Cuyahoga County Court of Common...

<GRANDJURORSIGNATURE>

<PROSECUTORSIGNATURE>

Foreperson of the Grand Jury

Prosecuting Attorney

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Cuyahoga County Court of Common Pleas

Criminal Court Division

State of Ohio, A True Bill Indictment For

Plaintiff Engaging In A Pattern Of Corrupt Activity - F1

VS. §2923.32(A)(1)

37 Defendants 95 Additional Count(s)

Defendants

Montrea Donaldson, Danielle Sheron, Joshua U. Trundle, Antonio Douglas, Pasquinel R. Averyheart, Clemons Porter III, Terrence Craig Wilson, Antwain D. Jones, Samuel Smith, Angella Kelley, Frank Thompson, Darlene Vernon,

Crystal N. Gardenshire, Monica Norton, Janet Noble, Andre Smiler, Michael K. Mankins, Ralph Williams, Michelle Browner, Dewayne Williams, Samuel Norflet, Avionna L. Winfree, Talica M. Green, Latrent Maurice Redrick, James

T. Jones, Jiare Clark, Joseph Clutter, Omni Cunningham, Demar E. Day, Kiah Ivory, Lamar Nunley, Marcellina Poole,

Malaika Reid, Khalyl T. Wadley, Roger E. Wiley, Kimberly Mankins, Darrin Roulette

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

06/30/2014 to 11/01/2017 January of 2018 626435-18-CR

The State of Ohio, }

SS.

Cuyahoga County

Count 1 Engaging In A Pattern Of Corrupt Activity - F1

§2923.32(A)(1)

Defendants Montrea Donaldson, Danielle Sheron, Joshua U. Trundle, Antonio Douglas,

Pasquinel R. Averyheart, Clemons Porter III, Terrence Craig Wilson, Antwain D. Jones, Samuel Smith, Angella Kelley, Frank Thompson, Darlene Vernon, Crystal

N. Gardenshire, Monica Norton, Janet Noble, Andre Smiler, Michael K. Mankins, Ralph Williams, Michelle Browner, Dewayne Williams, Samuel Norflet, Talica M. Green, James T. Jones, Jiare Clark, Joseph Clutter, Omni Cunningham, Demar E.

Day, Kiah Ivory, Lamar Nunley, Marcellina Poole, Malaika Reid, Khalyl T. Wadley, Roger E. Wiley, Kimberly Mankins, Darrin Roulette

Date of Offense On or about June 30, 2014 to October 4, 2017

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 Counties of Cuyahoga, Lake, and Summit, unlawfully

while employed by, or associated with, any enterprise did conduct or participate in, directly or

indirectly, the affairs of the enterprise through a pattern of corrupt activity or the collection of an unlawful debt and at least one of the incidents of corrupt activity was a felony of the first, second, or third degree, aggravated murder, or murder, or at least one of the incidents was a felony under the

law of this state that was committed prior to July 1, 1996, and constituted a felony of the first, second, or third degree, aggravated murder, or murder or was committed on or after July 1, 1996, or

one of the incidents of corrupt activity was a felony under the law of the United States or of another

state that, if committed in this state on or after July 1, 1996, would have constituted a felony of the


A True Bill Indictment





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

The Enterprise On or between June 2014 through November 2017, 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 2923.13(c) of the Revised Code.

This Enterprise existed separate and apart from the pattern of corrupt activity in which it engaged. In the alternative, this Enterprise is an “illicit enterprise” under O.R.C. 2923.22, whether or not this

Enterprise existed separate and apart from the pattern of corrupt activity described in this Indictment. 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 participate in and/or managed the affairs of the Enterprise, as

explained in this Indictment. As such, these purposes – the pattern of corrupt activity, to wit: an organized counterfeit check ring whose purpose was to steal money from local attorneys IOLTA accounts, insurance companies, local businesses, and other entities.

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 and/or aided and abetted by

each of the persons associated with the Enterprise. The Enterprise in this matter consisted of Montrea Donaldson, Joseph Clutter, Roger Wiley, Khalyl

Wadley, Latrent Redrick, Monica Norton, Antonio Douglas, Atwain Jones, Samuel Smith, Clemons Porter, Montrea Donaldson, Terrence Wilson, Frank Thompson, Darlene Vernon, Crystal Gardenshire, Janet Noble, Kendrick Blakney, Dontez Elam, Brianna Dixon, Darrin Roulette,

Kimberly Mankins, Michael Mankins, Michelle Browner, Dewayne Williams, Demar Day, Samuel A. Norflet, Avionna Winfree, Demar Dey, Maliaka Reid, Marcellina K. Poole, Kiah Ivory, Omni Cunningham, Jiare Clark, Lamar Nunley, James Jones, Talica Green, Joshua Trundle, Angella Kelley, Arryiona Lumpkin, Daniel Sheron, Pasquinel Averyheart, and other yet unknown, each of

whom did conduct and/or participate in, directly or indirectly in the affairs of said Enterprise, to wit: a group associated in fact for the purpose of engaging in counterfeit check ring, uttering, theft, telecommunications fraud, money laundering, and burglary through a pattern of corrupt activity as

defined in Section 2923.31(I)(2) or 2923.31(I)( 2)(C) of the Ohio Revised Code. The Enterprise consists of all of the above named and unnamed individuals who are involved in a highly sophisticated organized counterfeit check ring managed and directed by Montrea Donaldson

(hereinafter Donaldson). The ring’s sole purpose was to create counterfeit checks in numerous named individuals, also known as “walkers” who would then cash the checks at local banks. The accounts that were listed on the counterfeit checks were from various businesses and entities,

attorney accounts, and local banks, all for the purpose to steal money from the victims by deception. The Enterprise was managed, organized, and directed by Donaldson. Donaldson who has extensive schooling on use of computers and knowledge of how to create counterfeit checks was the driving

force behind this massive fraud which was perpetrated.







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To be able to accomplish the goals of the enterprise, Donaldson needed to organize resources to accomplish his thievery. Donaldson first needed to acquire the physical hardware needed to create the checks. Donaldson then acquired a laptop, computer, a printer and the software programs needed to physically create the checks. Donaldson then needed to have the computer skills needed to create

the checks on the computers. As a result of the investigation it was found that Donaldson had completed over 1,400 hours of computer instruction including 720 hours of computer office technology, and 720 hours to become a Microsoft Office certified specialist. This fact was

demonstrated when it took over 3 weeks for the federal computer analyst to gain access to Donaldson’s encrypted data.

Donaldson then engaged numerous individuals in the following ways to accomplish his corrupt activity:

1) Recruiters: Donaldson needed different names (walkers) to be placed on the numerous

counterfeit checks to be created. Donaldson then engaged Latrent Redrick, Monica Norton,

Joseph Clutter, Roger Wiley, Khalyl Wadley, Ralph Williams, and Andre Smiler to act as

recruiters. Their job was to find as many individuals as possible who had a valid state ID or a

driver’s license in order to cash (bust) the checks. At times some of the recruiters also acted as

walkers.

2) Walkers: these are the individuals who would actually go into the banks with their ID’s or

driver’s licenses and negotiate the fraudulent checks. These individuals would be approached

by the recruiters who would offer them a quick way to make money. The investigation

revealed upwards of thirty-five individuals whose role was simply to cash the checks. At

times some of the walkers never met Donaldson since they were contacted and handled

through the recruiters.

3) Account Numbers: Donaldson needed valid bank account numbers in order for the counterfeit

checks to be negotiated at the banks. To accomplish this part of the enterprise, Donaldson or

his associated would simply ask various individuals for account numbers of businesses they

had contact with, have associates do trash pulls to find account numbers, or would take photos

of checks that would show routing and account numbers that he would later utilize to create

counterfeit checks in furtherance of goals the enterprise.

Once the resources were in place, Donaldson would instruct the walkers, or a recruiter handling the walkers, on how to cash the counterfeit checks when going to the bank.

Donaldson would pick which bank depending on where the account came from, which branch to go to, what time of day to go, and what to say and do during the transaction. The walkers

were also instructed on what to look for if there was trouble, i.e. the teller would need to go in the back and verify the check or the teller would call the entity on the check. In either instance, the walker was instructed to immediately leave the bank and take the check. The

investigation revealed and caught on surveillance cameras the walkers doing exactly as instructed; however, the walkers on occasion were not able to retrieve the check as they left

the bank.







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The investigation also revealed that Donaldson, in order to avoid the bank verifying the counterfeit check, on one occasion sent two of his co-conspirators (Clemons Porter and Terrance Wilson) into the law office of John Spellacy to forward the office phone to another phone number controlled by Donaldson. Inside the office Clemons Porter, after distracting the

office personnel did forward the incoming calls to coordinate the walkers (Antwain Jones) attempting to cash fraudulent checks from the victim’s IOLTA account at that specific time. Furthermore, Donaldson utilized gloves while creating checks which illustrates demonstrates

the sophistication of the enterprise that was completely directed by Donaldson. The enterprise also engaged individuals to be the “drivers” whose function was to drive the

walkers to various banks to cash the checks. A known driver is Samuel Smith; however there are a number of drivers unknown at this time. At least on one occasion Donaldson permitted his car to be utilized by the walkers.

The recruiters known at this time who also acted as walkers are: Joseph Clutter, Roger Wiley, Khalyl Wadley, Latrent Redrick, and Monica Norton.

The walkers known at this time are: Antonio Douglas, Atwain Jones, Samuel Smith, Clemons Porter, Montrea Donaldson, Terrence Wilson, Frank Thompson, Darlene Vernon, Crystal Gardenshire, Janet Noble, Kendrick Blakney, Dontez Elam, Brianna Dixon, Darrin Roulette,

Kimberly Mankins, Michael Mankins, Michelle Browner, Dewayne Williams, Demar Day,

Samuel A. Norflet, Avionna Winfree, Demar Dey, Maliaka Reid, Marcellina K. Poole, Kiah Ivory, Omni Cunningham, Jiare Clark, Lamar Nunley, James Jones, Talica Green, Joshua Trundle, Angella Kelley, Arryiona Lumpkin, Daniel Sheron, Pasquinel Averyheart

The enterprise, who was led by Donaldson, disseminated 75 checks throughout Cuyahoga, Lake, and Summit Counties with a face value of $165,851.22 of which 59 checks were

successfully cashed/deposited for an actual loss of approximately $83,224.03. In order to further promote the goals of the enterprise and to facilitate the pattern of corrupt activity, Montrea Donaldson, Kimberly Mankins, Michael Mankins, Ralph Williams, Kiah

Ivory, Roger Wiley, Khalyl Wadley, Joseph Clutter, Joshua Trundle, Danielle Sheron, and Pasquinel Averyheart deposited counterfeit checks into banks accounts and then subsequently engaged in multiple bank transactions in order to obtain the illegal proceeds.

Furthermore, all of the proceeds of the unlawful passing of the counterfeit checks were distributed among the players of which distribution was dependent on that particular context; however, Donaldson always got the largest cut of the stolen money.

Affairs of the Enterprise 1. Did knowingly by deception obtain or exert control over property to deprive the owner of said

property.

2. Did by stealth and/or deception trespass in an occupied or in a separately secured or

separately occupied portion of an occupied structure when another person other than an







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accomplice of the offender is present with purpose to commit any criminal offense.

3. Did knowingly, have a scheme to defraud, disseminate, transmit, or cause to be disseminated

or transmitted by means of a wire, radio, satellite, telecommunication, telecommunication

device or service any writing, data, sign, signed, picture, send an image with the purpose to

execute or otherwise further the scheme to defraud.

4. Did knowingly with purpose to defraud, utter, or passes with the purpose to utter, any writing

that person knowns to have been forged.

5. Did conduct or attempt to conduct a transaction with the purpose to promote, manage,

establish, carry on, or facilitate the promotion, management, establishment, or carrying on of

corrupt activity.

Pattern of Corrupt Activity 1. Theft 2913.02(A)(3): No person, with purpose to deprive the owner of property or services,

shall knowingly obtain or exert control over either the property or services in by deception.

2. Burglary 2911.12(A)(3): No person, by force, stealth, or deception shall trespass in an

occupied structure or in separately occupied portion of the structure, with purpose to commit

in the structure or separately secured or separately occupied portion of the structure any

criminal offense.

3. Telecommunications Fraud 2913.05(A): No person, having devised a scheme to defraud, shall

knowingly disseminate, transmit, or cause to be disseminated, or transmitted by means of a

wire, radio, satellite, telecommunication, telecommunications devise, or telecommunications

service any writing, data, signal, picture, sound, or image with purpose to execute or

otherwise further the scheme to defraud.

4. Uttering 2913.31(A)(3): No person, with purpose to defraud, or knowing that the person is

facilitating a fraud, shall utter, or possess with purpose to utter, a writing that the person

knows to have been forged.

5. Money Laundering 1315.55(A)(3): No person shall conduct or attempt to conduct a

transaction with the purpose to promote, manage, establish, carry on, or facilitate the

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

Incidents of Corrupt Activity The Enterprise in this matter consisted of: Montrea Donaldson, Joseph Clutter, Roger Wiley,

Khalyl Wadley, Latrent Redrick, Monica Norton, Antonio Douglas, Atwain Jones, Samuel Smith,

Clemons Porter, Montrea Donaldson, Terrence Wilson, Frank Thompson, Darlene Vernon, Crystal Gardenshire, Janet Noble, Kendrick Blakney, Dontez Elam, Brianna Dixon, Darrin Roulette,

Kimberly Mankins, Michael Mankins, Michelle Browner, Dewayne Williams, Demar Day, Samuel

A. Norflet, Avionna Winfree, Demar Dey, Maliaka Reid, Marcellina K. Poole, Kiah Ivory, Omni Cunningham, Jiare Clark, Lamar Nunley, James Jones, Talica Green, Joshua Trundle, Angella Kelley, Arryiona Lumpkin, Daniel Sheron, Pasquinel Averyheart, and others yet to be identified, each of whom did conduct or participate in, directly or indirectly, the affairs of said enterprise, to-







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wit: a group of persons “associated in fact” for the purposes of engaging in THEFT, BURGLARY, TELECOMMUNICATIONS FRAUD, FORGERY, and MONEY LAUNDERING through a pattern of corrupt activity as defined in Section 2923.31(I)(2)(a) or (I)(2)(c) of the Revised Code.

The required predicate acts constituting the pattern of corrupt activity as defined in Section 2923.31(E) include listed criminal violations of Ohio Revised Code TITLE 29, THEFT, BURGLARY, TELECOMMUNICATIONS FRAUD, FORGERY, and MONEY LAUNDERING, as

alleged in the following: COUNTS ONE through NINETY-SIX of the indictment, all alleged as Predicate Acts, which are incorporated herein as if fully restated.

Furthermore, pursuant to Section 2923.32(B)(1), at least one of the incidents of corrupt activity, as defined in Section 2923.31(I)(2)(a) or (I)(2)(c) is a felony of the third degree or higher – COUNTS TWO, THREE, TWENTY, TWENTY-ONE, SEVENTY-FOUR, EIGHTY-THREE through EIGHTY-FIVE, EIGHTY-NINE, NINETY, NINETY-FOUR through NINETY-SIX , 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, 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.

The offense is 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 Aggravated Theft - F3

§2913.02(A)(1)

Defendants Montrea Donaldson, Danielle Sheron, Joshua U. Trundle, Antonio Douglas, Pasquinel R. Averyheart, Clemons Porter III, Terrence Craig Wilson, Antwain D.

Jones, Samuel Smith, Angella Kelley, Frank Thompson, Darlene Vernon, Crystal

N. Gardenshire, Monica Norton, Janet Noble, Andre Smiler, Michael K. Mankins, Ralph Williams, Michelle Browner, Dewayne Williams, Samuel Norflet, Talica M.

Green, James T. Jones, Jiare Clark, Joseph Clutter, Omni Cunningham, Demar E. Day, Kiah Ivory, Lamar Nunley, Marcellina Poole, Malaika Reid, Khalyl T. Wadley, Roger E. Wiley, Kimberly Mankins, Darrin Roulette

Date of Offense On or about June 30, 2014 to October 4, 2017

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

did with purpose to deprive the owner, John Spellacy & Associates, Robert Vechhio Law Firm,

Utica First Insurance Company, Muldoon's Saloon, Cuyahoga County Land Reutilization Corp, Triad Staffing, PS Cleveland, G-Lancer on 21, Singleton Construction Company, Lawrence Kahn, Kent State University, Thomas Lane Inc., Dave's Supermarket, Chagrin Wine and Beverage, Mookie's Beverage, John's Deli, Walmart, Check ‘n Go, CheckSmart, Ace Cash Express, Lee-

Harvard Convenience Store, Key Bank, PSE Credit Union, PNC Bank, US Bank, Fifth Third Bank,







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Huntington National Bank, Cleveland Fire Fighter's Credit Union, of money 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 or services stolen is valued at $150,000 or more and less than $750,000.


Ohio.

Count 3 Burglary - F2

§2911.12(A)(1)

Defendants Montrea Donaldson, Clemons Porter III, Terrence Craig Wilson, Antwain D. Jones, Samuel Smith

Date of Offense On or about July 19, 2017


did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised

Code, in an occupied structure or in a separately secured or separately occupied portion of an

occupied structure, when another person, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Telecommunications Fraud, 2913.05(A), and/or Theft,

2913.02.


Ohio.

Count 4 Telecommunications Fraud - F5

§2913.05(A)

Defendants Montrea Donaldson, Clemons Porter III, Terrence Craig Wilson, Antwain D. Jones, Samuel Smith



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.


Ohio.







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Count 5 Forgery - F4

§2913.31(A)(3)

Defendants Montrea Donaldson, Antwain D. Jones, Samuel Smith



with purpose to defraud, or knowing that he is facilitating a fraud on John J. Spellacy & Associates and/or Fifth Third Bank, did utter, or possess with purpose to utter, any writing, to wit: check unknown, dated unknown, in the amount of $7,500, payable to Antwain Jones, that Montrea

Donaldson, Antwain Jones, and Samuel Smith knows to have been forged and the value of the property or services or the loss to the victim is $7,500 or more and is less than $150,000.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on John J. Spellacy & Associates and/or Fifth Third Bank, did utter, or possess with purpose to utter, any writing, to wit: check

unknown, dated unknown, in the amount of $7,500, payable to Antwain Jones, that Montrea Donaldson, Antwain Jones, and Samuel Smith knows to have been forged and the value of the

property or services or the loss to the victim is $7,500 or more and is less than $150,000.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on John J. Spellacy & Associates and/or Fifth Third Bank, did utter, or possess with purpose to utter, any writing, to wit: check 3963, dated 07/20/2017, in the amount of $497.00, payable to Antwain Jones, that Montrea Donaldson,

Antain D. Jones, and Samuel Smith knows to have been forged.


Ohio.







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§2913.31(A)(3)

Defendants Montrea Donaldson



with purpose to defraud, or knowing that he is facilitating a fraud on John J. Spellacy & Associates, and/or Fifth Third Bank, and/or Huntington Bank, did utter, or possess with purpose to utter, any writing, to wit: check 10195, dated 7/27/2017, in the amount of $880.61, payable to Arryiona

Lumpkin, that Montrea Donaldson knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Antonio Douglas



with purpose to defraud, or knowing that he is facilitating a fraud on John Spellacy & Associates and/or Fifth Third Bank, did utter, or possess with purpose to utter, any writing, to wit: check 10187, dated 7/27/2017, in the amount of $1,950.00, payable to Terrence Wilson, that Montrea Donaldson

and Antonio Douglas knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on John J. Spellacy & Associates, and/or Fifth Third Bank, and/or CheckSmart, did utter, or possess with purpose to utter, any writing,

to wit: check 10198, dated 7/27/2017, in the amount of $876.33, payable to Antonio Douglas, that Montrea Donaldson and Antonio Douglas knows to have been forged.


Ohio.







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§2913.31(A)(3)

Defendants Montrea Donaldson, James T. Jones



with purpose to defraud, or knowing that he is facilitating a fraud on Robert Vechhio Law Firm and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 006853, dated 7/26/2017, in the amount of $986.37, payable to James Jones, that Montrea

Donaldson and James Jones knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on Robert Vechhio Law Firm and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 006852, dated 7/26/2017, in the amount of $987.59, payable to James Jones, that Montrea

Donaldson and James Jones knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on Robert Vechhio Law Firm and/or Huntingon National Bank, did utter, or possess with purpose to utter, any writing, to wit:

check 006847, dated 7/26/2017, in the amount of $993.39, payable to James Jones, that Montrea Donaldson and James Jones knows to have been forged.


Ohio.







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§2913.31(A)(3)


Date of Offense On or about August 1, 2017


with purpose to defraud, or knowing that he is facilitating a fraud on Robert Vechhio Law Firm, and/or Huntingon National Bank, and/or CheckSmart, did utter, or possess with purpose to utter, any writing, to wit: check 0006845, dated 7/28/2017, in the amount of $893.14, payable to Antonio

Douglas, that Montrea Donaldson and Antonio Douglas knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Frank Thompson



with purpose to defraud, or knowing that he is facilitating a fraud on Robert Vechhio Law Firm, and/or Huntingon National Bank, and/or Dave's Supermarket, did utter, or possess with purpose to utter, any writing, to wit: check 006857, dated 8/3/2017, in the amount of $623.14, payable to Frank

Thompson, that Montrea Donaldson and Frank Thompson knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Samuel Norflet



with purpose to defraud, or knowing that he is facilitating a fraud on Utica First Insurance Company and/or M & T Bank, did utter, or possess with purpose to utter, any writing, to wit: check

000495627, dated 8/21/2017, in the amount of $4,800, payable to Samuel Norflet, that Montrea Donaldson and Samuel Norflet knows to have been forged.


Ohio.







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§2913.31(A)(3)

Defendants Montrea Donaldson, Dewayne Williams



with purpose to defraud, or knowing that he is facilitating a fraud on Utica First Insurance Company and/or M & T Bank, did utter, or possess with purpose to utter, any writing, to wit: check 000495542, dated 8/7/2017, in the amount of $7,500, payable to Dewayne Williams, that Montrea

Donaldson and Dewayne Williams knows to have been forged and the value of the property or services or the loss to the victim is $7,500 or more and is less than $150,000.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on Utica First Insurance Company, and/or M & T Bank, and/or Chagrin Wine and Beverage, did utter, or possess with purpose to utter,

any writing, to wit: check 000495529, dated 8/4/2017, in the amount of $975, payable to Antonio Douglas, that Montrea Donaldson and Antonio Douglas knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Michael K. Mankins, Ralph Williams, Kimberly Mankins



with purpose to defraud, or knowing that he/she is facilitating a fraud on Utica First Insurance

Company and/or M & T Bank, and/or KeyBank, did utter, or possess with purpose to utter, any writing, to wit: check 000495829, dated 8/24/2017, in the amount of $35,000, payable to Kimberly Mankins, that Montrea Donaldson, Michael Mankins, Ralph Williams, and Kimberly Mankins

knows to have been forged and the value of the property or services or the loss to the victim is $7,500 or more and is less than $150,000.


Ohio.







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Count 20 Money Laundering - F3

§1315.55(A)(3)




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


Ohio.


§1315.55(A)(3)


Date of Offense On or about September 1, 2017


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

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


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Monica Norton, Michelle Browner



with purpose to defraud, or knowing that he/she is facilitating a fraud on Utica First Insurance Company, and/or M & T Bank, and/or PSE Credit Union, did utter, or possess with purpose to utter, any writing, to wit: check 000495748, dated 8/30/2017, in the amount of $2,250, payable to Michelle

Browner, that Montrea Donaldson, Monica Norton, and Michelle Browner knows to have been

forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Avionna L. Winfree








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with purpose to defraud, or knowing that he/she is facilitating a fraud on Utica First Insurance Company, and/or M & T Bank, and/or PNC, did utter, or possess with purpose to utter, any writing,

to wit: check 000495900, dated 9/13/2017, in the amount of $850, payable to Avionna Winfree, that Montrea Donaldson and Avionna Winfree knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Avionna L. Winfree



with purpose to defraud, or knowing that he/she is facilitating a fraud on Utica First Insurance Company, and/or M & T Bank, and/or PNC Bank, did utter, or possess with purpose to utter, any

writing, to wit: check 000495900, dated 9/13/2017, in the amount of $850, payable to Avionna Winfree, that Montrea Donaldson and Avionna Winfree knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Crystal N. Gardenshire, Monica Norton



with purpose to defraud, or knowing that he/she is facilitating a fraud on Muldoons and/or

Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 31829, dated 9/4/2017, in the amount of $642.17, payable to Chrystal Gardenshire, that Montrea Donaldson, Crystal Gardenshire, and Monica Norton knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on Cuyahoga County Land







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Reutilization Corp, and/or Key Bank, and/or US Bank, did utter, or possess with purpose to utter, any writing, to wit: check 163580, dated 8/25/2017, in the amount of $950, payable to Frank Thompson, that Montrea Donaldson and Frank Thompson knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Terrence Craig Wilson



with purpose to defraud, or knowing that he is facilitating a fraud on Cuyahoga County Land Reutilization Corp and/or Key Bank, did utter, or possess with purpose to utter, any writing, to wit: check 16355, dated 8/21/2017, in the amount of $1,300, payable to Terrence Wilson, that Montrea

Donaldson and Terrence Wilson knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Crystal N. Gardenshire, Monica Norton



with purpose to defraud, or knowing that he/she is facilitating a fraud on Cuyahoga County Land Reutilization Corp and/or Key Bank, did utter, or possess with purpose to utter, any writing, to wit: check 163565, dated 8/21/2017, in the amount of $1,035, payable to Chrystal Gardenshire, that

Montrea Donaldson, Crystal Gardenshire, and Monica Norton knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Darlene Vernon



with purpose to defraud, or knowing that he/she is facilitating a fraud on Cuyahoga County Land Reutilization Corp, and/or Key Bank, and/or Cleveland Fire Fighters Credit Union, did utter, or

possess with purpose to utter, any writing, to wit: check 164982, dated 9/11/2017, in the amount of







of 38

$4,250, payable to Darlene Vernon, that Montrea Donaldson and Darlene Vernon knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on Triad Staffing, and/or PNC

Bank, and/or Mookie's Beverage, did utter, or possess with purpose to utter, any writing, to wit: check 485717, dated 8/18/2017, in the amount of $493.56, payable to Terrence Wilson, that Montrea Donaldson and Terrence Wilson knows to have been forged.


Ohio.


§2913.31(A)(3)


Date of Offense On or about May 20, 2017


with purpose to defraud, or knowing that he is facilitating a fraud on Triad Staffing, and/or PNC Bank, and/or CheckSmart, did utter, or possess with purpose to utter, any writing, to wit: check 485701, dated 8/18/2017, in the amount of $450.85, payable to Frank Thompson, that Montrea Donaldson and Frank Thompspn knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on Triad Staffing, and/or PNC Bank, and/or Ace Cash Express, did utter, or possess with purpose to utter, any writing, to wit: check

484068, dated 8/25/2017, in the amount of $760.53, payable to Dontez Elem, that Montrea

Donaldson knows to have been forged.







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Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on Triad Staffing, and/or PNC

Bank, and/or Lee Harvard Convenience Store, did utter, or possess with purpose to utter, any writing, to wit: check 484098, dated 8/18/2017, in the amount of $508.17, payable to Briana Dixon, that Montrea Donaldson knows to have been forged.


Ohio.


§2913.31(A)(3)


Date of Offense On or about October 11, 2017


with purpose to defraud, or knowing that he is facilitating a fraud on Triad Staffing, and/or PNC Bank, and/or Check n' Go, did utter, or possess with purpose to utter, any writing, to wit: check 485710, dated 10/6/2017, in the amount of $410.25, payable to Terrence Wilson, that Montrea Donaldson and Terrence Wilson knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Janet Noble

Date of Offense On or about November 1, 2017


with purpose to defraud, or knowing that he/she is facilitating a fraud on Triad Staffing, and/or PNC Bank, and/or John's Deli, did utter, or possess with purpose to utter, any writing, to wit: check

516719, dated 10/31/2017, in the amount of $539.12, payable to Janet Noble, that Montrea

Donaldson and Janet Noble knows to have been forged.







of 38


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Monica Norton

Date of Offense On or about November 1, 2017


with purpose to defraud, or knowing that he/she is facilitating a fraud on Triad Staffing, and/or PNC

Bank, and/or John's Deli, did utter, or possess with purpose to utter, any writing, to wit: check 516710, dated 10/31/2017, in the amount of $537.74, payable to Kendrick Blakney, that Montrea Donaldson and Monica Norton knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Talica M. Green, Latrent Maurice Redrick



with purpose to defraud, or knowing that he/she is facilitating a fraud on PS Cleveland, and/or US Bank, and/or Key Bank, did utter, or possess with purpose to utter, any writing, to wit: check 617628, dated 9/26/2017, in the amount of $965.33, payable to Talica Green, that Montrea Donaldson, Talica Green, and Latrent Redrick knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Talica M. Green, Latrent Maurice Redrick



with purpose to defraud, or knowing that he/she is facilitating a fraud on PS Cleveland, and/or US Bank, and/or Key Bank, did utter, or possess with purpose to utter, any writing, to wit: check

617617, dated 9/26/2017, in the amount of $939.35, payable to Talica Green, that Montrea

Donaldson, Talica Green, and Latrent Redrick knows to have been forged.







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Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Andre Smiler, Darrin Roulette



with purpose to defraud, or knowing that he is facilitating a fraud on PS Cleveland and/or US Bank,

did utter, or possess with purpose to utter, any writing, to wit: check 817663, dated 10/2/2017, in the amount of $191.23, payable to Andre Smiler, that Montrea Donaldson, Andre Smiler, and Darrin Roulette knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Andre Smiler, Darrin Roulette



with purpose to defraud, or knowing that he is facilitating a fraud on Ohio Deptartment of Job and Family Services and/or Walmart, did utter, or possess with purpose to utter, any writing, to wit: check 10775, dated 10/2/2017, in the amount of $524, payable to Darrin Roulette, that Montrea Donaldson, Andre Smiler, and Darrin Roulette knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on G-Lancer on 21, and/or JP Morgan Chase Bank, and/or US Bank, did utter, or possess with purpose to utter, any writing, to wit:

check 551395, dated 9/5/2017, in the amount of $691.63, payable to Terrence Wilson, that Montrea








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Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on G-Lancer on 21, and/or JP

Morgan Chase Bank, and/or US Bank, did utter, or possess with purpose to utter, any writing, to wit: check 551461, dated 9/17/2017, in the amount of $623.49, payable to Terrence Wilson, that Montrea Donaldson and Terrence Wilson knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on G-Lancer on 21, and/or JP Morgan Chase Bank, and/or US Bank, did utter, or possess with purpose to utter, any writing, to wit: check 551503, dated 9/18/2017, in the amount of $803.55, payable to Terrence Wilson, that Montrea Donaldson and Terrence Wilson knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on G-Lancer on 21, and/or JP Morgan Chase Bank, and/or US Bank, did utter, or possess with purpose to utter, any writing, to wit:

check 551527, dated 9/18/2017, in the amount of $918.32, payable to Terrence Wilson, that Montrea








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Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Angella Kelley



with purpose to defraud, or knowing that he/she is facilitating a fraud on Singleton Construction

Company and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 8936, dated 7/5/2017, in the amount of $991.67, payable to Kiah Ivory, that Montrea Donaldson and Angella Kelley knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Antonio Douglas, Angella Kelley



with purpose to defraud, or knowing that he/she is facilitating a fraud on Singleton Construction Company and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 8935, dated 7/5/2017, in the amount of $988.24, payable to Kiah Ivory, that Montrea Donaldson and Angella Kelley knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he/she is facilitating a fraud on Singleton Construction Company and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing,

to wit: check 8937, dated 7/5/2017, in the amount of $993.07, payable to Kiah Ivory, that Montrea

Donaldson and Angella Kelley knows to have been forged.







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Ohio.


§2913.31(A)(3)







Ohio.


§2913.31(A)(3)






Ohio.


§2913.31(A)(3)













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Ohio.


§2913.31(A)(3)







Ohio.


§2913.31(A)(3)






Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on Lawrence M Kahn, Attorney at Law and/or Key Bank, did utter, or possess with purpose to utter, any writing, to wit: check 14889,

dated 7/25/2017, in the amount of $1,500, payable to Terrence Wilson, that Montrea Donaldson and

Terrence Wilson knows to have been forged.







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Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on Lawrence M Kahn, Attorney at

Law and/or Key Bank, did utter, or possess with purpose to utter, any writing, to wit: check 14998, dated 7/26/2017, in the amount of $1,500, payable to Terrence Wilson, that Montrea Donaldson and Terrence Wilson knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on Lawrence M Kahn, Attorney at Law and/or Key Bank, did utter, or possess with purpose to utter, any writing, to wit: check 14999, dated 7/26/2017, in the amount of $1,500, payable to Terrence Wilson, that Montrea Donaldson and Terrence Wilson knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Demar E. Day



with purpose to defraud, or knowing that he is facilitating a fraud on Kent State University and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check

50339947, dated 8/19/2014, in the amount of $941.19, payable to Demar Day, that Montrea

Donaldson and Demar Day knows to have been forged.







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Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he is facilitating a fraud on Kent State University and/or

Hun, did utter, or possess with purpose to utter, any writing, to wit: check 50337363, dated 8/18/2014, in the amount of $4,860.15, payable to Cierra King, that Montrea Donaldson and Demar Day knows to have been forged.


Ohio.


§2913.05(A)




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.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Marcellina Poole



with purpose to defraud, or knowing that he/she is facilitating a fraud on Kent State University and/or Hun, did utter, or possess with purpose to utter, any writing, to wit: check 50339965, dated

8/21/2014, in the amount of $3,500, payable to Latoya Thomas, that Montrea Donaldson and

Marcellina Poole knows to have been forged.







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Ohio.


§2913.05(A)

Defendants Montrea Donaldson, Marcellina Poole



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.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Malaika Reid

Date of Offense On or about June 30, 2017


with purpose to defraud, or knowing that he/she is facilitating a fraud on Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 1305976, dated 8/27/2014, in the amount of $3,500, payable to Malaika Reid, that Montrea Donaldson and Malaika Reid knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he/she is facilitating a fraud on Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 1305970, dated 6/27/2014, in

the amount of $925.62, payable to Malaika Reid, that Montrea Donaldson and Malaika Reid knows

to have been forged.







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Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he/she is facilitating a fraud on Huntington National Bank,

did utter, or possess with purpose to utter, any writing, to wit: check 1305972, dated 6/27/2014, in the amount of $942.12, payable to Malaika Reid, that Montrea Donaldson and Malaika Reid knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he/she is facilitating a fraud on Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 1305978, dated 6/27/2014, in the amount of $943.39, payable to Malaika Reid, that Montrea Donaldson and Malaika Reid knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Kiah Ivory, Khalyl T. Wadley, Roger E. Wiley

Date of Offense On or about March 17, 2015


with purpose to defraud, or knowing that he/she is facilitating a fraud on Thomas Lane Inc and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check

5120, dated 3/16/2015, in the amount of $766.49, payable to Kiah Ivory, that Montrea Donaldson,

Kiah Ivory, Khalyl Wadley, and Roger Wiley knows to have been forged.







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Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he/she is facilitating a fraud on Thomas Lane Inc and/or

Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 5123, dated 3/16/2015, in the amount of $803.09, payable to Kiah Ivory, that Montrea Donaldson, Kiah Ivory, Khalyl Wadley, and Roger Wiley knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he/she is facilitating a fraud on Thomas Lane Inc and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 5124, dated 3/16/2015, in the amount of $791.56, payable to Kiah Ivory, that Montrea Donaldson, Kiah Ivory, Khalyl Wadley, and Roger Wiley knows to have been forged.


Ohio.


§2913.31(A)(3)




with purpose to defraud, or knowing that he/she is facilitating a fraud on Thomas Lane Inc and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check

5125, dated 3/16/2015, in the amount of $787.19, payable to Kiah Ivory, that Montrea Donaldson,

Kiah Ivory, Khalyl Wadley, and Roger Wiley knows to have been forged.







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Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Joseph Clutter, Kiah Ivory, Khalyl T. Wadley, Roger E. Wiley




Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 5110, dated 3/16/2015, in the amount of $2,400, payable to Kiah Ivory, that Montrea Donaldson, Kiah Ivory, Khalyl Wadley, and Roger Wiley knows to have been forged.


Ohio.


§2913.05(A)






Ohio.


§1315.55(A)(3)






Ohio.







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§2913.31(A)(3)

Defendants Montrea Donaldson, Omni Cunningham




Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 5119, dated 3/16/2015, in the amount of $786.12, payable to Omni Cunningham, that Montrea Donaldson and Omni Cunningham knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Omni Cunningham



with purpose to defraud, or knowing that he/she is facilitating a fraud on Thomas Lane Inc and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 5111, dated 3/16/2015, in the amount of $793.85, payable to Omni Cunningham, that Montrea Donaldson and Omni Cunningham knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Jiare Clark



with purpose to defraud, or knowing that he is facilitating a fraud on Thomas Lane Inc and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check

5128, dated 3/16/2015, in the amount of $788.91, payable to Jiare Clark, that Montrea Donaldson

and Jiare Clark knows to have been forged.







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Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Jiare Clark



with purpose to defraud, or knowing that he is facilitating a fraud on Thomas Lane Inc and/or

Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 5130, dated 3/16/2015, in the amount of $792.87, payable to Jiare Clark, that Montrea Donaldson and Jiare Clark knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Lamar Nunley



with purpose to defraud, or knowing that he is facilitating a fraud on Thomas Lane Inc and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 5139, dated 3/16/2015, in the amount of $867.89, payable to Lamar Nunley, that Montrea Donaldson and Lamar Nunley knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Lamar Nunley



with purpose to defraud, or knowing that he is facilitating a fraud on Thomas Lane Inc and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check

5141, dated 3/16/2015, in the amount of $807.10, payable to Lamar Nunley, that Montrea Donaldson

and Lamar Nunley knows to have been forged.







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Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Joshua U. Trundle, Joseph Clutter

Date of Offense On or about April 17, 2015



Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 15526, dated 4/15/2015, in the amount of $3,500, payable to Joshua Trundle, that Montrea Donaldson, Joshua Trundle, and Joseph Clutter knows to have been forged.


Ohio.


§2913.05(A)






Ohio.


§1315.55(A)(3)






Ohio.







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§1315.55(A)(3)







Ohio.


§1315.55(A)(3)






Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Danielle Sheron, Joseph Clutter



with purpose to defraud, or knowing that he/she is facilitating a fraud on Thomas Lane Inc and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 15529, dated 4/15/2015, in the amount of $3,500, payable to Joshua Trundle, that Montrea

Donaldson, Danielle Sheron, and Joseph Clutter knows to have been forged.


Ohio.







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§2913.31(A)(3)




with purpose to defraud, or knowing that he/she is facilitating a fraud on Thomas Lane Inc and/or Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 15534, dated 4/17/2015, in the amount of $952, payable to Danielle Sheron, that Montrea

Donaldson, Danielle Sheron, and Joseph Clutter knows to have been forged.


Ohio.


§2913.05(A)




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



Ohio.


§1315.55(A)(3)






Ohio.







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§1315.55(A)(3)






Ohio.


§2913.31(A)(3)





Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check 15545, dated 4/17/2015, in the amount of $3,400, payable to Danielle Sheron, that Montrea Donaldson, Danielle Sheron, and Joseph Clutter knows to have been forged.


Ohio.


§2913.31(A)(3)

Defendants Montrea Donaldson, Pasquinel R. Averyheart




Huntington National Bank, did utter, or possess with purpose to utter, any writing, to wit: check

15538, dated 4/17/2015, in the amount of $3,500, payable to Pasquinel Averyheart, that Montrea Donaldson and Pasquinel Averyheart knows to have been forged.


Ohio.







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§2913.05(A)

Defendants Montrea Donaldson, Pasquinel R. Averyheart, Khalyl T. Wadley



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



Ohio.


§1315.55(A)(3)






Ohio.


§1315.55(A)(3)







Ohio.


§1315.55(A)(3)










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Ohio.

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