Case: 25CI1:22-cr-00469-WLK Document #: 1 Filed: 07/22/2022 Page 1 of 3

INDICTMENT Murder, Deliberate Design §97-3-19(l)(a)- 2 Counts CIRCUIT COURT NO. Qg-Lf~1w/K
Aggravated Assault §97-3-7(2)(a)(ii)- 2 Counts
Drive-by Shooting §97-3-109(1)- 1 Count
Shooting into a Vehicle§97-25-47- 1 Count

THE STATE OF MISSISSIPPI

FILED
JUL 22 2022
FIRST DISTRICT, HINDS COUNTY
ZACK WALLACE, CIRCUIT CLERK
BY________________o.c.
Circuit Court
March Term, A.D., 2022
First Judicial District
of Hinds County

The Grand Jurors of the State of Mississippi, taken from the body of good and lawful
persons of the First Judicial District of Hinds County, in the State of Mississippi, elected,
impanelled, sworn and charged to inquire in and for said District, County and State aforesaid, in
the name and by the authority of the State of Mississippi, upon their oath present: That

Joseph Brown
while acting in concert and/or aiding, assisting or encouraging
another or others known and unknown to the Grand Jury,
to-wit: Marzavier Harrington; Kenya Webster; Taire Johnson; Tairon Kelly

In said District, County and State

COUNT I

on or about the 151h day of December, 2021, in the county aforesaid and within the
jurisdiction of this Court, the said defendant being a male human being above the age of thirteen
(13) years, whose date of birth is January 15, 2004, did willfully, unlawfully, and feloniously,
with deliberate design to effect the death of Keyunta McWilliams, a female human being, kill
Keyunta McWilliams, to-wit; Joseph Brown, while acting in concert and/or aiding, assisting or
encouraging Marzavier Harrington, Kenya Webster, Taire Johnson, Tairon Kelly and others
known and unknown to the Grand Jury, did shoot Keyunta McWilliams or caused Keyunta
McWilliams to be shot, with a firearm, a deadly weapon causing Keyunta McWilliams' death all
occurring within the jurisdiction of this court and in violation of Section 97-3-19(1)(a),
Mississippi Code Annotated (1972, as amended); and,

COUNT II

based upon a series of acts connected together and constituting parts of a common scheme
and plan, said Joseph Brown being a male human being above the age of thirteen (13) years,
whose date of birth is January 15,2004, did, on or about the 15'h day of December, 2021, in the
county aforesaid and within the jurisdiction of this Court, willfully, unlawfully, and feloniously,
with the deliberate design to effect the death of Keyunta McWilliams' unborn child, as defined by
Section 97-3-37 Mississippi Code Annotated, kill Keyunta McWilliams's unborn child, to-wit;
Joseph Brown, while acting in concert and/or aiding, assisting or encouraging Marzavier
Harrington, Kenya Webster, Taire Johnson, Tairon Kelly and others known and unknown to the
Grand Jury, did shoot Keyunta McWilliams, who was pregnant at the time, and her unborn child,
or caused Keyunta McWilliams, who was pregnant at the time, and her unborn child, to be shot
with a firearm, a deadly weapon, causing Keyunta McWilliams' death and the death of her unborn
child all occurring within the jurisdiction of this court and in violation of Section 97 -3-19( 1)( a)
and Section 97-3-37 Mississippi Code Annotated (1972, as amended); and,
 Case: 25CI1:22-cr-00469-WLK Document #: 1 Filed: 07/22/2022 Page 2 of 3

COUNT III

based upon a series of acts connected together and constituting parts of a common scheme
and plan, said Joseph Brown being a male human being above the age of thirteen (13) years,
whose date of birth is January 15, 2004, did, on or about the 15th day of December, 2021, in the
county aforesaid and within the jurisdiction of this Court, willfully, unlawfully, and feloniously,
attempted to cause, or knowingly or recklessly under circumstances manifesting extreme
indifference to the value of human life or purposely or knowingly caused bodily injury to
Knowledge Wigley with a deadly weapon or other means likely to produce death or serious bodily
harm, to-wit: Joseph Brown, while acting in concert and/or aiding, assisting or encouraging
Marzavier Harrington, Kenya Webster, Taire Johnson, Tairon Kelly and others known and
unknown to the Grand Jury, did shoot at Knowledge Wigley, or caused Knowledge Wigley to be
shot at, with a firearm, a deadly weapon, at a time when Knowledge Wigley was a passenger in an
automobile being driven by Keyunta McWilliams, under circumstances manifesting extreme
indifference to the value of human life, all occurring within the jurisdiction of this court and in
violation of Section 97-3-7(2)(a)(ii), Mississippi Code Annotated (1972, as amended); and,

COUNT IV

based upon a series of acts connected together and constituting parts of a common scheme
and plan, said Joseph Brown being a male human being above the age of thirteen (13) years,
whose date of birth is January 15, 2004, did, on or about the 15th day of December, 2021, in the
county aforesaid and within the jurisdiction of this Court, willfully, unlawfully, and feloniously,
attempted to cause, or knowingly or recklessly under circumstances manifesting extreme
indifference to the value of human life or purposely or knowingly caused bodily injury to
Ky'Waun O'Brien Wigley, a two year old child, with a deadly weapon or other means likely to
produce death or serious bodily harm, to-wit: Joseph Brown, while acting in concert and/or aiding,
assisting or encouraging Marzavier Harrington, Kenya Webster, Taire Johnson, Tairon Kelly and
others known and unknown to the Grand Jury, did shoot at Ky'Waun O'Brien Wigley or caused
Ky'Waun O'Brien Wigley to be shot at, with a firearm, a deadly weapon, at a time when
Ky'Waun O'Brien Wigley, was a passenger in an automobile being driven by Keyunta
McWilliams, under circumstances manifesting extreme indifference to the value of human life, all
occurring within the jurisdiction of this court and in violation of Section 97-3-7(2)(a)(ii),
Mississippi Code Annotated (1972, as amended); and,

COUNTY

based upon a series of acts connected together and constituting parts of a common scheme
and plan, said Joseph Brown being a male human being above the age of thirteen (13) years,
whose date of birth is January 15, 2004, did, on or about the 15th day of December, 2021, in the
county aforesaid and within the jurisdiction of this Court, willfully, unlawfully, and feloniously,
attempted to cause serious bodily injury to Knowledge Wigley and Ky'Waun O'Brien Wigley, a
two year old child, human beings, and/or knowingly and intentionally caused serious bodily injury
to Keyunta McWilliams and her unborn child, human beings, or caused such injuries purposely,
knowingly or recklessly under circumstances manifesting extreme indifference to the value of
human life by discharging a firearm or causing a firearm to be discharged while in or on a vehicle
and not in lawful self defense, to-wit; Joseph Brown, while acting in concert and/or aiding,
assisting or encouraging Marzavier Harrington, Kenya Webster, Taire Johnson, Tairon Kelly and
other known and unknown to the Grand Jury, while occupying an automobile, a silver in color
BMW motor vehicle, being driven by Marzavier Harrington did shoot at or caused to be shot at,
multiple times, an automobile, a black in color Chevrolet Cobalt, motor vehicle, being driven by
Keyunta McWilliams, who was pregnant at the time, and which automobile was occupied by
 Case: 25CI1:22-cr-00469-WLK Document #: 1 Filed: 07/22/2022 Page 3 of 3

Knowledge Wigley and Ky'Waun O'Brien Wigley, who were passengers in the same, with deadly
weapons, firearms, all occurring within the jurisdiction of this court and in violation of Section
97-3-1 09( 1), Mississippi Code Annotated ( 1972, as amended); and,

COUNT VI

based upon a series of acts connected together and constituting parts of a common scheme
and plan, said Joseph Brown being a male human being above the age of thirteen (13) years,
whose date of birth is January 15, 2004, did, on or about the 151h day of December, 2021, in the
county aforesaid and within the jurisdiction of this Court, willfully, unlawfully, and feloniously,
shoot or discharge any pistol, shotgun, rifle or firearm of any nature or description into a motor
vehicle usually occupied by persons, whether actually occupied or not; to-wit, Joseph Brown,
while acting in concert and/or aiding, assisting or encouraging Marzavier Harrington,Kenya
Webster, Taire Johnson, Tairon Kelly and other known and unknown to the Grand Jury, while
occupying an automobile, a silver in color BMW motor vehicle, being driven by Marzavier
Harrington did shoot at or caused to be shot at, an automobile, a black in color Chevrolet Cobalt,
motor vehicle, being driven by Keyunta McWilliams, who was pregnant at the time, and which
automobile was occupied by Knowledge Wigley and Ky'Waun O'Brien Wigley who were
passengers in the same, multiple times with deadly weapons, firearms, all occurring within the
jurisdiction of this court and in violation of Section 97-25-4 7 Mississippi Code Annotated (1972,
as amended).

All of the above, Count I, Count II, Count III, Count IV, Count V and Count VI being contrary to
the form of the statute in such cases made and provided, and against the peace and dignity of the
State of Mississippi.