VALCARCE LAW OFFICE, LLC PO. Box 409 Bethe], Alaska 99559 (907) 543-2744 Telephone (907) 543-2746 Fax IN THE SUPERIOR COURT FOR THE STATE OF ALASKA FOURTH JUDICIAL DISTRICT AT Cm [Tu {iqu?i? Hi8 . cliff:- Egg); EA J.E. on behalf of JANE DOE 1, a minor child; B.M. on behalf of JANE DOE 2, a minor child Plaintiffs, vs. LOWERKUSKOKWIM SCHOOL DISTRICT, Defendant. Case No.2 4BE-19- 455 CI FIRST AMENDED COMPLAINT FOR DAMAGES (FILED BEFORE ANSWER) Plaintiffs JANE DOE 1, through her attorney Jim J. Valcarce, of the VALCARCE LAW OFFICE, and David Henderson of the HENDERSON LAW OFFICE, for their action against the defendant allege as follows: THE PARTIES . I. Plaintiffs JANE DOES 1?2, at all times relevant to the facts of this complaint, were and are residents of Bethel, Alaska within the Fourth Judicial District? State of Alaska. JANE DOES 1-2 are minor children Whose respective parent, identified by initials, bring claims on behalf of their minor child. Because the VALCARCE LAW OFFICE, LLC PO. Box 409 Bethel, Alaska 99559 (907) 543?2744 Telephone (907) 543?2746 Fax events described in this Complaint concern minors who were sexually assaulted and acts that are of an extremely personal nature, she chooses to identify herself only pseudonyms in the public documents ?led in this case.1 II. Defendant LOWER KUSKOKWIM SCHOOL DISTRICT, hereinafter is a school district Within the State of Alaska. Its Chief School Administrator is the superintendent. Plaintiff, and all agents and employees of LKSD, at all times relevant to the facts of this complaint, were residents of Bethel, Alaska, Within the Fourth Judicial District, State of Alaska. 1 The true names of the Plaintiffs, upon request, will be filed with the Court under seal. FIRST AMENDED COMPLAINT FOR DANIAGES PAGE 2 LKSD VALCARCE LAW OFFICE, LLC PO. Box 409 Bethe], Aiaska 99559 (907) 5430744 Telephone (907) 543-2746 Fax FACTS COMMON TO ALL CLAIMS IV. That the events which are the subject of this action occurred in Bethel, Alaska, in the Fourth Judicial District, State of Alaska. V. Approximately from 2000, Chris Carmichael (?Principal Carmichael?) was employed by the LKSD, including as a principal in Bethel from approximately 2014. VI. That as an employee, agent, and Principal of LKSD, Principal Carmichael had direct contact with minor children, including the minor plaintiff. VII That Principal Carmichael used his position as an employee of LKSD to meet, befriend, and groom minor plaintiffs JANE DOES 1?2. Principal Carmichael had substantial power, authority and control over the minor plaintiffs. LKSD provided Principal Carmichael with substantial authority and power oyer JANE DOES 1-2. IX. From at at least and approximately 2015-18, Principal Carmichael-1 repeatedly sexually abused children, including minor plaintiff JANE DOES 12. FIRST AMENDED COMPLAINT FOR DAMAGES PAGE 3 LKSD VALCARCE LAW OFFICE, LLC PO. Box 409 Bethe], Alaska 99559 {907) 5430.744 Telephone (907) 5434746 Fax X. LKSD, through its agents and servants, reasonably should have protected students from Principal Carmichael?s proclivity to sexually assault children. FIRST CLAIM FOR RELIEF ABUSE OF A MINOR XI. During the time periods of approximately 2015 to 2018, while employed by the Defendant, Principal Carmichael sexually assaulted JANE DOES 1-2, minors, who were under the age of sixteen-years-old. SECOND CLAIM FOR RELIEF OTHER TORTS XII. As alleged above, Principal Carmichael?s acts and omissions resulted in numerous other torts being committed against the minor plaintiff JANE DOES 1- 2. Principal Carmichael committed numerous civil torts, including but not limited to, assault and battery; negligence and negligence per se for violation of Alaska Statutes, Criminal Code and other rules that set codes of conduct; intentional and negligent infliction of emotional distress; indecent acts against, sexual solicitation and exploitation of minors; and harassment. THIRD CLAIM FOR RELIEF NEGLIGENCE All plaintiffs hereby incorporate by reference the preceding paragraphs of this complaint as they apply to each of them personally, and further allege that FIRST AMENDED COMPLAINT FOR DAMAGES . PAGE 4 LKSD VALCARCE LAW OFFICE, LLC PO. Box 409 Bethe], Aiaska 995 59 (907) 543?2744 Telephone (907) 543-2746 Fax the LKSD had a duty to exercise reasonable care in the hiring, retention and supervision of its employees, a duty which includes, but is not limited to, ensuring that Principal Carmichael who had daily contact with children was not prone to sexually abusing children, would not use his position to facilitate sexual abuse of children and would not otherwise endanger children. That LKSD breached its duty of care to the plaintiffs through its actions or inactions, including but not limited to: hiring Principal Carmichael; retaining Principal Carmichael as an employee; failing to provide proper oversight and supervision of Principal Carmichael; failing to appropriately and reasonable act and follow up on prior complaints;; and failing to exercise due care and caution. These acts and omissions of defendant the LKSD constitute negligence. FOURTH CLAIM FOR RELIEF PUNITIVE DAMAGES XIV. The conduct of the defendant, as described in the Complaint, was intentional, willful and wanton \misconduct, illegal, outrageous and malicious behavior, and conduct which showed a reckless indifference to the interests and well- being of minor children; therefore, Plaintiffs should be awarded punitive damages against the Defendant. DAMAGES XV. Plaintiffs, hereby incorporate by reference the preceding paragraphs of this complaint as they apply to each of them personally, and further allege that as a FIRST AMENDED COMPLAINT FOR DAMAGES PAGE 5 LKSD VALCARCE LAW OFFICE, LLC PO. Box 409 Bethel, Alaska 99559 (907) 543-2744 Telephone (907') 543?2746 Fax direct and proximate result of the sexual abuse, negligent and intentional in?iction of emotional distress, and conduct and torts described in the preceding paragraphs, plaintiffs, and each of them, suffered great past and future damage, loss, injury and harm including, but not limited to, the following: great pain of mind and body, shock, severe emotional distress, great mental anguish, embarrassment, disgrace, humiliation, and loss of enjoyment of life. Other damages include loss of earnings and earning capacity; past and future expense for medical and treatment, therapy, and counseling; and other economic and; non-economic injury and loss all to the damage of each plaintiff in an amount in excess of $100,000.00, the exact amount to be proven at trial. RESPONDEAT SUPERIOR XVI. Plaintiffs JANE DOE 1~2 hereby incorporate by reference the preceding paragraphs of this complaint, and further allege that at all times described herein Principal Carmichael was acting as an agent, servant and/or employee of the institutional defendant, the LKSD. Therefore, LKSD is vicariously liable to the plaintiff for each and every act of the abuser, alleged herein, and all injuries and damages caused thereby or resulting there from. AIDED IN AGENCY XVII. Plaintiffs JANE DOE 1-2 hereby incorporates by reference the preceding paragraphs of this complaint as they apply to each of them personally, FIRST AMENDED COMPLAINT FOR DAMAGES PAGE 6 LKSD VALCARCE LAW OFFICE, LLC PO. Box 409 Bethe], Alaska 99559 (907) 543-2744 Telephone (907) 543?2746 Fax and further allege that at all times described herein, Principal Carmichael had substantial power and/or authority over the minor; and this power and/or authority played a substantial role in bringing about and causing said-torts outlined above. Principal Carmichael was aided in the commission of acts injurious to plaintiffs by his agency relationship with the defendant. Pursuant to the doctrine of ?aided in agency,? LKSD is vicariously liable to the plaintiffs for its agent as alleged herein, and all injuries and damages caused thereby or resulting there from. WHEREFORE, plaintiff requests the following relief from this Court: 1) For damages against defendant in an amount to be determined at trial but in any event greater than 100,000.00, for each plaintiff; 2) For costs, interest and attorney?s fees in bringing this action; and 3) For such other relief as the court considers appropriate. DATED at Bethel, Alaska this 'y of January, 2020 LAW 0 ES OF DAVID HENDERSON Attor eys Plaintiff ABA No. 9806014 VALCARCE LAW OFFICE, LLC Attorneys for Plaintiff FIRST AMENDED COMPLAINT FOR DAMAGES PAGE 7 LKSD VALCARCE LAW OFFICE, LLC PO. Box 409 Bethel, Alaska 99559 (907) 5434744 Telephone (907) 543-2746 Fax By: K/h?l. ValthT/W ABA N0. 950 1 Certi?cate of Service I hereby 0% true and co COpy oft fo going was served this i (1: day of ?lial ax hand delivered to the following: D. Jack Guthrie Patterson Buchanan Fobes Leitch 21 12 Third Avenue, Suite 500 Seattle, WA 98121 Fax (206) 462-6701 FIRST AMENDED COMPLAINT FOR DAMAGES I PAGE 8 LKSD District Attorney, State of Alaska PD. 1302-: I70 Beihel, AK 99559 Phone: (907) 5434055 Fax: IN THE DISTRICT COURT FOR THE STATE OF ALASKA FOURTH JUDICIAL DISTRICT AT BBTHEL IN THE TRIAL COURTS STATE OFALAS STATE OF ALASKA, BETHELSERWCE Egan plaintiff, APR 0 9 2320 By vs. DEPUTY CLERK CHRISTOPHER A CARMICHAEL DOB: 06/16/1964 APSIN ID: 7053724 DMV NO.: 7504969 AK ATN: 116484021 Defendant. No. 4135-20? 562. CR INFORMATIQN I ccnify this and its do not contain 111:: name of a victim of a scxuat u?'cnsc 115ch in AS 12.61.149 or residence or bnsincss address or numbcr of a viciim of or to any offense unless it is an identifying the place ofa crime or an address er tc1ephonc number in a oft: court grounding and disdosmc aim: infonnaiion was by the court. The following (:9an: a crime involving DOMESTIC VIOLENCE as de?ned in AS 18.56990: NONE Count I - AS 1 Sexual Abuse Of A Minor In The Second Degree Christopher A. Carmichael 001 Count II AS Sexual Abuse Of A Minor In The Second Degree Christopher A. Carmichael - 002 THE DISTRICT ATTORNEY CHARGES: COUNT I: That on or about or between August 2017 and May 2018, at or near Bethe}, in the Fourth Judicial District, State of Alaska, CHRISTOPHER A. CARMICHAEL (DOB: 06-16- 1964), being 18 years of age or older, engaged in sexual contact. with CHILD (DOB: 2004), a person who was under 16 years of age and the offender occupied a position of authority in relation to the victim, to-wit: CHRISTOPHER A. CARMICHAEL touched CHILD breasts. District Attorney, State of Alaska FLO. Box 170 Bethel, AK 99559 Phone: 543?2055 Fax: mos-atmcnowN?t Nmmommnxowoc-dmcn-c-mmao All of which is a class felony offense being contrary to and in violation of and against the peace and dignity of the State of Alaska. COUNT Ii: That on or about February 9, 2018, at or near Bethel, in the Fourth Judicial District, State of Alaska, CHRISTOPHER A. CARMICHAEL (DOB: 06-16-l 964), being 18 years of age or older, engaged in sexual contact with CHILD (DOB: 2006), a person who was under 16 years of age and the offender occupied a position of authority in relation to the victim, to-wit: CHRISTOPHER A. CARMICHAEL tenched CHILD breasts. All of which is a class felony offense being contrary to and in violation of 1 and against the peace and dignity of the State of Alaska. The undersigned swears under oath this Information is based upon a review of police reports AK16010231, 1802063, and 1908408 submitted to date. As more speci?cally detailed below, starting in 2016, law enforcement became aware of allegations of inappropriate conduct involving a Lower Kuskokwim School District Principal, Christopher Carmichael (DOB: 6/16! 1964) (hereinafter, ?Cannichael?). Between 2016 and 2019, law enforcement conducted several investigations into specific allegations of misconduct. in both 2016 and 2018, law enforcement met with LKSD administrators and advised LKSD about the investigations and of the allegations made against Carmichael. Speci?cally, in 2016 LKSD was made aware of inappropriate Facebook mesSages between Carmichael and Child A, and in 201 LKSD was advised that Child 13 had alleged that Carmichael touched her breast with the back of his hand.I Both incidents were investigated by law enforcement and, as noted above, reported to the LKSD, but there was insuf?cient evidence at the time to successfully prosecute Carmichael. In 2019, the Bethel Police Department learned of another allegation of inappropriate conduct by Carmichael. At the time of the 2019 investigation, Carmichael remained employed by LKSD as the principal of Gladys Jung Elementary School. To protect the integrity of the investigation, it was determined that the existence of the investigation would The identities of the minor children referenced herein are omitted from this lnl?onnatioa. Rather, each child is referred to as Child A, Child B, and Child C, respectively. This is done to protect the identity of the child victims. Information Store Christopher A. Camlcliarl? Page 2 of9 District Attorney, State of Alaska 0 Box 176 Bethel, AK 99559 Phone: (987) 543-2055 Fax: coonummth?A wwmommaommummomM?so be kept con?dential and limited to BPD, AST, the Bethel District Attorney?s Of?ce, and (ultimately) the Federal Bureau of? Investigation. As more fully set forth below, the 2019 investigation into Carmichael?s conduct revealed an escalating course of conduct that culminated in Carmichael being arrested by federal authorities. The following summarizes the investigations: 2016 REPORT INVESTIATION in 2016, the Alaska State Troopers received a report that Carmichael sent inappropriate Facehook messages to a fourteen?year?old female former student (hereinafter, ?Child Child A?s mother questioned why her child was receiving messages from a school administrator talking about her child?s lips, naughty ways, and Spanking. AST initiated an investigation and recovered communications between Carmichael and Child A. In those messages, Carmichael referred to Child A as ?sweetness,? ?loveliness,? ?baby," ?sweetie,? ?sweet girl,? ?pumpkin,? "pretty girl,? ?beautiful," and ?sweetheart." review of the messages revealed that Carmichael sent the following messages to Child A: a ?love those luscious red lips on your pro?le pic know you and your naughty ways too well 0 ?you can?t escape my all seeing eye! ?bend you over my knee and On March 15, 2016, contacted LKSD Assistant Superintendent Carlton Kuhns (hereinafter, ?Kulms?) and advised Kuhns of the investigation. That same day, AST interviewed Carmichael in his of?ce at Gladys Jung Elementary School. AST confronted Carmichael with the messages he had seat Child A, and Carmichael stated he regretted the wording that he used. Carmichael advised he was in Anchorage at the time he sent the messages and that he was heavily medicated. Carmichael denied that he intended to be inappropriate. Carmichael told AST that he had assured Child A?s mother that the messages were taken out of context and that nothing inappropriate was said or happened. Carmichael further advised AST that he had brought up this situation to his boss immediately to let them knots what was taking place. AST discussed appropriate communication between teachers and students with Carmichael. Carmichael stated that he would not be ?Facebooking? with students and that he had learned his lesson. information State it A. Carmichael Page 3 of9 District Attorney, State of Alaska PD. Box 170 Bethel, AK 99559 Phone: 54342055 Fax: On March 2016, Kuhns contacted AST seeking assistance in searching Carmichael?s LKSD laptop and iPad for possible child pornography. At the request of LKSD, AST examined Carmichael?s LKSD MacBoolt Pro laptop. The examination did not discover any evidence of child exploitation but did con?rm that Carmichael had communicated with Child A via Facebook, Also, although clearly inappropriate and concerning, the messages sent from Carmichael to Child A did not constitute any criminal offense based on current law; therefore, law enforcement could take no further action regarding the conduct. 2018 REPORT 8: INVESTIATION On February 12, 2018, Bethel Police Department received a report that Carmichael touched the breast of an eleven-year?old girl (hereinafter, ?Child on February 9, 2018. Speci?cally, Child disclosed to her mother that Carmichael looked down at her breasts and then touched her breasts with his hand. Child disclosed to her mother that this took place in Carmichael?s of?ce. Child stated ?[she] was holding the door for [Carmichael] and then he looked down at [her] ?this part,? and then he touched it, on purpose.? Child clari?ed that ?this part? referred to her breast and that Carmichael used the back of his hand to touch her breast. Child further reported that Carmichael smiled before going to his of?ce. Child advised that she felt scared. - On February 15, 2018, BPD applied for and obtained a Glass warrant (4813-18- authorizing BPD to record conversations with Cannichael. In furtherance of the warrant, Child B?s mother called Carmichael advising she was concerned about Carmichael touching Child B?s breast. Carmichael responded that he was probably joking around and Wrestling with the kids, that he is ?very clumsy about how [he moves] and stuff,? that he was joking around with the kids and that it was possible that it happened, that he felt horrible, and that he had talked with Child telling her that he did not remember what happened and to know that i 5 he hurt her feelings or made her feel uncomfortable that it was not intentional. When Child B?s mother asked Carmichael about Carmichael tickling children, Carmichael said that the incident with Child made him rethink and he realized that he cannot afford to be playing with people anymore because sometimes people take it the among Way. Information Stan.- r. ChristophrrA. Page of? District Attorney, State ofAlaska 170 Bethe], AK 99559 Phone: (907) 543-2055 Fax: On February 20, 2018, Child B?s father met with BPD in preparation for his participation in a phone call recorded pursuant to Child B?s father told BPD that Carmichael contacted him and stated that the situation was a misunderstanding and that he must have accidently pushed against Child B. Carmichael told Child B?s father that he was really sorry and that he has a reputation to protect. Carmichael further stated that the Dean told him that he may have brushed up against Child or touched her inappropriately with the back of his hand. Carmichael told Child B?s father that he informed the Dean that it was probably an accident, that he was taking care of kids telling them to go out, and that he may have accidently touched her. During a recorded phone call, Carmichael told Child B?s father that he was not 100% sure of the allegations made by Child B. Carmichael ?rrther stated that he was trying to move kids out of his of?ce, and Carmichael promised he would never attempt to touch any person on their body in a place that is a private area. Carmichael advised he felt terrible about the situation and it was not intentional. On February 20, 2018, BPD Chief Waldron and BPD Lt. Davis (hereinafter, ?Davis? met-with LKSD Superintendent Dan Walker (hereinafter, ?Walker") to advise LKSD of the investigation. Following their meeting with Walker, BPD invited Carmichael to the Bethel Police Department to discuss the allegations made by Child 13. Cannichael agreed to meet with BPD advising BPD that he ?rst needed to contact the Dean about the situation. Carmichael met with BPD. Carmichael said that he was aware that Child had reported to a teacher that she was made uncomfortable by something that took place between him?and the student. Carmichael advised the complaint was vague and that he learned of the report from the Dean. Carmichael stated that he was ?mysti?ed? as to the issue. Carmichael denied having a memory of touching Child B?s breasts. However, Cannichael stated it could have happened because he was trying to shuttle kids out of his of?ce. Carmichael admitted that it was possible that he touched Child in a way that made her feel uncomfortable, but it wasnot intentional. 2019 REPORT On June 17, 2019, BPD received a report that Carmichael touched Child C?s breast and thighs when Child was in the seventh grade. It was reported that the sexual abuse took Interrelation State v. Carmichael Page 5 of? Bethcl, AK. 99559 Phone: (907) 543-2055 Fax: District Attorney, State of Alaska Box 170 (OCDNODGAWNJ place inside Gladys Jung Elementary School. Child had just ?nished the 8m Grade, so based upon Child C?s statements, the sexual abuse would have occurred during the 2017? 2018 school year. BPD met with Child C?s mother who advised that Child became close to Carmichael while Child was a student at Gladys Jung. Child C?s mother stated that alter Child matriculated to Bethel Regional High School, Child would return to Gladys Jung to visit with Carmichael. Child C?s mother advised that Carmichael had previously given her and Child gifts including basket woven pins, a king-sized bed, and paint. Child C?s mother also stated that when Child C?s father was incarcerated Carmichael told Child that she could call him ?Dad.? Child participated in an interview at the Child Advocacy Center Child stated that she had known Carmichael since the fourth grade and they used to walk on the playground together where Carmichael would sing and talk to her. Child stated that Carmichael would hug her. Child disclosed that by the time she was in sixth grade she had grown closer to Carmichael and would confide in him about her problems bullies, tough days, and God). Child described how she and Carmichael would spend time together after school. Child said it made her feel happy to be with Carmichael. Child said when she was in the seventh grade, around November 2017, Carmichael began touching her on her breasts. Child disclosed that one time, while they were in the together, she followed Carmichael into a closet, Carmichael closed the door, and Carmichael hugged her from behind and touched her breasts. Child stated that was the ?rst time he touched her breasts. Child described how Carmichael told her it needed to be outside of the cameras so he would take her into the closets and his of?ce to sexually abuse her.? Child disclosed that Carmichael touched her breasts every Friday after school or whenever he had the opportunity and all the staff were gone. Child was asked about how she felt when Carmichael hugged her from behind and groper! her breasts, and Child responded that at the time she thought it was sweet but now thinks it is creepy. Child stated that during the hugging episodes Carmichael would tell Child that he loved her or words to that effect. I lift) rmatic Star: Carmichael Peg: o' af9 District Attorney, State of Alaska 9.0. Box HO Bethe], AK 99559 Phone: 543?2055 Fax: tomwmm-a-th4 MmmamN?xomcowmmamm?xo Child was asked about any other incidents of touching. Child disclosed that One time when she was in car with him and his wife, Carmichael?s wife went into the store and Carmichael reached over, rubbed her upper thigh, and licked his ?ngers. Carmichael told her did that to comfort her. Child also disclosed that once while Carmichael was hugging Child 0 from behind, Carmichael ran his hand under her shirt around her stomach. Additionally, Child disclosed that Carmichael would sometimes kiss her around the neck. Child described these as not actual kisses but putting his mouth on her skin. Child said it was creepy when Carmichael was ?kissing? her neck. Child said the sexual abuse stopped during the summer before 8?1 Grade because she "stopped seeing Carmichael a?er her mother told her to stop seeing Carmichael. Child said her mother became uncomfortable with Cannichael's interactions with Child C. On September 19, 2019, BPD applied for and received a Glass warrant (4BE-19- authorizing the recording of communications with Carmichael. The warrant covered communications made via email, Skype, FaceTime. text messaging, Facebook, and anyother electronic means. (BPD applied for and received extensions on the warrant on October 30, 2019 and December 2, 2019.) On September 20, 2019, Davis began an undercover operation and took control of Child C?s Facebook account. Davis, acting as Child C, sent Christopher Carmichael a ?friend request.? On September 30, 2019, Child C?s mother contacted BPD and advised that Can'nichael spoke to Child C?s sister and told her to tell Child that he was not able to accept her Facebook request? even though he really wanted to. Carmichael thither asked Child C?s sister to tell Child that it was not a good idea right now, for Child to try again when she graduates, and that he loved and missed her. In response, and at direction of law enforcement, Child C?s mother sent Carmichael a message letting Carmichael know that Child was doing much better, that it was okay to send messages to her daughter, and that she would consider phone communication later on. Information State v. Citrl'rrophcr/i. Carmichael Page 7 of? District Attorney, State of Alaska P.O. Box 170 Bethcl, AK 99559 . Phone: (907) 543-2055 Fax: C(Om?mmbOJN?l On September 30, 2019, Carmichael accepted a ?friend request? from Child C?s Facebook account. Thereafter, Davis, in her undercover capacity, began to exchange messages with Carmichael.2 During the messaging, Carmichael acknowledges that he knows Child is l?uyears? old, and be repeatedly refers to Child as ?kiddo." As the messaging progressed, Carmichael began to write and which are believed to mean Love You," ?1 Miss You,? and Want You,? respectively. Throughout the messages, Carmichael repeatedly directs that the messages should be deleted. In December 2019, Carmichael inquires of Child about Child masturbating. Ultimately, Carmichael diScusses a plan to meet with Child C. On December 10, 2019, the Bethel Police Department, in conjunction with the Federal Bureau of Investigation, arranged for Child C3 to participate in a telephone call with Carmichael. The call was recorded pursuant to the previously authorized warrant. During the phone call, Child was holding a stuffed animal. During the phone call, Carmichael inquired whether Child was alone in her room. Carmichael proceeded to make many sexually explicit and graphic statements to Child C. These comments included a statement that Carmichael has masturbatcd to her ?thousands of times,? and a description of what Carmichael would like to do, sexually, to Child C. During the phone call, Carmichael also addressed Child C?s disclosure of being sexually abused by him, and he made the following admission: Umm when you were talking about me touching your boobs umm there are people, I'm sure people read that and Pro sure that they're very concerned about it. if you could do me a favor at some point when we are chatting on there you could say you know i remember that was an accident and you did say you were sorry. I know that's not true but could you do that for me to help protect me. 3 The Facebcck communications that follow, although described to have been between Child and Cannichacl, are between Lt. Davis, posing as Child C. and Carmichael. 3 Child C, under the supervision of law enforcement and with the consent ofher parents, participated in the recorded telephone call with Carmichael. lnl?cnnation State Christopher-A. Carmichael Page 6' of 9 District Attorney, State of Alaska Box 170 Bethe}, AK 99559 Phone: (907) 543-2055 Fax: Ultimately, after making a number of other sexually graphic statements, Carmichael told Child that he loves her and ended the call. Following the conclusion of the phone call, law enforcement executed federal search warrants on Carmichael?s residence. Carmichael was then interviewed bylaw enforcement. Carmichael admitted speaking with Child earlier that night. However, Carmichael?s version of the phone call with Child was inconsistent with the actual call recorded by law enforcement Speci?cally, Carmichael told law enforcement that it was Child who wanted him to meet her at the Longhouse, that he told her that it was his impression that Child wanted to make out in one way or another, that he sensed it was something sexual, that he told her it was inappropriate, that he told her he was not going to do that with her, and that he told her it was not going to happen. Carmichael admitted that he told Child to delete the messages about him touching her breasts. Carmichael also admitted that he is sexually attracted to Child C. Dated at Bethel, Alaska, this .911H day of APRIL, 2020. KEVIN G. CLARKS ON ATTORN GENE S. Thomas homey Heifer District Attorney Alaska Bar No. 0811064 QWA Mlht?kek Cir . We Oct ?Lo Inl?crrnalicn State v. Page 9 of?