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<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 1 of 108
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
VS. §2923.32(A)(1)
35 Defendants 257 Additional Count(s)
Defendants
Evelyn Cruz, Juan Cuevas, Christina Lozada, Xavier Hernandez, Jose Martinez, Juan Martinez, Lina Martinez, Victor
Padilla, Miriam Ramos, Juan Rodriguez, Erickson Ramos, Francisco Santiago, Lizmarie Torres-Bruno, Carlos Pagan,
Jonathan Musse, Ivan Pietri, Luis Cuevas, Alberto Pietri Jr., Sally Ortiz, Javier Millan, Jonathan Ortiz, Michael Ferguson,
Jose Vega, Edwin Mendez, Jose Trujillo, Juan Rivera, Javier Flores, Marilyn Rodriguez, Juan Hernandez, Auri Pietri, James
Lyle, Alberto Pietri, Jose Ramos, Carlos Sanchez, Manuel Vasquez
Dates of Offense (on or about) The Term Of Case Number
07/01/2007 to 04/29/2011 May of 2011 549476-11-CR
The State of Ohio, }
SS.
Cuyahoga County
Count 1 Engaging In A Pattern Of Corrupt Activity
§2923.32(A)(1)
Defendants Evelyn Cruz, Juan Cuevas, Christina Lozada, Xavier Hernandez, Jose Martinez,
Juan Martinez, Lina Martinez, Victor Padilla, Juan Rodriguez, Francisco Santiago,
Lizmarie Torres-Bruno, Carlos Pagan, Ivan Pietri, Luis Cuevas, Alberto Pietri Jr.,
Sally Ortiz, Javier Millan, Jose Vega, Edwin Mendez, Jose Trujillo, Marilyn
Rodriguez, Juan Hernandez, Auri Pietri, Jose Ramos
Date of Offense On or about July 1, 2007 to April 29, 2011
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
On or between the 1st day of July, 2007, and the 29
th day of April, 2011, in the County of
Cuyahoga, State of Ohio, or by some manner enumerated in Section 2901.12 of the Revised
Code whereby proper venue is placed in Cuyahoga County, DEFENDANTS, were associated
with an Enterprise, as defined in Section 2923.31(C) of the Revised Code.
This Enterprise is an “illicit enterprise” under O.R.C. 2932.22, whether or not this Enterprise
existed separate and apart from the pattern of corrupt activity described in this Indictment.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 2 of 108
This Enterprise functioned as a continuing unit by engaging in the diverse forms of illegal
activities, as stated in this Indictment. In so doing, the DEFENDANTS NAMED BELOW
are persons associated with the Enterprise who participated in and/or managed the affairs of
the Enterprise, as explained in this Indictment. As such, these persons provided continuity
and structure to the Enterprise in order to accomplish its illegal purposes – the pattern of
corrupt activity, to wit: 1) the theft of motor vehicles, and/or the acquisition or receipt of
previously stolen vehicles, for the purpose of transferring of Vehicle Identification Numbers
(VINs) and/ or valuable parts of those stolen vehicles to other, legitimately acquired vehicles
or frames for the purpose of reselling newly created vehicles under a “legitimate” vehicle
title, and 2) the possession and use of equipment, devices, instruments, and/or money
illegally as a result of, and in furtherance of the above activity as explained in this Indictment.
This Enterprise and the Persons Associated with the Enterprise were joined in purpose over a
period of time, although their various roles were different in order to accomplish the main
purposes of the Enterprise. These activities occurred with the knowledge and/or support of
and/or were aided and abetted by each of the persons associated with the Enterprise.
The Enterprise in this matter consisted of: Evelyn Cruz, Juan Cuevas, Christina Lozada, Xavier Hernandez, Jose Martinez, Juan Martinez, Lina Martinez, Victor Padilla, Juan Rodriguez, Francisco Santiago, Lizmarie Torres-Bruno, Carlos Pagan, Ivan Pietri, Luis Cuevas, Alberto Pietri Jr., Sally Ortiz, Javier Millan, Jose Vega, Edwin Mendez, Jose Trujillo, Marilyn Rodriguez, Juan Hernandez, Auri Pietri, Jose Ramos, and others yet
unknown, each of whom did conduct or participate in, directly or indirectly, the affairs of said
enterprise, to-wit: a group of persons “associated in fact” for the purposes of engaging in,
THEFT, RECEIVING STOLEN PROPERTY, TELECOMMUNICATIONS FRAUD, and
TAMPERING WITH GOVERNMENT RECORDS, through a pattern of corrupt activity as
defined in Section 2923.31(I)(2)(a) or (I)(2)(c) of the Revised Code, the predicate acts
constituting the pattern of corrupt activity as defined in Section 2923.31(E) of said enterprise,
which include criminal violations of Ohio Revised Code TITLE 29, Theft,
Telecommunications Fraud, Involuntary Manslaughter, and Tampering with Government
Records, as alleged in the following COUNTS FOUR through TWO HUNDRED FIFTY-
EIGHT of the indictment and are alleged as Predicate Acts, which are incorporated herein as
if fully restated, as well as other related acts of Theft, Receiving Stolen Property,
Telecommunications Fraud, and Tampering with Government Records.
Furthermore, pursuant to Section 2923.32(B)(1), at least one of the incidents of corrupt
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 3 of 108
activity, as defined in Section 2923.31(I)(2)(a) or (I)(2)(c) is a felony of the third degree or
higher (any and all counts of Tampering with Government Records), contrary to and in
violation of Section 2923.32(A)(1) of the Ohio Revised Code, and thereby, this COUNT
ONE, Engaging in a Pattern of Corrupt Activity, constitutes a Felony of the First degree,
contrary to and in violation of the Ohio Revised Code, Title 29, in 2923.32(A)(1) and against
the peace and dignity of the State of Ohio.
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 the following 62 motor vehicles which are
contraband and/or property derived from or through the commission or facilitation of an offense,
and/or instrumentalities the offender(s) used or intended to use in the commission or facilitation of a
felony offense.
LastName FirstName DOB Type Year Make Model Color VehicleVIN
Cruz Evelyn 14-Sep-
78 1994 JEEP 1J4FT68S3RL206316
Cuevas Juan 27-Aug-
88 Auto 1991 HONDA 2dr RED 2HGED6347MH515222
Cuevas Juan 27-Aug-
88 1992 HONDA 1HGEG8658NL034830
Ferguson Michael 23-Oct-
89 Auto 1993 HONDA 2 dr. PURPLE 2HGEJ2145PH505538
Flores Javier 26-Jul-76 1981 TOYOTA JT2KP61G9B5559905
Hernandez Xavier 25-Feb-
90 Auto 2000 HONDA 1HGEM1151YL00570
Hernandez Xavier 25-Feb-
90 Auto 1999 HONDA 2HGEJ6329XH100902
Lozada Christina 14-Mar-
90 Auto 2002 MAZDA Hatchback BLACK JM1BJ246421471372
Lyle James 18-Dec-
75 Auto 1999 OLDSMOBILE 1G3NF12E9XC336211
Lyle James 18-Dec-
75 Auto 1996 OLDSMOBILE 1GHDT13W0T2711781
Lyle James 18-Dec-
75 Auto 1992 HONDA 1HGEG8643NL006411
Lyle James 18-Dec-
75 Auto 1996 GMC SW RED 1GKEK13R0Tj702533
Lyle James 18-Dec-
75 Auto 1996 FORD 1FMDU34X9TZA12335
Martinez Juan 05-Mar-
89 Auto 1998 CHEVROLET 4 dr. GREEN 1G1NE52M2WY158816
Martinez Lina 14-Jul-85 Auto 1991 HONDA 2HGED6343MH558813
Martinez Lina 14-Jul-85 Auto 2001 NISSAN 4 Dr. GREEN 1N4DL01D41C115457
Martinez Lina 14-Jul-85 Auto 1990 HONDA 1HGCB7655LA087381
Martinez Lina 14-Jul-85 Auto 1996 FORD 1FALP6530TK199483
Martinez Lina 14-Jul-85 Auto 1993 MAZDA JM1EC4324P0216994
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 4 of 108
Mendez Edwin 27-Apr-
68 Auto 2000 Honda 1HGEM115XYL029513
Mendez Edwin 27-Apr-
68 Auto 2000 HONDA Civic BLACK 2HGEJ6345YH109180
Mendez Edwin 27-Apr-
68 Auto 1992 HONDA 2HGEH2345NH530560
Musse Jonathan 11-Dec-
78 Auto 2001 TOYOTA 4 dr. SILVER JTDBT123710100420
Musse Jonathan 11-Dec-
78 Auto 1994 ACURA Hatchback GREEN JH4DC4452RS037282
Ortiz Jonathan 01-Dec-
81 1989 HONDA 1HGED3553KA055086
Ortiz Sally 03-Jan-
69 1997 HONDA JHMEJ6576VS022607
Padilla Victor 19-Sep-
86 1991 HONDA 2HGED7369MH528593
Padilla Victor 19-Sep-
86 1993 HONDA Civic SI HB BLACK 2HGEH338XPH518187
Pagan Carlos 03-Nov-
86 1991 MITSUBISHI 4A3CS55U3ME110614
Pagan Carlos 03-Nov-
86 1988 HONDA 1HGCA6166JA022033
Pietri Auri 10-Apr-
79 1986 OLDSMOBILE 1G3GM47Y9GP310431
Pietri Auri 10-Apr-
79 1989 FORD 1FTEF14N1KLB09987
Pietri Auri 10-Apr-
79 1995 HONDA Hatchback RED 2HGEH2368SH513510
Pietri Auri 10-Apr-
79 1996 HONDA 1HGEJ6578TL013854
Pietri Jr. Alberto 17-Aug-
92 Auto 1994 HONDA Hatchback RED 2HGEH2369RH512876
Pietri Jr. Alberto 17-Aug-
92 Auto 1999 HONDA 2 dr. DARK GREEN 1HGEJ612XXL012544
Pietri Sr. Alberto 05-Aug-
73 1985 TOYOTA JT2AE86S5F0150927
Pietri Sr. Alberto 05-Aug-
73 1989 CHRYSLER JJ3CC54N8KZ032246
Pietri Sr. Alberto 05-Aug-
73 1978 DATSUN WHLA10016880
Ramos Erickson 21-Jul-92 Auto 1990 ACURA 4 dr. GRAY JH4DB1666LS007779
Ramos Erickson 21-Jul-92 1986 SUNBIRD SB208036G586
Ramos Jose 06-Oct-
84 Auto 1989 HONDA Hatchback GRAY 2HGED6359KH521688
Ramos Jose 06-Oct-
84 1993 CHEVROLET 1Y1SK5369PZ050784
Rodriguez Juan 17-Dec-
89 1988 TOYOTA 4T2ST68M7J0005300
Rodriguez Juan 17-Dec-
89 1992 MAZDA JM1EC4329N0121828
Rodriguez Juan 17-Dec-
89 SUV 1997 DODGE SW WHITE 2B4GP44R8VR101582
Rodriguez Marilyn 01-Jan-
73 Auto 2007 BMW 4 dr. SILVER WBAVC93537K030114
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 5 of 108
Rodriguez Marilyn 01-Jan-
73 2002 YAMAHA JY4AB02Y82C008526
Rodriguez Marilyn 01-Jan-
73 1995 ACURA JH4KA7668SC004839
Rodriguez Marilyn 01-Jan-
73 2003 KAWASAKI JKBKXEAC33A031905
Rodriguez Marilyn 01-Jan-
73 1988 JEEP 2BCCZ8147JB508129
Rodriguez Marilyn 01-Jan-
73 2001 YAMAHA JYACE08C31A004094
Rodriguez Marilyn 01-Jan-
73 Auto 1998 HONDA 2 dr. RED 1HGEJ8242WL005484
Rodriguez Marilyn 01-Jan-
73 Auto 1999 HONDA 4 dr. GREEN 2HGEJ6612XH538891
Sanchez Carlos 17-Aug-
81 1990 EGIL 4E3CT64UXLE153148
Santiago Francisco 05-Apr-
87 1985 AMC 1XMAC9768FK164101
Santiago Francisco 05-Apr-
87 Auto 1991 CHEVROLET 4 dr. MAROON 1G1BL53E9MW146431
Torres (Bruno) Lizmarie
31-Jan-74 SUV 1997 FORD expedition
DARK GREEN 1FMFU18L7VLA33999
Torres (Bruno) Lizmarie
31-Jan-74 1987 CHEVROLET 2GBEG25K8H4114581
Trujillo Jose 26-Dec-
73 1990 CHEVROLET 1G1JF14T8L7145580
Vega Jose 05-May-
87 Auto 1998 HONDA 4 dr. SILVER 1HGEJ8545WL024221
Vega Jose 05-May-
87 1999 HONDA 2HKRL1853XH500669
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 2 Conspiracy
§2923.01(A)(1)
Defendants Evelyn Cruz, Juan Cuevas, Christina Lozada, Xavier Hernandez, Jose Martinez,
Juan Martinez, Lina Martinez, Victor Padilla, Miriam Ramos, Juan Rodriguez,
Erickson Ramos, Francisco Santiago, Lizmarie Torres-Bruno, Carlos Pagan,
Jonathan Musse, Ivan Pietri, Luis Cuevas, Alberto Pietri Jr., Sally Ortiz, Javier
Millan, Jonathan Ortiz, Michael Ferguson, Jose Vega, Edwin Mendez, Jose
Trujillo, Juan Rivera, Javier Flores, Marilyn Rodriguez, Juan Hernandez, Auri
Pietri, James Lyle, Alberto Pietri, Jose Ramos, Carlos Sanchez, Manuel Vasquez
Date of Offense On or about January 1, 2008 to March 22, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 6 of 108
did, with purpose to commit or promote or facilitate the commission of Engaging in a Pattern of
Corrupt Activity, O.R.C. 2923.32(A)(1), plan or aid in planning the commission of the specified
offense with another person or persons, Evelyn Cruz, Juan Cuevas, Christina Lozada, Xavier
Hernandez, Jose Martinez, Juan Martinez, Lina Martinez, Victor Padilla, Juan Rodriguez, Francisco
Santiago, Lizmarie Torres-Bruno, Carlos Pagan, Ivan Pietri, Luis Cuevas, Alberto Pietri Jr., Sally
Ortiz, Javier Millan, Jose Vega, Edwin Mendez, Jose Trujillo, Marilyn Rodriguez, Juan Hernandez,
Auri Pietri, Jose Ramos, to wit: the theft of motor vehicles, and/or the acquisition or receipt of
previously stolen vehicles, for the purpose of transferring of Vehicle Identification Numbers (VINs)
and/ or valuable parts of those stolen vehicles to other, legitimately acquired vehicles or frames for
the purpose of reselling newly created vehicles under "legitimate" vehicle titles.
FURTHERMORE, and the object of the conspiracy was a felony of the first degree.
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 3 Conspiracy
§2923.01(A)(2)
Defendants Evelyn Cruz, Juan Cuevas, Christina Lozada, Xavier Hernandez, Jose Martinez,
Juan Martinez, Lina Martinez, Victor Padilla, Miriam Ramos, Juan Rodriguez,
Erickson Ramos, Francisco Santiago, Lizmarie Torres-Bruno, Carlos Pagan,
Jonathan Musse, Ivan Pietri, Luis Cuevas, Alberto Pietri Jr., Sally Ortiz, Javier
Millan, Jonathan Ortiz, Michael Ferguson, Jose Vega, Edwin Mendez, Jose
Trujillo, Juan Rivera, Javier Flores, Marilyn Rodriguez, Juan Hernandez, Auri
Pietri, James Lyle, Alberto Pietri, Jose Ramos, Carlos Sanchez, Manuel Vasquez
Date of Offense On or about January 1, 2008 to March 22, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to commit or promote or facilitate the commission of Engaging in a Pattern of
Corrupt Activity, O.R.C. 2923.32(A)(1), agree with another person or persons, Evelyn Cruz, Juan
Cuevas, Christina Lozada, Xavier Hernandez, Jose Martinez, Juan Martinez, Lina Martinez, Victor
Padilla, Juan Rodriguez, Francisco Santiago, Lizmarie Torres-Bruno, Carlos Pagan, Ivan Pietri, Luis
Cuevas, Alberto Pietri Jr., Sally Ortiz, Javier Millan, Jose Vega, Edwin Mendez, Jose Trujillo,
Marilyn Rodriguez, Juan Hernandez, Auri Pietri, Jose Ramos, that one or more of them would
engage in conduct that would facilitate the commission of the specified offense, to wit: the theft of
motor vehicles, and/or the acquisition or receipt of previously stolen vehicles, for the purpose of
transferring of Vehicle Identification Numbers (VINs) and/ or valuable parts of those stolen vehicles
to other, legitimately acquired vehicles or frames for the purpose of reselling newly created vehicles
under "legitimate" vehicle titles.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 7 of 108
FURTHERMORE, and the object of the conspiracy was a felony of the first degree.
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 4 Involuntary Manslaughter
§2903.04(A)
Defendants Victor Padilla, Juan Hernandez
Date of Offense On or about April 2, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did cause the death of Calvin McMahan and such death was the proximate result of Victor Padilla
and/or Juan Hernandez committing or attempting to commit the felony offense of O.R.C. 2913.02
Theft of a Motor vehicle.
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 5 Involuntary Manslaughter
§2903.04(A)
Defendants Victor Padilla, Juan Hernandez
Date of Offense On or about April 2, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did cause the death of Kelvin Pontajas and such death was the proximate result of Victor Padilla
and/or Juan Hernandez committing or attempting to commit the felony offense of O.R.C. 2913.02
Theft of a Motor vehicle.
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 6 Telecommunications Fraud
§2913.05(A)
Defendants Victor Padilla
Date of Offense On or about October 1, 2010 to October 24, 2010
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 8 of 108
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 7 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Victor Padilla
Date of Offense On or about October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or re-
tagged dashboard VIN with knowledge that the vehicle identification number or a derivative of the
vehicle identification number had been removed, defaced, covered, altered, or destroyed in such a
manner that the identity of the vehicle or part could not be determined by a visual examination of the
number at the site where the manufacturer placed the number.
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 8 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Victor Padilla
Date of Offense On or about October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or re-
tagged door-sticker VIN with knowledge that the vehicle identification number or a derivative of the
vehicle identification number had been removed, defaced, covered, altered, or destroyed in such a
manner that the identity of the vehicle or part could not be determined by a visual examination of the
number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 9 of 108
Count 9 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Victor Padilla
Date of Offense On or about October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or re-
tagged firewall VIN with knowledge that the vehicle identification number or a derivative of the
vehicle identification number had been removed, defaced, covered, altered, or destroyed in such a
manner that the identity of the vehicle or part could not be determined by a visual examination of the
number at the site where the manufacturer placed the number.
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 10 Receiving stolen property
§2913.51(A)
Defendants Victor Padilla
Date of Offense On or about October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of 2003 Chrysler Town & Country minivan, VIN:
2C4GP44L63R103293, the property of Javier Umanzor, 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.
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 11 Tampering with Records
§2913.42(A)(2)
Defendants Victor Padilla
Date of Offense On or about March 19, 2010 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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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.
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 12 Telecommunications Fraud
§2913.05(A)
Defendants Victor Padilla
Date of Offense On or about February 9, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 13 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Victor Padilla
Date of Offense On or about February 19, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 11 of 108
Count 14 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Victor Padilla
Date of Offense On or about February 19, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or re-
tagged door-sticker VIN with knowledge that the vehicle identification number or a derivative of the
vehicle identification number had been removed, defaced, covered, altered, or destroyed in such a
manner that the identity of the vehicle or part could not be determined by a visual examination of the
number at the site where the manufacturer placed the number.
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 15 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Victor Padilla
Date of Offense On or about February 19, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall), remove, deface, cover, alter, or destroy any identifying number that was lawfully
placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than the
manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 16 Receiving stolen property
§2913.51(A)
Defendants Victor Padilla
Date of Offense On or about February 9, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1997 Acura Integra hatchback (red), VIN: JHDC2386V001573,
the property of Daniel Kozdron, knowing or having reasonable cause to believe that the property had
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 12 of 108
been obtained through commission of a theft offense and the property involved was a motor vehicle.
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 17 Tampering with Records
§2913.42(A)(2)
Defendants Victor Padilla
Date of Offense On or about February 9, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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 18 Telecommunications Fraud
§2913.05(A)
Defendants Victor Padilla
Date of Offense On or about September 16, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 13 of 108
Count 19 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Victor Padilla
Date of Offense On or about August 11, 2010 to August 12, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 20 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Victor Padilla
Date of Offense On or about August 11, 2010 to August 12, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
Vehicle Identification Number (door-sticker) with knowledge that the vehicle identification number
or a derivative of the vehicle identification number had been removed, defaced, covered, altered, or
destroyed in such a manner that the identity of the vehicle or part could not be determined by a
visual examination of the number at the site where the manufacturer placed the number.
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 21 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Victor Padilla
Date of Offense On or about August 11, 2010 to August 12, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
Vehicle Identification Number (firewall) with knowledge that the vehicle identification number or a
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derivative of the vehicle identification number had been removed, defaced, covered, altered, or
destroyed in such a manner that the identity of the vehicle or part could not be determined by a
visual examination of the number at the site where the manufacturer placed the number.
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 22 Receiving stolen property
§2913.51(A)
Defendants Victor Padilla
Date of Offense On or about August 11, 2010 to August 12, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1995 Honda Civic 2-dr. (red), VIN: 1HGEJ1126SL022757, the
property of Paul Galloway, 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.
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 23 Tampering with Records
§2913.42(A)(2)
Defendants Victor Padilla
Date of Offense On or about August 12, 2010 to September 16, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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Count 24 Telecommunications Fraud
§2913.05(A)
Defendants Victor Padilla
Date of Offense On or about December 1, 2010 to December 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 25 Tampering with Records
§2913.42(A)(2)
Defendants Victor Padilla
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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 26 Fraudulent Actions Concerning a VIN
§4549.62(A)
Defendants Victor Padilla
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or motor vehicle engine,
remove, deface, cover, alter, or destroy any vehicle identification number or derivative of a vehicle
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<PROSECUTORSIGNATURE>
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Prosecuting Attorney
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identification number on a motor vehicleor motor vehicle engine.
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 27 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Victor Padilla
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
motor vehicle engine with knowledge that the vehicle identification number or a derivative of the
vehicle identification number had been removed, defaced, covered, altered, or destroyed in such a
manner that the identity of the vehicle or part could not be determined by a visual examination of the
number at the site where the manufacturer placed the number.
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 28 Receiving stolen property
§2913.51(A)
Defendants Victor Padilla
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine and transmission from a 1999 Honda Civic (blue), VIN:
1HGEM1158XL062556, the property of Leslie Lynch, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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Count 29 Receiving stolen property
§2913.51(A)
Defendants Victor Padilla
Date of Offense On or about October 21, 2008
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of 1999 Honda Civic (red), VIN: ???, the property of Karl Pilz,
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.
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 30 Grand Theft
§2913.02(A)(1)
Defendants Victor Padilla
Date of Offense On or about February 26, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did with purpose to deprive the owner, Kevin Camp, of a Honda Civic 2-Dr. hatchback (red): VIN
2HGEJ6344YH111762 or services, knowingly obtain or exert control over either the property or
services without the consent of the owner or person authorized to give consent and the property
stolen is a motor vehicle.
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 31 Receiving stolen property
§2913.51(A)
Defendants Victor Padilla
Date of Offense On or about July 6, 2010 to July 7, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 2002 Dodge Caravan, VIN: 2B8GP74L42R649375, the property
of Tessa Kostansek, 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.
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
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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Ohio.
Count 32 Receiving stolen property
§2913.51(A)
Defendants Victor Padilla
Date of Offense On or about July 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1998 Honda, VIN: 1HGEJ8143WL0600835, the property of Jared
Olszko, 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.
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 33 Receiving stolen property
§2913.51(A)
Defendants Victor Padilla
Date of Offense On or about July 12, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1999 Honda hatchback (silver), VIN: 2HGEJ6324XH107272, the
property of James Barnicle, 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.
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 34 Receiving stolen property
§2913.51(A)
Defendants Victor Padilla
Date of Offense On or about July 12, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
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<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
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Prosecuting Attorney
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did receive, retain, or dispose of a customized bicycle, the property of James Barnicle, knowing or
having reasonable cause to believe that the property had been obtained through commission of a
theft offense and the value of the property involved was $500 or more and was less than $5,000.
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 35 Receiving stolen property
§2913.51(A)
Defendants Victor Padilla
Date of Offense On or about October 6, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 2000 Honda Civic (black), VIN: 1HGEJ7223YL121529, the
property of Nicholas Sagaert, 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.
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 36 Receiving stolen property
§2913.51(A)
Defendants Victor Padilla
Date of Offense On or about October 21, 2009 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine from a 1998 Acura Integra (green), VIN:
JH4DC2399WS000704, the property of John Reed, knowing or having reasonable cause to believe
that the property had been obtained through commission of a theft offense and the value of the
property involved was $500 or more and was less than $5,000.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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Count 37 Tampering with Records
§2913.42(A)(2)
Defendants Victor Padilla
Date of Offense On or about October 19, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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 38 Possessing Criminal Tools
§2923.24(A)
Defendants Victor Padilla
Date of Offense On or about October 20, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did possess or have under the person's control any substance, device, instrument, or article, to wit:
"shaved" Honda ignition key with purpose to use it criminally.
FURTHERMORE, the "shaved" Honda ignition key involved in the offense was intended for use in
the commission of a felony, to wit: Receiving Stolen Property - Motor Vehicle, O.R.C. 2913.51.
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 39 Attempted Grand Theft
§2923.02 / 2913.02(A)(1)
Defendants Victor Padilla
Date of Offense On or about March 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did with purpose to deprive the owner, Adam Thompson, of a 1997 Acura Integra, VIN:
JHDC4365VS006127 or services, knowingly attempt to obtain or exert control over either the
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<PROSECUTORSIGNATURE>
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Prosecuting Attorney
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property or services without the consent of the owner or person authorized to give consent and the
property stolen is a motor vehicle.
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 40 Grand Theft
§2913.02(A)(1)
Defendants Victor Padilla
Date of Offense On or about April 1, 2010 to April 2, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did with purpose to deprive the owner, Richard Schiffbauer, of a 1994 Acura Intergra (white), VIN:
JH4DC4346RS004519 or services, knowingly obtain or exert control over either the property or
services without the consent of the owner or person authorized to give consent and the property
stolen is a motor vehicle.
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 41 Receiving stolen property
§2913.51(A)
Defendants Evelyn Cruz
Date of Offense On or about January 27, 2010 to February 16, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1995 Honda Civic hatchback (red), VIN: 2HGEH2463SH517821,
the property of Octavian Pavel, 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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
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Prosecuting Attorney
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Count 42 Fraudulent Actions Concerning a VIN
§4549.62(A)
Defendants Evelyn Cruz
Date of Offense On or about January 27, 2010 to February 16, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or Vehicle Identification
Number, remove, deface, cover, alter, or destroy any vehicle identification number or derivative of a
vehicle identification number on a motor vehicleor re-tag with a different VIN the vehicle firewall
VIN, dashboard plate VIN and door-sticker VIN.
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 43 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Evelyn Cruz
Date of Offense On or about January 27, 2010 to February 16, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
Vehicle Identification Number with knowledge that the vehicle identification number or a derivative
of the vehicle identification number had been removed, defaced, covered, altered, or destroyed in
such a manner that the identity of the vehicle or part could not be determined by a visual
examination of the number at the site where the manufacturer placed the number.
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 44 Receiving stolen property
§2913.51(A)
Defendants Evelyn Cruz
Date of Offense On or about February 26, 2010 to March 4, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1999 Honda 4-Dr. (green), VIN: 1HGEJ8643XL023214, the
property of Timothy Jenkins, knowing or having reasonable cause to believe that the property had
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<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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been obtained through commission of a theft offense and the property involved was a motor vehicle.
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 45 Receiving stolen property
§2913.51(A)
Defendants Evelyn Cruz
Date of Offense On or about February 28, 2010 to March 4, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1992 Honda Civic (white), VIN: 2HGEH2456NH517162, the
property of Kyle Slotnicky, 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.
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 46 Receiving stolen property
§2913.51(A)
Defendants Juan Cuevas
Date of Offense On or about May 31, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1994 Honda Civic 2-Dr. (blue), VIN: 2HGEH2361SH513171, the
property of Victoria Hampton, 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.
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 47 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Cuevas
Date of Offense On or about February 28, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
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<PROSECUTORSIGNATURE>
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did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard plate), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 48 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Cuevas
Date of Offense On or about February 28, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 49 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Cuevas
Date of Offense On or about February 28, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall), remove, deface, cover, alter, or destroy any identifying number that was lawfully
placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than the
manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 25 of 108
Count 50 Tampering with Records
§2913.42(A)(2)
Defendants Juan Cuevas
Date of Offense On or about July 29, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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 51 Telecommunications Fraud
§2913.05(A)
Defendants Juan Cuevas
Date of Offense On or about September 10, 2010 to October 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 52 Tampering with Records
§2913.42(A)(2)
Defendants Juan Cuevas
Date of Offense On or about July 23, 2010 to November 13, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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<PROSECUTORSIGNATURE>
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Prosecuting Attorney
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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.
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 53 Telecommunications Fraud
§2913.05(A)
Defendants Juan Cuevas
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 54 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Cuevas
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 27 of 108
Count 55 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Cuevas
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 56 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Cuevas
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall VIN), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 57 Receiving stolen property
§2913.51(A)
Defendants Juan Cuevas
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1999 Honda Civic 2-Dr. (red), VIN: 2HGEJ6324XH108566, the
property of Doug Rickon, 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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
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<PROSECUTORSIGNATURE>
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Prosecuting Attorney
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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 58 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Juan Cuevas
Date of Offense On or about December 1, 2010 to December 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
Vehicle Identification Number with knowledge that the vehicle identification number or a derivative
of the vehicle identification number had been removed, defaced, covered, altered, or destroyed in
such a manner that the identity of the vehicle or part could not be determined by a visual
examination of the number at the site where the manufacturer placed the number.
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 59 Tampering with Records
§2913.42(A)(2)
Defendants Juan Cuevas
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 29 of 108
Count 60 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Cuevas
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 61 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Cuevas
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 62 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Cuevas
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall), remove, deface, cover, alter, or destroy any identifying number that was lawfully
placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than the
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 30 of 108
manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 63 Receiving stolen property
§2913.51(A)
Defendants Juan Cuevas
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1992 Honda Civic (turquoise), VIN: 2HGEH2451NH503590, the
property of Zachary Carly, 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.
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 64 Receiving stolen property
§2913.51(A)
Defendants Juan Cuevas
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1995 Honda Civic hatchback (red), VIN: 2HGEH2463SH517821,
the property of Octavian Pavel, 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.
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 65 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Cuevas
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 31 of 108
did, with purpose to conceal or destroy the identity of a motor vehicle or a firewall VIN, door-
sticker, and dash VIN plate, remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 66 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Juan Cuevas
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 67 Receiving stolen property
§2913.51(A)
Defendants Juan Cuevas
Date of Offense On or about February 26, 2010 to March 4, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1999 Honda 4-Dr. (green), VIN: 1HGEJ8643XL023214, the
property of Timothy Jenkins, 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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 32 of 108
Count 68 Receiving stolen property
§2913.51(A)
Defendants Juan Cuevas
Date of Offense On or about February 26, 2010 to March 4, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1992 Honda Civic (white), VIN: 2HGEH2456NH517162, the
property of Kyle Slotnicky, 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.
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 69 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(2)
Defendants Juan Cuevas
Date of Offense On or about June 25, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did purport to sell or transfer a motor vehicle without delivering to the purchaser or transferee of it a
certificate of title, a salvage certificate of title, or a manufacturer's or importer's certificate to it,
assigned to the purchaser as provided for in Chapter 4505.19 of the Revised Code.
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 70 Receiving stolen property
§2913.51(A)
Defendants Juan Cuevas, Luis Cuevas
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1995 Honda Civic hatchback (red), VIN: 2HGEH2463SH517821,
the property of Octavian Pavel, 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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 33 of 108
Count 71 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Luis Cuevas
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a firewall VIN, door-
sticker, and dash VIN plate, remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 72 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Luis Cuevas
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 34 of 108
Count 73 Tampering with Records
§2913.42(A)(2)
Defendants Luis Cuevas
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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 74 Telecommunications Fraud
§2913.05(A)
Defendants Luis Cuevas
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 75 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Luis Cuevas
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 35 of 108
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 76 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Luis Cuevas
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 77 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Cuevas
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall VIN), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 36 of 108
Count 78 Receiving stolen property
§2913.51(A)
Defendants Luis Cuevas
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1999 Honda Civic 2-Dr. (red), VIN: 2HGEJ6324XH108566, the
property of Doug Rickon, 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.
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 79 Telecommunications Fraud
§2913.05(A)
Defendants Luis Cuevas
Date of Offense On or about January 20, 2010 to September 7, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 80 Tampering with Records
§2913.42(A)(2)
Defendants Luis Cuevas
Date of Offense On or about January 20, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 37 of 108
entity.
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 81 Receiving stolen property
§2913.51(A)
Defendants Luis Cuevas
Date of Offense On or about November 4, 2009 to November 23, 2009
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1993 Honda Civic CRX (blue), VIN: 2HGEH246X539449, the
property of Sheyla Cruz, knowing or having reasonable cause to believe that the property had been
obtained through commission of a theft offense and the value of the property involved was $500 or
more and was less than $5,000.
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 82 Receiving stolen property
§2913.51(A)
Defendants Michael Ferguson
Date of Offense On or about December 21, 2010 to December 22, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of an engine and transmission from a 1993 Honda Civic (purple), VIN:
1HGEJ115XPL034315, the property of Brandon Delude, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 38 of 108
Count 83 Receiving stolen property
§2913.51(A)
Defendants Javier Flores
Date of Offense On or about November 4, 2009 to November 23, 2009
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of an engine and seats from a 1993 Honda Civic CRX (blue), VIN:
2HGEH246X539449, the property of Sheyla Cruz, knowing or having reasonable cause to believe
that the property had been obtained through commission of a theft offense and the value of the
property involved was $500 or more and was less than $5,000.
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 84 Grand Theft
§2913.02(A)(1)
Defendants Juan Hernandez
Date of Offense On or about April 1, 2010 to April 2, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did with purpose to deprive the owner, Richard Schiffbauer, of a 1994 Acura Intergra (white), VIN:
JH4DC4346RS004519 or services, knowingly obtain or exert control over either the property or
services without the consent of the owner or person authorized to give consent and the property
stolen is a motor vehicle.
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 85 Grand Theft
§2913.02(A)(1)
Defendants Juan Hernandez
Date of Offense On or about March 25, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did with purpose to deprive the owner, Jeffrey So, of a 1999 Honda Civic (blue),
VIN:2HGEJ6445XH113243 or services, knowingly obtain or exert control over either the property
or services without the consent of the owner or person authorized to give consent and the property
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 39 of 108
stolen is a motor vehicle.
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 86 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Xavier Hernandez
Date of Offense On or about March 19, 2010 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 87 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Xavier Hernandez
Date of Offense On or about March 19, 2010 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 40 of 108
Count 88 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Xavier Hernandez
Date of Offense On or about March 19, 2010 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall VIN), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 89 Receiving stolen property
§2913.51(A)
Defendants Xavier Hernandez
Date of Offense On or about March 19, 2010 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of 2003 Chrysler Town & Country minivan, VIN:
2C4GP44L63R103293, the property of Javier Umanzor, 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.
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 90 Tampering with Records
§2913.42(A)(2)
Defendants Xavier Hernandez
Date of Offense On or about March 19, 2010 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
knowing it to have been tampered with as provided in division (A)(1) of this section and the writing,
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 41 of 108
data, computer software, or record was kept by or belonged to a local, state, or federal governmental
entity.
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 91 Receiving stolen property
§2913.51(A)
Defendants Xavier Hernandez
Date of Offense On or about March 10, 2009 to November 2, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine and transmission from a 1999 Honda Civic CRX 2-Dr.
(red), VIN:1HGEM115XXL054801, the property of Gary Santavicca, knowing or having reasonable
cause to believe that the property had been obtained through commission of a theft offense and the
value of the property involved was $500 or more and was less than $5,000.
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 92 Tampering with Records
§2913.42(A)(2)
Defendants Xavier Hernandez
Date of Offense On or about March 10, 2009 to November 2, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 42 of 108
Count 93 Telecommunications Fraud
§2913.05(A)
Defendants Xavier Hernandez
Date of Offense On or about March 10, 2009 to November 2, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 94 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Xavier Hernandez
Date of Offense On or about March 10, 2009 to November 2, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 95 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Christina Lozada
Date of Offense On or about December 21, 2010 to April 15, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 43 of 108
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 96 Obstructing Justice
§2921.32(A)(5)
Defendants Christina Lozada
Date of Offense On or about October 22, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to hinder the discovery, apprehension, prosecution, conviction, or punishment of
another for a crime or to assist another to benefit from the commission of a crime, communicate
false information to any person.
FURTHERMORE, and the crime committed by the person aided was aggravated murder, murder, or
a felony of the first or second degree and/or the act committed by the child aided would have been
one of those offenses if committed by an adult and the offender knew or had reason to believe that
the crime committed by the person aided was one of those offenses and/or that the act committed by
the child aided would have been one of those offenses if committed by an adult.
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 97 Obstructing Justice
§2921.32(A)(5)
Defendants James Lyle
Date of Offense On or about July 12, 2010 to December 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to hinder the discovery, apprehension, prosecution, conviction, or punishment of
another for a crime or to assist another to benefit from the commission of a crime, communicate
false information to any person.
FURTHERMORE, and the crime committed by the person aided was aggravated murder, murder, or
a felony of the first or second degree and/or the act committed by the child aided would have been
one of those offenses if committed by an adult and the offender knew or had reason to believe that
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 44 of 108
the crime committed by the person aided was one of those offenses and/or that the act committed by
the child aided would have been one of those offenses if committed by an adult.
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 98 Tampering With Evidence
§2921.12(A)(1)
Defendants James Lyle
Date of Offense On or about July 12, 2010 to December 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing that an official proceeding or investigation was in progress, or was about to be or likely
to be instituted, alter, destroy, conceal, or remove any record, document, or thing, with purpose to
impair its value or availability as evidence in such proceeding or investigation.
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 99 Receiving stolen property
§2913.51(A)
Defendants Jose Martinez
Date of Offense On or about January 26, 2010 to August 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine and transmission from a 1999 Honda Civic 2-Dr. (red),
VIN: 1HGEJ6340XH11069, the property of Robert Knauer, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 45 of 108
Count 100 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Jose Martinez
Date of Offense On or about January 26, 2010 to August 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
engine and transmission with knowledge that the vehicle identification number or a derivative of the
vehicle identification number had been removed, defaced, covered, altered, or destroyed in such a
manner that the identity of the vehicle or part could not be determined by a visual examination of the
number at the site where the manufacturer placed the number.
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 101 Tampering with Records
§2913.42(A)(2)
Defendants Jose Martinez
Date of Offense On or about January 26, 2010 to August 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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 102 Receiving stolen property
§2913.51(A)
Defendants Jose Martinez
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a transmission from a 2000 Honda Civic 2-Dr. (black), VIN:
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 46 of 108
1HGEJ8245YL080666, the property of Robert Burwell, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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 103 Tampering with Records
§2913.42(A)(2)
Defendants Jose Martinez
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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 104 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Jose Martinez
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a transmission from a 2000
Honda Civic 2-Dr. (black), VIN: 1HGEJ8245YL080666, remove, deface, cover, alter, or destroy any
identifying number that was lawfully placed upon a vehicle or vehicle part by an owner of the
vehicle or vehicle part, other than the manufacturer, for the purpose of deterring its theft and
facilitating its recovery if stolen.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 47 of 108
Count 105 Receiving stolen property
§2913.51(A)
Defendants Juan Martinez
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a transmission from a 2000 Honda Civic 2-Dr. (black), VIN:
1HGEJ8245YL080666, the property of Robert Burwell, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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 106 Tampering with Records
§2913.42(A)(2)
Defendants Juan Martinez
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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 107 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Juan Martinez
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
transmission from a 2000 Honda Civic 2-Dr. (black), VIN: 1HGEJ8245YL080666 with knowledge
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 48 of 108
that the vehicle identification number or a derivative of the vehicle identification number had been
removed, defaced, covered, altered, or destroyed in such a manner that the identity of the vehicle or
part could not be determined by a visual examination of the number at the site where the
manufacturer placed the number.
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 108 Receiving stolen property
§2913.51(A)
Defendants Lina Martinez
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a transmission from a 2000 Honda Civic 2-Dr. (black), VIN:
1HGEJ8245YL080666, the property of Robert Burwell, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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 109 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Lina Martinez
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or a
transmission from a 2000 Honda Civic 2-Dr. (black), VIN: 1HGEJ8245YL080666 with knowledge
that the vehicle identification number or a derivative of the vehicle identification number had been
removed, defaced, covered, altered, or destroyed in such a manner that the identity of the vehicle or
part could not be determined by a visual examination of the number at the site where the
manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 49 of 108
Count 110 Tampering with Records
§2913.42(A)(2)
Defendants Lina Martinez
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing she had no privilege to do so, and with purpose to defraud or knowing she was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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 111 Tampering with Records
§2913.42(A)(2)
Defendants Jonathan Musse
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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 112 Receiving stolen property
§2913.51(A)
Defendants Jonathan Musse
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a transmission from a 2000 Honda Civic 2-Dr. (black), VIN:
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 50 of 108
1HGEJ8245YL080666, the property of Robert Burwell, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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 113 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Jonathan Musse
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or a
transmission from a 2000 Honda Civic 2-Dr. (black), VIN: 1HGEJ8245YL080666 with knowledge
that the vehicle identification number or a derivative of the vehicle identification number had been
removed, defaced, covered, altered, or destroyed in such a manner that the identity of the vehicle or
part could not be determined by a visual examination of the number at the site where the
manufacturer placed the number.
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 114 Tampering with Records
§2913.42(A)(2)
Defendants Edwin Mendez
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 51 of 108
Count 115 Receiving stolen property
§2913.51(A)
Defendants Edwin Mendez
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1999 Honda Civic 2-Dr. (red), VIN: 2HGEJ6324XH108566, the
property of Doug Rickon, 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.
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 116 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Edwin Mendez
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 117 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Edwin Mendez
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 52 of 108
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 118 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Edwin Mendez
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall VIN), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 119 Tampering with Records
§2913.42(A)(2)
Defendants Edwin Mendez
Date of Offense On or about September 1, 2010 to September 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: vehicle title application,
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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 53 of 108
Count 120 Receiving stolen property
§2913.51(A)
Defendants Edwin Mendez
Date of Offense On or about December 1, 2007 to September 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1999 Honda Civic (black), VIN: 2HGEJ6342XH102377, the
property of Jacob Jaworsky, 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.
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 121 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Edwin Mendez
Date of Offense On or about December 10, 2007 to September 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 122 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Edwin Mendez
Date of Offense On or about December 1, 2007 to September 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 54 of 108
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 123 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Edwin Mendez
Date of Offense On or about December 1, 2007 to September 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall VIN), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 124 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Edwin Mendez
Date of Offense On or about December 1, 2007 to September 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 55 of 108
Count 125 Receiving stolen property
§2913.51(A)
Defendants Marilyn Rodriguez
Date of Offense On or about December 1, 2007 to September 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1999 Honda Civic (black), VIN: 2HGEJ6342XH102377, the
property of Jacob Jaworsky, 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.
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 126 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Marilyn Rodriguez
Date of Offense On or about December 1, 2007 to September 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 127 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Marilyn Rodriguez
Date of Offense On or about December 1, 2007 to September 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 56 of 108
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 128 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Marilyn Rodriguez
Date of Offense On or about December 1, 2007 to September 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall VIN), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 129 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Marilyn Rodriguez
Date of Offense On or about December 1, 2007 to September 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 57 of 108
Count 130 Tampering with Records
§2913.42(A)(2)
Defendants Javier Millan
Date of Offense On or about March 19, 2010 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title and vehicle
title application (pass-through), 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.
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 131 Tampering with Records
§2913.42(A)(2)
Defendants Javier Millan
Date of Offense On or about February 9, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title and vehicle
title application (pass-through), 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.
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 132 Tampering with Records
§2913.42(A)(2)
Defendants Javier Millan
Date of Offense On or about August 12, 2010 to September 16, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 58 of 108
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title and vehicle
title application (pass-through), 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.
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 133 Tampering with Records
§2913.42(A)(2)
Defendants Javier Millan
Date of Offense On or about July 23, 2010 to January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title and vehicle
title application (pass-through), 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.
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 134 Tampering with Records
§2913.42(A)(2)
Defendants Javier Millan
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title and vehicle
title application (pass-through), 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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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Count 135 Tampering with Records
§2913.42(A)(2)
Defendants Javier Millan
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title and vehicle
title application (pass-through), 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.
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 136 Tampering with Records
§2913.42(A)(2)
Defendants Javier Millan
Date of Offense On or about November 5, 2007
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title and vehicle
title application (pass-through), 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.
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 137 Tampering with Records
§2913.42(A)(2)
Defendants Javier Millan
Date of Offense On or about January 27, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 60 of 108
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title and vehicle
title application (pass-through), 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.
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 138 Tampering with Records
§2913.42(A)(2)
Defendants Javier Millan
Date of Offense On or about July 29, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title and vehicle
title application (pass-through), 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.
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 139 Tampering with Records
§2913.42(A)(2)
Defendants Javier Millan
Date of Offense On or about January 20, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title and vehicle
title application (pass-through), 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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 61 of 108
Count 140 Tampering with Records
§2913.42(A)(2)
Defendants Javier Millan
Date of Offense On or about January 26, 2010 to August 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title and vehicle
title application (pass-through), 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.
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 141 Receiving stolen property
§2913.51(A)
Defendants Jonathan Ortiz
Date of Offense On or about January 26, 2010 to August 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine and transmission from a 1999 Honda Civic 2-Dr. (red),
VIN: 1HGEJ6340XH11069, the property of Robert Knauer, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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 142 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Jonathan Ortiz
Date of Offense On or about January 26, 2010 to August 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 62 of 108
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 143 Tampering with Records
§2913.42(A)(2)
Defendants Jonathan Ortiz
Date of Offense On or about January 26, 2010 to August 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 144 Receiving stolen property
§2913.51(A)
Defendants Carlos Pagan
Date of Offense On or about January 26, 2010 to August 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine and transmission from a 1999 Honda Civic 2-Dr. (red),
VIN: 1HGEJ6340XH11069, the property of Robert Knauer, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 63 of 108
Count 145 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Carlos Pagan
Date of Offense On or about August 1, 2010 to August 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 146 Tampering with Records
§2913.42(A)(2)
Defendants Carlos Pagan
Date of Offense On or about January 26, 2010 to August 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 147 Telecommunications Fraud
§2913.05(A)
Defendants Carlos Pagan
Date of Offense On or about December 1, 2010 to December 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 64 of 108
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 148 Tampering with Records
§2913.42(A)(2)
Defendants Carlos Pagan
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 149 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Carlos Pagan
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a motor vehicle engine and
transmission, remove, deface, cover, alter, or destroy any identifying number that was lawfully
placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than the
manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 65 of 108
Count 150 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Carlos Pagan
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
motor vehicle engine and transmission with knowledge that the vehicle identification number or a
derivative of the vehicle identification number had been removed, defaced, covered, altered, or
destroyed in such a manner that the identity of the vehicle or part could not be determined by a
visual examination of the number at the site where the manufacturer placed the number.
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 151 Receiving stolen property
§2913.51(A)
Defendants Carlos Pagan
Date of Offense On or about November 15, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine and transmission from a 1999 Honda Civic (blue), VIN:
1HGEM1158XL062556, the property of Leslie Lynch, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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 152 Receiving stolen property
§2913.51(A)
Defendants Alberto Pietri Jr.
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1995 Honda Civic hatchback (red), VIN: 2HGEH2463SH517821,
the property of Octavian Pavel, knowing or having reasonable cause to believe that the property had
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 66 of 108
been obtained through commission of a theft offense and the property involved was a motor vehicle.
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 153 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Alberto Pietri Jr.
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a firewall VIN, door-
sticker, and dash VIN plate, remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 154 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Alberto Pietri Jr.
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 67 of 108
Count 155 Telecommunications Fraud
§2913.05(A)
Defendants Alberto Pietri Jr.
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 156 Tampering with Records
§2913.42(A)(2)
Defendants Alberto Pietri Jr.
Date of Offense On or about January 27, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 157 Receiving stolen property
§2913.51(A)
Defendants Alberto Pietri
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1995 Honda Civic hatchback (red), VIN: 2HGEH2463SH517821,
the property of Octavian Pavel, knowing or having reasonable cause to believe that the property had
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 68 of 108
been obtained through commission of a theft offense and the property involved was a motor vehicle.
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 158 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Alberto Pietri
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a firewall VIN, door-
sticker, and dash VIN plate, remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 159 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Alberto Pietri
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 69 of 108
Count 160 Receiving stolen property
§2913.51(A)
Defendants Alberto Pietri
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1995 Honda Civic hatchback (red), VIN: 2HGEH2463SH517821,
the property of Octavian Pavel, 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.
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 161 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(2)
Defendants Alberto Pietri
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did purport to sell or transfer a motor vehicle without delivering to the purchaser or transferee of it a
certificate of title, a salvage certificate of title, or a manufacturer's or importer's certificate to it,
assigned to the purchaser as provided for in Chapter 4505.19 of the Revised Code.
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 162 Receiving stolen property
§2913.51(A)
Defendants Auri Pietri
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1995 Honda Civic hatchback (red), VIN: 2HGEH2463SH517821,
the property of Octavian Pavel, 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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 70 of 108
Count 163 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Auri Pietri
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a firewall VIN, door-
sticker, and dash VIN plate, remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 164 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Auri Pietri
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 71 of 108
Count 165 Tampering with Records
§2913.42(A)(2)
Defendants Auri Pietri
Date of Offense On or about January 27, 2010 to February 16, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing she had no privilege to do so, and with purpose to defraud or knowing she was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 166 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Erickson Ramos
Date of Offense On or about December 1, 2010 to December 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 167 Tampering with Records
§2913.42(A)(2)
Defendants Erickson Ramos
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 72 of 108
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 168 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Erickson Ramos
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 169 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Erickson Ramos
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 73 of 108
Count 170 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Erickson Ramos
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall VIN), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 171 Receiving stolen property
§2913.51(A)
Defendants Erickson Ramos
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1992 Honda Civic (turquoise), VIN: 2HGEH2451NH503590, the
property of Zachary Carly, 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.
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 172 Receiving stolen property
§2913.51(A)
Defendants Jose Ramos
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a transmission from a 2000 Honda Civic 2-Dr. (black), VIN:
1HGEJ8245YL080666, the property of Robert Burwell, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 74 of 108
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 173 Tampering with Records
§2913.42(A)(2)
Defendants Jose Ramos
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 174 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Jose Ramos
Date of Offense On or about November 19, 2008 to April 30, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 75 of 108
Count 175 Attempted Grand Theft
§2923.02 / 2913.02(A)(1)
Defendants Jose Ramos
Date of Offense On or about October 11, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did with purpose to deprive the owner, State Of Ohio, of an Ohio Highway patrol "Bait" car (Honda
Civic) or services, knowingly attempt to obtain or exert control over either the property or
services without the consent of the owner or person authorized to give consent and the property
stolen is a motor vehicle.
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 176 Telecommunications Fraud
§2913.05(A)
Defendants Miriam Ramos
Date of Offense On or about January 20, 2010 to September 7, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 177 Tampering with Records
§2913.42(A)(2)
Defendants Miriam Ramos
Date of Offense On or about January 20, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing she had no privilege to do so, and with purpose to defraud or knowing she was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
knowing it to have been tampered with as provided in division (A)(1) of this section and the writing,
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 76 of 108
data, computer software, or record was kept by or belonged to a local, state, or federal governmental
entity.
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 178 Receiving stolen property
§2913.51(A)
Defendants Miriam Ramos
Date of Offense On or about November 4, 2009 to November 23, 2009
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of an engine and seats from a 1993 Honda Civic CRX (blue), VIN:
2HGEH246X539449, the property of Sheyla Cruz, knowing or having reasonable cause to believe
that the property had been obtained through commission of a theft offense and the value of the
property involved was $500 or more and was less than $5,000.
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 179 Receiving stolen property
§2913.51(A)
Defendants Juan Rivera
Date of Offense On or about February 18, 2008 to February 1, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine from a 1999 Acura Integra 2-door (maroon), VIN:
JH4DC436XXS003887, the property of Michael Minnick, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 77 of 108
Count 180 Tampering with Records
§2913.42(A)(2)
Defendants Juan Rivera
Date of Offense On or about February 18, 2008 to February 1, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 181 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Juan Rivera
Date of Offense On or about February 1, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 182 Receiving stolen property
§2913.51(A)
Defendants Juan Rodriguez
Date of Offense On or about May 31, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1994 Honda Civic 2-Dr. (blue), VIN: 2HGEH2361SH513171, the
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 78 of 108
property of Victoria Hampton, 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.
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 183 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Rodriguez
Date of Offense On or about May 31, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 184 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Rodriguez
Date of Offense On or about May 31, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 79 of 108
Count 185 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Juan Rodriguez
Date of Offense On or about May 31, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall VIN), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 186 Tampering with Records
§2913.42(A)(2)
Defendants Juan Rodriguez
Date of Offense On or about July 29, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 187 Telecommunications Fraud
§2913.05(A)
Defendants Juan Rodriguez
Date of Offense On or about September 10, 2010 to November 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 80 of 108
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 188 Telecommunications Fraud
§2913.05(A)
Defendants Juan Rodriguez
Date of Offense On or about January 20, 2010 to September 7, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 189 Tampering with Records
§2913.42(A)(2)
Defendants Juan Rodriguez
Date of Offense On or about January 20, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 81 of 108
Count 190 Receiving stolen property
§2913.51(A)
Defendants Juan Rodriguez
Date of Offense On or about November 4, 2009 to November 23, 2009
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of an engine and seats from a 1993 Honda Civic CRX (blue), VIN:
2HGEH246X539449, the property of State Of Ohio, knowing or having reasonable cause to believe
that the property had been obtained through commission of a theft offense and the value of the
property involved was $500 or more and was less than $5,000.
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 191 Obstructing Justice
§2921.32(A)(5)
Defendants Carlos Sanchez
Date of Offense On or about January 13, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to hinder the discovery, apprehension, prosecution, conviction, or punishment of
another for a crime or to assist another to benefit from the commission of a crime, communicate
false information to any person.
FURTHERMORE, and the crime committed by the person aided was aggravated murder, murder, or
a felony of the first or second degree and/or the act committed by the child aided would have been
one of those offenses if committed by an adult and the offender knew or had reason to believe that
the crime committed by the person aided was one of those offenses and/or that the act committed by
the child aided would have been one of those offenses if committed by an adult.
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 192 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(2)
Defendants Francisco Santiago
Date of Offense On or about July 8, 2010
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 82 of 108
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did purport to sell or transfer a motor vehicle without delivering to the purchaser or transferee of it a
certificate of title, a salvage certificate of title, or a manufacturer's or importer's certificate to it,
assigned to the purchaser as provided for in Chapter 4505.19 of the Revised Code.
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 193 Telecommunications Fraud
§2913.05(A)
Defendants Francisco Santiago
Date of Offense On or about February 9, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 194 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Francisco Santiago
Date of Offense On or about February 9, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 83 of 108
Count 195 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Francisco Santiago
Date of Offense On or about February 9, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 196 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Francisco Santiago
Date of Offense On or about February 9, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall VIN), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 197 Receiving stolen property
§2913.51(A)
Defendants Francisco Santiago
Date of Offense On or about February 9, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1997 Acura Integra hatchback (red), VIN: JHDC2386V001573,
the property of Daniel Kozdron, 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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 84 of 108
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 198 Tampering with Records
§2913.42(A)(2)
Defendants Francisco Santiago
Date of Offense On or about February 9, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 199 Telecommunications Fraud
§2913.05(A)
Defendants Francisco Santiago
Date of Offense On or about December 1, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 85 of 108
Count 200 Tampering with Records
§2913.42(A)(2)
Defendants Francisco Santiago
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 201 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Francisco Santiago
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a the engine and
transmission from a 1999 Honda Civic (blue), VIN: 1HGEM1158XL062556, remove, deface, cover,
alter, or destroy any identifying number that was lawfully placed upon a vehicle or vehicle part by an
owner of the vehicle or vehicle part, other than the manufacturer, for the purpose of deterring its
theft and facilitating its recovery if stolen.
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 202 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Francisco Santiago
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or the
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 86 of 108
engine and transmission from a 1999 Honda Civic (blue), VIN: 1HGEM1158XL062556 with
knowledge that the vehicle identification number or a derivative of the vehicle identification number
had been removed, defaced, covered, altered, or destroyed in such a manner that the identity of the
vehicle or part could not be determined by a visual examination of the number at the site where the
manufacturer placed the number.
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 203 Receiving stolen property
§2913.51(A)
Defendants Francisco Santiago
Date of Offense On or about November 15, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine and transmission from a 1999 Honda Civic (blue), VIN:
1HGEM1158XL062556, the property of Leslie Lynch, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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 204 Telecommunications Fraud
§2913.05(A)
Defendants Lizmarie Torres-Bruno
Date of Offense On or about October 1, 2010 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 87 of 108
Count 205 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Lizmarie Torres-Bruno
Date of Offense On or about October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (dashboard VIN plate), remove, deface, cover, alter, or destroy any identifying number that
was lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other
than the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 206 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Lizmarie Torres-Bruno
Date of Offense On or about October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (door-sticker), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 207 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Lizmarie Torres-Bruno
Date of Offense On or about October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a Vehicle Identification
Number (firewall VIN), remove, deface, cover, alter, or destroy any identifying number that was
lawfully placed upon a vehicle or vehicle part by an owner of the vehicle or vehicle part, other than
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 88 of 108
the manufacturer, for the purpose of deterring its theft and facilitating its recovery if stolen.
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 208 Tampering with Records
§2913.42(A)(2)
Defendants Lizmarie Torres-Bruno
Date of Offense On or about March 19, 2010 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing she had no privilege to do so, and with purpose to defraud or knowing she was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 209 Receiving stolen property
§2913.51(A)
Defendants Lizmarie Torres-Bruno
Date of Offense On or about March 19, 2010 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of 2003 Chrysler Town & Country minivan, VIN:
2C4GP44L63R103293, the property of Javier Umanzor, 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.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 89 of 108
Count 210 Receiving stolen property
§2913.51(A)
Defendants Lizmarie Torres-Bruno
Date of Offense On or about October 6, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 2000 Honda Civic (black), VIN: 1HGEJ7223YL121529, the
property of Nicholas Sagaert, knowing or having reasonable cause to believe that the property had
been obtained through commission of a theft offense and the value of the property involved was
$500 or more and was less than $5,000.
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 211 Receiving stolen property
§2913.51(A)
Defendants Lizmarie Torres-Bruno
Date of Offense On or about October 20, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine from a 1998 Acura Integra (green), VIN:
JH4DC2399WS000704, the property of John Reed, knowing or having reasonable cause to believe
that the property had been obtained through commission of a theft offense and the value of the
property involved was $500 or more and was less than $5,000.
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 212 Telecommunications Fraud
§2913.05(A)
Defendants Jose Trujillo
Date of Offense On or about December 1, 2010 to December 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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execute or otherwise further the scheme to defraud.
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 213 Tampering with Records
§2913.42(A)(2)
Defendants Jose Trujillo
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 214 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Jose Trujillo
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a the engine and
transmission from a 1999 Honda Civic (blue), VIN: 1HGEM1158XL062556, remove, deface, cover,
alter, or destroy any identifying number that was lawfully placed upon a vehicle or vehicle part by an
owner of the vehicle or vehicle part, other than the manufacturer, for the purpose of deterring its
theft and facilitating its recovery if stolen.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 91 of 108
Count 215 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Jose Trujillo
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or the
engine and transmission from a 1999 Honda Civic (blue), VIN: 1HGEM1158XL062556 with
knowledge that the vehicle identification number or a derivative of the vehicle identification number
had been removed, defaced, covered, altered, or destroyed in such a manner that the identity of the
vehicle or part could not be determined by a visual examination of the number at the site where the
manufacturer placed the number.
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 216 Receiving stolen property
§2913.51(A)
Defendants Jose Trujillo
Date of Offense On or about November 15, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine and transmission from a 1999 Honda Civic (blue), VIN:
1HGEM1158XL062556, the property of Leslie Lynch, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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 217 Receiving stolen property
§2913.51(A)
Defendants Jose Trujillo
Date of Offense On or about November 11, 2009
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine and transmission from a 1999 Honda Civic, VIN
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A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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1HGEM115XXL083490, the property of Robert Camp, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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 218 Telecommunications Fraud
§2913.05(A)
Defendants Jose Trujillo
Date of Offense On or about November 11, 2009 to November 24, 2009
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 219 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Jose Trujillo
Date of Offense On or about November 24, 2009
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or the
engine and transmission from a 1999 Honda Civic, VIN 1HGEM115XXL083490 with knowledge
that the vehicle identification number or a derivative of the vehicle identification number had been
removed, defaced, covered, altered, or destroyed in such a manner that the identity of the vehicle or
part could not be determined by a visual examination of the number at the site where the
manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 93 of 108
Count 220 Tampering with Records
§2913.42(A)(2)
Defendants Jose Trujillo
Date of Offense On or about August 27, 2009
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
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.
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 221 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Jose Trujillo, Javier Flores
Date of Offense On or about January 1, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 222 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Christina Lozada
Date of Offense On or about January 1, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 94 of 108
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 223 Obstructing Justice
§2921.32(A)(5)
Defendants Sally Ortiz
Date of Offense On or about October 22, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to hinder the discovery, apprehension, prosecution, conviction, or punishment of
another for a crime or to assist another to benefit from the commission of a crime, communicate
false information to any person.
FURTHERMORE, and the crime committed by the person aided was aggravated murder, murder, or
a felony of the first or second degree and/or the act committed by the child aided would have been
one of those offenses if committed by an adult and the offender knew or had reason to believe that
the crime committed by the person aided was one of those offenses and/or that the act committed by
the child aided would have been one of those offenses if committed by an adult.
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 224 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Sally Ortiz
Date of Offense On or about January 1, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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Ohio.
Count 225 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Sally Ortiz
Date of Offense On or about January 1, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 226 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Sally Ortiz
Date of Offense On or about January 1, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 96 of 108
Count 227 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Jose Ramos
Date of Offense On or about January 11, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 228 Telecommunications Fraud
§2913.05(A)
Defendants Jose Vega
Date of Offense On or about December 1, 2010 to December 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
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 229 Tampering with Records
§2913.42(A)(2)
Defendants Jose Vega
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was
facilitating a fraud on State Of Ohio, utter a writing or record, to wit: motor vehicle title application,
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 97 of 108
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.
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 230 Fraudulent Actions Concerning a VIN
§4549.62(B)
Defendants Jose Vega
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to conceal or destroy the identity of a motor vehicle or a transmission and an
engine from a 1999 Honda Civic (blue), VIN: 1HGEM1158XL062556, remove, deface, cover, alter,
or destroy any identifying number that was lawfully placed upon a vehicle or vehicle part by an
owner of the vehicle or vehicle part, other than the manufacturer, for the purpose of deterring its
theft and facilitating its recovery if stolen.
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 231 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Jose Vega
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or the
engine and transmission from a 1999 Honda Civic (blue), VIN: 1HGEM1158XL062556 with
knowledge that the vehicle identification number or a derivative of the vehicle identification number
had been removed, defaced, covered, altered, or destroyed in such a manner that the identity of the
vehicle or part could not be determined by a visual examination of the number at the site where the
manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 98 of 108
Count 232 Receiving stolen property
§2913.51(A)
Defendants Jose Vega
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of the engine and transmission from a 1999 Honda Civic (blue), VIN:
1HGEM1158XL062556, the property of Leslie Lynch, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $500 or more and was less than $5,000.
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 233 Obstructing Justice
§2921.32(A)(5)
Defendants Jose Vega
Date of Offense On or about November 26, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did, with purpose to hinder the discovery, apprehension, prosecution, conviction, or punishment of
another for a crime or to assist another to benefit from the commission of a crime, communicate
false information to any person.
FURTHERMORE, and the crime committed by the person aided was aggravated murder, murder, or
a felony of the first or second degree and/or the act committed by the child aided would have been
one of those offenses if committed by an adult and the offender knew or had reason to believe that
the crime committed by the person aided was one of those offenses and/or that the act committed by
the child aided would have been one of those offenses if committed by an adult.
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 234 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Jose Vega
Date of Offense On or about February 3, 2009
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A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 235 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Manuel Vasquez
Date of Offense On or about January 1, 2011
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 236 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Manuel Vasquez
Date of Offense On or about August 27, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 100 of 108
Count 237 Receiving stolen property
§2913.51(A)
Defendants Manuel Vasquez
Date of Offense On or about March 16, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of 1998 Honda Civic EX (black), VIN: 1HGEJ8148WL124674, the
property of Lenny R. Johnson, 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.
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 238 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Ivan Pietri
Date of Offense On or about March 2, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 101 of 108
Count 239 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(2)
Defendants Ivan Pietri
Date of Offense On or about February 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did purport to sell or transfer a motor vehicle without delivering to the purchaser or transferee of it a
certificate of title, a salvage certificate of title, or a manufacturer's or importer's certificate to it,
assigned to the purchaser as provided for in Chapter 4505.19 of the Revised Code.
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 240 Receiving stolen property
§2913.51(A)
Defendants Ivan Pietri
Date of Offense On or about February 26, 2010 to March 4, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of a 1999 Honda 4-Dr. (green), VIN: 1HGEJ8643XL023214, the
property of Timothy Jenkins, 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.
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 241 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Auri Pietri
Date of Offense On or about July 1, 2009
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
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Prosecuting Attorney
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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 242 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Auri Pietri
Date of Offense On or about October 21, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 243 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Auri Pietri
Date of Offense On or about October 25, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 103 of 108
Count 244 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Auri Pietri
Date of Offense On or about January 7, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 245 Fraudulent Actions Concerning a VIN
§4549.62(D)(1)
Defendants Marilyn Rodriguez
Date of Offense On or about September 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did buy, offer to buy, sell, offer to sell, receive, dispose of, conceal, or possess a motor vehicle or
firewall VIN, door-sticker, and dash VIN plate with knowledge that the vehicle identification
number or a derivative of the vehicle identification number had been removed, defaced, covered,
altered, or destroyed in such a manner that the identity of the vehicle or part could not be determined
by a visual examination of the number at the site where the manufacturer placed the number.
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 246 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about March 19, 2010 to October 24, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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 247 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about February 9, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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 248 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about August 12, 2010 to September 16, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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 249 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about July 23, 2010 to December 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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 250 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about November 16, 2010 to December 15, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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 251 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about September 28, 2010 to October 14, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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 252 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about November 5, 2007
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 106 of 108
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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 253 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about January 27, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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 254 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about July 29, 2010 to September 10, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 107 of 108
Count 255 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about January 20, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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 256 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about January 26, 2010 to August 31, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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 257 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about October 21, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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.
Cuyahoga County Court of Common Pleas
A True Bill Indictment
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
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Count 258 Motor Vehicle Certificate of Title Offenses
§4505.19(A)(4)
Defendants Javier Millan
Date of Offense On or about October 25, 2010
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly obtain goods, services, credit, or money by means of an invalid, fictitious, forged,
counterfeit, stolen, or unlawfully obtained original or duplicate certificate of title, registration, bill of
sale, or other instrument of ownership of a motor vehicle.
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.