SUPERIOR COURT OF THE STATE OF CALIFOKNIA,
FOR THE COUNTY OF LOS ANGELES
‘The People ofthe State of California, CASENO. BA453095
Pi
ssa meeagaee |" SECRET
2. THADDEUS JULIAN CULPEPER
COUNT
‘The said MATTHEW POWELL FLETCHER, THADDEUS JULIAN CULPEPPER AND OTHER
UNINDICTED CO-CONSPIRATORS are accused by the Grand Jury ofthe County of Los Angeles, State of
California, by ths Indictment, ofthe crime of CONSPIRACY TO COMMIT A CRIME, in violation of
Penal Code Section 182(a)(1), a Felony, committed prior tothe finding ofthis Indictment, and as follows:
Presented by the Foreperson ofthe Grand July tl presence of the Grand Jury, in open Superior Court
of the Site of California, within and forthe County bf Los Angeles, and filed asa recordin said Court this
2éth day of January, 2018
SHERRIR. CARTER, Executive OfficeriClerk
By. On or between January 29, 2015 and September 16, 2016, inthe County of Los Angeles, the said MATTHEW
POWELL FLETCHER, THADDEUS JULIAN CULPEPER AND OTHER UNINDICTED CO-
CONSPIRATORS id unlawfully conspire together and with another person and persons whose identity is
unknown to commit the crime of BRIBERY OF WITNESS, in violation of Section 137(a) of the Penal Code,
‘felony: that pursuant to and for the purpose of carrying ou the objectives and purposes ofthe aforesaid
‘conspiracy, the said defendants committed the following overt act and acts at and inthe County of Los Angeles
OVER ACTS
(On January 29, 2015, a approximately 6:03pm. afew hours after the murder of Terry Carter and
‘the attempted murder of Cle “Bone” Sloan, Mark Blankenship spoke with Marion “Suge” knight
‘on the phone.
On January 29, 2015, at approximately 8:15pm, a few hours after the murder of Terry Cart
the attempted murder of Cle “Bone” Sloan, Mark Blankenship sent a text message to Toilin
Kelly stating “tll Suge Ihave spoken to Reggic and have him ready and in check if we need
him”
On January 29, 2015, at approximately 10:18 p.m., Mark Blankenship sent a text message to
“Johnny” stating that he was going to meet with “Suge” and get his side ofthe story.
On January 30, 2015, at approximately 2:38 aim., Mark Blankenship send a text to Reggie
‘Beamon asking him to meet at 11:30 a
(On January 30, 2015, at approximately noon, Mark Blankenship sent a text to Toilin Kelly
stating “I'm driving with Reggie. HE SAW EVERYTHING AND CAN EXONERATE SUGE”.
On February 1, 2015, at approximately 1:20 pan., Mark Blankenship sent a text to Reggie
Beamon asking “ean you tlk?”
On February 1, 2015, at approximately 1:30 p.m., Mark Blankenship sent a text to Reggie
‘Beamon identifying the eyewitnesses tothe murder of Terry Carter: “Marvin McKenzic- took
video that went to TMZ, Dwayne Johnson-Knob, Jimmy-possible attacker, Terry.”
(On February 3,2015, a approximately 12:30p.m., Mark Blankenship sent a tex to Toilin Kelly
‘conceming eyewitness Dwayne “Knob” Johnson. The message read “I am seeing later today for
‘other’ reasons but we need to get his estimony ina tractor beam, asap.”
On February 16, 2015, at approximately 1:44 p.m., Mark Blankenship sent a text to Reggie
Beamon stating “please remember you are my highest priority and that I value and appreciate
you.
‘On February 16, 2015, at approximately 1:47 pam. Reggie Beamon sent Mark Blankenship text
stating... shld be. Show it I'm from Missouri the show me state. Reg.”
(On February 17, 2015, at approximately 3:41 p.m., Mark Blankenship sent Reggie Beamon a
‘MoneyGram in the amount of $250.00.
‘On March 9, 2015, at approximately 3:21 p:m., Mark Blankenship sent a text message to target
Matthew Powell Fletcher stating “I know how to get Sloan.”
‘On March 13, 2015, Marion “Suge” Knight spoke to Toilin Kelly on the telephone. He told her
that thee is a witness who will do whatever is needed and say that they saw a gun atthe murder
(On March 13, 2015, Tolin Kelly told Marion “Suge” Knight that Mark Blankenship put Regie
Beamon on the payroll,
(On March 13, 2015, Marion “Suge” Knight told an unidentified male that he had a “litle project
{or him coming up” and that “in a week or so, something would be coming your way.”
(On March 13,2015, at approximately 11:00 am. target Matthew Powell Fletcher send a text
‘message to Mark Blankenship stating “I have found a eyewitnes...he says there were multiple
‘uns...rying to get him to go public..he's seared, ..we are working him hard.”
and 17.
18,
20,
a.
2.
23,
25.
26.
2.
28
29.
30
3h.
22
33.
4.
35.
36
37
‘On March 16, 2015, Toilin Kelly told Marion Hugh “Suge” Knight that "Mat found other
witnesses” and that "Matt put some bread out there” o gt witnesses to “come around.
‘On March 16,2015, Mark Blankenship connected Marion Hugh “Suge” Knight to arget
“Matthew Powell Fletcher va thre-way telephone call.
‘On March 16,2015, Matthew Powell Fletcher old Marion Hugh “Suge” Knight tht witness
“Marvin Kiney would say tht there were guns a the murder scene and they would give Marvin
money for his testimony.
‘On March 16,2015, Mathew Powell Fletcher told Marion Hugh “Suge” Knight that 20-25,
‘thousand dollars was a fair investment to secure his freedom,
‘On May 9,2016, Marion Hugh “Suge” Knight had conversation with a Los Angeles County
Shecf's Department informant named “KB.”
On May 9, 2016, after “KB” implied that he could assist in Maron Hugh “Suge” Knight's
defense, Knight said I'm gonna fuk with you"
‘On May 10,2016, target Matthew Powell Fletcher called “KB.”
‘On May 10,2016, target Matthew Powell Fletcher told “KB” thatthe witnesses in Marion Hugh
“Suge” Knight's murder ease needed tobe paid for their testimony.
(On May 10,2016, target Matthew Powell Feicher told “KB" that he would discuss with Marion
Hugh “Suge” Knight possibly using “KB as witness inthe murder ease
On or between May 10,2016, and May 18, 2016, target Matthew Powel Fletcher provided
KB" phone number to target Thaddeus Julian Culpepper.
On May 18,2016, target Thaddeus Jlian Culpepper called “KB” and Culpepper agreed that
“KB” could call him back
On June 10,2016, target Thaddeus Julian Culpepper spoke with “KB.” Target Culpepper told
“KB” that he received his phone number from arget Matthew Powel leche.
On June 10,2016, KB” told target Thaddeus Julian Culpepper thet “he wasn’t here but
‘watever you need me todo I'll da it.” Target Culpepper replied “so you weren't thee but you
know what's going on?”
On June 10, 2016, target Thaddeus Julian Culpepper told “KB” to callhim when be KB")
retumed to California.
On June 22,2016, target Thaddeus Julian Culpepper called “KB”. "KB" told Target Culpepper
“Tl do whatever..but you know what, I'm gonna need afew dollar. ..maybe ater down the
lin.” Target Culpepper responded “of course, or couse.”
On June 28, 2016, target Thaddeus Julian Culpepper met with “KB” at a restaurant in Los
‘Angeles. Target Culpepper offered to draft a declaration for “KB” to sign and “KB” agreed.
On June 28, 2016 terget Thaddeus Julian Culpepper met with Marion Hugh “Suge” Knight ina
interview room a the Men's Cental alin Los Angeles, Target Culpepper tld Knight that
“KB” was willing otestify hat he saw guns atthe murder sene.
On June 29,2016, KB" met with target Thaddeus Julian Culpepper in Encino California, Target
Culpepper told “KB” that he intended to prepare a declaration for°KB"” to sign In aditon, he
‘wanted “KB” to watch the suvellace video from the murder. Target Culpepper provided “KB”
‘with a handwritten note containing a Los Angeles address; he told "KB" o “tuck that away.”
On June 29,2016 target Thaddeus Julian Culpepper met with Marion Hugh “Suge” Knight in a
interview room at the Men's Cental alin Los Angeles. Target Culpepper and Knight agreed to
use KB" asa witness but to withhold his identity unl th commencement ofthe ia
On June 29,2016, during the same meeting at Men's Cental Jil, Marion Hugh “Suge” Knight
asked target Thaddeus Jlian Culpepper if*KB” was in custody a the time ofthe murder. Target
Culpepper responded hat he had already checked and that he (KB) was no in custody.
On August 21,2016, target Matthew Powell Feicher met with Marion Hugh “Suge” Knight ina
{nerview oom atthe Men's Cental Jail in Los Angeles. Target Fletcher told Knight that witness
‘Marvin Kiny had tobe paid for his testimony; Knight agreed 38. On September 16, 2016, target Matthew Powell Fletcher met with Marion Hugh “Suge” Knight
ina interview room at the Men's Central Jal in Los Angeles. Target Fletcher told Knight thatthe
surviving viet in the attempted murder, Cle “Bone” Sloan, needed tobe paid money for his
testimony.” And Knight agreed
counT2
Fora furtherand separate cause of action, being 2 different offense ofthe same class of crimes and offenses as
the charge set forth in the aforestated Count hereof, the said MATTHEW POWELL FLETCHER,
‘THADDEUS JULIAN CULPEPPER AND OTHER UNINDICTED CO-CONSPIRATORS are accused by
the Grand Juy of the County of Los Angeles, tate of California, by tis Indictment, ofthe rime of
CONSPIRACY TO COMMIT A CRIME, in violation of Penal Code Section 183(a)(1), a Felony,
‘committed prior to the finding ofthis Indictment, and as follows:
(On and between January 29, 2015 and September 16,2016 inthe County of Los Angeles, the said MATTHEW
POWELL FLETCHER, THADDEUS JULIAN CULPEPPER AND OTHER UNINDICTED CO-
CONSPIRATORS did unlawfully conspire together and with another person and persons whose identity is
‘unknown to zommit the crime of SUBORNATION OF PERJURY UNDER OATH, in violation of Section
127 of the Penal Code, a felony; that pursuant to and for the purpose of carrying out the objectives and purposes
of the aforestd conspiracy, the said defendan((s) commited the following overt act and acts at and in the
County of Los Angeles:
OVERT ACTS
1, On January 29, 2015, at approximately 6:03pm. a few hours after the murder of Terry Carter and
the attempted murder of Cle “Bone” Sloan, Mark Blankenship spoke with Marion “Suge” knight
‘onthe phone.
2 On January 29, 2015, at approximately 8:15pm, afew hours afler the murder of Terry Carter and
the attempted murder of Cle “Bone” Sloan, Mark Blankenship sent a text message to Toilin
Kelly tating “tell Suge I have spoken to Reggie and have him ready and in check if we need
him”
3. On January 29, 2015, at approximately 10:18 pxm., Mark Blankenship set a text message to
“Johnny” stating that he was going to meet with “Suge” and get his ide ofthe story.
4. On January 30,2015, at approximately 2:38 a.m, Mark Blankenship send a text to Reggie
[Beamon asking him fo meet at 11:30 am,
5. On January 30, 2015, at approximately noon, Mark Blankenship sent a text to Tolin Kelly
siating “I'm driving with Reggie. HE SAW EVERYTHING AND CAN EXONERATE SUGE”.
6. On February 1, 2015, at approximately 1:20 p.m., Mark Blankenship sent a text to Reggie
Beamon asking “ean you talk?"
7. On February 1, 2015, at approximately 1:30 p.m., Mark Blankenship sent a text to Reggie
‘Beamon identifying the eyewitnesses to the murder of Terry Carter: “Marvin MeKenze- took
‘video that went to TMZ, Dwayne Johnson-Knob, Jimmy-possible attacker, Terry
8. On February 3, 2015, at approximately 12:30p.m., Mark Blankenship sent text to Toilin Kelly
‘concerning eyewitness Dwayne “Knob” Johnson. The message read “I am seeing later today for
“other” reasons but we need to get hs testimony in a tractor beam, ss9p."
9. On February 16, 2015, at approximately 1:44 pim., Mark Blankeaship sent a text to Reggie
‘Beamon stating “please remember you are my highest priority an that I value and appreciate
you. 13.
14
15.
16.
18.
19.
20,
21
2,
2
2s,
06.
n,
28.
2».
30,
31
32,
(On February 16,2015, at approximately 1:47 p.m., Reggie Beamon sent Mark Blankenship text
sating “..1 shld be. Show i, Im from Missouri the show me state. Reg.”
(On February 17, 2015, at approximately 3:41 p.m., Mark Blankenship sent Reggie Beamon a
‘MoneyGram in the amount of $250.00.
‘On March 9, 2015, at approximately 3:21 pim., Mark Blankenship sent a text message to target
‘Matthew Powell Fietcher stating “I know how to get Sloan.”
‘On Mareh 13, 2015, Marion “Suge” Knight spoke to Toilin Kelly onthe telephone. He told her
that there is a witness who will do whatever is needed and say that they saw a gun at the murder
(On March 13, 2015, Toilin Kelly told Marion “Suge” Knight that Mark Blankenship put Reggie
‘Beamon on the payroll
‘On March 13, 2015, Marion “Suge” Knight told an unidentified male that he had a “tle project
{or him coming up” and that “in a week or so, something would be coming your way.”
(On Mareh 13, 2015, at approximately 11:00 a.m., target Matthew Powell Fletcher send a text
‘message to Mark Blankenship stating “I have found a eyewitness...he says there were multiple
‘guns..trying to get him to go public...he'sscared...we are working him hard.”
‘On March 16, 2015, Toilin Kelly told Marion Hugh “Suge” Knight that "Matt found other
“witnesses” and that “Matt put some bread out there” to get witnesses to “come around.
‘On March 16, 2015, Mark Blankenship connected Marion Hugh “Suge” Knight to target
‘Matthew Powell Fletcher via a three-way telephone cll
‘On March 16, 2015, Matthew Powell Fletcher fold Marion Hugh “Suge” Knight that witness
‘Marvin Kincy would say thet there were guns at the musder scene and they would give Marvin
‘money for his testimony.
‘On March 16, 2015, Mathew Powell Fletcher told Marion Hugh “Suge” Knight that 20-25,
thousand dollars was afar investment to secure his freedom,
‘On May 9, 2016, Marion Hugh “Suge” Knight had a conversation with a Los Angeles County
Sheriff's Department informant named “KB.”
(On May 9, 2016, fier “KB” implied that he could assist in Marion Hugh “Suge” Knight's
defense, Knight said “I'm gonna fuck with you.”
‘On May 10, 2016, target Matthew Powell Flecher called “KB.”
On May 10, 2016, target Matthew Powel Fletcher told “KB” thatthe witnesses in Marion Hugh
“Suge” Knight's murder case needed to be pad for their testimony.
(On May 10, 2016, target Matthew Powell Fletcher told “KB” that he would discuss with Marion
‘Hugh “Suge” Knight possibly using “KB" as a witness in the murder case,
(On or between May 10,2016, and May 18, 2016, target Matthew Powell Fletcher provided
“KB"s phone number to target Thaddeus Julian Culpepper
‘On May 18, 2016, target Thaddeus Julian Culpepper called “KB” and Culpepper agreed that
'KB” could call him back.
On June 10, 2016, target Thaddeus Julian Culpepper spoke with “KB.” Target Culpepper told
‘“KB" that he received his phone number ffom target Matthew Powell Fletcher.
(On June 10, 2016, “KB” told target Thaddeus Julian Culpepper that “he wasn’t there but
‘ihatever you need me to do Ill doi.” Target Culpepper replied “so you weren't there but you
know what's going on?”
On June 10, 2016, target Thaddeus Julian Culpepper told “KB” to call him when he (°KE")
rotumed to California.
(On June 22, 2016, target Thaddeus Julian Culpepper called “KB”. “KB” told Target Culpepper
"'ll do whatever...but you know what, I'm gonna need a few doliar...maybe later down the
line.” Target Culpepper responded “of course, or course.”
On June 28, 2016, target Thaddeus Julian Culpepper met with “KB” at a restaurant in Los
‘Angeles. Target Culpepper offered to draft a declaration for “KB” to sign and °KB” agreed. 33. On June 28, 2016, target Thaddeus Julian Culpepper met with Marion Hugh “Suge” Knight in a
interview room at the Men's Central Jail in Los Angeles. Target Culpepper told Knight that
“SKB” was willing to testify that he saw guns atthe murder scene.
34. On June 29, 2016, “KB” met with target Thaddeus Julian Culpepper in Encino California, Target
Culpepper told “KB” that he intended to prepare declaration for “KB” to sign. In addition, he
‘wanted "KB" to watch the surveillance video from the murder. Target Culpepper provided “KB”
‘with a handwritten note containing a Los Angeles address; he told “KB” to “tick that away.”
35. On June 29, 2016, target Thaddeus Julian Culpepper met with Marion Hugh “Suge” Knight in a
interview room at the Men’s Central Jail in Los Angeles. Target Culpepper and Knight agreed to
use “KB” as a witness but to withhold his identity until the commencement of the tral
36. On June 29, 2016, during the same meeting at Men's Central Jil, Marion Hugh “Suge” Knight
asked target Thaddeus Julian Culpepper if “KB” was in custody atthe time of the murder, Target
(Culpepper responded that he had already checked and that he (KB) was notin custody.
37. On August 21, 2016, target Matthew Powell Fletcher met with Marion Hugh “Suge” Knight ina
interview room at the Men’s Central Jail in Los Angeles. Target Fletcher told Knight that witness
“Marvin Kincy had to be paid for his testimony: Knight agreed.
38. On September 16, 2016, target Matthew Powell Fletcher met with Marion Hugh “Suge” Knight
lerview room atthe Men's Central Jilin Los Angeles. Target Fletcher told Knight thatthe
tim in the attempted murder, Cle “Bone” Sloan, needed to be paid money for his
testimony.” And Knight agreed,
couNT3
Fora further and separate cause of action, being a different offense of the same class of crimes and offenses as
the charge set forth inthe aforestated Count hereof, the said MATTHEW POWELL FLETCHER,
‘THADDEUS JULIAN CULPEPPER AND OTHER UNINDICTED CO-CONSPIRATORS are accused by
the Grand Jury ofthe County of Los Angeles, State of California, by this Indictment, of the crime of
‘CONSPIRACY TO COMMIT AN ACT INJURIOUS TO PUBLIG, in violation of Penal Code Section
1182(a)(5), « Felony, committed prior to the finding ofthis Indictment, and as follows:
(On and between January 29, 2015 and September 16, 2016 inthe County of Los Angeles the said MATTHEW
POWELL FLETCHER, THADDEUS JULIAN CULPEPPER did unlawflly conspire together and with
‘another person and persons whose identity is unknown to commit and act injurious o the public health,
public morals, and pervert and obstruct justice, and the due administration of laws; that pursuant to and forthe
‘Purpose of carrying out the objectives and purposes of the aforesaid conspiracy the said defendants committed
‘the following overt act and acs at and in the Canty of Los Angeles
OVERT ACTS
1. On January 29, 2015, at approximately 6:03pm., afew hours after the murder of Terry Carter and
the attempted murder of Cle “Bone” Sloan, Mark Blankenship spoke with Marion “Suge” knight
‘on the phone
2. On January 29, 2015, at approximately 8:15pm, a few hours after the murder of Terry Carter and
the attempted murder of Cle “Bone” Sloan, Mark Blankenship sent a text message to Toilin
Kelly stating “ell Suge I have spoken to Reggie and have him ready and in check if we need
him” 20.
21
2,
23
26
On January 29, 2015, at approximately 10:18 pim., Mark Blankenship sent a text message to
“Johnny” stating that he was going to meet with “Suge” and pet his side of the story
On January 30, 2015, at approximately 2:38 a.m., Mark Blankenship send a text to Reggie
‘Beamon asking him to meet at 11:30 azn
(On January 30, 2015, at approximately noon, Mark Blankenship sent a text to Tolin Kelly
stating “I'm driving with Reggie. HE SAW EVERYTHING AND CAN EXONERATE SUGE”.
On February 1, 2015, at approximately 1:20 p.m. Mark Blankenship sent a text to Reggie
‘Beamon asking “can you talk?”
(On February 1, 2015, at approximately 1:30 p.m, Mark Blankenship sent a text to Reggie
‘Beamon identifying the eyewitnesses to the murder of Terry Carter: “Marvin McKeenzie- took.
video that went to TMZ, Dwayne Johnson-Knob, Jimmy-possible attacker, Tery.”
On February 3,2015, at approximately 12:30p.m., Mark Blankenship sent a text to Toilin Kelly
concerning eyewitness Dwayne “Knob” Johnson. ‘The messoge read “I am seeing later today for
“other” reasons but we need 1 get his testimony in a tractor bear, asap.”
On February 16, 2015, at approximately 1:44 pm., Mark Blankenship sent a text to Reggie
‘Beamon stating “please remember you are my highest priority and that | value and appreciate
you"
(On February 16, 2015, at approximately 1:47 p.m., Reggie Beamon sent Mark Blankenship text
stating “I shld be. Show it. 'm from Missouri the show me state. Reg.”
On February 17, 2015, at approximately 3:41 p.m., Mark Blankenship sent Reggie Beamon a
‘MoneyGram in the amount of $250.00.
(On March 9, 2015, at approximately 3:21 p.m., Mark Blankenship sent a text message to target
‘Matthew Powell Fletcher stating "I know how to get Sloan.”
(On March 13, 2015, Marion “Suge” Knight spoke to Toilin Kelly onthe telephone. He told her
that there isa witness who will do whatever is needed and say that they saw a gun atthe murder
(On March 13, 2015, Toilin Kelly told Marion “Suge” Knight that Mark Blankenship put Reggie
Beamon on the payroll
(On March 13, 2015, Marion “Suge” Knight told an unidentified male that he hada “ttle project
for him coming up" and that “in a week or so, something would be coming your way.
‘On March 13, 2015, a approximately 11:00a.m., target Matthew Powell Fletcher send a text
‘message to Mark Blankenship stating “I have found a eyewitness..he says there were multiple
‘guns..trying to get him to go public..he's scare. .we are working him hard.”
(On March 16, 2015, Toilin Kelly told Marion Hugh “Suge” Knight that "Matt found other
“witnesses” and that “Matt put some bread out there” to get witnesses to “come around.
(On March 16, 2015, Mark Blankenship connected Marion Hugh “Suge” Knight to target
Matthew Powel Fletcher via a three-way telephone cal
‘On March 16, 2015, Matthew Powell Fletcher told Marion Hugh “Suge” Knight that witness
Marvin Kiney would say that there were guns atthe murder scene and they would give Marvin,
‘money for hs testimony.
‘On March 16,2015, Mathew Powell Fleicher told Marion Hugh “Suge” Knight that 20-25,
‘thousand dollars was afar investment to secure his freedom.
On May 9, 2016, Marion Hugh “Suge” Knight had a conversation with a Los Angeles County
Sheriff's Department informant named “KB.”
(On May 9, 2016, after “KB” implied that he could assist in Marion Hugh “Suge” Knight's
defense, Knight said “I'm gonna fuck with you.”
(On May 10, 2016, target Matthew Powell Fietcher called “KB.”
(On May 10, 2016, target Matthew Powell Fletcher told “KB” thatthe witnesses in Marion Hugh
“Suge” Knight's murder case needed to be pad for their testimony.
(On May 10, 2016, target Matthew Powell Fletcher told “KB” that he would discuss with Marion
Hugh “Suge” Knight possibly using “KB” as a witness inthe murder case.
On or between May 10, 2016, and May 18, 2016, target Matthew Powell Fletcher provided
“KB's phone number to target Thaddeus Julian Culpepper. 27. On May 18,2016, target Thaddeus Julian Culpepper called “KB” and Culpepper agreed that
“KB” could call hmm back.
28. On June 10,2016, target Thaddeus Julian Culpepper spoke wit: “KB.” Target Culpepper told
“°KB" that he received his phone number from target Matthew Powel Fletcher.
29. On June 10, 2016, *KB” told target Thaddeus Julian Culpepper that “he wasn’t there but
‘whatever you need me to do I'l do it.” Target Culpepper replied “so you weren't there but you
know what's going on?”
30. On June 10, 2016, target Thaddeus Julian Culpepper told “KB'"to call him when he (“KB”)
returned to California,
31. On June 22, 2016, target Thaddeus Julian Culpepper called “KB”. “KB” told Target Culpepper
“I'l do whatever...but you know what, I'm gonna need afew doiar...maybe later down the
line.” Target Culpepper responded “of course, or course.”
32. On June 28, 2016, target Thaddeus Julian Culpepper met with “KB” a a restaurant in Los
‘Angeles. Target Culpepper offered to draft a declaration for “KB” to sign and “KB” agreed.
33. On June 28, 2016, target Thaddeus Julian Culpepper met with Marion Hugh “Suge” Knight in a
{interview room atthe Men's Central Jilin Los Angeles. Target Culpepper told Knight that
“SKB” was willing to testify that he saw guns atthe murder seen,
34. On June 29, 2016, “KB” met with target Thaddeus Julian Culpepper in Encino California. Target
Culpepper told “KB” that he intended to prepare a declaration for “KB” to sign. In addition, he
‘wanted “KB” to watch the surveillance video from the murder. Target Culpepper provided "KB"
with a handwritten note containing a Los Angeles address; he tcld "KB" to “tuck that away.”
35. On June 29, 2016, target Thaddeus Julian Culpepper met with Marion Hugh “Suge” Knight in a
interview room at the Men's Central Jilin Los Angeles. Target Culpepper and Kaight agreed to
use "KB" as a witness but to withhold his identity until the commencement ofthe trial
36. On June 29, 2016, during the same meeting at Men's Central Jil, Marion Hugh “Suge” Knight
asked target Thaddeus Julian Culpepper if KB” was in custody atthe time of the murder. Target
Culpepper responded that he had already checked and that he (KB) was notin custody.
37. On August 21, 2016, target Matthew Powell Fletcher met with Marion Hugh “Suge” Kt
interview room at the Men's Central Jilin Los Angeles. Target Fletcher tld Ki
Marvin Kiney had tobe paid for his testimony; Knight agreed
38. On September 16,2016, target Matthew Powell Fleicher met with Marion Hugh “Suge” Knight
terview room a the Men's Central Jail in Los Angeles. Target Fletcher told Kaight that the
ing victim inthe attempted murder, Cle “Bone” Sloan, needed tobe paid money for his
testimony.” And Knight agreed.
count 4
For further and separate cause of action, being a different offense ofthe same class of crimes and offenses as
the charge set forth in the aforestated Count hereof, the said MATTHEW POWELL FLETCHER AND
‘THADDEUS JULIAN CULPEPPER are accused by the Grand Jury ofthe County of Los Angeles, State of
California, by this Indictment, ofthe crime of ACCESSORY AFTER THE FACT-KNOWLEDGE OF
PERSON, in violation of Penal Code Section 32, « Felony, committed prior tthe finding of th
‘and as follows:
‘On or between March 9, 2015 and September 16,2016, inthe County of Los Angeles, the said MATTHEW
POWELL FLETCHER and THADDEUS JULIAN CULPEPPER did unlawfully, having knowledge that
Marion Hugh “Suge” Kaight was convicted of the crime of MURDER/MANSLAUGHTER , a felonies, in
violation of Sections 187/192 of the Penal Code of the State of California, did attempt to harbor, conceal, and
aid said Marion Hugh “Suge” Knight, with the intent that he/she might avoid and escape from arrest, ial,
‘conviction, and punishment for said felonies. counrs
Fora further and separate cause of action, being a different offense of the same class of erimes and offenses as
the charge set forth in the aforestated Count hereof, the said THADDEUS JULIAN CULPEPPER AND
OTHER UNINDICTED CO-CONSPIRATORS are accused by the Grand Jury of the County of Los
Angeles, State of California, by this Indictment, ofthe crime of CONSPIRACY TO COMMIT A CRIME, in
violation of Penal Code Section 182(a)(1), 2 Felony, committe prior othe finding of this Indictment, and as
follows:
(On or between June 3, 2016 thru February 15, 2017, in the County of Los Angeles, the ssid THADDEUS
JULIAN CULPEPPER AND OTHER UNINDICTED CO-CONSPIRATORS cid unlawfully conspire
together and with another person and persons whose identity is unknown to commit the erime of
DISOBEYING COURT ORDER, in violation of Section 166(a)(4) ofthe Penal Code, a felony; that pursuant
‘to and for the purpose of carrying out the objectives and purposes of the aforesaid conspiracy, the said
‘defendant(s) committed the following overt act and acts at and inthe County of Los Angeles:
OVERT ACTS
1. On June 3, 2016, target Thaddeus Julian Culpepper facilitated a three-way telephone call
between Marion Hugh “Suge” Knight, Tolin Kelly and other unidentified individuals, indirect
violation ofa January 29, 2016 court order and September 1, 2016 court order restricting
Knight's phone privileges and specifically prohibiting “hree-way calls"
2. On September 21, 2016, target Thaddeus Julian Culpepper facilitated a three-way telephone
call between Marion Hugh “Suge” Knight, Toilin Kelly and other unidentified individuals, in
iret violation of a January 29, 2016 court order and September 1, 2016 court order restricting
Knight's phone privileges.
3. OnNovember 4, 2016, target Thaddeus Julian Culpepper facilitated a three-way telephone call
between Marion Hugh “Suge: Knight, Toilin Kelly and other unidentified individuals, in direet
violation ofa January 29, 2016 court order and September 1, 2016 court order restricting
Knights phone privileges.
4, On February 15, 2017, target Thaddeus Julian Culpepper facilitated a Three-way telephone call
bbetween Marion Hugh “Suge” Knight, Tolin Kelly and other unidentified individuals, indirect
violation of a January 29, 2016 court order and September 1, 2016 cour restricting Knight's
phone privileges.
COUNT 6
For a further and separate cause of action, being 2 different offense ofthe same class of crimes and offenses as
the charg set forth in the aforestated Count hereof, the sid THADDEUS JULIAN CULPEPPER AND.
OTHER UNINDICTED CO-CONSPIRATORS are accused by the Grand Jury ofthe County of Los
‘Angeles, tate of California, by this Indictment, ofthe crime of CONSPIRACY TO COMMIT AN ACT
INSURIOUS TO PUBLIC, in violation of Penal Code Section 182(a)5), a Felony, commited prior to the
finding ofthis Indictment, and as follows:
(On and between June 3, 2016 thru February 15,2017 in the County of Los Angeles, the said THADDEUS
JULIAN CULPEPPER AND OTHER UNINDICTED CO-CONSPIRATORS cid unlawfully conspire
{together and with another person and persons whose identity is unknown to commit and act injurious tothe
public health, to public morals, and pervert and obstruct justice, and the due administration of laws; that
‘pursuant to and for the purpose of carrying out the objectives and purposes of the aforesaid conspiracy the sa
‘defendants committe the following overt act and acts at and in the County of Los Angeles: ‘OVERT ACTS
1. On June 3, 2016, target Thaddeus Julian Culpepper facilitated a three-way telephone call
‘between Marion Hugh “Suge” Knight, Toilin Kelly and other unidentified individuals, indirect
violation of a January 28, 2016 court order and September 1, 2016 court order restricting
Knight's phone privileges and specifically prohibiting “three-way calls”.
2. On Seplember 21, 2016, target Thaddeus Julian Culpepper facilitated a three-way telephone
call between Marion Hugh “Suge” Knight, Toilin Kelly and other unidentified individuals, in
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