02:00 ?ll ahepherd . 2. INDICTXENT N3, C13 CLAYTON SUPERIOR COURT November Term, 2011 . "on STATE OF GEORGIA VICTOR KEITH HILL a- r-uuw Cts. 1-4: Violation of Racketeer Influenced and Corrupt Organizations Act (11133.) (Its. son: Theft by Taking (Its. 314:2: making 9: False Statement Thoft by Taking Ct. 36: Violation of Oath by Public Of?cer lamenting a Witneas? ..-. Ryan-awn- Bill ll?oropcraon SPECIAL masomm?mr This #m day Of TRACY GRAHAM LAWSON DISTRICT ATTORNEY JRNrig-E?ia From: 7784773342 7704773342 P. 2/28 i PLEA The. Defendant Wolves formal awaignment, copy of indictmont/ accusation, list oi? witnesses, and wives indictment by tho Grand Jury where applicable, and also Waivers trial by jury and pleudts?. GUILTY NOT GUILTY This Wda}; oi? Dotmnt .. . . . Defont?la?tltiojkttorney mistrial Attorney VERDICT We, Jury, find the Defendant: . Forepotmn'l ID: R3962 JRNQUQUW 02101 All rheggl-a ahepherd STATE OF GEGRGIA The Grand Jurors 372774? iaeama 7704773342, 1 P. 3/28 BILL 011? INDICTMENT IN THE SUPERIOR COURT OF 5mm comm chosen, and sworn 1?07 the County of CLAYTON, tO-wil: 11min Sullivan, Forcperson William H. Davidson, Jr. Beatrice Montgomery Mike Klingshim Sharon Rhodes Angela, Dennis Ben Rivars Amanda Brand (Shawl Yuung Mary Hart Amie Jennings Joel Smith Fr? hm! 7734773348 ID: 81132111 Tredway Judith Lassie: CLW. Hugh Burnett Brad Marks Michaal Williams Marlon Grant BJ . Marks Randy Hallford Ray 141111777137 Dametrla Jennings P3961333 R7436z JBNM2042012 02:01 am rhe?a ahepherd 7704773342,. P. 4/26 I. . COUNT 1 . On behalf (31' the citizens at? the State (3f Georgia, do hereby charge and accuse; KEITH HTLL with the Ulil?ensc of: OF RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS far that the said accused hatween the lat day of Jamiary, 2097, and ?due 3131?. clay of I Dccamhm?, 2008, in Clayton County Georgia, did then and thaw: through a Pattum of Racketeeting Activity, acquim and maintain, directly and indiractly, an intatest in and control of an Enterp?se, real proparty, and personal prnpextly including United $tates violation 0f contrary to the laws. of said State,t1m good Order, peanut: and dignity that?eot?. COUNT ONE ofthis Bill of Indictment Expressly incorporates by refevenuc, as if Fully set 'lQI'll] herein, 1:11: allegations of the ENTERPRISE, the PATTERN OF ACTIVITY, and the ACTS OF RACKETEERTNG ACTIVITY us enumerated in pages 5 through 13 thhit. Bill (31? Indictment. Clayton Suparior Court Trauy Graham lawman Navember Term, 20] Diatrict Attatney Fr' 0m: TTB4TT3348 ID: P57982184 Jaw?Quanta 02:01 on 9m,? ahepherd 7704773342f P. 5/26 . - . COUNT 2 0n beholfof the citizens: of the State oi?Goovgin, do bomb): ohmgo and acouso: FOR KEITH HILL with [11% offense of: VIOLATION OF AND CORRUPT ORGANIZATIONS ACT . for thattho said accused bemoan the 191 day of January, 2007, and the: 31m. day of Deoo1obor,2008,in Clayton County, Georgia, did then and there: associate: with on Enterprise and did, through a Pattcm of Rackotooring Activity, dirootIy and indii'eotly oonduct and panicipate in the Enterprise, in violaxion of D.C.G.A. 164 4.. 40)) contrary to the laws of said Stats, the good order, peace and dignity thereof. COUNT TWO of this Bill of? Indictment Exprossly incorporates by reference, as if fully sot forth thorein, the allegations of the ENTERPRISE, the PATTERN OF RACKETEERWG ACTIVITY, and the ACTS OF RACKETEERING ACTIVITY a5 enumeratad in pages 5 through 13 ofthis Bill of Indietmont. Clayton Superior Court Tracy Graham Lawson November 'l?orm, 201 1 Diairioi Attomoy 4 From: 77"214773342 ID: Page-.395 R295: Jinan-2012 02:01 on new ahopherd tin-limo. P, 6/28 . li?, TH 1, . THE LAYTO COUNTY SHERIF thE Botw?o?on January 1, 1007 and Doonmbor 3 2008, Victor Keith l?lill servocl not elected Sheriff of Clayton County. During thin timo, Victor Keith Hill, acting through o. PATTERN OF RACKETEETUNG nitrintainod oontrol of on ENTERPRISE, the Clayton County Shorii?f?s Of?ce, a. govornmontal entity. Victor Keith i?Iill maintained an interest in and control of tho ENTERPRISE in Clayton County during the above dates, Among the duties of the Sheriff are: maintaining the county jail, noting for and housing prisoners, transporting prisoners to and from court and other correctional facilities, a?oat warrants, providing courthouse security, providing deputies to sown. tits bailiffs in judicial proceedings, and the approval of and reooipt of bail bonds. Although all omployooii of tho Clayton County Shoril?i?o thioo, regardless of position, remit or yearn of service, are civil service: employees pursuant to Clayton County Civil Sewioo System Act, Ga, L. 994, the Sheriff hat; the authority to hire whon?lovor he wishes, While tho Clayton County Shoriff?o Of?oo is a paramilitary organization with a chain 01? command, the Shorifimay override any recommendation for discipline: of on employee and may remove an individual from ptnition where they report to the ?chain - of command," making that omployoo roport clirootly to tho Shoriff. . THE. PATTERN OF RACKETEERING ACTIVITY Victor Koith Hill engaged in tin interrelated pattern of criminal activity motivated by and the oi?foot of which was poouniary gain. - Whilo sowing. as Shari ll of Clayton County, Victor Koith l-lill ongogod in at loom two ACTS RACKBTEERING ACTWITY, as dofmod by Of?cial Code ol?Gooi?gl? Annotated (000A) and 16?1 and as enumeratod holow. . . . Janna?ante ?From: 77647733413 ID: 02:01 at date ahepherd 7704773342 F. 7/28 EECUEIARY ?Al? Victor Keith Hill, through the PATTERN 0F RACKETEERING ACTIVITY and proceeds derived therefrom, acquired and maintained on internal in and control cl" personal property including money in Clayton County. By virtue of his position as Sheriff of Clayton County, Victor lieith Hill had opportunities, of which he tool: advantage, through the PATTERN OF liACl?li?l?EERlNG ACTIVITY, to obtain money and gain. - . . While serving as Sheriff. Victor Keith l-lill conducted the of the Sheriff in a manner in which he: illegally pro?ted ?nancially from his position anSherit?t? through the one of Clayton County Sheriffs Office Vehicles and fuel purchased by Clayton. County to transport himself on personal trips not legitimately related to the performance of any of Victor Keith l-lill?s duties as Sheriff; illegally ordered a Sheriff's Of?ce employee to perform porno nal on behalf ot? Victor Keith Hill by ordering the employee to aselst in the writing of a. hook that Victor Keith Hill was writing which was unrelated to his dutiee on Sheriff, while said employee was on?duty and being paid by Clayton County; illegully profited ?nancially from fundreicing events using err?duty Clayton County Sheriff 2 Of?ce employee's, Clayton County 3 Of?ce vehiclee, and tool purchased by Clayton County to conduct said fundraisers when eeid fondreicerc were used to fund the Committee to Reeleet Victor Hill campaign account; illegally pro?ted financially from the use of Clayton County funde to pay for a vacation rental in North Georgia; illegally profited from his position as Sheriff by allowing Sheriff?s Office employee to receive payment from Clayton County in the term of ?kickbacks? from the company that printed publication entitled. ?The Sherli?t?s Stan? illegally ordered that Sheriff?s Office employee he placed on paid ndntinietrntiye leave so that she could travel with Victor Keith Hill on personal trips and etill receive a salary. All of the crimes and note charged ONE AND TWO, of this Bill of indictment were committed between Jenuury 1,200? and December 31, 2008. At least one of the ACTS (3F ACTWITY occurred in Cluyto County. - . The ACT 0F ACTIVITY (which. together. the ATTERN OF RACKETEERTNG ACTWITY) engaged in? by Victor Keith Hill had the some or similar intentn, results, accomplices; victims and methodc'ot? commission, and were othermee interrelated by distinguishing characteristics. The ACTS OF, MCKETEBRING engaged in by Victor Keith l-lill were not isolated incidents, but formed a PATTERN OF RACKETEERWG ACTIVITY coordinated and . directed toward the ectmnon objectives cl" the exploitation of Victor Keith ill?n position no Sheriff for personal financial gain as well as the ?nancial gain of certain individuals he associated with. The ACTS OF were further interrelated through Victor Keith l-lill?c use of Clayton County Sheriffs Office employees and property to commit the ACTS OF RACKETEERING ACTIVITY. ?2318 Front: 7TB477334E ID: - Jhl?i?"3il"20i2 illi rhehia ahepherd - I 7704773342( . P. 8/26 . . ACTS OF RA CKETEERING ACTI The ACTS OF smiwrr? engaged in by Victor tress l-lill but are not limited to: - . 1. Violations of Article of Chapter 8 of the Criminal Code of Georgia relating to theft LOCGA {516-841, 'l?l-ll-EFT BY TAKING and OCGA {all Edi-:4, THEFT BY 2. Violations of QCGA ?16?lO-20, FALSE STATEMENTS AND CONCEALMENT OF FACTS, AND FEAU DU LENT DOCUMENTS 1N MATTERS OF STATE OR ACTS on monoroomto 1. THEFT The Pattern While: Sheriff of Clayton County, Victor Keith Hill used the properly of Clayton County and the lab or oi? its employees as though they wore his owe personal pmp??zi?i?y? Vieior Keith l-lill used Clayton County veliieleo himself to travel both and ombol?v state on personal hips, including vacations, not legitimately related to the preliminaries his duties as Sheriff. Victor Keith Hill used an Clayton County Sheriff 3 Office employee to perform work. on e. book that Victor Keith Hill was writing, which was unrelated to his duties as Sheriff. Victor Keith Hill else need on onudnly Clayton County Sheriff" Of?ce employee to work on his reeleotlon campaign to include designing, a website, postcards, signs. magnets, and other omnpalgn literature using Sheriff?s Ollieo 'oliliees and equipment. Vietor Keith Hill used Clayton County Sheriff? 3 Of?ce employees, Clayton County Sheriff? 5 Office vehicles, and fuel purchased by Clayton County to eonclnet fundraisers when said fundraisers were used to fund the Committee to Reeleot Viet'or Keith l-lill campaign account. Victor Keith Hill used Clayton County tends to psy for vacation rental as orth Cicorgiowhioh was for it personal trip and unrelated to his duties as Sheriff. Victor Keith Hill allowed it Sheriffs Of?ce employee to receive payment from Clnyioo County in the form of ?hiohhnolts?? from the company that printed a publication entitled, ??l?he Sheri??s Stan? Those ?kickbacks? were ellowo in order to pay the employee additional salary on for work he was doing on Viotor Keith Hill?s campaign. Victor Keith Hill ordered that Sheril?l?s Office employee he placed on paid administrative leave so that she could receive pay while not at work and while '7 mote?Beta oazaoem From: Tresrreesa to: Passions 02101 RH rheila nhepherd 770477334% . a - - travelling with Victor Keith Hill on, personal trips. the offense of THEFT BY in that Victor Keith Hill authorized payment from Clayton County Sheri it"s Office funds for a cabin rental with Blue Ridge Cabin Rentals to Helen, Georgia for a personal trip unrelated to his ol-??cial dutlea an Sheriffot Clayton County, and using fool purchased by Clayton County tor of?oial use, did travel to Helen, Georgia using a Clayton County Sheriff? 3 Of?ce 2003 Ford Excursion, and did thereby unlawfully take prooerty of Clayton County, with the intention of depriving Clayton County of the property. ll: . Between Augunt 6, 2008 and Alignet 11, 2003, Victor Keith Hill did in Clayton County oontntit the oflienee of THEFT BY in that Victor Keith Hitl used a Clayton County Sherl?? 5 Offline 2003 Ford Excursion to travel to the State of Florida for a personal trip unrelated to his of?cial duties as Sheriff of Clayton County, and did thoreby unlawfully talte property of Clayton County, with the intention of depriving ayton County of the property, lg . On or about August 6, 2008, Victor Keith [-Iill did in Clayton County commit the offense of BY TAKING in that Victor Keith l-lill took Clayton Cotmty fuel from the county fuel pumps in .loneeboro, Georgia, and used said fuel for a personal trip to Florida unrelated to his official duties as Sheriff of Clayton County, and did thereby unlawfully take property of Clayton County, with the intentiou ot?doprlving (3131th County ofthe property. 1d On or about Au Fuel.- ?7 2008, Victor Keith Hill did in Clayton County cannon the offense of THEFT BY TAKING in that Victor Keith l-Iill need Clayton County funds to purchase goods in the amount of $162,633 at FortPtoroe Citgo in Fort Pierce, Florida while on a 9 personal trip unrelated to his ofheial duties as Sheriff of Clayton County, and did thereby unlawfully take property of Clayton County, wi the intention of depriving Clayton County of the property. . - lo On or about August 7, 2008, Victor Keith l-Iill did in Clayton County commit the offense of THEFT BY TAKING in that Violet Keith Hill used Clayton County funds to purchase $42.59 in goods and services. at a Radio Shack store in West Palm Beach Florida, aaid goods and soryioea being for personal use and unrelated to his official duties as Sheriff of Clayton County, and did thereby talto property of Clayton County, with the intention ol? depriving Clayton County of the property. F. 8/28 Between June 4, 2008 and June 7, 2033, Victor Keith l-lill did in Clayton County commit - 19-2812 Front: T??l4773342 ID: Paoet?ll?g Jhll~20~2012 02:02am rheFi-a ahepherd 7704773342( ale/26 If On or about August 8, 2008,.Viotor Keith l?Iill did in Clayton County commit the offense of TI-IBFT BY TAKING in that Victor Keith Hill used Clayton County funds to purchase 535 00.00 in goods and services at a Sprinthextel store in Florida, said goods and serviees being for personal use and unrelated to his ot?l?ioial duties at: Sheriff of Clayton County, and did thereby unlawfully take property of Clayton County, with the intention ot?deprivtng Clayton County of the propetty. 1t: 01?1 fibUUi August 1 It 2003. Vi?tt?n? Keith Hill did in Clayton County commit llto offense of THEFT BY TAKING in that Victor Keith Hill uaod Clayton County funds to purchase goods in the amount of til I 42.63 at BP Oil in Miami, Florida while on a personal trip unrelated to his ott?oial dutiea an Sheriff of Clayton County, and did thereby unlawfully take property of Clayton County, with the intention of depriving Clayton County of the property. I . Between August 25, 2003 end September 2, 2003, Victor Keith Hill (lid in Clayton County commit the offense of THEFT BY TAKING in that Victor Keith Hill used a Clayton County Sheriff's Office 2003 Ford Excursion to travel to the State of South Carolina for :1 personal trip unrelated to his of?cial duties as Sheriff of ClaytonCouoty, and did thereby unlawfully take property ot?Cloyton County, with the intention of dot?loving Clayton County of the property. It . Between September It}, 2008 and September 11, 200 8, Victor Keith I-lill did in Clayton County commit the offense of Tl?tl?i BY rl?Al?ill?xl Cir in that Victor Keith Hill used it Clayton County Sheriff?s Office 2006 Dodge Charger to travel to the States ot?Alabarna for a personal trip unrelated to his official duties as Sheriff of Clayton County, and did thereby unlawfully take property of Clayton County with the intention ot?dopttring Clayton County ot?tlto property. 11 On or about September 10, 2008, Victor Keith I?lill did in Clayton County commit the offense ol? THEFT BY TAKING in that Victor Keith Hill look Clayton County the] from the fuel pumps in onoeboro, Georgia, and used Said fuel for a personal trip to travel to the States ot?Alabtnna and unrelated to his of?cial duties as Sheriff of Clayton County, and did thereby unlawfully talto property of Clayton County, with the intention ol?depriying Cileyton County of the property. From: 7784773342 . ID: Paoe:EliEl H2963 momma-02mm nap-.1 nhepherd "(Yunnan? P.ll/28 . On or about September 10, 2008, Victor Keith Hill did in Clayton County commit the offense of THEFT BY in that Vietm' Keith l-Iill need Clayton County funds to purchase goods in the amount at 131? Oil in Bay Minette, Alabama while on it personal trip unrelated to his official duties as Sheriff ol": Clayton County, and (lid thereby unlawfully take property ol? Clayton County, with the intention of depriving Clayton County of the property. 1; On or about September ll, 2003, Victor hieitb Hill dirl in Clayton County commit the offense of BY TAKING in that Victor Keith Hill used Clayton County funds to purchase goods in the amount of $70.37 at BP Oil in Hope Hull, Alabama while on a per?ouul trip unrelated to his. ol?tieiul duties as Sheriff of Clayton County, and did thereby unlawfully take property of Clayton County, with the intention of depriving County of the property 1 - Between September 15, 2008 and September 16, 2003, Victor Keith Hill did in Clayton County commit the ol?l?enne of THEFT BY in that Victort?eith t'lill used it Clayton County Sheriff 5 Of?ce 2006 Dodge Charger to notation the State of Mississippi For it personal trip unreluted to hit: ollioiul dutier no Sheriff of Clayton County, and did thereby unlawfully take property of Clayton County, with the intention of depriving Clayton County of the property. in Between September 20, 2008 and September 21, 2008, Vietor Keith i-lill did in Clayton County commit the offense of Tl'lEFl? BY in that Victor Keith Hill used o, Clayton County Sheriff?s Of?ee Dodge 2006 Charger to travel to the State of Mieniesippi [or a personal trip unrelated to his official duties as Sheriff of Clayton County, and did thereby unlawfully take property of Clayton County, with the intention of depriving Clayton County of the property. - Between October 3 2008 and November 5, 2003, Viotor Keith Hill did in Clayton County commit the offense BY TAKING in that Victor Keith [-1111 used a Clayton County Sheriff 3 Office 2006 Dodge Charger to travel to the Store oi'North Carolina fer a personal trip unrelated to his of?cial clutter: as Sheriff or Clayton County, and did thereby unlawfully take property of Clayton County, with the intention of depriving Clayton County of the property, l0 19*8913 From: ID: Pane E111 Janet?2012 02:02 no than ahephetd 7704773342,. 111. . . Between April 4, 2007 and Deoetnher 31, 2008, Viotor Keith Hill (lid in Clayton County commit the ol-?l?enae of THEFT BY TAKING in that Viotor Keith I'lill ordered and procured Clayton County Sheriff?a Oflioe employee Jonathan Newton, while on-duty and while being paid by Clayton County, to work on a hook that Victor Keith Hill was writing, which was unrelated to his duties on Sheriff, and did thereby unlawfully take the service of Jonathan Newton, property ol?valuo, the property of Clayton County, with the intention of depriving Clayton County of the property. 1?1 Between April 4, 2007 and August 6, 2008, Victor Keith Hill did in Clayton County omnntit the offense of "l?lall?iF?l? BY TAKING in that Victor Keith Hill ordered and pro outed Clayton County Sheri llha'Ot?t?ioo employee Jonathon Newton, wltile-onwduty and while being paid by Clayton County, to work on Victor Keith Hill?s reelection campaign using Sheril?l?a Office offices and equipment and did thereby unlewlirliy take the service ol? Jonathan Newton, property of value, the property of Clayton County, with the intention of depriving Clayton County of the propertyabout May 19, 2007, Victor Keith Hill diet in Clayton County eormnit the offense of THEFT BY in that Victor Keith Hill did thereby unlawfully take the services of Cilayton County Sheriff?s Of?ce employooa, while on duty and while being paid by Clayton County, by ordering, proeuring and allowing, said employees to work on the asnigontent of the ?Sheriff Vlotor l-lill Biker? a Festival 2007,? a fundraiaing event for the Committee to Reeleet Victor Hill, and did thereby unlawfully take property of value, the property of Clayton County, with the intention of depriving Clayton County of the property. . On or about May 19, 2007, Victor Keith l?lill?rlirl in Clayton County commit the offense BY Li in that Victor Keith Hill on thereby unlawfully tone yohlolea of the County Sheriff1 3 Office, using fuel purchased by Clayton County for official use,_to be used for the ?Sheriff Vietor Hill Bilter?s Festival 2007,? a funrltaioing event for the Committee to Reeleot Victor Hill, and did thereby unlawfully tnlte property of value, the property of Clayton County, with the intention of depriving Clayton County of the propo?y. - . it On or about September 17, 2007, Victor Keith Hill did in Clayton County commit the offense of THEFT BY TAKING in thatViotot Keith lelill did thereby unlawtiilly take the - services of Clayton County Sheriffs Office employees, while on duty and while being paid by Clayton County, by ordering, procuring and allowing said employeen to work on the assignment of the ?The 2007 Sheriff Victor Hill Annual Golf Tournament,? a event for the Committee to Reeleot Victor Hill, and did thereby unlawfully . ii P, 12/26 J?l?ielge??i?i?? Ft?orn'. 771214773348 ID: - PanellBlE [12:02 rhei?a ahepherd 77047733421. P. 13/28 mice property of value, the property of Clayton County, with? the intention of depriving Clayton County of the property. - .1 On or about September 17, 2007, Victor Keith Hill did in Clayton Cunnty commit the offense ot? THEFT BY in that Victor Keith l-lill did thereby unlawfully take vehicles ot?the Clayton County Sheriff?s Office, using fuel purchased by Clayton County for of?cial use, to be used for the ?The 200'? Sheriff Victor Hill Annual Golf ?l?ournument," t?undteieing event for the Committee to Reelect Victor Hill, and did thereby unlawfully take property ol'ynlue, the property of Clayton County, with the intention of depriving Clayton County of the property. . 13, On or about April 17, 2008, Victor Keith llill did in Clayton County commit the offense of THEFT BY TAKING in that Victor Keith Hill did use the Clayton County Sheriff? :3 Olfliee DEA Shared account to pay $26,100.00 to Advantage Ful?llment Services, too. for printing services on the May 2008 ?Sheriff?e Star" publication, lmowing that the . actual cost for the printing services. of the publication were less. than $26,l {16.00 and that Jonathan Newton would rcceiye refund from Advantage Ful?llment Services, inc, and did thereby unlawfully take the funds of Clayton County, property of Clayton County, with the intention of depriving Clayton County of the property. 12v. - . On or about May 29, 2003, Victor Keith Hill did in Clayton County commit the offence of THEFT BY in that Victor Keith Hill did use the Clayton County Slierll?l"e Of?ce General Ledger to pay $27,680.00 to Advantage Ful?llment Services, Inc.- t?or printing services on the July (2.008 ?Sheriff?s Slur? publication, knowing that the actual cost for the printing, services of the publication was less then $27 ,530-30 and that Jonathan Newton would receive at refund from Advantage Fulfillment Servicee, inc, and did thereby unlawfully take the t?undu of Clayton County, ptoperty of Clayton County, with the intention of depriving Clayton County of the property. 13 On or about October 3, 2008, Victor Keith l-lill did in Clayton County commit the offense of THEFT BY TAMN in that Victor Keith Hill did use the Clayton County Sheriff." 8 Office Forfeited Drug, Money account to pay $37,923.93 to Advantage Fulfillment S?t?vio??st inc. for printing service's on the October 2008 ?Sheriff?s Star? publication, knowing that the actual coat for the printing services of the publion ion was less than $37,928.93 and that ,louuthun Newton would receive 11 refund from Advantage Ful?llment Services, Inc., and did thereby unlawfully take the funds of Ciluytou County, property of Clayton County, with the intention otdepriving Clayton County of the properly. Between August 9, 2003 and Septemhet 19, 2003, Victor Keith I-lill did in Clayton County commit the offense of THEFT BY "l?AKll?lG In that Victor Keith Hill did 12 Front: ID: I R5965: Jhl?leEUeQUlE 02:02 till rhe?t?a aliepliercl 7704773342 P. 14/28 authorize a Oi?l?iee employee, to be placed on paid administrative leave when said employee was traveling on personal tripe with Victor Keith Hill, and did thereby unlawfully take the ?mdn 0f Clayton County, with the intention 01? depriving Clayton County of the property. 12 - . Between September 20, 2008 and November 19, 2008, Victor Keith Hill chat in Clayton County commit the offense of THEFT BY TAKING in that Victor Keith Hill (lid authorize a Short it?s: Of?ce employee, to be pinned on paid siok leave which wait in feet not warranted, and while said employee was traveling with Victor Keith Hill and did thereby unlawfully take the funds ot?Clayton County, with the intention of depriving Clayton County of the property. 1. FALSE STATEMENTS AND WRITINGS, CONCEALMENT OF FACTS, AND FRAUDULENT DOCUMENT MATTERS WITHIN JURISDICTION 011? STATE 0R POLITICAL SUBBIVISIDNS The Pattern Between August 8, 2008 and September 19, 2008, Viotor Keith Hill did cause a false writing to be made within the political subdivision of Clayton County, when he ordered and allowed that a Sheriff? 9. Of?ce employee, Beatrice Powell, he placed on paid administrative leave so that she could travel with Victor Keith Hill on personal trips. The statue assigned to Beatrice Poweli?e absentee statue, ?administrative leave,? was false and ?etitiooa. Zn . Between August it, 2008 and September 19, 2008, Victor Keith Hill did aolicii, nation. and knowingly, allow a false, ?ctitious, anti "fraudulent statement and representation to he made, by causing and allowing the employee payroll records, to wit: The AnTeam Daily Renter and the Clayton County it'l?M hive b?yateni Employee Time Card Detail Report of the Clayton County Sheriff?s Of?ce to reflect that Beatrice Powell was on administrative leave, From August 8, 2003 and September 19, 2008, knowing the some to be a false, ?ctitious, fraudulent statement anti representation, within the Clayton (In only Sheriff?s Department, a department ot? a political subdivision of thin State. '31) . Between September 20, 2003 and November 19, 2008, Victor Keith i-lill tiitl eolioit, entree, and knowingly, allow a false, ?otitioae, and fraudulent atateroent? and representation to be made, by causing, and allowing the employee payroll records, to wit: The earn Daily Roster and the Clayton County ETM Lire System Employee Time Cam Detail Report at? the Clayton County Sheriff?s Of?oe to?relieel that Beatrice Powell was on sick leave from September 20, RODS and November 19, 2008, knowing the same to he a false, ?ctitious, fraudulent statement and representation, within the Clayton . 13 Jennie-Bate From: treatment?1 ID: . . Paae=814 02103 Fill rhetle ahepherd 7704773342. 7 P. 15/28 7 County Sheriff? 5 Department, a department of polltleel subdivision of this State. COUNT 3 On behalf of the citizens of the State of Georgia, do hereby charge and accuse: VICTOR with the offense of: OF RACKETEER ENCED AND CORRUPT ACT for that the said executed between the 7th day of January, 2007, and the 30th day of June, 201 the exact date of the offense being, unlutown to the Grand Jury in Clayton Ciotmtya Georgia, then and there: . - through a Pottem of Reokoteorlng Activity, acquire and maintain, directly and indirectly, an interest in and control of an Enterprise, real propet?ty, and personal property including United States etut'enoy, in violation of O.C.G.A. 16-1 440:1) contrary to the laws of said State, the good order, peace and dignity thereof. COUNT 'l'lrlREE of this Bill 01?? Indictment expressly by as if fully set forth therein, the allegations of the ENTERPRISE, the PATTERN 0F - RACKETFJERING ACTW 1' l?Y, and this" ACTS 01" RACKETEERING ACTIVITY its; lemtmemted in pages 16 through 13 of this Bill of lndtetmeot. Clayton Superior Court 'l?Ieey Graham Lawson - November Term, 2011 District Attorney '14 J?Nei?aeEtZtif-l From: T784TYBB4E ID: Faggai? 53:95:: 02:03 PM rhethia ahepherd . 7704778342 - Pew/28 COUNT 4 On behaii? of ihe: citizens of the: State: of Georgia, do hereby niinrgn and accuse: VICTOR KEITH HILL with the. offense; of: VIDLATION OF MCKETEER AND CORRUPT ORGANIZATIONS ACT for that the: said accused batman this int daynf January, 2007, and the 39th day oi? 11.1116, 201 i the exact date: al' the arrange being, unknown in the Grand Jury in Ciaytnn Cmniy, Georgia, than and thaw: aasnciatz: with an Enterprise: and did, through a Pattern of Rackcteering Activity, directly and indirectly conduct and pmiicipate in the: Enterprise, in viniaticn of 0. 20.1%. 16-14- 403) to the laws of said Stain, the gonad order, panes and dignity tiierenf. COUNT FOUR of this Bill of Indictment exprensiy incorpnrates by raf?ence, as if fuiiy set forth therein, the allagaiions of the ENTERPRISE, the OF RACKETEERING ACTIVITY, and the, ACTS OF RACIQETEERING ACTIVITY as an'nemtnd in pages 16 thrnugh 13 nfthis Bill of indictment. Cinyion Superior Cnurt Tracy Graham Lawsnn November Term, 2011 District Attonwy 15 Ft?nm: 77134773348 ID: Panei?i? [12103 Fill rheiia shepherd 7704773342 .. P. l7/2ii rry Victor Keith Hill engaged in an interrelated pattern oi? criminal activity motivated by and the et?l?ect at" which was pecuniary gain. While maintaining and interest and control of the COMMITTEE T0 REELECT HILL SHERIFF, Victor Keith Hill engaged in at least two ACTS DP ACTWITY, as defined by Of?cial Code of Georgia Annotated (OCGA) and and as enumerated belowt PECUNI GAIN Victor Keith Hill, through the PATTERN 0F ACTIVITY and proceeds derived therefrom, acquired and maintained an interest in and control of personal property including money in Clayton County. By virtue at his position as a political candidate for Sheriff of Clayton County, and by and through the acceptance oi? campaign contributions into the depository account entitled, COMMITTEE TO - REELECT VICTOR Hi LL Victor Keith Hill had opportunities, of which he took advantage, through the PATTERN OF RACKETEE. 1N6 to obtain money and ?nancial gain. While maintaining, and interest and control of this account, Victor Keith i-lill conducted ?nancial transactions on this account in which he: illegally pro?ted through a check drawn on this scoot at and made payable by Victor Keith Hill to a connotation whose sole interest holder is Victor Keith t?lill, illegally profited through a. check drawn on this account and made payable by Victor Keith Hill to an associate of Victor Keith Hill who in into provided a portion cl" these funds to Victor Keith Hill; illegally profited by depositing a check made payable to ?Victor Hill" l-?or a campaign contribution by depositing said check into his personal checking account Bank of America. All of the crimes and acts charged in COUNTS THREE AND FOUR, oi?this Bill cl? Indictment were committed between January 1, 2007 and Jane 30, 2011. At least one of the ACTS OF RACKETEERING occurred in Clayton County. - - The ACTS OF MCKETEERENG ACTIVITY (which, together, establish the PA'lTEl'tbl OF RACKETEERING ACTIVITY) engaged in by Victor Keith Hill had the same or similar intents, results, accomplices, victims and methods of commission, and were otherwise interrelated by distinguishing; characteristics. The ACTS OF engaged in by Victor Keith l-Iiil were noi isolated incidents, but formed a PATTERN 0F RACKEFEERING A "i?iVlTY coordinated and directed toward the common objectives of facilitating the exploitation ol? the Committee 16 19-2312 From: 7794773343 ID: 00202012 02:03 an rhetta ahcpherd 7704773342. To Victor Hill?s dcpocitory campaign account for personal ?nancial gain. OF THE ACTS RACKETEERING ACTH 11:3? The nora on ACTIVITY engagcd in by Victor Kean l-lill but are not limitctl to: l. Violations of Article 1 of Charitcr 3 of tho Criminal Carlo of Georgia rotating. to tlicit (OCGA {nor?2, THEFT BY TAKING and OCGA ?l6-B-4, THEFT BY ACTS on 1.. Theft Tho Pattern January 1, 2007 and June 30, 201 Victor Kcith Hill maintained an and control over his campaign account cntitlcd, Comtnittcc To Victor Hill Sheriff. The of this account is rcqutrcti tinder O.C.G.A. ?21a5? 30(c), and all contributions to this account can to lac disposed of pursuant to O.C.G.A. ?21u5r33{aj. Victor licitlt Hill took campaign contributions that were to ho lawfully uscd for. a designated pnlpoac, and contorted thorn to hia own nac, aald funds for an unlawful purpose. 0n August M, 2008, Victor Keith Hill paid Naomi Nash, $15,000.00 "from this account tinder tho gniac that it won payment for Naomi Nash?s - carvico as his campaign managct. most of tho money can returned to Victor Kcith? Hill after tho funds were deposited and than withdrawn from Naomi Nash?s: pctaonal account. Similarly, on l4, 2008. "Victor Keith l-lill Withdraw $7,000.00 from this Committee To Recloot Victor Hill account with a made payable, to Itcacmcca. a Nov ado Corporation. For which Victor Keith Hill is the only corporatc ofticcr. On 17, 2003, Victor Keith than wrote a chock from Eton-thorn Inc. in amnion of $7,000.00 to Eagle Optional, LLC, a limitccl liability 01? which Victor Keith Hill in the: only On June 6, 201 Victor Keith Hill dcpoaitcd a campaign contribution from Icon Company Inc Bcanty Manor-Morrow in that amount of $1,000.00 into his pciaonal Bank of Amcrica. account rather than the campaign account known as Victor Hill Shoal-T. All of tltcac funds clcaignatcd campaign funds to bc used by Victor Keith only to defray ordinary and necessary inonncd in connection with tho candidate's: campaign for of?ce or his Ful?llment or of o?fficc and not for personal financial gain. (0.0.G.A. 17 P. 18/20 From: . Pact-3:318 02:03 ?ll rhella ahepherd 7704773342] I P. 19/abnut August 14, 201 I, Victur Keith Hill did in Clayton County, Gaorgia. commit the offense" of BY TAKING in that VICTOR HILL did unlawfully take?; $15,000.00 from Iht?: To Victor l-lill Sheriff by a check made payable in Naaml Nash, for an unlawful purpose, and with the intent of depriving, the Committee To Reelect Victor I-Iill Sheriff madam from said l?unclt. lg On or about November 14,2011, Victor Keith Hill did in Clayton County, Gemrgia this: offense of THEFT BY in that VICTOR KEITH HILL did unlawfully take $7,000.00 from tht: Cninmittee T9 Re?ect Victor I?Iill Sheriff by a check made payable to Southern Resources. for an unlawiitl purposc, and with the intent {1f depriving the. Canimittee To llaelect Victor l-lill Sheri ff amount from said funds. .15; . - On or about June 6, RBI 1 Victor I?iaith I-Iill did in Clayton Cowl Georgia commit the offense of THEFT BY in thal VICTOR KEITH HILL did unlawfully italic 21 $25,000.00 check mack: pay ahlc to Victor Hill for the purpose oi? a campaign contribution and by depotilliitg gaid check into his personal checking, amount, with the intent of depiiving the; Committee: To Radiant Victor l-lill Sheriff account'fmm said fund?. 18 From: . ID: Pagezma $95 02 03 PM Pill/28 rhel??a ahepherd 77047733d2(. COUNT :3 it of the State: d'l? Gemglm do hereby chargr: and 36611361 On behalf of citizen THEFT BY TAKING for that the said aucusxsd batman tha day at" June, 2008., and the: day of June, . 2003, the exact date: ofthc effenae: baidg unknown to tho Grand Jury in Clayton County, Gearg'ta, than and time: with the edema of: my! said 'm of Clayton Can did take Unit?d States mummy. the unlawful taking being with the. intended of dcpriving Clayton Victm' Keith Hill did take said property while Sheriff 0f Clayton County, duties as such ef?car and employee; in vinla?nn 0" SAGA. 16 Wash afht taut?. tht: good murder, peace and dignity cfercnce, at: if fully set forth herein, Ct paragraph 121 cm page 8 of contrary to the. laws of thla Ell-alt:q Indictment i?c?rpom?tes by 1? Coiutt Five, of this Bill a the and gations set forth in ACTS RACKETEERLN Bill of Indictment. Tram thham Lawsan District Attorney Clayton Elupe?or Calm Nuvember Term, 19 Frum: 10: Jaw 19~E?tl? Paee??l?d 02134 ?ll rhellal ahepherd 7704773342. - Pl 21/28 COUNT 6 On behalf of the citizens of the State of Greou'gia1 do hereby charge and accuse: with the offense of: THEFT BY TAKING for that We said accused between the 6th clay of August, 2008August, 2008, the exact date 'of the offenne County, Georgiiu thon and there: being urdmown to the Grand Jury in Clayton dial unlawfully take 91 Clayton County Of?ce vel?ole, to wit: a. 2003 Ford Excursion, the property of Clayton County, said unlawful taking being with the intention of depriving Clayton County of the property; further, Violor Keith Hill did take S?ld properly while Sheriff of Clayton County, in breech of his duties no such of?cer and employee; in violation of O.C.G.A. 164341 contrary to ?ne lows of this State. lhe good order, peace and dignity thereof. Count Six of this Bill of? Indictment lnoomorntoe by reference, as iffully set forth herein, the allegations set forth in ACTS OF RAG Bill of Indictment. Clayton Superior Court November Tenn. 201 J?Helg-Egia From: paragraph 11) on page 3 of this Tracy Graham Lawson District Attorney 10 ID: Pa983881 R5962 02:04 on rhe?ua .ahepherd' immune - 13.22/28 COUNT 7 On behalf of the eitivene ol? the State of Georgia, do hereby charge and accuse: moron KEITH HILL with the offense of: THEFT BY TAKING for that the said accused on or about the 6th day of August, 2008 in Clayton County, Georgia, then and there: did unlawfully take that from the Clayton Gaunt? gas pumps, the property of Clayton County, eeicl unlawful taking being with the intention of depriving Clayton County of the propeity; further, Victor Keith Hiil cit cl take suiti property while Sheriff of Clayton County, in breach oi?hiu dutiee as such officer on employee; in violation of O. .G.A. 16-3-2 contuu?y to the lows oi" this titete, the good order, peace and dignity thereof. Count Seven of this Bill of indictment incorporates by reference, ue if fully set forth herein, the allegations set forth in ACTS OF MCKETEERTNG on page 8 of thie Bill of Indictment. Clayton Superior Court Tracy Graham Lawson NoVember Term, 201 1 District Attorney 21 Fil?ie 198918 BE: ESPN Fr Cunt: ID: Page: BEE I 02104 ?ll ahepherd 7704773342{. COUNT 8 On hehalf ot?tha citizens of the State 'til? Georgia, d0 hereby charge and HILL with the offense of: THEFT BY TAKING for that the said accused an or about the 7th clay of August, 2008 in Clayton County, Georgia, then and there: . - - . did unlawfully take 62.63 in United States currency, the property of Clayton Gauntyt said unlaw?il taking being with the intention of depriving Clayton Ceunly at" the property; further, Victor Keith Hill tlid take said property while Sheriff of Clayton County, in breaeh el?hle duties as such of?cer and empleyee; in vielation (if 16~3e2 contrary to the laws til" thia State, the gnarl order, peace and dignity thereof. Gaunt Eight of this Bill at Indictment ineerporatea by reference, are it" fully set forth herein, the allegatiana set forth in ACTS OF RACKETEERING paragraph ld err page 8 ofthia Bill of Indictment. Clayton Superior Court Tracy Graham latwaoh Nevemher Term: 2101 1 District: Attorney 21 rim?1939312 From: treattssaa ID: R=9az Jaw?swore 02:04 on rher?? shepherd 77047733421 9.24/st COUNT 9 On of the citizens of the State ot? Georgia, 'do hereby charge and sou use: I vroroR?Ksm-n-ULL with the offense ot?: THEFT BY TAKING for that the said accused on or about the 7th day ot? Allerguste 2008 in Clayton County, Georgia, then and there: - . (lid take $42.59 in United States currency, the property of Clayton County, said unlaw?ll taking being with the intention of depriving Clayton County oftho property; further, Victor Keith Hill did take said property white Sheriff: of Clayton County, in breach of his duties as such of?cer and employee; in violation of O.C.G.A. S, 16-8-2 - contrary to the tows?of this State, the good order, peace and dignity thereof. Count Nine of this Bill of Indictment incorporates by reference. as if fully set forth - hereto, the allegatimts set forth in ACTS OF paragraph-1e on page 8' of this Bit] ol? Indictment. . Clayton Superior Coort 1 Tracy Graham Lawson November arm, 201 - District Attorney 23 smog-Bole I2:33Ptvt' Front: 77134773348 ID: ems-A an 770477334?m I - COUNT 10 On behalf 0f the citizens of the Stat: of Georgia, do hereby charge and accuse: VICTOR with the off?nseof: BY TAKING A for that the said accused on or hhoul the 8th day of August, 2008 in Clayton County, Georgia, men and there: did unlawfully take $500.00 in United States currency, the property of Clayton County, said unlawful taking being with the ln?tch?on pf depriving, Clayton County of the property; View Keith Hill did take said while: Shariff of Claylml County, in breach 'ol'hl's duties as such a?oat and employee; in violaticsn t} 1633-2 - - . to the laws olflhis Shalmhe gonad antler, peace and dignity lhereol". (30th Ten of this Bill of Indictment incorporate? by fefarencc, :15 ll Rally set forth herein. the allagations sat forth in ACTS OF RACKETEERING paragraph 11' on page. 9 of this Bill of Indictment. . Clayton Superior Court - . . Tracy Graham Lawson member Tenn, 2011 - Math 01, Niamey 24 J?Nri?Sm??i?B Frurn: 7?@4??3342 .ID: . Pageuaas 2:952 02154 PM ?17} La allepllet?cl 7704773342. 28/26 COUNT 11 On behalf of the eltlzens of the State at? Georgia, do hereby charge and accuse: I with the el?fenee of: THEFT BY TAKING for that the said accused on or about the day of August, 2008 in Clayton County. Georgia, then and mere: did take $142.63 ln United States currency, the pteperty of Clayten County, said unlawful taking being with the intention of depriving Clayton Cetmty of the pt?bperty; further, Victor Keith Ilill did take said pt'ctpe?y while Sheriff of Clayton County, in breach of his duties as such ef?eer and empleyee; in violation of 0.0.6 .A 16?8?2 eentraty to the laws of this Stete,t11e good orde1~,peaee and dignity thereof. Count EleVen of this Bill at? Indictment itteer poretee by reference, as if fully set herein, the allegatiens set forth in AC Yb 0F RACKETEERING paragraph lg on page 9 01" this Bill of indictment. Clayton Superior Court Tracy Graham Lemon November Term, 2011 Distriet Attorney 25 J?llnl?a?a?le From: 77134773348 ID: PagetaEEr R=95x 02105 on rhotlla ahepherd .7704773342t. . . . F. 1/26 COUNT 12 On behalf of the citizens of the State ol'Georgia, do hereby charge and accuse: VICTOR HILL with the offense of: THEFT BY For that the said between the 25m clay of August, 2008, and the 2nd (lay of September, 2008,1zhe exact date ol?the offense being unknown to the Grand Jury in Clayton County, Georgia, then and there: dlL'l unlawfully take 21 Clayton County Office vehicle, {0 Wilt a 2003 Ford Excursion, the property of Clayton County, eoicl unlawful taking, being with lho intention l? depriving Clayton County of the property; further, Victor Keith Hill did take said property while Sheliffof Clayton Colmtya in broaoh of his dotiee as such of?cer and employee; in violation of O.C.G.A. 16-3"? contrary to the laws ofthis State? the good order, peace mid dignity thereof. Count Twelve of thie Bill of Indictment incorporates by relevelled:1 as: if fully set forth herein, the allegations set forth in ACTS OF RACKETEERIHG paragraph on page El of this Bill of Indictment. Clayton Superior Court - ?l?rooy Gmham Lawson November Tenn, 201 1 Dietriol Attorney 26 J'Rl?lei?B?E?Elie From: ID: Paee?ZiBi 02105 fill ahepherd CDUNT 13 7704773342 . P. 2/ 2h . - On behalf of the: oilizono of the Stato?ol? Ifiiesotgioq do hereby chorgo and accuse: VICTOR KEITH mm with the} offense ol?: THEFT BY TAKING for that the: said accusod hotwoon the W511 day of September, S?lli?mlh?l', 2008., the 67:31 date of the being unhnt "Clayton County, Georgia, ?ton and there: am unlawfully tithe a Clayton Comty Shoi'it 0 Nice vehiclo, Charger, tho property of Clayton County, said uni awful taking 2008, and tho 11th day of wn to the Gram Jury in to wit: a. 2006 Dotlgo being with tho intontion o? dopriving Clayton County oftho property; Further, Victor Keith Hill did take. said propmty while. Sheriff of Clayton County, in brooch ofhis dutios as high officer on employee; in violation of ll 16-8-2 contrary to tho laws of this Static, the good order, peace and dignity thereof. Count Thirtoon ol?this Bill of Indictment inoomm-aloo by rotorenoo, as. if fully set forth herein, the allegations sotfoith in OF RACKETEERWG of this Bill of "Indictmont. Clayton Superior Court November Town, 2011 27 JEN-lg-Eai? From: 7784773348 ID: paragraph ti on page 9 Ttaoy Graham Lawmtt District Attomoy 02305 ?ll rhetl-a ahepherd 7704773342 3/26 - i COUNT 14 On behalfof the citizens of the State of Georgia, do hereby olnngo and accuse: - . VICTOR HILL with the offense of: . Tl-lEF'l? BY TAKING for that the gain accused on or about the 10th day oi" Soptonlbor, 2003 in Clayton County, Georgia, than and thorn: . did unlawfully take tool from the Clayton County fool pumps, tho property of Clayton County, said unlawful taking being with the intention ol?doprlving Clayton County of the property; Eutthon Victor Koitlt Hill did take: said property while Sheriff of Clayton County, in breach ol?his; dutios as such officer and employoo; in violation of O.C.G.A, 1 6?8~2 - . to tho lows of this State, the good order, 13an and dignity thereof. Count Fom?toon of this Bill of incl ictlnont incorporates by reference, as if fully not forth heroin, theallcgatiousa not truth in ACTS 01" RACKETEERING paragraph lj on page 9 of this Bill of Indictment. Clayton Superior Court Tracy Graham Lawson Novomhor Tenn, 20] . District Attornoy 28 From: ID: Page:@@3 9:952 02105 ?ll rheLl-a ahopherd 7704773342; r. 4/28 0n bolral'l?oftho cltizono of the Store: of Georgia, do hereby charge and VWTOR KEITH HILL with the offense of: THEFT or warm for that the said acousod on or about tho 10th day of ptomber, 3008111 Clayton County, - Georgia, than and there: . did unlawfully take $58.91 lo United States o?rronoy, the property of Clayton County, said unlawful taking liming with tho inton?ou of depriving Clayton County of the property; fu rthor, Victor Kolth llill di (1 toko said property while Shorlff of Clayton County, in broaoh of his ouch officer and omployoe; in violation of 1 $34.2 contrary to the laws of this Slalol the. good order, peaco and dignity thorool'. Coun?t b?i'ftoon ol?thls Bill of Indictment inoorporotos lay reference, as if fully set forth 0F heroin, the allegations sot limb. in N..- of this Bill o-l?lndiotmoot. Clayton Suporior Court November Torin, 2011 JRHvi?El?E?Ejla oozeopm From: rro?roaqa RACICETEHRING paragraph 11: on page 10 ?l?raOy Graham Lawson Distrlot Attorney 29 ID: Paoe:E?E34 02505 EN rhehia ahepherd f. . - P. 5/28 COUNT 16 On hehalf at? the citizens: {3f the State: of Gem?gta, do here and accuse: with the offense 01". VICTOKKEITH HILL THEFT BY TAKING - for that the said accused on or about the 11th day of Septemhsr, 2008 in Cluytan County. Gem?gia, than and them: did take $70.37 in United States mummy, the; property of Claymn ?aunty, said tmiawful taking being with the: intention of depriving Claytnn County 01" the pmperty; further, Victor Keith Bill did take said property whim Sherift?of Clayton County, in breach ot?his dutica as gush ef?car and cmployea; in violation of 0.0.6 .15.. 16-3?2 contrary to the laws of this State, thes good order, peace. and dignity thetaot?. Couht Sixtecm of this Bill of Indictment by reference, as if fully am i?oxth herein, the. allegatimw tat forth in ACTS OF RACKETEERING paragraph 1! on pagcl? nfi?his Bill of Clayton Superim Court November Term, 201 I 19-3'13 From: 7734773348 ?l?racy Graham Lawson Ditlrict Attorney 30 ID: Rzgez 02:05 ?ll rhell-a ahepherd 7704773342.": COUNT 17 On behalf of the citizens of the State of Goorgia, do hereby olmxge: and acouso: VICTOR KEITH HILL with tho offense of: . moor BY memo for that the said accused between the I 5th day of Septembcn 2008, and the: 16th day of 2008, the. exact date of the offense home, unknown to the Grand Jury in Clayton County, Georgia. then and thore; did unlawfully lake a Clayton County Shoriff?g Of?ce vehicle, to wit: ?12006 Dodge . Charger. tho property of Clayton County, oafd unlawful taking being with the intomlo?n of depriving Clayton County ofthe propo?y; further, Victor Keith Hill did. take; Said property while Sheriff of Clayton County, in breach of his duties as such of?cer and employee; in violation of: O.C.G.A. i3 16-84 . contrary to "the lows of 111115 Statel tho good order, peace and dignity thereof. P. 6/26 Count Seventeen 01' this Bill of lndlotmont incorporates by reforemo, as if fully sot forth heroin, the allegations act forth in ACTS OF RACKETEERENG paragraph Im on page 10 of this Bill of lndiotmont. Clayton Superior Court ovombor worm, 201 19-8812 From: 77814773348 Tracy Graham Lawson [3 lstriol Altornoy 31 ID: Raga}: 02:05 ?ll rhella ahapherd COUNT 18 7704773342?- P. 7/28 Oh behalf of tht: aitizans of tllf: State of Georgia :10 hareby charge and assure: VICTOR KEITH 1-K with the offensa 0f: THEFT TAKJNG for that the said amused between tha 20th day of September, 2008September, 2098, the exact date 0f the offense being unknown to the Grand Jury in Clayton Georgia, thananrl that's: did m?awfully take a Claytun County Sheriffs Of?ce whistle, to wit: a 2006 Dodge: Chargar tin: pl?op?rty of Clayton Cihunty, said unlawful taking being with intention 01" depriving Clayton County of' the Victarli'eith Hill did take said property while. Sheriff of Clayton County? in breach of his duties as such officer and employee; in violation of O.C.G.A. {3 16-84 contrary t0 the: laws O?I?thls State, the good order, peace and digully llrercof. Count Eightaan of this Bill of Indistment incorporates by ralbrehcc, as il? fully set farm herein, the allegatiuns sat fourth in ACES OF RACKETEERIHG paragraph 111 on page 10 ul? this Bill of Indictment, Clayton Superior Caurt November Term, 201 1 32 JEN-igr??la From: 10: Tracy Graham Lawson Attorney Page R3952 02:06 go rhette ahepherd . COUNT 19 770477334g . P. 8/28 On behalf of the citizens of the State of Georgie, do hereby charge and ammo: VICTOR. KEITH HILL with the offense of: THEFT BY TAKING for that the sold between the 31 at day of Oetohetg 2008, and the 5th day of November, 2008, the exeet date of the offense being unknown to the Grand Jury in Clayton County, Cleotgle, then and there: (lid unlawfully take Clayton County Sheriffs Of?ce vehiole, to wlt: a 2006 Dodge Charger the property of Clayton County, said unlev?ul taking being with thetotention of depriving, Clayton County ol? the property; further, Victor Keith Hill (lid take said property while Sheril?l' 01? Clayton County, in breach of his duties as such of?cer and employee; in violation of O.G.G.A, 16-8-2 Count Nineteen 01? this Bill of Indictment incorporates herein, the allegations set forth in of this; Bill of Indietment. Clayton Superior Count November Term, 2m 1 33 From: 77134773342 ID: by reference, a3 if fully set forth CTS OF paragraph 10 on page 10 Tracy Graham lemon District Attorney Page Bee Far-95'2- 02106 Pill rhella ahepherd l- 770477 3342i P. 91' 28 COUNT 20 On behalf of the citizens of the State of Georgia, do hereby charge and accuse: with the o?'enee of: mm KElTl-l HILL BY TAKING for that the said access-ed between the 4th day of April 2.007, and the Met day of December, 2008, the exact date of the offense being unknown to the Grand my in Clayton County, Georgia, then and there: with the intention of deprwing Clay did unlawfully take the of Clayton County Sheriffs employee Jonathan Newton, the preperty of Clayton County. by while said employee was tan?duty on County, to work on a book. that Viol directly or indirectly ordering Jonathan Newton, :1 while said employee was being paid by Clayton 31' Keith Hill was writing, said unlawful taking being . ton County of the property; further, Viemr Keith l-lill did take said prope?y while Sheriff of Clayton County, in breach othie duties as such o?ieer reed employee; in violation 01 Q. Lem. mes-z contrary to lhe laws of this Stole, the good order, peeoe and dignity thereof. Count Twenty of this Bill of Indictment of this Bill of lndlelmont. Clayton Superior Cowl; November Tenn, 2011 From: lneor?pomtee by reference, as if Fully set forth herein, the allegations set forth ln OF paragraph 1p on page 11 Traey Graham Lawson District Attorney 34' ID: mom?201203067771 rheoa ahepherd 7704773342 Pill/28 I. COUNT El On behalf ol? the citizene of the State of Georgia, do horoby charge and accuse: . VICTOR Kent-I HILL with the offense of: THEFT BY TAKING "For that the rigid accused between the 4th day of April, 2007, and tho 6th day of Aug??h 2008, the exact date ot?the offense being unknown to the Grand July in Clayton County, Georgia, then and there; . did unlaw?illy the sowioes'of Clayton County Sheriffs employee Jonathan Newton, the: proporty of Clayton County, by directly or indirectly ordering, onotheh Newton, while eaid employee was onjduty and while said employee was: being paid by Clayton County. to perform work on Victor Keith Hill's reelection campaign, said unlawful taking being with the intention of depriving Clayton County oftho property; further, Victor Keith Hill {lid take tho propelty while Sheriff of Clayton County, in breaeh of his duties as such of?cer and employoe; in violation of 0.116.731. 16~8~2 contrary to the laws of this State, the good order, peace and dignity thereof. Count TwentynOue of thlo Bill of indictment incorporates by reference, as il? fully set forth herein, the allegations: set forth in OF RACKETEERJNG paragraph It; on page ol?thlo Bill ol?Indiotmont. Clayton Superior Court - . . . Tracy Graham Lawson November Term, 201 1 Distriel Attomey From: ID: I 'Paoe:lil? [53:96? 02:03 HM rhetla ahepherd . 7704773342! . P. 11/26 COUNT 2?2. On behalf ofthc citizcns 6f the Slate Qt?Georgia; do hereby charge and accuse: VICTOR KEITH with the ?ffenm: of: THEFT BY TAKING for that the said accussd on of 6:130 Georgia, than and there: it the 19th day of May, 2007 in Clayton Caunty. tlid unlawfully take tha services 01" Clayton County Sheriff?s Difficu- employees and Clayton County Slietil?FS Of?ce of participating 111 a Committee t9 Victor Hill Bllcer?s Festival depriving Clayton County of?the prnp?rty; 1311:16165: the propeity 0f Clayton Co unty, l?ot ?(ha purpose Reeloct Victor Hill fundraising event Entitled "Sheriff 5 said unlawlul taking being with the intention of [hrthiers Victor Keith Hill did take said proparty while Sheriff Lil?Claytmi County, in breach of hisduties as such office? and . employee; in violation of its-m mutt-my tn the: laws of this State, the good wider, peace and dignity theredf. ?aunt Twanty-Two of this Bill of Indimtma nt incorporates by re?l?ht?cnce, as if fully set faith herein, the, allegations Set forth in ACTS OF RACKETEERING paragraphs 11? on page 11 of this Bill of Claymn Superim? Court Novomher Tami, 201 "amaspm me: T78477334E Tracy Graham Lawson Digitict Attmuoy 36 13? Pagemti 12:95:; man?201202th rhetta ahepherd 7704773342. 12/26 l- COUNT 23 I Dr: behalf of the eitizene of the State of Georgia, do hereby charge and accuse: A we.romterri-1 met. with the offonae of: THEFT BY TAKING for that the said accused on or about the 19th day of May,- 2007 in Clayton County, Georgim then and there: did unlawfully take Clayton County Sheriffs Of?ce vehieleei the property, of Clayton County, for the pul'pus? ot? pettioipeting in a Committee to Reeleot Victor Hill event entitled ?Sheriff Victor Hill Biker?s Festival 2007.,? eaid unlawful taking being with the intention of depriving Clayton County of the property; further, Victor Keith Hill dict lake said propotty while Sheriff o'l?Claytoh County, in breach of his duties as such of?cer and employee; in violation of D.C.G.A. 16-3?2 - contrary to the lows of this Slate), the good order, peace and dignity'ihereol?. Count. Twetrty?fltree of this Bill of indictment locorporeleo by reference, as if fully set foxth herein1 the allegations set Forth in ACTS OF RACKETEERTNG paragraph Is on page 11 of this Bill oflntiietment. . Clayton Superior Court Tracy Graham Lawson November Term, 20! District Attomoy 37 From: 778%??3348 - ID: Paoeil?la [12103 77047i33?12t P1 13/28 denoted On behalf of the oitizene of the State of Georgia, do hereby charge and neenee: l-llLL With the unease of: THEFT BY TAKING for that the said accused on or about the 17th day of September, 2007 in Clayton County, Gentgin, then and there: did unlawfully tolte the newleeo of Clayton County Sheriffs Of?ce employees and Clayton County Sherilz't?e Of?ce vehicles and equipment, the property of Clayton County, for the purpose of participating in a Committee to .Reeleel Victor Hill fundteieing event entitled "The 2007 Sheriff Victor Annual Golf staid unlawful Being, with the intention of depriving Lloyton County of the property; further, Victor Keith Hill clid take said. property while Sheriff of Clayton County, in breach of his duties: as soon officer and employee; 1n violation of {t ln?Rnl. contrary to the lows of this State, the good order, peace and dignity thereof. Count Twenty?Four ofthis'lilill of Indictment inotnpotntes by reference, as if fully set {oath herein, the ellegotione eet?fovth in ACTS OF MCKETEERTNG pntogteph It on page 11 of. this Bill at" Indictment. Clayton Superior Court ?l?reey Graham Lawson November Term, 2011 District Attorney - 33 From: to: P51951313 9:952 13.14/28 1704173343, @2108 PM rhehia ahepherd i he 17th day of Sepiambet,1007 in Clayton Caunty, with the (?ange of: for that the t'?d accused am at abo ut Georgia, than ?nch. 1:11 We 0 "use whims mam did uniawfu'ny ml?: cClaymn Clayten Co 11 an of?cial 113:3, the mommy 0? m? ale Victor Hill fundrais'mg we 11 aw arti?ipa?ngin naCom 1.311 10G o'lf imummen ea arty; such af?cer an ?z?nheritt ictor 1 1* yum Comma at the prop intention ol? depriving a said property iff of Clay vtna nCou unty,n in wnla?o? of . . .. .16 41?1 the 1:,st 0f this ?the gem}. order, peace and dignity thereof. ingot tpm?ates bray We anus, *013 EERIHG pam'gr sanitary to RACKETE 1? bf In ply?F: m3 at this. tt'or in Count minus ?at as if fun}; set aph into on fm th herein, 161wa1 ?21 of this Bill of Indictment Trac 3 Graham Lawson page I - District Niamey mCou?; Claytan Supe? 201 1 November Term, 39 7784773342 ID: aa?eaPM me. Paaenaiz} town-?2012 02:06 All rhetla ahapherd COUNT 26 7704773342l P. 15/28 On behalf of the citizens of the State of Georgia, do hereby charge and VICT OR KEITH l-llLL with the offense ot?: THEFT BY TAKING. for that the gold accused on or about the 7th day of April, 2008 in Clayton {3013?th Georgia} then and there: unlawfully take United States currency, the pt?operty of Clayton County, from the Clayton Comtty Sheriffs Of?ce DEA Shared Alt-sets a Advantage Ful?llment Services, ltte. knowing that sol mount by check made payable to til eheelt exceeded the invoice ??om Advantage Ful?llment Sewlees, too, said unlawful taking, being with the intention ot depriving Clayton County of the property; further, Viptor Keith did take said property whlle Sheriff of Clayton County, in breach of his duties as sueh officer and. employee; in violation ol? O.C.CJ.A 1 eoottary to the laws of this: State, the good order, peace and dignity thereof. Count Twehty-Slx of this Bill of Indictment incorporates by reference, as if fully set forth herein, the allegations set t'ottlt A of this Bill of Indictment. Qlayton Superior Coutt November Term, 201 40 From: 7794773348 ID: CTS OF RACKET paragraph lv on page 12 Tracy Graham Lawson District Attorney Page E15 R2952 02:07 RN rhefha ahepherd COUNT 2'7 77047'73342{ P. 16/28 On behalf of the oitizono of tho Slam of Georgia, do hereby charge and amuse: VICTOR KELTH HILL with the offense of: THEFT BY TAKING for that tho said. accused. on or about the 29th day of May, 2003 in Clayton Bounty, Georgia: than and. them: did unlawfully take United States ourronoy, tho property of Clayton County, from the Clayton County Sheril'l?s' Of?ce Gonoral Lodger Advantage Ful?llmont Services, Inc. knowing that sai along hoiog, with the intonlion otor lioith Hill did take sold A?vanlago Ful?ll mom: Sowioos, 1110.3 said unlawful depriving Clayton County of the propouy; Further, Vi out by check mado payrolls]: to chock tho invoice from property while Shoril?l' of Clayton County, in breach of his duties as such oi??cor and employee; in violation of O.C.G.A. 16?3-2 contrary to the lowo ofthis State, tho good order, peace and dignity thereof. Count Twonly~Sovon of this Bill'of Indictment inoorpo 0 forth herein, the. allegations sot forth in ACTS 11th 12 of this Bill of Incliotmeot. Clayton Superior Court Novomhor Torm, 201 41- Fimmi T7o4?73342 ID: ratoo by roforonoo. as if fully sol MCKETEERTNG paragraph 1w on Tracy Graham Diotricl Attorney Page:816 R2952 rhetlaaheph a - #70477 . (. er 334%. P. 17/28 COUNT 28 On belmll?of the citizens 0f the State (If Geargia, do charge and accuse: HILL with offenae of: THEFT BY TAKWG 1hr that the. said amused on or abcaut the 3rd day ofOctober, 2003 in Clayton County, Georgia, than and there: . . (lid take United States currency, the. property of Clayton County? from the Clayton County Sheriff?s Di?l?ica Forfeited Manny account by pluck made payabls to Advantage Ful?llme?t Servicess, Inc. knowing that said check thr: invoice ?l'mm Advantage Ful?llment Services, lath, sald'unlaw?ll taking being with the lutentl?n of depriving Claylnn County of the property; further, Victnf Keith Hill did take said. px'mparty while Sheriff 13f Claymu County, in breach ofhis duties as such nf?cer and employee; in violation 0f Q.C.G.A. 1643-2 contrary to tha laws of this State. the gnocl order, prance and dignity tllm?aaf. Gaunt ?l?wcmy?Eight of this Bill of Indictment incoxporateg by rel'arcnca, as: if fully set forth harem, the allegations set forth in ACTS OF RACKETEZERENG paragraph 131 on I page 12 of this 8111 of?lndictment. Clayton Supcrim' Cnurt Tracy Graham Lawson Nummber Term, 2911 ?5511501 42 From: 77134773348 ID: - Page:817- R3355: 02:07 i .. - . Fill rhe(tia ahepheld 77047733421." Rig/28 COUNT 29 On behalf oi?tlm citizans of the State of Gdiirgia, dc hereby charge and accuse: KEITH HILL with the ol?fensa (if; THEFT BY TAKING far that the said accusad betwaen thr: 9th day miAilgiist; 2008, and the 19111 day of S?pt?mb?l?, 2008, the exact date of the offense lacing unknown to the. Grand Jury in Clayton County, Gmorgia, ihcn and time: did unlawfully take, United States currency, th? property of Clayton County, by ordering directly or indiractl that Beatrice Powell be placed on paid administrative leave, said tmlawfui taking 136ng wi [11 the intention of depriving Clayton Cuuhty of the prilpcirty; Victor Keith Hill did take said pf?p?l?ty while Sheriff" of Claylun County, in breach of his dutieis as such al?t?icer and employee; in violation of OSHA. {4 168?2 . Contrary In the laws of this State, the gnod ordain. peace and dignity thm?cof. ,Cmmt weniy-Nine of this Bill of Indictmant incorporates by reference, as if fully set forth herein, the allegaticmsi get fed]: in ACTS OF RACKETEERNG paragraph 13; on page 12 of this Billoi?" Indictment. - Clayton Superior Court Ti'acy Graham Lawsnn NOVEITIIJGE Tarn?, 2011 District Attorngy 43 Frum: ID: Panei?l? R2963 02:07 till .h in I at ahepherd 7704773342l. - p. 19/25 COUNT 30 On bah-alt" 01" the citimns ?fths State ot'Gcorgia, (to hershy charge and accu?r-J: KEITH HILL. with tll??ff?n?? of: THEFT BY TAKING for that the said accusad hatween the 20th day of September, 2008: and this 19th day (if Novamher, 2008, the exact date ofthe offenae being unknown to the Grand Jury in Clayton County, Gem-gia, then and there: did unlawfully take United States amenity, the pmpe?y of Claw-011 Countyi by ardcring directly or that Bcalri?t} Powell he placed on sick leave,-said unlawful taking haing with the. intantion of depriving Clayton County of the furthar, Victm' Keith Hill did take said pmperty while: Sheriff of Claytrian County, in bt?cach of his clutias a: such officer and employee; in violation of 0.0.G.A. 16-8-2 contrary to the laws of this State, the good order, peace mid dignity thereof. Count Thirty of this Bill of Indictment incorporates by refarancag. as if fully sat forth herein, the. allegations Set faith in ACTS OF RACKETEERING pamgraph 12 on page 13 ofthis Bill of Indictment. Clayton Superior Court Tracy Graham angon Novamber Term, 20] 1 District Attomay 44 Jaw-tweme as: I . 86PM Fl om ID. P3193819 [2:952 02:07 Hl?l rhelbla ahepherd. 7704773344? COUNT 31 On behalf of the citizens of the State afGeorgia, do hereby charge and. amuse: VICTOR HILL with the offense of: MAKING A FALSE STATEMENT for that the said accused between the 8th clay of August, 2008, and tha 19th day of Saplernber, 2003, the exact date of the offanss being unknawn t0 the: Grand ury ln Claytnn Cnunty, Georgia, than and that's: solicit, cause, and knowingly allnw Clayton Gaunt}: Sheriffs Of?ce employees to falsaly statc on 91 Clayton County Sheriff's Office amployee paymll record that Baatricc Powell was on paid administrative leave thereby kmwin g1}; and willfully making a false, ?attens, and frauduiiant statement and reprcsenta?on in a matter within the jurisdictinn of the: Clayton County Sheriff?s Offica, a department ot?a political subdivision of this State in vialation of 0.13.6.A. 16?10-20 contrary to laws ofthis State, thr: good order, peace and dignity Gaunt Twanty-Nine of this Bill of Indictment incorporates by reference, as if fully sat forth herein, the allegations act forth In ACTS OF MCKETEERING paragraph Zn on page 13 of this Bill of indiclmant. Clayton Sup?ri?t Court Treaty Graham Lawson Nav?mber Term, 20? District Atturney 45? From: ?"f84??3342 ID: [351938213 Elf-963?? 02:0 . 7 an 'ahepherd 7704773342t P. 21/28 COUNT 32 0o behal i? of the citizens oi?tlto State of Goorgia, do hereby charge and mouse: VICTOR KEITH HILL. with tile offense of: MAKING A FALSE SPATEMENT for that the said ?c?ttS?tl botwoon the: 3th day of Auguot, 2608, and the 19th day of . Septembor, 2008,. the: wool date of tho offense boing unknown to tho Grand my in Clayton County, Georgia, thou attci there: solicit, goose, and imowingly allow Clayton County Sheriff's Office employees to falsol 3 state. on 51 Clayton County Sheriffs; Of?ce employee: payroll that Beatrice Powell was on sick leave thereby lmowingly and willfully making in false, liotiouo, and ii?audulont Statement and roprosontation in a motto: within the jurisdiction of the Clayton County Sheriffs Of?co, a dopartmont of a political subdivision ofthis State in violation 161 - contrary to the lows ofthis Stato, the good order, peace and dignity thereof. Count Thirty of this Bill of Indictment incorporates by toforonoo, as if fully set forth heroin, the: allegations sot?forth in ACTS OF RACKETEERFNG paragraph on page 13 of this Bill of indiclmont. - Clayton Superior Court . Tritoy Graham Lawson November Term, 2011 District Attorney 46 From: 7?Ei4??3348 ID: ahePhei?d 7704773342f- [3.22/23 COUNT 33 On behalf oftho citizens oftho State of Georgia, do hereby change: and acousc: VICTOR KEITH HtLt. with the offense, of: THEFT BY TAKING to: that the said accusod on 01 about the 14th day of August 2008 Clayton County, .: Goorgta thou and thofo: . did unlaw?tlly take. $15,000.00,Itho property ot?the ownpaign deposit account for Committee to Rob-loot Sheri IT Victor Hill, with the intention of depriving said owner of said property in Violation 16-8?2 contrary to the laws of this Stato, tho good ot'dor, pcaoo and dignity thorco (30th Thirty?Ono of this Bill ot Indictment inoorpomtoo by reference, as if l?utly sot fotth horotn, the allegations set forth In ACTS OF IMCKETLEMNG paragraph on page 18 01 this Bill of [odiotmont . Clayton Superior Court Tl'ooy Graham Lawson November Term, 2011 . ?Diotrict Attorney 47 JoH~19?Eota oa:aePM From: ??o4??334a Io: Page: BEE a 7 0207777 141ng Kahepheld 77047733421 COUNT 34 - On behalf nl?the citizens of the State of Georgia, do hereby charge and accuse: VICTOR KEITH HILL with the offensa: of' THEFT BY TAKING for thal said accused on or about the 14th day ol August 2008' _171 Clayton County, Gam?gia then and thelea'_ {lid 11:21antu take 000. 00 the {3101361131 01' the campaign daposit account for Committae tc? Racket Sheriff Victor Hill, said unlawful taking being with the intention of depriving Clayton County ofthe propelty; Further, Victm Kaith Hill did take said pmperty while Sheri of Clayton County, in breach of his duties as such affine-r and employee; in violation of 16-8v2 . contrary to the laws afthia Slate, the gaod order, peanut: and dignity therepf. Count l-rty -Twu of this Bill oflndictment incorporates by Imel'emnce as it fully sat fol-711 1161:3111 the allegations set forth in ACTS OF RACKETEERWG paragraph on page 13 of this Bill Indictment. . Clayton Super} 01' Court I Tracy Graham Lawson Nevember Tenn, 201 1 District Attorney 48 From: 7754773342 ID: I 9:793:82? Rzasz 02:07 Fill ?1qu ahepherd . 77047733? COUNT. 35 On hehalfol?the citizells ol" the State of Georgia, db charge and accuse: VICTOR 1-1 HILL ?lth the of?ng: of: THEFT BY TAKING fm that the said accuaed 011 or about [he 6tl1day of June ROI 1 111 Clayton County Georgia 111511 and there: did unlawfully ['3ch $2,000.00, the property ofthe cmnpaign depoflit a?c?ut?lt FEW . Conunittce In Reelect Sheriff Victor Hill, saidunlawful taking balm}; faith the ultentmn of d?prlving Clayton County oi?thc propafly; Further, Victol' Keltll (lid talkie said property Whil? Slmriffol?Claytm] County, in breach of hm claims as such Of?cer and cillploycc; in violation of .A. 1643-2 contrary to the laws ?fthia State. the good order, peace and dignity thereof. Gaunt Thil ty-Fiw: ut?this Bill at ales hemin, the allegations set forth' in ACIS OF RACKETEERING pmagraph 11. an page 13 this Bill at Indicatment Clayton Superior Court Tina}: Graham Lawsnn Nl?avcmber Term, 201 1 Dismal Attorney 49 JRN?ia?Eaie E12: ESPN From: ??a4??33?4e ID: Page E324 [2:962 i . 2 08 HH rhefla ahepherd 770477334a. COUNT 36 On 13311211fo the citizens: 0f the Slate ol?Gaorgia, do hereby charge and accuse: VICTQR KEITH HILL with ?w Offense of: VIOLATION OF OATH BY PUBLIC OFFICER For that tha said accused batman The: [at day ofJanuary, 2007, and this 3131: day of . December, 2008, in Clayton (30th Georgia, then and there: Ewing Shcz'il?l?ef Clayton County, a public nl??cer and of?cial, and having previously been administered the Of?cial Oath of Sheriff as pras?ribed by law (OCGA 15-164)a lnpluding that portion of the Oath stating that he will "take only my lawful fees," Vicmr Keith Hill did willfully and intentionally violate the twins oftliia Oath by taking United . States cuwency, services, equipment, and vehiclazz oftlw Clayton County Sheriff?s Of?ce. fm' pumoscs unrelated to his of?cial duties; as Sheriff in violatinn of 0,663.14. 16-1 to the lam. o?his State, the guard order, peace and dignity tharenl?. Claytcm Superiqr Court. Tracy Graham?: Lawson Novamber 2011 - District Attorney 50 From: ID: . Pa BE I 535 R=95z 11.11111 773342;. COUNT 37 011 bellall? ofthe citizens oftha State of Georgia, do heraby charge and accuse: VICTOR KEIT 1-1 HILL with tlu: ol?l?ensc 01": INFLUENCING A WITNESS for 11mm said accused on or about the 3rd clay of September, 2011 in Clayton County, Gcorgia, than and there: with the intent to deter Naomi Nagh, a witness, from tastitying freely, fully, and truthfully to a matter pending in front ol?tlle Spacial Purpose Grand Jury 9f Claylnn County. did unlawfully offer and deliver servings 'of an attorney and assistance with personal 1213113 wliila said Naomi Nash was incarcerated in the Harold Banks Detention Center. E1 bene?t, 1'6Warcl, and cansiclcratinn, to said witness in 1Jinlation of 0.C.G.A. 16?10493 anntrary to the laws of this Slate, the good ord?lh PGEIGE and dignity thereof. Clayton Superior (301111 Tracy Graham Lawson November Term, 201 1 District Attorney 5 1 E12: 27PM Fran}: ID: Pa?e E186