Criminal Court Division State of Ohio, VS. Plaintiff For Engaging In A Pattern Of Corrupt Activity - F1 2923.32(A)(1) 8 72 Additional Count(s) Gregory R. Cochran, Justin B. Taylor, David A. Quinones, Antonio Caraballo, Abel Guzman, Joseph A. Sabo, Robert E. Schepis, Anthony Alvarez Dates of Offense (on or about) The Term Of Case Number 11/01/2012 to 05/01/2014 September of 2014 591528-14-CR The State of Ohio, Cuyahoga County } SS. Count 1 Engaging In A Pattern Of Corrupt Activity - F1 2923.32(A)(1) Gregory R. Cochran, David A. Quinones, Antonio Caraballo, Abel Guzman, Joseph A. Sabo, Robert E. Schepis, Jason B. Taylor Date of Offense On or about November 1, 2012 through May 1, 2014 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 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 November 1, 2012 through May, 1 2014, in the County of Cuyahoga, as well as the Counties of Huron, Lake, Lorain, Medina, Portage, Stark, Summit, and Wood, 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, as part of a continuing course of conduct were associated with an Enterprise, as defined in Section 2923.31(C) of the Revised Code. Page 1 of 38
The Enterprise existed separate and apart from the pattern of corrupt activity in which it engaged. In the alternative, this Enterprise is an illicit enterprise under O.R.C. 2932.22, whether or not this Enterprise existed separate and apart from the pattern of corrupt activity described in this Indictment. This Enterprise functioned as a continuing unit by engaging in the diverse forms of illegal activities, as stated in this Indictment. In so doing, the DEFENDANTS NAMED BELOW are persons associated with the Enterprise who participated in and/or managed the affairs of the Enterprise who participated in and/or managed the affairs of the Enterprise, as explained in the Indictment. As such, these persons provided continuity and structure to the Enterprise in order to accomplish its illegal purposes-the pattern of corrupt activity, to wit: an organized Burglary ring whose purpose was to unlawfully enter residential homes to steal various items and personal property of innocent victims and to sell such illegal gotten goods to a fence in order to enrich themselves monetarily. 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. 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 racketeering activity in which it engaged. To constitute an associationin-fact enterprise under O.R.C. 2923.31, a group need not have a hierarchal structure, chain of command, or other business-like attributes; decisions may be made on and 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 proven by evidence that the various associates function as a continuing unit. Proof of a pattern of corrupt activity may be sufficient under O.R.C. 2923.31 to create an inference that an association-in-fact enterprise does exist. The Enterprise is an association and/or organization and/or a group of persons associated-in-fact although not a legal entity, including but not limited to David Quinones, Gregory Cochran, Antonio Caraballo, Abel Guzman, Robert Schepis, Justin Taylor, and Joseph Sabo and others yet unknown, each of whom did conduct and/or participate in, directly in the affairs of said enterprise, to wit a group of persons associated in fact for the purpose of burglarizing residential homes, stealing property from those homes, then selling the property to a fence who receives the stolen property and resells the property for profit. With regard to the diverse forms of illegal activities as described in this Indictment, this Enterprise had an ascertainable structure inherent in the pattern of corrupt activity in which it was engaged. As such, this Enterprise had at least three structural features: (1) a purpose, (2) relationships among those Persons Associated with the Enterprise, and (3) longevity sufficient to permit those Persons to pursue the Enterprise s purpose, which is sometimes referred to as a continuing unit. The Enterprise The Enterprise consists of all of the above named and unnamed individuals who are involved in an organized Burglary ring managed and directed by David Quinones, who learned the methods and means of residential burglary from his deceased father, Jose Quinones. Jose Quinones, the father of David Quinones, taught his son and his friend, Gregory Cochran, the art of residential burglary. David Quinones also was introduced by his father to the fence he utilized which was/is Joseph Sabo. A Page 2 of 38
fence is a person who knowingly procures, buys stolen goods and then resells them for profit. Gregory Cochran is a close associate of David Quinones and also learned the art of residential Burglary from Jose Quinones as well as David Quinones. Antonio Caraballo and Abel Guzman met David Quinones in prison and was recruited by David Quinones to join his criminal enterprise when they got out of prison. Robert Schepis and Justin Taylor also were recruited by David Quinones and Gregory Cochran to facilitate the organization s purpose of residential burglaries. As indicated previously, Joseph Sabo was the fence of the organization in that he purchased the stolen property and then resold the property for his own personal gain. This burglary ring was managed and directed by David Quinones and Gregory Cochran, who developed the organization s methods, plans, and execution of the burglaries. This ring operated in the following nine counties, Cuyahoga, Huron, Lake, Lorain, Medina, Portage, Stark, Summit, and Wood over at least an 18 month period. David Quinones and Gregory Cochran directed and taught Antonio Caraballo, Abel Guzman, Robert Schepis, and Justin Taylor how to burglarize residential homes, the best time, the proper method of entry to the homes, what to steal and how to dispose of the ill-gotten goods. All the members roles were interchangeable after they learned the ropes of burglarizing residential homes. That is why they all participated in selecting which homes to burglarize, the forced entry into homes, the actual taking of which property and acting as lookouts. Whoever went to work (a term used by the ring to burglarize homes) would share the proceeds when the stolen goods were sold to Joseph Sabo, the fence. The following is a description of how the ring operated. David Quinones and Gregory Cochran would focus on larger homes in high-end neighborhoods with a preference for homes located in cul-de-sacs or on streets leading to cul-de-sacs. Often one or more homes would be targeted on the same street or in the same areas. Google maps would be utilized to search which location to hit and the preference of the ring was to break into the homes during standard time as darkness would come earlier. Once the areas was picked, the ring would case the neighborhood during the daytime to plan which houses to break into, where to park the getaway car, and where the lookout would be and how to plan their exit from the neighborhood. When selecting the houses to burglarize, it usually came down to how comfortable the members would be with the area, especially David Quinones and Gregory Cochran, based upon their knowledge of how to be most efficient when breaking into residential homes. Once satisfied, they would park usually in an adjacent street and would come through the back of the property because there would be less light. The ring would like to have a wooden area to approach the targeted homes for cover and sometimes, the ring would not case the area and just pick the targets on scene and execute the burglaries. The decisions regarding these issues were heavily influenced by David Quinones and Gregory Cochran. Friday and Saturday nights were preferable since that is the night most people would go out. The members would gain entry by forcing open a door leading into the garage, rear doors or windows. Later Page 3 of 38
on, the ring members would be so bold as to break in through the front door. The preferred method to gain entry was a pry bar which they usually kept at Gregory Cochran s house. Most of the time, David Quinones would break into the houses and let Gregory Cochran in and they (David Quinones and Gregory Cochran) would direct the location of the lookout. As part of their modus operandi, the members of the ring would usually purchase mechanic brand gloves with dimpled palms and fingers from local auto parts stores in the area of the targeted homes or purchase them before they went into the targeted area. Once in the house a pillow case from the home itself was usually used to haul the stolen property away. The master bedroom was always targeted first before the rest of the house was ransacked. Initially preference was shown for just jewelry, cash, and prescription drugs but as the ring matured, they targeted electronic games, computers, IPads, and other portable electronic items. The targeted houses were ransacked by the time the members of the ring were done. Usual time in the targeted homes was between 15 to 30 minutes. After the burglaries, Gregory Cochran would separate the jewelry by carat weight and remove the stones. Also, Gregory Cochran had a test kit to distinguish between the fake diamonds and real ones and once this vetting process was complete, they would then take the stolen property to Joseph Sabo, their fence. Joseph Sabo was the fence for David Quinones father and owned a flea market booth inside the Streetsboro Flea Market where he would sell the stolen items he bought from the ring members. Over 1,500 items were seized with the search warrant from Joseph Sabo s booth and to date, nearly a dozen victims have identified their property. Also a search of Joseph Sabo s house located on Spring Road in Cleveland contained items identified as stolen from the homes burglarized by this ring. Multiple police agencies from all nine counties were coordinated by the Cuyahoga County organized crime task force. Key evidence of this burlary ring came from GPS mapping devices recovered from members of the burglary ring, as well as GPS location data recovered from burglary ring members mobile phones. Analysis of the burglary ring members mobile phone location data in comparison to the GPS device location data established the practice, pattern, and methods of the burglary ring. This extensive burglary ring was responsible for 39 burglaries over an eighteen month period with a total of $221,051.00 of property stolen. AFFAIRS OF THE ENTERPRISE 1. Did knowingly by force, stealth or deception trespassed in an occupied structure when another person, other than the accomplice of the offender is present, with purpose to commit in the structure any criminal offense, to wit theft. 2. Did with purpose to deprive the owner of property, shall knowingly obtain or exert control over said property by deception. 3. Did receive, retain, or disposed of property of another knowing or having reasonable cause to believe that the property has been obtained through the commission of a theft offense. THE PATTERN OF CORRUPT ACTIVITY- from November 1, 2012 to May 1, 2014 1. BURGLARY; TRESPASS IN A HABITATION WHEN A PERSON IS PRESENT OR LIKELY TO BE PRESENT R.C. 2911.12 (A)(1) No person, by force, stealth, or deception, shall do any of the following: Page 4 of 38
Trespass in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when another person other than an accomplice of the offender is present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense; 2. THEFT; AGGRAVATED THEFT R.C. 2913.02(A)(1)-(5) No person, with purpose to deprive the owner of property or services, shall knowingly obtain or exert control over either the property or services in any of the following ways: by deception. 3. RECEIVING STOLEN PROPERTY R.C. 2913.51 No person shall receive, retain, or dispose of property of another knowing or having reasonable cause to believe that the property has been obtained through commission of a theft offense. INCIDENTS OF CORRUPT ACTIVITY 1. On or about November 9, 2012, Gregory R. Cochran and David A. Quinones did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when David and Alisa Jeras, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02. 2. On or about November 9, 2012, Gregory R. Cochran and David A. Quinones did with purpose to deprive the owner, David and Alisa Jeras, of jewelry and commemorative coins or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $7,500 or more and less than $150,000. 3. On or about November 9, 2012, David A. Quinones did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Rebecca Faulk, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02. 4. On or about November 9, 2012, David A. Quinones did with purpose to deprive the owner, Rebecca Faulk, of jewelry or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. 5. On or about December 28, 2012, Gregory R. Cochran and David A. Quinones did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Loren Marinin and Carla Horoszko, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02. 6. On or about December 28, 2012, Gregory R. Cochran, Justin B. Taylor, and David A. Quinones did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Kevin and Letitia Kwiatkowski, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02. 7. On or about December 28, 2012, Gregory R. Cochran, Justin B. Taylor, and David A. Quinones did with purpose to deprive the owner, Kevin and Letitia Kwiatkowski, of cash and jewelry or services, knowingly Page 5 of 38
obtain or exert control over either the property or services by deception and the property or services stolen is valued at $7,500 or more and less than $150,000. 8. On or about January 18, 2013, David A. Quinones and Abel Guzman did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Steven and Mary Ruhe, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2911.02.. 9. On or about January 18, 2013, David A. Quinones and Abel Guzman did with purpose to deprive the owner, Steven and Mary Ruhe, of jewelry or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. 10. On or about January 18, 2013, David A. Quinones and Abel Guzman did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Linda Yonkof, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 11. On or about January 18, 2013, David A. Quinones and Abel Guzman did with purpose to deprive the owner, Linda Yonkof, of jewelry or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $7,500 or more and less than $150,000. 12. On or about February 5, 2013, Abel Guzman did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Soheir and Adile Botros, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 13. On or about February 5, 2013, Abel Guzman did with purpose to deprive the owner, Soheir and Adile Botros, of jewelry and cash or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. 14. On or about February 9, 2013, David A. Quinones and Abel Guzman did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Rafael and Patti Dominguez, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 15. On or about February 9, 2013, David A. Quinones and Abel Guzman did with purpose to deprive the owner, David Gido, of cash, jewelry, and electronics or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. 16. On or about February 9, 2013, David A. Quinones and Abel Guzman did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when David Gido, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 17. On or about March 3, 2013, Abel Guzman did, by force, stealth, or deception, trespass, as defined in Page 6 of 38
section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Scott and Nancy Willard, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 18. On or about February 18, 2013, Justin B. Taylor and David A. Quinones did by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Anthony Dimarco, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 19. On or about April 3, 2013, Gregory R. Cochran, Antonio Caraballo, and Abel Guzman did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Christopher and Julie Mead, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 20. On or about April 3, 2013, Gregory R. Cochran, Antonio Caraballo, and Abel Guzman did with purpose to deprive the owner, Christopher and Julie Mead, of jewlery and cash or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. 21. On or about November 23, 2013, Gregory R. Cochran and David A. Quinones did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when John and Jean Lawrie, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 22. On or about November 29, 2013, Gregory R. Cochran, David A. Quinones, and Robert E. Schepis did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Karl and Angela Miller, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 23. On or about November 29, 2013, Gregory R. Cochran, David A. Quinones, and Robert E. Schepis did with purpose to deprive the owner, Karl and Angela Miller, of jewelry or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. 24. On or about November 29, 2013, Gregory R. Cochran, David A. Quinones, and Robert E. Schepis did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when James and Diane Strong, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02. 25. On or about November 29, 2013, Gregory R. Cochran, David A. Quinones, and Robert Schepis did with purpose to deprive the owner, James and Diane Strong, of jewelry and cash or services, knowingly obtain or Page 7 of 38
exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. 26. On or about December 7, 2013, Gregory R. Cochran and David A. Quinones did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Kevin Gottschalk and Judith Lasits, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02. The offender had a firearm on or about his person or under his control while committing the offense. 27. On or about December 7, 2013, Gregory R. Cochran and David A. Quinones did with purpose to deprive the owner, Kevin Gottschalk and Judith Lasits, of a gun or services, knowingly obtain or exert control over either the property or services by deception and the property stolen is a firearm or dangerous ordnance. 28. On or about December 7, 2013, Gregory R. Cochran and David A. Quinones did with purpose to deprive the owner, Kevin Gottschalk and Judith Lasits, of jewelry and cash or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. 29. On or about January 4, 2014, Gregory R. Cochran and Antonio Caraballo did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Robert Nord, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 30. On or about January 4, 2014, Gregory R. Cochran and Antonio Caraballo did with purpose to deprive the owner, Robert Nord, of jewelry, cash, and electronics or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. 31. On or about January 11, 2012, Gregory R. Cochran and Antonio Caraballo did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Michael and Mary Manos, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 32. On or about January 11, 2014, Gregory R. Cochran and Antonio Caraballo did with purpose to deprive the owner, Michael and Mary Manos, of jewelry and electronics or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $7,500 or more and less than $150,000. 33. On or about January 18, 2014, Gregory R. Cochran and Antonio Caraballo did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Angelo and Laura Coreno, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 34. On or about January 18, 2014, Gregory R. Cochran and Antonio Caraballo did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when David and Lynn Ernes, not Page 8 of 38
the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 35. On or about January 18, 2014, Gregory R. Cochran and Antonio Caraballo did with purpose to deprive the owner, David and Lynn Ernes, of jewelry or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. 36. On or about January 31, 2014, Gregory R. Cochran and Antonio Caraballo did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Michael Zifer, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 37. On or about April 23, 2014, Antonio Caraballo and Robert E. Schepis did, by force, stealth, or deception, attempt to trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when David Smith, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. 38. On or about April 23, 2014, Antonio Caraballo and Robert E. Schepis did, by force, stealth, or deception, trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Richard and Veronica Martinez- Bennett, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 2 Conspiracy - F2 2923.01(A)(1) Gregory R. Cochran, Justin B. Taylor, David A. Quinones, Antonio Caraballo, Abel Guzman, Joseph A. Sabo, Robert E. Schepis, Date of Offense On or about November 1, 2012 to May 1, 2014 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, including but not limited to: Burglarized residential homes in a nine county area, stealing property within those homes and then dispose of the stolen property to a fence who then sells said property to innocent purchasers, all in furtherance of the above activity. Page 9 of 38
The Enterprise in the matter consisted of David Quinones, Gregory Cochran, Antonio Caraballo, Abel Guzman, Robert Schepis, Justin Taylor, Joseph Sabo, and numerous other yet to be named parties, each of whom did conduct or participate in, directly or indirectly, the affairs of said enterprise, to wit: a group of persons associates in fact for the purposes of engaging in Burglary and Theft (by deception), through a pattern of corrupt activity as defined in Sections 2923.31(I)(2)(a) or (I)(2)(c) of the Ohio Revised Code. The predicate acts that constitute the pattern of corrupt activity as defined in O.R.C. 2923.31(E) of said enterprise, which include criminal violations of the Revised Code Title 29 as alleged in the following counts three through seventy-two. FURTHERMORE, and the object of the conspiracy was a felony of the second degree. Count 3 Gregory R. Cochran, David A. Quinones Date of Offense On or about November 9, 2012 occupied structure, when David and Alisa Jeras, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, 2913.02. Count 4 Grand Theft - F4 Gregory R. Cochran, David A. Quinones Date of Offense On or about November 9, 2012 did with purpose to deprive the owner, David and Alisa Jeras, of jewelry and commemorative coins or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $7,500 or more and less than $150,000. Page 10 of 38
Count 5 David A. Quinones Date of Offense On or about November 9, 2012 occupied structure, when Rebecca Faulk, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02. Count 6 Theft - F5 David A. Quinones Date of Offense On or about November 9, 2012 did with purpose to deprive the owner, Rebecca Faulk, of jewelry or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. Page 11 of 38
Count 7 Gregory R. Cochran, David A. Quinones Date of Offense On or about December 28, 2012 occupied structure, when Carla Horoszko, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02. Count 8 Gregory R. Cochran, Justin B. Taylor, David A. Quinones Date of Offense On or about December 28, 2012 occupied structure, when Kevin and Letitia Kwiatkowski, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02. Count 9 Grand Theft - F4 Gregory R. Cochran, Justin B. Taylor, David A. Quinones Date of Offense On or about December 28, 2012 did with purpose to deprive the owner, Kevin and Letitia Kwiatkowski, of cash and jewelry or Page 12 of 38
services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $7,500 or more and less than $150,000. Count 10 David A. Quinones, Abel Guzman Date of Offense On or about January 18, 2013 occupied structure, when Steven and Mary Ruhe, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2911.02.. Count 11 Theft - F5 David A. Quinones, Abel Guzman Date of Offense On or about January 18, 2013 did with purpose to deprive the owner, Steven and Mary Ruhe, of jewelry or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. Page 13 of 38
Count 12 David A. Quinones, Abel Guzman Date of Offense On or about January 18, 2013 occupied structure, when Linda Yonkof, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, 2913.02.. Count 13 Grand Theft - F4 David A. Quinones, Abel Guzman Date of Offense On or about January 18, 2013 did with purpose to deprive the owner, Linda Yonkof, of jewelry or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $7,500 or more and less than $150,000. Count 14 Abel Guzman Date of Offense On or about February 5, 2013 occupied structure, when Soheir and Adel Botros, not the accomplice of the offender, was present, Page 14 of 38
with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 15 Theft - F5 Abel Guzman Date of Offense On or about February 5, 2013 did with purpose to deprive the owner, Soheir and Adel Botros, of jewelry and cash or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. Count 16 David A. Quinones, Abel Guzman Date of Offense On or about February 9, 2013 occupied structure, when Rafael and Patti Dominguez, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Page 15 of 38
Count 17 Theft - F5 David A. Quinones, Abel Guzman Date of Offense On or about February 9, 2013 did with purpose to deprive the owner, David Gido, of cash, jewelry, and electronics or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. Count 18 David A. Quinones, Abel Guzman Date of Offense On or about February 9, 2013 occupied structure, when David Gido, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 19 Justin B. Taylor, David A. Quinones Date of Offense On or about February 18, 2013 occupied structure, when Anthony Dimarco, not the accomplice of the offender, was present, with Page 16 of 38
purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 20 Attempted Burglary - F3 2923.02 / 2911.12(A)(1) Abel Guzman Date of Offense On or about March 2, 2013 did, by force, stealth, or deception, attempt to trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when Carl and Linda Orringer, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, 2913.02. Count 21 Abel Guzman Date of Offense On or about March 3, 2013 occupied structure, when Scott and Nancy Willard, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Page 17 of 38
Count 22 Grand Theft - F4 Abel Guzman Date of Offense On or about March 3, 2013 did with purpose to deprive the owner, Scott and Nancy Willard, of jewelery and electronics or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $7,500 or more and less than $150,000. Count 23 David A. Quinones, Abel Guzman Date of Offense On or about March 7, 2013 occupied structure, when Steven and Sara Reger, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02. Count 24 Grand Theft - F4 David A. Quinones, Abel Guzman Date of Offense On or about March 7, 2013 did with purpose to deprive the owner, Steven and Sara Reger, of jewelry or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $7,500 or more and less than $150,000. Page 18 of 38
Count 25 David A. Quinones, Abel Guzman Date of Offense On or about March 7, 2013 occupied structure, when Robin Joseph, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 26 Abel Guzman Date of Offense On or about March 10, 2013 occupied structure, when Kameshwari Deverakonda, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Page 19 of 38
Count 27 Abel Guzman Date of Offense On or about March 16, 2013 occupied structure, when Michael and Catherine Cunningham, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 28 Grand Theft - F4 Abel Guzman Date of Offense On or about March 16, 2013 did with purpose to deprive the owner, Michael and Catherine Cunningham, of jewelry and cash or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $7,500 or more and less than $150,000. Count 29 Abel Guzman Date of Offense On or about March 16, 2013 occupied structure, when Jonathan Waler and Jennifer Agoston, not the accomplice of the offender, Page 20 of 38
was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 30 Petty Theft - M1 Abel Guzman Date of Offense On or about March 16, 2014 did with purpose to deprive the owner, Jonathan Waler and Jennifer Agoston, of jewelry or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at less than $1,000. Count 31 David A. Quinones, Abel Guzman Date of Offense On or about March 23, 2013 occupied structure, when Annette Fuller and Stephen James, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, 2913.02. Firearm Specification - 1 year - 2941.141(A) The Grand Jurors further find and specify that the offender had a firearm on or about his person or under his control while committing the offense. Page 21 of 38
Count 32 Grand Theft - F3 David A. Quinones, Abel Guzman Date of Offense On or about March 23, 2013 did with purpose to deprive the owner, Annette Fuller and Stephen James, of a gun or services, knowingly obtain or exert control over either the property or services by deception and the property stolen is a firearm or dangerous ordnance. Count 33 Theft - F5 David A. Quinones, Abel Guzman Date of Offense On or about March 23, 2013 did with purpose to deprive the owner, Annette Fuller and Stephen James, of jewelry and cash or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. Count 34 David A. Quinones, Abel Guzman Date of Offense On or about March 23, 2013 occupied structure, when Gary and Vicki Timple, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Page 22 of 38
Count 35 Gregory R. Cochran, Antonio Caraballo, Abel Guzman Date of Offense On or about April 3, 2013 occupied structure, when Christopher and Julie Mead, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 36 Theft - F5 Gregory R. Cochran, Antonio Caraballo, Abel Guzman Date of Offense On or about April 3, 2013 did with purpose to deprive the owner, Christopher and Julie Mead, of jewlery and cash or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. Page 23 of 38
Count 37 Gregory R. Cochran, David A. Quinones Date of Offense On or about November 23, 2013 occupied structure, when John and Jean Lawrie, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 38 Gregory R. Cochran, David A. Quinones, Robert E. Schepis Date of Offense On or about November 29, 2013 occupied structure, when Karl and Angela Miller, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 39 Theft - F5 Gregory R. Cochran, David A. Quinones, Robert E. Schepis Date of Offense On or about November 29, 2013 did with purpose to deprive the owner, Karl and Angela Miller, of jewelry or services, knowingly Page 24 of 38
obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. Count 40 Gregory R. Cochran, David A. Quinones, Robert E. Schepis Date of Offense On or about November 29, 2013 occupied structure, when James and Diane Strong, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 41 Theft - F5 Gregory R. Cochran, David A. Quinones, Robert E. Schepis Date of Offense On or about November 29, 2013 did with purpose to deprive the owner, James and Diane Strong, of jewelry and cash or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. Page 25 of 38
Count 42 Gregory R. Cochran, David A. Quinones Date of Offense On or about December 7, 2013 occupied structure, when Kevin Gottschalk and Judith Lasits, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Firearm Specification - 1 year - 2941.141(A) The Grand Jurors further find and specify that the offender had a firearm on or about his person or under his control while committing the offense. Count 43 Grand Theft - F3 Gregory R. Cochran, David A. Quinones Date of Offense On or about December 7, 2013 did with purpose to deprive the owner, Kevin Gottschalk and Judith Lasits, of a gun or services, knowingly obtain or exert control over either the property or services by deception and the property stolen is a firearm or dangerous ordnance. Count 44 Theft - F5 Gregory R. Cochran, David A. Quinones Date of Offense On or about December 7, 2013 Page 26 of 38
did with purpose to deprive the owner, Kevin Gottschalk and Judith Lasits, of jewelry and cash or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. Count 45 Gregory R. Cochran, David A. Quinones Date of Offense On or about December 15, 2013 occupied structure, when Jane Semple, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 46 Theft - F5 Gregory R. Cochran, David A. Quinones Date of Offense On or about December 15, 2013 did with purpose to deprive the owner, Jane Semple, of jewelry and cash or services, knowingly obtain or exert control over either the property or services by deception and the property or services stolen is valued at $1,000 or more and less than $7,500. Page 27 of 38
Count 47 Attempted Burglary - F3 2923.02 / 2911.12(A)(1) Gregory R. Cochran, David A. Quinones Date of Offense On or about December 15, 2013 did, by force, stealth, or deception, attempt to trespass, as defined in section 2911.21(A)(1) of the Revised Code, in an occupied structure or in a separately secured or separately occupied portion of an occupied structure, when David Dunnington, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 48 Gregory R. Cochran, Antonio Caraballo Date of Offense On or about January 4, 2014 occupied structure, when Robert and Margaret Nord, not the accomplice of the offender, was present, with purpose to commit in the structure or in the separately secured or separately occupied portion of the structure any criminal offense, to wit: Theft, R.C. 2913.02.. Count 49 Theft - F5 Gregory R. Cochran, Antonio Caraballo Date of Offense On or about January 4, 2014 did with purpose to deprive the owner, Robert and Margaret Nord, of jewelry, cash, and electronics Page 28 of 38