IN THE COURT OF COMMON PLEAS

STATE OF OHIO ))

COUNTY OF MAHONING )SS:)

STATE OF OHIO )

PLAINTIFF

VS.

IVAN MALDONADOD.O.B. 3-9-68S.S. #-----59224648 Euclid Blvd.Boardman, Ohio 44512AndANTHONYJ.MALDONADOD.O.B. 11-1-1984S.S. #-----6423960 BevRoadBoardman, Ohio 44512AndRON GRANGERD.O.B. 11-9~64S.S. #-----85421354 Shannon RoadGirard, Ohio 44420

DEFENDANTS

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'SECRET- INDtcTMENT :-.-JUDGE /()CASE NO. 2010 CRJ lINDICTMENT FOR

COUNTS ONE, SIXTEEN:FALSIFICATION; IN THEFTOFFENSER.C.2921.13 (A) (4).M-1COUNTS SIX, SEVEN, EIGHT,NINE, TEN, TWELVE,THIRTEEN, FOURTEEN,FIFTEEN, TWENTY-THREE:THEFT R.C. 2913.02(A) (3) F-5COUNTS THREE, EIGHTEEN:GRAND THEFTR.C. 2913.02(A) (3) F-4COUNTS FOUR, NINETEEN,TWENTY:TAMPERING WITH RECORDSR.C. 2913.42 (A) (1) F.,3COUNTS TWO, SEVENTEENTWENTY-ONE:FALISFICATION; IN THEFTOFFENSER.C. 2921. 13(A) (9) F-4COUNTS FIVE, TWENTY~TWO,TWENTY-FOUR:THEFT IN OFFICE;RESTITUTION; WITHHOLDINGOF RETIREMENT BENEFITSR.C. 2921.41 (A) (1) F-3COUNT ELEVEN:THEFT; R.C. 2913.02 (A) (3) M-1

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2010CR0031900038352745

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COUNT ONE

The jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about August 1, 2003 and continuing until on orabout May 31, 2009 IVAN MALDONADO did knowingly make a false statement, orknowingly swear or affirm the truth of a false statement previously made, when: thestatement was made with purpose to secure the payment of unemployment compensation;Ohio Works First; prevention, retention, and contingency benefits and services; disabilityfinancial assistance; retirement benefits; economic development assistance as defined in9.66 of the Ohio Revised Code; or other benefits administered by a governmental agencyor paid out of a public treasury; in violation ofR.C.292 1.13(A)(4), Falsification; in theftoffense, a Misdemeanor of the First Degree, against the peace and dignity ofthe State ofOhio.

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COUNT TWO

The jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about August 1, 2003 and continuing until on orabout May 31, 2009 IVAN MALDONADO did knowingly make a false statement, orknowingly swear or affirm the truth of a false statement previously made, when: thestatement was made with purpose to commit or facilitate the commission of a theftoffense; in violation ofR.C. 2921.13 (A) (9), Falsification; in theft offense, Felony of theFourth Degree, against the peace and dignity of the State of Ohio.

COUNT THREE

The jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority ofthe State ofOhio, do find and present that on or about August 1, 2003 and continuing until on orabout May 31, 2009 IVAN MALDONADO did, with the purpose to depriveYoungstown State University, the owner of the services, did knowingly obtain and exertcontrol over said services, to wit: fee remission for college courses, by deception, thevalue of said services being $5,000 or more, but less than $100,000.00, in violation ofR.C. 2913.02 (A) (3), Grand Theft, a Felony of the Fourth Degree, against the peace anddignity of the State of Ohio.

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COUNT FOUR

The jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority ofthe State ofOhio, do find and present that on or about August 1, 2003 and continuing until on orabout May 31, 2009 IVAN MALDONADO did, knowing he had no privilege to do so,and with purpose to defraud or knowing he was facilitating a fraud: falsify, destroy,remove, conceal, alter, deface, or mutilate a writing, computer software, data, computerdata or record; in violation ofR.C. 2913.42 (A) (1), Tampering with Records a Felony ofthe Third Degree, against the peace and dignity of the State of Ohio.

COUNT FIVE

The jurors of the Grand Jury of the State of Ohio, within ~andfor the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about August 1, 2003 and continuing until on orabout May 31, 2009 IVAN MALDONADO did, being a public official or party officialcommit a theft offense, as defined in section 2913.01 (K) of the Revised Code, and:the said Ivan Maldonado used his office in aid of committing the offense or permitted orassented to its use in aid of committing the offense; in violation ofR.C. 2921.41 (A) (1),Theft in Office; Restitution; Withholding of Retirement Benefits a Felony ofthe ThirdDegree.

COUNT SIX

The Jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about June 16, 2003 and continuing through on orabout July 26, 2005, at Mahoning County, IVAN MALDONADO, did with the purposeto deprive Youngstown State University, the owner, of the property, did knowinglyobtain and exert control over said property, to wit: $711.58, by deception by causing thevictim to remit funds to Ohio Public Employees Retirement System to benefit Cory V.Carfora in violation ofR.C. 2913.02(A) (3), Theft, a felony of the Fifth Degree, againstthe peace and dignity of the State of Ohio.

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COUNT SEVEN

The Jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about April 6, 2005 and continuing through on orabout July 26, 2005, at Mahoning County, IVAN MALDONADO, did with the purposeto deprive Youngstown State University, the owner, of the property, did knowinglyobtain and exert control over said property, to wit: $3,889.77, by deception by causingthe victim to remit funds to Ohio Public Employees Retirement System to benefitRaymond J. Cruickshank in violation ofR.C. 2913.02(A) (3), Theft, a felony of the FifthDegree, against the peace and dignity of the State of Ohio.

COUNT EIGHT

The Jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about August 11, 2003 and continuing through on orabout January 28,2004, at Mahoning County, IVAN MALDONADO, did with thepurpose to deprive Youngstown State University, the owner, of the property, didknowingly obtain and exert control over said property, to wit: $3,499.95 by deception bycausing the victim to remit funds to Ohio Public Employees Retirement System to benefitBernice M. Hamrock in violation ofR.C. 2913.02(A) (3), Theft, a felony of the FifthDegree, against the peace and dignity of the State of Ohio.

COUNT NINE

The Jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about January 23,2003 and continuing through on orabout March 4, 2004, at Mahoning County, IVAN MALDONADO, did with the purposeto deprive Youngstown State University, the owner, of the property, did knowinglyobtain and exert control over said property, to wit: $1,810.81 by deception by causing.the victim to remit funds to Ohio Public Employees Retirement System to benefit SheilaA. M. Maldonado (Martin) in violation ofR.C. 2913.02(A) (3), Theft, a felony of theFifth Degree, against the peace and dignity of the State of Ohio.

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COUNT TEN

The Jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about June 28, 1999 and continuing through on orabout September 30, 1999 at Mahoning County, IVAN MALDONADO, did with thepurpose to deprive Youngstown State University, the owner, of the property, didknowingly obtain and exert control over said property, to wit: $4,494.19 by deception bycausing the victim to remit funds to Ohio Public Employees Retirement System to benefitMichael A. Pieton in violation ofR.C. 2913.02(A) (3), Theft, a felony of the FifthDegree, against the peace and dignity ofthe State of Ohio.

COUNT ELEVEN

The Jurors of the Grand Jury ofthe State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about August 20, 2002 and continuing through on orabout October 3,2002 at Mahoning County, IVAN MALDONADO, did with thepurpose to deprive Youngstown State University, the owner, of the property, didknowingly obtain and exert control over said property, to wit: $91.98 by deception bycausing the victim to remit funds to Ohio Public Employees Retirement System to benefitFrank Richards in violation ofR.C. 2913.02(A) (3), Theft a misdemeanor ofthe FirstDegree, against the peace and dignity of the State of Ohio.

COUNT TWELVE

The Jurors of the Orand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority ofthe State ofOhio, do find and present that on or about December 23,2003 and continuing through onor about March 1, 2004 at Mahoning County, IVAN MALDONADO, did with thepurpose to deprive Youngstown State University, the owner, of the property, didknowingly obtain and exert control over said property, to wit: $952.33 by deception bycausing the victim to remit funds to Ohio Public Employees Retirement System to benefitRichard J. Sweany in violation ofR.C. 2913.02(A) (3), Theft, a felony of the FifthDegree, against the peace and dignity of the State of Ohio.

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COUNT THIRTEEN

The Jurors ofthe Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about April 8, 2005 and continuing through on orabout July 25, 2005 at Mahoning County, IVAN MALDONADO, did with the purposeto deprive Youngstown State University, the owner, of the property, did knowinglyobtain and exert control over said property, to wit: $2,794.08 by deception by causingthe victim to remit funds to Ohio Public Employees Retirement System to benefit RomanP. Swerdan in violation ofR.C. 2913.02(A) (3), Theft, a felony of the Fifth Degree,against the peace and dignity of the State of Ohio.

COUNT FOURTEEN

The Jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about March 23, 1998 and continuing through on orabout September 11, 1998 at Mahoning County, IVAN MALDONADO, did with thepurpose to deprive Youngstown State University, the owner, of the property, didknowingly obtain and exert control over said property, to wit: $1,240.45 by deception bycausing the victim to remit funds to Ohio Public Employees Retirement System to benefitMaria E. Volpe in violation ofR.C. 2913.02(A) (3), Theft, a felony of the Fifth Degree,against the peace and dignity of the State of Ohio.

COUNT FIFTEEN

The Jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority ofthe State ofOhio, do find and present that on or about January 23,2006 and continuing through on orabout June 9, 2006 at Mahoning County, IVAN MALDONADO, did with the purpose todeprive Youngstown State University, the owner, of the property, did knowingly obtainand exert control over said property, to wit: $1,233.21 by deception by causing thevictim to remit funds to Ohio Public Employees Retirement System to benefit Mark A.Welton in violation ofR.C. 2913.02(A) (3), Theft, a felony of the Fifth Degree, againstthe peace and dignity of the State of Ohio.

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COUNT SIXTEEN

The Jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about August 1, 2003 and continuing through on orabout May 31,2009 ANTHONY J. MALDONADO did knowingly make a falsestatement, or knowingly swear or affirm the truth of a false statement previously made,when: the statement was made with purpose to secure the payment of unemploymentcompensation; Ohio Works First; prevention, retention, and contingency benefits andservices; disability financial assistance; retirement benefits; economic developmentassistance as defined in 9.66 ofthe Ohio Revised Code; or other benefits administered bya governmental agency or paid out of a public treasury; in violation ofR.C.2921.13(A)( 4), Falsification; in theft offense, a Misdemeanor of the First Degree,against the peace and dignity of the State of Ohio.

COUNT SEVENTEEN

The Jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about August 1, 2003 and continuing through on orabout May 31,2009 ANTHONY J. MALDONADO did knowingly make a falsestatement, or knowingly swear or affirm the truth of a false statement previously made,when: the statement was made with purpose to secure the payment of unemploymentcompensation; Ohio Works First; prevention, retention, and contingency benefits andservices; disability financial assistance; retirement benefits; economic developmentassistance as defined in 9.66 ofthe Ohio Revised Code; or other benefits administered bya governmental agency or paid out of a public treasury; in violation ofR.C.2921.13(A)(9), Falsification; in theft offense, a Felony of the Fourth Degree, againstthe peace and dignity of the State of Ohio.

COUNT EIGHTEEN

The jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about August 1, 2003 and continuing until on orabout May 31,2009 ANTHONY J. MALDONADO did, with the purpose to depriveYoungstown State University, the owner ofthe services, did knowingly obtain and exertcontrol over said services, to wit: fee remission for college courses, by deception, thevalue of said services being $5,000 or more, but less than $100,000.00, in violation ofR.c. 2913.02 (A) (3), Grand Theft, a Felony of the Fourth Degree, against the peace anddignity of the State of Ohio.

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COUNT NINETEEN

The jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority ofthe State ofOhio, do find and present that on or about August 1, 2003 and continuing until on orabout May 31, 2009 ANTHONY J. MALDONADO did, knowing he had no privilege todo so, and with purpose to defraud or knowing he was facilitating a fraud: falsify,destroy, remove, conceal, alter, deface, or mutilate a writing, computer software, data,computer data or record; in violation ofR.C. 2913.42 (A) (1), Tampering with Records aFelony of the Third Degree, against the peace and dignity of the State of Ohio.

COUNT TWENTY

The jurors of the Grand Jury of the St~te of Qhio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about March 9, 2006 and continuing until on or aboutMay 22, 2009 RON E. GRANGER did, knowing he had no privilege to do so, and withpurpose to defraud or knowing he was facilitating a fraud: falsify, destroy, remove,conceal, alter, deface, or mutilate a writing, computer software, data, computer data orrecord; in violation ofR.C. 2913.42 (A) (1), Tampering with Records a Felony of theThird Degree, against the peace and dignity of the State of Ohio.

COUNT TWENTY-ONE

The jurors of the Orand Jury of the State of Ohio, within and for the body of theCounty ofMahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about March 9, 2006 and continuing until on or aboutMay 22, 2009 RON E. GRANGER did knowingly make a false statement, or knowinglyswear or affirm the truth of a false statement previously made, when: the statement wasmade with purpose to commit or facilitate the commission of a theft offense; in violationofR.C. 2921.13 (A) (9), Falsification; in theft offense, Felony of the Fourth Degree,against the peace and dignity of the State of Ohio.

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COUNT TWENTY-TWO

The jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about March 9, 2006 and continuing until on or aboutMay 22, 2009 RON E. GRANGER did, being a public official or party official commit atheft offense, as defined in section 2913.01 (K) of the Revised Code, and:the said RON E. GRANGER used his office in aid of committing the offense or permittedor assented to its use in aid of committing the offense; in violation ofR.C. 2921.41 (A) (1), Theft in Office; Restitution; Withholding of Retirement Benefits aFelony ofthe Third Degree.

COUNT TWENTY-THREE

The jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority ofthe State ofOhio, do find and present that on or about March 9, 2006 and continuing until on or aboutMay 22, 2009 RON E. GRANGER did with the purpose to deprive Girard MunicipalCourt, the owner of the property, did knowingly obtain and exert control over saidproperty, to wit: $4,581.50 by deception; the value of said property being $500.00 ormore but less than $5,000.00; in violation ofR.C. 2913.02(A) (3), a felony of the FifthDegree, against the peace and dignity of the State of Ohio.

COUNT TWENTY -FOUR

The jurors of the Grand Jury of the State of Ohio, within and for the body of theCounty of Mahoning, on their oaths, and in the name and by the authority of the State ofOhio, do find and present that on or about March 23, 1998 and continuing until on orabout July 26, 2005 IVAN MALDONADO did, being a public official or party officialcommit a theft offense, as defined in section 2913.01 (K) of the Revised Code, and:the said Ivan Maldonado used his office in aid of committing the offense or permitted orassented to its use in aid of committing the offense; in violation ofR.C. 2921.41 (A) (1),Theft in Office; Restitution; Withholding of Retirement Benefits a Felony of the ThirdDegree.

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PROSECUTING ATTORNEY

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