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IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT
IN AND FOR ST. JOHNS COUNTY, FLORIDA
| |
STATE OF FLORIDA, CASE NO.:
FDLE Case #: EI-32-0288 |
Vv. i
, BRIANA MAUREEN JORDAN |
| JAMIE LYNN JOHNSON
CHRISTIAN GERARD WHITEHURST
: SARAH SALLEY ARNOLD |
DYLAN ANDREW RUMRELL,
Defendants. |
ee |
| SWORN AFFIDAVIT |
| COUNT 1: TAMPERING WITH PHYSICAL EVIDENCE |
FLA. STAT, §918.13(2)(A) |
THIRD DEGREE FELONY
COUNT 2: UNAUTHORIZED VOTER GUIDES - |
FLA, STAT. §106,1436 |
FIRST DEGREE MISDEMEANOR |
COUNT 3: CRIMINAL CONSPRIACY |
| FLA. STAT. §777.04
| SECOND DEGREE MISDEMEANOR |
COMES NOW, Your Affiant, Special Agent Supervisor Adam Graff of the Florida Department |
| of Law Enforcement, who, being duly sworn makes the following statements under oath: |
BACKGROUND
Your Affiant, Special Agent Supervisor (SAS) Adam Graff, has been a sworn law enforcement |
officer for over 25 years and has received training for and/or conducted investigations related to |
election crimes, public corruption, burglary, narcotics, vice activities, property crimes, financial |
crimes, fraud, fencing operations, money laundering, racketeering violations, and violent crimes. |
Page 1 of 13 :
Filed 07/06/2026 03:37 PM with the Clerk of the Circuit Court, St. Johns County, Florida, DIN: 6Your Affiant is currently employed as a Special Agent Supervisor with the Florida Department
| of Law Enforcement and is currently assigned to the Election Crimes Unit of the Office of |
Executive Investigations. |
Your Affiant is empowered to conduct investigations of violations of the criminal laws of the |
State of Florida, including those enumerated in Chapters 106, pertaining to violation of election }
laws. Your Affiant believes that the laws of the State of Florida have been violated, specifically |
those laws enumerated in Florida Statutes Section 918.13(2)(a), Tampering With Physical |
Evidence, Florida Statutes Section 106.1436, Unauthorized Voter Guides, and Florida Statutes |
Section 777.04, Conspiracy.
In investigating this case, Your Affiant has participated in this investigation and/or has |
personally interviewed those whose information is set forth herein, and/or has reviewed reports !
of interviews or other investigative information prepared by others appearing in this affidavit. |
As a result of Your Affiant’s participation in this investigation and/or reports, oral and written, |
given by other law enforcement officers, and Your Affiant’s review of relevant records, Your |
Affiant is familiar with the circumstances of the offenses described in this affidavit.
Your Affiant has probable cause to believe and does believe that the laws of the State of Florida |
relative to: Tampering with Physical Evidence, Section 817.568(2)(a), Florida Statutes, Third |
Degree Felony, Unauthorized Voter Guides Section 106.1436, Florida Statutes, First Degree |
Misdemeanor, and Criminal Conspiracy, Section 774.04, Florida Statutes, Second Degree |
Misdemeanor have been violated by the above-named suspects. Your Affiant's reasons for so |
believing are as follows:
STATEMENT OF PROBABLE CAUSE |
Investigation revealed that between August 1, 2024 and August 15 2024, Brianna Jordan |
coordinated and conspired with Jamie Johnson, Christian Whitehurst, Sarah Arnold, Dylan |
Rumrell, and others create fraudulent voter guides using the name, logo, and likeness of the St.
Johns County Republican Executive Committee (SJREC) without permission, The fraudulent |
guides portrayed candidates for the 2024 Republican primary as being endorsed by the SJREC, |
Page 2 of 13when they were not actually endorsed. At a campaign house, located at 1351 Grant St, St. |
Augustine, FL, the aforementioned defendants placed the fraudulent voter guides into envelopes, !
without return addresses, and sent them to thousands of registered republican “super voters” in |
St. Johns County, FL. Upon learning that the fraudulent voter guides had been reported to law |
enforcement for investigation, Brianna Jordan destroyed evidence of the incident by burning the |
fraudulent voter guides in the backyard of campaign house on Grant St. |
On August 12, 2024, the Florida Department of State, Office of Election Crimes and Security |
(OECS) received an election complaint in reference to fraudulent voter guides in St. Johns |
| County, FL. The complaint, which had been forwarded via the Republican Party of Florida |
(RPOF), was on behalf of the St. Johns County Republican Executive Committee, The !
complaint provided the following:
e On June 6, 2024, the SJREC held a meeting for the purpose of voting on the endorsement !
of political candidates for the 2024 Republican Primary Election to be held on August 20, |
2024, (Note that early voting for the 2024 Primary Election was scheduled to take place |
between August 9, 2024 and August 17, 2024). As a result of that meeting, the SIREC |
chose to endorse the following candidates for political office:
o Mara Macie, US House of Representatives, District 5
a Gerry James, Florida Senate, District 7 |
o Kim Kendall, Florida House, District 18 |
o Ann-Marie Evans, St. Johns County Commissioner, District |
o Clay Murphy, St. Johns County Commissioner, District 3 |
o Ann Taylor, St. Johns County Commissioner, District 5 |
o Francis Cummings, St. Johns County School Board, District 2 |
o Linda Thomsom, St. Johns County School Board, District 5 |
* Upon selection of the candidates to receive the SJREC’s official endorsement, the SIREC |
created an official voter guide. The official voter guide listed the officially endorsed |
candidates, as well as the statutorily required disclaimers and the St. Johns County |
“GOP” logo. The SJREC printed out 20,000 voter guides, which were delivered to voters |
by SJREC related personnel during neighborhood outreach events. |
Page 3 of 13 |* On August 9, 2024, the SJREC began receiving complaints from citizens that had |
received fraudulent voter guides. The fraudulent voter guides listed that they were from |
the St Johns County GOP, however there were no statutorily required disclaimers as to |
who had paid/or created for the guides. The guides also displayed the St Johns County |
GOP logo, except that the logo was a reverse color scheme from the official logo. The |
fraudulent voter guide listed the following Candidates, all of whom were not endorsed by |
: the SJREC: |
| o Tom Leek, Florida Senate, District 7 .
| o Nick Primrose, Florida House, District 18
o Darryl Boyer, Florida House, District 19 |
o Jim Priester, St Johns County Sheriff |
o Brandon Patty, St Johns County Clerk and Comptroller
o Christian Whitehurst, St Johns County Commissioner, District | |
o Roy Alaimo, St Johns County Commissioner, District 3 |
o Henry Dean, St Johns County Commissioner, District 5 |
o Lynn Straughan, St. Johns County School Board, District 5
o Tamara Renuart, State Committeewoman |
¢ On August 12, 2024, an interview was conducted with Denver Cook, Chairman of the |
SJREC. Mr. Cook provided the same information contained in the initial complaint. Mr. |
Cook further advised that no one outside the SJREC had been authorized to use the St. |
Johns County GOP logo. Mr. Cook provided Your Affiant with four of the fraudulent |
voter guides, which were not in any envelopes, as well as 26 envelopes containing :
fraudulent voter guides that had been mailed to citizens registered as Republicans in St |
Johns County, FL. A review of the envelopes showed that the items had been mailed |
from a post office in Jacksonville, FL (Duval County) and Orlando, FL (Orange County).
Mr. Cook did not know who had created or mailed the fraudulent voter guides. Mr. Cook |
also provided a copy of the SJREC press release concerning the fraudulent voter guides, |
which was made due to the confusion created by them. |
e Approximately 135 houscholds in St. Johns County made complaints to the SJREC and |
provided the SJREC with the fraudulent voter guides and associated envelopes. |
Page 4 of 13 |On August 12, 2024, an additional complaint was made by Nick Primrose, candidate for Florida |
| House of Representatives.
Investigation revealed that between February of 2023 and August of 2024, numerous individuals |
conducted political campaigns for elected offices in St. Johns County, FL. Some of the
candidates employed either Front Street Consulting, LLC or Saint Strategies, LLC to assist with
| the operations of their political campaigns. Front Street Consulting and Saint Strategies were |
| shown on Sunbiz.org to be owned/operated by Brianna Jordan. The following political
candidates utilized Jordan’s companies: |
| «Tom Leek, Florida Senate, District 7 |
e Nick Primrose, Florida House, District 18 |
. e Darryl Boyer, Florida House, District 19 |
e Jim Priester, St Johns County Sheriff
e Brandon Patty, St Johns County Clerk and Comptroller |
. © Christian Whitehurst, St Johns County Commissioner, District 1
| e Roy Alaimo, St Johns County Commissioner, District 3
e Henry Dean, St Johns County Commissioner, District 5 |
During the course of the campaigns, the SJREC Executive Board made a decision to endorse |
: candidates for the 2024 Primary Election, to be held on August 20, 2024. On June 6, 2024, the |
| SJREC held meeting for its membership to vote on which candidates to endorse for the primary |
| election. That vote resulted in the SJREC endorsing candidates not represented by Jordan, |
| Between the SJREC vote, on June 6, 2024, and August 1, 2024, Jordan developed a scheme to |
| negate the SJREC’s endorsement of the opposing candidates. Jordan’s scheme consisted of |
7 creating a voter guide that mimicked the SJREC official voter guide. Jordan used the same logo
as the SJREC: however, she reversed the color from white lettering on a red background to red |
lettering on a white background, Jordan did not include any of the statutorily required language |
to identify who created or paid for the production of the voter guide. :
Page 5 of 13On August |, 2024, Jordan conducted a “Secret Envelope Stuffing” operation at 1351 Grant St,
St. Augustine, FL. This location was a residence, rented by Jordan, to be used as a campaign |
| headquarters. The operation consisted of individuals, under the direction of Jordan, placing the
| fraudulent voter guides into envelopes. Pre-printed labels, with the addresses of registered |
Republican voters in St. Johns County, were then placed on the envelopes. Jordan then used US |
postage stamps on the envelopes, instead of metered postage, in an attempt to conceal the origin |
of the fraudulent voter guides. The envelopes were then mailed from post offices in Orlando, FL |
and Jacksonville, FL in a further attempt to conceal their origins. The postmark dates on the
envelopes were from August 5, 2024, to August 15, 2024. [t was determined that Jordan
obtained in excess of 10,000 fraudulent voter guides and purchased approximately 20,000 US
postage stamps.
On August 15, 2024, Your Affiant contacted Nick Primrose by phone. Mr. Primrose had |
submitted a complaint regarding the fraudulent voter guides. Mr. Primrose advised that he had
utilized Jordan to assist in his political campaign in St. Johns County. Mr. Primrose advised that |
his campaign had received a request from Jordan to provide a volunteer for an envelope stuffing |
operation starting on August 1, 2024. Mr. Primrose advised that they provided one of their |
volunteers, Kyler Carpenter, to help Jordan, On August 9, 2024, Mr. Primrose and his wife |
received one of the aforementioned fraudulent voter guides. On August 12, 2024, Mr. Primrose |
was approached by Kyler Carpenter. Carpenter advised Mr. Primrose that he was present at
Jordan’s “campaign headquarters” when the fraudulent voter guides were placed into envelopes. |
Mr. Primrose then called and confronted Jordan about the fraudulent voter guides, Jordan |
initially denied any involvement with the fraudulent voter guides but later made admissions to |
creating and mailing them. Mr. Primrose advised he terminated his contracts with Jordan at that |
time. The phone calls between Mr, Primrose and Jordan were confirmed via Jordan’s phone |
records, which were obtained for this investigation, via subpoena. |
On August 15, 2024, Your Affiant made contact with Tom Leek. Mr. Leek had contacted the |
FDLE concerning the fraudulent voter guides. Mr. Leek advised that he had received third-party |
information from Mr. Primrose about Jordan’s participation in the fraudulent voter guides. Mr. |
Leek advised that he did not authorize anyone, including Jordan, to publish the fraudulent voter |
Page 6 of 13guides on his behalf. Mr. Leek advised that he discontinued using Jordan’s services after |
receiving this information about her involvement in the fraudulent voter guides. |
On August 21, 2024, Your Affiant conducted an interview with Kyler Carpenter, Carpenter was |
represented by his attorney, Timothy Miller. Mr. Carpenter advised that he had been a volunteer :
with the Primrose campaign. Mr. Carpenter stated that he was asked to help Jordan with a |
“Secret Envelope Stuffing” operation at the campaign headquarters, located at 1351 Grant St, St. :
Augustine, FL. Carpenter advised that he arrived at that location on August 1, 2024 at 0800
hours and was there for at least five hours. Carpenter advised that the operation consisted of him |
and Garrett Davis, an employee of Jordan’s, sitting at the dining room table placing the |
| fraudulent voter guides into envelopes and sealing them. The envelopes were then taken into the
living room, where address labels and postage stamps were placed on them. Mr, Carpenter was |
| shown a photograph of the fraudulent voter guides and was able to confirm that they were the |
same items he placed in the envelopes. Mr. Carpenter identified the people involved in the |
fraudulent voter guide operation as: |
e Brianna Jordan was overseeing the operation |
| * Jamie Johnson assisted with operation.
e Garrett Davis was an intern and assisted with placing the fraudulent voter guides in the |
envelopes. Davis also participated in taking the fraudulent voter guides to the post office |
: to be mailed. |
® St. Johns County Commissioner Christian Whitehurst was assisting placing labels and |
stamps on the envelopes containing the fraudulent voter guides. Whitehurst’s mother !
was also present and assisted with the fraudulent voter guide operation, as well as
| possibly helping to mail the envelopes. |
¢ St. Johns County Commissioner Sarah Armold was assisting with placing labels and |
stamps on the envelopes. Arnold also had her children present with her at the campaign |
headquarters while assisting the operation. |
° St. Augustine Beach Mayor Dylan Rumrell was assisting with placing labels and stamps |
on the envelopes, |
Page 7 of 13 |On February 27, 2025, Your Affiant conducted an interview with Jamie Johnson at her |
residence. Johnson confirmed that she had worked for Brianna Jordan and Front Street |
Consulting during the 2024 Election. Johnson advised that she was originally working for |
Jordan on behalf of the Jim Priester campaign. Johnson advised that she was present when the |
| fraudulent voter guides were placed into envelopes and mailed to voters. Johnson was shown a |
photograph of the fraudulent voter guide and confirmed it was the same voter guides being |
mailed by Jordan. Johnson advised that Jordan had created the fraudulent voter guides using an
online program called Canva. Johnson did not know where Jordan had the fraudulent voter |
guides printed. Johnson estimated that about 10,000 fraudulent voter guides were created and
mailed due to Jordan purchasing 10,000 US postage stamps. Everything done with the |
fraudulent voter guides was done by hand to prevent them from going through a machine and :
lessen the chance that fraudulent voter guides/envelopes could be tracked. The envelopes were |
mailed by Jordan and Garrett Davis at the post office. Johnson advised when the story about the
fraudulent voter guides aired on the local news channels, Jordan panicked and started to burn the |
remaining fraudulent voter guides in the back yard of the Grant St, address, while Johnson and |
Davis were present. Jordan took the remaining fraudulent voter guides, that had not been
bummed, to her residence in St. Petersburg to destroy the evidence. Johnson believed that Jordan |
created the fraudulent voter guides due to her being frustrated with the SJREC not backing the |
“right people”, Johnson advised the following people took part in the fraudulent voter guide
operation: |
e St. Johns County Commissioner Christian Whitehurst |
* St. Johns County Commissioner Sarah Arnold |
e St. Augustine Beach Dylan Rumrell |
e Brianna Jordan |
¢ Garrett Davis |
e Kelly Harrison, campaign manager for the Priester Campaign. |
On February 28, 2025, Your Affiant conducted and interview with St. Augustine Beach Mayor |
Dylan Rumrell. Mayor Rumrell was shown a photograph of the fraudulent voter guide. Mayor |
Rumrell advised that he had previously seen the fraudulent voter guide due to receiving one in |
the mail. Mayor Rumrell denied seeing the fraudulent voter guide at any other time, Mayor |
Page 8 of 13 |Rumrell admitted to going to the Jordan’s campaign house several times during August of 2024. |
Mayor Rumrell advised that he was assisting Henry Dean with his political campaign and the
purpose of the visit for Jordan was to view “campaign advertisements and videos” for Henry |
Dean, Mayor Rumrell denied any involvement with the fraudulent voter guides, |
On March 8, 2025, Your Affiant received and returned a phone call from Jamie Johnson. |
Johnson advised that she had been contacted by Jordan earlier in the day. Johnson advised that
Jordan asked her if she had been interviewed by an FDLE investigator yet. Johnson informed |
Jordan that she had not been interviewed, however she was aware that FDLE was looking for |
her. Johnson stated that Jordan instructed her not to speak with FDLE. Jordan further advised
Johnson that she (Jordan) would provide and pay for an attorney for Johnson. Johnson indicated
that Jordan was going to be talking to the other subjects involved in the investigation. Phone |
records were later obtained for Jordan, which confirmed that Jordan had spoken with Johnson on |
March 8, 2025. The records also showed that Jordan had been speaking with Whitehurst and
Arnold during the same time frame. |
On October 1, 2025, Your Affiant conducted an interview with Garrett Davis and his attorney, :
Steve Alexander. Mr. Davis had been provided with a Use Immunity Agreement by the Office |
of Statewide Prosecution. Mr. Davis confirmed that he was an intern for Jordan from July, 2024 |
to August, 2024. Mr. Davis was shown a photograph of the fraudulent voter guide and |
confirmed that it was the same voter guides that had been mailed to voters by Jordan during the
2024 Primary Election, Mr. Davis advised that Jordan had created the fraudulent voter guides to |
“counter” the true voter guide put out by the SIREC, Mr. Davis advised that Jordan had created
the fraudulent voter guides using Canva. Mr. Davis advised that Jordan ordered between 10,000 |
and 30,000 of the fraudulent voter guides, which were delivered via an “18 wheeler” to the |
campaign house on Grant St. and later unloaded at Jordan’s residence at 1425 Los Robles Ave, |
St. Augustine, FL. Davis advised that the fraudulent voter guides were sent to voters via the US
Postal Service using first class stamps so that the mailing would not have a return address. At
the direction of Jordan, Mr. Davis mailed some of the fraudulent voter guides at a drop mailbox |
in Jacksonville, FL. After the fraudulent voter guides story aired on the local news, Jordan had |
Mr. Davis purchase a “kettle grill” from the Home Depot on US Highway 1, St. Augustine, FL.
Page 9 of 13Jordan gave Mr. Davis cash to purchase the grill so that it would not show up on Jordan’s credit |
card. Jordan, Johnson, and Mr. Davis then burned some of the fraudulent voter guides in the
| backyard of the Grant St. address. Jordan took the remaining fraudulent voter guides back with |
: her to Sarasota, FL to destroy. The date that the voter guides were destroyed at the Grant St. |
| Address was either August 12, 2024 or August 13, 2024, Mr. Davis advised the following
| people were involved with mailing the fraudulent voter guides: |
| e Brianna Jordan was the organizer. :
« Jamie Johnson. |
e §t. Johns County Commissioner Whitehurst was shown the false voter guides and knew
he was not endorsed by the SJREC. Whitehurst was present for several days of the |
operation. |
e Whitehurst’s mother placed stamps and labels on the fraudulent voter guides, as well as |
mailed some of them at the post office. Davis did not know her name. |
e St. Johns County Commissioner Sarah Amold was present and knew the voter guides |
were fraudulent. Arnold took part in placing labels and stamps on the envelopes. |
Armold’s children were present and assisted with placing stamps and labels on the
envelopes as well. |
* St. Augustine Beach Mayor Dylan Rumrell was present and shown the fraudulent voter
guides. Rumrell should have known that the candidates listed on the fraudulent voter |
guide were not the candidates actually endorsed by the SJREC, Per Davis, Rumrell was |
assisting with placing the fraudulent guides in envelopes and mailing them. |
e James “Jim” Priester was present and shown the fraudulent voter guides. Priester knew |
that he, nor any of the other candidates on the fraudulent voter guide, were not endorsed |
by the SJREC. Priester did not stuff the fraudulent voter guides into the envelope, |
however he was provided with them to place in the mail. Priester’s wife was with him :
when he received the fraudulent voter guides to mail, |
* James Kelly Harrison was shown the fraudulent voter guides, and he knew that the |
candidates on the fraudulent voter guide were not the ones endorsed by the SJREC, |
Harrison was the campaign manager for Priester. |
e A male from the Nick Primrose Campaign was present for one day of the operation. |
Davis stated he was told by Jordan that this person went back to the Primrose Campaign |
Page 10 of 13 !and informed them about the fraudulent voter guide operation, This person was
. identified as Kyler Carpenter.
Subpoenas were obtained for Jordan’s business and personal banking accounts and credit cards.
The records confirmed that Jordan was making payments for a Canva.com account. The records |
showed that Jordan made purchases from several printing companies that would have |
corresponded with the possible purchase of the fraudulent voter guides. Jordan made several |
| large purchases from the United States Postal Service (USPS) in the amounts of$7,302 (July 24,
2024), $14,602 (July 31, 2024), and $2,802 (August 6, 2024). The records further confirmed that |
Jordan had made payments for services to Jamie Johnson, Garrett Davis, and Kelley Harrison
during the timeframe of this incident.
Phone records were obtained, via subpoena, for Jordan. A review of the phone records showed
that on August 11, 2024, after a story about the fraudulent voter guides was aired on the local |
news, Jordan made phone calls to three businesses that provide shredding services. The provider |
for each business appeared to belong to a company called “Shred Nation” that operated out of |
UPS stores. The stores were located in The Villages, Apopka, and Tampa. |
Between June 4, 2026 and June 10, 2026, Your Affiant and other FDLE Inspectors conducted
interviews with individuals who had reported turning the fraudulent voter guides to the SJREC.
Approximately 60 of the individuals interviewed remembered receiving the fraudulent voter
guides in the mail prior to the 2024 Primary Election. The individuals all resided at addresses in |
St. Johns County, FL at the time they received the fraudulent voter guides. |
Your Affiant believes that based upon the investigation in its entirety, and evidence gathered |
during the investigation, probable cause exists that the following violations of law were |
committed:
Brianna Maureen Jordan (W/F December 19, 1990): |
COUNT |: TAMPERING WITH PHYSICAL EVIDENCE |
Page 11 of 13FLA, STAT, §918.13(2)(A) |
THIRD DEGREE FELONY
COUNT 2; UNAUTHORIZED VOTER GUIDES |
FLA. STAT. §106.1436 |
FIRST DEGREE MISDEMEANOR |
COUNT 3: CRIMINAL CONSPRIACY |
| FLA. STAT. §777.04 |
| SECOND DEGREE MISDEMEANOR
Jamie Lynn Johnson (W/F March 27, 1980): |
COUNT 1: © UNAUTHORIZED VOTER GUIDES
FLA, STAT. §106.1436 |
FIRST DEGREE MISDEMEANOR |
COUNT 2: CRIMINAL CONSPRIACY |
FLA, STAT, $777.04 |
SECOND DEGREE MISDEMEANOR |
Christian Gerard Whitehurst (W/M April 4, 1982): |
COUNT 1: UNAUTHORIZED VOTER GUIDES . |
FLA. STAT. §106, 1436 |
FIRST DEGREE MISDEMEANOR |
COUNT 2: CRIMINAL CONSPRIACY |
FLA, STAT. §777.04 |
SECOND DEGREE MISDEMEANOR |
Sarah Salley Arnold (W/F September 12, 1985): |
COUNT 1: UNAUTHORIZED VOTER GUIDES |
FLA, STAT. §106.1436 !
FIRST DEGREE MISDEMEANOR |
COUNT 2: CRIMINAL CONSPRIACY :
FLA. STAT, §777.04
SECOND DEGREE MISDEMEANOR
Dylan Andrew Rumrell (W/M April 8, 1977): :
Page 12 of 13 |COUNT 1: UNAUTHORIZED VOTER GUIDES |
FLA. STAT. §106.1436 |
FIRST DEGREE MISDEMEANOR
COUNT 2: CRIMINAL CONSPRIACY |
FLA. STAT. §777.04
SECOND DEGREE MISDEMEANOR
| WHEREFORE, your Affiant prays that an information will be issued to arrest the |
aforementioned defendants and bring them before the Court so that they may be dealt with
| according to law,
| — |
| assa
| eT eS
| Adam Grafh Special Agent Supervisor |
Florida Department of Law Enforcement
The foregoing instrument was acknowledged before me by means ofphysical presence this 19" |
day of June 2026 by Special Agent Supervisor Adam Graff who has produced identification and |
who did take an oath, |
I Enforcement Officer ; |
Florida Department of Law End
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