Six Months After Election, Judge Affirms Green as Salem Mayor

After a two-day trial in April, over six months of litigation, and five days of deliberation, Washington Circuit Judge Larry Medlock ruled today in regards to The Matter of the Election of the Mayor of Salem and found that Justin Green, who won the popular vote in the Nov. 5, 2019 General Election and was sworn into office in December, is the Mayor of Salem. 

Green’s Democratic challenger in the November election was beaten 930 to 358 votes, a margin of 572 votes. 

Ackerman filed the suit to challenge the election on November 18, thirteen days after he lost the election. 

In his order, Judge Medlock wrote, “The Court concludes that [William] Ackerman has not met his burden to prove by clear and convincing evidence that Green was not eligible to run for Mayor of the City of Salem because he was not resident of the City of Salem for one (1) year prior to the election to be resident of the City of Salem.”

Judge Medlock notes that Ackerman did not meet his burden of proof to show that Green was not a resident of the City of Salem for a period of one year prior to the November General Election and that Ackerman failed to assert his allegations prior to the November election as mandated by the Indiana Supreme Court
in White v. Indiana Democratic Party (963 NE2d 481 (In. 2012))

Ackerman, the Democratic party, and Ron Haendiges, who ran against Green in the 2019 Primary, all questioned Green’s eligibility to run for election but none of them acted before any of the elections. 

“Once again, it is important to note the Circuit Court Clerk was contacted by both Democrats and Republicans, both before the Primary Election and before the General Election, with questions about the process for challenging residency,” wrote Judge Medlock. “Moreover, Clerk Rockey affirmed that each party was given the correct information about how to challenge the issue before each election. The record is clear, Ackerman did not challenge Green’s residency until after he lost the General Election.”

Judge Medlock also pointed out that Ackerman’s Democratic Party and Green’s Republican Opponents (Haendiges) could have challenged Green’s residency prior to the primary and then Ackerman or the Democratic Party before the general election.

However, as Judge Medlock states, (in all caps for emphasis) “NO ONE CHALLENGED GREEN’S RESIDENCY, PRIOR TO ANY POLLING.”

Despite all the evidence that Ackermand and attorney Doug Leatherbury presented, Judge Medlock outlined 31 points that the case didn’t meet the Burden of Proof. 

They are: 

1. Salem is Class Three City. The eligibility requirement for serving as mayor of Salem is set out by Indiana Code. The eligibility statute sets forth:
   IC 3-8-1-26 Mayor of second or third class city Sec. 26. candidate for the office of mayor of the second or third class city must have resided in the city for at least one (1) year before the election. [Pre-1986 Recodification Citation: 36-4-5-2(b).] As added by P.L.5-1986, SEC.4.
2.  It is Ackerman’s burden to prove that Green was not a resident of Salem from the period beginning November 5, 2018, and the period ending November 5, 2019.
3. The challenger’s evidence must meet the “clear and convincing” burden of proof standard.
4. The question of residence for the purposes of determining whether an individual is eligible to run for office and/or serve in office has been litigated in Indiana for over one
   hundred years.
   5. The seminal case on residency is State Election Board V. Bayh, 521 N.E.2d 13 (IN.1988). In Bayh, the Republican Party (prior to Election Day) claimed that Evan Bayh had
   not been resident of the State of Indiana for five (5) years prior to running for Governor.
   a. The evidence presented at trial indicated that Bayh had been born in Indiana but that he had lived in Washington, D.C. with his family while his father was a member of the United States’ Senate. When Bayh turned eighteen (18), he
   registered to vote in Vigo County, Indiana, and he voted in every primary election and every general election since he became a qualified voter.
   b. Bayh enrolled at Indiana University in Bloomington, Indiana, in 1974. Upon graduation in 1978, he was accepted to the University of Virginia Law School. He was a law clerk for Washington, D.C. law firm during his law school career.
   In 1982, Bayh took and passed the District of Columbia bar examination. From March 1982 until March 1983, Bayh clerked for the federal judge in the Southern District of Indiana.
   c. In 1983, Bayh took the Indiana Bar Examination and passed. Following his successful completion of Indiana Bar Examination, Bayh went to work for Washington, D.C. law firm, and leased an apartment in the District of Columbia
   for one year. The move was always meant to be temporary. One month after arriving in D.C., Bayh returned to Indiana to be sworn in and signed an affidavit of intent to return to practice law in Indiana within two years.
   d. Despite living and working in D.C., Bayh evidenced his intent to return to Indiana during his sixteen months working for the D.C. law firm. For instance, he returned to Indiana multiple times to attend political conventions; he subscribed to
   the Indianapolis Star; he sent Christmas cards to Indiana Democratic party officials, and he paid his Indiana State Bar Association dues.
   e. On December 1, 1984, Bayh returned to Indiana to work for his father’s law firm, and he remained in Indiana from that point forward.
   f. The Petitioners argued that Bayh had not been a resident of Indiana for five years prior to the election of 1988. Bayh argued that despite having “lived” in Washington, D.C.; Bloomington, Indiana; Charlottesville, Virginia, and back in Washington, D.C. before returning to Indiana, he was always resident of Indiana. The Indiana Supreme Court agreed with Bayh’s position.
   6. In reviewing the issue of domicile and residency, the Court concluded that: Domicile means “the place where a person has his true, fixed, permanent home and principal establishment, and to which place he has, whenever he is absent, the
   intention of returning.” Domicile can be established in one of three ways: “domicile of origin or birth, domicile by choice, and domicile by operation of law.” Id. 13 l7
   7. Our Supreme Court further stated that:
   “Once acquired, domicile is presumed to continue because “every man has residence somewhere, and he does not lose the one until he has gained one in another place. Establishing new residence or domicile terminates the former domicile. Change of domicile requires an actual moving with an intent to go to a given place and remain there. “It must be an intention coupled With acts evidencing that intention to make the new domicile home in fact… [T]here must be the intention to abandon the old domicile; the intention to acquire new one; and residence in the new place in order to accomplish a change of domicile.” Id. 13
5. Even though Bayh had been living, attending school, and working in Washington D.C., Bayh also intended to return to Indiana. The Courts record was replete with acts and
   statements of intent that supported the Court’s conclusion that Bayh was always a resident of Indiana.
6. Although the statutes governing mayoral and gubernatorial candidates differ on the length of residency, the Indiana Supreme Court’s interpretation of residency is equally
   applicable to and binding on both positions.
7. In reviewing evidence related to temporary absences, the Indiana Supreme Court stated
   that: “A person who leaves his place of residence temporarily, but with the intention of returning, has not lost his original residence. Yonkey v. State (1866), 27 Ind. 236. We have said:
   Where an old resident and inhabitant, having his domicile from his birth in a particular place, goes to another place or country, the great question whether he has changed his domicile will depend mainly upon the question, to be determined from all the circumstances, whether the new residence is temporary or permanent… If the departure from one‘s fixed and settled abode is for purpose in its nature temporary, whether it be business or pleasure, accompanied by the intent of returning as soon as such purpose is accomplished; in general, such
   the person continues to be an inhabitant for all purposes of enjoying civil and political privileges, and of being subject to civil duties.” Bayh, at 1317.
8. Ackerman has argued that the Sales Disclosure Form evidenced an intent to reside at SR56; however, the uncontroverted testimony at trial from the Deputy Auditor
   demonstrates that, after Green had relinquished control of the document to the County Auditor’s Office, she made a decision inconsistent with the language of the document. Her decision will not be used as a basis to determine the intent of Green.
9. In Bayh, the Court appeared to conclude that even extended absences would not be sufficient, standing alone, to alter an individual’s residence. For instance, Bayh lived in D.C. in an apartment while working for D.C. law firm for a period of sixteen (16) months, and yet, the Supreme Court agreed that during that period, he always resided in Indiana.
10. Witnesses testified regarding trash pick-up, delivery 0f mail, and their observations of Green’s presence at the Tucker street address. Their testimony must be considered in
    light of all the other evidence introduced at trial.
11. Green was absent from the city and staying at 2900 Old State Road 56 while he renovated the uninhabitable residence on Tucker Avenue. Based on comparable facts in Bayh, Ackerman has failed to prove that the Mayor’s temporary absence altered his intent to maintain residency in the City. From the totality of the facts and evidence in the records, the Court cannot say that Salem was,
    “. .. not the place where Green had his true, fixed, permanent home and principal establishment, and to which place he has, whenever absent, the intention of returning.”
12. Green’s intent was to either establish his permanent residence at 509 Tucker Street or to convey the appearance that he was residing at said address.
13. The evidence before the court does not clearly show that Green’s residence was outside of the City of Salem. He did not change his voter registration. He did not change his driver’s
    license. He did not change his insurance license or file his income tax returns from that address.
14. Despite any conflicting evidence that may have been presented, the Court cannot conclusively find by clear and convincing evidence that Green’s residence for the one (1) year period preceding the November 2019 Salem City election was not the city of Salem.
15. In addition to the issue of residency, this court is obligated to address the questions raised in defense of the election contest petition.
16. In support of this argument, the Respondent would cite to the Indiana Supreme Court, in White V. Indiana Democratic Party, 963 N.E.2d 481 (IN. 2012), stating that:
    The Indiana Constitution guarantees that “[a]ll elections shall be free and equal.” Ind. Const. art. 2, 1. Consistent with this guarantee, this Court has always been wary of overturning the will of the voters who have freely and willingly cast their ballots. See, e.g., Burke v. Bennett, 907 N.E.2d 529 (Ind.2009) (“This application of the Indiana disqualification statute is consistent with the longstanding respect for the right of the people to free and equal elections and
    the reluctance of this Court t0 remove from office person duly elected by the
    voters.”).
    The Indiana Supreme Court has also held that:
    6‘ 6′ We liberally construe the statutes governing post-election contests 1n order that the will 0f the people in the choice of public officers may not be defeated by any merely formal or technical objections.’ Pabey v. Pastrick, 816 N.E.2d 1138, 1148 (Ind.2004) (quoting Tombaugh v. Grogg, 146 Ind. 99, 103, 44 N.E. 994, 995 (1 896)).
17. It has further stated that: “Even where facts are alleged that might if later proven to render the candidate ineligible, “[t]he existence of the fact which disqualifies, and of the law which makes that fact operate to disqualify, must be brought home so closely and so clearly to the knowledge or notice of the elector, as that to give his vote therewith indicates an intent to waste it.” Oviatt v. Behme, 238 Ind. 69, 74, 147 N.E.2d 897, 900 (1958) (quoting People ex rel. Furman v. Clute, 50 N.Y. 451 (1872)). Those voters who are lawfully qualified to participate in our democratic process “may
    not be disenfranchised except by their own willful or deliberate act t0 the extent that one who did not receive the highest vote cast may still be declared elected.” Id. at 74—75, 147 N.E.2d at 900.”
18. And finally, the Indiana Supreme has succinctly concluded that: “Our conclusion is that the Code places a burden on political campaigns to investigate and vet their opposition before the pre-election time limitations expire, but that is better than the alternative: that challenger might ignore known (or knowable) disqualification challenge before the election, wait to see who won at the polls and then seek to set aside the results of the democratic process. Such a result is inconsistent with free elections and respect for voters‘ expressed preferences.” White, at. 490.
19. Ackerman, the Democratic Party, and even Green’s Republican Primary opponents (Haendiges) were suspicious of his residency.
20. Ackerman admitted that he confronted the Democratic Party Chair with questions regarding the issue of residency.
21. Once again, it is important to note the Circuit Court Clerk was contacted by both Democrats and Republicans (Haendiges), both before the Primary Election and before the General Election, with questions about the process for challenging residency. Moreover, Clerk Rockey affirmed that each party was given the correct information about how to challenge the issue before each election. The record is clear, Ackerman did not challenge Green’s residency until after he lost the General Election.
22. Ackerman’s Democratic Party and Green’s Republican Opponents could have challenged Green’s residency prior to the primary and then Ackerman or the Democratic Party before the general election.
23. NO ONE CHALLENGED GREEN’S RESIDENCY, PRIOR TO ANY POLLING.
24. Even if the Court had found the elected Mayor to be ineligible, the Court should not set aside the election results based on Indiana Law as stated White v. Indiana Democratic Party 963 NE2d 481 (IN 2012).
25. The Court concludes that Ackerman has not met his burden to prove by clear and convincing evidence that Green was not eligible to run for Mayor of the City of Salem
    because he was not resident of the City of Salem for one (1) year prior to the election to be resident of the City of Salem.
26. The case of Kite vs. Curlin, 139 NE3d 1113 (Ind. Ct. App. 2020), was decided 0n 30 December 2019. The transfer was denied on 23 April 2020, the case was cited by Ackerman
    as controlling law. The Court finds the case to be informative and instructive but not controlling. The fact pattern is different from the case filed by Ackerman.
27. Ackerman’s claim fails for all the reasons provided above.

Facts we learned in the case were: 

1. Justin Todd Green (hereinafter “Green”) was born on January l9, 1977 in Salem, Indiana.
   2. He lived with his parents on the family farm at 2879 North Trueblood Road from his birth until he graduated from high school. He registered to vote for the first time on
   October 16, 1995, at his family home.
   3. Green graduated from Salem High School in 1995. He graduated from Vincennes University in 1997 and returned to Salem.
   4. Green got his first job and was living at 13 Walnut Tree Apartments in the City limits of Salem. He changed his voter registration from the family farm to his new apartment.
   5. In 1999, he moved to 115 Nichols Avenue. Nichols Avenue is located in the City of Salem and Green changed his voter registration to reflect his new residence. He was
   living in Salem and was selling cars for Dixon Auto Sales.
   6. In 2003, Green bought home at 106 Macon Avenue. This home is also located in the City of Salem. Green changed his voter’s registration to reflect his new address at the Washington County Clerk’s office.
   7. In 1999, Green secured a license to sell Life, Accident Health, Property and Casualty Insurance from the Indiana Department of Insurance. His State License Number is 2963000. The license was issued reflecting that his address on February 12, 1999, was 106 Macon Ave., Salem, Indiana. The expiration date on the license was January 1, 2007.
2. Green founded Green Auto Sales in the City of Salem in 2007.
3. In addition to starting Green Auto Sales, a new business in 2007, Green became a political candidate and ran for Salem City Council.
4. Green ran Green Auto Sales and served on the Salem City Council from January 2008 until 2019.
5. In 2012, a house and sixty-six acres became available for sale at 2900 North Old State Road 56 (hereinafter “SR 56”).
6. The SR56 property was bought on October 20, 2012 by Green.
7. The sellers were Roger Baird, Sr. and his wife Polly. Sales Disclosure Statement was filed with the Washington County government offices. Green did not fill out the form; however, he did sign the document under the “penalties of perjury”.
8. The document identifies Justin Green, 106 Macon Ave., Salem, Indiana as the buyer. It notes his telephone number is (812) 883-7134.
9. The SALES DISCLOSURE FORM includes language which states: THE SALES DISCLOSURE FORM MAY BE USED TO APPLY FOR CERTAIN DEDUCTIONS FOR THIS PROPERTY, IDENTIFY ALL OF THOSE THAT.”
10. In this portion of the document, there appears this question and instruction: “Will this property be the buyer’s primary residence? Provide a complete address of the primary
    residence, including county” In this section Green identified his “primary residence” as 106 Macon Ave, Salem, Indiana.
11. Green did not personally fill out this document. However, he did provide the information that was used. He informed the preparer that his primary residence was 106 Macon Avenue and that he did not want the government to vacate the homestead exemption for his primary residence.
12. Green secured a mortgage on the SR56 property through Mid-Southern Bank. The mortgage payment covering principal and interest. Green’s bank provided him with a payment book. The address on the payment book in 2012 was 106 Macon Ave. The address on his payment book on the date of the trial was 509 Tucker Street.
13. The First Deputy of the Washington County Auditor’s (hereinafter “Deputy Auditor”) office testified at trial. She testified that she was the individual that took the steps to assign homestead exemption on Green’s property located at SR56.
14. The Deputy Auditor testified that she did an investigation to determine where the homestead exemption should be assigned. She did not have a duty to attempt to determine if homestead exemption should be credited to the SR56 property. She did not contact Green and ask him if it was his desire to have a homestead exemption on SR56.
15. The Deputy Auditor acknowledged that the document signed by Green indicated that his primary residence was 106 Macon Avenue, Salem, Indiana and that he was not
    requesting that homestead exemption be removed from his primary residence.
16. Green sold the Macon Avenue house on June 3, 2016 and purchased the 509 Tucker Street property on June 13, 2016.
17. Christie Grider, Respondent’s current girlfriend of 17 years testified that she and Green moved together to 2900 Old State Road 56, Salem, IN 47167 in 2016. The Tucker
    Street house needed renovation to be habitable. Later, Justin Green moved from their home to reside by himself at 509 Tucker Street, Salem, IN 47167. Christie Grider was
    unable to provide a date for the move. Respondent testified that in 2016 the property was uninhabitable. In 2016 the Tucker Street was assessed as a pole barn for $600.00 and was not reassessed as residential property until 2019.
18. Green secured a “Building Permit” to begin the renovations on the Tucker Street property on September 21, 2016. The Tucker Street home was inspected on July 17, 201 7. It was
    considered habitable; however, it did not have kitchen appliances or carpeting. It was not fully furnished at that time.
19. Green acknowledged that he visited the Auditor’s Office about five times in 2019 in the process of changing the homestead from 2900 Old State Road 56, Salem, IN 47167 t0 509 Tucker Street, Salem, IN 47167.
20. Greg Ball, Washington County Assessor, testified that the last assessment at 509 Tucker Street, was June, 2019, at which time the property was changed from “other structure” with an assessed value 0f $900.00 to “Residential”.
21. Bill Barnett, Petitioner’s witness from Knapp, Miller, Brown Agency was told by Green that his residence was in the City of Salem.
22. Sabrina Burdine, Executive Director of the Washington County Economic Development Commission has an office in City Hall and works closely with the Mayor on a variety of economic issues. Ms. Burdine testified that she had no knowledge of the 509 Tucker Street property and conducted her correspondence with Respondent at his Business
    address, 501 South Main Street, Salem, IN 47167.
23. Green moved from Macon Avenue t0 SR 56 and then to Tucker Street and contacted the Indiana Department of Insurance to notify them of the need to change his residence on his Insurance License to Tucker Street.
24. Randall Bills, whose address is on the newly built State Road 56, has an address similar to the [Green’s]. Randall Bill’s address is 2900 State Road 56, Salem, IN 47167. As
    a result, he occasionally receives utility bills intended for [Green] at 2900 Old State Road 56. When this has happened, Mr. Bills would return the mail to the post office. [He also admitted in court that he had opened some mail before returning it to the post office]
25. Necole Caldwell, resides at 601 Tucker Street, Salem, IN. She has lived there for eight years. This address is adjacent to 509 Tucker Street, Salem, IN. 47167. Necole Caldwell
    observed construction work being done at the property two years ago. She periodically saw Respondent pull in long enough to check mail, but had never seen trash cans out on
    pickup day. Her children, at times, leave their toys in Respondent’s driveway and they remain undisturbed. She does not know Christie Grider, [Green’s] girlfriend, and
    has never seen females at the property.
26. Todd Smith, who resides at 501 Tucker Street, Salem, IN 47167 owns his own home and has lived there since 1999. Todd Smith has never seen females at 509 Tucker Street, Salem, IN 47167 and has seen neighborhood children playing in the driveway. The first time Todd Smith saw a trash can put out was April of 2020 and he postulates the Respondent did not reside at 509 Tucker Street, Salem, IN 47167 until January 2020.
27. William Ackerman (hereafter Ackerman) entered evidence 0f water usage at both addresses for the two years prior t0 the election. During the two years prior to the election, [Green] was billed only the minimum monthly bills 0f $10.28 for the first two months and the minimum monthly billings for the remaining twenty-two months in the amount of $12.30 each at 509 Tucker Street, Salem, IN 47167. However, at 2900 Old
    State Road 56, Salem, IN 47167 monthly billings indicate thousands of gallons of water used each month.
28. At some point, Green changed his residence from 2900 N. Old State Road 56, Salem, IN 47167 to 509 Tucker Street, Salem, IN 47167, and submitted copies of his driver’s license and other cards with the address of 509 Tucker Street, Salem, IN 47167 printed
    thereon.
29. Green notified the Washington County Circuit Court Clerk of his address change for voter registration purposes on September 7, 2016 to 509 Tucker Street, Salem, Indiana.
30. Green renewed his driver’s license to reflect his change of address from Macon Avenue to Tucker Street in 2016.
31. Green pays all of the utility bills for the SR56 property. Jackson County REMC sends the SR56 billing statement to Green at this house 0n Tucker Street.
32. East Washington Rural Water sends the bill for the water usage at SR56 to Green at his house on Tucker Street.
33. The Washington County tax records reflect that the property at SR56 is owned by Green. The tax card states that Green, the owner, lives at 509 Tucker Street, Salem, Indiana.
34. Green called limited witnesses to confirm that he actually resided at 509 Tucker Street, Salem, IN 47167, at any time, including from November 5, 201 thru November 5, 2019.
35. On January 15, 2019, Green filed Candidate Organization Form (CAN-l) declaring his
    intent to run for Mayor of Salem. The CAN-l listed his residence as the house on Tucker Street.
36. He was opposed in the Republican Primary by Ron Haendiges, Robert “Bobby” Fletcher, and Christie Luckett.
37. There were members of both the Democrat and Republican Party who questioned Green’s residency prior to the 2019 Primary Election.
38. The Washington County Circuit Court Clerk, Stephanie Rockey was contacted by members of both the Republican and Democrat parties regarding allegations involving Green’s residency. She stated that she advised members of both parties that they were still within the time frame for challenging Green’s residency. She informed them that they could file a formal complaint with the County Election Board or the Indiana Election Division. No one challenged Green’s residency by filing challenge before the May
    Primary.
39. Haendiges, the Republican Candidate for Mayor, heard rumors that [Green] did not reside in Salem and was ineligible to be Salem Candidate. Haendiges made a personal investigation at the Washington County Auditor’s Office, obtained copies of the Homestead Exemption, and assessments of both the old 56 and Tucker Street properties and brought his findings to Tara Hunt, the Washington County Republican Chair, who did not take any action on behalf of the Republican Party or the City of Salem Voters.
40. Ackerman, the Democratic Candidate, conferred with various individuals who led him to conclude that Green did not reside in Salem, one year prior to the election.
41. Rockey informed the complaining parties that, after the time frame for challenging the residency had passed, they could file a civil lawsuit in the Washington Circuit Court.
42. The Democratic Party Chair (Darlene Briscoe) raised the issue of Green’s residency throughout the campaign as did the Democrat candidate.
43. Ackerman testified that he knew of the allegations that Green was not a resident of the City of Salem after he was nominated in the May Primary. He went to the Democratic Party Chair (Briscoe) and asked what steps he could
    take to challenge the residency issue. He was informed that he needed to tend to his campaign. Ackerman did not contest Green’s residency with the Washington County Circuit Court Clerk or the Indiana Election Division, nor did he file any civil action in the Washington Circuit Court prior to the November 2019 General Election.
44. The local press reported on these allegations before the general election.
45. The allegations were made on various social media sites.
46. The Democratic Party Chair (Briscoe) held press conferences to publicize the allegations before the General Election.
47. The local radio station (WSLM) toured Green’s Tucker Street home on September l6, 2019, and broadcast the video on Facebook.
48. The General Election was held November 5, 2019 and Green received 72% of the votes over 2.5 times the votes Ackerman received, despite the media and other candidates
    scrutiny of Green’s claimed residence or domicile.
49. Ackerman filed this election challenge within the appropriate time frame claiming that Green is “ineligible” to hold the office of Mayor.
50. The challenger, Ackerman asserts that Green was not a resident of Salem.

The following documents were entered into evidence:

• Justin Green’s Voter Registration Records: All voter registration records of Justin Green obtained from the Washington County, Indiana Clerk’s office;
• Jackson County REMC Bills for 2900 North Old State Road 56: Bills are for service provided at Old State Road 56. Billing statement was mailed to 106 Macon on 12/3 1/15 and 509 Tucker on 12/31/17;
• Tax Card 509 East Tucker: Tax Card from 6/13/16 for Tucker Street. Billing statement
  sent to 509 Tucker Street t0 Justin Green;
• Tax Card 2900 N. Old State Rd. 56: Tax bill sent to 509 Tucker Street Justin Green’s Life, Accident, Property and Casualty Insurance License: Issued 2/12/99 Expiration 1/31/17. Address: 106 Macon Ave., Salem, In.
• Justin Green’s Request for Change of Address Insurance License: Service Request to change address from 106 Macon Ave. to 509 Tucker St. submitted 11/21/16;
• Justin Green’s Gun Permit: Gun permit issued 12/31/14 to Justin Green; Address 106 Macon Ave., Salem, Indiana;
• Copies of Justin Green’s Indiana Operator’s License: License issued 1/13/12 address 106 Macon Ave., Salem; Reissued 9/2/16 address 509 Tucker St., Salem;
• Mortgage Audit Confirmation from Mid—Southern Bank— November 30, 2018; Notice of audit of the mortgage. Mortgage owed on Old State Road property. Notice sent to 509 Tucker Street address.
• Anthem BlueCross BlueShield Health Care Summary- December 2, 2017; Summary mailed to 509 Tucker Street;
• Certificate Off-Road Vehicle/Snowmobile Registration 7/12/16- Registration for Snowmobile 106 Macon then transferred to 509 Tucker;
• Mid-Southern Savings Bank Financial Summary- Mailed to 509 Tucker Street
• Hartford Funds Financial Summary- Mailed t0 509 Tucker Street on 9/30/17;
• Jackson County REMC Billing Statement— Bills for service at 2900 Old State Road 56, Salem, Indiana and mailed to Justin Green at 509 Tucker Street;
• Justin Green’s Federal and State Tax Returns: Justin Green’s Federal and State Tax
• Returns from 2012 until Present
• Green’s Verizon Cell Phone Billing Statements; Mailed t0 509 Tucker Street, Salem,
  Indiana;