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612/201 0 FILED IN OFFICE LVOlA GARDNER CLERK OF CIRCUIT COURT ORANGE CO FL

THE SUPREME COURT OF FLORIDA

CASE NUMBER SC09-1910

STATE OF FLORIDA Orange County Case No.: 2010


. .
CF'":J lo'lO
Plaintiff OSP Case No.: 2010-0091-TPA . D\\I ;';>0

VS.
Count 1: ORGANIZED FRAUD
JAMES.i\. GREER, F.S. S17,f)34
First "Qegree Felony "\
Defendant. "

I. Counts 2,3, 5: .GRAND· THEFT IN THE


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THIRD DEGREE
F.S. S12.014(2)(c)3
Third Degree Felony

. Count 4: GRAND THEFT IN THKSECOND


DEGREE
F.S. SI2.014(2)(b)1
Second Degree Felony

Count 6: MONEYLAUNDERING
F.S.896.101
First Degree Felony

IN THE NAME AND BY 'THE AUTHORITY OF THE STATE OF FLORIDA .

CQUNT I-ORGANIZED FRAUD

. The GRAND JURORS of the Nineteenth Statewide Grand Jury for the State of Florida,
duly called, impaneled, and sworn to inquire and true presentment make, upon their oaths, do
present and charge that beginning on or about May 1, 2007, and continuing through and .
including on or about March 31, 2010, in the Second, Ninth, Thirteenth, and Eighteenth Judicial
Circuits of Florida, to~wit: Leon, Orange, Hillsborough, and' Seminole Counties, Defendant
JAMES A. GREER and others engaged in a systematic. ongoing coUrse of conduct with the
intent to defraud or with the intent to obtain property from ·one or more persons by false or
fraudulent pretenses, representations, or promises or willful misrepresentations ofa future act,
to-wit: the Defendant, whiie a salaried employee of the Republican Party of Florida (RPOF),
created with others a Florida Limited· Lialjility Corporation (LLC) named Victory Strategies
(VSLLC) in which the Defendant held amonetary and/or ownership interest, in order to obtain
funds from the RPOF by defrauding and thereby inducing the RPOFlopay VSLLC and then
redirecting the funds into his ownaccount(s), withoutthe infonned knowledge or consent ofthe
RPOF'sExecutive Board, and thereby obtained property, tq-wit: U.S. Currency with an
aggregate value of $50,000.00 or more, in violation ofF.s. 817.034(4)(a)1 and 777.01 L
COUNT 2-GRAND THEFT THIRD DEGREE

The GRAND JURORS of the Nineteenth Statewide Grand Jury for the State of Florida,
duly called, impaneled, and sworn to inquire and true presentment make, upon their oaths, do
present and charge that on or' about July 23, 2009, in the Second, Ninth, and Eighteerith Judicial
Circuits of Florida, to~wit: Leon, Orange, and Seminole Counties, Defendant JAMES A.
GREER did knowingly obtain or use, or endeavor to obtain or use United States currency,the
property of the Republican Party of Florida, the value ofsaidprQpertybeing $10,000 or more but
less than $20,000, with the intent to temporarily or permanently deprive the Republican Party of
Florida of a right to the property, or a benefit therefrom, or'to appropriate the property to
defendant's own use or to the use of a person not entitled thereto, in violation of Florida Statute
812.014(2)(c)3 and 777.0n.

COUNT 3 - GRAND THEFT THIRD DEGREE

The GRAND JURORS of the Ninete~nth Statewide Grand Jury for the State 'of Florida,
duly called, impaneled, and sworn to inquire and true presentment make, upon their oaths, do
, present and charge that on or about August 26, 2009, in the Second, Ninth, and Eighteenth
Judicial Circuits of Florida, to-wit: Leon, Orange, and Seminole Counties, Defendant JAMES
A. GREER did knowingly obtain or use, or' endeavor to obtain or use United States currency,
the property of the Republican Party of Florida, the value of said property being $10,000 or more
but less than $20,000, with the intent to temporarily orpermanently deprive the Republican Party
of Florida of a right to the property, or a benefit therefrom, or to appropriate the property to
defendant's own use or to the use oia person not entitled thereto, in violation of Florida Statute
812.014(2)(c)3 and 777.011.

COUNT 4 -GRAND THEFT SECOND DEGREE

The GRAND JURORS of the Nineteenth StatewideGraIid Jury for the State of Florida,
duly called~ impaneled, and sworn to inquire and true presentment make,upon their oaths, do
present and charge that on or about September 10,2009, in the Second, Ninth, and Eighteenth
Judicial Circuits of Florida, to-wit: Leon, Orange, and Seminole Counties, Defendant JAMES
A. GREER did knowingly obtain or use, otendeavor to obtain or use United States currency,
the property of the Republican ,Party of Florida, the value of said property being $20,000 or more
but less than $100,000, with the intent to temporarily orpenp.anently deprive the Republican
Party of Florida of a right to the property" or a benefit therefrom, or to appropriate the property to
defendant's own use or to the use of a person not entitled thereto, in violation of Florida Statute
812.014(2)(b)1 and 777.011.
,./.t' "

//
Initials of the Grand Jury ForepersonF'-~_"""

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CdUNT 5 - GRAND THEFT THIRD DEGREE

The GRAND JURORS of the Nineteenth Statewide Grand Jury for the State of Florida,
duly called, impaneled, and sworn to inquire and true presentment make, upon their oaths, -do
present and charge that on or about October 7, 2009, in the Second,- Ninth, and Eighteenth
Judicial Circuits -of Florida, to-wit: Leon, Orange, and Seminole Counties, Defendant JAMES
A•. GREER did knowingly obtain or use, or endeavor to obtain or use United States currency,
the property of the Republican Party of Florida, the value of said property being $10,000 or more
but less than $20,000, with the intent to temporarily pr permanently deprive the Republican Party
of Florida of a right to the property, or a benefit _therefrom, or to appropriate the property to
defendant's O\\<TI use or to the use of a person not entitled thereto, in viblationof Florida Statute
812.014(2)(c)3 and 777.011.

COUNT-6 - MONEY LAUNDERING _

The GRAND JURORS of the Nineteenth Statewide Grand Jury for the State of Florida,
duly called, impaneled, and sworn to inquire and 'true presentment make, upon their oaths, do
present and charge that beginning on or about February 2009, and continuing through and
including on or about January 2010, in the Second, Ninth,Thirteenth, and Eighteenth Judicial
Circuits of Florida, to-wit: Leon, Orange, Hillsborough,and Seminole Counties, Defendant
JAMES A. GREER, while knowing that the property involved in a fmancial transaction
represented the proceeds of some form of unlawful activity, did conduct or attempt to conduct
such a financial transaction which in fact involved the proceeds of specified unlawful activity,
to-wit: violations of Chapter 817 and Chapter 812, Florida Statutes, relating to organized fraud
and grand theft with the intent to promote the carrying on ofsaid specified unlawful activity or
knowing that the transaction was designed in whole or part to conceal or disguise the nature, the
location, the source, the ownership, or the control-of the proceeds of specified unlawful activity,
and the amounts of the financial transactions involved totaled or exceeded $100,000.00 in a
twelve month period, all in violation of Section 896.l0l(3)(a) and (5)(c) and 777.011, Florida
Statutes. .

AND ALL OF THE ABOVE OFFENSES OCCURRED IN TWO OR MORE JUDICIAL


CIRCUITS AS PART OF ARELATED TRANSACTION OR WERE COMMITTED IN
CONNECTION WITH AN ORGANIZED CRIMINAL CONSPIRACY AFFECTING TWO OR
MORE JUDICIAL CIRCUITS OF THE STATE OF FLORIDA.

~Nineteenth Statewide Grand Jury of Florida

~I ,,,lit>
Date

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I, WILLIAM N; SHEPHERD, Legal Adviser, Nineteenth Statewide Grand Jury, and


Statewide Prosecutor for the State of Florida, hereby certify that I, as such Prosecuting Officer
and as authorize~ 3d required by law, have advised the Grand Jury which returned this
Indictment this ~ day of May, 2010. .

G~d=~L
William N ~Shepherd . ~
Legal Adviser to the .
Nineteenth Statewide Grand Jury
Florida Bar Number 088668
1515 N. Flagler Drive, Suite 900
West Palm Beach, Florida 33401
561-837-5100

The foregoing Indictment was returned before me in open Court this I t day of
May, 2010, and further, it is hereby sealed until the Defendant's arrest, at which time it shall be
unsealed without necessity of further Order of this Court. I he eby certify order the transfer
of this Indictment to Orange County, Florida, pursuant to 10 'aa St tute 9. .3.

HONO
Presiding Judge
Nineteenth Statewide Grand Jury

Filed in the Supreme Court ofFlorida, this 19" day of May, 2010.

Filed in the Circuit Court of the Ninth Judicial Circuit, Orange County, Florida,this
~ dayof ~ 2010. .

Clerk
Deputy Clerk A
Attest:
Thomas
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Isup;:/le~~~~;<%.l,.J".J
cas

Defendant's Data:

JAMES A. GREER
White Male
DOB: 06/08/1962
LKA: 1205 Prestige Point, Oviedo, Florida 32765

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