Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Dec 27 2:06 PM-1808006309 0B080 - K43 The State of Ohio, SS Franklin County INDICTMENT FOR: Unlawful Securities Practices (ORC 1707.44) (F3) (7 Counts); Unlawful Securities Practices (ORC 1707.44) (F3) (2 Counts); Unlawful Securities Practices (ORC 1707.44) (F3) (2 Counts); Unlawful Securities Practices (ORC 1707 .44) (F1) (2 Counts); Grand Theft (ORC 2913.02) (F4) (1 Count); Unlawful Securities Practices (ORC 1707.44) (F2) (1 Count); Unlawful Securities Practices (ORC 1707.44) (F2) (1 Count); Grand Theft (ORC 2913.02) (F4) (1 Count); Unlawful Securities Practices (ORC 1707.44) (F2) (1 Count); Theft From a Person in a Protected Class (ORC 2913.02) (F3) (1 Count). Total: 19 Counts. Grand Jury Term Beginning September 14, 2018 Count One Unlawful Securities Practices, ?1707.44, F3 Defendants Jeffery Luke Westerman Date of Offense On or about January 1, 2014 to December 31, 2014 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about January 1, 2014 to December 31, 2014, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose to deceive, did make, record, or publish or cause to be made, recorded, or published, a report of a transaction in securities which was false in any material respect. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is seven thousand ?ve hundred dollars or more but less than thirty-seven thousand ?ve hundred dollars. Count Two Unlawful Securities Practices, ?1707.44, F3 Defendants Jeffery Luke Westerman Date of Offense On or about January 1, 2015 to December 31, 2015 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about January 1, 2015 to December 31, 2015, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose to deceive, did make, record, or publish or cause to be made, recorded, or published, a report of a transaction in securities which was false in any material respect. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is seven thousand ?ve hundred dollars or more but less than thirty-seven thousand ?ve hundred dollars. Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Dec 27 2:06 PM-180R006309 0B080 - K44 Count Three Unlawful Securities Practices, ?1707.44, F3 Defendants Jeffery Luke Westerman Date of Offense On or about January 1, 2013 to December 31, 2013 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about January 1, 2013 to December 31, 2013, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose to deceive, did make, record, or publish or cause to be made, recorded, or published, a report of a transaction in securities which was false in any material respect. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is seven thousand ?ve hundred dollars or more but less than thirty-seven thousand ?ve hundred dollars. Count Four Unlawful Securities Practices, ?1707.44, F3 Defendants Jeffery Luke Westerman Date of Offense On or about January 1, 2013 to December 31, 2013 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about January 1, 2013 to December 31, 2013, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose to deceive, did make, record, or publish or cause to be made, recorded, or published, a report of a transaction in securities which was false in any material respect. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is seven thousand ?ve hundred dollars or more but less than thirty-seven thousand ?ve hundred dollars. Count Five Unlawful Securities Practices, ?1707.44, F3 Defendants Jeffery Luke Westerman Date of Offense On or about June 26, 2015 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about June 26, 2015, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, did knowingly make or cause to be made a false representation concerning a material and relevant fact, in any oral statement or in any prospectus, circular, description, application, or written statement, for the purpose of selling any securities in this state. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is seven thousand ?ve hundred dollars or more but less than thirty-seven thousand ?ve hundred dollars. Franklounty 01110 Clerk of Courts of the Common Pleas 2018 Dec 27 2 06 8C 0 0 Count Six Unlawful Securities Practices, ?1707.44, F3 Defendants Jeffery Luke Westerman Date of Offense On or about June 26, 2015 to December 10, 2018 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do find and present that Jeffery Luke Westerman late of said County, on or about June 26, 2015 to December 10, 2018, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, did, in purchasing or selling securities, knowingly engage in any act or practice that was, in Chapter 1707, declared illegal, de?ned as fraudulent, or prohibited, to wit: used IRA funds for personal expenses. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is seven thousand ?ve hundred dollars or more but less than thirty-seven thousand ?ve hundred dollars. Count Seven Unlawful Securities Practices, ?1707.44, F3 Defendants Jeffery Luke Westerman Date of Offense On or about January 1, 2014 to December 31, 2014 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about January 1, 2014 to December 31, 2014, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose to deceive, did make, record, or publish or cause to be made, recorded, or published, a report of a transaction in securities which was false in any material respect. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is seven thousand ?ve hundred dollars or more but less than thirty-seven thousand ?ve hundred dollars. Count Eight Unlawful Securities Practices, ?1707.44, F3 Defendants Jeffery Luke Westerman Date of Offense On or about January 1, 2014 to December 31, 2014 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about January 1, 2014 to December 31, 2014, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose to deceive, did make, record, or publish or cause to be made, recorded, or published, a report of a transaction in securities which was false in any material respect. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is seven thousand ?ve hundred dollars or more but less than thirty-seven thousand ?ve hundred dollars. Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Dec 27 2:06 PM-18CR006309 0B0 8 - K4 6 Count Nine Unlawful Securities Practices, ?1707.44, F3 Defendants Jeffery Luke Westerman Date of Offense On or about January 1, 2013 to December 31, 2013 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about January 1, 2013 to December 31, 2013, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose to deceive, did make, record, or publish or cause to be made, recorded, or published, a report of a transaction in securities which was false in any material respect. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is seven thousand ?ve hundred dollars or more but less than thirty-seven thousand ?ve hundred dollars. Count Ten Unlawful Securities Practices, ?1707.44, F1 Defendants Jeffery Luke Westerman Date of Offense On or about January 1, 2014 to December 31, 2014 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about January 1, 2014 to December 31, 2014, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose to deceive, did make, record, or publish or cause to be made, recorded, or published, a report of a transaction in securities which was false in any material respect. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is one hundred ?fty thousand dollars or more. Count Eleven Unlawful Securities Practices, ?1707.44, F1 Defendants Jeffery Luke Westerman Date of Offense On or about January 1, 2013 to December 31, 2013 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about January 1, 2013 to December 31, 2013, within the County of Franklin aforesaid, in violation of section 1707 .44 of the Ohio Revised Code, with purpose to deceive, did make, record, or publish or cause to be made, recorded, or published, a report of a transaction in securities which was false in any material respect. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is one hundred ?fty thousand dollars or more. Franklin Co . OB08 0 K47 ty 0th Clerk of Courts of the Common Pleas 2018 Dec 27 2 06 PM 18CR006309 Count Twelve Grand Theft, ?29l3.02, F4 Defendants Jeffery Luke Westerman Date of Offense On or about November 18, 2013 to December 31, 2013 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about November 18, 2013 to December 31, 2013, within the County of Franklin aforesaid, in violation of section 2913.02 of the Ohio Revised Code, did with purpose to deprive the owner, Rocky Moody, of property or services, to wit: cash, knowingly obtain or exert control over either the property or services beyond the scope of the express or implied consent of the owner or person authorized to give consent. Furthermore, the property or services stolen is valued at seven thousand ?ve hundred dollars or more and less than one hundred ?fty thousand dollars. Count Thirteen Unlawful Securities Practices, ?1707.44, F2 Defendants Jeffery Luke Westerman Date of Offense On or about February 24, 2016 to August 31, 2017 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and'offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about February 24, 2016 to August 31, 2017, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, did knowingly make or cause to be made a false representation concerning a material and relevant fact, in any oral statement or in any prospectus, circular, description, application, or written statement, for the purpose of selling any securities in this state. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is thirty-seven thousand ?ve hundred dollars or more but less than one hundred ?fty thousand dollars. Count Fourteen Unlawful Securities Practices, ?1707.44, F2 Defendants Jeffery Luke Westerman Date of Offense On or about February 24, 2016 to August 31, 2017 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about February 24, 2016 to August 31, 2017, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, did, in purchasing or selling securities, knowingly engage in any act or practice that was, in Chapter 1707, declared illegal, de?ned as ?audulent, or prohibited, to wit: used IRA funds for personal expenses. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is thirty?seven thousand ?ve hundred dollars or more but less than one hundred ?fty thousand dollars. Frankl?n . CEO 8 0 K48 County Clerk of Courts of the Common Pleas 2018 Dec 27 2 06 PM 18CR006309 Count Fifteen Grand Theft, ?2913.02, F4 Defendants Jeffery Luke Westerman Date of Offense On or about February 24, 2016 to August 31, 2017 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about February 24, 2016 to August 31, 2017, within the County of Franklin aforesaid, in violation of section 2913.02 of the Ohio Revised Code, did with purpose to deprive the owner, Rodney Moody, of property or services, to wit: cash, knowingly obtain or exert control over either the property or services beyond the scope of the express or implied consent of the owner or person authorized to give consent. Furthermore, the property or services stolen is valued at seven thousand ?ve hundred dollars or more. Count Sixteen Unlawful Securities Practices, ?1707.44, F2 Defendants Jeffery Luke Westerman Date of Offense On or about January 1, 2014 to December 31, 2014 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about January 1, 2014 to December 31, 2014, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose to deceive, did make, record, or publish or cause to be made, recorded, or published, a report of a transaction in securities which was false in any material respect. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is thirty-seven thousand ?ve hundred dollars or more but less than one hundred ?fty thousand dollars. Count Unlawful Securities Practices, ?1707.44, F3 Seventeen Defendants Jeffery Luke Westerman Date of Offense On or about November 7, 2016 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about November 7, 2016, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, did knowingly make or cause to be made a false representation concerning a material and relevant fact, in any oral statement or in any prospectus, circular, description, application, or written statement, for the purpose of selling any securities in this state. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is seven thousand ?ve hundred dollars or more but less than thirty-seven thousand ?ve hundred dollars. FranklCounty 0 IO Clerk of Courts of the Common Pleas 2018 Dec 27 2 06 PM 18CROO6309 Count Eighteen Unlawful Securities Practices, ?1707.44, F3 Defendants Jeffery Luke Westerman Date of Offense On or about November 7, 2016 to December 10, 2018 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about November 7, 2016 to December 10, 2018, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, did, in purchasing or selling securities, knowingly engage in any act or practice that was, in Chapter 1707, declared illegal, de?ned as fraudulent, or prohibited, to wit: used investment funds for personal expenses. Furthermore, the value of the funds or securities involved in the offense or the loss to the victim is seven thousand ?ve hundred dollars or more but less than thirty?seven thousand ?ve hundred dollars. Count Nineteen Theft From a Person in a Protected Class, ?29l3.02, F3 Defendants Jeffery Luke Westerman Date of Offense On or about November 7, 2016 to December 10, 2018 The Jurors of the Grand Jury of the State of Ohio, duly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the State of Ohio, upon their oath do ?nd and present that Jeffery Luke Westerman late of said County, on or about November 7, 2016 to December 10, 2018, within the County of Franklin aforesaid, in violation of section 2913.02 of the Ohio Revised Code, did with purpose to deprive the owner, Lawrence Lubbers, of property or services, to wit: cash, knowingly obtain or exert control over either the property or services beyond the scope of the express or implied consent of the owner or person authorized to give consent. Furthermore, the victim of the offense is an elderly person, disabled adult, active duty service member, or spouse of an active duty service member and the property or services stolen is valued at seven thousand ?ve hundred dollars or more. Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Dec 27 2:06 PM-18CR006309 0B080 - K50 All of the above conduct being contrary to the form of the statute in such cases made and provided, and against the peace and dignity of the State of Ohio. Ron O'Brien Prosecuting Attorney Franklin County, Ohio A TRUE BILL William J. Davies, 0071072 Assistant Prosecuting Attorney #2 Foreperson, Grand Jury