Cuyahoga County Court of Common Pleas

Criminal Court Division

State of Ohio,
Plaintiff
VS.

A True Bill Indictment For

Bribery - F3 2921.02(B) 18 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 10/13/2013

September of 2013

581077-13-CR

The State of Ohio,

Cuyahoga County Count One 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 Two 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 Three 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 Four 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 Five 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 Six 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 Seven 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 Eight 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 Nine 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 Ten Defendants Date of Offense

Dereliction Of Duty - M2 2921.44(B) Harry J. Jacob III On or about April 13, 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 Eleven 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 Twelve 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 Thirteen 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 Fourteen 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 Fifteen 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 Sixteen 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 Seventeen 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 Eighteen 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 Nineteen 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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