Criminal Court Division State of Ohio, VS. Plaintiff For Participating In A Criminal Gang - F2 2923.42(A) 13 42 Additional Count(s) 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, Cuyahoga County } SS. Count 1 Participating In A Criminal Gang - F2 2923.42(A) 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 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 Page 1 of 48
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 Gang s territory is 105 th 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 Page 2 of 48
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 Gang s 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 Gang s 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. Page 3 of 48
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 1 st 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 Page 4 of 48
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 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 Page 5 of 48
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 Page 6 of 48
Furthermore, the State hereby puts 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 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, Page 7 of 48
and/or is an instrumentality the offender(s) used or intended to use in the commission or facilitation of a felony offense. Count 2 Engaging In A Pattern Of Corrupt Activity - F1 2923.32(A)(1) 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 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 1 st 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 Page 8 of 48
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. Page 9 of 48
5. The epicenter of the Criminal Gang s 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 Gang s 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 Gang s 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. Page 10 of 48
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 Page 11 of 48
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 Page 12 of 48
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. 10. 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 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. Page 13 of 48
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 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 Page 14 of 48
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; 114527 Mitchell Mickey Taylor Jr.: CR-14-589272 Quasean Qua-Qua Townsend: CR-13-578147A Theodore Theo Travis: CR-10-536771; CR-11-549845; 559172; CR-13-579153 DL-09- CR-12- 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 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 Page 15 of 48
Theodore Theo Travis: 1:14-cr-00331-JRA-1 15. Furthermore, the State hereby puts 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 Page 16 of 48
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 Count 3 Conspiracy F2 2923.01(A)(2) 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 In the County of Cuyahoga, the 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 Page 17 of 48
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 4 Conspiracy F2 2923.01(A)(1) 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 In the County of Cuyahoga, the 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 Page 18 of 48
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) 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. Page 19 of 48
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. Count 6 Attempted Murder - F1 2923.02 / 2903.02(B) 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 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: Felonious Assault in violation of Ohio Revised Code 2903.11, in violation of Section 2903.02 of the Revised Code. Page 20 of 48
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. Count 7 Attempted Murder - F1 2923.02 / 2903.02(B) 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 Celeste Balian, 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. Page 21 of 48
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. Count 8 Attempted Murder - F1 2923.02 / 2903.02(B) 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 Radica Williams, 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. Page 22 of 48
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. Count 9 Attempted Murder - F1 2923.02 / 2903.02(B) 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 Demetrius Keith, 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 - 5 year, "Drive By Shooting" - 2941.146(A) Page 23 of 48
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. Count 10 Attempted Murder - F1 2923.02 / 2903.02(B) 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 Juan Smith, 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 - 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 Page 24 of 48
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. Count 11 Felonious Assault - F2 2903.11(A)(2) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 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,. 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 Page 25 of 48
motor vehicle other than a manufactured home. Count 12 Felonious Assault - F2 2903.11(A)(2) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 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,. 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 Page 26 of 48
motor vehicle other than a manufactured home. Count 13 Felonious Assault - F2 2903.11(A)(2) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 did knowingly cause or attempt to cause physical harm to Celeste Balian by means of a deadly weapon or dangerous ordnance, to wit: WASR-10 Rifle with Folding Stock,. 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 Page 27 of 48
motor vehicle other than a manufactured home. Count 14 Felonious Assault - F2 2903.11(A)(2) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 did knowingly cause or attempt to cause physical harm to Radica Williams by means of a deadly weapon or dangerous ordnance, to wit: WASR-10 Rifle with Folding Stock,. 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 Page 28 of 48
motor vehicle other than a manufactured home. Count 15 Felonious Assault - F2 2903.11(A)(2) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 did knowingly cause or attempt to cause physical harm to Demetrius Keith by means of a deadly weapon or dangerous ordnance, to wit: WASR-10 Rifle with Folding Stock,. 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 Page 29 of 48
motor vehicle other than a manufactured home. Count 16 Felonious Assault - F2 2903.11(A)(2) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 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,. 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 Page 30 of 48
motor vehicle other than a manufactured home. Count 17 Felonious Assault - F2 2903.11(A)(1) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 did knowingly cause serious physical harm to Juan Smith. 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. Page 31 of 48
Count 18 Improperly Handling Firearms In A Motor Vehicle - F4 2923.16(B) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 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. 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. Page 32 of 48
Count 19 Improperly Handling Firearms In A Motor Vehicle - F4 2923.16(A) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 did knowingly discharge a firearm while in or on a motor vehicle. 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. Count 20 Discharge Of Firearm On Or Near Prohibited Premises - F1 2923.162(A)(3) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 did discharge a firearm upon or over a public road or highway and the violation caused serious physical harm to a person Juan Smith. Page 33 of 48
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. Count 21 Improperly Discharging Into Habitation - F2 2923.161(A)(1) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 knowingly, without privilege, did discharge a firearm at or into an occupied structure that is a permanent or temporary habitation of John Doe. Page 34 of 48
Count 22 Criminal Damaging Or Endangering - M2 2909.06(A)(1) Ibrahim Adbul-Haqq, Idale Goins, Ron Hunter II, Mickey James Date of Offense On or about February 16, 2014 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) Malik A. Pruitt Date of Offense On or about January 4, 2015 to January 6, 2015 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. Page 35 of 48
Count 24 Robbery - F2 2911.02(A)(2) Malik A. Pruitt Date of Offense On or about January 4, 2015 to January 6, 2015 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. Page 36 of 48
Count 25 Kidnapping - F1 2905.01(A)(2) Malik A. Pruitt Date of Offense On or about January 4, 2015 to January 6, 2015 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) Malik A. Pruitt Date of Offense On or about January 4, 2015 to January 5, 2015 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. Page 37 of 48
Count 27 Conspiracy - F4 2923.01(A)(1) Malik A. Pruitt 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) Quasean Townsend Date of Offense On or about January 4, 2015 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. Page 38 of 48
Count 29 Aggravated Robbery - F1 2911.01(A)(1) Randall Brooks Date of Offense On or about January 15, 2014 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 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 Count 30 Aggravated Robbery - F1 2911.01(A)(1) Randall Brooks Date of Offense On or about January 15, 2014 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 Louisiana Chicken and/or Page 39 of 48
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. Count 31 Aggravated Robbery - F1 2911.01(A)(1) Randall Brooks Date of Offense On or about January 15, 2014 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 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. Page 40 of 48
Count 32 Aggravated Robbery - F1 2911.01(A)(1) Randall Brooks Date of Offense On or about January 15, 2014 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 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. Page 41 of 48
Count 33 Kidnapping - F1 2905.01(A)(2) Randall Brooks Date of Offense On or about January 15, 2014 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. Page 42 of 48
Count 34 Kidnapping - F1 2905.01(A)(2) Randall Brooks Date of Offense On or about January 15, 2014 did, by force, threat, or deception, purposely remove Louisiana Chicken and/or Mecole Taylor from the place where he was found or restrain the liberty of him for the purpose of facilitating the commission of a felony to wit: Aggravated Robbery 2911.01 or flight thereafter. Count 35 Kidnapping - F1 2905.01(A)(2) Randall Brooks Date of Offense On or about January 15, 2014 did, by force, threat, or deception, purposely remove Popeye's Louisiana Chicken and/or Sherae Campbell 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: Aggravated Robbery 2911.01 or flight thereafter. Page 43 of 48
Count 36 Kidnapping - F1 2905.01(A)(2) Randall Brooks Date of Offense On or about January 15, 2014 did, by force, threat, or deception, purposely remove Popeye's Louisiana Chicken and/or Emil L. Grover from the place where he was found or restrain the liberty of him for the purpose of facilitating the commission of a felony to wit: Aggravated Robbery 2911.01 or flight thereafter. Page 44 of 48
Count 37 Obstructing Justice - F3 2921.32(A)(1) Ledon Allen, Timothy Willis Date of Offense On or about October 2, 2014 did, with purpose to hinder the discovery, apprehension, prosecution, conviction, or punishment of another for a crime or to assist another to benefit from the commission of a crime, harbor or conceal the other person or child. FURTHERMORE, and the crime committed by the person aided was aggravated murder, murder, or a felony of the first or second degree and/or the act committed by the child aided would have been one of those offenses if committed by an adult and the offender knew or had reason to believe that the crime committed by the person aided was one of those offenses and/or that the act committed by the child aided would have been one of those offenses if committed by an adult. Count 38 Obstructing Justice - F3 2921.32(A)(2) Ledon Allen, Timothy Willis Date of Offense On or about October 2, 2014 did, with purpose to hinder the discovery, apprehension, prosecution, conviction, or punishment of another for a crime or to assist another to benefit from the commission of a crime, provide the other person or child with money, transportation, a weapon, a disguise, or other means of avoiding discovery or apprehension. Page 45 of 48