Cuyahoga County Court of Common Pleas

Criminal Court Division

State of Ohio,
Plaintiff
VS.

A True Bill Indictment For

Bribery - F3 2921.02(B) 28 Additional Count(s)
Case Number

Harry J. Jacob III

Kenneth C. Schuman, Defendants

The Term Of

Dates of Offense (on or about)

07/25/2006 to 11/04/2013

January of 2014

584560-14-CR

The State of Ohio,

Cuyahoga County Count 1 Defendants Date of Offense

SS.

Bribery - F3 2921.02(B) Kenneth C. Schuman On or about August 30, 2006 to November 7, 2006

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

did knowingly solicit or accept for himself or another person any valuable thing or valuable benefit, to wit: money, to corrupt or improperly influence him or another public servant or party official with respect to the discharge of his or the other public servant's or party official's duty, either before or after he was elected, appointed, qualified, employed, summoned, or sworn as a public servant or party official.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.

Count 2 Defendants Date of Offense

Having An Unlawful Interest In A Public Contract - F4 2921.42(A)(1) Kenneth C. Schuman On or about August 30, 2006 to November 7, 2006

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did while being a public official knowingly authorize or employ the authority or influence of his office to secure authorization of any public contract in which he, a member of his family, or any of his business associates had an interest.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.

<GRANDJURORSIGNATURE>
Foreperson of the Grand Jury

<PROSECUTORSIGNATURE>
Prosecuting Attorney

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Cuyahoga County Court of Common Pleas

A True Bill Indictment

Count 3 Defendants Date of Offense

Soliciting Or Receiving Improper Compensation - M1 2921.43(A)(1) Kenneth C. Schuman On or about November 2, 2006 to November 7, 2006

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did while being a public servant knowingly solicit or accept any compensation, other than as allowed by divisions (G), (H), and (I) of section 102.03 of the Revised Code, to perform the public servant's official duties, to perform any other act or service in the public servant's public capacity, for the general performance of the duties of the public servant's public office or public employment, or as a supplement to the public servant's public compensation.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 4 Defendants Date of Offense

Money Laundering - F3 1315.55(A)(1) Kenneth C. Schuman On or about November 2, 2006 to November 7, 2006

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did conduct or attempt to conduct a transaction knowing that the property involved in the transaction was the proceeds of some form of unlawful activity with the purpose of committing or furthering the commission of corrupt activity.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 5 Defendants Date of Offense

Theft In Office - F4 2921.41(A)(1) Kenneth C. Schuman On or about July 25, 2006 to June 17, 2013

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did, while being a public or party official, commit a theft offense, as defined in division (K) of section 2913.01 of the Revised Code, when the offender used the offender's office in aid of committing the offense or permitted or assented to its use in aid of committing the offense and the value of property or services stolen was five hundred dollars or more and was less than five thousand dollars.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.

<GRANDJURORSIGNATURE>
Foreperson of the Grand Jury

<PROSECUTORSIGNATURE>
Prosecuting Attorney

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Cuyahoga County Court of Common Pleas

A True Bill Indictment

Count 6 Defendants Date of Offense

Obstructing Justice - F5 2921.32(A)(5) Kenneth C. Schuman On or about October 8, 2013

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

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, communicate false information to any person. FURTHERMORE, and the crime committed or alleged to have been committed by the person aided was James Walsh, a felony.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 7 Defendants Date of Offense

Falsification - M1 2921.13(A)(3) Kenneth C. Schuman On or about October 8, 2013

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did knowingly make a false statement, or knowingly swear or affirm the truth of a false statement previously made, when the statement was made with purpose to mislead a public official in performing the public official's official function.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 8 Defendants Date of Offense

Soliciting - M3 2907.24(A) Kenneth C. Schuman On or about October 13, 2013

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did solicit Jane Doe 1 to engage in sexual activity for hire.

The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.

<GRANDJURORSIGNATURE>
Foreperson of the Grand Jury

<PROSECUTORSIGNATURE>
Prosecuting Attorney

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Cuyahoga County Court of Common Pleas

A True Bill Indictment

Count 9 Defendants Date of Offense

Bribery - F3 2921.02(B) Harry J. Jacob III On or about April 20, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did knowingly solicit or accept for himself or another person any valuable thing or valuable benefit, to wit: sex, to corrupt or improperly influence him or another public servant or party official with respect to the discharge of his or the other public servant's or party official's duty, either before or after he was elected, appointed, qualified, employed, summoned, or sworn as a public servant or party official.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 10 Defendants Date of Offense

Dereliction Of Duty - M2 2921.44(B) Harry J. Jacob III On or about April 20, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did while being a law enforcement, ministerial, or judicial officer negligently fail to perform a lawful duty in a criminal case or proceeding.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 11 Defendants Date of Offense

Soliciting - M3 2907.24(A) Harry J. Jacob III On or about January 1, 2009 to June 30, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did solicit Jane Doe 2 to engage in sexual activity for hire.

The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.

<GRANDJURORSIGNATURE>
Foreperson of the Grand Jury

<PROSECUTORSIGNATURE>
Prosecuting Attorney

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Cuyahoga County Court of Common Pleas

A True Bill Indictment

Count 12 Defendants Date of Offense

Promoting Prostitution - F4 2907.22(A)(4) Harry J. Jacob III On or about December 1, 2011 to May 1, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

knowingly , for the purpose of violating or facilitating the violation of Section 2907.22 of the Revised Code, induce or procure Jane Doe 2 and Jane Doe 3 to engage in sexual activity for hire.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 13 Defendants Date of Offense

Soliciting - M3 2907.24(A) Harry J. Jacob III On or about December 1, 2011 to May 1, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did solicit Jane Doe 2 and Jane Doe 3 to engage in sexual activity for hire.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 14 Defendants Date of Offense

Promoting Prostitution - F4 2907.22(A)(2) Harry J. Jacob III On or about April 20, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

knowingly supervise, manage, or control the activities of a prostitute in engaging in sexual activity for hire.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 15 Defendants Date of Offense

Promoting Prostitution - F4 2907.22(A)(4) Harry J. Jacob III On or about April 20, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

knowingly , for the purpose of violating or facilitating the violation of Section 2907.22 of the Revised Code, induce or procure Jane Doe 3 and Jane Doe 4 to engage in sexual activity for hire.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.

<GRANDJURORSIGNATURE>
Foreperson of the Grand Jury

<PROSECUTORSIGNATURE>
Prosecuting Attorney

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Cuyahoga County Court of Common Pleas

A True Bill Indictment

Count 16 Defendants Date of Offense

Soliciting - M3 2907.24(A) Harry J. Jacob III On or about April 20, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did solicit Jane Doe 3 and Jane Doe 4 to engage in sexual activity for hire.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 17 Defendants Date of Offense

Soliciting - M3 2907.24(A) Harry J. Jacob III On or about June 29, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did solicit Jane Doe 4 to engage in sexual activity for hire.

The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 18 Defendants Date of Offense

Soliciting - M3 2907.24(A) Harry J. Jacob III On or about August 14, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did solicit Jane Doe 4 to engage in sexual activity for hire.

The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 19 Defendants Date of Offense

Soliciting - M3 2907.24(A) Harry J. Jacob III On or about September 29, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did solicit Jane Doe 4 to engage in sexual activity for hire.

The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.

<GRANDJURORSIGNATURE>
Foreperson of the Grand Jury

<PROSECUTORSIGNATURE>
Prosecuting Attorney

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Cuyahoga County Court of Common Pleas

A True Bill Indictment

Count 20 Defendants Date of Offense

Tampering with Records - F3 2913.42(A)(1) Harry J. Jacob III On or about April 20, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on Bedford Municipal Court and/or Orange Village, falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Journal Entry, and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 21 Defendants Date of Offense

Tampering With Evidence - F3 2921.12(A)(2) Harry J. Jacob III On or about April 20, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did, knowing that an official proceeding or investigation was in progress, or was about to be or likely to be instituted, make, present, or use any record, document, or thing, knowing it to be false and with purpose to mislead a public official who was or might have been engaged in such proceeding or investigation, or with purpose to corrupt the outcome of any such proceeding or investigation.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 22 Defendants Date of Offense

Tampering With Evidence - F3 2921.12(A)(1) Harry J. Jacob III On or about November 2, 2013 to November 4, 2013

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did, knowing that an official proceeding or investigation was in progress, or was about to be or likely to be instituted, alter, destroy, conceal, or remove any record, document, or thing, with purpose to impair its value or availability as evidence in such proceeding or investigation.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.

<GRANDJURORSIGNATURE>
Foreperson of the Grand Jury

<PROSECUTORSIGNATURE>
Prosecuting Attorney

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Cuyahoga County Court of Common Pleas

A True Bill Indictment

Count 23 Defendants Date of Offense

Failure To Report A Felony - M4 2921.22(A)(1) Harry J. Jacob III On or about July 1, 2013

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did, knowing that a felony had been or was being committed, knowingly fail to report such information to law enforcement authorities.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 24 Defendants Date of Offense

Possessing Criminal Tools - F5 2923.24(A) Harry J. Jacob III On or about April 18, 2012 to November 4, 2013

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did possess or have under the person's control any substance, device, instrument, or article, to wit: cellular telephone, computer with purpose to use it criminally. FURTHERMORE, the cellular telephone, computer involved in the offense were intended for use in the commission of a felony, to wit: 2913.12(A)(2), and/or 2921.12(A)(1), and/or 2907.22(A)(2), and/or 2907.22(A)(4).
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 25 Defendants Date of Offense

Tampering with Records - F3 2913.42(A)(1) Harry J. Jacob III On or about May 21, 2012 to May 25, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on the people of Bedford Heights and/or the constituents of the Bedford Municipal Court and/or the the Bedford Municipal Court Clerk, falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Journal Entry, and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.

<GRANDJURORSIGNATURE>
Foreperson of the Grand Jury

<PROSECUTORSIGNATURE>
Prosecuting Attorney

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Cuyahoga County Court of Common Pleas

A True Bill Indictment

Count 26 Defendants Date of Offense

Tampering With Evidence - F3 2921.12(A)(2) Harry J. Jacob III On or about May 21, 2012 to May 25, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did, knowing that an official proceeding or investigation was in progress, or was about to be or likely to be instituted, make, present, or use any record, document, or thing, knowing it to be false and with purpose to mislead a public official who was or might have been engaged in such proceeding or investigation, or with purpose to corrupt the outcome of any such proceeding or investigation.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 27 Defendants Date of Offense

Obstructing Justice - UM 2921.32(A)(5) Harry J. Jacob III On or about May 21, 2012 to May 25, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

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, communicate false information to any person. FURTHERMORE, and the crime committed or alleged to have been committed by the person aided was Domestic Violence, a misdemeanor.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count 28 Defendants Date of Offense

Falsification - M1 2921.13(A)(11) Harry J. Jacob III On or about May 21, 2012 to May 25, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did knowingly make a false statement, or knowingly swear or affirm the truth of a false statement previously made, when the statement was made on an account, form, record, stamp, label, or other writing that was required by law.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.

<GRANDJURORSIGNATURE>
Foreperson of the Grand Jury

<PROSECUTORSIGNATURE>
Prosecuting Attorney

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Cuyahoga County Court of Common Pleas

A True Bill Indictment

Count 29 Defendants Date of Offense

Falsification - M1 2921.13(A)(13) Harry J. Jacob III On or about May 21, 2012 to May 25, 2012

The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did knowingly make a false statement, or knowingly swear or affirm the truth of a false statement previously made, when the statement was made in a document or instrument of writing that purports to be a judgment, lien, or claim of indebtedness and was filed or recorded with the secretary of state, a county recorder, or the clerk of a court of record.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.

<GRANDJURORSIGNATURE>
Foreperson of the Grand Jury

<PROSECUTORSIGNATURE>
Prosecuting Attorney

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