|
_ MARK BRNOVICH
| Attomey General
Firm Bar No. 14000
F, STERLING STRUCKMEYER
+ || Assistant Attorn: eral
State Bar No.: 026117
Pima County Computer No.: 66197
«6 ||400 West Congress, Suite S-315
‘Tueson, Arizona 85761
7 || Tetephone No.: (520) 628-6362
ile: (520) 628-6613
* | sterling Struckmeyer@azag.gov |
° 1017-001541 |
10 |] Attorneys for Plaintif |
u IN THE SUPERIOR COURT OF THE STATE OF ARIZONA |
2 IN AND FOR THE COUNTY OF PIMA |
'S || STATE OF ARIZONA, | case No: CR204.9 5394-004
|
4 |
Plaintiff, |
us |v
DIRECT INDICTMENT
6 |p 5
aExonE DiS: CHARGING VIOLATIONS OF: |
0 |
Defendant, | COUNT 1: FRAUDULENT SCHEMES |
8 [AND ARTIFICES, 9 Class Two Felony, in|
» | violation of A.R.S. § 13-2310 |
s0 UNTS 2-15: THEFT, Class Two Felony.
in violation of A.R.S. § 13-1802(A)(2).
‘The grand jurors of the County of Pima, in the name of the State of Arizona, and by
ay || authority, accuse and charge that in Pima County:
a |is
2 [ly
2%
a| CR2u
COUNT ONE
A CLASS
FRAUDULENT SCHEME
On or about April 19, 2017, through May 18, 2017, JERONE DAVIS (001), pursuant (0 «
ue of one hundred thousand
scheme or artifice to defraud, knowingly obtained a benefit, with a
+ |] dollars or more, by means of false or fraudulent pretenses, representations, promises or material |
5 lJomissions, in violation of A.RS. §§ [3-2310, 13-2301, 15-301 et. seq., 13-603, 13-701, 13-702. |
6 |] 13-703, 13-801, 13-804, and 13-811
i
5 THERT.A
On or about April 19, 2017, JERONE DAVIS (001), without lawful authority, knowingly
10 |leonverted for an unauthorized term or use services or property of another, to wit: ia
U1 | Bientrusted to the det
12 |}term or use, in violation of A.R'S. §§ 13-1802(A)(2), 13-1802(G) and (H), 13
13-701, 13-702, 13-708, 13-801, 13-804, and 13-811
dant oF placed in the defendant's possession for a limited, authorized
1 ed, seg., 15-603,
COUNT THRE
A W
is | t
IE
16 On or about April 19, 2017, JERONE DAVIS (001), without lawful authority, knowingly |
a
1s HIM crtrusted to the defendant or placed in the defendant's possession fora limited
|
authorized term or use, in violation of A.R.S. §§ 13-1802iA)(2), 13-1802(G) and (H), 13-301 et |
converted for an unauth:
Jed term ot use services or property of another, to v
ao [foes 13-603, 13-701, 13-702, 13-703, 13-801, 13-804, and 13-811. |
a COUNT FOUR
» THEFT, A CLASS TWO FELONY, |
2 On or about April {9, 2017, JERONE DAVIS (001), without lawful authority, knowingly |
o4 |leonverted for an unauthorized term or use services or property of anothe
os | to the defendant or placed in the defendant's possession for a limited.
6
2 ||authorized term or use, in violation of A.R.S. §§ 13-1802(A}(2), 13-1802(G) and (11), 13-301
| CR20 195394 -004
seq., 13-603, 13-701, 13-702, 13-703, 13-801, 13-804, and 13-811
3 | COUNT FIVE
; THEFT. A CLASS TWO FELON
s On or about April 19, 2017, JERONE DAVIS (001), without lawful authority, knowingly
. ized term of use serviees of propery of another, wo wit: EET
converted for an unautho
t's possession for a limited,
HE cntrested to the defendant or placed in the defen
authorized term or use, in violation of A.R.S. §§ 13-1802(A)(2), 13-1802 (G) and (H), 13-301 et
$
||seq., 13-603, 13-701, 13-702, 13-703, 13-801, 13-804, and 13-811
>
» | COUNT SIX
| ‘THEFT, A CLASS TWO FELONY
a| On or about April 19, 2017, JERONE DAVIS (001), without lawful authority, knowingly
|
converted for an unauthorized term or use services or property of another, to wit:
B
(EB crested to tne detendant or placed in the defendant's possession for a limited
1S || authorized term or use, in violation of A.R.S. §§ 13-1802(A¥2), 13-1802¢G) and (H), 13-301 et
15 || seq., 13-603, 13-701, 13-702, 13-703, 13-80], 13-804, and 13-811
” COUNT SEVEN
|
8
On or about April 19, 2017, JERONE DAVIS (001), without lawful authority, knowingly
comerted for an unauthorized term or use services or property of another. o wit
entrusted to the defendant or placed in the defendant’s possession for a limited, authorized term or
21 | use, in violation of A.R.S. §§ 13-1802(A)(2), 13-1802(G) and (H), 13-301 ef, seq. 13-603, 13-701. |
2 || 13-702, 13-703, 13-801, 13-804, and 13-811
|
DAVIS (001), without lawful authority, knowingly
es or property of another, o vit
261 | csc to the defendant or placed in the defendant's possession for a limited,
authorized term or use, in violation of A.R.S. §§
13-1802(A)(2), 13-1802(G) and (11), 13-301 et
1, 13-702, 13-703, 13-801, 13-804, and 13-81
|
|
FT, A CLASS TWO FELONY |
|
|] seq.. 13-603, 13
4 COUNT NINE
4 On or about May 18, 2017, JERONE DAVIS (001), without lawful authority, knowingly
converted for an unauthorized term of use services or property of another, to wit: J
HRB crusted to the defendant or placed in the defendant’s possession for a limited
8
authorized term or use, in violation of A.R.S. §§ 13-1802(A)(2), 13-1802(G) and (H), 13-301 et.
° Il seq., 13-603, 13-701, 13-702, 13-703, 13-801, 13-804, and 13-81 |
|
h COUNT TEN
wu AC TWO FELONY
b
(On of about May 18, 2017, JERONE DAVIS (001), without lawful authority, knowingly
b
converted for an unauthorized tem or use services or property of another, to wit:
4
PERI «sted 0 the defendant oF placed in the dete
authorized term or use, in violation of A.R.S. $§ 13-1802(A)(2), [3-1802(G) and (H), 13-301 er.
int’s possession for a limited,
16 |) seg., 13-603, 13-701, 13-702, 13-703, 13-801, 13-804, and 13-811
|
|| COUNT EL
|
ey On or about May 18, 2017, JERONE DAVIS (001), without lewful authority, knowin
>|)
|
converted for an unauthorized term or use services or property of another, to wit: jf
a4 He to the defendant or placed in the defendant's possession for a lin
(G) and (H), 13-301 et
thorized term or use, in violation of A.R.S, §§ 13-1802(A)(2), 13-1802
25 || seg., 13-603, 13-701, 13-702, 13-703, 13-801, 13-804, and 13-811WI << ustcd to the defendant or placed in the defendant's posse
On of about May 18, 2017, JERONE DAVIS (001), without lawful authority, knowingly
converted for an unauthorized term or use services or property of another, to wit: | |
jon for a limited
authorized term or use, in violation of A.R.S. §§ 13-1802(A)(2), 13-1802(G) and (H), 13-301 ef
seq., 13-603, 13-701, 13-702, 13-703, 13-801, 13-804, and 13-811.
coun’
THEET. AC
On of about May 18, 2017, JERONE DAVIS (001), without lawful authority, knowingly
converted for an unauthorized term or use services or property of another. 10 wit: | |
MM crusted to the defendant or placed in the defendant's possession for a limited,
G) and (H), 13-301 er
authorized term or use, in violation of A.R.S, §§ 13-1802(A)(2), 13-181
13-703, 13-801, 13-804, and 13-811
seq., 13-603, 13-701, 13-70
On or about May 18, 2017, JERONE DAVIS (001), without lawful authority, knowingly
converted for an un:
entrusted to the defendant or placed in the defendant's possession for a limited, authorized term or
use, in violation of A.R.S. $§ 13-1802(A)(2), 13-1802(G) and (H), 13-301 ef. seq, 13-603, 13-701
13-702,
-703, 13-801, 13-804, and 13-811
COUNT FIFTEEN
On of about May 3, 2017, JERONE DAVIS (001), without lawful authority, knowin
entrusted to the defendant or placed in the defendant’s possession for a limited, authorized term or
converted for an unauthorized term or useCR2U195794-0
=
i
|
use, in violation of A.R.S. §§ 13-1802(A\(2), 13-1802(G) and (H), 13-301 ex. seg., 13-603, 13-701,
13-702, 13-703, 13-801, 13-804, and 13-811. |
MARK BRNOVICH
| ATTORNEY GENERAL
ea a |
By: