THE STATE OF TEXAS Cause &//7c02s_

jZ.

Court of the Justice of the Peace

COUNTY OF HENDERSON Precinct # I—L

Before me the undersigned authorth, on this day personally appeared, the Henderson County Fire Marsha!, Shane
Renberg, who after being duly sworn upon his oath deposes and says that he has good reason to believe and does
believe that Randy Harley, V/M DOB 07/19/1965, did on or about the 18th day of May, 2018, in Henderson
County, Texas, commit the offense of Bribery, Texas Penal Code §36.02(a)(l) a 2nd Degree Felony, whereby
Randy Harley intentionally and knowingly, solicited and accepted a benefit, to-wit: 51,200.00, as consideration for
his decision to exercise his discretion, to-wit: making false entries on a governmental record, to-wit: a Henderson
County Community Supervision & Corrections Department, CSR Timesheet, to certify a criminal defendant has
performed community service hours (work) at the Payne Springs Volunteer Fire Department, as the Fire Chief, a
public ser ant.

Affiant, Shane Renberg states that his reason for believing the same is based upon the following:

Affiant Henderson County Fire Marsha? Shane Renberg, is a certified Peace Officer for the State of Texas and
employed as the Fire Marshal of Henderson County, Texas. Affiant has over 13 years of experience as a peace
officer and in that time has gained training, experience and knowledge in criminal investigations. Affiant is certified
as an Advanced Peace Officer by the Texas Commission of Law Enforcement. Affiant has conducted interviews of
witnesses, gathered evidence, reviewed documents and records and has developed facts that establish sufficient
probable cause to state that:

On Monday, July 23, 2018 Affiant was conducting an investigation of possible Theft of funds from the Payne
Springs Volunteer Fire Department. During that investigation Affiant learned of a possible Bribers and Tamperin
with Governmental Record incident may have occurred involving the Fire Chief, Randy Harley.

Affiant learned that there were some assertions that persons who were convicted of criminal offenses and p!aced on
probation could acquire court-ordered community service hours by approaching Randy Harley and make a
donation” in exchange for Randy Harley’s signature on any documents required by the probation department.

The “probation department” is the Henderson Coun Community Supervision & Corrections Department. The
probation department is a branch of the courts that supervises criminal defendants placed on probation by the courts
and ensures that criminal defendants adhere to court ordered conditions of release. The probation department
directly reports to the courts and establishes direct rules and records required to be kept by the government to record
and assure all court ordered conditions are met by criminal defendants.

One of the common court ordered conditions is that a criminal defendant must perform community service hours for
a non-profit organization. (The probation department keeps track of such hours performed by a probationer on the
“CSR Tthiesheet). This document is provided to a probationer and instructed to find an approved organization and
perform the community service work. Once the work is performed, a member of the organization signs and records
the date and number of hours of work performed. Affiant states that the “CSR Timesheet” is a government record as
defined by §37.01(2) of the Texas Penal Code.

Affiant contacted the Henderson County Supervision & Corrections Department (HCSCD) and inquired about any
probationers who may have recent!y submitted documentation claiming they had performed community service
hours at the Payne Springs Volunteer Fire Department. The HCSCD reported they had one probationer submit a
“CSR Tirnesheet” stating they had performed community service work at the Payne Springs Volunteer Fire
Department.

The probationer, Rusn Dorough, was on probation for an offense in another county but supervised by the HCSCD.
Dorough was ordered to complete one hundred and twenty hours (120) of community service hours as part of his

L’nminal Comptah,t-Bribe.Randy Harley

 F%/7i’c-z j_

probation conditions. The HCSCD received from Rusty Dorough via e-mail a CSR Timesheet claiming he had
performed the 120 hours of community service at the Payne Springs Volunteer Fire Department.

Affiant called and then later met with Rusty Dorough. Rusty Dorough stated during the interview that he met with
Payne Springs Fire Chief Randy Harley, who advised him if he made a donation of S1,200, Randy would fill out
the,” HCSCD, CSR Timesheet” giving Rusty Dorough his community service hours.

Rusty stated he obtained S 1,200 in cash and met with Randy’ Harley at the Payne Springs Fire Department on Hwy
198 in Payne Springs, Texas on May 18, 2018. Rusty Dorough stated he and Randy sat in Randy’s truck in the
parking lot of the Fire Department. Rusty Dorough stated he handed Randy the CSR Timesheet and Randy began to
fill out the CSR Timesheet reflecting Rusty Dorough worked approximately 122 hours of community service
between May 18, 2018 and June 24, 2018. Rusty Dorough stated he did not work any ofthe hours listed in the form
Randy filled out. Randy used different pens to make the record appear like the record was filled out properly. Rusty
Dorough stated Randy then opened a black note book and instructed Rusty to drop the S 1,200 inside. Rusty
Dorough stated he obtained the” CSR Timesheet “from Randy Harley. Rusty Dorough stated he later sent the CSR
Timesheet after June 24, 2018 to his probation officer. The HCSCD reports that upon calling Randy Harley, [tardy
verified the information on the CSR Timesheet to be true and correct. The probation officer recorded and gave Rusty
Dorough credit for performing his community service hours.

Affiant also obtained the document Rusty Dorough had in his possession reflecting the community service hours
claimed to have been performed. Affiant is yen familiar ith Randy Harley’s signature and recognized the
signature as Harlvs.

Affiant also is in possession of bank records belonging to the Fire Department. A review of those records does not
reveal a Sl,200 cash deposit into the Fire Departments bank account within a reasonable period of time that could
account for the S 1,200 provided to Harley by Rust Dorough.

Affiant states that there is probable cause to believe that Randy Harley committed the offense of Bribery on May
18, 2018 in Henderson County, Texas, by exercising his discretion as a public servant, the Fire Chief of the Payne
Springs Volunteer Fire Department by making false entries on a 1-ICSCD, CSR Timesheet reflecting Rusty Dorough
perfonned 120 hours of community service work at the Payne Springs Volunteer Fire Department when Randy
Harley knew that Rusty Dorough did not perform the work and solicited and accepted a benefit ofS 1,200.00 in cash
inconsideration for exercising that discretion.

Witness my signature on this the fr day of Az6’s7’ - ,2018.

C’Affiant
Subscribed and sworn to before me on -e day of August, 2018.

Justice orPeace HEderson County. Texas

Precinct

The foregoing instrument, having been presented to me, and after findin probable cause does exist for the issuance
ofa warrant of arrest, the same is here by ordered issued on this 9day of/E ç 2018 at
C7L1[ O’clock P. M

Justice of the Peace

Precinct C1

cnmjna CompIaint’Bñbe”Rar.dy Har!oy

THE STATE OF TEXAS Cause F/
7;t’2
Court of the Justice of the Peace
COUNTY OF HENDERSON Precinct # f

Before me the undersigned authority, on this day personally appeared, the Henderson County Fire Marshal, Shane
Renberg, who after being duly sworn upon his oath deposes and says that he has good reason to believe and does
believe that Randy Harley, V/N1 DOB 07/19/1965, did on or about the 18th day of May, 2018, in Henderson
County, Texas, commit the offense of Tampering with Governmental Record, Texas Penal Code §37. l0(a)( I), a
2nd Degree Felony, whereby Randy Harley intentionally and knowingly, made false entries on a governmental
record, to-wit: a Henderson County Community Supervision & Corrections Department, CSR Timesheet, with intent
to harm or defraud the Henderson County Community Supervision & Corrections Department.

Affiant, Shane Renberg states that his reason for believing the same is based upon the following:

Afflant Henderson County Fire Marshal Shane Renbera, is a certified Peace Officer for the State of Texas and
employed as the Fire Marshal of Henderson County, Texas. Affiant has over 13 years of experience as a peace
officer and in that time has gained trainin2. experience and knowledge in criminal investigations. Affiant is certified
as an Advanced Peace Officer by the Texas Commission of Law Enforcement. Affiant has conducted interviews of
witnesses, gathered evidence, reviewed documents and records and has developed facts that establish sufficient
probable cause to state that:

On Monday July 23, 2018 Affmant was conducting an investigation of possible Theft of funds from the Payne
Springs Volunteer Fire Department. During that investigation Afliant learned of a possible Bribery and Tampering
with Governmental Record incident may have occurred involving the Fire Chief, Randy Harley.

Affiant learned that there were some assertions that persons who were convicted of criminal offenses and placed on
probation could acquire court-ordered community service hours by approaching Randy Harley and make a
“donation” in exchange for Randy Harley’s signature on any documents required by the probation department.

The •probation department” is the Henderson County Community Supervision & Corrections Department. The
probation department is a branch of the courts that supervises criminal defendants placed on probation by the courts
and ensures that criminal defendants adhere to court ordered conditions of release. The probation department
directly reports to the courts and establishes direct rules and records required to be kept by government to record and
assure all court ordered conditions are met by criminal defendants.

One of the common court ordered conditions are that a criminal defendant must perform community service hours
for a non-profit organization. The probation department in order to keep track of such hours performed by a
probationer is the ‘CSR Timesheet”. This document is provided to a probationer and instructed to find an approved
organization and perform the community service work. Once the work is performed, a member of the organization
signs and records the date and number of hours of work performed. Affiant states that the “CSR Timesheet” is a
government record as defined by §37.01(2) of the Texas Penal Code.

Affiant contacted the Henderson County Supervision & Corrections Department (HCSCD) and inquired about any
probationers who may have recently submitted documentation claiming they had performed community service
hours at the Payne Springs Volunteer Fire Department. The HCSCD reported they had one probationer submit a
CSR Timesheet stating they had performed community service work at the Payne Springs Volunteer Fire
Department.

The probationer, Rusw Dorough, was on probation for an offense in another county’ but supervised by the HCSCD.
Dorough was on probation and was ordered to complete one hundred and twenty hours (120) of community service
hours as part of his probation conditions. The HCSCD received from Rusty Dorough via e-mail a CSR Timesheet
claiming he had performed the 120 hours of community service at the Payne Springs Volunteer Fire Department.

criminal complaintTanpering with Government Rocord.Ran,ly Harley

 F’ 7/

Affiant called and then later met with Rusty Dorough. Dorough stated during the interview that he met with Payne
Springs Fire Chief Randy Harley, who advised him if he made a donation of $1,200, Randy would fill out the
Henderson County Community Supervision and Correction Department, CSR timesheet giving Rusty his
community service hours.

Rusty stated he obtained 51,200 in cash and met with Randy at the Payne Springs Fire Department on Hwy 198 in
Payne Springs, Texas on May 18, 2018. Rusty stated he and Randy sat in Randy’s truck in the parking lot of the
Fire Department. Rusty Stated he handed Randy the CSR Timesheet and Randy made filled out the CSR Timesheet
reflecting Rusty worked approximately 122 hours of community service between May l8, 2018 to June 24, 2018.
Rusty stated he did not work any of the hours. Randy used different pens to make the record look like the record was
filled out properly. Rusty stated Randy then opened a black note book and instructed Rusty to drop the money
inside. Rusty stated he held the CSR Timesheet and then sent the CSR Timesheet to his probation officer. The
Probation Department also called Randy Harley about the community service hours and he verified them to be true
and correct. The probation officer recorded and gave Rusty Dorough credit for performing his community service
hours.

Affiant also obtained the document Rusty had in his possession reflecting the community service hours claimed to
have been performed. Affiant is very familiar with Randy Harley’s signature and recognized the signature as
Harley’s.

Affiant also is in possession of bank records belonging to the Fire Department. A review of those records do not
reveal a $1,200 cash deposit into the Fire Department’s bank account within a period of time that could account for
the S 1,200 cash given to Randy Harley by Rusty Dorough.

Affiant states that there is probable cause to believe that Randy Harley committed the offense of Tampering with
Government Record on May 18, 2018 in Henderson County, Texas, by making false entries on a HCSCD, CSR
Timesheet, reflecting Rusty Dorough performed 120 hours of community service work at the Payne Spring
Volunteer Fire Department when Rand>’ Harley knew that Rusty Dorough did not perform the work, knowing that
the entries in the CSR Timesheet he signed were false ,with intent to harm and defraud the Henderson County
Supervision & Corrections Division.

Witness my signature on this the 1w day of ,20 18.

ffiant
Subscribed and sworn to before me on day of August, 2018.

Justice of leace Henderson County, Texas

Precinct c4

The foregoing instrument, having been presented to me, and after finding probable cause does exist for the issuance
of a warrant of arrest, the same is here by ordered issued on this 6-’ t’day of is at
O’clock,/2.. M,

ehePeac e
Precinct

criminal complaintTam1enn wiLl, Oavomment Rcorcl-Ranily Harloy