name CRIOS Crim. R. 4(c) 9 SUMMONS Department of Law, Criminal Division 310 Street Suite 60] ,Anchoragc, AK 99501 Phone: (907) 269~6250 Fax: (907) 269-7939 Email: lawosp@alaska.gov 44?5444 IN THE DISTRICT COURT FOR THE STATE OF ALASKA THIRD JUDICIAL DISTRICT AT ANCHORAGE STATE OF ALASKA, Plaintiff, '39; vs. GABRIELLE LEDOUX ,3 77,33. ?59" a a" LISA SIMPSON CADEN VAUGHT Defendants. 3AN-18-2715 3AN-18-27I7 3AN-18-2718 3AN-18- 2719 3AN-18-2720 3AN-18-2722 3AN-18-2723 3AN-18-2725 3AN-18-2726 8? 2728 3AN-18-2729 3AN-18-2965 3AN-18-2966 3AN-18-2967 3AN-18-2968 3AN-18-2969 3AN-18-2970 3AN-18- 3157 3AN-18-3160 3AN-18-316I SW No. CR (Gabrielle LeDoux) N0. 3AN-20- 2473 CR (LisaMSimpson) No. 3AN-20- 2.13M CR (Caden Vaught) INFORMATION Department of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: 269-6250 Fax: (907) 269?7 939 Email: lawosp@alaska.gov 2 ?/1772 '2 OK I certify this document and its attachments do not contain the (1) name of a victim of a sexual offense listed in AS 12.6l.l40 or (2) residence or business address or telephone number of a victim of or witness to any offense unless it is an address identifying the place ot?a crime or an address or telephone number in a transcript of a court proceeding and disclosure of the information was ordered by the court. The following counts charge a crime involvingDOMESTlC VIOLENCE as defined in AS 18.66.990: NONE Count I - AS 15.56.040 Voter Misconduct 1 Gabrielle LeDoux - 001, Lisa Simpson 001 Count II - AS 15.56.040 Voter Misconduct 1 Lisa Simpson 002, Caden Vaught - 001 Count - AS 15.56.040 Voter Misconduct 1 Lisa Simpson 003, Caden Vaught - 002 Count IV - AS 15.56.040 Voter Misconduct Caden Vaught - 003 Count - AS 15.56.040 Voter Misconduct Caden Vaught - 004 Count VI AS 15.56.050 Voter Misconduct 2 Gabrielle LeDoux 002, Lisa Simpson - 004 Count VII - AS 15.56.050 Voter Misconduct 2 Caden Vaught 005 Count - AS 15.56.050 Voter Misconduct 2 Caden Vaught - 006 Count IX - AS 15.56.050 Voter Misconduct 2 Gabrielle LeDoux - 003, Lisa Simpson - 005 Count AS 15.56.050 Voter Misconduct 2 lnfon'nation State v. LeDoux, Lisa Simpson, Caden Vaught, Page 2 of 18 Department of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: (907) 269-6250 Fax: (907) 269?7939 Email: Iawosp@alaska.gov Caden Vaught - 007 Count XI - AS 15.56.050 Voter Misconduct 2 Caden Vaught - 008 Count XII - AS 15.56.035 Unlawful Interference Voting 2 Gabrielle LeDoux - 004 Count AS 15.56.035 Unlawful Interference Voting 2 Gabrielle LeDoux - 005, Lisa Simpson - 006 Count XIV AS 15.56.035 Unlawful Interference Voting 2 Gabrielle LeDoux - 006, Lisa Simpson - 007 Count XV AS 15.56.035 Unlawful Interference Voting 2 Gabrielle LeDoux - 007 Count XVI - AS 15.56.035 Unlawful Interference Voting 2 Gabrielle LeDoux - 008 Count XVII - AS 15.56.035 Unlawful Interference Voting 2 Gabrielle LeDoux - 009 Count - AS 15.56.035 Unlawful Interference Voting 2 Gabrielle LeDoux - 010 THE OFFICE OF SPECIAL PROSECUTIONS CHARGES: COUNT I 3414-2671721 2(75 "247 That in the Third Judicial District, State of Alaska, on or about July 18, 2018, at or near Anchorage, Alaska GABRIELLE R. LEDOUX and LISA M. SIMPSON, while Information State v. Gabrielle LeDoux, Lisa Simpson, Caden Vaught, Page 3 of 18 uepartment of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: (907) 269-6250 Fax: (907) 26931939 Email: law05p@alaska.gov (DmNODm-th?l ?Wan-mm . .9172 mi acting as principals or accomplices, intentionally made a false af?davit, swore falsely, or falsely af?rmed under an oath required by Title 15, to wit: falsely ?lled out Simpson?s voter registration application. All of which is a Class Felony offense being contrary to and in violation of AS 15.56.040 and against the peace and dignity of the State of Alaska. COUNT 11 That in the Third Judicial District, State of Alaska, on or about June 17, 2018, at or near Anchorage, Alaska, LISA M. SIMPSON and CADEN C. VAUGHT, while acting as principals or accomplices, intentionally made a false af?davit, swore falsely, or falsely af?rmed under an oath required by Title 15 to wit: falsely ?lled out Vaught?s voter registration application. All of which is a Class Felony offense being contrary to and in violation of AS 15 56.040 and against the peace and dignity of the State of Alaska. COUNT That in the Third Judicial District, State of Alaska, on or about September 28, 2018, at or near Anchorage, Alaska, LISA M. SIMPSON and CADEN C. VAUGHT, while acting as principals or accomplices, intentionally made a false af?davit, swore falsely, or falsely af?rmed under an oath required by Title 15, to wit: falsely ?lled out Vaught?s voter registration application. All of which is a Class Felony offense being contrary to and in violation of AS 15.56.040 and against the peace and dignity of the State of Alaska. COUNT IV That in the Third Judicial District, State of Alaska, on or about August 21, 2018, at or near Anchorage, Alaska, CADEN C. VAUGHT intentionally made a false affidavit, swore falsely, or falsely af?rmed under an oath required by Title 15, to wit: signing under oath when voting a questioned ballot in the 2018 primary election. Information State v. Gabrielle LeDoux, Lisa Simpson, Caden Vaught, Page 4 of 18 uepartment of Law, Criminal Division 310 Street Suxte 601 Anchorage, AK 99501 Phone: (907) 269-6250 Fax: (907) 269-7939 Email: 1awosp@alaska.gov All of which is a Class Felony offense being contrary to and in violation of AS 15.56.040 and against the peace and dignity of the State of Alaska. COUNT That in the Third Judicial District, State of Alaska, on or about November 6, 2018, at or near Anchorage, Alaska, CADEN C. VAUGHT intentionally made a false affidavit, swore falsely, or falsely af?rmed under an oath required by Title 15, to wit: signing under oath when voting a questioned ballot in the 2018 general election. All of which is a Class Felony offense being contrary to and in violation of AS 15.56.040 and against the peace and dignity of the State of Alaska. COUNT VI That in the Third Judicial District, State of Alaska, on or about July 18, 2018, at or near Anchorage, Alaska, GABRIELLE R. LEDOUX and LISA M. SIMPSON, while acting as principals or accomplices, registered Simpson to vote without being entitled to register under AS 1507030. All of which is a Class A Misdemeanor offense being contrary to and in violation of AS and against the peace and dignity of the State of Alaska. COUNT VII That in the Third Judicial District, State of Alaska, on or about June 17, 2018, at or near Anchorage, Alaska, CADEN C. VAUGHT registered to vote without being entitled to register under AS 15.07.030. All of which is a Class A Misdemeanor offense being contrary to and in violation of AS and against the peace and dignity of the State of Alaska. COUNT That in the Third Judicial District, State of Alaska, on or about September 28, 2018, at or near Anchorage, Alaska, CADEN C. VAUGHT registered to vote without being entitled to register under AS 15.07.030. Information State v. Gabrielle LeDoux, Lisa Simpson, Caden Vaught, Page 5 of 18 uepartment of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: (907) 269-6250 Fax: (907) 269?7939 Email: lawosp@alaska.gov Nmm-h-oaN?thom-slmm-tsz?so .9-173 217?! All of which is a Class A Misdemeanor offense being contrary to and in violation of AS 15 and against the peace and dignity of the State of Alaska. COUNT IX That in the Third Judicial District, State of Alaska, on or about July 18, 2018, at or near Anchorage, Alaska, GABRIELLE R. LEDOUX and LISA M. SIMPSON, while acting as principals or accomplices, knowingly made a material false statement while applying for voter registration or reregistration. All of which is a Class A Misdemeanor offense being contrary to and in violation of AS 15 56.05 and against the peace and dignity of the State of Alaska. COUNT That in the Third Judicial District, State of Alaska, on or about June 17, 2018, at or near Anchorage, Alaska, CADEN C. VAUGHT knowingly made a material false statement while applying for voter registration or reregistration. All of which is a Class A Misdemeanor offense being contrary to and in violation of AS and against the peace and dignity of the State of Alaska. COUNT XI That in the Third Judicial District, State of Alaska, on or about September 28, 2018, at or near Anchorage, Alaska, CADEN C. VAUGHT knowingly made a material false statement while applying for voter registration or reregistration. All of which is a Class A Misdemeanor offense being contrary to and in violation of AS and against the peace and dignity of the State of Alaska. COUNT XII That in the Third Judicial District, State of Alaska, on or about July 18, 2018, at or near Anchorage, Alaska, GABRIELLE R, LEDOUX knowingly solicited or Information State v. Gabrielle LeDoux, Lisa Simpson, Caden Vaught, Page 6 of 18 k, uepartment 01 Law, Criminal Division 310 Street Su1te 601 Anchorage AK 99501 Phone: (907) 269-6250 Fax: (907) 269-7939 Email: 1awosp@alaska.gov 39W :26? ~23 {78. .2173 2m encouraged, directly or indirectly, a registered voter who is no longer quali?ed to vote under AS 15.05.010, to vote in an election, to wit: LISA SIMPSON. All of which is a Class A Misdemeanor offense being contrary to and in violation of AS 15.56.035 and against the peace and dignity of the State of Alaska. COUNT That in the Third Judicial District, State of Alaska, on or about August 19, 2018, at or near Anchorage, Alaska, GABRIELLE R. LEDOUX and LISA M. SIMPSON, while acting as principals or accomplices, knowingly solicited or encouraged, directly or indirectly, a registered voter who is no longer quali?ed to vote under AS 15.05.010, to vote in an election, to wit CADEN C. VAUGHT in the 2018 primary election. All of which is a Class A Misdemeanor offense being contrary to and in violation of AS 15 56.035 and against the peace and dignity of the State of Alaska. COUNT XIV That in the Third Judicial District, State of Alaska, on or about September 25, 2018, at or near Anchorage, Alaska, GABRIELLE R. LEDOUX and LISA M. SIMPSON, while acting as principals or accomplices, knowingly solicited or encouraged, directly or indirectly, a registered voter who is no longer quali?ed to vote under AS 15.05 .010, to vote in an election, to wit CADEN C. VAUGHT in the 2018 general election. All of which is a Class A Misdemeanor offense being contrary to and in violation of AS 15.56.035 and against the peace and dignity of the State of Alaska. COUNT XV That in the Third Judicial District, State of Alaska, on or about July 18, 2018, at or near Anchorage, Alaska, GABRIELLE R. LEDOUX knowingly solicited or encouraged, directly or indirectly, a registered voter who is no longer quali?ed to vote Information State v. Gabn?e?e LeDoux, Lisa Simpson, Caden Vaught, Page 7 of 18 Department of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: (907) 269-6250 Fax: (907) 269?7939 Email: lawosp@alaska.gov 3214/. 204.217 under AS 1505010, to vote in an election, to wit Patrick Simpson in the 2018 primary election. All of which is a Class A Misdemeanor offense being contrary to and in violation of AS 15.56.035 and against the peace and dignity of the State of Alaska. COUNT XVI That in the Third Judicial District, State of Alaska, on or about September 25, 2018, at or near Anchorage, Alaska, GABRIELLE R. LEDOUX knowingly solicited or encouraged, directly or indirectly, a registered voter who is no longer quali?ed to vote under AS 15.05.010, to vote in an election, to wit Patrick Simpson in the 2018 general election. All of which is a Class A Misdemeanor offense being contrary to and in violation of AS 15.56.035 and against the peace and dignity of the State of Alaska. COUNT XVII That in the Third Judicial District, State of Alaska, on or about November 3, 2014, at or near Anchorage, Alaska, GABRIELLE R. LEDOUX knowingly solicited or encouraged, directly or indirectly, a registered voter who is no longer quali?ed to vote under AS 15.05.010, to vote in an election, to wit: Dot Helgason in the 2014 general election. All of which is a Class A Misdemeanor offense being contrary to and in violation of AS 15.56.035 and against the peace and dignity of the State of Alaska. COUNT That in the Third Judicial District, State of Alaska, on or about October 21, 2014, at or near Anchorage, Alaska, GABRIELLE R. LEDOUX knowingly solicited or encouraged, directly or indirectly, a registered voter who is no longer quali?ed to vote under AS 1505010, to vote in an election, to wit: Bonnie Bailey in the 2014 general election. lnfon'nation State v. Gabn?eh?e LeDoux, Lisa Simpson, Caden Vaught, Page 8 of 18 i7 ,31 Department of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: (907) 269-6250 Fax: (907) 269-7939 Email: lawosp@alaska.gov Saw/0 a; 9,173 CR 217rfc? All of which is a Class A Misdemeanor offense being contrary to and in violation of AS 15.56.035 and against the peace and dignity of the State of Alaska. The undersigned swears under oath this Information is based upon a review of reports drafted in Alaska State Trooper case number AK18059736 submitted to date, a review of evidence collected and conversations with involved investigators. On August 16, 2018, the Division of Elections noti?ed the Alaska State Troopers that there appeared to be irregularities with a number of applications for absentee ballots for the upcoming Primary Election, which was to be held on August 21, 2018. Those irregularities focused attention on the House District 15 Republican primary. AST investigators worked with the Alaska Division of Elections to determine if there was a common cause for, or link, between the signi?cant number of irregularities. Voter records from the last several election cycles were examined, voters were contacted in person and over the phone, and over 25 search warrants were obtained between August 16, 2018 and November 30, 2018. The FBI joined the investigation at the end of November, 2018. As part of the ongoing investigation, investigators attempted to contact Gabrielle LeDoux, one of the candidates in the Republican primary for House District 15. Investigators also attempted to contact several people known to have worked or helped on LeDoux?s campaign, including Lisa (Vaught) Simpson, a friend of LeDoux?s who previously worked for LeDoux as her chief of staff and was listed as a LeDoux campaign of?cial with APOC in some capacity in several election cycles. Text messages to and from LeDoux and others, including Simpson, were also collected pursuant to search warrants. These texts raised concerns that LeDoux had solicited and/or encouraged people who did not live in her district to vote in the House District 15 primary and general elections in 2018 and 2014. Investigators determined that Simpson registered to vote in House District 15 on July 18, 2018, by ?lling out and mailing a voter registration application to DOE. Simpson voted in person at a House District 15 precinct polling place in both the 2018 information State v. Gabrielle LeDoux, Lisa Simpson. Caden Vaught, Page 9 of 18 Department of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: (907) 269?6250 Fax: (907) 269~7939 Email: lawosp@alaska.gov fw??ei?m CR 9473(1 19?17% C): primary and general elections (held on August 21 and November 6, respectively). Simpson?s adult son, Caden Vaught, also registered to vote in the House District 15 primary and general elections (Vaught submitted three separate voter registration applications between June and September 2018, two of the registrations listed an address within House District 15). In order to register to vote, a voter must ?ll out a voter registration form; this form requires the person to provide, amongst other information, their name and residence address. Those details are required to be provided by law. The Alaska Constitution, Article V, Sec. 1 requires that: voter shall have been, immediately preceding the election, a thirty day resident of the election district in which he seeks to vote . . Alaska Statute 15.05.020 de?nes residence by setting forth the parameters, including, in pertinent part: The residence of a person is that place in which the person?s habitation is ?xed, and to which, whenever absent, the person has the intention to return. If a person resides in one place, but does business in another, the former is the person?s place of residence. Temporary work sites do not constitute a dwelling place. A person does not gain residence in any place to which the person comes without the present intention to establish a permanent dwelling at that place. The term of residence is computed by including the day on which the person?s residence begins and excluding the day of election. Everyone who registers to vote must sign the following certi?cation as part of their voter registration application: Voter Certi?cate: Read and Sign: I certify, under penalty of perjury, that the above information I provided on this document is true and correct. I am not registered to vote in another state, or I have provided information to cancel that registration. I further certify that I am a resident of Alaska and I have not been convicted of a felony, or having been so convicted, have been unconditionally discharged from incarceration, probation and/or parole. Information State v. Gabn?e?e LeDoux. Lisa Simpson, Caden Vaught, Page 10 of 18 Department of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: (907) 269-6250 Fax: (907) 269-7939 Email: lawosp@aiaska.gov _k 2175? 17474 WARNING: If you provide false information on this application you can be convicted of a misdemeanor AS 15.56.050. Caden Vaught voted in House District 15 in both the 2018 primary and general elections by what is called a ?questioned ballot.? A questioned ballot is used when the status of an in?person voter cannot be immediately veri?ed through records on Election Day. A person using such a ballot must sign an additional, but similar, oath prior to voting: I swear or a?irm, under penalty of perjury, that: The information on this form is true, accurate and complete to the best of my knowledge. I further certify that I am a resident of Alaska and I have not been convicted of a felony, or having been so convicted, have been unconditionally discharged from incarceration, probation, and/or parole. I am not registered to vote in another state, or I have taken the necessary steps to cancel that registration. I am or have been a registered voter in Alaska at some time in the last 4 years or am newly registering. I have not and will not vote in any other manner in this election. Simpson submitted a voter registration application she signed on July 18, 2018. In her application, she listed her address of residence as a particular unit of a triplex located on Boston Street, which is in House District 15. Simpson signed the form below the oath acknowledging that she was swearing to its contents under penalty of perjury. LeDoux signed the registration form as the registrar.1 Simpson voted in person at a House District 15 precinct in both the primary and general election cycles. Simpson could only lawfully vote in House District 15 using the Boston Street address if she had legally established that location as her residence within at least thirty days of the election. Investigators pulled records to verify where Simpson lived between July and November of 2018. Three different relevant addresses were found when reviewing records: residences on Shoshoni Avenue, Dorbrandt Street, and Boston Street. 1 Registrars are qualified voters authorized by the Division of Elections to assist with the completion and veri?cation of an applicant?s identity and the submission of voter registration forms to the Division of Elections. Registrars are able to act as ?witnesses? for voters signing their application; those applications that are witnessed by a registrar become effective on the day the voter registration application is signed, instead of the day the division receives it. Infon'nation State v. Gabrfeh'e LeDoux, Lisa Simpson, Caden Vaught, Page 11 01?18 MW #671 17a 44444444.; Email: lawosp@alaska.gov .3. (0 Phone: (907) 269-6250 Fax: (907) 269-7939 Department of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 NGm-h-mN?i 2175 2174 Shoshoni Avenue: Public records showed that Simpson?s husband, Patrick Simpson, had owned a residential property on Shoshoni Avenue in Anchorage since at least 2017. This address is not within House District 15. Dorbrandt Streeti Lisa Simpson owned a triplex on Dorbrandt St. prior to June 2018. In June 2018, ownership of that triplex was converted to an LLC (with the name of the property?s address as its title). The LLC, jointly owned by Lisa and Patrick Simpson, was described as being a lessor of residential buildings and dwellings and listed the Simpson?s Shoshoni Avenue address as the physical address. The Dorbrandt triplex is not in House District 15. Boston Street: Public records also indicated that on August 14, 2018, the Simpsons purchased a triplex on Boston Street. That triplex is located in House District 15. On her July voter registration application, Lisa Simpson listed Unit in the Boston Street residence as her residence address. The Simpsons did not own the Boston residence at that time. According to Chugach Electric Service records, someone other than Patrick or Lisa Simpson took over payment responsibility for the services at Unit of the Boston residence (the unit Lisa Simpson claimed as her residence) on October 30, 2018. Based on available records, it appears that this person was a tenant renting the unit from the" Simpsons. PFD records indicate that Simpson used the Dorbrandt Street address on the PFD application she ?led on March 18, 2018 for both her mailing and physical address. Simpson used the Shoshani address for her physical address (with a PO Box as her mailing address) on her PFD application ?led on March 5, 2019. In early 2019, investigators obtained a search warrant to seize and search LeDoux?s phone and certain email messages. Once the documents were available for review, they were screened by the US. Department of Justice in a process called a ?taint review? to ensure the contents did not include privileged information, such as Information State v. Gabrielle LeDoux, Lisa Simpson, Caden Vaughi, Page 12 of 18 310 Street Suite 601,Anchorage, AK 99501 Phone: (907) 269-6250 Fax: (907) 269?7939 Department of Law, Criminal Division Email: lawosp@alaska.gov 9471 communications with attorneys. This review was conducted by individuals not connected to the prosecution team in order to ensure that members of the prosecution team did not review or come into possession of privileged material. The contents of the phone and email search were shared with members of the state prosecution team towards the end of February in 2020. On July 18, 2018 (the same day Lisa Simpson registered to vote using the Boston address as her residence address) LeDoux sent the following text to Simpson: ?Did you ?ll out the voter registration form? Will Pat do one also.? Simpson replied ?Yes, I ?lled out the voter registration. Pat doesn?t want to do it until we close on the property.? In the two days immediately before the primary election, LeDoux sent several texts to Simpson inquiring about the status of Caden Vaught?s application, noting that he ?is NOT on list of peOple who requested absentees.?2 On the day of the primary, August 21, LeDoux texted Simpson and informed her that Vaught had submitted a new voter form moving his residence to the Dorbrandt address, which (as LeDoux noted in the text) was in House District 23. On September 25 and 27 of 2018, after the primary but before the general election, LeDoux sent three texts to Simpson about getting Vaught and Patrick Simpson registered in her district: ?We have got to get Caden and hopefully Pat reregistered by October ?Can you get Caden and hOpefully Patrick reregistered by end of next week??; ?And can you get Caden registered in the district.? Simpson responded on September 27 by stating: ?Yes, I can reregister Caden but not Pat. He won?t unless he actually lives there and we don?t yet.? On the 28th, LeDoux asked for Simpson?s address and stated ?Maybe I can reregister Caden when I see him.? Simpson responded ?You can register Caden at [the speci?c address on] Lori Drive.? 2 As is discussed in more detail below, Vaught?s initial voter application, on June 17, would have ensured he received a House District 15 ballot. However, his second application, signed on July 12 (more than 30 days prior to the primary election), in which he listed the Dorbrandt address switched his registration to House District 23. Thus, based on the subsequent application, he was not on the list ofeiigibie House District 15 voters in August of2018. Information State v. Gabn?e?e LeDoux, Lisa Simpson, Caden Vaught, Page 13 of 18 UK UL OCDCD??mm-wa?i Email: lawosp@alaska.gov _x _x (D 03 O) A (.0 Department of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: (907)269-6250 Fax: (907) 269-7939 2344/40 9 l7 Qt 2i (R 1174 (3/2 On December 4, 2018, after both elections were over, LeDoux texted Simpson and asked ?Have you moved in at Boston Street.? Simpson responded, ?We are still trying to get [a tenant out]. I think she is physically gone but all her stuff is still there and it stinks. We went to court, have given her numerous chances and I?m having the locks changed today. She hasn?t paid any rent for 3 months!? Moreover, as described above, an apparent tenant had taken over ?nancial responsibilities in October for the unit Simpson claimed as her residence when voting. In summary, the Simpsons did not own the Boston triplex at the time Lisa Simpson ?lled out her voter registration application in July 2018?and at the time of the general election, a tenant had, eight days prior, signed a contract for utilities for the unit Simpson claimed to live in. A review of other text messages on Simpson?s phone provided additional indication that the Simpsons were living at the Shoshoni residence during the latter part of 2018 and into 2019, not the Boston triplex. Caden Vaught submitted three voter registration applications during the 2018 election cycle; each form includes language that it is signed under penalty of perjury. Vaught?s ?rst application was signed on June 17, 2018 with a listed residence address on Lori Drive (which is in House District 15). Simpson is the listed registrar on this form. Vaught?s second application was signed on July 12, 2018 with a residence address on Dorbrandt Street (the same address as the residence that Lisa Simpson owns; this residence is not in House District 15). On this form, Vaught listed the Lori address as his mailing address. Vaught?s third voter registration application was signed on September 28, 2018, (after the primary but before the general election?wand the day after Simpson texted LeDoux to say she would re?register Vaught) and listed a residence on Lori Drive as his address. It appears that LeDoux signed this third application as the registrar. Vaught voted in both the primary and general election by questioned ballot in person at a House District 15 polling place. Each time, he signed the certi?cation verifying under penalty of perjury that the information he provided was accurate. In both information State v. Gabrielle LeDoux, Lisa Simpson, Caden Vaught, Page 14 of 18 Department of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: (907) 269-6250 Fax: (907) 269-7939 Emaii: 1awosp@alaska.gov N) MMNm?x?x?x?x?x-t?x-t?X?x 2.021720?. 2.175 (1C 217% at the primary election on August 21, 2018 and the general election on November 6, 2018, Vaught listed and certi?ed under oath that his residence address was on Lori Drive. On March 28, 2019, Caden Vaught was interviewed by the FBI. Vaught said that in November of 2015 he moved to the Lori address (which is in House District 15) and lived with his brother and sister-in-law, Charles and Bethany Vaught. Vaught reported that he lived at Lori until approximately August 2016. Vaught reported that he moved back in with his mom at the Dorbrandt residence in August of 2016 and lived there until he went to the Alaska Military Youth Academy. Vaught reported that he spent ?ve and a half months at the Youth Academy during 2018. The Dorbrandt residence is not in House District 15. Vaught said that when he returned from the Youth Academy, he moved into a residence on Brandon Street with his ?ancee on Aug. 27, 2018. This address is not in House District 15. Vaught said his mom ?lled out-his ?rst voter application (on June 17) while he was at the Youth Academy, but that he signed it. Vaught said that he ?lled out and signed the other two voter applications. He reported that he was attending the Alaska Military Youth Academy at the time he ?lled out his second application; the Dorbrandt address he provided was where he lived with his mom prior to leaving for the Youth Academy. By the time he ?lled out the third application, Vaught was living at the Brandon Street residence. Vaught acknowledged that he did not live at the Lori Drive residence at the time that he signed or submitted any of the three applications. A review of Vaught?s PFD applications corroborates the timeline he provided to the FBI, as his PFD records show that Vaught listed the Dorbrandt Street address as his mailing and physical address on his March 19, 2018 application and the Brandon Street address on his March 5, 2019 application. Charles and Bethany Vaught were interviewed on March 28, 2019 and reported that Caden Vaught lived with them in 2015, but that he had not lived with them for about two years?and that he was not living with them during any of the time period Information State v. Gabrielle LeDoux, Lisa Simpson, Caden Vaught. Page 15 of 18 Department of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: (907) 269-6250 Fax: (907) 269-7939 Email: lawosp@aiaska.gov 91/1/26) 217 17 217% surrounding the 2018 elections. Charles and Bethany con?rmed the general timeline that Caden Vaught provided to the FBI as to where he was living. Additional information was discovered during a review of LeDoux?s phones. Multiple text messages were found that showed that LeDoux requested at least two pe0ple to vote in her district?despite their having told LeDoux that they no longer lived in the district. On November 3, 2014?the day before the election??LeDoux sent two relevant messages to Helgason, one at 0642 hours: Dot. I have not seen your name I the list of people who have requested absentee ballots. TODAY at 5 pm Alaska standard time is the last day to request a ballot. You can only request now through fax or online. This is going to a VERY CLOSE election and I am going to really NEED your vote. Can please request a ballot TODAY. And a second at 1234 hours: Dot, don?t worry about the legality of this. Remember when I wanted to challenge peOple 4 years ago the division of elections was simply not interested. You own the place so you clearly have the right to claim it as your residence. At this point you would not even able to vote in the district where living because not registered there. So PLEASE go on line and request a ballot. Helgason did not vote in the 2014 election in House District 15. Helgason was contacted on March 6, 2020. She reported that she did not recall LeDoux asking her by text to vote in House District 15. According to Helgason, she moved from her residence in House District 15 a year or two prior to the 2014 election but had not changed her voter registration. Public records indicated that Helgason did continue to own a residence in House District 15 through January of 2015, but according to Helgason she did not reside in that residence in November of 2014 (or at any point in 2014). Despite indicating that she did not recall the text message exchange, Helgason reported that when LeDoux texted her about being registered to vote in House District 15, she believed that LeDoux was just telling her so she could vote. On October 21, 2014, LeDoux sent a text to Bonnie Bailey, stating: Information State v. Gabrielle LeDoux, Lisa Simpson, Caden Vaught. Page Department of Law, Criminal Division 310 Street Suite 601,Anchorage, AK 99501 Phone: (907) 269-6250 Fax: (907) 269-7939 Email: lawosp@alaska.gov or: Q. (7)9 CK ?247% CK 2117hrs LeDoux to Bailey ?Hi Bonnie. Where you and josh living these days. still registered in my district and would really appreciate it if you would vote here. I am in a real tight race. I can send you absentee ballot applications if you give me your new address.? By asking for Bailey?s new address, LeDoux indicated she knew Bailey had moved. Bailey con?rmed this by sending texts at 2206 hours that stated ?I?m living in midtown?3 and ?But I think I can still vote east side.? LeDoux reSponded at 2208 hours by stating: ?You should still vote here. You and josh are still registered here, can change your registration after the election.? On October 27, 2014, LeDoux encouraged Bailey to vote early, apparently to avoid going ?back to the eastside.?4 Bailey was interviewed by investigators on March 5, 2020. She acknowledged that she knew LeDoux from Kodiak and that LeDoux was one of her mother?s friends growing up. When shown the text messages, Bailey reported that she did not believe the text messages were correct. Bailey stated that at the time she was going through a separation and her husband was living in the district, but that she was not in a permanent residence. Bailey reported that LeDoux had come to Bailey?s temporary residence, which was not in the district, around the time of the texts. Bailey also reported that she had suggested something to LeDoux and LeDoux stated that she could not do it because Bailey did not live in her district. Bailey stated that she did not believe that LeDoux would ask Bailey to vote in her district unless she was living in the district. Bailey reported that she does not believe that the text messages accurately re?ect what LeDoux said and claimed she had conversations with LeDoux where LeDoux told Bailey not to vote in her district. 3 The area commonly known as ?midtown? falls outside of the boundaries of House District 15. 4 The message is somewhat unclear, but states: ?Since things are so hectic for you guys you should consider voting early at the muni or the division of elections so would have to ce back to the eastside, this election is going to close so every vote will count.? Information State v. Gabrielle LeDoux, Lisa Simpson, Caden Vaught, Page 1' 7 of 1'8 Department of Law, Criminal Division 310 Street Suite 601,Anch0rage, AK 99501 Phone: (907) 269-6250 Fax: (907) 269-7939 Email: lawosp@alaska.gov 32/14/20- ,2)an 7475 2! 7 at All of the text messages reviewed were downloaded from LeDoux?s cell phone in a manner that protected the integrity of the data on the phone. In other words, when the phones were imaged and downloaded, the information was pulled from the phones in an identical version as was stored on the device. No material was altered or manipulated in any way when the phone was downloaded, and a full and accurate replication of the data stored on the device is made and saved. BAIL INFORMATION Per the Alaska Public Safety Information Network, none of the defendants have criminal convictions in Alaska. Dated at Anchorage, Alaska, this 13th day of March, 2020. KEVIN G. CLARKSON ATTORNEY GENERAL By: Je a L. Gruenstgin A istant Attorney General Alaska Bar No. 0912086 Information State v. Gabrielle LeDoux. Lisa Simpson, Caden Vaught, Page 18 of 18 CR ca (CR