ELECTRONICALLY FILED

COURT OF COMMON PLEAS

Monday, October 7, 2019 3:03:08 PM
CASE NUMBER: 2019 CR 03194 Docket ID: 33893602
MIKE FOLEY
CLERK OF COURTS MONTGOMERY COUNTY OHIO

2019CRA4952 DAYTON MUNICIPAL COURT

THE STATE OF OHIO, MONTGOMERY COUNTY

2019 CR 03194
THE COURT OF COMMON PLEAS

(September Term in the year Two Thousand and Nineteen)

MONTGOMERY COUNTY, SS.

THE GRAND JURORS of the County of Montgomery, in the name, and by the
authority of the State of Ohio, upon their oaths do find and present that: RAYMOND
ANDREW WALTERS, on or about AUGUST 26, 2019 in the County of Montgomery,
aforesaid, and State of Ohio, did knowingly cause or attempt to cause physical harm to
another, to-wit: LLOYD WALTERS, by means of a deadly weapon or dangerous ordnance,
to wit: knife and/or knives, contrary to the form of the statute (in violation of Section
2903.11(A)(2) of the Ohio Revised Code) in such case made and provided, and against the
peace and dignity of the State of Ohio.

SECOND COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did
knowingly cause serious physical harm to another, to-wit: LLOYD WALTERS; contrary to
the form of the statute (in violation of Section 2903.11(A)(1) of the Ohio Revised Code) in
such case made and provided, and against the peace and dignity of the State of Ohio.

THIRD COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, with
purpose to deprive the owner, to-wit: LLOYD WALTERS of property or services, did
knowingly and without the consent of the owner or person authorized to give consent, obtain
or exert control over said owner's property or services, to-wit: a 1999 CHEVROLET PICKUP
TRUCK, being a motor vehicle; contrary to the form of the statute (in violation of Section
2913.02(A)(1) of the Ohio Revised Code) in such case made and provided, and against the
peace and dignity of the State of Ohio.

FOURTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, with
purpose to deprive the owner, to-wit: LLOYD WALTERS of property or services, did
knowingly and by threat, obtain or exert control over said owner’s property or services,
to-wit: a 1999 CHEVROLET PICKUP TRUCK, being a motor vehicle; contrary to the form
of the statute (in violation of Section 2913.02(A)(4) of the Ohio Revised Code) in such
case made and provided, and against the peace and dignity of the State of Ohio.

FIFTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, with
purpose to deprive the owner, to-wit: OFFICER TODD AND/OR RIVERSIDE POLICE
DEPARTMENT of property or services, did knowingly and without the consent of the owner
or person authorized to give consent, obtain or exert control over said owner's property or
services, to-wit: a 2014 FORD EXPLORER POLICE CRUISER, being a motor vehicle;
contrary to the form of the statute (in violation of Section 2913.02(A)(1) of the Ohio Revised
Code) in such case made and provided, and against the peace and dignity of the State of
Ohio.

SIXTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, in
attempting or committing a theft offense, or in fleeing immediately after the attempt or
offense, did inflict, attempt to inflict or threaten to inflict physical harm on another, contrary
to the form of the statute (in violation of Section 2911.02(A)(2) of the Ohio Revised Code) in
such case made and provided, and against the peace and dignity of the State of Ohio.

SEVENTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did
knowingly cause serious physical harm to property, to-wit: CITY OF RIVERSIDE POLICE
CRUISER that is owned, leased, or controlled by a governmental entity, and the value of
said property and/or the amount of physical harm involved is Seven Thousand Five Hundred
Dollars ($7500.00) or more but less than $150,000; contrary to the form of the statute (in
violation of Section 2909.05(B)(2) of the Ohio Revised Code) in such case made and
provided, and against the peace and dignity of the State of Ohio.

EIGHTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did operate
a motor vehicle so as willfully to elude or flee a police officer after receiving a visible or
audible signal from a police officer to bring the offender’s motor vehicle to a stop and the
operation of the motor vehicle by the offender was a proximate cause of serious physical
harm to persons or property; contrary to the form of the statute (in violation of Section
2921.331(B) and 2921.331(C)(5)(a)(i) of the Ohio Revised Code) in such case made and
provided, and against the peace and dignity of the State of Ohio.
NINTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did operate
a motor vehicle so as willfully to elude or flee a police officer after receiving a visible or
audible signal from a police officer to bring the offender’s motor vehicle to a stop and the
operation of the motor vehicle by the offender caused a substantial risk of serious physical
harm to persons or property; contrary to the form of the statute (in violation of Section
2921.331(B) and 2921.331(C)(5)(a)(ii) of the Ohio Revised Code) in such case made and
provided, and against the peace and dignity of the State of Ohio.

TENTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did operate
a motor vehicle so as willfully to elude or flee a police officer after receiving a visible or
audible signal from a police officer to bring his motor vehicle to a stop and in committing said
offense, the offender was fleeing immediately after the commission of a felony offense;
contrary to the form of the statute (in violation of Section 2921.331(B) and 2921.331(C)(4)
of the Ohio Revised Code) in such case made and provided, and against the peace and
dignity of the State of Ohio.

ELEVENTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did cause
the death of another, to-wit: P.J., as a proximate result of the offender’s committing or
attempting to commit an offense of violence, to-wit: ROBBERY, in violation of 2911.02(A)(2),
a felony of the SECOND DEGREE, and that said offense is not a violation of either Section
2903.03 or 2903.04 of the Revised Code; contrary to the form of the statute (in violation of
Section 2903.02(B) of the Ohio Revised Code) in such case made and provided, and against
the peace and dignity of the State of Ohio.

TWELFTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did cause
the death of another, to-wit: E.M., as a proximate result of the offender’s committing or
attempting to commit an offense of violence, to-wit: ROBBERY, in violation of 2911.02(A)(2),
a felony of the SECOND DEGREE, and that said offense is not a violation of either Section
2903.03 or 2903.04 of the Revised Code; contrary to the form of the statute (in violation of
Section 2903.02(B) of the Ohio Revised Code) in such case made and provided, and against
the peace and dignity of the State of Ohio.

THIRTEENTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did as a
proximate result of committing or attempting to commit a felony, to-wit: FAILURE TO
COMPLY WITH ORDER/SIGNAL OF POLICE OFFICER, cause the death of another, to-
wit: P.J., then and there being a living human being; contrary to the form of the statute (in
violation of Section 2903.04(A) of the Ohio Revised Code) in such case made and provided,
and against the peace and dignity of the State of Ohio.

FOURTEENTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did as a
proximate result of committing or attempting to commit a felony, to-wit: FAILURE TO
COMPLY WITH ORDER/SIGNAL OF POLICE OFFICER, cause the death of another, to-
wit: E.M., then and there being a living human being; contrary to the form of the statute (in
violation of Section 2903.04(A) of the Ohio Revised Code) in such case made and provided,
and against the peace and dignity of the State of Ohio.

FIFTEENTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did while
operating or participating in the operation of a motor vehicle, motorcycle, snowmobile,
locomotive, watercraft, or aircraft, recklessly cause serious physical harm to another
person, or another’s unborn, to-wit: G.J.; contrary to the form of the statute (in violation of
Section 2903.08(A)(2)(b) of the Ohio Revised Code) in such case made and provided,
and against the peace and dignity of the State of Ohio.

SIXTEENTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did while
operating or participating in the operation of a motor vehicle, motorcycle, snowmobile,
locomotive, watercraft, or aircraft, recklessly cause serious physical harm to another
person, or another’s unborn, to-wit: B.J.; contrary to the form of the statute (in violation of
Section 2903.08(A)(2)(b) of the Ohio Revised Code) in such case made and provided,
and against the peace and dignity of the State of Ohio.

SEVENTEENTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, did while
operating or participating in the operation of a motor vehicle, motorcycle, snowmobile,
locomotive, watercraft, or aircraft, recklessly cause serious physical harm to another
person, or another’s unborn, to-wit: GAIL CRUMP; contrary to the form of the statute (in
violation of Section 2903.08(A)(2)(b) of the Ohio Revised Code) in such case made and
provided, and against the peace and dignity of the State of Ohio.

EIGHTEENTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, while
operating or participating in the operation of a motor vehicle, motorcycle, snowmobile,
locomotive, watercraft, or aircraft, as a proximate result of committing a violation of
division (A) of Section 4511.19 of the Revised Code or of a substantially equivalent
municipal ordinance, did cause serious physical harm to another person or another’s
unborn, to-wit: G.J.; contrary to the form of the statute (in violation of Section
2903.08(A)(1)(a) of the Ohio Revised Code) in such case made and provided, and against
the peace and dignity of the State of Ohio.

NINETEENTH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, while
operating or participating in the operation of a motor vehicle, motorcycle, snowmobile,
locomotive, watercraft, or aircraft, as a proximate result of committing a violation of
division (A) of Section 4511.19 of the Revised Code or of a substantially equivalent
municipal ordinance, did cause serious physical harm to another person or another’s
unborn, to-wit: B.J.; contrary to the form of the statute (in violation of Section
2903.08(A)(1)(a) of the Ohio Revised Code) in such case made and provided, and against
the peace and dignity of the State of Ohio.

TWENTIETH COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, while
operating or participating in the operation of a motor vehicle, motorcycle, snowmobile,
locomotive, watercraft, or aircraft, as a proximate result of committing a violation of
division (A) of Section 4511.19 of the Revised Code or of a substantially equivalent
municipal ordinance, did cause serious physical harm to another person or another’s
unborn, to-wit: GAIL CRUMP; contrary to the form of the statute (in violation of Section
2903.08(A)(1)(a) of the Ohio Revised Code) in such case made and provided, and against
the peace and dignity of the State of Ohio.

TWENTY-FIRST COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, while
operating or participating in the operation of a motor vehicle, motorcycle, snowmobile,
locomotive, watercraft or aircraft, did cause the death of another or the unlawful
termination of another’s pregnancy as the proximate result of committing a violation of
division (A) of Section 4511.19 of the Revised Code or of a substantially equivalent
municipal ordinance and was, at the time of the offense, driving under a suspension or
cancellation imposed under Chapter 4510. or any other provision of the Revised Code or
was operating a motor vehicle or motorcycle, did not have a valid driver’s license,
commercial driver’s license, temporary instruction permit, probationary license, or
nonresident operating privilege, and was not eligible for renewal of the offender’s driver’s
license or commercial driver’s license without examination under Section 4507.10 of the
Revised Code; contrary to the form of the statute (in violation of Sections
2903.06(A)(1)(a)/(B)(2)(b)(i) of the Ohio Revised Code) in such case made and provided,
and against the peace and dignity of the State of Ohio.

TWENTY-SECOND COUNT:

AND the grand jurors of this County, in the name and by the authority of the State of Ohio,
upon their oaths, do find and present that: RAYMOND ANDREW WALTERS on or about
AUGUST 26, 2019 in the County of Montgomery, aforesaid, and State of Ohio, while
operating or participating in the operation of a motor vehicle, motorcycle, snowmobile,
locomotive, watercraft or aircraft, did cause the death of another or the unlawful
termination of another’s pregnancy as the proximate result of committing a violation of
division (A) of Section 4511.19 of the Revised Code or of a substantially equivalent
municipal ordinance and was, at the time of the offense, driving under a suspension or
cancellation imposed under Chapter 4510. or any other provision of the Revised Code or
was operating a motor vehicle or motorcycle, did not have a valid driver’s license,
commercial driver’s license, temporary instruction permit, probationary license, or
nonresident operating privilege, and was not eligible for renewal of the offender’s driver’s
license or commercial driver’s license without examination under Section 4507.10 of the
Revised Code; contrary to the form of the statute (in violation of Sections
2903.06(A)(1)(a)/(B)(2)(b)(i) of the Ohio Revised Code) in such case made and provided,
and against the peace and dignity of the State of Ohio.

Respectfully submitted,

MATHIAS H. HECK, JR.,

Prosecuting Attorney
Montgomery County, Ohio

By Daniel J. Brandt
Assistant Prosecuting Attorney
Supreme Court # 0068650

By Erin Leigh Claypoole

Assistant Prosecuting Attorney
Supreme Court # 0068154
 INDICTMENT FOR:
CT. 1 - FELONIOUS ASSAULT (deadly weapon) - F2
CT. 2 - FELONIOUS ASSAULT (serious physical harm) - F2
CT. 3 - GRAND THEFT (MOTOR VEHICLE) - F4
CT. 4 - GRAND THEFT (MOTOR VEHICLE) - F4
CT. 5 - GRAND THEFT (MOTOR VEHICLE) - F4
CT. 6 - ROBBERY (INFLICT, ATTEMPT TO INFLICT OR THREATEN TO INFLICT
PHYSICAL HARM) - F2
CT. 7 - VANDALISM (government property over $7500 but less than $150,000) - F4
CT. 8 - FAILURE TO COMPLY W/ORDER OR SIGNAL OF POLICE OFFICER
(Serious Physical Harm) - F3
CT. 9 - FAILURE TO COMPLY W/ORDER OR SIGNAL OF POLICE OFFICER
(Substantial Risk of Serious Physical Harm) - F3
CT. 10 - FAILURE TO COMPLY W/ORDER OR SIGNAL OF POLICE OFFICER
(fleeing felony) - F4
CT. 11 - MURDER (proximate result) - UNCLASSIFIED FELONY
CT. 12 - MURDER (proximate result) - UNCLASSIFIED FELONY
CT. 13 - INVOLUNTARY MANSLAUGHTER (felony) - F1
CT. 14 - INVOLUNTARY MANSLAUGHTER (felony) - F1
CT. 15 - VEHICULAR ASSAULT - F4
CT. 16 - VEHICULAR ASSAULT - F4
CT. 17 - VEHICULAR ASSAULT - F4
CT. 18 - AGGRAVATED VEHICULAR ASSAULT - F3
CT. 19 - AGGRAVATED VEHICULAR ASSAULT - F3
CT. 20 - AGGRAVATED VEHICULAR ASSAULT - F3
CT. 21 - AGGRAVATED VEHICULAR HOMICIDE (no drivers license) - F1
CT. 22 - AGGRAVATED VEHICULAR HOMICIDE (no drivers license) - F1

A TRUE BILL

______________________________
Foreman of the Grand Jury

“NOTICE: UNDER SECTION 2923.13 OF THE OHIO REVISED CODE, NO PERSON

WHO IS CHARGED BY THIS INDICTMENT/INFORMATION OR CONVICTED OF THE
CHARGE(S) IN THIS INDICTMENT/INFORMATION MAY KNOWINGLY ACQUIRE,
HAVE, CARRY OR USE ANY FIREARM OR DANGEROUS ORDNANCE.”