IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS STATE OF MISSOURI

STATE OF MISSOURI ) ) SS CITY OF ST. LOUIS ) IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS STATE OF MISSOURI STATE OF MISSOURI, ) Plaintiff, ) ) CAUSE NO.: 1222-CR05524-01 vs. ) ) DIVISION NO.: 19 THURLESTER JOHNSON, ) Defendant, ) STATE S SENTENCING MEMORANDUM Comes now the State of Missouri and states as follows: 1. On November 10, 2014, the defendant pled guilty to the following offenses: I. Robbery First Degree II. Armed Criminal Action III. Robbery First Degree IV. Armed Criminal Action V. Robbery First Degree VI. Armed Criminal Action VII. Attempted Robbery 1st Degree VIII. Armed Criminal Action IX. Assault 1st Degree X. Armed Criminal Action XI. Assault 1st Degree XII. Armed Criminal Action XIII. Assault 1st Degree XIV. Armed Criminal Action XV. Assault 1st Degree XVI. Armed Criminal Action XVII. Robbery 1st Degree XVIII. Armed Criminal Action 1

XIX. Attempted Robbery 1st Degree XX. Armed Criminal Action XXI. Robbery First Degree XXII. Armed Criminal Action XXIII. Robbery First Degree XXIV. Armed Criminal Action XXV. Robbery First Degree XXVI. Armed Criminal Action XXVII. Robbery First Degree XXVIII. Armed Criminal Action XXIX. Attempted Robbery 1st Degree XXX. Armed Criminal Action XXXI. Attempted Robbery 1st Degree XXXII. Armed Criminal Action XXXIII. Robbery 1st Degree XXXIV. Armed Criminal Action XXXV. Robbery 1st Degree XXXVI. Armed Criminal Action XXXVII. Robbery 1st Degree XXXVIII. Armed Criminal Action XXXIX. Robbery 1st Degree XL. Armed Criminal Action XLI. Attempted Robbery 1st Degree XLII. Armed Criminal Action XLIII. Attempted Robbery 1st Degree XLIV. Armed Criminal Action XLV. Attempted Robbery 1st Degree XLVI. Armed Criminal Action XLVII. Robbery 1st Degree XLVIII. Armed Criminal Action XLIX. Robbery 1st Degree L. Armed Criminal Action LI. Robbery 1st Degree LII. Armed Criminal Action LIII. Robbery 1st Degree LIV. Armed Criminal Action, In all, this totals sixteen counts of robbery 1 st degree, seven counts of attempted robbery 1 st degree, four counts of assault 1st degree, and twenty- 2

seven counts of armed criminal action; twenty-three victims; and five separate incidents. Case Summary 2. The facts and circumstances of defendant s robbery spree are as follows: COUNTS 1 16 August 10, 2012, at about 10:50 p.m. 4535 Olive Street (Grand Masonic Hall) Central West End Neighborhood Officer Joseph Morrell was on patrol in the area of Taylor and Maryland when he heard gunshots. He was stopped by a citizen who told him that someone was shooting around the corner. Officer Morrell went to the area of the gunshots and saw four elderly victims standing outside of the Grand Masonic Hall, where they had just left a Bingo game. The victims reported that defendant approached them as they were walking to their car. Defendant said Drop everything you have. Do it, or I ll shoot you all. C.B. threw a briefcase containing $200.00 and a checkbook belonging to the bingo hall as well as his wallet containing $120.00 at defendant. Defendant took M.B s purse. Defendant also ripped a gold chain off of M.B. s neck. Defendant took a purse belonging to W.H. Nothing was taken from E.A. because she did not have any money. E.A. told defendant she had nothing to give him and defendant replied Do you want to get shot? E.A. pleaded with defendant and asked how he could shoot someone for having no money. As defendant was running away he pointed his gun at the victims. C.B. is a CCW permit holder and C.B. drew his weapon and fired at defendant in response. Defendant fired his weapon at the four victims. C.B. s pant leg was hit as well as his shoe by defendant s bullets. C.B. and M.B. later identified defendant in both a photo spread and a physical lineup as the person who took their property at gunpoint and also shot at them. 3

COUNTS 17 20 August 12, 2012, at about 9:15 p.m. 1617 Lafayette Ave. Peabody Housing Complex & Lafayette Square Neighborhood S.S. and K.S. left an acquaintance s house in the Lafayette Square neighborhood and were walking to their car when defendant surprised them from behind. Defendant said, Don t move. Both victims turned around and saw a dark colored semi-automatic handgun in defendant s hand pointed at them. Defendant told S.S. to give him everything he had and S.S. gave defendant his iphone, car key and credit cards. Defendant then said, Where is the money? multiple times. Defendant then searched S.S. s pockets but did not find any money. K.S. did not have anything to give defendant. After defendant completed the robbery, he told the victims to run in the opposite direction and not look back. Both victims later identified defendant in a photo spread and a line-up as the person who robbed them at gunpoint. COUNTS 21 32 August 19, 2012, at about 12:30 a.m. 32 N. Euclid Central West End Neighborhood Four new Washington University graduate students left their graduate school orientation activity to grab a bite to eat. As they crossed the south alley of West Pine, defendant approached them with a dark colored semiautomatic handgun. Defendant pointed the gun at the four victims and said, Give me everything. Put everything in a pile. As the victims retrieved their belongings for defendant, he said I have a gun. I ll kill you. Do you not believe me? Do you want me to fire a shot? Defendant took wallets from the two male victims, S.K. and M.C. and purses from two female victims, A.H. and A.B. After the robbery was completed, the victims ran together to the nearby 34 Club to seek help. Meanwhile, R.B. and K.I. exited the 34 Club and started walking south on Euclid. K.I. brought R.B. s attention to defendant, who looked 4

unusual because he was walking with purses in his hand. Before R.B. could reply to K.I., defendant turned around and pointed his handgun at them. Defendant said, Give me everything you got, I ain t kidding. At this point R.B. ran across Euclid. Within seconds he heard a gunshot and saw the defendant still holding the handgun as he ran across the street. R.B. then he heard defendant yell Drive! Drive! R.B. then saw defendant getting into the passenger side of a dark colored newer model SUV. K.I. across ran across Euclid after defendant demanded his property. As he was running, he heard a gunshot from defendant s direction. A security guard at a nearby apartment complex heard the gunshot and then saw a man matching defendant s description getting into the passenger side of a newer model dark red SUV and could hear him yelling Go, go, go! R.B., A.H.and M.C. later identified defendant in a photo spread. K.I., S.K., M.C., A.H. and A.B. later identified defendant in a line-up. Counts 33 46 August 22, 2012, at about 10:56 p.m. 551 S. Broadway (near Busch Stadium) Downtown Neighborhood Victims, five friends who worked together as nurses, attended a Cardinal baseball game and walked together afterwards to Beale on Broadway. As they were walking to their vehicle after leaving the restaurant, defendant approached them and said, I want five purses on the ground now! I m not playing around. As defendant said these words, he was pointing a black handgun at the victims. Four of the women threw their purses to the ground only for defendant to then demand their jewelry. As victim S.D. handed defendant her ring, he said Don t call for help or I will shoot you! After taking property from the victims, defendant told them to walk towards the stadium. Meanwhile, two women, J.J. and her daughter S.J., who work at Busch Stadium, walked through the group of nurses as they were being robbed on their way home. Defendant tried to rob them but seeing what they had with them said, I don t want your shit! Run and I will blow your 5

fucking head off. J.J. and S.J. walked with the nurses to the stadium to seek help. S.D. saw a maroon or dark colored SUV next to where she was standing during the robbery. She later identified the driver of the SUV in a photo spread. Defendant was arrested on 10.3.2012 at the Moto Mart Convenience Store. Police searched the house where defendant was living. Police found.40 caliber ammunition behind the bedroom dresser, a loaded.40 caliber handgun in the living room couch and a trash bag containing four purses in the kitchen pantry. Detectives also found a kitchen trash bag containing four purses, including purses belonging to S.D. and M.R. and R.G s wallet. Victims R.G., J.G., S D., M.R., J.J. and S.J. identified defendant in a photo spread. All seven victims also identified defendant in a line-up. All of the victims identified the gun found at defendant s house as the weapon he used in the robbery. Counts 47 54 September 27, 2012, at 8:55 p.m. 4502 Laclede Central West End Neighborhood Four teachers finished eating their dinner at Applebee s and walked to their car when defendant approached them and said Can I get a light? Victim C.H. told defendant that they do not smoke and they quickly approached their car and started to get inside. As C.H. closed the driver s side door defendant grabbed it, pulling it from her hand and forcing it open. Defendant reached into the car and showed a black handgun to the four victims inside. Defendant said give me everything now. The other three women handed their purses to C.H. who gave them to defendant. C.H. also gave defendant her own purse. A witness saw the robbery and hid when the defendant saw him and said, Come here. I want to talk to you. The witness saw defendant get into a maroon SUV. 6

Detectives were able to find the maroon Ford Explorer in the moments after the robbery. Victim C.M. s iphone was stolen. Using victim K.C. s iphone, the detectives were able to track defendant s whereabouts using GPS technology. The GPS traced defendant s movements to a residence at 5100 Northland. At that address detectives saw the maroon Ford Explorer used in the robberies parked on the street. The windows were rolled down and the hood was warm to the touch. The plate on the car was registered to defendant. This information regarding defendant s name was used by detectives investigating this robbery spree in developing photo spreads and live line-ups.. Defendant History 3. The defendant is a prior and persistent offender having pled to the following offenses: On November 5, 1987, in St. Louis County, Missouri, defendant pled guilty to charge of receiving stolen property (felony) and he received a suspended imposition of sentence. On December 18, 1987, defendant pled guilty to the charge of receiving stolen property (felony), Cause Number 21CCR-560400, in St. Louis County, Missouri, and he was granted a suspended imposition of sentence. Defendant s probation was revoked on June 13, 1990 and he was sentenced to three years in the Missouri Department of Corrections. On May 18, 1988, defendant pled guilty to the charge of Operating a Vehicle without a Valid License (misdemeanor) in St. Louis County, Missouri, and was sentenced to ten days in county jail and a fine of $750.00. On June 13, 1990, in St. Louis County, Missouri, defendant pled guilty to stealing (felony), Cause Number 90CR-3708, and he was sentenced to three years in the Missouri Department of Corrections. On June 3, 1994, defendant pled guilty to five counts of robbery first degree and five counts of armed criminal action, Cause Number 2193R- 4405A-01, in St. Louis County, Missouri, and was sentenced to thirty years in the Missouri Department of Corrections. 7

On June 3, 1994, defendant pled guilty to the charges of 1) robbery second degree, 2) armed criminal action, 3) assault first degree, and 4) armed criminal action, Cause Number 2193C-4980-01, in St. Louis County, Missouri, and was sentenced to fifteen years in the Missouri Department of Corrections. On June 3, 1994, defendant pled guilty to the charges of 1) robbery first degree, and 2) armed criminal action, Cause Number 2193R-05207A-01, in St. Louis County, Missouri, and was sentenced to thirty years in the Missouri Department of Corrections. On June 3, 1994, defendant pled guilty to the charges of 1) robbery first degree, 2) armed criminal action, 3) assault second degree, and 4) armed criminal action, Cause Number 2193R-05210-A, in St. Louis County, Missouri, and was sentenced to thirty years in the Missouri Department of Corrections on each robbery first degree and armed criminal action and fifteen years on each attempted robbery count. On June 3, 1994, defendant pled guilty to four counts of robbery first degree, six counts of attempted robbery first degree and ten counts of armed criminal action, Cause Number 2193R-4405A-01, in St. Louis County, Missouri, and was sentenced to thirty years in the Missouri Department of Corrections. On June 3, 1994, defendant pled guilty to the charges of 1) robbery first degree, and 2) armed criminal action, Cause Number 2193R-6110, in St. Louis County, Missouri, and was sentenced to thirty years in the Missouri Department of Corrections. On June 3, 1994, defendant pled guilty to the charges of 1) robbery first degree, and 2) armed criminal action, Cause Number 2193R-6267B, in St. Louis County, Missouri, and was sentenced to thirty years in the Missouri Department of Corrections. On June 3, 1994, defendant pled guilty to the charges of 1) robbery first degree, and 2) armed criminal action, Cause Number 2193R-6268A, in St. Louis County, Missouri, and was sentenced to thirty years in the Missouri Department of Corrections. 8

On June 3, 1994, defendant pled guilty to one count of robbery first degree, one count of felonious restraint, and two counts of armed criminal action, Cause Number 2193R-6269, in St. Louis County, Missouri, and was sentenced to thirty years in the Missouri Department of Corrections for the robbery first degree and armed criminal actions counts and seven years on the count of felonious restraint. On June 3, 1994, defendant pled guilty to three counts of robbery first degree and three counts of armed criminal action, Cause Number 2193R- 6272, in St. Louis County, Missouri, and was sentenced to thirty years in the Missouri Department of Corrections on each count. On September 11, 1996, defendant pled guilty to the charge of delivery or possession of a weapon in a correctional facility, in St. Francois County (Farmington), and was sentenced to five years in the Missouri Department of Corrections. On May 21, 1997, defendant pled guilty to the charge of violence to an inmate, in Washington County, Missouri (Potosi) and was sentenced to five years in the Missouri Department of Corrections. 4. Please see attachment for defendant s arrest history. 5. The defendant was on parole for numerous robbery offenses (see above) when he committed the crimes charged in this case. Defendant s Character 6. Defendant has previous convictions for twenty-five robbery related offenses. 7. In August and September 2012, defendant s actions constituted nothing short of a crime spree. His actions directly impacted the lives and sensibilities of twenty-three victims. Each of these victims had their notions of safety taken away when defendant pointed a loaded gun at them. Their impression of the City of St. Louis is forever changed because of defendant s actions 9

8. Each of defendant s victims was doing totally normal activities when defendant robbed them. Each victim deserves to go about their personal business in safety. In counts 1 16, four elderly people were leaving a bingo game at the Masonic Hall. In counts 17 20, defendant targeted a couple leaving a home in Lafayette Square. In counts 21 32, defendant victimized four Washington University graduate students leaving orientation activities. In counts 33 42, defendant targeted five nurses leaving a restaurant after enjoying a Cardinals baseball game at Busch Stadium. In counts 43 46, defendant targeted two stadium employees, a mother and daughter, who were leaving work and going home. In counts 47 54, defendant targeted four teachers who ate dinner at Applebee s and were getting into their car. 9. Defendant committed his crimes in vibrant neighborhoods that are all too frequently victimized by serious crimes. The Downtown and Central West End neighborhoods are favorite neighborhoods for the citizens of St. Louis as well as visitors to the area. 10. The Lafayette Square Neighborhood was targeted by defendant in counts 17 20. Residents of the Lafayette Square Neighborhood have previously filed a neighborhood impact statement with the Court. 11. The Central West End Neighborhood was targeted by defendant in counts 1-16, counts 21-32, and counts 47-54. Individual residents of the Central West End have previously filed two impact statements with the Court; both letters stress the importance of the CWE to the people who live there and to City as a whole. Victim Impact Information 12. The State informs the Court of the following victim impact information: a. Mr. and Mrs. C.B. (victims on counts 1-4 and 9-12) were robbed at gunpoint by defendant after leaving a bingo game at 10

the Masonic Hall. Defendant s actions have changed the way this couple views the world. They now keep the doors to their home locked at all times, even when they are home. The installed an alarm system. They are truly fearful in their own home. C.B. ran the Bingo game and he described how he was forced to close the bingo game for a month until he was able to hire more security. In addition, they installed cameras at the hall. C.B. feels that when the defendant fired his weapon at them he did not take into account the safety of the four victims or any of the other people in the area at the time; he worries that any of them could have been hit by defendant s bullets. Most of all, C.B. stresses that his wife M.B. is still shook up from the assault and robbery. She finds it hard to even attend the plead and sentencing hearing, but she will in support of her husband. She finds it hard to even talk about what happened to her. b. The State has attached to this memorandum a victim impact statement from victim R.B., who defendant robbed after leaving an establishment in the Central West End (counts 29 and 30). In his letter he stresses that he is constantly looking over his shoulder when walking in public and that his confidence in human beings has been greatly diminished. c. The State has attached to this memorandum a victim impact statement from R.G., who defendant robbed after leaving an establishment near Busch Stadium (counts 33 and 34). She stresses that defendant changed her life forever. She was terrified to be alone, had to explain the events to her four year old son and felt a financial strain as well as emotional strain on her life. d. S.D. (victim on counts 35 and 36) was robbed at gunpoint by defendant outside of Busch Stadium. She would like the Court to know that the biggest impact for her was the loss of her sense of security and safety. In the days after the robbery, she felt paranoid everywhere she went. Even still, when she walks to 11

her car in the parking lot at the hospital where she works, she is freaked out, on edge and paranoid. She thinks that everyone who approaches me is doing so for the wrong reasons. These feelings are a direct result of defendant s actions the night she was robbed. e. The State has attached to this memorandum a victim impact statement from M.R., who defendant robbed after leaving an establishment near Busch Stadium (counts 37 and 38). In her letter she describes how defendant ruined an annual tradition with co-workers, attending a Cardinals game. She also describes how this incident has effected her emotionally, making her fearful of never seeing her child again and seeing defendant s face in her dreams. This incident was life changing for her. f. The State has attached to this memorandum a victim impact statement from J.G.; defendant robbed her after leaving an establishment near Busch Stadium (counts 39 and 40). She writes I feel the emotional damage this man has done to me, my family and my friends is far worse than the physical items he took from us. She has struggled with trust issues and feels suspicious around strangers as a direct result of defendant s actions. g. The State has attached to this memorandum a victim impact statement from S.M., who defendant tried to rob after leaving an establishment near Busch Stadium (counts 41 and 42). She stresses in her letter that since this event, she no longer walks places, she carries mace with her and she has lost time at work due to anziety and has fear in her daily life. I will never feel safe like I did prior to this awful event. He changed life as I knew it forever. Recommendation Wherefore, the State of Missouri respectfully requests, that under the facts and circumstances of this case, considering the history and character of the defendant, and for the protection of the public, the Court impose the following sentences: 12

Count 1: Life in the Missouri Department of Corrections; Count 2: Life in the Missouri Department of Corrections, to run consecutive with Count 1; and, Counts 3 54: Life in the Missouri Department of Corrections on each count, to run concurrent with all other counts; for a total sentence of life imprisonment plus life imprisonment in the Missouri Department of Corrections. Respectfully Submitted, /s/ Jeff Coleman Jeff Coleman, #52351 Assistant Circuit Attorney 1114 Market Street, Room 401 St. Louis, MO 63101 (314) 622-4941 13