ASSAULT, HANDGUN VIOLATION, THEFT, DISORDERLY INTOXICATION

State of Maryland,
City of Baltimore, to wit:
IN THE CIRCUIT COURT FOR BALTIMORE CITY
THE STATE OF MARYLAND Date of Offense: On/About March 5, 2023
-VS-
Location : 2705 Pennsylvania Avenue, Baltimore, Maryland
LARRY WORSLEY

defendant:

INDI CTMENT

The Grand Jurors of the State of Maryland for the body of the City of Baltimore,

do on their oath present that, on/about March 5, 2023, in the City of Baltimore, State of

Maryland, the Defendant, Larry Worsley, did commit assault(s), theft, use of a firearm in

a crime of violence and disorderly intoxication, in violation of the Criminal Law, Public

Safety and Alcoholic Beverages Articles of Maryland, against the peace, government,

and dignity of the State.

Background

1. “Tequila Sunset” is a bar located at 2705 Pennsylvania Avenue, in

Baltimore City, Maryland.

2. On March 5, 2023, the Defendant, Larry Worsley, entered the bar with an

unknown female. He started a “tab” and subsequently ordered 3 alcoholic beverages.

3. Soon after consuming the third drink, the Defendant, Larry Worsley,

became noticeably intoxicated. He was seen physically assaulting the unknown female

who was with him.

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4. The Defendant, Larry Worsley, was told that he had to leave the bar. The

Defendant, Larry Worsley, then attempted to leave the bar without paying his $42 tab.

5. While attempting to leave the bar, the Defendant, Larry Worsley, grabbed

another female, and stated, “You’re coming with me” as he attempted to

drag her out of the bar. Several unknown patrons of the bar intervened and protected

from the attack.

6. After being separated from , a bar employee, ,

approached the Defendant, Larry Worsley, and told him to pay his tab. At that time, the

Defendant, Larry Worsley, reached into a hip satchel and pulled out a .40 caliber

handgun, racked it, and told , “I’m not paying for shit.”

7. With the gun still in his hand, the Defendant, Larry Worsley, grabbed his

unknown female companion by the hair and dragged her towards a white Mercedes.

After placing the unknown female companion in the Mercedes, the unknown female was

able to lock the doors, start the car, and take off.

8. The Defendant, Larry Worsley, then began walking away from the bar.

Police officers located him walking several blocks away from the bar, and subsequently

located a .40 caliber handgun on him. The identified victims then positively identified

the Defendant, Larry Worsley, as the person who had assaulted them, brandished a

firearm, and refused to pay his tab for the alcohol.

Charges

9. The Grand Jurors, having received evidence supporting paragraphs 1-8

herein, reaffirming and incorporating said paragraphs, do allege and charge:

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ASSAULT, HANDGUN VIOLATION, THEFT, DISORDERLY INTOXICATION

(Count 1)

The Grand Jury for Baltimore City, State of Maryland, January 2023 term, having
been duly sworn, do on their oaths present and allege that the above named Defendant, on
or about March 5, 2023, in the area of 2705 Pennsylvania Avenue, in Baltimore City,
State of Maryland, did assault in the first degree by use of handgun in the
commission of an assault, in violation of the Criminal Law Article, and against the peace,
government and dignity of the State.

Assault 1st Degree, CR 3-202(a), CJIS 1-1420

(Count 2)

The Grand Jury further alleges that the above named Defendant, on or about
March 5, 2023, in the area of 2705 Pennsylvania Avenue, in Baltimore City, State of
Maryland, did assault an unknown female in the first degree by use of handgun in the
commission of an assault, in violation of the Criminal Law Article, and against the peace,
government and dignity of the State.

Assault 1st Degree, CR 3-202(a), CJIS 1-1420

(Count 3)

The Grand Jury further alleges that the above named Defendant, on or about
March 5, 2023, in the area of 2705 Pennsylvania Avenue, in Baltimore City, State of
Maryland, did assault in the second degree in violation of the Criminal Law
Article, against the peace, government and dignity of the State.

Assault 2nd Degree, CR 3-203; CJIS 1-1415

(Count 4)

The Grand Jury further alleges that the above named Defendant, on or about
March 5, 2023, in the area of 2705 Pennsylvania Avenue, in Baltimore City, State of
Maryland, did assault in the second degree in violation of the Criminal
Law Article, against the peace, government and dignity of the State.

Assault 2nd Degree, CR 3-203; CJIS 1-1415

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ASSAULT, HANDGUN VIOLATION, THEFT, DISORDERLY INTOXICATION

(Count 5)

The Grand Jury further alleges that the above named Defendant, on or about
March 5, 2023, in the area of 2705 Pennsylvania Avenue, in Baltimore City, State of
Maryland, did assault an unknown female in the second degree in violation of the
Criminal Law Article, against the peace, government and dignity of the State.

Assault 2nd Degree, CR 3-203; CJIS 1-1415

(Count 6)

The Grand Jury further alleges that the above named Defendant, on or about
March 5, 2023, in the area of 2705 Pennsylvania Avenue, in Baltimore City, State of
Maryland, did use a firearm in the commission of a crime of violence, as defined in the
Public Safety Article, PS 5-101, in violation of the Criminal Law Article, against the
peace, government and dignity of the State.

Use of a Firearm in Commission of a Crime of Violence, CR 4-204, CJIS 1-5299

(Count 7)

The Grand Jury further alleges that the above named Defendant, on or about
March 5, 2023, in the area of 2705 Pennsylvania Avenue, in Baltimore City, State of
Maryland, did use a firearm in the commission of a crime of violence, as defined in the
Public Safety Article, PS 5-101, in violation of the Criminal Law Article, against the
peace, government and dignity of the State.

Use of a Firearm in Commission of a Crime of Violence, CR 4-204, CJIS 1-5299

(Count 8)

The Grand Jury further alleges that the above named Defendant, on or about
March 5, 2023, in the area of 2705 Pennsylvania Avenue, in Baltimore City, State of
Maryland, did steal alcoholic beverages belonging to Tequila Sunset, a business, having a
value of less than $100, in violation of the Criminal Law Article, against the peace,
government and dignity of the State.

Theft, CR 7-104; CJIS 1-0521

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ASSAULT, HANDGUN VIOLATION, THEFT, DISORDERLY INTOXICATION

(Count 9)

The Grand Jury further alleges that the above named Defendant, on or about
March 5, 2023, in the area of 2705 Pennsylvania Avenue, in Baltimore City, did cause a
public disturbance and endanger the safety of another individual while intoxicated, in
violation of the Alcoholic Beverages Article, against the peace, government and dignity
of the State.

Disorderly Intoxication, AB 6-320(a); CJIS 1-1661