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AFFIDAVIT AND APPLICATION FOR A SEARCH WARRANT IN THE SUPERIOR COURT OF COBB COUNTY

STATE OF GEORGIA

Docket No. _________ The undersigned, Special Agent Wesley Horne, being duly sworn, deposes and says: I am a certified Law Enforcement Officer of the State of Georgia employed by the Georgia Bureau of Investigation. I am charged with the duty of enforcing violations of criminal laws to include crimes against persons and death investigations, and that I have reason to believe that in Cobb County, Georgia, on the person, premises, or property described as follows: (state detailed description of person, property, or location)

the dwelling of Thomas Edmund Goodwin, W/M; DOB: ; the residence is located in Cobb County at the intersection of Latimer Lane and Latimer Court; it is described as a two story, contemporary residence with grey siding and a two car garage. The drive to the residence enters off of Latimer Lane but the garage faces Latimer Court. The mailbox has the number on it.

There is now located certain instruments, articles, person(s), or things, namely: (specify evidence, contraband, or person(s) to be searched for)

Computer(s) and related storage media, the following forms containing the name of John Celmer or Richard Sartain: Final Exit Network intake interview forms, Final Exit Network First Responder’s Checklist, documentation of First Responder’s evaluation of member, letter written by member giving their reason for a hastened death, Final Exit Network Request for Exit Guide Support Form, Final Exit Network My Instruction on Changing or Not Changing the Appearance of My Body and Bedside which may also read My Wishes Regarding the Appearance of my Body form, Final Exit Network Statement of My Decision Following Medical Consultation which may also read My Decision Following Medical Consultation form, Final Exit Event Log, Final Exit Network Expense and Reimbursement form, Final Exit Network Donation of Expense form, Statement of Mutual Understanding between Final Exit Network and Exit Guides Form, Final Exit Network questionnaire or application completed by the exit guide, John Celmer’s suicide note and all documentation of meeting(s) and conversation(s) with John D. Celmer, Final Exit Network instructor and training manuals to include notes and any paperwork described above related to other victims of assisted suicide, tampering with evidence and racketeer influenced and corrupt organization laws.

Which is (name the law being violated)

Racketeer Influenced and Corrupt Organizations O.C.G.A. § 16-14-1 through O.C.G.A. § 16-14-15; Assisting Suicide O.C.G.A. § 16-5-5; Tampering with Evidence O.C.G.A. § 16-10-94

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The facts tending to establish probable cause that a crime has been, or is being committed and the above described instruments, articles or things described above are presently located at the above described premises or property are as follows: _______________________________________________________ Comes now your Affiant, Special Agent Wesley Horne. Affiant is employed with the Georgia Bureau of Investigation. Affiant is a P.O.S.T. Certified Peace Officer charged with the duty of enforcing the criminal laws of the State of Georgia. Affiant is currently assigned to the GBI’s Atlanta Regional Office in Conyers, Georgia and has the responsibility of general investigations to include crimes against persons and death investigations. Affiant has been employed with the GBI for more than six years and has been in the criminal justice profession for more than twelve years. The information outlined in this affidavit was provided to Affiant, Special Agent Wesley Horne, by Georgia Bureau of Investigation (GBI) Assistant Special Agent in Charge (ASAC) Mitchell M. Posey who has twelve (12) years of law enforcement experience with the Georgia Bureau of Investigation. ASAC Posey attended the sixteen week (16) GBI Basic Agent Academy. During this academy Affiant learned about criminal investigation to include death investigation, white collar crimes and preparation of search warrants. White collar crimes often involves the search and seizure of documentation on paperwork and computers or other storage related media along with financial records to determine if a criminal act has occurred. ASAC Posey has also attended advanced courses related to death investigation and search and seizures. ASAC Posey has lead and assisted with numerous death investigations and white collar criminal investigation and wrote numerous search warrants that have led to the arrest and conviction of the responsible parties. ASAC Posey is a certified law enforcement instructor. ASAC Posey is able to provide this information to the Affiant of this affidavit and search warrant under the collective knowledge doctrine. ASAC Posey learned from Cumming Police Department Detective Sergeant Scott Burgess that on June 20, 2008 the Cumming Police Department along with Forsyth County Coroner, Lauren McDonald III, responded to John Celmer’s residence at

. Celmer was found dead in his bed. Celmer had previously been diagnosed with cancer. Initial observations lead authorities to believe Celmer had died of natural causes. Books titled the Final Exit which discussed assisted suicide were found at Celmer’s residence. An autopsy was competed on Celmer. The cause of death was ruled asphyxia suffocation as a result of the inhalation of helium and the manner of death was ruled a homicide. ASAC Posey learned on Sunday, June 29, 2008 that John Celmer’s wife, Susan Celmer, was cleaning up John Celmer’s residence and found Final Exit Network paperwork on John Celmer’s computer. ASAC Posey learned this organization provided information and support to people who are suffering and wanted to end their lives. Susan Celmer found release forms belonging to Final Exit Network signed by John Celmer. Susan Celmer found a typed letter dated May 1, 2008, that was addressed to Nick Sheridan, Southeastern Regional Coordinator for Final Exit Network. The letter indicated John

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Celmer desired to pursue a “helium induced methodology… for the purposes of coordinating my demise.” In this letter John Celmer appeared to ask for help from the Final Exit Network in carrying out the helium inducement. John Celmer wrote, “If however, for some imaginable reason(s), you do not feel comfortable in the continuance of your involvement… rest assured that I will have no other choice than to pursue any and all alternative sources of available means of helium inducement including pathetically taking measures into my own hands if necessary.” John Celmer’s 2008 calendar had the following notation on May 7, 2008: Claire here @ 1:30. Susan Celmer found handwritten notes that appeared to be written by John Celmer dated May 7, 2008 about a conversation he had with Claire Blehr. Within the note, John Celmer documented that the procedure required a hood and he had to inhale helium quickly. Within the note, Claire Blehr and Ted Goodwin would help and remove the hood, helium tanks and any related material. It appeared Claire Blehr had assisted one other person commit suicide. Susan Celmer found a receipt dated May 7, 2008, where John Celmer purchased two helium tanks. Susan Celmer found an email dated June 19, 2008 at 4:55 P.M addressed to Claire Blehr. John Celmer said to Claire Blehr that he was unhappy with his two surgeries and was seriously considering “my plan (you know what I mean by that).” John Celmer thanked Claire Blehr for “reinforcing that I can count on all of you to cooperate in assisting me with it should it come to fruition.” Susan Celmer also found two editions of the book titled Final Exit in John Celmer’s residence one of which was the third edition with its addendum. Susan Celmer also found Claire Blehr’s home telephone number o cellular telephone number of , and email address of at John Celmer’s residence. The telephone numbers and the email address are registered to Claire Blehr at

. Ted Goodwin’s name and an address of telephone number of was found at John Celmer’s residence. This is not Thomas Edmund Goodwin’s (Ted E. Goodwin) telephone number or address but belongs to another man named Theodore J. Goodwin. GBI Intelligence provided ASAC Posey with Ted Goodwin’s driver’s license photographs, date of births and social security numbers. ASAC Posey verified Thomas E. Goodwin and Theodore J. Goodwin are not the same person and that Thomas E. Goodwin is the person associated with Final Exit Network. Thomas Edmund Goodwin of Final Exit Network is referred to as Ted Goodwin the remainder of this affidavit. Theodore J. Goodwin is not discussed again in this affidavit. On Monday June 30, 2008, ASAC Posey requested John Celmer’s son, Paul Sciandra, to make a controlled telephone call to Claire Blehr. Paul Sciandra was equipped with a recorder and microphone. Paul Sciandra called Claire Blehr on the telephone number found at John Celmer’s residence. Upon calling the number the person answering the phone introduced herself as Claire Blehr. Paul Sciandra introduced himself as John Celmer’s son. Claire Blehr stated that she and Ted Goodwin were with John Celmer when he died. Claire Blehr explained they provide a service to people who are not terminally ill so they no longer have to suffer. Claire Blehr would not tell Paul Sciandra how John Celmer died and would only say that she and Ted Goodwin did what John Celmer asked them to do. Claire Blehr did state that she was holding one of John

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Celmer’s hands and Ted Goodwin was holding the other when he died. Claire Blehr stated that she and Ted Goodwin did remove the helium tanks and a file of paperwork related to Final Exit Network from John Celmer’s residence at his request. Claire Blehr said this included a handwritten suicide note written by John Celmer. Claire Blehr stated this paperwork would be retained for one year. Claire Blehr asked Paul Sciandra to dispose of any other Final Exit paperwork. Claire Blehr stated her only role was to provide information and support to John Celmer and she did not assist with his suicide. Claire Blehr asked for Paul Sciandra’s telephone number so she could call Ted Goodwin and recontact Paul Sciandra. A short time later Ted Goodwin called Paul Sciandra on the telephone number Sciandra provided to Claire Blehr. Ted Goodwin called from his cellular telephone,

. Ted Goodwin introduced himself and stated he was with the Final Exit Network. Ted Goodwin also stated that he and Claire Blehr were present with John Celmer at the time of his death. Ted Goodwin explained Claire Blehr called him at 7:30 PM. An analysis of Ted Goodwin’s cellular phone indicated this call took place during the evening hours. Claire Blehr said John Celmer wanted to die at 11:00 PM. Ted Goodwin added he lives in Florida and maintains a house in Georgia and just happened to be in the area on business. Ted Goodwin and Claire Blehr arrived at John Celmer’s residence at 10:00 PM and John Celmer died at 11:30 P.M. Ted Goodwin explained how John Celmer died. Ted Goodwin stated the group talked for about one hour. Ted Goodwin was concerned John Celmer’s wife would return because she lived near him. Susan and John Celmer were still legally married but they did not live together. Ted Goodwin was aware John Celmer told his wife he was tired and asked her to go home. Claire Blehr previously stated after talking the three walked upstairs together. Ted Goodwin indicated John Celmer placed a plastic bag over his head and there were hoses running from the plastic bag to the helium tanks (2). John Celmer breathed in the pure helium and was unconscious within twenty (20) seconds and died within twelve (12) minutes. Ted Goodwin also stated they held John Celmer’s hands. Ted Goodwin and Claire Blehr stayed with John Celmer for another fifteen (15) or twenty (20) minutes and then removed the helium tanks and hood from the residence. Ted Goodwin said they turned off the lights and closed the garage door when they left John Celmer’s residence. Ted Goodwin said he threw the helium tanks and hood into a dumpster in Acworth, Georgia. Ted Goodwin also indicated he asked John Celmer to destroy any paperwork related to the Final Exit Network and encourage Paul Sciandra to do the same. Ted Goodwin stated his only role was to provide information and support to John Celmer and did not assist with his suicide. Ted Goodwin explained the Final Exit Network was a group of people who were under medical supervision and they helped ease the suffering of people who may not have other medical options. Ted Goodwin required Paul Sciandra to acknowledge that he knew his father was going to die anyway. Ted Goodwin explained that Exit Guides try to talk members out of committing suicide. John Celmer contacted the Final Exit Network and was interviewed by at least two people by telephone. John Celmer provided the Final Exit Network with his medical records. Ted Goodwin was aware Claire Blehr met with John Celmer on two occasions but Ted Goodwin only met him on

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the date of his death. Ted Goodwin said John Celmer signed some paperwork on three occasions and he found John Celmer to be competent. Ted Goodwin said he was not a doctor but owned a business in the medical field that employed doctors and nurses. ASAC Posey interviewed Dr. Brant Carlson to learn about John Celmer’s medical condition. Dr. Carson was John Celmer’s oncologist. John Celmer previously had head and neck cancer but was cancer free at the time of his death. John Celmer recently had two surgeries that repaired his deteriorated jaw and a skin graft over a hole in his lower jaw. Both surgeries were a success and John Celmer was making a remarkable recovery. John Celmer was still in pain because he had arthritis in his hip that could have been replaced in approximately three months. John Celmer’s pain could have been greatly reduced if he had taken his pain medication properly and stopped drinking alcohol and smoking cigarettes. John Celmer was concerned about his public appearance because of his recent surgery to his face. Dr. Carlson last saw John Celmer on Wednesday prior to his death. Dr. Carlson scheduled for John Celmer to meet with a psychiatrist on Monday, June 23, 2008, to help John Celmer improve his lifestyle so he could recover quicker. Susan Celmer provided Detective Scott Burgess the Dell computer where she retrieved the above documented information and John Celmer’s cellular phone. Paul Sciandra who also assisted in cleaning up John Celmer’s residence provided Detective Scott Burgess with an IBM ThinkPad that he removed from the residence. These computers, related storage devices, and cellular telephone were examined by the Georgia Bureau of Investigation (GBI) High Technology Unit. This unit found all the same documents Susan Celmer previously reported finding on the computer related to the Final Exit Network. Claire Blehr’s email was identified through the GBI High Technology Unit’s analysis to be Bellsouth indicated this was an active email assigned to Claire Blehr at

. It should be noted this is the same email address and home address documented for Claire Blehr in the Final Exit Network Guides Roster seized by the Phoenix Police Department. A sample suicide letter was also found on John Celmer’s computer that was authored by Claire Blehr on January 20, 2008. This indicates that Claire Blehr formulated this document on her computer and provided it to John Celmer either through a mobile storage device or through email. A letter written by John Celmer addressed to Gladd Group dated May 6, 2008 was also found on the computer. This letter indicated that Nick Sheridan suggested he needed to purchase a “hood” (exit bag) in order to complete his hastened death by the means of helium inhalation. This letter indicated the “hood” cost sixty dollars. A scanned copy of the sixty dollar check address to the Gladd Group was also located on the computer. John Celmer had the email address of Nick Sheridan and Claire Blehr saved under the contacts on his computer. Multiple email communications between John Celmer and Claire Blehr related to his hastened death were located. The GBI High Technology Unit also located bits of text from the hard drive of the computer that is obvious communication between John Celmer and members of the Final Exit Network. The easiest avenue for

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John Celmer to communicate this information to members of Final Exit Network would have been by email. The GBI High Technology Unit located two letters authored by John Celmer one of which was addressed to Nick Sheridan and dated May 1, 2008. The first was John Celmer’s personal letter addressed to Nick Sheridan where he discussed the fact that he was serious about pursuing his hastened death and requested the assistance of the Final Exit Network. This letter complies with the organization’s requirements to write a personal letter stating why they wish to die. The second letter that was found was a summary of John Celmer’s recent medical history and complication concerning his cancer as well as some accompanying medical records. This is also a required form of documentation sent to Nick Sheridan that is later forwarded to Dr. Larry Egbert along with the personal letter previously discussed. In this letter John Celmer discussed extensively the medical procedure for which he completed just prior to his death. This letter was authored on May 1, 2008 which was before John Celmer completed the two surgeries performed by Dr. Carlson. John Celmer mostly discussed how his deteriorated jaw caused him social embarrassment and financial hardship because of lost of wages since he could not entertain employment opportunities. John Celmer only briefly mentioned discomfort but never discussed being in extensive pain. John Celmer’s condition changed and improved from the time he was accepted by Final Exit Network’s Medical Review Committee to his exit event or death. A third name of Duffy Rutledge who was associated with the Final Exit Network was found in John Celmer’s cellular phone. The telephone number of was stored as “Duffy - Exit”. Duffy’s telephone number was registered to Gail Rutledge at

. ASAC Posey did not find Duffy Rutledge’s name on the Final Exit Network’s roster information. Duffy’s name was also mentioned in the bits of text found on John Celmer’s computer. This text indicates that John Celmer was looking forward to talking with Duffy. John Celmer had the email address of written at the top of his calendar for the month of May 2008. This email address was registered to Gail Rutledge at

. Investigators learned John Celmer had contact with at least four people affiliated with the Final Exit Network. Through deductive reasoning Duffy Rutledge was identified as the Final Exit Network’s First Responder. As the First Responder, Duffy would have completed an intake interview with John Celmer. Duffy would have also submitted his evaluation of John Celmer to Nick Sheridan which would also have been forwarded to Dr. Egbert. The details of this interview and evaluation are discussed later in this affidavit. Susan Celmer also provided Detective Scott Burgess with two Final Exit books and an addendum to the third edition. This material explains the steps of how death can occur through the inhalation of helium. The material teaches to remove the helium tanks and hood from the crime scene so as not to “intrigue the minds of the police, thus making their inquiries lengthier.” The material also contains the following text: “If you are not a doctor, you may be unaware that there is a reflex movement of limbs that occurs when one falls asleep speedily, with or without helium. This is not the sign of

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someone struggling to take the bag off although it may appear that way. We have seen this often and it is the same reflex that people may have in falling asleep normally without an inert gas influence. It is accentuated in helium use due to the rapidity of sleep occurring.” Claire Blehr and Ted Goodwin stated they held John Celmer’s hand during this process. This would have prevented John Celmer the ability to pull the hood off his head if he changed his mind about dying. On Wednesday July 15, 2008 ASAC Posey met with Detective Lois Weiss of the Phoenix Police Department Homicide Unit. The Phoenix Police Department investigated the death of Jana Van Voorhis. The Phoenix Police Department learned Jana Van Voorhis died as a result of inhalation of helium with the assistance of Frank Langsner and Wye Hale-Rowe, who are also members of Final Exit Network. The details of this death investigation are outline later in this affidavit. During a search warrant at Frank Langsner’s residence the Phoenix Police Department seized some of the Final Exit Network’s training material and Final Exit Network forms related to Jana Van Voorhis. ASAC Posey reviewed the training information that was seized by the Phoenix Police Department. ASAC Posey learned the process for joining the Final Exit Network along with the steps taken up to and past a member’s death. An applicant must first join the Final Exit Network which cost fifty dollars. An applicant would request to be contacted by the Final Exit Network. The Final Exit Network First Responder contacts the applicant and completes an intake interview. This is the first Final Exit Network person that speaks with the applicant. The first responder completes a form titled Final Exit Network Intake Interview. An applicant is expected to purchase and read the third edition of the Final Exit book. An applicant must send either their medical records, a statement about their illness, a hospice agreement, or a letter indicating they failed in obtaining their medical records to their Case Coordinator along with a personal letter written by the applicant addressed to the Final Exit Network’s Medical Director. This personal letter should state why the applicant wants to die and anything else the applicant wants to say. The applicant is given general information about the preferred inhalation method (helium). The First Responder also completes a form labeled First Responder’s Checklist. The First Responders document their impression of the applicant and send it along with the intake interview and First Responder Checklist forms to the Case Coordinator. The Case Coordinator sends the intake interview, First Responder evaluation and check list to the Medical Director, Dr. Lawrence Egbert. Former Case Coordinator Roberta Massey documented that an applicant’s doctor could mail medical records to Dr. Egbert at or fax them to If the applicant is accepted by the Medical Committee an Exit Guide is assigned by the Case Coordinator. An Exit Guide that lives closest to the applicant is generally chosen. The Exit Guide then decides whether or not to accept the case. The Exit Guide then makes a “get acquainted” call to the member (formerly referred to as applicant). The Exit Guide must personally visit the member on at least one occasion to assess the member and the security situation. The Exit Guide may visit the member multiple times depending on the circumstances. The Exit Guides learned through

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training material that members are people whose illness put them in a dependent position no matter how self-possessed they may seem. The Exit Guide has the member sign forms labeled Request for Exit Guide Volunteer Support and My Instruction on Changing or Not Changing the Appearance of My Body and Bedside which may also read My Wishes Regarding the Appearance of My Body plus the first signature on the form labeled Statement of My Decision After Medical Advice which may also read My Decision Following Medical Consultation. Each of these forms are mailed or faxed to the Case Coordinator. During this stage, the Exit Guide will gain information to include current medical conditions and prognosis, if home hospice care is utilized, medications and dosages, determine if family members are aware of the member’s desire to a hastened death, does the member have any caregivers, is there a surveillance system at their home, does the member have a medical durable power of attorney, and when and how does the member want to die. The Exit Guide instructs the member of a specific brand and size helium tanks (2) and exit bag to purchase approximately one month prior to the date the member has decided to die. The Exit Guide verifies that the member still wants to die and has the member place a second signature on the form labeled Statement of My Decision After Medical Advice. The Exit Guide must also verify that the member’s family members approve of their decision, or if they do not know, then they will not be a hazard to intervene. Exit Guides request the member to open their garage door(s) and allow the two Exit Guide’s cars to park in the garage so they are out of sight on the date of the exit event. This is also useful if the guides remove the equipment (helium tank, exit bag, etc.) and do not want to be seen by neighbors. The exit guide inquires about people who may visit the member without first calling, or what would happen if someone called the member and he/she did not answer. The Exit Guide should inspect the member’s equipment and rehearse the death event. The Exit Guide shows the member how to wear the exit bag like a shower cap and then allows the member to put the exit bag on their head and briefly pull it all the way down. The Exit Guide must also learn who or how the member’s body will be discovered. The Case Coordinator is to be consulted with a solitary person who has nobody to find their deceased body. If a third party is aware of the member’s death, they are to wait at least two hours after the death prior to calling the authorities and are prompted on what to tell the authorities. The Case Coordinator must be consulted when a member is planning an exit event (death) with an Exit Guide. There must be two guides present at every death. The Exit Guide who has prior contact with the member and a more experienced Senior Exit Guide. The Senior Exit Guide and the Exit Guide will talk and discuss the preexisting plans. The Senior Exit Guide can call and talk with the member prior to the exit event. On the day of the death, the Senior Exit Guide will rehearse the exit event with the member. The member will sign the form labeled Statement of My Decision after Medical Advice for the third and final time. Prior to the exit event, the guides should

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review the Exit Planning Checklist with the member. The Exit Guides are reminded of the following equipment disposal guidelines:

1. Replace hex nuts and black nipple valve on the helium tanks. 2. Have large trash bags on hand in advance. 3. Leave helium tank in the boxes. Remove and discard balloons. Boxes will later

be placed in the trash bags. 4. Have grocery bag on hand. Exit bag will later be placed in a grocery bag for

separate disposal. 5. Later, after death, place trash bags in a commercial dumpster (such as behind a

grocery store). Place grocery bag in a separate dumpster. The Exit Guides are instructed to wear latex gloves when disposing of the equipment. The Exit Guides are reminded that the disposal of equipment is to protect the identity of the member and the Exit Guides. The Senior Exit Guide proceeds to the exit event. The Senior Exit Guide instructs the member through the exit event. The member is asked to sit in a semi reclining position. The helium tanks will be left in their boxes and placed so the member can reach them. The member places the exit bag on their head like a shower cap. The member collapses the bag close to their head to expel the air. The member slightly turns on the helium tank to inflate the exit bag. When the bag is full, the Senior Exit Guide asks the member if he/she wants to proceed and reminds them when they pull the bag down there will be no turning back. If the member decides to proceed, they exhale and pull the exit bag down and quickly secure it around their neck and then inhale two deep breathes. Unconsciousness follows after about two or three inhalations. As the body goes deeper into sleep, there may be twitching of the arms and legs. The Exit Guide is generally holding one arm and feeling for a wrist pulse. The carotid pulse can also be checked. Most Senior Exit Guides will leave the exit bag on and the gas running until the tanks are empty. Unless the member requested otherwise, the guides rearrange the member as though death had occurred during sleep. The guides then remove the exit bag from the member and remove the equipment from the residence. After leaving the scene, the guides usually go to a restaurant to “quietly celebrate”. The guides can discuss their feeling or anything else about the situation. One of the guides must contact the Case Coordinator after the exit event and complete the form labeled Final Event Log and mail or fax it to the Case Coordinator. If applicable, the Exit Guide will make a follow up contact to the family member to inquire what happened after the death was reported and provide this information to the case coordinator. ASAC Posey located a form in the training material signed by Frank Langsner titled Statement of Mutual Understanding between Final Exit Network and Exit Guides. Frank Langsner signed and dated this form December 4, 2005. Documents indicate Frank Langsner attended training in San Francisco presented by the Final Exit Network December 2-4, 2005. This document essentially states that Final Exit Network attempts

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to minimize the risk to Exit Guides by discussing the laws pertaining to assisted suicide in all fifty states. Final Exit Network provides appropriate training and legal defense if necessary, but Exit Guides must remain within the limitation imposed by law and refer to the standard protocol received and discussed in training. ASAC Posey also saw a Final Exit Network questionnaire that was completed by Frank Langsner during his training. Frank Langsner answered questions to include why he wished to become an Exit Guide, if he has attended the death of a loved one and his views on hastened death. ASAC Posey also located in the training material a form labeled Final Exit Network Expense and Reimbursement Form. It is documented at the bottom of this form that it is available as an Excel spreadsheet. This form reimbursed guides for expenses during their travel to include mileage. This form is submitted to Judy Coats, VP & Treasurer, . The member rosters list Judy Coats as living in Rochester Hills, Michigan. GBI Intelligence Unit verified current records indicating that Judy Coats lives in Rochester Hills, Michigan. It should be noted Judy Coats is no longer the Treasurer of Final Exit Network. In July of 2008, Dalton Baker became the treasury of Final Exit Network. The Final Exit Network roster list Dalton Baker as residing in St. Louis, Missouri. ASAC Posey also located a letter signed by Final Exit Network President, Ted Goodwin, asking the guides to donate their expenses to the Final Exit Network. This letter contains a section for the guide to list their expense and the amount they pledge back to the organization. The guide must sign and date this form. The Final Exit Network forms discussed above are attached to this Affidavit and marked as an Exhibit – Forms. This eleven-page Exhibit is incorporated into and made a part of this Affidavit by specific reference. Documented in a form titled First Responder Information, January 2007 that appears to be authored by former Case Coordinator Roberta Massey were instructions that applicants must first be a member of Final Exit Network prior to the intake interview. The yearly fee to join Final Exit Network is fifty dollars but in cases of severe hardship can be as little as ten dollars. Applicants are advised to buy and read the book, Final Exit, 3rd Edition with the addendum or purchase the DVD or videotape of Final Exit. Exit guides are warned to be cognizant of stringent security at apartment complexes along with applicants who have family members who oppose their desire to die. Massey informs that an opposing family member who lives out of state may not pose the same threat as one who lives down the street. Massey warns security and opposing family members could have the applicant placed in a psychiatric ward, that hospices may pull out and the police may respond. Massey documents that the presence of hospice not only helps the patient (applicant) but also reduces the risk to Final Exit Network. Massey documented the process an applicant would follow from start to finish. In this process, Massey wrote that the Exit Guides will remove the helium tanks and paraphernalia so authorities do not become familiar with the fact that people are using the tanks for other than party purposes. Massey encouraged Exit Guides to inform the applicant not to complete this process on their own without the help of the Exit Guides. The applicant may botch the process and end up in worse medical shape than before. Massey explained the applicant may get the helium flow

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wrong or claw at the bag and pull it off, either one could result in brain damage and leave the applicant in a vegetative state. ASAC Posey learned the following concerning the details of the Jana Van Voorhis death investigation. On June 6, 2007, Detective Lois Weiss, badge number 6004, along with Detective Jennifer Mellinger, badge number 6067, of the Phoenix Police Department’s Homicide Unit became involved in a death investigation, Phoenix Police report number: 2007-70751550. On April 15, 2007 at 4:15 P.M., Jana Van Voorhis, a 58 year old female, was found deceased in her home and was reported to have died of natural causes. Jana passed away in her home located at in Phoenix, Arizona, Maricopa County. Subsequent to Jana’s death, contact was made by the victim’s family. They suggested that Jana had committed suicide and expressed their concerns about a telephone call they received on April, 13, 2007. The call was from an unknown female, who asked Viki to check on her sister. The caller ID came back to the name of Frank Langsner at In addition, there was a telephone message left on Jana’s answering machine from a male named Frank, informing Jana that the “hood hasn’t arrived from the UPS store yet.” On June 6, 2007 at 9:10 A.M., Detective Mellinger and Detective Weiss contacted Frank Langsner at his home located at . Frank was not a suspect and the contact at his home was a fact finding mission in order to develop information about Jana and the possibility that she had committed suicide. The purpose of the contact was on behalf of the family. Frank was not placed under arrest and he was free to stop answering Detective Weiss and Detective Mellinger’s questions at any time. Detective Weiss told Frank that Jana’s family had informed her about Jana’s interest in organizations such as the Final Exit Network and the Hemlock Society. The Final Exit Network and Hemlock each were members of the ‘World Federation for the Right to Die Societies.’ Frank said he belonged to the “Final Exit” and that he was a member. He stated that he was an “Exit Guide.” Frank admitted to being present with Jana Van Voorhis when she committed suicide through helium inhalation. Frank said that Wye Hale-Rowe from Aurora, Colorado was present with Jana Van Voorhis as well. Frank was the ‘Exit Guide’ who had been assigned to Jana Van Voorhis by their main person in New Jersey (Roberta Massey), after her application to the Final Exit Network. Wye Hale-Rowe was a Lead Exit Guide for the Final Exit Network and flew to Phoenix from Colorado, during the morning of April 12th, 2007. Wye Hale-Rowe’s presence was necessary in order to assist Frank with helping Jana. They were present to keep Jana in the state of mind so that she would be able to commit suicide. Frank explained the role of an Exit Guide was to “help get them in a frame of mind that they want to do it.” Jana wanted to end her life and told the Final Exit Network’s ‘Medical Committee,’ that she was terminally ill, which caused intolerable suffering. The medical evaluation was

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performed, and Frank said it was completed telephonically. On June 8, 2007, the Phoenix Police Department’s investigation into Jana’s medical records revealed that Jana was not terminally ill but was mentally unstable. Frank provided Detective Weiss and Detective Mellinger with information on the initial consultation that Frank had completed on Jana. While Detectives Mellinger and Weiss were in Frank’s home, he left the room and returned with several pieces of paper. He began to read from the paper and stated Jana had the following ailments: porphyria, lesion on the liver, possible breast cancer, many head injuries, removal of the gall bladder, an enlarged liver and spleen, a hysterectomy in 2006, removal of silicon implants, overexposure to radiation, ingestion of rat poison and additional intolerable pain. Frank went on further to read several medications, some of which were: Lexapro, Klonopin, Ambien, Vicodin and Tylenol PM. Frank stated, “she was a mess and she was so happy to want to do it.” Frank recalled how often Jana would fall asleep while he was speaking with her in person. Jana was under the impression that the Final Exit Network would supply the means for her to take her life. Final Exit Network strongly discouraged violence and instead, they informed Jana she could purchase helium tanks at a party store and this would be a method she could use. Frank was the supporting person for Jana and she would contact his home often. Frank and Wye had a ‘practice session’ with Jana on April 12th, 2007, at around one or two in the afternoon. Wye flew in from Colorado that same morning to go with him to Jana’s home at for a practice session. Frank said, “we showed her how to do it” by correctly placing the hood over her head and turning on the helium tanks. Jana practiced hooking up the tanks and placing the hood over her head. Jana’s hair was in the way, so Frank told Jana to put her hair up for the time when they would return, which was ten in the evening. Frank wanted Wye there because she was the main Exit Guide and had “done 18 or 19 of them over the years.” Later that same evening, Frank and Wye returned to Jana’s home and Wye asked Jana if she was ready to take her life. Jana said she was ready and committed suicide through helium inhalation while Frank and Wye watched. Frank said that she had died peacefully 15 minutes later. Jana “just went to sleep”. Detective Weiss told Frank that she had researched some chapters in Final Exit, books 1 and 2. It was documented in the book that individuals, who take their lives via helium inhalation, normally take a sedative prior to placing the hood over their head and turning on the helium tank(s). Detective Weiss asked Frank if Jana took a sedative prior to placing the hood over her head and turning on the helium tank(s). Frank responded she did not take a sedative. After the suicide was completed, Frank and Wye removed the two helium tanks, along with the hood and tubing. They disposed of the tanks and other related apparatuses in two different undisclosed locations in Phoenix. Frank said they were placed in dumpsters. The purpose of removing all of the equipment is so it appears to the victim’s family that the death was natural. Final Exit Network promotes helium

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inhalation because helium is an inert gas and is undetectable in the blood stream at autopsy. Frank then offered answers to the questions which were posed in the beginning of our contact with him. Wye Hale-Rowe had contacted Jana’s sister, Viki on April 13, 2007 because they wanted the body to be discovered. In addition, Frank left a message for Jana at her home, shortly before her death. Jana had contacted him and was panicked over the hood she had ordered, which was to be used during the commission of her suicide. The hood had not yet been delivered. Jana expected the hood to arrive the following day but it did not arrive until a week later. Frank said that was a “sign of someone that wants out.” On June 12, 2007 at 8:16 A.M., Detectives Weiss and Mellinger served a search warrant at in Scottsdale, Arizona, in the County of Maricopa. This was the residence of Frank Langsner. Several items were retrieved from his bedroom, to include Jana Van Voorhis’ Final Exit Network Intake interview forms, her Final Exit log and binders on the Final Exit Network’s training manuals. On June, 14 2007 at 11:58 A.M., Detectives Weiss and Mellinger served a search warrant at in Aurora, Colorado, in the County of Arapahoe. This was the residence of Wye Hale-Rowe. Several items were retrieved from her living room/ den area, to include Jana Van Voorhis’ Final Exit Network Intake interview forms, Final Exit Network “Statement of My Decision Following Medical Consultation” form, Jana’s Final Exit Log and binders on the Final Exit Network’s training manuals. Even though Wye would not speak with the Detectives, she made one telephone call to a person she called “Ted.” “Ted” told Wye he would get her an attorney. The Final Exit Log seized by the Phoenix Police Department documented the events which occurred on the day of Jana Van Voorhis’ exit event. This log was written by Wye Hale-Rowe. Wye Hale-Rowe documented on the Final Exit Log that during the rehearsal of the death event Jana seemed to need assurance a second and third time that the procedure would be painless and peaceful. Wye documented the death event. Wye explained that Jana “put on the bag on her head as rehearsed and crushed out the air. The bag quickly filled up with helium after she turned them on and adjusted the valve flow from the tanks. She said she was ready to continue and pulled down the bag.” It should be noted, as was discussed in the training material, the previous sentence would be Jana’s answer to Wye’s question determining if she wanted to proceed and reminding her that when she pulls the bag down there will be no turning back. This log also documented that after approximately fifteen minutes all signs of respiration and pulse had disappeared and the tank valves were completely opened. The log further documents how Frank Langsner parked his car in Jana Van Voorhis’s garage and the equipment was placed in Frank’s car. Three trash bags were dropped in three separate, pre-scouted office trash sites in the area. Wye documented Jana Van Voorhis’ garage door opener was placed in her mailbox.

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Detectives Weiss and Mellinger noted on the intake interview paperwork that a man named “Harry Lien” completed the intake interview on Jana Van Voorhis. On April 15, 2008 at 8:20 A.M. Detectives Weiss and Mellinger contacted Harry Lien at his residence located at in Green Valley, Arizona, Pima County. Harry admitted to completing the intake interview on Jana and said he faxed the paperwork to the Case Coordinator. Investigators learned the Case Coordinator was Roberta Massey in Cherry Hills, New Jersey Roberta received all of the faxes from the intake interviews and it was reviewed by what Harry referred to as a “so called medical committee.” Harry indicated he maintained a copy of the intake interview he conducted with Jana. Harry essentially stated he does not follow a person through the process after he completes the intake interview. Harry only learned of Jana’s death because of an article that was written in the newspaper. Harry has been associated with Final Exit Network since it started in 2004. Harry explained the operations of the Final Exit Network. A person calls the Final Exit Network telephone number which is monitored by a paid answering service. The answering service obtains a small amount of information and provides it to the Case Coordinator. The Case Coordinator then has the First Responder contact the person to complete the intake interview. The First Responder sends the intake interview to the Case Coordinator who sends it to the Medical Review Committee. Harry was not certain of everything done by this committee. If the person is accepted as a member an Exit Guide is assigned to them. Then the Exit Guide communicates with the member until their exit event. Harry stated the Final Exit Network has training classes for Exit Guides. Harry stated he was a First Responder and has not attended the Exit Guide training class. On June 13, 2008 at 2:15 A.M., the Phoenix Police Department responded to Camelback Road, space D-84, in Phoenix, Arizona, Maricopa County. This death investigation (Phoenix Police Report number: 2008-81196299) involved a man named Victor Torrey, date of birth: His wife, Shirley Torrey (date of Birth: ), was also present. She claimed to have found him with a painter’s mask on his mouth and another large, plastic bag over his head. She removed the bag from his head and immediately called the police. Detective Heather Polombo #6237 of the Phoenix Police Homicide Unit, assumed the investigation. Shirley told Detective Polombo that Victor was a long standing member of the Hemlock Society and a former Exit Guide for that group. Victor was recently taking insulin for his diabetes and was disgusted with his current condition, although he was not terminally ill. Shirley believed her husband committed suicide to avoid being hospitalized over his current condition. As Detective Polombo was going through the unit, she discovered the third edition of the Final Exit book. Inside of the book, she discovered there was a piece of paper in the book with the following information: Ted Goodwin Final Exit 1-800-878-8983

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$60 – 10 minute 20 minute 50 balloon tank

Kennasaw, GA. 30144

The above listed toll free 800 telephone number is the phone number of Ted Goodwin’s business, OHR Incorporated, as noted on the business’ website. GBI intelligence verified the above address is Ted Goodwin’s Georgia residence. Based on ASAC Posey’s experience gained in this investigation, information contained in the note indicates that Victor Torrey discussed his hastened death with the Final Exit Network. Victor Torrey listed Ted Goodwin’s business telephone number and home address. Other details in the note also correspond to Final Exit Network procedures. The exit hood cost sixty dollar ($60). Death by the inhalation of helium could occur between ten and twenty minutes. Finally, the Final Exit Network advises its member to purchase a fifty balloon helium tank to ensure there is enough helium to cause death. On May 31, 2008 Maricopa County, Arizona Attorney’s Office Commander Mark Stribling and Detective Larry Mayer interviewed Roberta Massey at her residence in New Jersey. Roberta was the Case Coordinator but was no longer affiliated with the Final Exit Network. Roberta stated the Final Exit Network formed in September of 2004 and she became involved in 2005. Roberta ended her association with the Final Exit Network in mid January or early February of 2008. Roberta was also previously a member of other similar organizations called the Hemlock Society and End of Life Choice. During the early stages of the interview, Roberta indicated she could not answer any questions about the Final Exit Network and that the questions should be presented to the president, Ted Goodwin. Roberta made the statement “they would take my head off if I said too much.” Roberta remembered there was a conference call concerning the criminal investigation into the death of Jana Van Voorhis by Final Exit Network personnel but she would not provide any names. Roberta indicated she could not specifically remember receiving Jana Van Voorhis medical records because she has “dealt with an awful lot of people.” Roberta indicated, as is documented in the training material, that she should have received Jana’s medical records and eventually sent them to Dr. Larry Egbert at his residence. Dr. Egbert would send Roberta an email that the applicant was either accepted or denied as a member of the Final Exit Network. Roberta agreed sometimes the applicant’s doctor mails or faxes the medical records directly to Dr. Egbert’s home address. Roberta stated Dr. Egbert would have “every piece of record there is.” As is documented in the training material created by Roberta, the applicant’s doctor is told that Dr. Egbert is receiving the records because he is a pain management specialist. Roberta admitted the organization instructs their members not to tell anyone, unless absolutely necessary, that they are a part of the Final Exit Network including the applicant’s own doctor. The reason this is done includes preventing the involvement of law enforcement authorities. Plus, the training material indicates this may lead to the member being admitted to a mental hospital.

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Roberta stated she had a separate ID set up on her computer just for the Final Exit Network. Roberta stated she had recently been getting rid of everything on her computer related to Final Exit Network. Robert commented “there were thousands of emails on that damn computer…” It should be noted that within the training material are the names, address, phone numbers and email address of the Final Exit Network’s personnel. Roberta previously maintained historical records of members. After Roberta’s departure, four new Case Coordinators were created but she would not name them. Roberta said the new Case Coordinators were board members. These Case Coordinators would have records of active cases, and Dr. Egbert would have medical records. Roberta sent her historical records to the person who supervises the four Case Coordinators but again she would not name this person. Roberta indicated Ted Goodwin would have records of members he served as a guide. It should be noted this means Ted Goodwin would have the records of John Celmer. Roberta said there is no building that houses the Final Exit Network. Ted Goodwin owns a business in Georgia. Final Exit Network’s mail is sent to Georgia and some of Ted Goodwin’s office people do a lot of work for the Final Exit Network. It should be noted, according to records, Jessique Kelly is listed as an authorized user of the Final Exit Network’s post office box and an employee of Ted Goodwin’s business, OHR Inc. The OHR, Inc. website listed Jessique Kelly as the administrative manager for the company. The only other employees listed on the website were President Ted Goodwin and operational manager Randy Riblett. GBI Personnel Director verified Jessique Kelly and Randy Riblett were the only full time employees and that Ted Goodwin was the President of OHR, Inc. An analysis of Ted Goodwin cellular telephone bill indicated he was contacted by Claire Blehr after her scheduled meeting with John Celmer on May 7, 2008. After the controlled telephone call from Paul Sciandra, Ted Goodwin contacted Dr. Larry Egbert’s work and home telephone number. Ted Goodwin had numerous conversations with Claire Blehr, Nick Sheridan, and Dr. Larry Egbert during John Celmer’s association with the Final Exit Network. On September 12, 2008, an undercover Georgia Bureau of Investigation Agent utilizing the name of Richard Sartain joined Final Exit Network. On November 20, 2008, the undercover agent called the Final Exit Network number of 800-524-3948 and spoke with the answering service and inquired about receiving more information about Final Exit Network. On November 23, 2008 the undercover agent was contacted by Case Coordinator Nick Sheridan from telephone number Sheridan learned the undercover agent wanted to hasten his death. Sheridan asked for the undercover agent’s medical records and a personal letter stating why the undercover agent wanted to hastened his death. Sheridan mentioned the personal letter was needed so they would have it “on record.” Sheridan asked to receive this information and he would pass it onto the Medical Review Committee. The undercover agent requested to mail this information directly to a doctor. Sheridan provided the undercover agent

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with Dr. Egbert’s name and mailing address of . On December 12, 2008, ASAC Posey wrote the personal letter and mailed it and

Richard Sartain’s fictitious medical records to the address listed above which is Dr. Egbert’s residence. On December 10, 2008, Judy Snyderman who was the First Responder called the undercover agent and she asked him all the questions listed on the Final Exit Network intake interview forms. Judy Snyderman had previously contacted the undercover agent and provided a telephone number of On December 24, 2008, the undercover agent received a call from Nick Sheridan notifying him he had been accepted as a member of the Network and that he would receive a call from Claire Blehr. On December 24, 2008, Exit Guide Claire Blehr called the undercover agent to arrange a time she could meet with him at his residence and provided a contact number of Claire Blehr asked the undercover agent if he had read the material related to the helium death. Blehr warned the undercover agent not to attempt the helium method alone because he could pull the exit hood off his head and be in worse condition than he was before he started. Blehr explained that she and the Senior Exit Guide, Ted Goodwin, would prevent the undercover agent from pulling the hood off his head. On Thursday, January 8, 2009, Blehr met with the undercover agent at a residence in Dawson County. Blehr explained the exit event. Blehr said the undercover agent would place the exit hood on top of his head similar to a shower cap. The undercover agent would then inflate the hood by turning on the helium tank. Blehr stated he would then breathe out, pull the exit hood completely over his head, take two deep breathes and then the “lights would go out.” Blehr explained he would not be dead at this point and that she and Ted Goodwin would let the helium tanks run for twenty minutes after they last felt his pulse. Blehr explain one of the guides would stand beside the undercover agent during this process and the other guide would be on the bed holding his hands down to ensure the undercover agent did not pull the bag off his head. Blehr explained she had assisted with three other deaths and Ted Goodwin was with her each time. Blehr explained Ted Goodwin had assisted with about thirty deaths. On January 16, 2009, Ted Goodwin talked to the undercover agent by telephone. Ted Goodwin was reached at his cellular phone,

Ted Goodwin wanted to ensure that nobody would unexpectedly come to the undercover agent’s residence during the exit event. Ted Goodwin ensured the undercover agent had not discussed his hastened death with anybody outside Final Exit Network. Ted Goodwin added he wanted to avoid a police investigation and prosecution. Ted Goodwin explained the process of the undercover agent death as a result of inhalation of helium. Ted Goodwin essentially described this as a peaceful process. Ted Goodwin explained he and Claire Blehr would remove the helium tanks and exit hood and the undercover agent’s death would be attributed to heart failure. Ted Goodwin explained the brain is the first organ to die but the heart and lungs might keep working until the heart stops because it and the brain are not receiving oxygen. Ted Goodwin explained he had been present for thirty five deaths in the past four years. Ted Goodwin and the undercover agreed to talk once or twice a week until the exit event. ASAC Posey reviewed a Channel3000.com article found on the internet that was dated February 27, 2008. Ted Goodwin was quoted as saying Final Exit Network had assisted 130 members end their lives in the organization’s three year history. Final

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Exit Network website documented this organization started on September 16, 2004. Ted Goodwin also mentioned in this article that the organization was sure their members are not simply depressed 99.9% of the time because of a thorough psychological and psychiatric screening. Ted Goodwin said their screening improved after an Arizona member (Jana Van Voorhis) with past psychological problems ended her life and two Exit Guides were investigated but not charged. It should be noted the GBI undercover agent received no psychological and psychiatric screening. ASAC Posey reviewed a flyer provided by Final Exit Network in September of 2008 that documented the organization had over sixty (60) first responders and exit guides. ASAC Posey conducted an analysis of Final Exit Network’s bank records from March 1, 2007 through October 31, 2008. ASAC Posey noticed that Final Exit Network treasurer Judy Coats and Dalton Baker wrote numerous checks to reimburse Exit Guides for their travels. It should be noted that in July of 2008, Dalton Baker assumed the responsibilities of Treasurer as evident in the signatures on the checks, as well as, documented on the Network’s website. The bank statements during Judy Coats tenure contained her home address. The bank statements now have Dalton Baker’s home address at The Final Exit Network wrote numerous reimbursement checks for Exit Guide travels to Ted Goodwin, Dr. Larry Egbert, Nick Sheridan, Claire Blehr, Wye Hale-Rowe, Dalton Baker, Bernie Klein, Judy Snyderman and many other people. Judy Coats wrote expense checks to Bernie Klein for training material and Exit Guide training in Chicago in June of 2008. Dr. Egbert also received a reimbursement check in June of 2008 for travel expenses related to training in Chicago. Ted Goodwin also received a reimbursement check in June of 2008 that is only documented as expense reimbursement. Judy Coats wrote an expense check to Dalton Baker for training material and Exit Guide training in California in November of 2007. Dr. Egbert received a travel expense check in November 2007 but the reason for the travel was not documented. The Network wrote many checks to Diane King for data entry and Catherine Mann for clerical work. Recently, Dalton Baker wrote a check to Jessique Kelly paying her an hourly salary of fifteen dollars an hour for nineteen and a half hours of work. Dalton Baker also reimbursed Jessique Kelly for a filing cabinet. The Network wrote numerous expense checks to Dr. Larry Egbert, Ted Goodwin and OHR, Inc. that were not related to Exit Guide travels. The Network reimbursed OHR, Inc. for rent, utilities and unreimbursed salaries, Federal Express charges, and postage. Dr. Egbert was paid by the Network for speaking events, Federal Express charges, and postage. Ted Goodwin was paid by the Network for miscellaneous expenses, speaking events, webcasting, and to repay a thirty thousand dollar loan given to the Network by Goodwin. The Network also wrote a check in 2007, as well as one in 2008, paying for Post Office Box Number 965005. ASAC Posey noticed at the end of June 2008, Judy Coats ceased from signing the Final Exit Network’s checks. In July of 2008, Dalton Baker began signing the Final Exit Network’s checks. On July 11, 2008, Dalton Baker was paid three hundred thirty four

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dollar and eighty cents for treasurer duties. The change of Treasurer was also noted on the Final Exit Network website. Roberta Massey was written a check by Judy Coats shortly after the death of Jana Van Voorhis for Case Coordinator’s expenses and Wye Hale-Rowe was written a check reimbursing her for an Exit Guide expense. After Phoenix Police Department executed search warrants at Frank Langsner and Wye Hale-Rowe residences, Judy Coats wrote two checks to a Phoenix, Arizona lawyer as a retainer for both the Final Exit Network and Frank Langsner. Judy Coats later wrote a check to a separate lawyer as a retainer for Wye Hale-Rowe. ASAC Posey noticed the Final Exit Network wrote numerous checks to a company named At Conference. This is a conferencing call company. Roberta Massey stated that personnel of the Final Exit Network had a conference call to discuss the Jana Van Voorhis death. This further corroborates the organizational level of the Final Exit Network and that its members are working together as a criminal enterprise. During the analysis of the Final Exit Network bank record, ASAC Posey noticed checks written to Jennifer Pohlhaus for maintenance of the World Federation of Right to Die Society’s (WFRTDS) website. ASAC Posey also noticed Final Exit Network paid annual dues to this same organization. ASAC Posey viewed the WFRTDS website and noticed Ted Goodwin was the United States contact and referred to the Final Exit Network website and information email address. ASAC Posey obtained the bank records of WFRTDS and noticed in the business minutes that Ted Goodwin was listed as the Treasurer and that Final Exit Network would take over the maintenance of the WFRTDS website. WFRTDS Certificate of Incorporation defined this organization as a nonprofit corporation. This nonprofit corporation was created to promote the cause of self-determination in dying by making representations to any appropriate international organization, by commissioning and publishing research into any aspect of that issue, and by promoting co-operation between organization whose aim is to advance the individual’s right to self-determination in dying. The incorporation document further stated WFRTDS would acquire the assets of other similar not-for-profit corporations, whether by purchase, gift, merger consolidation or otherwise and to solicit, accept, and hold contribution, gifts and grants of every sort and to borrow funds for the purpose of the corporation. ASAC Posey noticed other organizations that share a similar cause as Final Exit Network also pay WFRTDS annual dues. Two of these organizations documented under the memo section of the check that the dues paid were for one percent of the respective organization annual revenue. WFRTDS’ bank statements contain the address of Ted Goodwin’s Florida address,

It is important to seize all WFRTDS business records to include financial records, training and research records to determine the extent this organization has assisted Final Exit Network illegally assist others hastened their death. On June 1, 2008 Commander Stribling and Detective Mayer of the Maricopa County, Arizona Attorney’s Office interviewed the Final Exit Network Medical Director Dr. Larry Egbert at his office located at Physicians for Social Responsibility, 325 East 25th Street, Baltimore, MD 21218, telephone number 410-235-7760. Dr. Egbert referred all

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questions to the Final Exit Networks lawyer but did not provide the lawyers’ name. The telephone number of 410-235-7760 is registered to Dr. Egbert’s business address. The Final Exit Network’s roster documented Dr. Larry Egbert address as

1, telephone number fax number and email address as . GBI intelligence verified this is Dr. Egbert’s home address and the telephone number is registered to Dr. Egbert’s office. The email address is registered to Dr. Egbert at his home address of

. The Final Exit Network website listed Dr. Larry Egbert as the Medical Director, Senior Exit Guide and frequent Network speaker. The Final Exit Network’s roster documented Case Coordinator, Nick Sheridan’s, address as , home telephone number

cellular number , email address . GBI intelligence verified this is Nick Sheridan home address and home telephone number. This email address was registered to Nick Sheridan at his home address of

. The Final Exit Network roster listed Dalton Baker’s contact information as

telephone number email address GBI Intelligence verified this as being Dalton Baker’s current address and phone number. The Final Exit Network website listed Dalton Baker as the Treasurer who joined the Network’s board in 2006. Dalton Baker has served as a First Responder, Senior Exit Guide and member of the training faculty. The Final Exit Network roster listed Bernie Klein’s contact information as

telephone number and email address as GBI Intelligence verified this as being Bernie Klein’s current address and phone number. The Final Exit Network website listed Bernie Klein as the Secretary of Final Exit Network. Bernie Klein joined the board in 2007. Bernie Klein served as a First Responder, Exit Guide and Final Exit Network speaker. The website’s calendar listed Bernie Klein’s last speaking engagement on September 28, 2008 in Jamestown, New York. Bernie Klein was scheduled to speak on end of life issues and Final Exit Network’s role. The Final Exit Network roster did not list Duffy Rutledge, Judy Snyderman, Diane King, Jessique Kelly, and Catherine Mann. Judy Snyderman was listed on the Final Exit Network website as a Network board member since 2008. Judy Snyderman has served as a First Responder and Exit Guide Past-President. The Final Exit Network’s roster documented President, Ted Goodwin’s, address as

Ted Goodwin’s home telephone number is cellular number email address

. The home telephone and fax number is registered to Thomas and Marilyn Goodwin at . The cellular phone is registered to Thomas E. Goodwin at the same Punta Gorda, Florida address. The email address is registered to Ted Goodwin’s wife Marilyn with all the contact numbers

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being documented as the Goodwin’s home telephone number of Earthlink was not able to provide an IP log for this email address. As documented above, Ted Goodwin’s Georgia residence is located at 15 Latimer Lane, Kennesaw, Georgia. The Georgia Secretary of State website list Ted Goodwin’s Kennesaw, Georgia address under his name. The Georgia Secretary of State document listed Ted Goodwin as the Chief Financial Officer when this entity was established in Georgia on August 26, 2004. The Final Exit Network has an account with PayPal which was started on September 9, 2004. One address listed on this account for Final Exit Network is . The Final Exit Network website listed Ted Goodwin as the President and founding board member who has served as a Senior Exit Guide and frequent Network speaker. ASAC Posey noticed the public address for Final Exit Network is Post Office Box 965005, Marietta, Georgia. This post office box was obtained in September 2004 by T.E. Goodwin. A physical address was provided as

. The business that is located at this address is Resource MFG. ASAC Posey learned this was a previous address for OHR, Inc. The public phone numbers for Final Exit Network are 800-524-3984 and 770-499-7800. The billing address for 770-499-7800 documented by AT&T is the post office box documented above. The service address is . Final Exit Network, Inc. incorporated with the State of Georgia on August 26, 2004 and dissolved their corporation on May 16, 2008. Thomas E. Goodwin was listed as the Chief Financial Officer and a board member by the Georgia Secretary of State’s Office. Ted Goodwin is currently the President of this organization. Based on the fact that members of this organization hesitate to discuss the organizations business and refer questions to Ted Goodwin, it is obvious he closely manages the activity of the Final Exit Network and the organization’s personnel. The Final Exit Network teaches its personnel the Final Exit Network’s standard operating procedures and the laws of all fifty states related to assisted suicide. The Case Coordinator (in Celmer’s case, Nick Sheridan) managed the activity of the guides and managed the administrative paperwork necessary for a member to join the organization and experience a hastened death with the assistance of the Exit Guides (Claire Blehr/Ted Goodwin). The Medical Director (Dr. Egbert) determined if an applicant can join the organization and ultimately experience a hastened death with the assistance of the Exit Guides. The Exit Guides completed the work of the organization which includes communication with the members, completion of paperwork and assisting with the member’s hastened death. The manner in which the Final Exit Network trains its personnel should be documented in the training material. By the manner in which the Network documents its activity, it is reasonable to believe the Exit Guide trainers create an instructor’s manual. Final Exit Network thoroughly documents its actions from its training manual, Exit Guide travels and Final Exit Event Log. It is reasonable to believe Exit Guide instructors would create an instructor’s manual documenting the Exit Guide training class for liability purposes. ASAC Posey noticed that most of the Final Exit Network paperwork documents their actions so law

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enforcement or family members cannot misconstrue their actions. As a certified law enforcement instructor, ASAC Posey understands the importance of creating and maintaining instructor’s manual for classes that are taught in high liability areas such as law enforcement and the same would be true for people who are teaching others how to assisting people commit suicide with or without breaking the law. This point alone makes Final Exit Networks training program a high liability area in the criminal and civil arena. This information would further prove that the Final Exit Network trains its volunteers to prevent a member from pulling the exit bag off their head after they start the exit event; and because the organization trains its volunteer to remove evidence from the crime scene, the organization and its members are violating Georgia’s Racketeer Influenced and Corrupt Organizations Act. Exit Guide Claire Blehr indicated to Paul Sciandra and the undercover agent that deceased members’ records were retained for one year. Claire Blehr was never specific as to which records were retained for one year. The potential liability discussed in the paragraph above, creditability is given to the fact that Final Exit Network would retain their records on a member for one year. It is ASAC Posey’s experience and through consultation with Federal Bureau of Investigation Steve McGinty that in the current era, treasurer duties are more easily accomplished through accounting computer software programs such as Quickbooks, Turbotax, Microsoft Excel software or other programs. These programs are utilized by accountants and other people who are tasked with organizing and maintaining the financial records of an entity. It is also common that financial information is maintained long after their usefulness has passed; furthermore, past financial information can be passed from one treasurer to another for accountability, maintenance of records, and for informative purposes. Agent McGinty is a nineteen (19) year veteran of the Federal Bureau of Investigation in the area of white collar crime. Agent McGinty has worked financial, mortgage and health care fraud. Agent McGinty is considered an expert in white collar crime. Therefore, staleness is not an issue for the type of records and information sought by this affidavit. Members of Final Exit Network communicated with John Celmer by email. ASAC Posey received undercover agent Richard Sartain’s membership letter dated October 20, 2008 which asked members to register their email address by sending an email to info@finalexitnetwork.org. The letter stated that email is very important to Final Exit Network. As noted in the examination of John Celmer’s computer, vital information can be obtained from email contacts. Therefore, it is important to seize the computers of the Final Exit Network member documented in this search warrant to review email contacts with others people associated with Final Exit Network in the furtherance of the criminal organization. This would include laptop computer(s) which can easily be moved from one person residence to a secondary residence or office. Because this organization operates as a nonprofit corporation, it is prudent to expect volunteers of the organization to store information and documents related to the organization on their computer or other storage media along with retaining original or copied documents. Information stored on computers and related storage media can be deleted but retrieved through a forensic examination. This is based on the

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documentation outlined in this affidavit and the experience of GBI High Technology Investigative Unit Assistant Special Agent in Charge Sandra Putnam. Sandra J. Putnam is the Assistant Special Agent in Charge of the High Technology Investigations Unit and has been with the Georgia Bureau of Investigation for 14 years. ASAC Putnam has extensively worked computer crimes and computer forensics for the last six years. ASAC Putnam has participated in over 600 hours of training in computer investigative methods and computer forensics. ASAC Putnam is a Certified Forensic Computer Examiner and a Certified Fraud Examiner and also provided the following information: Computer files or remnants of such files can be recovered months or even years after they have been downloaded onto a hard drive, deleted, or viewed via the Internet. Electronic files downloaded to a hard drive can be stored for years at little to no cost. Even when such files have been deleted, they may be recoverable months or years later using readily-available forensic tools. When a person “deletes” a file on a home computer, the data contained in the file does not actually disappear; rather, that data remains on the hard drive until it is overwritten by new data. Therefore, deleted files, or remnants of deleted files, may reside in free space or slack space – that is, in space on the hard drive that is not allocated to an active file or that is unused after a file has been allocated to a set block of storage space – for long periods of time before they are overwritten. In addition, a computer’s operating system may also keep a record of deleted data in a “swap” or “recovery” file. Similarly, files that have been viewed via the Internet are automatically downloaded into a temporary Internet directory or cache. The browser typically maintains a fixed amount of hard drive space devoted to these files, and the files are only overwritten as they are replaced with more recently viewed Internet pages. Thus, the ability to retrieve residue of an electronic file from a hard drive depends less on when the file was downloaded or viewed than on a particular user’s operating system, storage capacity, and computer habits.

SPECIFICS REGARDING THE SEIZURE AND SEARCHING OF COMPUTER SYSTEMS

Based on my own experience and consultation with other agents who have been involved in the search of computers and retrieval of data from computer systems and related peripherals, and computer media, there are several reasons why a complete search and seizure of information from computers often requires seizure of all electronic storage devices, as well as all related peripherals, to permit a thorough search later by qualified computer forensic agents or examiners in a laboratory or other controlled environment:

a. Computer storage devices, such as hard disks, diskettes, tapes, laser disks, compact discs, and DVDs, can store the equivalent of hundreds of thousands of pages of information. Additionally, when an individual seeks to conceal information that may constitute criminal evidence, that individual may store the information in random order with deceptive file names. As a result, it may be necessary for law enforcement authorities performing a search to examine all the stored data to determine which particular files are

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evidence or instrumentalities of criminal activity. This review and sorting process can take weeks or months, depending on the volume of data stored, and would be impossible to attempt during a search on site; and

b. Searching computer systems for criminal evidence is a highly technical process, requiring specialized skill and a properly controlled environment. The vast array of computer hardware and software available requires even those who are computer experts to specialize in some systems and applications. It is difficult to know before a search what type of hardware and software are present and therefore which examiners will be required to analyze the subject system and its data. In any event, data search protocols are exacting scientific procedures designed to protect the integrity of the evidence and to recover even hidden, erased, compressed, password-protected, or encrypted files. Since computer evidence is extremely vulnerable to inadvertent or intentional modification or destruction (both from external sources or from destructive code imbedded in the system as a booby trap), a controlled environment is essential to its complete and accurate analysis.

Based on my own experience and my consultation with other agents who have been involved in computer searches, searching computerized information for evidence or instrumentalities of a crime often requires the seizure of all of a computer system’s input and output peripheral devices, related software, documentation, and data security devices (including passwords) so that a qualified computer examiner can accurately retrieve the system’s data in a laboratory or other controlled environment. There are several reasons that compel this conclusion:

a. The peripheral devices that allow users to enter or retrieve data from the storage devices vary widely in their compatibility with other hardware and software. Many system storage devices require particular input/output devices in order to read the data on the system. It is important that the analyst be able to properly re-configure the system as it now operates in order to accurately retrieve the evidence listed above. In addition, the analyst needs the relevant system software (operating systems, interfaces, and hardware drivers) and any applications software which may have been used to create the data (whether stored on hard drives or on external media), as well as all related instruction manuals or other documentation and data security devices.

b. In order to fully retrieve data from a computer system, the examiner also

needs all magnetic storage devices, as well as the central processing unit (CPU). In cases like the instant one where the evidence consists partly of image files, the monitor and printer are also essential to show the nature and quality of the graphic images which the system could produce. Further, the examiner again needs all the system software (operating systems or interfaces, and hardware drivers) and any applications

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software which may have been used to create the data (whether stored on hard drives or on external media) for proper data retrieval.

c. I am familiar with and understand the implications of the Privacy

Protection Act (“PPA”), 42 U.S.C. § 2000aa, and the role of this statute in protecting First Amendment activities. I am not aware that any of the materials to be searched and seized from the SUBJECT PREMISES are protected materials pursuant to the PPA. If any such protected materials are inadvertently seized, all efforts will be made to return these materials to their authors as quickly as possible.

Ted Goodwin served as a Senior Exit Guide for John Celmer. Affiant believes there is probable cause to search the residence, computer(s) and storage media of Ted Goodwin for documents related to John Celmer, Richard Sartain and the Final Exit Network. Former Case Coordinator Roberta Massey told investigators Goodwin would possess paperwork related to those he had personally assisted with their hastened death. Because Ted Goodwin is a Senior Exit Guide who has been present at thirty to thirty five deaths and the President of the organization it is prudent to believe he would have business records and records related to the hastened death of John Celmer and others. It is also prudent to believe Ted Goodwin would have financial records related to the travel and donations of the Exit Guide members who have assisted with the hastened death of other victims. Ted Goodwin has two residence, one in Georgia and one in Florida. The Florida residence appears to be his primary residence. OHR, Inc. employee, Jessique Kelly, told the GBI Personnel Director that Ted Goodwin came to OHR, Inc. approximately once a month. Ted Goodwin’s Georgia residence is located in close proximity to OHR, Inc. It is reasonable to believe Ted Goodwin resides at this Georgia residence when he travels to visit OHR, Inc. This affidavit has clearly documented Ted Goodwin and OHR, Inc. connections to Final Exit Network. Ted Goodwin provided this address to a man who committed suicide in Phoenix, Arizona in 2008 and this address was listed on a November 2005 Final Exit Network First Responder’s roster. This address is listed as one address for Final Exit Network on its PayPal account. Ted Goodwin clearly has the ability to receive and store Final Exit Network documents discussed in this affidavit at his Georgia residence. Affiant requests permission to seize all Final Exit Network paperwork related to the hastened death of other victims retained by Ted Goodwin along with any training or instructor material which would include notes used for speaking engagements for Final Exit Network.

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I swear or affirm that all of the information contained in this Affidavit and all other testimony given by me under oath is true to the best of my knowledge and belief.

AFFIANT: _______________________

TITLE: _____ Sworn to and subscribed to before me this ______ day of February, 2009 at (AM)(PM)

_______________________________________ Judge of Superior Court,

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SEARCH WARRANT IN THE SUPERIOR COURT OF COBB COUNTY

STATE OF GEORGIA

Docket No. __________ TO: ALL PEACE OFFICERS OF THE STATE OF GEORGIA Affidavit having been made before me by Special Agent Wesley Horne deposes and says: I am a certified Law Enforcement Officer of the State of Georgia employed by the Georgia Bureau of Investigation. I am charged with the duty of violations of criminal laws to include crimes against persons, and that I have reason to believe that in Cobb County, Georgia, on the person, premises, or property described as follows: (state detailed description of person, property, or location)

the dwelling of Thomas Edmund Goodwin, W/M; DOB: ; the residence is located in Cobb County at the intersection of Latimer Lane and Latimer Court; it is described as a two story, contemporary residence with grey siding and a two car garage. The drive to the residence enters off of Latimer Lane but the garage faces Latimer Court. The mailbox has the number 15 on it.

There is now located certain instruments, articles, person(s), or things, namely: (specify evidence, contraband, or person(s) to be searched for)

Computer(s) and related storage media, the following forms containing the name of John Celmer or Richard Sartain: Final Exit Network intake interview forms, Final Exit Network First Responder’s Checklist, documentation of First Responder’s evaluation of member, letter written by member giving their reason for a hastened death, Final Exit Network Request for Exit Guide Support Form, Final Exit Network My Instruction on Changing or Not Changing the Appearance of My Body and Bedside which may also read My Wishes Regarding the Appearance of my Body form, Final Exit Network Statement of My Decision Following Medical Consultation which may also read My Decision Following Medical Consultation form, Final Exit Event Log, Final Exit Network Expense and Reimbursement form, Final Exit Network Donation of Expense form, Statement of Mutual Understanding between Final Exit Network and Exit Guides Form, Final Exit Network questionnaire or application completed by the exit guide, John Celmer’s suicide note and all documentation of meeting(s) and conversation(s) with John D. Celmer, Final Exit Network instructor and training manuals to include notes and any paperwork described above related to other victims of assisted suicide, tampering with evidence and racketeer influenced and corrupt organization laws.

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Which is (name the law being violated)

Racketeer Influenced and Corrupt Organizations O.C.G.A. § 16-14-1 through O.C.G.A. § 16-14-15; Assisting Suicide O.C.G.A. § 16-5-5; Tampering with Evidence O.C.G.A. § 16-10-94

Based upon the affidavit given under oath or affirmation and all other evidence given to me under oath or affirmation, I am satisfied that there is probable cause to believe that a crime is being committed or has been committed and that the property described above is presently located on the person, premises, or property described above. You are hereby commanded to enter, search, and seize within ten (10) days of this date, the person, premises, or property described above. A copy of this Warrant is to be left with the person searched, or if no person is available, on the premises or vehicle searched, and a written return, including an inventory of any things seized, shall be made before me or a Court of competent jurisdiction without unnecessary delay after the execution of this Search Warrant. SO ORDERED this _____ day of ___________________, 20___, at ______ (AM)(PM)

__________________________________ Judge of the Superior Court

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==================================================================

RETURN OF SERVICE _____________________________________________________________________ [ ] This Search Warrant was not executed and is returned to the judicial officer who issued it. [ ] I executed this Search Warrant on the ____ day of ____________________, 20___, at ______(AM)(PM) and searched the person, premises, or property described in the warrant. A copy of this warrant: [ ] Was left with _________________________________________________ [ ] Was left in the following conspicuous place: _________________________ _________________ because no one was available to be given the warrant Attached hereto is an inventory consisting of _____ pages, of the instruments, articles, or things which were seized pursuant to this Search Warrant. This inventory was made in the presence of ____________________________ and I swear (affirm) that this inventory is a true and detailed account of all instruments, articles, or things seized pursuant to this Search Warrant.

__________________________________ Affiant Sworn and subscribed to before me this ____ day of _____________ 20___ _________________________________ Judge of Superior Court