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|STATE OF INDIANA
COUNTY OF BROWN
|IN THE BROWN CIRCUIT COURT
CAUSE NO. 07COl-9308-CF-260
STATE OF INDIANA
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.
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.