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FILED IN OFFICE L
VOlA
GARDNER CLERK
OF
CIRCUIT COURT ORANGE
CO
FL
THE
SUPREME COURT
OF FLORIDA
CASE NUMBER SC09-1910 STATE
OF
FLORIDAOrange
County
Case No.:
2010
C
F'":J
lo'lO
.
.
PlaintiffOSP Case No.:2010-0091-TPA .
D\\I
;';>0
VS.
Count
1:
ORGANIZED FRAUDJAMES.i\. GREER,F.S.
S17,f)34
First
"Qegree
Felony "\Defendant.
I.
Counts
2,3,
5: .GRAND·
"
THEFT
IN
THE
----------------~
THIRD
DEGREE
F.S. S12.014(2)(c)3
Third
Degree Felony. Count 4: GRAND
THEFT
IN
THKSECOND
DEGREEF.S. SI2.014(2)(b)1Second Degree Felony
Count
6: MONEYLAUNDERINGF.S.896.101First Degree FelonyIN
THE
NAME AND BY
THE
AUTHORITY
OFTHE
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 JudicialCircuits
of
Florida,
to~wit:
Leon, Orange, Hillsborough, and' Seminole Counties, DefendantJAMES A.
GREER
and others engaged in a systematic. ongoing
coUrse
of
conduct with theintent to defraud or with the intent to obtain property from
·one
or more persons by false orfraudulent 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 obtainfunds from the RPOF by defrauding and thereby inducing the
RPOFlopay
VSLLC and thenredirecting 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 anaggregate value
of
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, dopresent and charge that
on
or' about July 23, 2009, in the Second, Ninth, and Eighteerith JudicialCircuits
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,theproperty
of
the Republican Party
of
Florida, the value ofsaidprQpertybeing $10,000 or more butless 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 todefendant's
own
use or
to
the use
of
a person
not
entitled thereto, in violation
of
Florida Statute812.014(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 EighteenthJudicial 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 morebut 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 todefendant's own use or
to
the use
oia
person not entitled thereto,
in
violation
of
Florida Statute812.014(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, dopresent and charge that on or about September
10,2009,
in the Second, Ninth, and EighteenthJudicial 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 morebut less
than
$100,000, with
the
intent
to
temporarily orpenp.anently deprive the RepublicanParty
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 Statute812.014(2)(b)1 and 777.011.
,./.t'
"
//
Initials
of
the Grand Jury
ForepersonF'-~_"""
Page 2
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 EighteenthJudicial Circuits -
of
Florida, to-wit: Leon, Orange, and Seminole Counties, Defendant JAMESA
•.
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 morebut 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 _herefrom, or to appropriate the property todefendant's
O\\<TI
use or to the use
of
a person not entitled thereto, in viblationof Florida Statute812.014(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 andincluding on or about January 2010, in the Second, Ninth,Thirteenth, and Eighteenth JudicialCircuits
of
Florida, to-wit: Leon, Orange, Hillsborough,and Seminole Counties, Defendant
JAMES
A. GREER, while knowing that the property involved in a fmancial transactionrepresented the proceeds
of
some form
of
unlawful activity, did conduct or attempt
to
conductsuch 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 fraudand grand theft with the intent to promote the carrying on
of
said specified unlawful activity orknowing that the transaction was designed in whole or part to conceal or disguise the nature, thelocation, 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 $100,000.00in atwelve month period, all in violation
of
Section 896.l0l(3)(a) and (5)(c) and 777.011, FloridaStatutes. .AND ALL
OF
THE ABOVE OFFENSES OCCURRED IN
TWO
OR MORE JUDICIALCIRCUITS
AS
PART OF ARELATED TRANSACTION OR WERE COMMITTED INCONNECTION WITH AN ORGANIZED CRIMINAL CONSPIRACY AFFECTING TWO ORMORE JUDICIAL CIRCUITS
OF
THE
STATE
OF
FLORIDA.
~
ineteenth Statewide Grand Jury
of
Florida
~I
,,,lit>
DatePage 3
---_._._
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