Indictment CR 635246 Zienup

Cuyahoga County Court of Common Pleas
Criminal Court Division
State of Ohio, A True Bill Indictment For

Plaintiff Engaging In A Pattern Of Corrupt Activity - F1
VS. §2923.32(A)(1)
Zienup Sbeih-Maddox Kirsten M. Laurie
Kimberly St. John-
Stevenson,
Defendants 20 Additional Count(s)
Dates of Offense (on or about) The Term Of Case Number

08/01/2016 to 07/30/2018 September of 2018 635246-18-CR
The State of Ohio,

Cuyahoga County } SS.
Count 1 Engaging In A Pattern Of Corrupt Activity - F1

§2923.32(A)(1)
Defendants Zienup Sbeih-Maddox, Kimberly St. John-Stevenson
Date of Offense On or about August 1, 2016 to July 30, 2018
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
while employed by, or associated with, any enterprise did conduct or participate in, directly or
indirectly, the affairs of the enterprise through a pattern of corrupt activity or the collection of an
unlawful debt and at least one of the incidents of corrupt activity was a felony of the first, second, or
third degree, aggravated murder, or murder, or at least one of the incidents was a felony under the
law of this state that was committed prior to July 1, 1996, and constituted a felony of the first,
second, or third degree, aggravated murder, or murder or was committed on or after July 1, 1996, or
one of the incidents of corrupt activity was a felony under the law of the United States or of another
state that, if committed in this state on or after July 1, 1996, would have constituted a felony of the
first, second, or third degree, aggravated murder, or murder under the law of this state.
THE ENTERPRISE
On or between the 1st day of August, 2016 and the 30 th day of July, 2018, in the County of
Cuyahoga, State of Ohio, or by some manner enumerated in Section 2901.12 of the Revised
Code whereby proper venue is placed in Cuyahoga County, DEFENDANTS, were associated
with an Enterprise, as defined in Section 2923.31(C) of the Revised Code.
This Enterprise is an “illicit enterprise” under O.R.C. 2932.22, whether or not this Enterprise
existed separate and apart from the pattern of corrupt activity described in this Indictment.
<GRANDJURORSIGNATURE> <PROSECUTORSIGNATURE>
Foreperson of the Grand Jury Prosecuting Attorney
Page 1 of 14
Cuyahoga County Court of Common Pleas A True Bill Indictment
This Enterprise functioned as a continuing unit by engaging in the diverse forms of illegal
activities, as stated in this Indictment. In so doing, the DEFENDANTS NAMED BELOW
are persons associated with the Enterprise who participated in and/or managed the affairs of
the Enterprise, as explained in this Indictment. As such, these persons provided continuity
and structure to the Enterprise in order to accomplish its illegal purposes – the pattern of
corrupt activity, as described below.
Beginning in August 2016, Zienup Sbeih-Maddox and her partner, Kimberly St.
John-Stevenson, created and operated a public Facebook page called “Zee’s
Place” that offered “too good to be true” deals on items such as diapers, toys, car
seats, and trips to Disney World. The page was targeted toward suburban moms
in search of bargains. Items were offered for sale on the Zee’s Place page;
individuals who wished to purchase an item communicated with Sbeih-Maddox
and/or St. John-Stevenson through Facebook Messenger and email to place their
orders; payment was made primarily via money orders, online payment apps, and
gift cards. Because of the bargain prices on the offered items, the community
grew by word of mouth; ultimately, at least 200 people made purchases from
Zee’s Place. Any new Zee’s Place customer received at least their first “bargain”
without any issue; however, upon ordering (and paying for) additional “bargains,”
Sbeih-Maddox and St. John-Stevenson failed to remit the purchased items,
instead offering delays and excuses and never returning the funds paid.
Sbeih-Maddox and St. John-Stevenson transferred proceeds of the orders back

and forth between multiple bank accounts to disguise the nature and origin of the
funds. As a result of this suspicious activity their accounts were closed by their
respective banks; at this point, Sbeih-Maddox and St. John-Stevenson recruited
Holly Freeman, Nicole Tesmer, and Lindsay Putnam to accept Zee’s Place
payments through their accounts and pass along the funds to Sbeih-Maddox and
St. John-Stevenson.
As word got around the Zee’s Place Facebook community that orders were going
unfulfilled and not refunded, Sbeih-Maddox erased all of her Facebook accounts.
A warrant was issued for Sbeih-Maddox’s arrest as a result of the Zee’s Place
transactions, as a result of which she fled to the western United States. While
Sbeih-Maddox was on the run, her sister, Kirsten Laurie, moved Zee’s Place
Page 2 of 14
proceeds through her (Laurie’s) bank account to Sbeih-Maddox.
The Enterprise’s illegal activities are further illustrated and explained in the charged predicate
acts in this Indictment.
This Enterprise and the Persons Associated with the Enterprise were joined in purpose over a
period of time, although their various roles were different in order to accomplish the main
purposes of the Enterprise. These activities occurred with the knowledge and/or support of
and/or were aided and abetted by each of the persons associated with the Enterprise.
The Enterprise in this matter consisted of: Zienup Sbeih-Maddox, Kimberly St. John-
Stevenson, Kirsten Laurie, Holly Freeman, Nicole Tesmer, Lindsey Putnam, the unregistered
internet business “Zee’s Place”, Ink Plus, LLC and others yet unknown, each of whom did
conduct or participate in, directly or indirectly, the affairs of said enterprise, to-wit: a group of
persons “associated in fact” for the purposes of engaging in Telecommunications Fraud,
Theft, and Money Laundering through a pattern of corrupt activity as defined in Section
2923.31(I)(2)(a) or (I)(2)(c) of the Revised Code. These Predicate Acts constitute the pattern
of corrupt activity as defined in Section 2923.31(E) of said enterprise, which include criminal
violations of the Ohio Revised Code TITLE 29 as alleged in the following COUNTS
THREE, FOUR, EIGHT, TEN, ELEVEN, and criminal violations of Ohio Revised Code
TITLE 13 as alleged in COUNTS FIVE through SEVEN, and TWELVE through
NINETEEN of the indictment, which are incorporated herein as if fully restated, as well as
other, related fraudulent acts.
Furthermore, pursuant to Section 2923.32(B)(1), at least one of the incidents of corrupt

activity, as defined in Section 2923.31(I)(2)(a) or (I)(2)(c) is a felony of the third degree or
higher (TELECOMMUNICATION FRAUD in COUNT THREE, THEFT in COUNT FOUR
and ALL COUNTS OF MONEY LAUNDERING) contrary to and in violation of Section
2923.32(A)(1) of the Ohio Revised Code, and thereby, this COUNT ONE, ENGAGING IN A
PATTERN OF CORRUPT ACTIVITY, constitutes a Felony of the First degree, contrary to
and in violation of the Ohio Revised Code, Title 29, in 2923.32 (A)(1) and against the peace
and dignity of the State of Ohio.
Forfeiture of Property - §2941.1417(A)
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of 2005 GMC Envoy, Ohio registration
HAA-6454, VIN: 1GKDT13S652311590 which is contraband and/or property derived from or
through the commission or facilitation of an offense, and/or is an instrumentality the offender(s) used
or intended to use in the commission or facilitation of a felony offense.
Page 3 of 14
the defendant(s) is/are the owner(s) and/or possessor(s) of All items seized within the areas described
to be searched during the execution of the 4 location search warrants in this case, including but not
limited to: Black iPhone 8 with T-Mobile Sim Card #8901260912758175725 and/or T-Mobile Sim
Card #8901260935781344569 and/or Vanilla Visa card #4847186165942729 and/or HP laptop
computer, partial serial #CNDS and/or Dell laptop computer and/or PayPal credit card scanner
and/or Apple iPhone 7Plus, model A1784, with no visible serial number and/or 11 Target gift cards
and/or 4 Panera gift cards and/or wallet with all items therein, which is contraband and/or property
derived from or through the commission or facilitation of an offense, and/or is an instrumentality the
offender(s) used or intended to use in the commission or facilitation of a felony offense.
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 2 Conspiracy - F2
§2923.01(A)(2)
Date of Offense On or about August 1, 2016 to July 30, 2018
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully,
with purpose to commit or to promote or facilitate the commission of Engaging in a Pattern of

Corrupt Activity in violation of O.R.C, 2923.32(A)(1) did, agree with another person or persons that
one or more of them will engage in conduct that facilitates the commission of Engaging in a Pattern
of Corrupt Activity in violation of O.R.C, 2923.32(A)(1), and in furtherance of the conspiracy did
undertake substantive overt acts, to wit: participating in a criminal enterprise described as follows.
Beginning in August 2016, Zienup Sbeih-Maddox and her partner, Kimberly St.
John-Stevenson, created and operated a public Facebook page called “Zee’s
Place” that offered “too good to be true” deals on items such as diapers, toys, car
seats, and trips to Disney World. The page was targeted toward suburban moms
in search of bargains. Items were offered for sale on the Zee’s Place page;
individuals who wished to purchase an item communicated with Sbeih-Maddox
and/or St. John-Stevenson through Facebook Messenger and email to place their
orders; payment was made primarily via money orders, online payment apps, and
gift cards. Because of the bargain prices on the offered items, the community
grew by word of mouth; ultimately, at least 200 people made purchases from
Zee’s Place. Any new Zee’s Place customer received at least their first “bargain”
without any issue; however, upon ordering (and paying for) additional “bargains,”
Sbeih-Maddox and St. John-Stevenson failed to remit the purchased items,
instead offering delays and excuses and never returning the funds paid.
Sbeih-Maddox and St. John-Stevenson transferred proceeds of the orders back
Page 4 of 14
and forth between multiple bank accounts to disguise the nature and origin of the
funds. As a result of this suspicious activity their accounts were closed by their
respective banks; at this point, Sbeih-Maddox and St. John-Stevenson recruited
Holly Freeman, Nicole Tesmer, and Lindsay Putnam to accept Zee’s Place
payments through their accounts and pass along the funds to Sbeih-Maddox and
St. John-Stevenson.
As word got around the Zee’s Place Facebook community that orders were going
unfulfilled and not refunded, Sbeih-Maddox erased all of her Facebook accounts.
A warrant was issued for Sbeih-Maddox’s arrest as a result of the Zee’s Place
transactions, as a result of which she fled to the western United States. While
Sbeih-Maddox was on the run, her sister, Kirsten Laurie, moved Zee’s Place
proceeds through her (Laurie’s) bank account to Sbeih-Maddox.
The Enterprise’s illegal activities are further illustrated and explained in the charged predicate
acts in this Indictment.
The Enterprise in this matter consisted of: Zienup Sbeih-Maddox, Kimberly St. John-
Stevenson, Kirsten Laurie, Holly Freeman, Nicole Tesmer, Lindsey Putnam, the unregistered
internet business “Zee’s Place”, Ink Plus, LLC and others yet unknown, each of whom did
conduct or participate in, directly or indirectly, the affairs of said enterprise, to-wit: a group of
persons “associated in fact” for the purposes of engaging in Telecommunications Fraud,
Theft, and Money Laundering through a pattern of corrupt activity as defined in Section
2923.31(I)(2)(a) or (I)(2)(c) of the Revised Code. These Predicate Acts constitute the pattern
of corrupt activity as defined in Section 2923.31(E) of said enterprise, which include criminal
violations of the Ohio Revised Code TITLE 29 as alleged in the following COUNTS
THREE, FOUR, EIGHT, TEN, ELEVEN, and criminal violations of Ohio Revised Code
TITLE 13 as alleged in COUNTS FIVE through SEVEN, and TWELVE through
NINETEEN of the indictment, which are incorporated herein as if fully restated, as well as
other, related fraudulent acts.
FURTHERMORE, and the object of the conspiracy was a felony of the first degree, to wit: Engaging
in a Pattern of Corrupt Activity, O.R.C, 2923.32(A) (1).

the defendant(s) is/are the owner(s) and/or possessor(s) of 2005 GMC Envoy, Ohio registration
HAA-6454, VIN: 1GKDT13S652311590 which is contraband and/or property derived from or
through the commission or facilitation of an offense, and/or is an instrumentality the offender(s) used
Page 5 of 14
or intended to use in the commission or facilitation of a felony offense.

the defendant(s) is/are the owner(s) and/or possessor(s) of All items seized within the areas described
to be searched during the execution of the 4 location search warrants in this case, including but not
limited to: Black iPhone 8 with T-Mobile Sim Card #8901260912758175725 and/or T-Mobile Sim
Card #8901260935781344569 and/or Vanilla Visa card #4847186165942729 and/or HP laptop
computer, partial serial #CNDS and/or Dell laptop computer and/or PayPal credit card scanner
and/or Apple iPhone 7Plus, model A1784, with no visible serial number and/or 11 Target gift cards
and/or 4 Panera gift cards and/or wallet with all items therein, which is contraband and/or property
derived from or through the commission or facilitation of an offense, and/or is an instrumentality the
offender(s) used or intended to use in the commission or facilitation of a felony offense.
Ohio.
Count 3 Telecommunications Fraud - F2

§2913.05(A)
Date of Offense On or about January 1, 2015 to November 1, 2017
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
FURTHERMORE, and the offender committed a violation of division (A) of Section 2913.05 of the
Revised Code and the violation occurred as part of a course of conduct involving other violations of
division (A) of Section 2913.05 of the Revised Code or violations of, attempts to violate,
conspiracies to violate, or complicity in violations of section 2913.02, 2913.04, 2913.11, 2913.21,
2913.31, 2913.42, 2913.43, or 2921.13 of the Revised Code and the value of the benefit obtained by
the offender or of the detriment to the victim of the fraud is one hundred fifty thousand dollars or
more but less than one million dollars.
Ohio.
Count 4 Aggravated Theft - F3

§2913.02(A)(3)
Date of Offense On or about January 1, 2015
Page 6 of 14
did with purpose to deprive the owner, the named 158 victims presented on the "CR 635249
Victims" list, attached to this indictment,, of money and/or gift cards loaded with funds or services,
knowingly obtain or exert control over either the property or services by deception and the property
or services stolen is valued at $150,000 or more and less than $750,000.
Ohio.
Count 5 Money Laundering - F3

§1315.55(A)(1)
Defendants Zienup Sbeih-Maddox
Date of Offense On or about August 31, 2016 to February 27, 2017
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.
(Zienup Sbeih-Maddox's Chase account ending in x 5871, received over $13,000.00 in electronic
transfers from Kimberly St. John-Stevenson and sent out approximately $5,000.00 in electronic
transfers to Kimberly St. John-Stevenson.)
Ohio.

§1315.55(A)(1)
Defendants Kimberly St. John-Stevenson
Date of Offense On or about September 20, 2016 to October 19, 2016
(Snapshot: Kimberly St. John-Stevenson's Chase account ending in x6288 received $11,883.08 in
deposits from Zienup Sbeih-Maddox AND victims of Zee's Place.)
Ohio.
Page 7 of 14

§1315.55(A)(1)
Defendants Zienup Sbeih-Maddox, Kirsten M. Laurie
Date of Offense On or about September 16, 2016 to April 27, 2017
(Chase account ending in x1637 received $7,363.74 electronically from Zienup Sbeih-Maddox via
Quickpay.)
Ohio.
Count 8 Tampering With Evidence - F3

§2921.12(A)(1)
Date of Offense On or about March 17, 2017 to May 31, 2017
did, knowing that an official proceeding or investigation was in progress, or was about to be or likely
to be instituted, alter, destroy, conceal, or remove any record, document, or thing, with purpose to
impair its value or availability as evidence in such proceeding or investigation.
(Facebook account deleted in this time period after victims began notifying police and investigators
began following up on screenshots)
Ohio.
Count 9 Receiving stolen property - F4

§2913.51(A)
Defendants Kirsten M. Laurie
Date of Offense On or about October 11, 2016 to April 27, 2017
did receive, retain, or dispose of money from commingled funds, the property of the named 158
victims presented on the "CR 635249 Victims" list, attached to this indictment., knowing or having
reasonable cause to believe that the property had been obtained through commission of a theft
offense and the value of the property involved was $7,500 or more and was less than $150,000.
(During the time period Kirsten Laurie received $10,043.73 in 68 electronic transfers and one case
deposit).
Page 8 of 14
Ohio.
Count 10 Obstructing Justice - F3

§2921.32(A)(2)
Date of Offense On or about December 15, 2017 to July 30, 2018
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, provide the other
person or child with money, transportation, a weapon, a disguise, or other means of avoiding
discovery or apprehension.
FURTHERMORE, and the crime committed by the person aided was aggravated murder, murder, or
a felony of the first or second degree or the act committed by the child aided would have been one of
those offenses if committed by an adult and the offender knew or had reason to believe that the crime
committed by the person aided was one of those offenses or that the act committed by the child aided
would have been one of those offenses if committed by an adult.
(From her Ink Plus, LLC Citizens Bank account ending in x6109, Kimberly St. John-Stevenson sent
money to her personal Citizens Bank account -to which Zienup Sbeih-Maddox had access and from
which she used$62,368.29 while she was traveling out west avoiding her arrest warrants.)
Ohio.
Count 11 Obstructing Justice - F3

§2921.32(A)(2)
Date of Offense On or about June 1, 2018
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, provide the other
person or child with money, transportation, a weapon, a disguise, or other means of avoiding
discovery or apprehension.
FURTHERMORE, and the crime committed by the person aided was aggravated murder, murder, or
a felony of the first or second degree or the act committed by the child aided would have been one of
those offenses if committed by an adult and the offender knew or had reason to believe that the crime
committed by the person aided was one of those offenses or that the act committed by the child aided
would have been one of those offenses if committed by an adult.
Page 9 of 14
(Kirsten Laurie makes six (6) separate funding transactions totaling $745.08 on to Kimberly St.
John-Stevenson's Green Dot card, account #x1035, which is used by both St. John-Stevenson and
Zienup Sbeih-Maddox while Sbeih-Maddox is a fugitive from justice).
Ohio.

§1315.55(A)(1)
Date of Offense On or about October 21, 2016 to November 7, 2016
(Through the Venmo app, a total of $24,890.00 paid to Zee's Place in 35 transactions that were
credited to Zienup.sbeih@gmail.com and the funds were cashed out to to JP Morgan Chase Bank
accounts ending in x5871 (Kimberly St. John-Stevenson's account) and x2688 (Zienup Sbeih-
Maddox's account.)
Ohio.

§1315.55(A)(1)
Date of Offense On or about August 1, 2016 to June 30, 2017
(Multiple PayPal accounts: x6814, x9312, x2871, and x0426 - Over $90,000 was received by Zienup
Sbieh-Maddox from victims of Zee's Place, which then spends or transfers -> 1250 debit card
transactions).
Ohio.
Page 10 of 14

§1315.55(A)(1)
Date of Offense On or about December 2, 2016 to February 22, 2017
(Victims of Zee's Place scam sent their payments to Western Union (over $22,000.00) where it was
collected and cashed out by Zienup Sbeih-Maddox).
Ohio.

§1315.55(A)(1)
Date of Offense On or about July 24, 2017 to September 8, 2017
(Kimberly St. John-Stevenson's Key Bank account #x2832 transfers money to Kirsten Laurie and
also has many purchases by Zienup Sbeih-Maddox while she is a fugitive from justice.)
Ohio.

§1315.55(A)(1)
Date of Offense On or about November 9, 2017 to April 16, 2018
(Kimberly St. John-Stevenson used her US Bank account ending in x8945 to fund Zienup Sbieh-
Maddox while she is a fugitive from justice --> $8,371.00 in cash deposits made from 11/9/17 -
12/4/17)
Page 11 of 14
Ohio.

§1315.55(A)(1)
Date of Offense On or about February 15, 2017 to March 14, 2017
(In this time period all electronic deposits from Zienup Sbeih-Maddox stopped but there were
$2,680.00 in cash ATM deposits.)
Ohio.

§1315.55(A)(1)
Date of Offense On or about April 18, 2017 to April 28, 2018
(Kimberly St. John-Stevenson electronically deposited $3,914.21 in to Zienup Sbeih-Maddox's Bank
of America account using fourteen (14) separate transfers in eleven (11) days.)
Ohio.

§1315.55(A)(1)
Date of Offense On or about December 2, 2017 to July 30, 2018
Page 12 of 14
(From her Ink Plus, LLC Citizens Bank account ending in x6109, Kimberly St. John-Stevenson sent
money to her personal Citizens Bank account -to which Zienup Sbeih-Maddox had access, and from
which she used $62,368.29- while she was traveling out west avoiding her arrest warrants.)
Ohio.
Count 20 Possessing Criminal Tools - F5

§2923.24(A)
Date of Offense On or about May 10, 2018
did possess or have under the person's control any substance, device, instrument, or article, to wit:
HP laptop computer, partial serial #CNDS and/or Dell laptop computer and/or PayPal credit card
scanner and/or Apple iPhone 7Plus, model A1784, with no visible serial number and/or 11 Target
gift cards and/or 4 Panera gift cards and/or wallet with all items therein with purpose to use it
criminally.
FURTHERMORE, the HP laptop computer, partial serial #CNDS and/or Dell laptop computer
and/or PayPal credit card scanner and/or Apple iPhone 7Plus, model A1784, with no visible serial
number and/or 11 Target gift cards and/or 4 Panera gift cards and/or wallet with all items therein
involved in the offense were intended for use in the commission of a felony, to wit:
Telecommunication Fraud, O.R.C. 2913.05 and/or Money Laundering, O.R.C. 1315.55 and/or
Obstructing Justice, O.R.C. 2921.32 (A)(2)..
the defendant(s) is/are the owner(s) and/or possessor(s) of HP laptop computer, partial serial #CNDS
and/or Dell laptop computer and/or PayPal credit card scanner and/or Apple iPhone 7Plus, model
A1784, with no visible serial number and/or 11 Target gift cards and/or 4 Panera gift cards and/or
wallet with all items therein which is contraband and/or property derived from or through the
commission or facilitation of an offense, and/or is an instrumentality the offender(s) used or intended
to use in the commission or facilitation of a felony offense.
Ohio.
Page 13 of 14
Count 21 Possessing Criminal Tools - F5

§2923.24(A)
Date of Offense On or about August 20, 2018
did possess or have under the person's control any substance, device, instrument, or article, to wit:
Black iPhone 8 with T-Mobile Sim Card #8901260912758175725 and/or T-Mobile Sim Card
#8901260935781344569 and/or Vanilla Visa card #4847186165942729 with purpose to use it
criminally.
FURTHERMORE, the Black iPhone 8 with T-Mobile Sim Card #8901260912758175725 and/or T-
Mobile Sim Card #8901260935781344569 and/or Vanilla Visa card #4847186165942729 involved
in the offense were intended for use in the commission of a felony, to wit: Telecommunication
Fraud, O.R.C. 2913.05 and/or Money Laundering, O.R.C. 1315.55.
the defendant(s) is/are the owner(s) and/or possessor(s) of Black iPhone 8 with T-Mobile Sim Card
#8901260912758175725 and/or T-Mobile Sim Card #8901260935781344569 and/or Vanilla Visa
card #4847186165942729 which is contraband and/or property derived from or through the
commission or facilitation of an offense, and/or is an instrumentality the offender(s) used or intended
to use in the commission or facilitation of a felony offense.
Ohio.
Page 14 of 14

Indictment CR 635246 Zienup

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Indictment CR 635246 Zienup

Uploaded by

Copyright:

Available Formats

Cuyahoga County Court of Common Pleas

Criminal Court Division

State of Ohio, A True Bill Indictment For

Dates of Offense (on or about) The Term Of Case Number

The State of Ohio,

Count 1 Engaging In A Pattern Of Corrupt Activity - F1

Sbeih-Maddox and St. John-Stevenson transferred proceeds of the orders back

proceeds through her (Laurie’s) bank account to Sbeih-Maddox.

Furthermore, pursuant to Section 2923.32(B)(1), at least one of the incidents of corrupt

with purpose to commit or to promote or facilitate the commission of Engaging in a Pattern of

Sbeih-Maddox and St. John-Stevenson transferred proceeds of the orders back

Forfeiture of Property - §2941.1417(A)

or intended to use in the commission or facilitation of a felony offense.

Count 3 Telecommunications Fraud - F2

Count 4 Aggravated Theft - F3

Count 5 Money Laundering - F3

Count 6 Money Laundering - F3

Count 7 Money Laundering - F3

Count 8 Tampering With Evidence - F3

Count 9 Receiving stolen property - F4

Count 10 Obstructing Justice - F3

Count 11 Obstructing Justice - F3

Count 12 Money Laundering - F3

Count 13 Money Laundering - F3

Count 14 Money Laundering - F3

Count 15 Money Laundering - F3

Count 16 Money Laundering - F3

Count 17 Money Laundering - F3

Count 18 Money Laundering - F3

Count 19 Money Laundering - F3

Count 20 Possessing Criminal Tools - F5

Count 21 Possessing Criminal Tools - F5

You might also like