cuyahoga county court of common...

<GRANDJURORSIGNATURE>

<PROSECUTORSIGNATURE>

Foreperson of the Grand Jury

Prosecuting Attorney

of 22

Cuyahoga County Court of Common Pleas

Criminal Court Division

State of Ohio, A True Bill Indictment For

Plaintiff Engaging In A Pattern Of Corrupt Activity - F1

VS. §2923.32(A)(1)

10 Defendants 16 Additional Count(s)

Defendants

Eddie Lawson, Edward Lawson, Lawson Towing And Auto Wrecking Llc, Marcellar G. Grayer, Randy Harris, Gary G. Thompson Jr., James D. Mingo, Angela Wilkes, Melvin King, Deshawn Darryl Douglas

Dates of Offense (on or about) The Term Of Case Number

04/24/2012 to 02/09/2016 May of 2016 607043-16-CR

The State of Ohio, }

SS.

Cuyahoga County

Count One Engaging In A Pattern Of Corrupt Activity - F1

§2923.32(A)(1)

Defendants Eddie Lawson, Edward Lawson, Lawson Towing And Auto Wrecking Llc, Marcellar G. Grayer, Randy Harris, Gary G. Thompson Jr., James D. Mingo, Angela Wilkes, Melvin King, Deshawn Darryl Douglas

Date of Offense On or about April 24, 2012 to February 9, 2016

The Jurors of the Grand Jury of the State of Ohio, within and for the body of the County aforesaid, on their oaths, IN THE NAME

AND BY THE AUTHORITY OF THE STATE OF OHIO, do find and present, that the above named Defendant(s), on or about the

date of the offense set forth above, in the County of Cuyahoga, unlawfully

while employed by, or associated with, any enterprise did conduct or participate in, directly or indirectly, the affairs of the enterprise through a pattern of corrupt activity or the collection of an

unlawful debt and at least one of the incidents of corrupt activity was a felony of the first, second, or third degree, aggravated murder, or murder, or at least one of the incidents was a felony under the law of this state that was committed prior to July 1, 1996, and constituted a felony of the first, second, or third degree, aggravated murder, or murder or was committed on or after July 1, 1996, or

one of the incidents of corrupt activity was a felony under the law of the United States or of another state that, if committed in this state on or after July 1, 1996, would have constituted a felony of the

first, second, or third degree, aggravated murder, or murder under the law of this state.

On or about or about April 24, 2012 to February 9, 2016 LAWSON TOWING AND AUTO WRECKING LLC EDWARD M. LAWSON, EDDIE L. LAWSON, MELVIN KING, DARRYL DOUGLAS, JAMES MINGO, MARCELLAR GRAYER, RANDY HARRIS, and ANGELA WILKES did being employed by, or associated with, any enterprise conduct or participate in, directly or indirectly, the affairs of the enterprise through a pattern of corrupt activity when at least one incident of corrupt activity was a felony of the first, second or third degree.


A True Bill Indictment





of 22

THE ENTERPRISE This Enterprise is an association and/or organization and/or a group of persons and/or companies associated in fact, although not a legal entity, including but not limited to EDWARD M. LAWSON, EDDIE L. LAWSON, MELVIN KING, DARRYL DOUGLAS, JAMES MINGO, MARCELLAR GRAYER, RANDY HARRIS, ANGELA WILKES, and others known and unknown all of whom are persons associated with the Enterprise (collectively, "Persons associated with the Enterprise" or "Persons"). This Enterprise existed as an "Association in Fact Enterprise" under R.C. 2932.32 because it: (1) was an ongoing organization with a commonality of purpose or a guiding mechanism to direct the organization or (2) was a continuing unit with an ascertainable structure and/or (3) had an organizational structure that was distinct from the pattern of predicate acts. As an alternative to point (3), this Enterprise is an illicit enterprise under R.C. 2932.32 because it had an organizational structure distinct from the pattern of predicate acts whether or not this enterprise performed any legal acts. The persons and/or companies associated with the Enterprise performed, from time to time, some lawful acts while working for entities connected with the Enterprise, and as a result, this Enterprise existed separate and apart from the pattern of corrupt activity described in this Indictment. For example and without limitations, members of the enterprise stole catalytic converters from anonymous vehicles and were then reimbursed for the stolen catalytic converters with the proceeds from the sale of the catalytic converters to metal recycling facilities. However, the persons named herein and others named in this count also performed illegal acts as part of and in furtherance of their association with this Enterprise, as stated in this indictment. A more detailed description of the Enterprise is stated in below. A. THE PARTIES LAWSON TOWING AND AUTO WRECKING LLC is a Domestic Limited Liability Corporation registered in Ohio (Entity Number 1774676), whose agent /registrant is EDWARD M. LAWSON, 14114 Miles Ave., Cleveland, Ohio 44128, and whose stated purpose is “[t]o operate a business of buying and selling of salvage materials, including but not limited to: scrap iron and steel, automobile parts, and construction building materials. Towing of vehicles.” EDWARD M. LAWSON – is referred to as “Wink.” EDWARD M. LAWSON is the owner of LAWSON TOWING & Auto Wrecking, LLC located at 14114 Miles Ave. Cleveland, OH 44128. This business was the subject of a CPD search on 10/31/13 involving knowingly stolen vehicles being delivered to the business to be scrapped. Lawson possesses a “scrap metal dealer” (R.C. 4737.04) that qualifies him to legally sell catalytic converters and scrap automobiles to metal recycling facilities for processing. He receives stolen catalytic converters from stolen cars and sells them to metal recycling facilities with his scrapping license, and also sells stolen cars to metal recycling facilities with his scrapping license. Lawson then reimburses the individuals that gave him the stolen catalytic converters and stolen cars with the proceeds while giving himself a small fee for the service. Lawson primarily sells the stolen catalytic converters and stolen cars to New Western Reserve Recycling, LLC., and Ferrous Processing and Trading (“FPT”). EDDIE L. LAWSON – is an employee of Lawson Auto and is the cousin of EDWARD M. LAWSON. Lawson has also been reported to be a member of the ‘Lee Road Gang’ with the alias ‘Sleezie E’. Lawson drives a black Yukon Denali with the license plate number of GDW1220. Lawson has been linked to several thefts of catalytic converters throughout Greater Cleveland and Northeast Ohio with video footage either showing his face or his black Yukon Denali at the scene of the thefts.







of 22

MELVIN KING – has been arrested with EDDIE L. LAWSON in relation to catalytic converter thefts on several occasions. JAMES MINGO stated that King taught him how to steal catalytic converters and that King was related to the Lawson family. Interviewee also stated that King sometimes posed as EDWARD M. LAWSON in order to use Lawson’s scrapping license and sell catalytic converters to a metal recycling facility in Kentucky. This may be substantiated by King claiming to be Edward “Wink” Lawson during a stop by Ohio Highway Patrol on I-71 North involving possession of 28 catalytic converters on December 16, 2015. King has been linked to several thefts of catalytic converters throughout Greater Cleveland and Northeast Ohio. DARRYL DOUGLAS – is the son of EDWARD M. LAWSON (“Wink”). DARRYL DOUGLAS has been linked to several thefts of catalytic converters throughout Greater Cleveland and Northeast Ohio. JAMES MINGO – is the cousin of Randy Harris, an employee of Edward M. Lawson. On or about February 9, 2016, the Solon Police Department arrested JAMES MINGO and DARRYL DOUGLAS in connection with stealing catalytic converters in Solon, OH. MARCELLAR GRAYER – is also known as “Buster.” MARCELLAR GRAYER was an employee at LAWSON TOWING. On or about December 16, 2015, the Ohio Highway Patrol stopped Grayer, MELVIN KING, and RANDY HARRIS on I-71 North while they were in possession of 28 catalytic converters and criminal tools. During this stop, MELVIN KING claimed to be Edward “Wink” Lawson. RANDY HARRIS – is the cousin of JAMES MINGO. Harris is an employee at LAWSON TOWING and sometimes accompanies EDWARD M. LAWSON to sell catalytic converters to a metal recycling facility in Kentucky. On or about December 16, 2015, the Ohio Highway Patrol stopped Harris, MARCELLAR GRAYER, and MELVIN KING on I-71 North while they were in possession of 28 catalytic converters and criminal tools. During this stop, MELVIN KING claimed to be Edward “Wink” Lawson. ANGELA WILKES – is a resident of Euclid who reported her car stolen to the Akron Police Department on November 20, 2013, however the car had been crushed by EDWARD M. LAWSON on October 31, 2013. B. THE SCHEME OR PHASES OF THE ENTERPRISE'S EXISTENCE Within the scope of this enterprise and to further its affairs, EDWARD M. LAWSON (“Wink”) made it known to an undercover Cleveland Police Officer and his employees at LAWSON TOWING & AUTO WRECKING, LLC that he would reimburse individuals that gave him stolen catalytic converters and stolen automobiles. LAWSON TOWING is a licensed limited liability company with the office of the Secretary of State in Ohio. EDWARD M. LAWSON’s reimbursement came from the metal recycling facility as sale proceeds for the stolen catalytic. EDWARD M. LAWSON was the only individual able to legally sell the catalytic converters to metal recycling facilities because he is a “scrap metal dealer” under R.C. 4737.04. However, MELVIN KING sometimes posed as EDWARD M. LAWSON to enable him to sell the catalytic converters as well. The metal recycling facilities buy catalytic converters for the precious metals (i.e. platinum, palladium) contained in them. The value of each catalytic converter is based upon the amount of precious metal found in that type of catalytic converter. Within the scope of this enterprise and to furthers its affairs, EDDIE L. LAWSON is known to have stolen catalytic converters or equipment on at least 24 occasions in order to be reimbursed by EDWARD M. LAWSON, his employer and cousin, following the sale of those catalytic converters to







of 22

metal recycling facilities. Within the scope of this enterprise and to furthers its affairs, MELVIN KING is known to have stolen catalytic converters on at least seven occasions in order to be reimbursed by EDWARD M. LAWSON, his employer and relative, following the sale of those catalytic converters to metal recycling facilities. Within the scope of this enterprise and to furthers its affairs, DARRYL DOUGLAS is known to have stolen catalytic converters on at least four occasions in order to be reimbursed by EDWARD M. LAWSON, his employer and father, following the sale of those catalytic converters to metal recycling facilities. Within the scope of this enterprise and to furthers its affairs, MARCELLAR GRAYER is known to have stolen catalytic converters on at least two occasions in order to be reimbursed by EDWARD M. LAWSON, his employer, following the sale of those catalytic converters to metal recycling facilities. Within the scope of this enterprise and to furthers its affairs, RANDY HARRIS is known to have stolen catalytic converters on at least two occasions in order to be reimbursed by EDWARD M. LAWSON, his employer, following the sale of those catalytic converters to metal recycling facilities. Within the scope of this enterprise and to further its affairs, ANGELA WILKES is known to have submitted a false police report to the Akron Police Department that her car was stolen on November 20, 2013, despite the fact that EDWARD M. LAWSON had crushed her car on October 31, 2013, and fraudulently submitted a claim to GEICO insurance for payment on the purportedly stolen vehicle. The grand jury finds that acts committed in furtherance of this enterprise were acts committed within a course of conduct that occurred in Cuyahoga, Ashland, and/or Summit County, Ohio C. COMMON PURPOSE OF THE ENTERPRISE: This Enterprise functioned as an ongoing organization with commonality of purpose or a guiding mechanism to direct the organization. As stated above, each Person Associated with the Enterprise performed separate acts on behalf of and in furtherance of the Enterprise. The persons associated with this enterprise were members of an Enterprise engaged in a pattern of corrupt activity. Likewise, this occurred with the knowledge and/or support of other Persons Associated with the Enterprise in order that this Enterprise, as an association in fact, could continue and thrive because of the activities of each of the persons of the Enterprise. This Enterprise functioned as a continuing unit with an ascertainable structure while it was engaging in the diverse forms of illegal activities. In doing so from the time stated herein, the Persons Associated with the Enterprise participated in and/or managed the affairs of the Enterprise as previously stated. As such, these persons provided continuity and structure to the Enterprise in order to accomplish its illegal purposes—the pattern of corrupt activity as set forth in this count. This enterprise and the Persons Associated with the Enterprise were joined in purpose over a period, with various roles that were different, and with methods that changed in order to accomplish the main purpose of the Enterprise.







of 22

The structure of the organization, as an Enterprise in fact, starts out with LAWSON TOWING & AUTO WRECKING, LLC. LAWSON TOWING is owned by EDWARD M. LAWSON and is a licensed business with Ohio’s Secretary of State. LAWSON TOWING primarily scrapped automotive vehicles for their metal and valuable parts. However, employees of LAWSON TOWING also had an understanding with EDWARD M. LAWSON that he would reimburse them for stolen catalytic converters they provided to EDWARD M. LAWSON. EDWARD M. LAWSON is a “scrap metal dealer” under R.C. 4737.04 which allowed him to legally sell scrapped metal to metal recycling facilities. EDWARD M. LAWSON was the only “scrap metal dealer” working at LAWSON TOWING. EDWARD M. LAWSON sold the scrap metal, i.e. stolen catalytic converters, to the metal recycling facility he would reimburse the employee according to the value the stolen catalytic converters had been sold for. Employees of LAWSON TOWING were EDDIE L. LAWSON, MELVIN KING, MARCELLAR GRAYER, and RANDY HARRIS. DARRYL DOUGLAS was affiliated with the Enterprise as EDWARD M. LAWSON’s son. ANGELA WILKES was affiliated with the enterprise because reported her car stolen to the AKRON POLICE DEPARTMENT in November 2013 despite the fact that EDWARD M. LAWSON had already crushed the car weeks earlier, in October 2013. This Enterprise is comprised of the Persons Affiliated with the Enterprise, all of whom acted with the purpose described in this Indictment, and all of whom conducted their activities over a period for a common purpose. This Enterprise as an informal association comprised of the Persons Associated with the Enterprise functioned as a continuing unit, separate from the pattern of activity in which it engaged because one or more person associated with this Enterprise performed legal acts as described herein. The non-exclusive list of lawful activities described herein occurred while this Enterprise functioned as a continuing unit and with an organization structure which engaged in diverse forms of illegal activities as stated in this Indictment. It also consisted of Companies. While the Persons Associated with the Enterprise may have performed, from time to time, some lawful acts as described above, while working for entities connected with the Enterprise, these Persons, however, also performed illegal acts as part of and in furtherance of this Enterprise, as stated in this Indictment. Based on the foregoing, this Enterprise existed separate and apart from the pattern of corrupt activity in which it was engaged, and this Enterprise functioned as a continuing unit by engaging in the diverse forms of illegal activities, as stated in this Indictment. In the alternative, this Enterprise is an "illicit enterprise" under R.C. 2932.32 which is one that is unlawful or engaged in prohibited activities. The schemes described in this indictment constitute prohibited activities. This illicit enterprise existed separate and apart from the pattern of corrupt activity as described in this Indictment even if it did not do legal transactions during this period. Because of either one of these two situations, this Enterprise functioned as an organizational structure and as a continuing unit, even though it was engaging in the diverse forms of illegal activities as described in this Indictment. In either situation, the persons associated with the Enterprise participated in and/or managed the affairs of the Enterprise and as such provided continuity and structure to the Enterprise in order to accomplish its illegal purpose—the pattern of corrupt activity explained in the this count. This enterprise and the persons associated with in were joined in purpose over a period, although their various roles were different in order to accomplish the main purpose of the Enterprise. All these schemes were necessary to make the overall organization successful as an Enterprise engaged in corrupt activity. These activities occurred with the knowledge and/or support of and or were aided or abetted by each of the persons associated with the Enterprise.







of 22

D. AFFAIRS OF THE ENTERPRISE The affairs of the Enterprise involve the jurisdiction of the State of Ohio and took place in Cuyahoga County as well as in other counties and in other States and include but are not limited to:

1. MONEY LAUNDERING, R.C. 1355.15(A)(1): No person shall conduct or attempt to conduct a transaction knowing that the property involved in the transaction is the proceeds of some form of unlawful activity with the purpose of committing or furthering the commission of corrupt activity.

2. MONEY LAUNDERING, R.C. 1315.55(A)(3): No person shall conduct or attempt to conduct a

transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity.

3. TAMPERING WITH GOVERNMENT RECORDS, R.C. 2913.42(A)(1), (B)(4): No person, knowing

the person has no privilege to do so, and with purpose to defraud or knowing that the person is facilitating a fraud, shall falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record and the data, computer software, or record is kept or belongs to a local, state, or federal governmental entity.


the person has no privilege to do so, and with purpose to defraud or knowing that the person is facilitating a fraud, shall utter any writing or record, knowing it to have been tampered with as provided in division (A)(1) of this section, and the data, computer software, or record is kept or belongs to a local, state, or federal governmental entity.

5. FORGERY, R.C. 2913.31(A)(2): No person, with purpose to defraud, or knowing that the person

is facilitating a fraud, shall forge any writing so that it purports to be genuine when it is actually spurious, or to be the act of another who did not authorize that act, or to have been executed at a time or place with terms different from what in fact was the case, or to be a copy of an original when no such original existed, and the value of the property or services or the loss to the victim one thousand dollars or more but less than seven thousand five hundred dollars.

6. RECEIVING STOLEN PROPERTY, R.C. 2913.51(A): No person shall receive, retain, or dispose of

property of another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense.

7. THEFT, R.C. 2913.02(A)(1): No person, with purpose to deprive the owner of property, shall

knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent.

E. THE PATTERN OF CORRUPT ACTIVITY FROM APRIL 24, 2012 TO FEBRUARY 9, 2016. A "Pattern of corrupt activity" means two or more incidents of corrupt activity, whether or not there has been a prior conviction, that are related to the affairs of the same enterprise, are not isolated, and are not so closely related to each other and connected in time and place that they constitute a single event. On or about two or more occasions, person associated with the Enterprise directly or indirectly committed one or more of the following:







of 22


transaction knowing that the property involved in the transaction is the proceeds of some form of unlawful activity with the purpose of committing or furthering the commission of corrupt activity.


transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity.


the person has no privilege to do so, and with purpose to defraud or knowing that the person is facilitating a fraud, shall falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record and the data, computer software, or record, and the writing, computer software, data, or record and the data, computer software, or record is kept or belongs to a local, state, or federal governmental entity.


the person has no privilege to do so, and with purpose to defraud or knowing that the person is facilitating a fraud, shall utter any writing or record, knowing it to have been tampered with as provided in division (A)(1) of this section, and the data, computer software, or record is kept or belongs to a local, state, or federal governmental entity.

4. FORGERY, R.C. 2913.31(A)(2): No person, with purpose to defraud, or knowing that the person

is facilitating a fraud, shall forge any writing so that it purports to be genuine when it is actually spurious, or to be the act of another who did not authorize that act, or to have been executed at a time or place with terms different from what in fact was the case, or to be a copy of an original when no such original existed, and the value of the property or services or the loss to the victim one thousand dollars or more but less than seven thousand five hundred dollars.

5. RECEIVING STOLEN PROPERTY, R.C. 2913.51(A): No person shall receive, retain, or dispose of

property of another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense.

6. THEFT, R.C. 2913.02(A)(1): No person, with purpose to deprive the owner of property, shall

knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent.

F. INCIDENTS OF CORRUPT ACTIVITY — predicate acts The Grand Jury further finds that this Enterprise and the Persons Associated with the Enterprise were responsible for the above-mentioned pattern of corrupt activity with regard to the following property on the following dates. The Grand Jury further finds that the following incidents directly or indirectly affected the affairs of the Enterprise and occurred in Cuyahoga, Ashland, and/or Summit County, Ohio: MONEY LAUNDERING

1. On or about May 1, 2014, EDWARD M. LAWSON did conduct or attempt to conduct a transaction







of 22

knowing that the property involved in the transaction is the proceeds of some form of unlawful activity with the purpose of committing or furthering the commission of corrupt activity. (May 1, 2014 $1575 Payment to undercover Cleveland Police Officer for the processing of stolen automobiles)

2. On or about June 13, 2014, EDWARD M. LAWSON did conduct or attempt to conduct a

transaction knowing that the property involved in the transaction is the proceeds of some form of unlawful activity with the purpose of committing or furthering the commission of corrupt activity. (June 13, 2014 $1300 Payment to undercover Cleveland Police Officer for the processing of stolen automobiles)

3. On or about May 1, 2014, EDWARD M. LAWSON did conduct or attempt to conduct a transaction

with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity. (May 1, 2014 $1575 Payment to undercover Cleveland Police Officer for the processing of stolen automobiles)

4. On or about June 13, 2014, EDWARD M. LAWSON did conduct or attempt to conduct a

transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity. (June 13, 2014 $1300 Payment to undercover Cleveland Police Officer for the processing of stolen automobiles)

5. On or about May 1, 2014, LAWSON TOWING & AUTO WRECKING, LLC did conduct or attempt to

conduct a transaction knowing that the property involved in the transaction is the proceeds of some form of unlawful activity with the purpose of committing or furthering the commission of corrupt activity. (May 1, 2014 $1575 Payment to undercover Cleveland Police Officer for the processing of stolen automobiles)

6. On or about June 13, 2014, LAWSON TOWING & AUTO WRECKING, LLC did conduct or attempt

to conduct a transaction knowing that the property involved in the transaction is the proceeds of some form of unlawful activity with the purpose of committing or furthering the commission of corrupt activity. (June 13, 2014 $1300 Payment to undercover Cleveland Police Officer for the processing of stolen automobiles)

7. On or about May 1, 2014, LAWSON TOWING & AUTO WRECKING, LLC did conduct or attempt to

conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity. (May 1, 2014 $1575 Payment to undercover Cleveland Police Officer for the processing of stolen automobiles)

8. On or about June 13, 2014, LAWSON TOWING & AUTO WRECKING, LLC did conduct or attempt

to conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity. (June 13, 2014 $1300 Payment to undercover Cleveland Police Officer for the processing of stolen automobiles)

9. On or about November 20, 2013, ANGELA WILKES did conduct or attempt to conduct a transaction knowing that the property involved in the transaction is the proceeds of some form of unlawful activity with the purpose of committing or furthering the commission of corrupt







of 22

activity. (Submitting GEICO insurance claim for purportedly stolen 2006 Chrysler Pacifica which had already been crushed by EDWARD M. LAWSON)

10. On or about November 20, 2013, ANGELA WILKES did conduct or attempt to conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity. (Submitting GEICO insurance claim for purportedly stolen 2006 Chrysler Pacifica which had already been crushed by EDWARD M. LAWSON)

TAMPERING WITH GOVERNMENT RECORDS

11. On or about April 3, 2014, EDWARD M. LAWSON, knowing he has no privilege to do so, and with

purpose to defraud or knowing that he is facilitating a fraud, did falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record and the data, computer software, or record, to wit: 6 fraudulent automobile titles, and the writing, computer software, data, or record and the data, computer software, or record is kept or belongs to a local, state, or federal governmental entity. (April 3, 2014 receipt of 6 fraudulent automobile titles from undercover Cleveland Police Officer to Edward M. Lawson to present to metal processing facility for stolen automobiles)

12. On or about April 3, 2014, EDWARD M. LAWSON, knowing he has no privilege to do so, and with

purpose to defraud or knowing that he is facilitating a fraud, did utter any writing or record, to wit: 6 fraudulent automobile titles, knowing it to have been tampered with as provided in division (A)(1) of this section, and the data, computer software, or record is kept or belongs to a local, state, or federal governmental entity. (April 3, 2014 receipt of 6 fraudulent automobile titles from undercover Cleveland Police Officer to Edward M. Lawson to present to metal processing facility for stolen automobiles)

13. On or about April 3, 2014, LAWSON TOWING & AUTO WRECKING, LLC, knowing it has no

privilege to do so, and with purpose to defraud or knowing that it is facilitating a fraud, did falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record and the data, computer software, or record, to wit: 6 fraudulent automobile titles, and the writing, computer software, data, or record and the data, computer software, or record is kept or belongs to a local, state, or federal governmental entity. (April 3, 2014 receipt of 6 fraudulent automobile titles from undercover Cleveland Police Officer to Edward M. Lawson to present to metal processing facility for stolen automobiles)

14. On or about April 3, 2014, LAWSON TOWING & AUTO WRECKING, LLC, knowing it has no

privilege to do so, and with purpose to defraud or knowing that it is facilitating a fraud, did utter any writing or record, to wit: 6 fraudulent automobile titles, knowing it to have been tampered with as provided in division (A)(1) of this section, and the data, computer software, or record is kept or belongs to a local, state, or federal governmental entity. (April 3, 2014 receipt of 6 fraudulent automobile titles from undercover Cleveland Police Officer to Edward M. Lawson to present to metal processing facility for stolen automobiles)

15. On or about November 20, 2013, ANGELA WILKES, knowing she has no privilege to do so, and with purpose to defraud or knowing that she is facilitating a fraud, did falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record and the data,







of 22

computer software, or record, to wit: November 20, 2013 Akron Police Department Incident Report, and the writing, computer software, data, or record and the data, computer software, or record is kept or belongs to a local, state, or federal governmental entity. (November 20, 2013 Akron Police Department Report in which ANGELA WILKES reported her 2006 Chrysler Pacifica Stolen, despite the fact that it had been crushed by EDWARD M. LAWSON on October 31, 2013)

16. On or about November 20, 2013, knowing she has no privilege to do so, and with purpose to defraud or knowing that she is facilitating a fraud, did utter any writing or record, to wit: November 20, 2013 Akron Police Department Incident Report, knowing it to have been tampered with as provided in division (A)(1) of this section, and the data, computer software, or record is kept or belongs to a local, state, or federal governmental entity. (November 20, 2013 Akron Police Department Report in which ANGELA WILKES reported her 2006 Chrysler Pacifica Stolen, despite the fact that it had been crushed by EDWARD M. LAWSON on October 31, 2013)

FORGERY

17. On or about April 3, 2014, EDWARD M. LAWSON, with purpose to defraud, or knowing that he

is facilitating a fraud, did forge any writing so that it purports to be genuine when it is actually spurious, or to be the act of another who did not authorize that act, or to have been executed at a time or place with terms different from what in fact was the case, or to be a copy of an original when no such original existed, and the value of the property or services or the loss to the victim one thousand dollars or more but less than seven thousand five hundred dollars. (April 3, 2014 receipt of 6 fraudulent automobile titles from undercover Cleveland Police Officer to Edward M. Lawson to present to metal processing facility for stolen automobiles)

18. On or about April 3, 2014, LAWSON TOWING & AUTO WRECKING, LLC, with purpose to

defraud, or knowing that it is facilitating a fraud, did forge any writing so that it purports to be genuine when it is actually spurious, or to be the act of another who did not authorize that act, or to have been executed at a time or place with terms different from what in fact was the case, or to be a copy of an original when no such original existed, and the value of the property or services or the loss to the victim one thousand dollars or more but less than seven thousand five hundred dollars. (April 3, 2014 receipt of 6 fraudulent automobile titles from undercover Cleveland Police Officer to Edward M. Lawson to present to metal processing facility for stolen automobiles)

RECEIVING STOLEN PROPERTY

19. On or about April 24, 2012, EDDIE L. LAWSON did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (EDDIE L. LAWSON and MELVIN KING pulled over on I-71 in Ashland while attempting to steal convertor from disabled vehicle on highway, in possession of 12 cut convertors)

20. On or about April 24, 2012, MELVIN KING did receive, retain, or dispose of property of another

knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (EDDIE L. LAWSON and MELVIN KING pulled over on I-71 in Ashland while attempting to steal convertor from disabled vehicle on highway, in possession of







of 22

12 cut convertors) 21. On or about October 31, 2013 EDWARD M. LAWSON did receive, retain, or dispose of property

of another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (CPD search of LAWSON TOWING found stolen vehicles)

22. On or about October 31, 2013 LAWSON TOWING & AUTO WRECKING, LLC did receive, retain, or

dispose of property of another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (CPD search of LAWSON TOWING found stolen vehicles)

23. On or about February 4, 2014, EDDIE L. LAWSON did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (EDDIE L. LAWSON arrested in parking lot of GCRTA Triskett Station with 4 convertors while in process of stealing a fifth)

24. On or about April 20, 2014, DARRYL DOUGLAS did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (DARRYL DOUGLAS and GARY THOMPSON arrested on I-77 in Richfield while attempting to steal a convertor off a disabled vehicle with a cut convertor in the car)

25. On or about April 20, 2014 GARY THOMPSON did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (DARRYL DOUGLAS and GARY THOMPSON arrested on I-77 in Richfield while attempting to steal a convertor off a disabled vehicle with a cut convertor in the car)

26. On or about April 3, 2014 EDWARD M. LAWSON did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (CPD undercover officer recorded Lawson receiving five stolen vehicles to have processed for the officer)

27. On or about April 3, 2014 LAWSON TOWING & AUTO WRECKING, LLC did receive, retain, or

dispose of property of another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (CPD undercover officer recorded Lawson receiving five stolen vehicles to have processed for the officer)

28. On or about September 1, 2014, MELVIN KING did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (MELVIN KING and GARY G. THOMPSON arrested by CPD in process of stealing convertor from vehicle at Raindbow Motors, had 7 cut convertors in their vehicle)

29. On or about September 1, 2014, GARY G. THOMPSON did receive, retain, or dispose of property

of another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (MELVIN KING and GARY G. THOMPSON arrested by CPD in process of stealing convertor from vehicle at Raindbow Motors, had 7 cut convertors in their







of 22

vehicle) 30. On or about July 6, 2015, EDDIE L. LAWSON did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (video of EDDIE L. LAWSON in black Yukon Denali stealing scooter at GCRTA Westlake parking lot)

31. On or about December 16, 2015, MELVIN KING did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (KING, HARRIS, and MARCELLUS GRAYER stopped on I-71 in Ashland County in possession of 28 cut convertors)

32. On or about December 16, 2015, RANDY HARRIS did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (KING, HARRIS, and MARCELLUS GRAYER stopped on I-71 in Ashland County in possession of 28 cut convertors)

33. On or about January 27, 2016 MARCELLAR HARRIS did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (HARRIS and GRAYER were captured on video as they stole convertors from A-1 Auto in Cleveland)

34. On or about January 27, 2016 RANDY HARRIS did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (HARRIS and GRAYER were captured on video as they stole convertors from A-1 Auto in Cleveland)

35. On or about February 9, 2016, DARRYL DOUGLAS did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (DOUGLAS and MINGO arrested with 6 cut convertors in Solon following theft of two convertors nearby)

36. On or about February 9, 2016, JAMES MINGO did receive, retain, or dispose of property of

another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. (DOUGLAS and MINGO arrested with 6 cut convertors in Solon following theft of two convertors nearby)

THEFT

37. On or about April 24, 2012, EDDIE L. LAWSON did, with purpose to deprive the owner of

property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (EDDIE L. LAWSON and MELVIN KING pulled over on I-71 in Ashland while attempting to steal convertor from disabled vehicle on highway, in possession of 12 cut convertors)

38. On or about April 24, 2012, MELVIN KING did, with purpose to deprive the owner of property,

knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (EDDIE L. LAWSON and MELVIN KING pulled over on I-71 in







of 22

Ashland while attempting to steal convertor from disabled vehicle on highway, in possession of 12 cut convertors)

39. On or about February 4, 2014, EDDIE L. LAWSON did, with purpose to deprive the owner of

property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (EDDIE L. LAWSON arrested in parking lot of GCRTA Triskett Station with 4 convertors while in process of stealing a fifth)

40. On or about April 20, 2014, DARRYL DOUGLAS did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (DARRYL DOUGLAS and GARY G. THOMPSON arrested on I-77 in Richfield while attempting to steal a convertor off a disabled vehicle with a cut convertor in the car)

41. On or about April 20, 2014, GARY THOMPSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (DARRYL DOUGLAS and GARY G. THOMPSON arrested on I-77 in Richfield while attempting to steal a convertor off a disabled vehicle with a cut convertor in the car)

42. On or about September 19, 2014 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of black Yukon Denali in Cleveland Clinic parking lot parked next to a catalytic converter theft)

43. On or about September 24, 2014 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of black Yukon Denali in parking lot of Lorain County Community College at the time of three catalytic converters thefts)

44. On or about October 1, 2014 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of black Yukon Denali in Cleveland Clinic parking lot parked next to a catalytic converter theft)

45. On or about October 8, 2014 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of Lawson and black Yukon Denali with license plate GDW1220 in Yorktown Lanes parking lot parked next to catalytic converter theft)

46. On or about October 10, 2014 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of black Yukon Denali in Brooklyn parking lot at the time of a catalytic converter theft)

47. On or about May 26, 2015 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of black Yukon Denali in Bath parking lot at 260 Springside Dr. during a catalytic converter theft)







of 22



50. On or about May 26, 2015 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (witness stated two black males in a black Yukon Denali in North Olmsted parking lot at Corporate Center during a catalytic converter theft)

51. On or about June 26, 2015 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (witnesses stated two black males in a black Yukon Denali with license plate number GDW1220 in Avon parking lot at Suretech parked next to victim’s car during a catalytic converter theft)

52. On or about July 6, 2015 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of Lawson in black Yukon Denali stealing scooter at GCRTA Westlake parking lot)

53. On or about September 30, 2015, EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of black Yukon Denali parked next to damaged Accord in Richfield)

54. On or about September 30, 2015, EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of black Yukon Denali parked next to damaged Odyssey in Richfield)

55. On or about September 30, 2015, EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of black Yukon Denali parked next to damaged Accord in Richfield)

56. On or about November 16, 2015 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of black Yukon Denali in parking lot of GCRTA Woodhill-Buckeye Station during catalytic converter theft)

57. On or about February 5, 2016 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of black Yukon Denali in Beachwood parking lot







of 22

during theft of trailer containing snow removal equipment)

58. On or about February 9, 2016 EDDIE L. LAWSON did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (black Yukon Denali in Westlake parking lot during theft of trailer containing landscaping equipment)

59. On or about December 16, 2015 MELVIN KING did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (stopped on I-71N with Grayer and Harris possessing 28 catalytic converters and criminal tools)

60. On or about December 16, 2015 MARCELLAR GRAYER did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (stopped on I-71N with King and Harris possessing 28 catalytic converters and criminal tools)

61. On or about December 16, 2015 RANDY HARRIS did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (stopped on I-71N with King and Grayer possessing 28 catalytic converters and criminal tools)

62. On or about January 27, 2016 MARCELLAR GRAYER did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (HARRIS and GRAYER captured on video climbing a fence and stealing eight catalytic converters from the parking lot of A-1 United Auto)

63. On or about January 27, 2016 RANDY HARRIS did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of two individuals climbing a fence and stealing eight catalytic converters from the parking lot of A-1 United Auto)

64. On or about February 9, 2016 DARRYL DOUGLAS did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of maroon Chevy Cruze parked next to damaged Chevrolet S-10 in Bird Technologies parking lot in Solon)

65. On or about February 9, 2016 DARRYL DOUGLAS did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of maroon Chevy Cruze parked next to damaged Acura in Bird Technologies parking lot in Solon)

66. On or about February 9, 2016 JAMES MINGO did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of maroon Chevy Cruze parked next to damaged Chevrolet S-10 in Bird Technologies parking lot in Solon)

67. On or about February 9, 2016 JAMES MINGO did, with purpose to deprive the owner of property, knowingly obtain or exert control over the property without the consent of the owner or person authorized to give consent. (video of maroon Chevy Cruze parked next to damaged







of 22

Acura in Bird Technologies parking lot in Solon)

Forfeiture of Property - §2941.1417(A)

The Grand Jurors further find and specify that

the defendant(s) is/are the owner(s) and/or possessor(s) of 1) 2001 Nissan Sentra, VIN No. 3N1CB51D21L447037; 2) 2004 Chrysler Sebring, VIN No. 1C3EL46X04N409234; 3) 1995

Oldsmobile Cutlass Ciera, VIN No. 1G3AJ55M4S6404879; 4) 2006 Chrysler Pacifica, VIN No. 2A4GM68456R749690; 5) 1990 BMW, VIN No. WBAHC2302LBE25388; 6) 2001 Jeep Cherokee, VIN No. 1J4FF48S31L630708; 7) 1998 Buick Century, VIN No. 2G4WS52MXW1451866; 8) 1987 Cadillac Sedan de Ville, VIN No. 1G6CD518XH4224127; 9) 1998 CAT Excavator, VIN No.

6CR03345; 10) Craftsman Air Compressor, Ser. # 919165406; 11) Generac Generator GP55OP, Ser. # T56012070031961; 12) Coleman Generator Powermate 8000, Ser. # E18710524; 13) White steel shed with miscellaneous tools and equipment; 14) Maverick 12-guage shotgun, Ser. # MV38317K;

15) Glock model 22 pistol, 40 caliber, Ser. # TPG808; 16) LG flat screen TV, Ser. # MXBP12469; 17) Visio flat screen TV, Ser. # LWJSNKBN4202047; and 18) Network DVR H.264 which is contraband and/or property derived from or through the commission or facilitation of an offense, and/or is an instrumentality the offender(s) used or intended to use in the commission or facilitation

of a felony offense.

The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of

Ohio.

Count Two Conspiracy - F2

§2923.01(A)(1)

Defendants Eddie Lawson, Edward Lawson, Lawson Towing And Auto Wrecking Llc, Marcellar G. Grayer, Randy Harris, Gary G. Thompson Jr., James D. Mingo,

Angela Wilkes, Melvin King, Deshawn Darryl Douglas

Date of Offense On or about April 24, 2012 to February 9, 2016

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

with purpose to commit or to promote or facilitate the commission of Engaging In a Pattern of Corrupt Activity in violation of R.C. 2923.32(A)(1) did, with another person or persons, plan or aid in planning the commission of Engaging in a Pattern of Corrupt Activity in violation of R.C. 2923.32(A)(1), and in furtherance of the conspiracy did undertake substantive overt acts, to wit: On or about or about April 24, 2012 to February 9, 2016 the common purpose of the Enterprise regarding its ongoing illegal conduct was for defendants EDDIE L. LAWSON, MELVIN KING, DARRYL DOUGLAS, MARCELLAR GRAYER and RANDY HARRIS to steal catalytic converters from anonymous vehicles throughout Northeast Ohio, provide them to LAWSON TOWING & AUTO WRECKING, LLC and/or EDWARD M. LAWSON ("Wink"), have EDWARD M. LAWSON sell those stolen catalytic converters to metal recycling facilities as a "scrap metal dealer" under R.C. 4737.04, and then reimburse the original catalytic converter thief with the proceeds of the sale to the metal recycling facility. LAWSON TOWING & AUTO WRECKING, LLC and/or EDWARD M. LAWSON ("Wink") also purchased purportedly stolen cars from an undercover Cleveland Police Officer and used purportedly fraudulent titles to convey the cars to a metal recycling facility, after which he reimbursed the undercover Cleveland Police Officer with the proceeds of the sale.







of 22

LAWSON TOWING AND AUTO WRECKING LLC and EDWARD M. LAWSON Laundered Money Tampered with Government Records, Forged automobile titles, and Received Stolen Property; EDDIE L. LAWSON Received Stolen Property and committed Theft; DARRY DOUGLAS Received Stolen Property and committed Theft; MELVIN KING Received Stolen Property and committed Theft; RANDY HARRIS Received Stolen Property and committed Theft; MARCELLAR GRAYER Received Stolen Property and committed Theft; James Mingo Received Stolen Property and committed Theft; ANGELA WILKES committed money laundering and tampering with government records.

FURTHERMORE, and the object of the conspiracy was a felony of the first degree, to wit: LAWSON TOWING AND AUTO WRECKING LLC EDWARD M. LAWSON, EDDIE L. LAWSON, MELVIN KING, DARRYL DOUGLAS, JAMES MINGO, MARCELLAR GRAYER, RANDY HARRIS, and ANGELA WILKES did being employed by, or associated with, any enterprise conduct or participate in, directly or indirectly, the affairs of the enterprise through a pattern of corrupt activity when at least one incident of corrupt activity was a felony of the first, second or third degree; their conduct being Engaging in a Pattern of Corrupt Activity in violation of R.C. 2923.32(A)(1) and 2923.32(B)(1).

Forfeiture of Property - §2941.1417(A)

The Grand Jurors further find and specify that

the defendant(s) is/are the owner(s) and/or possessor(s) of 1) 2001 Nissan Sentra, VIN No.

3N1CB51D21L447037; 2) 2004 Chrysler Sebring, VIN No. 1C3EL46X04N409234; 3) 1995 Oldsmobile Cutlass Ciera, VIN No. 1G3AJ55M4S6404879; 4) 2006 Chrysler Pacifica, VIN No. 2A4GM68456R749690; 5) 1990 BMW, VIN No. WBAHC2302LBE25388; 6) 2001 Jeep Cherokee, VIN No. 1J4FF48S31L630708; 7) 1998 Buick Century, VIN No. 2G4WS52MXW1451866; 8) 1987

Cadillac Sedan de Ville, VIN No. 1G6CD518XH4224127; 9) 1998 CAT Excavator, VIN No. 6CR03345; 10) Craftsman Air Compressor, Ser. # 919165406; 11) Generac Generator GP55OP, Ser.

# T56012070031961; 12) Coleman Generator Powermate 8000, Ser. # E18710524; 13) White steel

shed with miscellaneous tools and equipment; 14) Maverick 12-guage shotgun, Ser. # MV38317K; 15) Glock model 22 pistol, 40 caliber, Ser. # TPG808; 16) LG flat screen TV, Ser. # MXBP12469; 17) Visio flat screen TV, Ser. # LWJSNKBN4202047; and 18) Network DVR H.264 which is contraband and/or property derived from or through the commission or facilitation of an offense,

and/or is an instrumentality the offender(s) used or intended to use in the commission or facilitation of a felony offense.


Ohio.

Count Three Money Laundering - F3

§1315.55(A)(1)

Defendants Edward Lawson, Lawson Towing And Auto Wrecking Llc

Date of Offense On or about May 1, 2014


did conduct or attempt to conduct a transaction knowing that the property involved in the transaction

was the proceeds of some form of unlawful activity with the purpose of committing or furthering the







of 22

commission of corrupt activity.


Ohio.

Count Four Money Laundering - F3

§1315.55(A)(3)


Date of Offense On or about May 1, 2014


did conduct or attempt to conduct a transaction with the purpose to promote, manage, establish, carry

on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity.


Ohio.

Count Five Money Laundering - F3

§1315.55(A)(1)


Date of Offense On or about June 13, 2014


did conduct or attempt to conduct a transaction knowing that the property involved in the transaction was the proceeds of some form of unlawful activity with the purpose of committing or furthering the



Ohio.

Count Six Money Laundering - F3

§1315.55(A)(3)


Date of Offense On or about June 13, 2014


did conduct or attempt to conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity.


Ohio.







of 22

Count Seven Tampering with Records - F3

§2913.42(A)(1)


Date of Offense On or about April 3, 2014


did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on the State of Ohio, falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: 6 fraudulent automobile titles, and the

writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity.


Ohio.

Count Eight Tampering with Records - F3

§2913.42(A)(2)




did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on the State of Ohio, utter a writing or record, to wit: 6 fraudulent automobile

titles, knowing it to have been tampered with as provided in division (A)(1) of this section and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal

governmental entity.


Ohio.

Count Nine Forgery - F5

§2913.31(A)(2)




with purpose to defraud, or knowing that he is facilitating a fraud on the State of Ohio, did forge any writing, to wit: 6 fraudulent automobile titles, so that it purports to be genuine when it actually is spurious, or to be the act of another who did not authorize that act, or to have been executed at a time

or place or with terms different from what in fact was the case, or to be a copy of an original when no such original existed.


Ohio.







of 22

Count Ten Receiving stolen property - F4

§2913.51(A)


Date of Offense On or about October 31, 2013


did receive, retain, or dispose of 1995 Oldsmobile Cutlass Ciera, VIN 1G3AJ55M4S6404879, the property of Jasmine F. Brown, knowing or having reasonable cause to believe that the property had been obtained through commission of a theft offense and the property involved was a motor vehicle.


Ohio.

Count Eleven Receiving stolen property - F4

§2913.51(A)




did receive, retain, or dispose of 1987 Cadillac DeVille, VIN 1G6CD518XH4224127, the property of Charles Manning, knowing or having reasonable cause to believe that the property had been obtained through commission of a theft offense and the property involved was a motor vehicle.


Ohio.

Count Twelve Receiving stolen property - F4

§2913.51(A)




did receive, retain, or dispose of 2001 Jeep Cherokee, VIN 1JFFF48S31L630708, the property of

Carolyn Commons-Skubon, knowing or having reasonable cause to believe that the property had

been obtained through commission of a theft offense and the property involved was a motor vehicle.


Ohio.

Count Thirteen Motor Vehicle Certificate of Title Offenses - UF

§4505.19(A)(3)









of 22


did, with intent to defraud, possess, sell, offer to sell, counterfeit, or supply a blank, forged, fictitious, counterfeit, stolen, or fraudulently or unlawfully obtained certificate of title, registration,

bill of sale, or other instruments of ownership of a motor vehicle or conspire to commit an act under Section 4504.19(A)(1) through (2) of the Revised Code.


Ohio.

Count Fourteen Money Laundering - F3

§1315.55(A)(1)

Defendants Angela Wilkes

Date of Offense On or about November 20, 2013


did conduct or attempt to conduct a transaction knowing that the property involved in the transaction was the proceeds of some form of unlawful activity with the purpose of committing or furthering the



Ohio.

Count Fifteen Money Laundering - F3

§1315.55(A)(3)




did conduct or attempt to conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity.


Ohio.

Count Sixteen Tampering with Records - F3

§2913.42(A)(1)




did, knowing she had no privilege to do so, and with purpose to defraud or knowing she was facilitating a fraud on Akron Police Department, falsify, destroy, remove, conceal, alter, deface, or

mutilate any writing, computer software, data, or record, to wit: November 20, 2013 Akron Police

Department Report, and the writing, data, computer software, or record was kept by or belonged to a







of 22

local, state, or federal governmental entity.


Ohio.

Count Seventeen Tampering with Records - F3

§2913.42(A)(2)




did, knowing she had no privilege to do so, and with purpose to defraud or knowing she was

facilitating a fraud on Akron Police Department, utter a writing or record, to wit: November 20, 2013 Akron Police Department Report, knowing it to have been tampered with as provided in division (A)(1) of this section and the writing, data, computer software, or record was kept by or belonged to

a local, state, or federal governmental entity.


Ohio.

cuyahoga county court of common...

Documents