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STATE OF INDIANA COUNTY OF BROWN	IN THE BROWN CIRCUIT COURT CAUSE NO. 07COl-9308-CF-260
STATE OF INDIANA VS HULDA CLARK
PROBABLE CAUSE AFFIDAVIT Filed August 16, 1993 I, Amy M. Huffman, being duly sworn upon my oath, depose and say: 1. I am an adult and competent to make this affidavit based upon personal knowledge, and at all time relevant to this affidavit, I was acting in my professional capacity as an Indiana Deputy Attorney General. 2. On May 11, 1993, at approximately 1:00 p.m., Karl Milhon, an investigator for the Indiana Department of Health, Acquired Diseases Division, and I entered the premises of Hulda Clark, Ph.D., Coffey Lane, Nashville, IN 47448. 3. We visited Dr. Clark's office undercover. Karl posed as a bi-sexual male who recently learned that a former partner had tested positive for the HIV virus. I posed as his supportive friend who lives in Nashville. 4. Dr. Clark practices at her house on Coffey Lane, just outside of the town of Nashville. 5. Karl was asked to read and fill out two forms before seeing the doctor. One form asked for symptoms and general medical condition. The other stated that Dr. Clark used vitamins, minerals and herbs to change amino acids in the body and that she practices orthomolecular nutritional therapy. it also clearly stated that her analysis is based upon blood tests. This sheet stated she is not a medical doctor and had to be signed and dated by all patients. 6. Upon entering the patient room, I observed a large flat box holding small brown bottles with labels and number of small black switches on the desk. Next to it was a box with a white scale with numbers from one to one hundred, similar to ones I have seen to test the strength of batteries. The top of this box looked similar to a scale, and had two platforms. The box said "Vi-Tel 618" in big orange letters on the front side. A gold "wand" was attached to this machine by a black wire on the right side. Clamped to this black wire, near its base, was a teethed clip (a smaller version of one used to recharge car batteries) with a thin, red, curly wire. On the end of the red wire was what looked like a red ink pen with a silver metal tip about the size and pointedness of a ball-point pen. Under the desk, I observed a car battery that was not disguised and appeared to be attached to the machine. Also on the desk was a small clear bowl with wet, white gauze. Karl smelled the contents and said the liquid had no smell and appeared to him to be water. 7. The following are statements made by Hulda Clark to us during our appointment concerning her treatment of HIV positive patients. During this appointment, she tested Karl for cancer and the HIV virus an the machine described above. She told him he had the HIV virus, but said that he did not have cancer. 8. These quotes were recorded on 4 small cassette tape player worn under my clothing and were transcribed by me. "HC" refers to Hulda Clark, "KM" refers to Karl Milhon; and "AH" refers to Amy Huffman. 9. HC: "We treat AIDS patients here everyday." 10. HC: "I can test you here. It's a one minute test and its all electronic." 11. HC: "We'll have you cleared up, (from the HIV virus) in less than two weeks and I don't know of anybody else who can do that. And I can guarantee it, in f act. A money back guarantee, if you want." KM: "You mean you can cure it?" HC: "Yes, I can kill the virus in three minutes. No one else knows how to do it and I am trying to publish it in two months." 12. HC: "I have treated about 70 patients and haven't had a single failure, There's no way it can fail if you know how to kill it. it's not like some others . . . it's not like arthritis or migraines or something like that. It's just a simple thing. And, there's a lot of complexity to not getting it back again. It isn't just what you think, that you can get the virus from somebody. It's not like that. You can pick it up, but it's not like that." 13. HC: "This (HIV test) isn't, you know, something that's legally acceptable, because it's in a new territory." 14. HC: "It's a measuring device (referring to the machine described in paragraph 6) and it will tell us how much, if any, of that virus you have." 15. HC: "Of course, everybody who is found positive is required, if it's through the health department, is required to notify you or something like that. our lab is not. We do what's called an antigen test to test for the presence of the virus and we get the results here and we give them to you when you come back." 16. HC: "The lab test won't pick up on this unless there's a lot of it. Of course my device picks up a molecule." 17. HC: (The gold, wand is covered in a piece of wet gauze and held in Karl's right hand. She places a few drops of water on the side of Karl's left middle finger and touches it with the tip of the red pen. The machine makes a laud screeching noise and the arm of the mater jumps to one hundred.) "You're full of the virus. (inaudible -- she performs the test several more times) And we will cure it in three minutes." 18. HC: "But you will also get it back so you need to commit yourself to coming here six times. I'll see you once a week or once every five days, but you're not sick enough to see that often. . . I'm going to kill the virus this afternoon while you (inaudible) ... right here in the office, before you leave the office and it'll be gone." 19. HC: (She flips several switches on the machine and indicates she is testing the HIV levels in different organs in the body.) "Here's your thymus. (Uses machine.) Little bit in your thymus. (inaudible) (Uses machine) That's your liver." 20. HC: I'm going to check you for cancer. This is what I do for each person as they come in because it's so common now even though they have not had any risk factors That's not even where it comes from. That's how it's transmitted but not . . . (inaudible). AH: The virus? HC: (Uses machine) That's negative. (uses machine) Negative. HCG, that's a pre-cancer type." 21. As we left Dr. Clark's office, her receptionist gave Karl a prescription to the Medical Laboratory, in Indianapolis, which ordered an HIV/Antigen blood test, with Hulda Clark, Ph.D., as the prescribing physician. 22. Karl drove to Indianapolis to have the blood test and when he returned to Nashville at approximately 4:00 p.m., we returned to Dr. Clark's office as she had requested. 23. As we approached Dr. Clark's office, the receptionist with long brown hair told us that three patients on the premises were HIV positive. one of them, Tim Lee, walked outside and spoke with us about the treatment he had received for the HIV virus from Dr. Clark. 24. When Dr. Clark was ready to see us we returned to the same examining room and she began testing Karl again for cancer and RCG. At this point, the receptionist called Dr. Clark to the phone for an "urgent" call of which we overheard her conversation. 25. She was being questioned by someone about her practice and stated she would need to speak with her attorney. 26. Dr. Clark then went into her home for a few minutes and when she returned she asked whether we were from the State Board of Health. 27. Karl stated that he was with the Board of Health and that she should speak with her attorney. She said she already had. 28. She then asked Karl what he was going to do about his positive test for HIV. She said he would need to see a doctor because although he was wall now, he would soon be sick. She gave him detailed advice on avoiding foods containing benzine. 29. Dr. Clark told us that AIDS is prevalent in the gay community because benzine is present in the "Rush" and "Pot" commonly used. She said AIDS is not a sexual disease but can be transmitted that way. 30. She also stated that everything she told us earlier (in our first appointment) was a "mistake." 31. I asked her whether she was diagnosing and treating patients. She said no, she was identifying substances in the body and eliminating them. 32. Karl gave Dr. Clark his supervisor's name and phone number and we left. Further the affiant sayeth naught. Amy M. Huffman Deputy Attorney General May 25, 1993