Cuyahoga County Court of Common Pleas - … · Cuyahoga County Court of Common Pleas ... “Rio”...

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 Participating In A Criminal Gang - F2 VS. 2923.42(A)

13 Defendants 42 Additional Count(s)

Defendants

Ledon Allen, Ibrahim Adbul-Haqq, Randall Brooks, Robert George, Idale Goins, Ron Hunter II, Mickey James, Eric

Myrieckes Jr., Malik A. Pruitt, Mitchell Taylor Jr., Quasean Townsend, Theodore D. Travis, Timothy Willis

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

01/01/2014 to 01/23/2015 January of 2015 592669-15-CR

The State of Ohio, }

SS.

Cuyahoga County

Count 1 Participating In A Criminal Gang - F2 2923.42(A)

Defendants Ledon Allen, Ibrahim Adbul-Haqq, Randall Brooks, Robert George, Idale Goins,

Ron Hunter II, Mickey James, Eric Myrieckes Jr., Malik A. Pruitt, Mitchell Taylor

Jr., Quasean Townsend, Theodore D. Travis

Date of Offense On or about January 1, 2014 to January 23, 2015

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

In the County of Cuyahoga, the Defendants did actively participate in a criminal gang, with

knowledge that the criminal gang engages in or had engaged in a pattern of criminal gang

activity, and did purposely promote, further, or assist any criminal conduct, as defined in

division (C) of section 2923.41 of the Revised Code, or did purposely commit or engage in

any act that constituted criminal conduct, as defined in division (C) of section 2923.41 of the

Revised Code, to wit:

Aggravated Murder, in violation of R.C. 2903.01(A), Murder, in violation of R.C.

2903.02(A), Felonious Assault, in violation of R.C. 2903.11(A)(1) and R.C. 2903.11(A)(2),

Kidnapping, in violation of R.C. 2905.01(A)(2) and R.C. 2905.01(B)(2), Aggravated

Robbery, in violation of R.C. 2911.01(A)(1) and R.C. 2911.01(A)(3), Shooting into a

Habitation in violation of 2923.161(A)(1); Discharge of a Firearm on or Near prohibited


A True Bill Indictment



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Premises, in violation of R.C. 2923.162(A)(3), Criminal Damaging in violation of R.C.

2909.06(A), Obstructing Justice, in violation of R.C. 2921.32(A)(2) and R.C 2921.32(A)(4),

Theft, in violation of 2913.02(A)(1), Bribery in violation of R.C. 2921.02, and Trafficking in

violation of R.C. 2925.03.

Introduction

1. The Criminal Gang, Cutthroats, also known as CT and 105 operated in Cuyahoga County from approximately January 1, 2011 through January 23, 2015. This

gang is affiliated with and considered a subset of the Heartless Felons.

2. The epicenter of the Criminal Gangs territory is 105th and Superior, with its territory encompassing Superior to St. Clair, and MLK to Parkwood, in the city of Cleveland,

Cuyahoga County.

3. This Criminal Gang and the Persons Associated with the Criminal Gang were joined in purpose over a period of time, although their various roles were different, in order to

accomplish the main purposes of the Criminal Gang. These activities occurred with the

knowledge and/or support of and/or were aided and abetted by each of the persons

associated with the Criminal Gang.

4. Members of the Criminal Gang held ranks including but not limited to Godfather, Godson, HNIC, Underboss, Lieutenants, and Foot Soldiers.

5. The Criminal Gang in this matter, consisting of a group of individuals whose common purpose was to execute the scheme on behalf of the Criminal Gang, consisted of, but is

not limited to, the following:

Ledon Don Allen, Ibrahim E.B. Abdual-Haqq, Tavion Polo Tae Bogan, Mario





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Rio Braxton, Lovell Vell or Flockavelli Briggs, Randall Skeet Brooks,

Lavontrae Von Von Durden, Robert Bobby George, Idale Dale Goins, Ron

Poodah Hunter II, Mickey Tooder James, Russell Russ James, Rodney Johnson,

Laron Lloyd, Eric E Myrieckes Jr., Malik Oleek Pruitt Jr., Mitchell Mickey

Taylor Jr., Quasean Qua-Qua Townsend, Theodore Theo Travis, L.W. DOB:

03/03/1997, Nathaniel Nate Wright.

6. Members of the Criminal Gang attended meetings organized by the Criminal Gangs leaders where assignments, known as missions, were given to lower ranking

members to complete. Missions included, but were not limited to, robbing local

establishments, homes, and individuals, collecting taxes or fees from individuals

dealing drugs in the Criminal Gangs territory, and retaliation against rival gangs. All

missions were to be carried out within three days of the order being handed down.

7. Any profits members of the Criminal Gang made from missions or other approved criminal acts were to be split, with the majority of the profit given to the leaders of the

Criminal Gang. Profits were used by the gang for various reasons including, but not

limited to, a means of income for members of the Criminal Gang, and bail and

commissary for other members of the Criminal Gang who were incarcerated.

8. Members of the Criminal Gang were also expected to learn and follow 10 Golden Rules. If members violated those rules, failed to complete a mission, or were

insubordinate to a higher rank, they would be give a violation or v at the meetings.

An individual who was given a v would be whacked or physically assaulted for

approximately two minutes by two members of the Criminal Gang. The individual

being punished would have to abide by the no hands policy, under which the

individual could not fight back. If the individual fell to the ground during the assault

they would be permanently expelled from the Criminal Gang.





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9. Members of the Criminal Gang possess gang paraphernalia including, but not limited to, clothing with Cutthroat or CT4L (Cutthroat for life), tributes to incarcerated

members such as the bank bros, and tributes to deceased Criminal Gang members

such a Mario Rio Braxton and Tavion Polo Tae Bogan. A non-member wearing

gang paraphernalia would be false flagging and result in either serious physical harm

or possibly death.

10. Some Members of the Criminal Gang have tattoos that are a tribute to the Criminal Gang as well as deceased Criminal Gang Members. These tattoos include, but are not

limited to: Cutthroat, 105, Family First, Family 1st OTF (Only the Fam), and

Fam. The term Fam is a term used by members of the Criminal Gang to describe

the Criminal Gang.

Conduct of the Criminal Gang

Among the means and methods by which the defendants and their associates conducted and

participated in the conduct of the affairs of the Criminal Gang were the following:

1. Members of the Criminal Gang and their associates committed acts involving Assault in connection with maintaining discipline and punishment of the Criminal Gang

Members and their associates.

2. Members of the Criminal Gang and their associates committed acts involving Attempted Murder, Aggravated Robbery, Felonious Assault, Shooting into a

Habitation, and Unlawful Discharge of a Firearm over a Public Roadway in connection

with maintaining the authority standing, and reputation of the Criminal Gang Members

and their associates.

3. Members of the Criminal Gang and their associates committed acts involving





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Attempted Murder, Aggravated Robbery, Felonious Assault, Shooting into a


with maintaining the territory of the Criminal Gang Members and their associates.

4. Members of the Criminal Gang and their associates committed acts involving Narcotics Trafficking, Firearms Trafficking, Aggravated Robbery, and Felonious Assault in

connection with generating income for the Criminal Gang and its associates.

Predicate Acts Committed by the Criminal Gang

The required predicate acts constituting the pattern of criminal gang activity as defined in

Sections 2923.41 and as required by 2923.42 include criminal violations of Ohio Revised

Code. The following members of the Criminal Gang have already been convicted or

adjudicated of predicate acts attributed to the Cutthroat Criminal Gang:

Ledon Don Allen: DL-11-100993; DL-10-121064; DL-10-100613;

DL-09-114533

Tavion Polo Tae Bogan: DL-13-111628; DL-13-101153; DL-13-101009;

DL-12-118878

Mario Rio Braxton: DL-11-101450; DL-10-102179; DL-09-124024;

DL-09-121235; DL-09-119345; DL-09-113307;

DL-09-110600

Lovell Vell or Flockavelli Briggs: 1:14-cr-00030-DCN

Randall Skeet Brooks: CR-14-585831

Lavontrae Von Von Durden: 1:14-cr-00013-DCN-1; 1:13-mj-04170-NAV

Robert Bobby George: DL-11-111795; DL-11105076; DL-06-106895

Idale Dale Goins: CR-14-584662; DL-12-100980; DL-09-115696





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Ron Poodah Hunter II: DL-13-110238

Mickey Tooder James: CR-14-586065; DL-13-113530; DL-13-109606;

DL-10-122084

Russell Russ James: CR-12-563251; CR-13-574861

Rodney Johnson: 1:14-cr-00012-DNC-1

Laron Lloyd: CR-14-585186

Eric E Myrieckes Jr.: CR-14-588495; DL-11-111795

Malik Oleek Pruitt Jr.: CR-14-588852; DL-13-102969; DL-09-114527

Mitchell Mickey Taylor Jr.: CR-14-589272; DL-10-100983; DL-09-119345;

DL-09-110604

Quasean Qua-Qua Townsend: CR-13-578147A

Theodore Theo Travis: CR-10-536771; CR-11-549845; CR-12-559172;

CR-13-579153; DL-02-101102; DL-01-106738 (F4)

L.W. DOB: 03/03/1997: DL-13-113530; DL-13-113686; DL-12-119117

Nathaniel Nate Wright: 1:14-cr-00013-DCN-2; 1:13-mj-04169-NAV

The following members of the Criminal Gang have pending predicate acts attributed to the

Cutthroat Criminal Gang and are incorporated as if re-written herein:

Robert Bobby George: CR-14-588849; CR-14-589369

Mitchell Mickey Taylor: CR-14-588849; CR-14-589369

Theodore Theo Travis: 1:14-cr-00331-JRA-1





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Furthermore, the State hereby puts Defendants on notice that the additional new charges

listed below, also constitute predicate acts, and are incorporated as if re-written herein:

Ledon Don Allen: CR-15-592669 (ALL FELONY COUNTS)

Ibrahim E.B. Abdual-Haqq: CR-15-592669 (ALL FELONY COUNTS)

Randall Skeet Brooks CR-15-592669 (ALL FELONY COUNTS)

Idale Dale Goins: CR-15-592669 (ALL FELONY COUNTS)

Ron Poodah Hunter II: CR-15-592669 (ALL FELONY COUNTS)

Mickey James: CR-15-592669 (ALL FELONY COUNTS)

Malik Oleek Pruitt Jr.: CR-15-592669 (ALL FELONY COUNTS)

Quasean Qua-Qua Townsend: CR-15-592669

(ALL FELONY COUNTS)

Theodore Theo Travis: CR-15-592669 (ALL FELONY COUNTS)

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 10805 Hathaway, parcel number 109-19-

081 which is contraband and/or property derived from or through the commission or facilitation of

an offense, and/or is an instrumentality the offender(s) used or intended to use in the commission or

facilitation of a felony offense.

Forfeiture of a Weapon - 2941.1417(A)


the defendant(s) is/are the owner(s) and/or possessor(s) of WASR-10 Rifle with Folding Stock,

Serial Number 1-32217-2002; Mosser 500A 12 Guage Shotgun, Serial Number 5912925, which is

contraband and/or property derived from or through the commission or facilitation of an offense,





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and/or is an instrumentality the offender(s) used or intended to use in the commission or facilitation

of a felony offense.

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

Count 2 Engaging In A Pattern Of Corrupt Activity - F1 2923.32(A)(1)

Defendants Randall Brooks, Robert George, Idale Goins, Ron Hunter II, Mickey James, Eric

Myrieckes Jr., Malik A. Pruitt, Mitchell Taylor Jr., Quasean Townsend, Theodore

D. Travis


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

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

indirectly, the affairs of the enterprise through a pattern of corrupt activity or the collection of an

unlawful debt and at least one of the incidents of corrupt activity was a felony of the first, second, or

third degree, aggravated murder, or murder, or at least one of the incidents was a felony under the

law of this state that was committed prior to July 1, 1996, and constituted a felony of the first,

second, or third degree, aggravated murder, or murder or was committed on or after July 1, 1996, or

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

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

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

On or between the 1st day of January 2014 through the 23

rd day of January 2015, 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 AND

DELINQUENT, were associated with an Enterprise, as defined in Section 2923.31(C) of the

Revised Code.

The Cutthroat Enterprise

1. An enterprise, includes any union or group of individuals, associated-in-fact, where the group of persons are associated together for a common purpose of engaging in a





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course of conduct. An association-in-fact enterprise must have a structure, but it does

not need to have an ascertainable structure beyond that inherent in the pattern of

corrupt activity in which it engaged. An association-in-fact enterprise must have at

least three structural features: a purpose, relationships among those associated with the

enterprise, and longevity sufficient to permit these associates to pursue the enterprise's

purpose. The existence of an association-in-fact enterprise is often-times more readily

proven by what it does, rather than by abstract analysis of its structure.

2. To constitute an association-in-fact enterprise under O.R.C. 2923.31, a group need not have a hierarchical structure, a chain of command, or other business-like attributes;

decisions may be made on an ad hoc basis and by any number of methods. Members

of the group need not have fixed roles; different members may perform different roles

at different times. An enterprise is proved by evidence of an ongoing organization,

formal or informal, and by evidence that the various associates function as a continuing

unit. The existence of an enterprise is distinct from the pattern of corrupt activity, and

proof of one does not necessarily establish the other. Proof of a pattern of pattern of

corrupt activity may be sufficient in a particular prosecution under O.R.C. 2923.31 to

create an inference that an association-in-fact enterprise does exist.

3. 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.

4. The Criminal Gang, Cutthroats, also known as CT and 105 operated in Cuyahoga County from approximately January 1, 2011 through January 23, 2015. This

gang is affiliated with and considered a subset of the Heartless Felons.





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5. The epicenter of the Criminal Gangs territory is 105th and Superior, with its territory encompassing Superior to St. Clair, and MLK to Parkwood, in the city of Cleveland,

Cuyahoga County.

6. This Criminal Gang and the Persons Associated with the Criminal Gang were joined in purpose over a period of time, although their various roles were different, in order to

accomplish the main purposes of the Criminal Gang. These activities occurred with the

knowledge and/or support of and/or were aided and abetted by each of the persons

associated with the Criminal Gang.

7. Members of the Criminal Gang held ranks including but not limited to Godfather, Godson, HNIC, Underboss, Lieutenants, and Foot Soldiers.

8. The Cutthroat Enterprise in this matter, consisting of a group of individuals whose common purpose was to execute the scheme on behalf of the Criminal Gang.

9. Members of the Criminal Gang attended meetings organized by the Criminal Gangs leaders where assignments, known as missions, were given to lower ranking

members to complete. Missions included, but were not limited to, robbing local

establishments, homes, and individuals, collecting taxes or fees from individuals

dealing drugs in the Criminal Gangs territory, and retaliation against rival gangs. All

missions were to be carried out within three days of the order being handed down.

10. Any profits members of the Criminal Gang made from missions or other approved criminal acts were to be split, with the majority of the profit given to the leaders of the

Criminal Gang. Profits were used by the gang for various reasons including, but not

limited to, a means of income for members of the Criminal Gang, and bail and

commissary for other members of the Criminal Gang who were incarcerated.





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11. Members of the Criminal Gang were also expected to learn and follow 10 Golden Rules. If members violated those rules, failed to complete a mission, or were

insubordinate to a higher rank, they would be give a violation or v at the meetings.

An individual who was given a v would be whacked or physically assaulted for

approximately two minutes by two members of the Criminal Gang. The individual

being punished would have to abide by the no hands policy, under which the

individual could not fight back. If the individual fell to the ground during the assault

they would be permanently expelled from the Criminal Gang.

12. Members of the Criminal Gang possess gang paraphernalia including, but not limited to, clothing with Cutthroat or CT4L (Cutthroat for life), tributes to incarcerated

members such as the bank bros, and tributes to deceased Criminal Gang members

such a Mario Rio Braxton and Tavion Polo Tae Bogan. A non-member wearing

gang paraphernalia would be false flagging and result in either serious physical harm

or possibly death.

13. Some Members of the Criminal Gang have tattoos that are a tribute to the Criminal Gang as well as deceased Criminal Gang Members. These tattoos include, but are not

limited to: Cutthroat, 105, Family First, Family 1st OTF (Only the Fam),

and Fam. The term Fam is a term used by members of the Criminal Gang to

describe the Criminal Gang.

Conduct of the Illicit Cutthroat Enterprise

5. The Enterprise in this case existed as 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 Count(s). The Criminal Enterprise in this matter, consists of a

group of individuals whose common purpose was to execute the scheme outlined





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herein on behalf of the Cutthroat Gang.

6. This Enterprise functioned as a continuing unit by engaging in the diverse forms of illegal activities, as stated in this Count. In so doing, the DEFENDANTS AND

DELINQUENT NAMED BELOW are persons associated with the Enterprise who

participated in and/or managed the affairs of the Enterprise, as explained in this Count.

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: committing

criminal activity within Cuyahoga County for the sole benefit of the gang and its

members, included but was not limited to Aggravated Murder, in violation of R.C.

2903.01(A), Murder, in violation of R.C. 2903.02(A), Felonious Assault, in violation

of R.C. 2903.11(A)(1) and R.C. 2903.11(A)(2), Kidnapping, in violation of R.C.

2905.01(A)(2) and R.C. 2905.01(B)(2), Aggravated Robbery, in violation of R.C.

2911.01(A)(1) and R.C. 2911.01(A)(3), Shooting into a Habitation in violation of

2923.161(A)(1); Discharge of a Firearm on or Near prohibited Premises, in violation of

R.C. 2923.162(A)(3), Criminal Damaging in violation of R.C. 2909.06(A), Obstructing

Justice, in violation of R.C. 2921.32(A)(2) and R.C 2921.32(A)(4), Theft, in violation

of 2913.02(A)(1), Bribery in violation of R.C. 2921.02, and Drug Trafficking in

violation of R.C. 2925.03; Participating in a Criminal Gang in violation of Ohio

Revised Code Section 2923.42; and in furtherance of the above activity as explained in

this Count.

7. Among the means and methods by which the defendants and their associates conducted and participated in the conduct of the affairs of the Criminal Gang were the following:

8. Members of the Criminal Gang and their associates committed acts involving Assault in connection with maintaining discipline and punishment of the Criminal Gang

Members and their associates.

9. Members of the Criminal Gang and their associates committed acts involving





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Attempted Murder, Aggravated Robbery, Felonious Assault, Shooting into a


with maintaining the authority standing, and reputation of the Criminal Gang Members

and their associates.

10. Members of the Criminal Gang and their associates committed acts involving Attempted Murder, Aggravated Robbery, Felonious Assault, Shooting into a


with maintaining the territory of the Criminal Gang Members and their associates.

11. Members of the Criminal Gang and their associates committed acts involving Narcotics Trafficking, Firearms Trafficking, Aggravated Robbery, and Felonious

Assault in connection with generating income for the Criminal Gang and its associates.

12. The Illicit Cutthroat Enterprise in this matter consisted of:

Ledon Don Allen, Ibrahim E.B. Abdual-Haqq, Tavion Polo Tae Bogan, Mario

Rio Braxton, Lovell Vell or Flockavelli Briggs, Randall Skeet Brooks,

Lavontrae Von Von Durden, Robert Bobby George, Idale Dale Goins, Ron

Poodah Hunter II, Mickey Tooder James, Russell Russ James, Rodney Johnson,

Laron Lloyd, Eric E Myrieckes Jr., Malik Oleek Pruitt Jr., Mitchell Mickey

Taylor Jr., Quasean Qua-Qua Townsend, Theodore Theo Travis, L.W. DOB:

03/03/1997, Nathaniel Nate Wright.

and possibly 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 a pattern of corrupt activity as defined in Section

2923.31(I)(2)(a) or (I)(2)(c) of the Revised Code.





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Predicate Acts Committed by the Cutthroat Enterprise

13. The required predicate acts constituting the pattern of corrupt activity as defined in Section 2923.31(E) include criminal violations of Ohio Revised Code TITLE 29. The

following members of the Criminal Gang have already been convicted or adjudicated

of predicate acts attributed to the Cutthroat Criminal Gang, and the State hereby puts

Defendants on notice that the required predicate acts are outlined as if re-written herein

in all counts as outlined below:

Ledon Don Allen: DL-11-100993; DL-10-121064;

DL-10-100613; DL-09-114533

Tavion Polo Tae Bogan: DL-13-111628; DL-13-101153; DL-13-

101009;

DL-12-118878

Mario Rio Braxton: DL-11-101450; DL-10-102179; DL-09-

124024; DL-09-121235; DL-09-119345; DL-

09-113307; DL-09-110600

Lovell Vell or Flockavelli Briggs: 1:14-cr-00030-DCN

Randall Skeet Brooks: CR-14-585831

Lavontrae Von Von Durden: 1:14-cr-00013-DCN-1; 1:13-mj-

04170-NAV

Robert Bobby George: DL-11-111795; DL-11105076; DL-06-

106895

Idale Dale Goins: CR-14-584662; DL-12-100980;

DL-09-115696

Ron Poodah Hunter II: DL-13-110238





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Mickey Tooder James: CR-14-586065; DL-13-113530; DL-13-

109606; DL-10-122084

Russell Russ James: CR-12-563251; CR-13-574861

Rodney Johnson: 1:14-cr-00012-DNC-1

Laron Lloyd: CR-14-585186

Eric E Myrieckes Jr.: CR-14-588495; DL-11-111795

Malik Oleek Pruitt Jr.: CR-14-588852; DL-13-102969; DL-09-

114527

Mitchell Mickey Taylor Jr.: CR-14-589272

Quasean Qua-Qua Townsend: CR-13-578147A

Theodore Theo Travis: CR-10-536771; CR-11-549845; CR-12-

559172; CR-13-579153

L.W. DOB: 03/03/1997: DL-13-113686; DL-12-119117

Nathaniel Nate Wright: 1:14-cr-00013-DCN-2; 1:13-mj-04169-

NAV

are alleged as Predicate Acts, which are incorporated herein as if fully restated, against

the peace and dignity of the State of Ohio.

14. The following members of the Criminal Gang have pending predicate acts attributed to the Cutthroat Criminal Gang and are incorporated as if re-written herein:

Robert Bobby George: CR-14-588849; CR-14-589369

Mitchell Mickey Taylor: CR-14-588849; CR-14-589369





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Theodore Theo Travis: 1:14-cr-00331-JRA-1

15. Furthermore, the State hereby puts Defendants on notice that the additional new charges listed below, also constitute predicate acts, and are incorporated as if re-written

herein:

Ledon Don Allen: CR-15-592669 (ALL FELONY COUNTS)

Ibrahim E.B. Abdual-Haqq: CR-15-592669 (ALL FELONY COUNTS)

Randall Skeet Brooks CR-15-592669 (ALL FELONY COUNTS)

Idale Dale Goins: CR-15-592669 (ALL FELONY COUNTS)

Ron Poodah Hunter II: CR-15-592669 (ALL FELONY COUNTS)

Mickey James: CR-15-592669 (ALL FELONY COUNTS)

Malik Oleek Pruitt Jr.: CR-15-592669 (ALL FELONY COUNTS)

Quasean Qua-Qua Townsend: CR-15-592669

(ALL FELONY COUNTS)

Theodore Theo Travis: CR-15-592669 (ALL FELONY COUNTS)

L.W. DOB 03/03/1997: CR-15-592669 (ALL FELONY COUNTS)

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 (any and all Aggravated Murder counts, in violation of R.C. 2903.01(A); any and all

Murder counts, in violation of R.C. 2903.02(A); any and all Murder counts, in violation of

R.C. 2903.02(A)/2923.02; any and all Kidnapping counts in violation of Ohio Revised Code

Section 2905.01; any and all Felonious Assault counts in violation of Ohio Revised Code

Section 2903.01; any and all Attempted Felonious Assault counts in violation of Ohio

Revised Code Section 2923.02/2903.01; any and all Robbery counts in violation of Ohio

Revised Code Section 2911.01; any and all Shooting into a Habitation in violation of





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2923.161(A)(1); any and all Discharge of a Firearm on or Near prohibited Premises counts, in

violation of R.C. 2923.162(A)(3); any and all Bribery counts in violation of Ohio Revised

Code Section 2921.02, contrary to and in violation of Section 2923.32(A)(1) of the Ohio

Revised Code, and thereby, this COUNT TWO, 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.


Count 3 Conspiracy F2 2923.01(A)(2)






In the County of Cuyahoga, the Defendants did, with purpose to commit or promote or

facilitate the commission of Engaging in an Pattern of Corrupt Activity, O.R.C.

2923.32(A)(1), agree with another person or persons, that one or more of them would engage

in conduct that would facilitate the commission of the specified offense, to wit, committing

criminal activity within Cuyahoga County for the sole benefit of the gang and its members,

included but was not limited to: Aggravated Murder, in violation of R.C. 2903.01(A),

Murder, in violation of R.C. 2903.02(A), Felonious Assault, in violation of R.C.

2903.11(A)(1) and R.C. 2903.11(A)(2), Kidnapping, in violation of R.C. 2905.01(A)(2) and

R.C. 2905.01(B)(2), Aggravated Robbery, in violation of R.C. 2911.01(A)(1) and R.C.

2911.01(A)(3), Shooting into a Habitation in violation of 2923.161(A)(1); Discharge of a

Firearm on or Near prohibited Premises, in violation of R.C. 2923.162(A)(3), Criminal

Damaging in violation of R.C. 2909.06(A), Obstructing Justice, in violation of R.C.

2921.32(A)(2) and R.C 2921.32(A)(4), Theft, in violation of 2913.02(A)(1), Bribery in

violation of R.C. 2921.02, and Drug Trafficking in violation of R.C. 2925.03; Participating in

a Criminal Gang in violation of Ohio Revised Code Section 2923.42; and in furtherance of

the above activity as explained in this Count, including but not limited to:

Ledon Don Allen, Ibrahim E.B. Abdual-Haqq, Tavion Polo Tae Bogan, Mario Rio





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Braxton, Lovell Vell or Flockavelli Briggs, Randall Skeet Brooks, Lavontrae Von

Von Durden, Robert Bobby George, Idale Dale Goins, Ron Poodah Hunter II, Mickey

Tooder James, Russell Russ James, Rodney Johnson, Laron Lloyd, Eric E Myrieckes

Jr., Malik Oleek Pruitt Jr., Mitchell Mickey Taylor Jr., Quasean Qua-Qua Townsend,

Theodore Theo Travis, L.W. DOB: 03/03/1997, Nathaniel Nate Wright.

FURTHERMORE, and the object of the conspiracy was a felony of the first degree.

Criminal Gang Activity Specification - 2941.142(A)


the offender committed the felony that is an offense of violence while participating in a criminal

gang as defined in Section 2923.41 of the Ohio Revised Code.


Count 4 Conspiracy F2 2923.01(A)(1)






In the County of Cuyahoga, the Defendants did, with purpose to commit or promote or

facilitate the commission of Engaging in an 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, to wit: committing criminal activity within the Cuyahoga County for the

sole benefit of the gang and its members, included but was not limited to: Aggravated

Murder, in violation of R.C. 2903.01(A), Murder, in violation of R.C. 2903.02(A), Felonious

Assault, in violation of R.C. 2903.11(A)(1) and R.C. 2903.11(A)(2), Kidnapping, in violation

of R.C. 2905.01(A)(2) and R.C. 2905.01(B)(2), Aggravated Robbery, in violation of R.C.

2911.01(A)(1) and R.C. 2911.01(A)(3), Shooting into a Habitation in violation of

2923.161(A)(1); Discharge of a Firearm on or Near prohibited Premises, in violation of R.C.

2923.162(A)(3), Criminal Damaging in violation of R.C. 2909.06(A), Obstructing Justice, in

violation of R.C. 2921.32(A)(2) and R.C 2921.32(A)(4), Theft, in violation of 2913.02(A)(1),

Bribery in violation of R.C. 2921.02, and Drug Trafficking in violation of R.C. 2925.03;

Participating in a Criminal Gang in violation of Ohio Revised Code Section 2923.42; and in





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furtherance of the above activity as explained in this Count, including but not limited to:

Ledon Don Allen, Ibrahim E.B. Abdual-Haqq, Tavion Polo Tae Bogan, Mario Rio

Braxton, Lovell Vell or Flockavelli Briggs, Randall Skeet Brooks, Lavontrae Von

Von Durden, Robert Bobby George, Idale Dale Goins, Ron Poodah Hunter II, Mickey

Tooder James, Russell Russ James, Rodney Johnson, Laron Lloyd, Eric E Myrieckes

Jr., Malik Oleek Pruitt Jr., Mitchell Mickey Taylor Jr., Quasean Qua-Qua Townsend,

Theodore Theo Travis, L.W. DOB: 03/03/1997, Nathaniel Nate Wright.

FURTHERMORE, and the object of the conspiracy was a felony of the first degree.






Count 5 Attempted Murder - F1 2923.02 / 2903.02(B)

Defendants Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James

Date of Offense On or about February 16, 2014


did attempt to cause the death of Ramel Lee, as a proximate result of the offender committing or

attempting to commit an offense of violence that is a felony of the first or second degree, to wit:

Felonious Assault in violation of Ohio Revised Code 2903.11, in violation of Section 2903.02 of the

Revised Code.





Firearm Specification - 1 year - 2941.141(A)





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the offender had a firearm on or about his person or under his control while committing the offense.



the offender had a firearm on or about his person or under his control while committing the offense

and displayed the firearm, brandished the firearm, indicated that he possessed the firearm, or used it

to facilitate the offense.

Firearm Specification - 5 year, "Drive By Shooting" - 2941.146(A)


the offender committed the violation of Section 2923.161 of the Revised Code or the felony that

includes, as an essential element, purposely or knowingly causing or attempting to cause the death of

or physical harm to another and that the offense was committed by discharging a firearm from a

motor vehicle other than a manufactured home.






did attempt to cause the death of Malcolm Edwards, as a proximate result of the offender committing

or attempting to commit an offense of violence that is a felony of the first or second degree, to wit:


Revised Code.












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did attempt to cause the death of Celeste Balian, as a proximate result of the offender committing or



Revised Code.














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did attempt to cause the death of Radica Williams, as a proximate result of the offender committing



Revised Code.

















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did attempt to cause the death of Demetrius Keith, as a proximate result of the offender committing



Revised Code.



















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did attempt to cause the death of Juan Smith, as a proximate result of the offender committing or



Revised Code.




















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Count 11 Felonious Assault - F2 2903.11(A)(2)




did knowingly cause or attempt to cause physical harm to Ramel Lee by means of a deadly weapon

or dangerous ordnance, to wit: WASR-10 Rifle with Folding Stock,.






















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did knowingly cause or attempt to cause physical harm to Malcolm Edwards by means of a deadly

weapon or dangerous ordnance, to wit: WASR-10 Rifle with Folding Stock,.






















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did knowingly cause or attempt to cause physical harm to Celeste Balian by means of a deadly























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did knowingly cause or attempt to cause physical harm to Radica Williams by means of a deadly























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did knowingly cause or attempt to cause physical harm to Demetrius Keith by means of a deadly























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did knowingly cause or attempt to cause physical harm to Juan Smith by means of a deadly weapon

or dangerous ordnance, to wit: WASR-10 Rifle with Folding Stock,.






















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did knowingly cause serious physical harm to Juan Smith.























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Count 18 Improperly Handling Firearms In A Motor Vehicle - F4 2923.16(B)




did knowingly transport or have a loaded firearm in a motor vehicle in such a manner that the

firearm is accessible to the operator or any passenger without leaving the vehicle.




















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Count 19 Improperly Handling Firearms In A Motor Vehicle - F4 2923.16(A)




did knowingly discharge a firearm while in or on a motor vehicle.
















Count 20 Discharge Of Firearm On Or Near Prohibited Premises - F1 2923.162(A)(3)




did discharge a firearm upon or over a public road or highway and the violation caused serious

physical harm to a person Juan Smith.







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Count 21 Improperly Discharging Into Habitation - F2 2923.161(A)(1)




knowingly, without privilege, did discharge a firearm at or into an occupied structure that is a

permanent or temporary habitation of John Doe.















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Count 22 Criminal Damaging Or Endangering - M2 2909.06(A)(1)




did knowingly cause or create a substantial risk of physical harm, by any means, to property of Julius

Smoot, to wit: GMC Yukon, without his consent.


Count 23 Aggravated Robbery - F1 2911.01(A)(1)

Defendants Malik A. Pruitt



did, in attempting or committing a theft offense, as defined in section 2913.01 and 2913.02 of the

Revised Code, or in fleeing immediately after the attempt or offense upon Jackee Johnson did have a

deadly weapon, to wit: firearm, on or about his person or under his control and either displayed the

weapon, brandished it, indicated that he possessed it, or used it.











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Count 24 Robbery - F2 2911.02(A)(2)




did, in attempting or committing a theft offense, as defined in Section 2913.01 and 2913.02 of the

Revised Code, or in fleeing immediately after the attempt or offense upon Jackee Johnson, did

inflict, attempt to inflict, or threaten to inflict physical harm on another, Jackee Johnson.


















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Count 25 Kidnapping - F1 2905.01(A)(2)




did, by force, threat, or deception, purposely remove Jackee Johnson from the place where she was

found or restrain the liberty of her for the purpose of facilitating the commission of a felony to wit:

Robbery in violation of 2911.02 or flight thereafter.














Count 26 Bribery - F3 2921.02(C)




did promise, offer, or give or another person any valuable thing or valuable benefit, to wit: money,

with purpose to corrupt a witness or improperly to influence him with respect to his testimony in an

official proceeding, either before or after he was subpoenaed or sworn.

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





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Ohio.

Count 27 Conspiracy - F4 2923.01(A)(1)


Date of Offense On or about January 6, 2015


FURTHERMORE, and the object of the conspiracy was a felony of the third degree.


Count 28 Trafficking - F5 2925.03(A)(1)

Defendants Quasean Townsend



did knowingly sell or offer to sell a controlled substance or a controlled substance analog and the

drug involved in the violation is marihuana or a compound, mixture, preparation, or substance

containing marihuana other than hashish in an amount less than 200 grams.






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Defendants Randall Brooks




Revised Code, or in fleeing immediately after the attempt or offense upon Tandre Smith and/or

Popeye's Louisiana Chicken did have a deadly weapon, to wit: firearm, on or about his person or

under his control and either displayed the weapon, brandished it, indicated that he possessed it, or

used it.











and displayed the firearm, brandished the firearm, indicated that his possessed the firearm, or used it








Revised Code, or in fleeing immediately after the attempt or offense upon Louisiana Chicken and/or





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Mecole Taylor did have a deadly weapon, to wit: firearm, on or about his person or under his control

and either displayed the weapon, brandished it, indicated that his possessed it, or used it.



















Revised Code, or in fleeing immediately after the attempt or offense upon Popeye's Louisiana

Chicken and/or Sherae Campbell did have a deadly weapon, to wit: firearm, on or about his person

or under his control and either displayed the weapon, brandished it, indicated that he possessed it, or

used it.










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Revised Code, or in fleeing immediately after the attempt or offense upon Popeye's Louisiana

Chicken and/or Emil L. Grover did have a deadly weapon, to wit: weapon, on or about his person or

under his control and either displayed the weapon, brandished it, indicated that he possessed it, or

used it.













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





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Ohio.

Count 33 Kidnapping - F1 2905.01(A)(2)




did, by force, threat, or deception, purposely remove Tandre Smith and/or Popeye's Louisiana

Chicken from the place where her was found or restrain the liberty of her for the purpose

of facilitating the commission of a felony to wit: Aggravated Robbery 2911.01 or flight thereafter.










the offender had a

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