FRUECTINON ORLY FILED ERK OR THES AW WEEE CRUINTY ETRE COAT GGSEOABEER: 20279 CRR OEE THIRD JUDICIAL DISTRICT, SHAWNEE COUNTY, KANSAS CRIMINAL LAW DIVISION ‘STATE OF KANSAS, PLAINTIFF, Vs CASE # AGENCY CASE#: 19-36159 Stevon Charles Watkins Jr. WM DEFENDANT. STATE OF KANSAS. ) ) ss: COUNTY OF SHAWNEE =) AFFIDAVIT |, Detective Stephanie Dicken, Shawnee County Sheriff's Office, being of lawful age and first duly swom upon my oath, depose and state as follows: ' believe the above individual(s) has committed the following crime(s): Election Perjury 25-2411 Voting without Being Qualified 25-2416 a1 Interference with Law Enforcement 21-6904 atc Advance Voting Unlawful Acts. 25-1128 F DL Notice of Change of Address 8-248 (On or about the 4th day of December, 2019, | was assigned to follow-up on a Topeka Capital Journal report that Steven Charles Watkins Jr. WM QIN had listed his residential ‘address on his Kansas Voter Registration as the UPS store located at 6021 SW 20" St. Ste A in Topeka, Shawnee County, Kansas. News reports indicated Mr. Watkins was living at the QB cperirent complex. Mat same day, | met withthe spariment manager SIRES GERRI Ste confirmed Mr. Watkins lived at the complex.On 12/5/19, | met with the Shawnee County Election Commissioner, WM QED and the Director of Voter Services, =D WIF $B | was provided documentation relating to Mr. Watkins’ Voter Registration, These documents include the folowing: * A copy of Mr. Watkins’ 2017 Kansas Voter Registration Application correctly completed listing his mailing address at the UPS Store. ‘* A screenshot of the’ Elections Office ELVIS system showing an address change to the UPS Store with a transaction date of 8/28/19, The screenshot also Indicates that change was made at a Motor Vehicle Office.‘* A copy of an Application for Advance Ballot by Mail for Mr. Watkins listing his residential address as the UPS Store location dated 10/28/19. 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GEER o:p121000 to me that because Mr. Watkins had reported his address as being the UPS Store, he received the wrong ballot for the local election held in November of 2019. Mr. Watkins received a ballot that included the Topeka City Council District 8 race. Mr. ‘Watkins was reported to live at thefIIIIINIB apariments which is located in the Topeka City Council District 9, which was not up for election. The Advance Ballot envelope above was retured to the Election's Office. | was also provided a poll book for a group of 7 envelopes that Included the one shown above. This poll book indicates of the 7 envelopes, there were no blank ballots. The poll book is shown below. ‘Poll Wook tor Box / Batch #4 ‘ae ARTE Sac Ta ttn ad erry wen ae | EERO te eae = Ft we ees| Set acting, | Se tata nasOn 12/12/19 | received a screenshot of the Elections Office ELVIS system showing an address change for Mr. Watkins that had been dated 12/6/19 and completed through the DMV ondtine, The address provided was for the main office of the (UNNNMEBapartment complex and not his particular apartment as is shown below, On 12/18/19 | received a response to a subpoena from the QUNINB Apartments that included Mr. Watkins application and lease agreement. The lease agreement is for Si I #2 120 oF 22t ease is trom e1a0/19 wh 1729120. On 123/20 | received an additional Kansas Voter Registration Application for Mr, Watkins dated 1/17/20 as shown below. samt,| obtained copies of blank forms that clearly list the affirmation that a voter must sign from the Shawnee County Election's Office website. The first affirmation is shown below and appears on the Kanas Voter Registration Application. in ‘The second affirmation is shown below and appears on the Application for Advance Ballot by Mail, ‘5. Voter Signature Not Fala stant na atrmatn x sever vl nonpereon ley, |do slay afi under panaty of perury that | ama quale elector residing at the adress Hated above of am authorized to slon forthe above named voter who has a dsoblily preventing te voter om siniag an apeicaton. | am ented ia vote an advance voting ballot and Ihave not void and wil not otherwise vote atte EER ection to be held on MED. pees On 2/10/20 | met with Mr. Watkins and his attorneys, Lucinda Luetkemeyer and Todd Graves, at their offices in Kansas City, MO. | was provided with a typed statement from Mr. ‘Watkins. This three page document includes some of Mr. Watkins educational background. He graduated from the United States Military Academy at West Point, and several Army Schools to include, Ranger, Airborne, Sapper, Air Assault and Pathfinder. He also received a master’s degree in real estate development from MIT as well as a master’s degree from Harvard. | discussed specific elections related documents with Mr. Watkins during our interview. | showed him the screen capture for his address change on his voter registration dated 8/28/19. He told me the document sounds right and looks right. | asked Mr. Watkins if he completed the address change in a DMV office or online. He told me he did not have any memory of that. In his typed statement, Mr. Watkins confirms he registered to vote in Shawnee County, Kansas Using his mailing address at the UPS Store, He explains, after he leamed a residential address was required, he revised his voter registration to reflect his residential address of SIN ee| discussed the Application for Advance Ballot by Mail dated 10/28/19. | showed Mr. Watkins @ copy of this document. He told me it wasn't his handwriting or signature on the document but he would have authorized a staffer to complete that document for him. | discussed the ballot return envelope dated 11/4/19 and showed Mr. Watkins a copy of this document. He explained this looked more like his handwriting and signature but he did not have any memory of signing that particularly. | asked Mr. Watkins if he was aware that he may have voted in the wrong city council election. He advised he was aware of that. | asked Mr. Watkins if he intended to vote in the wrong city council election. He responded, no ma'am. He went on to tell me that he actually didn't vote for city council. | explained there is no way for us to verify that and he acknowledged he knows that. Mr. Watkins told me he moves a lot. He did not intend to mislead anyone. He further explained he obviously wasn't trying to claim he lives at the UPS Store. This interview was recorded on my Axon Body Camera, (On 6/4/20 | received copies of Maihin Ballots #839 for the Topeka City Council District 8 and USD 437 School Board elections held on November 5%, 2019. There were 20 total ballots in this group. 4 ballots were completely blank with no votes cast in either the City Council or ‘Schoo! Board elections. The remaining ballots had votes cast in the City Council District 8 election. As explained above, Mr. Watkins’ ballot was included in a group of 7 ballots. The poll book for this small group of ballots indicated there were no blank ballots in that group. Therefore, Mr. Watkins’ statement to me that he did not vote in the City Council District 8 election is presumed to be false. ‘On 8/28/19, Mr. Watkins changed his address on his Kansas Driver's License, SRB HEEB © tne UPS store address in person at the Topeka Driver's License office which is located at 300 SW 29" St. in Topeka, Shawnee County Kansas. He also changed his voter registration information to list the UPS Store as his residential address as explained above. The Kansas Department of Revenue provided surveillance video of that transaction as well as supporting documentation, Notes regarding that change of address indicate he changed both his residential and mailing address at that time. Mr. Watkins did not reside at the UPS Store and then failed tonotify the DMV within 10 days of moving to the BBB epartmonts, The length of his lease with the (MII apartments is 6/30/19 to 1/29/20. All of the aforementioned events occurred in Shawnee County Kansas Wherefore the affiant believes that there are reasonable grounds and probable cause to believe that Steven Charles Watkins Jr. WM NB has committed the ccrime(s) included in the complaint and prays the Court issues a warrant for the arrest of the defendants). | verify under penalty of perjury that the foregoing is true and correct. Executed on this 14th day of July, 2020. Sonate Se vy Printed/Typed Name_Detective Stephanie Dicken / 787 ‘Shawnee County Sheriff's Office