RELED EN OEDEOE INDICTMENT 34 9 Clerk FULTON SUPERIOR COURT THE STATE OF GEORGIA 1: VIOLATION OF RACKETEER INF LUENCED AND CORRUPT ORGANIZATIONS ACT, O.C.G.A. BEVERLY HALL C1 1, 2, 3, 13 MILLICENT FEW Ct 1,19 SHARON DAVIS-WILLIAMS Ct 1, 6-8 TAMARA COTMAN Ct1,4 MICHAEL HTTS Ct 1,5 CHRISTOPHER WALLER Ct 1, 9-11, 16 GREGORY REID Ct 1,9, 14, 15, 17 SANDRA WARD Ct1,9, 11,12 STARLETTE MITCHELL Ct 1,9, 13, 14 KIMBERLY ODEN Ct 1, 9 ARMSTEAD SALTERS C1 1,20, 21, 23 SHERIDAN ROGERS Ct 1, 20,-22 DANA EVANS CI 1, 24, 25, 29, 31 ANGELA WILLIAMSON C1 1, 24, 32, 33, 36 DERRICK BROADWATDR C: 1, 24, 26, 29, 34 SHAYLA SMITH C1 1, 24, 26, 35 DESSA CURB Ct 1, 27, 30 LERA MIDDLEBROOKS C1 1, 37, 39, 40 SHANI ROBINSON Ct 1,37 PAMELA CLEVELAND Ct 1, 37, 43 DIANE BUCKNERNVEBB Ct 1, 37, 42 GLORIA IVEY Ct 1, 38,41 LISA TERRY C1 1, 44, 45 IN GRID ABELLA-SLY Ct 1, 44-46 AIETED 45, -17 LUCIOUS BROWN CI 1, AS, 49 CAROL DENNIS Ct 1, 43 TAMEKA GOODSON Ct 1, 68 TABEEKA JORDAN Ct 1, 59, 51 CLARIETTA DAVIS Ct 1, 52-54 DONALD BULLOCK Ct 1, 55-58 TI-IERESIA COPELAND Ct 1, 60, 61, 62 SHEILA EVANS Ct 1,59, 60, 63 WILLIE DAVENPORT Ct 1, 64, 65 FRANCIS MACK C1 1, 65 2: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-19-29 3: THEFT BY TAKING, O.C.G.A. ,9 16-3-2 4: INFLUENCING WITNESSES, O.C.G.A. 16-10-93 5: INFLUENCING WITNESSES, 16-10-93 6: FALSE STATEMENTS AND WRITINGS, 16-10-29 7: FALSE STATEMENTS AND WRITINGS, 16-19-20 8: FALSE SWEARING, o.c.G.A. 16-10-71 9: FALSE STATEMENTS AND WRITINGS, 16-10-20 10: FALSE STATEMENTS AND WRITINGS, 16-10-29 11: FALSE STATEMENTS AND O.C.G.A. 16-16-29 12: FALSE STATEMENTS AND O.C.G.A. 16-19-20 13: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 14: FALSE STATEMENTS AND WRITINGS, 0.C.G.A. 16-10-20 15: FALSE STATEIVENTS AND WRITINGS, O.C.G.A. 16-10-20 16: FALSE SWEARING, O.C.G.A. 16-19-71 17: FALSE SWEARING, 16-10-71 18: FALSE SWEARING, O.C.G.A. 16-19-71 19: FALSE SWEARING, 0.C.G.A. 16-10-71 20: FALSE STATEMENTS AND WRITINGS, 16-10-20 21: FALSE STATEMENTS AND O.C.G.A. 16-10-29 22: FALSE STATEMENTS AND WRITINGS, 16-10-29 23: INFLUENCING WITNESSES, 16-10-93 24: FALSE STATEMENTS AND WRITINGS, 16-10-20 25: FALSE STATEMENTS AND WRITINGS, 16-10-20 26: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 27: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 29: FALSE STATEMENTS AND WRITINGS, 0.C.G.A. 16-10-20 29: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-29 30: FALSE STATEMENTS AND WRITINGS, 16-10-20 31: FALSE STATEMENTS AND WRITINGS, 16-10-20 32: FALSE STATEMENTS AND WRITINGS, 0.C.G.A. 16-10-20 33: FALSE 16-10-71 34: FALSE SWEARING, O.C.G.A. 16-10-71 35: FALSE SWEARING, O.C.G.A. 16-10-71 36: FALSE SWEARING, 16-10-71 37: FALSE STATEMENTS AND WRITINGS, 16-10-20 30: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 39: FALSE STATEMENTS AND WRTTINGS, 16-10-20 40: INFLUENCING WITNESSES, O.C.G.A. 16-10-93 41: FALSE STATEMENTS AND WRITINGS, 16-10-20 42: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 43: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 44: FALSE STATEMENTS AND WRTTINGS, O.C.G.A. 16-10-20 45: THEFT BY TAKING, O.C.G.A. 16-S-2 46: FALSE AND WRITINGS, 0.C.G.A. 16-10-20 47: FALSE STATEMENTS AND WRITINGS, I6-10-20 48: FALSE STATEMENTS AND WRITINGS, 16-10-20 49: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 50: FALSE STATEMENTS AND WRITINGS, 16-10-20 51: THEFT BY TAKING, O.C.G.A. 16-8-2 52: FALSE STATEMENTS AND WRITINGS, 0.C.G.A. 16-10-20 53: FALSE STATEMENTS AND WRITINGS, 16-10-20 54: THEFT BY TAKING, G.C.G.A. 16-8-Z 55: FALSE STATEMENTS AND WRITINGS, o.c.G.A. 16-10-20 56: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 57: FALSE STATEMENTS AND WRITINGS, 0.C.G.A. 16-10-20 58: FALSE SWEARING, 16-10-71 59: FALSE STATEMENTS AND 16-10-20 60: THEFT BY TAKING, 16-S-2 61: FALSE STATEMENTS AND WRITINGS, 0.C.G.A. 16-10-20 62: FALSE STATEMENTS AND WRITINGS, 16-10-20 63: FALSE STATEMENTS AND WRITINGS, 0.C.G.A. 16-10-20 64: FALSE AND WRITINGS, O.C.G.A. 16<<10-20 65: FALSE STATEMENTS AND WRITINGS, O.C.G.A. I6-10-20 TJZ L4 (5 BILL ,2e /5 4 Grand Jury Fcreperson PAUL L. HOWARD, IR, District Attorney The Defendant waives copy of The Defendant waives copy of The Defendant waives copy of indictment, list of witnesses, indictment, list of witnesses, indictment, list of witnesses, formal arraignment and pleads formal arraignment and pleads formal arraignment and pleads Guilty. Guilty. Guilty. Defendant Defendant Defendant Attorney for Defendant Attorney for Defendant Attorney for Defendant Assistant District Attorney Assistant District Attorney Assistant District Attorney This day of This day of TEE SHE EQUNTY TEE -EEJRQERS, seiected, chesen and worn for the County GfFu1'{0n, to wit: 1. Danielle M. 2:3. Kcllon, Mch'ss:1 .1. 2. Ronald J. Grecr_. As-si. Foreper.son 15. Loilnn, Robert C. 3. Regina Trolman. Secretary 16, Loi. Deborah C. -1. Amelia M, Johnson. Asst. E5 1. 5. Brown_. Janzica B. 18. Naivoss, Eric L. 6. Craig. Daren P. a 20. B. -- 21. Scott. L. 5. 22.. Troner. 10. Grnuban, Cynilmin S. 23. Paul 3. Han, M. 9 -H 1.2. 7* "3 13. I-IuEURc.hinson_ Sandra H. 1 3 TABLE OF CONTENTS COUNT I: VIOLATION OF GEORGIA RACKETEER INF LUENCED AND CORRUPT ORGANIZATIONS ACT, O.C.G.A 16-14-4 (C) ..9 .- 10 THE ENTERPRISE .. 13 THE NATURE OF THE CONSPIRACY .. 14 ACTS OF RACKETEERIN BY SENIOR ADMINISTRATORS OF APS .. 17 A. FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 .. 18 B. THEFT BY TAKING, O.C.G.A. 16-8-2 .. 19 C. INFLUENCING WITNESSES, O.C.G.A. 16-10-93 ..20 D. FALSE SVVEARING, O.C.G.A. 16-10-71 ..20 ACTS OF RACKETEERIN CONCERNING PARKS MIDDLE SCHOOL ..21 E. 2006: FALSE STATEMENTS ANB WRITINGS, O.C.G.A. 16-10-20 ..22 F. 2006: THEFT BY TAKING, O.C.G.A. 16-8-2 ..24 G. 2007: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..24 H. 2007: THEFT BY TAKING, O.C.G.A. 16-8-2 ..25 I. 2008: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..25 J. 2008: THEFT BY TAKING, O.C.G.A. 16-8-2 ..26 K. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..27 L. 2010: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..28 M. 2010: FALSE SWEARING, O.C.G.A. 16-10-71 ..30 ACTS OF RACKETEERIN CONCERNING GIDEON ELEMENTARY SCHOOL ..30 N. 2008: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..31 O. 2008: THEFT BY TAKING, O.C.G.A. 16-8-2 ..33 P. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..33 Q. 2010: INFLUENCING WITNESSES, O.C.G.A. 16-10-93 ..35 R. 2010: FALSE STATEIVIENTS AND WRITINGS, O.C.G.A. 16-10-20 ..35 ACTS OF RACKETEERIN CONCERNING DOBBS ELEMENTARY SCHOO ..35 S. 2008: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..36 T. 2008: THEFT BY TAKING, O.C.G.A. 16-8-2 ..37 U. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..38 V. 2010: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..38 W. 2011: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..39 X. 2012: FALSE SWEARING, O.C.G.A. 16-10-71 ..40 ACTS OF RACKETEERING CONCERNING DUNBAR ELEMENTARY SCHOOL .. 41 Y. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..41 Z. 2010: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..42 AA. 2010: INFLUENCING WITNESSES, O.C.G.A. 16-10-93 "43 ACTS OF RACKETEERING CONCERNING I-IUMPHRIES ELENIENTARY SCHOOL ..43 BB. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..-44 CC. 2009: THEFT BY TAKING, O.C.G.A. 16-8-2 ..44 DD. 2010: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..-44 ACTS OF RACKETEERIN CONCERNING KENNEDY MIDDLE SCHOOL "45 EE. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..45 ACTS OF RACKETEERIN CONCERNING DEERWOOD ACADEMY ..46 FF. 2008: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-I0-20 ..46 GG. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-2-0 7 HH. 2009: THEFT BY TAKING, O.C.G.A. 16-8-2 ..48 ACTS OF RACKETEERING CONCERNING VENETIAN ELEMENTARY SCHOOL ..48 II. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..-48 JJ. 2009: THEFT BY TAKING, O.C.G.A. 16-8-2 ..49 ACTS OF RACKETEERING CONCERNING B.E. HEIGHTS ELEMENTARY SCHOOL ..49 KK. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..50 5 LL. 2010: FALSE STATEMENTS AND VVRITINGS, O.C.G.A. 16-I0-20 ..51 MM. 2010: FALSE SWEARING, O.C.G.A. 16-10-71 ..S1 ACTS OF RACKETEERING CONCERNING BEN TEEN ELEMENTARY SCHOOL .. 51 NN. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..52 O0. 2009: THEFT BY TAKING, O.C.G.A. 16-8-2 ..53 PP. 2010: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..53 ACTS OF RACKETEERIN CONCERNING D.H. STANTON ELEMENTARY SCHOOL ..53 QQ. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..54 OVERT ACTS IN FURTHERAN CE OF THE CONSPIRACY ..55 COUNT 2: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..64 COUNT 3: THEFT BY TAKING, O.C.G.A. 16-8-2 ..64 COUNT 4: INFLUENCING WITNESSES, O.C.G.A. 16-10-93 ..64 COUNT 5: INFLUENCING WITNESSES, O.C.G.A. 16-10-93 ..65 COUNT 6: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 "65 COUNT 7: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..65 COUNT 8: FALSE SVVEARING, O.C.G.A. 16-10-71 ..66 PARKS MIDDLE SCHOOL .. 66 COUNT 9: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..66 COUNT 10: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..67 COUNT 11: FALSE STATEMENTS AND VVRITINGS, O.C.G.A. 16-10-20 ..67 COUNT 12: FALSE STATEMENTS AND O.C.G.A. 16-10-20 ..68 COUNT 13: FALSE STATEMENTS AND WRITINGS, O.C.C--.A. 16-10-20 ..68 COUNT 14: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..68 COUNT 15: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..69 COUNT 16: FALSE SWEARING, O.C.G.A. 16-I0-71 ..69 COUNT 17: FALSE SWEARING, O.C.G.A. I6-10-71 ..70 COUNT 18: FALSE SVVEARING, O.C.G.A. 16-10-71 COUNT 19: FALSE SWEARING, O.C.G.A. 16-10-71 ..7i GIDEONS ELEMENTARY SCHOOL ..71 COUNT 20: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..71 COUNT 21: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-I0-20 ..72 COUNT 22: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..72 COUNT 23: INFLUENCING WITNESSES, O.C.G.A. 16-10-93 ..73 DOBBS ELEMENTARY SCHOOL .. 73 COUNT 24: FALSE STATEMENTS AND O.C.G.A. 16-10-20 ..73 COUNT 25: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 COUNT 26: FALSE STATEMENTS AND O.C.G.A. 16-10-20 ..74 COUNT 27: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..7S COUNT 28: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..75 COUNT 29: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..76 6 COUNT 38: FALSE STATEMENTS AND O.C.G.A. 16-10-20 COUNT 31: FALSE STATEMENTS AND O.C.G.A. 16-10-20 .. 76 COUNT 32: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..77 COUNT 33: FALSE SVVEARING, O.C.G.A. 16-10-71 ..77 COUNT 34: FALSE SWEARING, O.C.G.A. 16-10-71 ..77 COUNT 35: FALSE SWEARING, O.C.G.A. 16-10-71 ..78 COUNT 36: FALSE SWEARING, O.C.G.A. 16-10-71 ..78 DUNBAR ELEMENTARY SCHOOL .. 78 COUNT 37: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..78 COUNT 38: FALSE STATEMENTS AND O.C.G.A. 16-10-Z0 ..79 COUNT 39: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-19-20 ..79 COUNT 40: INFLUENCING WITNESSES, O.C.G.A. 16-10-93 ..79 COUNT FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-220 ..80 COUNT 42: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16>>-10-20 ..80 COUNT 43: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..80 ELEMENTARY SCHOOL .. 81 COUNT 44: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..81 COUNT 45: THEFT BY TAKING, O.C.G.A. 16-8-2. ..81 COUNT 46: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..81 COUNT 47: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-I0-20 ..82 KENNEDY MIDDLE SCHOOL .. 82 COUNT 48: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..82 COUNT 49: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..83 DEERWOOD ACADEMY .. 83 COUNT 50: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..83 COUNT 51: THEFT BY TAKING, O.C.G.A. 3.6-8-2 .. 84 VENETIAN HILLS ELEMENTARY SCHOOL .. 84 COUNT 52: FALSE STATEMENTS AND WRITINGS, O.C.G.A. I6-10-20 "84 COUNT 53: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..85 COUNT 54: THEFT BY TAKEVG, O.C.G.A. 16-8-2 ..85 HEIGHTS ELEMENTARY SCHOOL ..86 COUNT 55: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..86 COUNT 56: FALSE STATEIVIENTS AND WRITINGS, O.C.G.A. 16-10-20 ..86 COUNT 57: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 ..87 COUNT 58: FALSE SWEARING, O.C.G.A. 16-10-71 "87 BENTEEN ELEMENTARY SCHOOL ..87 COUNT 59: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 16-10-20 "87 7 QOUNT 60: THEFT BY TAKING, 0.C.G.A. 16-S-2 .. 88 COUNT 61: FALSE STATEMENTS AND O.C.G.A. 16-10-20 ..88 COUNT 62: FALSE STATEMENTS AND WRITINGS, 0.C.G.A. ..89 COUNT 63: FALSE STATEMENTS AND O.C.G.A. 16~10-20 ..89 D.H. STANTON ELEMENTARY SCHOOL ..90 COUNT 64: FALSE STATEMENTS AND O.C.G.A. 16-10~28 ..9G COUNT 65: FALSE STATEMENTS AND VVRITINGS, O.C.G.A. 16-10-20 ..90 connr i: VEGLATEGN or GEDRGEA RACKETEER rnrwancnn AND connerr ORGANEZATIONS ACT, 16-144 in the name and on behalf of the citizens of the State of Georgia, do charge and accuse BEVERLY HALL PAMELA CLEVELAND MILLECENT FEW SHANI ROBENSON SHARON DAVIS-WILLIAMS DIANE WEBB BUCIGVER TAMARA COTMAN GLORIA EVEY MICHAEL PITTS LISA TERRY WALLER ENGRID ABELLA-SLY GREGORY REED WENDY AHMED SANDRA WARD LUCIOUS BROVVN STARLETTE MITCHELL CARGL DENNIS KIMBERLY ODEN TAMEKA GOODSGN ARMSTEAD SALTERS TABEEKA JORDAN SHERIDAN ROGERS CLARIETTA DAVES DANA EVANS DONALD BULLOCK ANGELA WELLIAMSGN THERESEA CGPELAND DERRECK BRGABWATER SHEELA EVANS SHAYLA SMITH WILLIE DAVENPORT DESSA QURB FRANCES MACK LERA MEDDLEEROGKS with the offense of VIOLATEGN GE RACKETEER ENFLUENCED AND CORRUPT GRGANIZATEGNS RICG O.C.G.A. 16-14-4 for the said accused together with unindicted coconspirators, in the State of Georgia and County of Fulton, on or between the 31" day of May, 2005 and the 1" day of December, 2012, the exact date(s) being unknown to the Grand Jurors at this time, unlawfully conspired and endeavored to acquire and maintain, directly and indirectly, an interest in and control of U.S. Currency, the property of the Atlanta Public School System and the Georgia Department of Education as further specified below, through a pattern of racketeering activity, in violation of 0.C.G.A. 16-14-4 and while employed by and associated with APS, unlawfully conspired and endeavored to conduct and participate in, directly and indirectly, APS through a pattern of racketeering activity, in violation of 0.EUR.G.A. 16-144 as described below and incorporated by reference as if fully set forth herein; contrary to the laws of said State, the good order, peace and dignity thereof; APS: AYP: BEFENITIGNS Atlanta Public School System, formally the "Atlanta Independent School System." A school system in the City of Atlanta, Fulton County, Georgia. Adequate Yearly Progress. Part of the No Child Left Behind Act of 2001. AYP is a measure of year-to-year student achievement on statewide assessments. Schools, school districts, and states must demonstrate a certain level of performance on reading, English/language arts, and mathematics assessments. Schools that "meet" AYP for two consecutive years are designated as "Distinguished Schools," a status that entitles the school to a monetary award. Schools that "do not meet" AYP for two consecutive years in the same subject area are designated as "Needs Improvement" schools. Each year that a school fails to make AYP, its NI status increases, requiring progressively more involved state participation in the school's management, as follows: NI-1: School must implement a School Improvement Plan and must offer Public School Choice. NE-2: Same as NH and funding for Supplemental Education Services g. after school tutorial programs) must be set aside in the school's Title I allocation. NE-3: Same as NI-2. A School Corrective Plan must also he put in place to include at least one of the following: replace all or most of the school's staff, implement a new curriculum, decrease management authority at the school level, hire an outside expert to advise the school, extend theschool year"/school day, or restructure the school's internal organizational arrangement. NE-4: Same as NI--3. A School Restructuring Plan must be created to include at least one of the following: reopen the school as a public charter school, replace all or most of the school's staff, enter into a contract with a private management company to operate the school, or any other major restructuring of the school's governance arrangement. NE-5: Same as NI-4. The school must implement the Restructuring Plan developed and approved in the previous year. Ni-6: Same as 1-5. The will conduct a School Performance Review and Needs Assessment. Based on the assessment, the makes a recommendation to the State Board of Education and an Improvement Contract is created. 10 BRC CRCT: GGSA: EEP: Same as NL6. The school must implement the Improvernent Contract and the school becomes a School Year 1. N38: Same as NI-7. The school becomes a School Year 2. The performs another System Performance Review and Needs Assessment and develops a Management Contract for the school. NE--9: Same as Nl--8. The school must implement the Management Contract and becomes a Contract--Managed School Year I. NE-10: Same as Ni-9. The school also becomes a Contract-Managed School Year 2 and must update the Management Contract. Blue Ribbon Commission. The BRC was created by Beverly Hall and the Atlanta Education Fund, and was authorized by a resolution of the Atlanta Board of Education. The BRC was charged with conducting an independent investigation of Atlanta Public Schools as a result of the state's erasure analysis of spring 2009 CRCT. Criterion-Referenced Competency Test. A standardized test used in Georgia as the AY assessment tool for elementary and middle schools. The CRCT evaluates grades in reading, language arts, and mathematics. Grades 3-8 are also tested in science and social studies. Georgia Department of Education. The agency that governs public education in the state of Georgia. The manages funding and testing for local educational agencies accountable for student achievement. The Department is managed by the State Superintendent of Schools. Governor's Office of Student Achievement. A State agency which provides accountability for Georgia's schools, pre--K through postsecondary levels. The intent is to improve student achievement and school completion in Georgia. Individualized Education Program. A plan that is developed by a team of people including teachers, other qualified personnel, parents/guardians, and the student, if appropriate. The purpose of the IEP is to ensure that a child with certain disabilities or irnpairments attending a public elementary or secondary education institution receives appropriate, specialized instruction and related accommodations. ll NCLB: OER: Paraprofessional: PEC: SRT: Targets "fest Coordinator: No Child Left Behind Act of 2001. NCLB is a United States Act of Congress that reauthorized the Elementary and Secondary Education act, which included Title I, the governments aid program for disadvantaged students. NCLB requires states to develop and administer basic skills assessments to all students at select grade levels in order to receive federal school funding. Georgia's statewide assessment is the CRCT. Office of Internal Resolution/Employee Relations within APS. This office processes and investigates complaints and reports of employee wrongdoing and related employment matters. Also called "parapro." Paraprofessional educators generally assist teachers in the classroom, supervise students outside of the classroom, or provide administrative support for teaching under the teacher's supervision. Professional Development Plan. A plan developed and used to correct perceived deficiencies in teachers' and administrators' performance. Its purpose is to encourage and support professional improvement in specified areas. Program for Exceptional Children. Program offering specialized, educational testing, evaluation and other services to eligible children with certain disabilities or irnpairrnents. Each eligible student must have an IEP. School Reform Team. APS was organized into four (4) geographically aligned areas comprised of elementary and middle schools, each headed by an executive director. The structure was intended to provide greater accountability and faster services to schools and parents. An accountability program implemented under Beverly Hall's administration, consisting of specific performance goals set for each school at the beginning of the school year. The targets were based on quantifiable measures, primarily CRCT performance, and also included factors such as attendance, and enrollment in rigorous academic courses. An individual, usually a teacher assigned to a school, with responsibility for overseeing proper test administration during the testing period. 12 TEE ENTERFRESE The Atlanta Independent School System (hereinafter was created in 1870 and is an independent school system. Lane City ofAz,'lam'a, 267 Ga. 843, 483 575 (1997). APS is a governmental entity and constitutes an "entexprise" as that term is defined in O.C.G.A. 13 TEE NATURE GF THE EUR0NSPIRACY AND THE MEANS BY WHICH IT ACCOMPLISHEB While Superintendent of APS, Beverly Hall set annual performance objectives for APS and the individual schools within it, commonly referred to as "targets." If a school achieved 70% or more of its targets, all employees of the school received a bonus. Additionally, if certain system-wide targets were achieved, Beverly Hall herself received a substantial bonus. Targets for elementary and middle schools were largely based on students' performance on the Criterion Referenced Competency Test a standardized test given annually to elementary and middle school students in Georgia. Additionally, student attendance was a contributing factor to achieving targets and obtaining bonuses. Beverly Hall's targets often set more rigorous goals for schools than Adequate Yearly Progress a measure of year-to--year student achievement on statewide assessments created under the No Child Left Behind Act of 2001 Under Beverly Hall's target system, schools had to perform at a higher standard on the CRCT than otherwise required by the State in order to receive a bonus. AYP required schools to have a certain percentage of students merely pass the CRCT. The Georgia Department of Education requires that the CRCT be administered under conditions to prevent tampering and other irregularities that could affect test results. Any deviations from these procedures are prohibited. Beverly Hall was required, by statute, to abide by and enforce the regulations of the regarding test administration and to certify in writing that those regulations had been followed. APS principals and teachers were frequently told by Beverly Hall and her subordinates that excuses for not meeting targets would not be tolerated. When principals and teachers could not reach their targets, their performance was criticized, their jobs were threatened and some 14 were terminated. Over time, the nnreasonable pressure to meet annual APS targets led some employees to cheat on the CRCT. The refusal of Beverly Hall and her top administrators to accept anything other than satisfying targets created an environment where achieving the desired end result was more important than the students' education, To satisfy annual targets and AYP, test answer sheets were altered, fabricated, and falsely certified. Test scores that were inflated as a result of cheating were purported to be the actual achievement of targets through legitimately obtained improvements in students' performance When, in fact, the conspirators knew those results had been obtained through cheating and did not reflect students' actual academic performance. As part of the conspiracy, employees of APS who failed to satisfy targets were terminated or threatened with termination, while others who achieved targets through cheating were publicly praised and financially rewarded. For example, teachers who reported other teachers who cheated were terminated, while teachers who were caught cheating were only suspended. The message from Beverly Hall was clear: there were to he no exceptions and no excuses for failure to meet targets. Beverly Hall placed unreasonable emphasis on achieving targets; protected and rewarded those who achieved targets through cheating; terminated principals who failed to achieve targets; and ignored suspicions CRCT score gains at schools within APS. As a result, cheating became more and more prevalent within APS, until by the time the 2009 CRCT was administered, cheating was taking place in a majority of APS's 83 elementary and middle schools. This was substantiated by GOSA's erasure analysis, which identified 43 APS elementary and middle schools with at least one out of four classrooms within those schools having a statistically improbable number of erasures changing wrong answers to right answers. GOSA's erasure 15 analysis identified an additional 9 APS elementary and middle schools as having at least one out of five classrooms with a statistically improbable number of erasures changing wrong answers to right answers. Confessions by dozens of APS employees subsequently confirmed what GOSA's statistical analysis indicated; widespread cheating occurred on the 2009 CRCT. It was further a part of the conspiracy and endeavor that targets achieved through cheating were used to obtain financial and other rewards for many of the conspirators. It was further part of the conspiracy and endeavor that targets achieved through cheating were used by Beverly Hall to obtain substantial performance bonuses. It was further part of the conspiracy and endeavor that Beverly Hall and other conspirators would interfere with, suppress and obstruct investigations into cheating using various methods. Conspirators would refuse to investigate reports of cheating; suppress and deny the existence of reports of cheating; fail to act upon APS investigators' conclusions that cheating was occurring; suppress and deny the APS investigators' conclusions that cheating was in fact occurring; fail and refuse to provide complaints of cheating to the Governor's Special Investigators, the Georgia Bureau of Investigation and investigators from the Fulton County District Attorney's Office; and intimidate witnesses with the intent to hinder, delay, or prevent the communication of criminal offenses to law enforcement officers. When questioned by the Governor's Special Investigators and law enforcement officers, many of the conspirators made false statements some under oath denying their knowledge of and participation in the cheating. It was further part of the conspiracy and endeavor that each Defendant agreed that a conspirator would commit, attempt to commit; or solicit, coerce; or intimidate another person to commit at least two acts of racketeering activity. 16 ACTS OF RACKETEERENG ACTEVETY The following acts constitute a pattern of racketeering activity in that they were corninitted in furtherance of one or more incidents, schemes, or transactions that had the same or similar intents, results, accomplices, victims or methods of commission or otherwise were interrelated by distinguishing characteristics. ACTS OF RACKETEERING BY SENIOR ABMINISTRATORS OF APS BEVERLY HALL served as the Superintendent of APS, in which capacity she was employed by and associated with APS. In her capacity as the Superintendent, BEVERLY HALL conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. MILLICENT FEW served as the Chief Human Resources Officer of APS, in which capacity she was employed by and associated with APS. In her capacity as the Chief Human Resources Officer, MELLICENT FEW conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. SHARON BAVISJWILLIAMS served as the Executive Director of for APS, in which capacity she was employed by and associated with APS. In her capacity as the SRT--I Executive Director, SHARON DAVISJWILEIAMS conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. MICHAEL PETTS served as the Executive Director of SRT--2 for APS, in which capacity he was employed by and associated with AP-S. In his capacity as the Executive Director, MICHAEL PETTS conspired and endeavored to violate the Georgia RICO Act throtigh a pattern of racketeering activity, as described herein below in this Count. CGTMAN served as the Executive Director of SRT--4 for APS, in which capacity she was employed by and associated with APS. In her capacity as the SRT--4 Executive Director, TAMARA CGTMAN conspired and endeavored to violate the Georgia RICO Act through a patteni of racketeering activity, as described herein below in this Count. A. FALSE STATEMENTS AND WRITINGS, 0.C.G.A. 16-10-20 1) BEVERLY HALL, in the County of Fulton and State of Georgia, on or about the day of October, 2009, did knowingly and willfuliy make and use a false document, by completing and submitting a Superintendent's Test Certification tn the knowing the same to contain false statements, to wit: that adhered to all written regulations and procedures relating to testing and test administration, including the distribution and collection of test materials, test security, use of test results and department testing dates and the reporting of irregularities established in the Student Assessment Handbook, System and School Test Coordinator Manuals"; 2) SHARON BAVES-WILLEAMS, in the County of Fulton and State of Georgia, on or between the 19th day of April, 2009 and the day of May, 2009, the exact dates being unknown to the Grand Jurors at this time, did knowingly and willfully conceal and cover up, by a trick, scheme, or device, a material fact, to wit: that during the 2009 CRCT at Perkerson Elementary School, test monitor Dr. Jackie Boyce was told by students that their teacher gave them correct answers, in violation of the testing rules and regulations set forth by the 3) SHARON DAVESNVELLIAMS, in the County of Fulton and State of Georgia, on or between the 19"' day of April, 2009 and the day ef May, 2009, the exact dates being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, to wit: a standardized test feedback form, by causing Dr. Jackie Boyce to omit his written observation that during the 2009 CRCT at Elementary School said monitor witnessed a teacher pointing out correct answers to students causing said students to change their answers from wrong to right, in violation of the testing rules and regulations set forth by the in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and the Governor's Office of Student Achievement departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. l6-- l4~3 18 B. BY TAEGNG, G.C.G.A. 16-8-2 4) 5) 6) 7) 8) BEVERLY HALL, in the County of Fulton and State of Georgia, on or between the 93' day of flctober, 2006 and the 31" day of October, 2006, the exact dates being unknown to the Grand Jurors at this time, while an employee of a government institution in breach of her duties as such employee, did unlawfully take U.S. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue her a monetary bonus based on 2006 CRCT results for schools in APS which she knew were false, BEVERLY HALL, in the County of Fulton and State of Georgia, on or between the 10"' day of September, 2007 and the 31" day of Gctober, 2007, the exact dates being unknown to the Grand Jurors at this time, while an employee of a government institution in breach of her duties as such employee, did nnlawfiilly take US. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue her a monetary bonus based on 2007 CRCT results for schools in APS which she knew were false; BEVERLY HALL, in the County of Fulton and State of Georgia, on or between the 1" day of September, 2008 and the 31" day of Gctober, 2008, the exact dates being unknown to the Grand Jurors at this time, while an employee of a government institution in breach of her duties as such employee, did unlawfully take US. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue her a monetary bonus based on 2008 CRCT results for schools in APS which she knew were false; BEVERLY EALL, in the County of Fulton and State of Georgia, on or between the 14"' day of September, 2009 and the 31" day of October, 2009, the exact dates being unknown to the Grand Jurors at this time, while an employee of a government institution in breach of her duties as such employee, did unlawfiilly take U.S. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue her a monetary bonus based on 2009 CRCT results for schools in APS which she knew were false; BEVERLY HALL, in the County of Fulton and State of Georgia, on or between the day of November, 2009 and the 30"' day of September 2010, the exact dates being unknown to the Grand Jurors at this time, while an officer or employee of a government institution in breach of her duties as such officer or employee, did unlawfully take U.S. currency, the property of the with the intention of depriving said owner of said property, by causing the Distinguished District monetary award from the to be issued to Parks Middle School by reporting 2009 CRCT results that she knew were false; 19 9) BEVERLY HALL, in the County of Fulton and State of Georgia, on or between the day of November, 2009 and the 30"' day of September 2010, the exact dates being unknown to the Grand Jurors at this time, while an officer or employee of a government institution in breach of her duties as such officer or employee, did unlawfully take U.S. currency, the property of the with the intention of depriving said owner of said property, by caused the Distinguished District monetary award from the to be issued to Benteen Elementary School by reporting 2009 CRCT results that she knew were false; 10) BEVERLY HALL, in the County of Fulton and State of Georgia, on or between the day of November, 2009 and the 30"' day of September 2010, the exact dates being unknown to the Grand Jurors at this time, while an officer or employee of a government institution in breach of her duties as such officer or employee, did unlawfully take U.S. currency, the property of the with the intention of depriving said owner of said property, by causing the Distinguished District monetary award from the to be issued to D.H. Stanton Elementary School by reporting 2009 CRCT results that she knew were false; which conduct constitutes racketeering activity pursuant to O.C.G.A. 16-143 C. INFLUENCING WITNESSES, 0.C.G.A. 11? 16-10-93 11) TAMARA COTMAN, in the County of Fulton and State of Georgia, on or about the 17"' day of November, 2010, did knowingly intimidate Principal Jirnniye Hawkins, and other APS employees, with the intent to hinder or delay the communication of information related to the commission of a criminal offense to GBI and other law enforcement officers investigating cheating in 12) MICHAEL PITTS, in the County of Fulton and State of Georgia, on or between the 1" day of August, 2010, and the 31" day of August, 2010, did knowingly intimidate Dorothea Wilson, and other staff at Parks Middle School, with the intent to hinder or delay the communication of information related to the commission of a criminal offense to GBI and other law enforcement officers investigating cheating in D. FALSE SWEARING, 0.C.G.A. 16-10-71 13) BEVERLY EALL, in the County of Fulton and State of Georgia, on or about the 18"' day of May, 2011, having been administered a lawful oath or affirmation, did knowingly and willfully make false statements to the Governor's Special Investigators, to wit: a. That she never received cornpiaints about Parks Middle School or CHRISTOPHER WALLER after he became principal; b. That she never met with Reginal Dukes in connection with his investigation into complaints about CHRESTGPEER WALLER at Parks Middle School; 20 E4) MELLECENT FEW, in the County of Fulton and State of Georgia, on or about the 1" day of June 2011, having been administered a lawful oath or affirmation, did knowingly and willfuily make false statements to the Governor's Special Investigators, to wit: a. That she never ordered the destruction of early drafts of the Deerwood investigation completed by outside investigator Penn Payne; b. That she did not meet with Reginal Dukes in connection with his investigation into complaints about CHRISTOPHER WALLER at Parks Middle School; 15) SHARON DAVIS-WILLIAMS, in the County of Fulton and State of Georgia, on or about the day of May, 2911, having been administered a Iawfui oath or affirmation, did knowingly and willfully make false statements to the Governor's Special Investigators, to wit: a. That she did not receive a testing irregularity report from Jackie Boyce; b. That she has not asked anybody to change information or misrepresent information regarding the 2009 and c. That she reported the allegation that a teacher gave students the answers on the CRCT to the Research, Planning, and Accountability office; which conduct constitutes racketeering activity pursuant to O.C.G.A. ACTS GE RACKETEERING CONCERNING PARKS MIDDLE SCHGOL CHRISTOPHER WALLER served as the Principal of Parks Middle School, in which capacity he was employed by and associated with APS. In his capacity as Principal, WALLER conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. GREGGRY REED served as the Assistant Principal of Parks Middle School, in which capacity he was employed by and associated with APS. in his capacity as Assistant Principal, GREGGRY REED conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. SANDRA WARD served as the Instructional Facilitator and, in 2010, as the Testing Coordinator, at Parks Middle School, in which capacities she was employed by and associated with APS. In her capacity as Instructional Facilitator and Testing Coordinator, WARD conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. STARLETTE METCHELL served as a teacher at Parks Middle School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, STARLETTE MITCHELL conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. KEMBERLY ODEN served as a teacher at Parks Middle School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, KIMBERLY ODEN conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. E. 2006: FALSE STATEMENTS AND WRITINGS, 16-10-20 16) CHRISTOPHER WALLER, in the County of Fulton and State of Georgia, on or between the 1" day of August, 2005 and the 8th day of February, 2006, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Stacey Johnson to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2006 CRCT for Parks Middle School; 17) CHRISTOPHER WALLER, in the County of Fulton and State of Georgia, on or between the day of March, 2006 and the 26"' day of April, 2006, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Darnany Lewis to knowingly and willfully make and use false documents and writings, by asking him to participate in falsifying students' answer sheets on the 2006 CRCT for Parks Middle School; 18) CHRISTOPHER WALLER, in the County of Fulton and State of Georgia, on or between the 29"' day of March, 2006 and the 26" day of April, 2006, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Draper to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2006 CRCT for Parks Middle School; 19) WALLER, GREGORY REIB, and SANDRA WARD, in the County of Fulton and State of Georgia, during the CRCT testing period on or between the 17"' day of April, 2006 and the 26"' day of April, 2006, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2006 CRCT answer sheets for students at Parks Middle Schook 20) BEVERLY HALL, in the County of Fulton and State of Georgia, on or between the 10"' day of May, 2006 and the 20"' day of December, 2006, the exact dates being unknown to the Grand Jurors at this time, in violation of her duty as APS superintendent, pursuant to O.C.G.A. 20-2-109 and the testing rules and regulations set forth by the Georgia Department of Education did knowingly and willfully conceal and cover up, by a trick, scheme, or device, material facts, to wit: BEVERLY HALL received a complaint that WALLER was pressuring teachers to cheat on the Spring 2006 CRCT at Parks Middle School and after Reginal Dukes' report concluded that cheating had occurred on the Georgia Eighth Grade Writing Assessment at Parks Middle School and the results of the Spring 2006 CRCT at Parks Middle School had likely been coinprornised, intentionally failed to report this information to the and the Georgia Professional Standards Commission 21) MICHAEL PETTS, in the County of Fulton and State of Georgia, on or between day of May, 2006 and the 20"' day of December, 2006, the exact dates being unknown to the Grand Jurors at this time, did knowingly and willfully conceal and cover up, by a trick, scheme, or device, material facts, to wit: MICHAEL PETTS received complaints that CHRISTOPHER WALLER was pressuring teachers to cheat on the Spring 2006 CRCT at Parks Middle School and after Reginal Dukes' report concluded that cheating had occurred on the Georgia Eighth Grade Writing Assessment at Parks Middle School and the results of the Spring 2006 CRCT at Parks Middle School had likely been compromised, intentionally failed to report this information to the all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and the Governor's Office of Student Achievement departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. l6- F. 2006: THEFT BY TAKENG, O.C.G.A. 16-8-2 22) BEVERLY HALL, in the County of Fulton and State of Georgia, on or between the 17"' day of April, 2006 and the 20th day of Becember, 2006, the exact dates being unknown to the Grand Jurors at this time, while an officer or employee of a government institution in breach of her duties as such officer or employee, did unlawfiilly take U.S. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue a monetary bonus to APS employees at Parks Middle School based on falsified test results on the 2006 CRCT for Parks Middle School; 23) CHRISTOPHER WALLER, GREGORY REID, and SANDRA WARD, in the County of Fulton and State of Ge rgia, on or aoout tr 20"' day of December, 2006 and while employees of a government institution in breach of their duties as such employees, did unlawfully take U.S. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue each of the accused a monetary bonus based on falsified test results on the 2006 CRCT for Parks Middle School; which conduct constitutes racketeering activity pursuant to O.C.G.A. G. 2007: FALSE STATEMENTS AND WRITINGS. 0.C.G.A. 16-10-20 24) WALLER, in the County of Fulton and State of Georgia, on or between the 28" day of March, 2007 and the 26"' day of April, 2007, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Darnany Lewis to knowingly and willfully make and use false documents and writings, by asking him to participate in falsifying students' answer sheets on the 2007 CRCT for Parks Middle School; 25) CHRISTOPHER WALLER, in the County of Fulton and State of Georgia, on or between the 28"' day of March, 2007 and the 26"' day of April, 2007, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Draper to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2007 CRCT for Parks Middle School; 26) WALLER, GREGQRY REED, SANDRA WARD, and STARLETTE MITCHELL, in the County of Fulton and State of Georgia, during the CRCT testing period on or between the 16"' day of April, 2007 and the 26"' day of April, 2007, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2007 CRCT answer sheets for students at Parks Middle School; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. 24 ii. 2007: THEFT BY TAKING, G.EUR.G.A. 27) CHRISTOPHER WALLER, GREGGRY REED, SANDRA WARD, and STARLETT MITCHELL, in the County of Fulton and State of Georgia, on or about the 20"' day of December, 2007 and while employees of a government institution in breach of their duties as such employees, did unlawfully take U.S. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue each of the accused a monetary bonus based on falsified test results on the 2007 CRCT for Parks Middle School; which conduct constitutes racketeering activity pursuant to O.C.G.A. 16-14>>-3 l. 2008: FALSE STATEMENTS AND WRITENGS, 0.C.G.A. 8 16-10-20 28) WALLER, in the County of Fulton and State of Georgia, on or between the 31" day of March, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Darnany Lewis to knowingly and willfully make and use false documents and writings, by asking him to participate in falsifying students' answer sheets on the 2008 CRCT for Parks Middle School; 29) WALLER and GREGORY REID, in the County of Fulton and State of Georgia, on or between the 31" day of March, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Draper to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2008 CRCT for Parks Middle Schook 30) WALLER, in the County of Fulton and State of Georgia, on or between the 31" day of March, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Dorothea Wilson to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2008 CRCT for Parks Middle School; 33) QREGGRY in the County of Fulton a.nd State of Georgia, on or between the 31" day of March, 2008 and the 15' day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Latasha Smiley to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2008 CRCT for Parks Middle School; 32) GREGORY REED, in the County of Fulton and State of Georgia, on or between the 315' day of March, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Charles Mitchell to knowingly and willfully make and use false documents and writings, by asking him to participate in falsifying students' answer sheets on the 2008 CRCT for Parks Middle School; 25 33) GREGGRY REED, SANDRA WARD, STARLETTE MITCHELL, and KIMBERLY ODEN, in the County of Fulton and State of Georgia, during the CRCT testing period on or between the 21" day of April, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2008 CRCT answer sheets for students at Parks Middle School; 34) CPIRESTOPHER WALLER, in the County of Fulton and State of Georgia, did knowingly and willfully make and use a false document and writing, by completing, signing, and submitting a CRCT School Certification Form for Parks Middle School to APS dated the day of May, 2008, knowing the same to contain false statements, to wit: (1) The written plans for testing were followed, including all directives in the Examiner is Mantra], the Testing Coordinator': Manual, and system correspondence; (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/ circumstance has been reported to the system coordinator; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. .3. 2008: THEFT BY TAKING, G.C.G.A. 16-<<8-2 35) CHRISTOPHER WALLER, GREGORY REIE, SANDRA WARD, STARLETTE METCHELL, and KIMBERLY QDEN, in the County of Fulton and State of Georgia, on or about the 19"' day of Becember, 2008 and while employees of a government institution in breach of their duties as such employees, did unlawfully take US. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue each of the accused a monetary bonus based on falsified test results on the 2008 CRCT for Parks Middle School; which conduct constitutes racketeering activity pursuant to O.C.G.A. 16-l4-3 K. 2009: FALSE STATEMENTS AND WRITINGS, O.C.G.A. _8 16-10-20 36) CHRISTOPHER WALLER, in the County of Fulton and State of Georgia, on or between the 27"' day of March, 2009 and the 30th day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Darnany Lewis to knowingiy and willfully make and use false documents and writings, by asking him to participate in falsifying students' answer sheets on the 2009 CRCT for Parks Middle School; 37) CERESTOPHER WALLER, in the County of Fulton and State of Georgia, on or between the 27"' day of March, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Draper to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT for Parks Middle School; 38) in the County of Fulton and State of Georgia, on or between the 27"' day of March, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Dorothea Wilson to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT for Parks Middle School; 39) GREGORY REID, in the County of Fulton and State of Georgia, on or between the 27"' day of March, 2009 and the 30"" day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Charles Mitchell to knowingly and willfully make and use false documents and writings, by asking him to participate in falsifying students' answer sheets on the 2009 CRCT for Parks Middle School; 40) WALLER, in the County of Fulton and State of Georgia, on or between the 27"' day of March, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Adrienne Powell to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT for Parks Middle School; 41) CHRISTOPHER WALLRR, GREGORY REIB, SANBRA WARE, METCRELL, and KEMBERLY GDEN, in the County of Fulton and State of Georgia, during the CRCT testing period on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2009 CRCT answer sheets for students at Parks Middle School; 27 42) WALLER, in the County of Fulton and State of Georgia, did knowingly and willfully make and use a false document and writing, by completing, signing, and submitting a CRCT School Ceitifieation Form for Parks Middle School to APS dated the 30:" day of April, 2009, knowing the same to contain false statements, to wit: (1) The written plans for testing were followed, including all directives in the Examz'ner's Manual, the Testing Coordz'nat0r's Manual, and system correspondence; (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irreguiarityf circumstance has been reported to the system coordinator; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. L. 2010: FALSE STATEMENTS AND WRITINGS, 0.C.G.A. 6; 16-10-20 4-3) WALKER, GREGGRY REED, and SANBRA WARD, in the County of Fulton and State of Georgia, on or between the 27"' day of Aprii, 2910 and the day of May, 2610, did knowingly and willfully make and use a false document and writing, to wit: a testing irregularity report, knowing the same to contain a false statement, to wit: that Chynel Walker removed a test instruction manual from Megan Eckert's classroom; 44) WALLER, GREGGRY REID, and SANBRA WARD, in the County of Fulton and State of Georgia, on or between the 27"' day of April, 2010 and the day of May, 2010, did intimidate and coerce Megan Eckeit to knowingly and willfully make and use a false document and writing, to wit: a testing irregularity report, knowing the same to contain a false statement; 28 45) CHRESTOPHER WALLER and SANERA WARD, in the County of Fulton and State of Georgia, did knowingly and willfully make and use a false document and writing, by completing, signing, and submitting a CRCT School Certification Form for Parks Middle School to APS dated the 28th day of April, 2010, knowing the same to contain false statements, to wit: (1) The written plans for testing were followed, including all directives in the Examz'rzer's Manual, the esting Coordinator is and system correspondence; (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/circumstance has been reported to the system coordinator; 46) SANDRA WARE, in the County of Fulton and State of Georgia, on or about the 20"' day of October, 2010, did knowingly and willfully make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone erasing or changing answers on students' CRCT answer sheets; 47) STARLETTE MITCHELL in the County of Fulton and State of Georgia, on or about the 20"' day of October, 2010 did knowingly and willfully make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone erasing or changing answers on students' CRCT answer sheets; 48) STARLETTE in the County of Fulton and State of Georgia, on or about the 15" day of December, 2010 did knowingly and willfully make a false statement to a agent, to wit: that she only participated in changing answers on students' CRCT answer sheets in 2009; 49) GREGGRY REED, in the County of Fulton and State of Georgia, on or about the 20"' day of Gctober, 2010, did knowingly and willfully make a false statement to a Georgia Bureau of Investigations agent, to wit: that he did not participate in, assist with or have knowledge of anyone erasing or changing answers on students' CRCT answer sheets; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. 29 M. 2010: FAESE SWEARENG, G.C.G.A. 16-10-71 in the County of Fulton and State of Georgia, on or about the 18"' day of April, 2011; having been administered a lawful oath or affirmation, did knowingly and willfully rnake false statements to the Governor's Special Investigators; to wit: a. That he was not aware of any irnproprieties whatsoever with respect to how CRCT testing was conducted at Parks Middle School; b. That he was not aware of any adult changing answers on students' CRCT answer sheets; That he did not have any knowledge of teachers at Parks Middle School keeping tests later than they should have; 51) GREGORY REID, in the County of Fulton and State of Georgia, on or about the 18"' day of April, 2011; having been administered a lawful oath or affirmation; did knowingly and willfully make false statements to the Governor's Special Investigators, to wit: a. That he was not aware teachers were cheating on the CRCT at Parks Middle School; b. That he did not suggest or direct teachers to cheat; c. That he did not have any knowledge of teachers at Parks Middle School keeping tests later than they should have; which conduct constitutes racketeering activity pursuant to O.-C.G.A. ACTS OF RACKETEERING CGNCERNING GEDEONS ELEMENTARY ARMSTEAD SALTERS served as Principal of Gideons Elementary School, in which capacity he was employed by and associated with APS. In his capacity as Principal, ARMSTEAD SALTERS conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. 30 EQGERS served as the testing coordinator at Gideons Elementary School, in which capacity she was employed by and associated with APS. In her capacity as the testing coordinator, SHEREDAN RGGERS conspired and endeavored to Violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. N. 2008: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 3 16-10--29 52) ARMSTEAB SALTERS and SHEREBAN ROGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Bernadine Macon to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2008 CRCT for Gideons Elementary School; 53) ARMSTEAD SALTERS and SHERIDAN ROGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Daisy Bowser to knowingly and willfully make and use false documents and writings, uy asking her to participate in falsifying students' answer sheets on the 2008 CRCT for Gideons Elementary School; 54} ARMSTEAB SALTERS and SHERIDAN RGGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Veronica Jordan to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2008 CRCT for Gideons Elementary School; 55) ARMSTEAD SALTERS and SHERIDAN ROGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day ef April, 2908 and the 15* day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Oliver Banks, Jr. to knowingly and willfiilly make and use false documents and writings, by asking him to participate in falsifying students' answer sheets on the 2008 CRCT for Gideons Elementary School; 56) SHEREDAN ROGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Trernelia Donaldson to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2008 CRCT for Gideons Elementary School; 31 57) SHEREGAN ROGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Gtand Jurors at this time, did solicit Denethia Weddington-Watd to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2008 CRCT for Gideons Elenientaiy School, 58) SHERIDAN ROGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 1" day of May, 2098, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Cheryl Hunt to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the .2008 CRCT for Gideons Elementary School; 59) ARMSTEAB SALTERS and SHEREDAN ROGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 15* day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2008 CRCT answer sheets for students at Gideons Elementary School; 60) ARIVESTEAD SALTERS and SHERIDAN ROGERS in the County of Fulton and State of Georgia, did knowingly and willfully make and use a false document and writing, by completing, signing, and submitting a CRCT School Certification Form or Gideons Elementary School to APS dated the 2" day of May, 2008, knowing the same to contain false statements, to wit: (1) The written plans for testing were followed, including all directives in the Examiners Marina], the Testing C0ordimzz'0r's Manual, and system correspondence; (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/circumstance has been reported to the system coordinator; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. 32 G. 2008: THEFT BY TAKENG, 0.C.G.A. 16-S-2 61) ARMSTEAD SALTERS and SHERIDAN ROGERS, in the County of Fulton and State of Georgia, on or about the 19"' day of December, 2008 and while employees of a governrnent institution in breach of their duties as such employees, did unlawfully take U.S. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue each of the accused a monetary bonus based on falsified test results on the 2008 CRCT for Gideons Elementary School; which conduct constitutes racketeering activity pursuant to O.C.G.A. F. 2009; FALSE STATEMENTS ANEE WRETENGS, 62) ARMSTEAD SALTERS and SHERIDAN ROGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Bernadine Macon to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT for Gideons Elementary School; 63) ARMSTEAD SALTERS and SHERIDAN RGGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of Aprii, 2009 and the 30"" day of Aprii, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Daisy Bowser to knowingiy and wilifiilly make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT for Gideons Elementary School; 64) ARMSTEAD SALTERS and SHEREBAN ROGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Veronica Jordan to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT for Gideons Elementary School; SALTERS and SHERIDAN RGGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Oliver Banks, Jr. to knowingly and willfully make and use false documents and writings, by asking him to participate in falsifying students' answer sheets on the 2009 CRCT for Gideons Elementary School; 33 66) ARMSTEAD SALTERS and SHEREDAN RGGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Treinelia Donaldson to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT for Gideons Elementary School; 67) ARMSTEAD SALTERS and SHERIDAN ROGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Denethia Weddington--Ward to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT for Gideons Elementary School; 68) ARMSTEAD SALTERS and SHEREDAN RGGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Cheryl Hunt to knowingly and willfiilly make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT for Gideons Elementary School; 69) ARMSTEAD SALTERS and SHEREBAN RGGERS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 2i" day of April, 2009 and the 39"' day of April, 2989, tr exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2009 CRCT answer sheets for students at Gideons Elementary School; 70) ARMSTEAD SALTERS and SHERIDAN ROGERS in the County of Fulton and State of Georgia, did knowingly and willfiilly make and use a false document and writing, by completing, signing, and submitting a CRCT School Certification Form for Gideons Elementary School to APS dated the dfl' day of May, 2009, knowing the same to contain false statements, to wit: (1) The written plans for testing were followed, including all directives in the Examineris Manual, the Testing Coordinator': Manual, and system correspondence; (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/circumstance has been reported to the system coordinator; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. 34 Q. 2010: TNFLUENCENG WETNESSES, G.EUR.G.A. .8 16-10-93 '71) ARMSTEAD SAL-TEES, in the County of Fulton and State of Georgia, on or between the 30th day of June, 2010 and the 17"' day of November, 2010, did knowingly intimidate Oliver Banks, Jr., and other Gideons Elementary School employees, with the intent to hinder or delay the communication of information related to the commission of a criminal offense to GBI and other law enforcement officers investigating cheating in which conduct constitutes racketeering activity pursuant to O.C.G.A. 16-14-3 R. 2010: FALSE STATEMENTS ANZC9 WRETINGS, O.C.G.A. 16-19-23 72) SHEREDAN ROGERS in the County of Fulton and State of Georgia, on or about the 21" day of October, 2010, did knowingly and willfully make false statements to a GBI agent, to wit: a. That she did not return CRCT booklets to teachers so they could change answers; b. That she did not instruct teachers to change answers on CRCT answer sheets; and c. That she was not present while other teachers changed students' answers on the CRCT answer sheets; ali in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. ACTS RACKETEERENG CGNCERNENG ELEMENTARY SCHOOL SANA EVANS served as Principal of Dobbs Elementary School, in which capacity she was employed by and associated with APS. In her capacity as Principal, BANA EVANS conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. 35 ANGELA WILLEAMSON served as a teacher at Dobbs Elenientary School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, AN GELA WELLIAMSON conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. BROADWATER served as a teacher at Dobbs Elementary School, in which capacity he was employed by and associated with APS. In his capacity as a teacher, DERRICK BROADWATER conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. SEAYLA SMITH served as a teacher at Dobbs Elementary School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, SHAYLA SMITH conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. BESSA CURB served as a teacher at Dobbs Elementary School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, DESSA CURB conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. S. 2008: FALSE STATEMENTS AND WRETENGS, 5 36-10-29 73) DANA EVANS, ANGELA WILLEAMSON, DERRICK BROADWATER and SHAYLA SMETH, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2008 CRCT, thereby causing them to falsify their 2008 CRCT answers sheets at Dobbs Elementary School; 36 74) EESSA CURB, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2009 CRCT answer sheets for students at Dohbs Elementary School; 75) DANA EVANS, in the County of Fulton and State of Georgia, did knowingly and willfully make and use a false document and writing, by completing, signing, and submitting a CRCT School Certification Form for Dobbs Elementary School to APS dated the day of May, 2008, knowing the same to contain false statements, to wit: (1) The written plans for testing were followed, including all directives in the Examiner 's fidanual, the Testing Co0rdz'nat0r"S and system correspondence; (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/circumstance has been reported to the system coordinator; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state govemrnent, which conduct constitutes racketeering activity pursuant to O.C.G.A. T. 2008: TEEFT BY TAKING. 0.C.G.A. 8 16-8-2 76) DANA EVANS, ANGELA WILLIAMSON, EERRECK BRGADWATER, SHAYLA SMITH and DESSA CURB, in the County of Fulton and State of Georgia, on or about the 19"' day of December, 2008, and while employees of a government institution in breach of their duties as such government employees, did unlawfully take US. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue each of the accused a bonus check based on falsified test results on the 2008 CRCT for Dobbs Elementary School; which conduct constitutes racketeering activity pursuant to O.C.G.A. 37 U. 2009: FALSE STATEMENTS ANS 0.C.G.A. 8 16-10-20 77) DANA EVANS, ANGELA BERRICK BRGADWATER and SEAYLA SMITH, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully niake and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2009 CRCT, thereby causing them to falsify their 2009 CRCT answers sheets at Dobbs Elementary School; 78) DESSA CURB, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of Apr.-Ii, 2909 and the 39"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use faise documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2009 CRCT answer sheets for students at Dobbs Elementary School; 79) DANA EVANS, in the County of Fulton and State of Georgia, did knowingly and willfully make and use a false document and writing, by completing, signing, and submitting a CRCT School Certification Form for Dobbs Elementary School to APS dated the 30"' day of April, 2909, knowing the same to contain false statements, to wit: (1) The written plans for testing were followed, including all directives in the Examz'ner's Mamtal, the Testing Coordinators fl/Icmuar', and system correspondence; (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/circumstance has been reported to the system coordinator; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. 16-14-3 V. 2010: FALSE STATEMENTS AND WRETENGS. 8 16-10-20 80) DERRECK BROADWATER and SE-IAYLA SMITH, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 20*" day of April, 2010 and the 30"' day of April, 2010, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2010 CRCT, thereby causing them to falsify their 20l 0 CRCT answers sheets at Dobbs Elementary School; 38 EARTA EVANS, in the County of Fulton and State of Georgia, did knowingly and willfully make and use a false document and writing, by completing, signing, and subrnitting a CRCT School Certification Form for Dobbs Elementary School to APS dated the 29"' day of April, 2010, knowing the same to contain false statements, to wit: (1) The written plans f0t' testing were followed, including all directives in the Examiners Manual, the Testing C0ordz'nator's Manual, and system correspondence; (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/circumstance has been reported to the system coordinator; all in a matter within the inrisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. l6--l4~3 W. 2011: FALSE STATEMENTS AND WRITENGS, G.C.G.A. 3 1640-20 82) DERRICK BROABWATER, in the County of Fulton and State of Georgia, on or about the day of February, 2011, did knowingly and willfiilly make a false statement to a GBI agent, to wit: that he did not participate in, assist with or have knowledge of anyone giving students answers during the 83) DESSA CURB, in the County of Fulton and State of Georgia, on or about the 21" day of February, 2611, did knowingly and willfully make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone erasing or changing answers on students' CRCT answer sheets; 84) BANA EVANS with in the County of Fulton and State of Georgia, on or about the 27th day of February, 2011 did knowingly and willfully make false staternents to a GBI agent, in violation of O.C.G.A. 16-l0-20, to wit: a. That she did not hear anything about cheating at Dobbs Elementary School; 13. That she did not allow teachers to cheat at Dobbs Elementary School; 85) ANGELA WILLIAMSON in the County of Fulton and State of Georgia, on or about the 1" day of March, 2011, did knowingly and willfully make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone giving students answers during the 39 all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. X. 2012: FALSE SWEARENG, 0.C.G.A. 16-10-71 86) DERRICK BRGADWATER, in the County of Fulton and State of Georgia, on or about the 25th day of April, 2012, having been administered a lawful oath by a hearing officer authorized to conduct Fair Dismissal Act hearings pursuant to 0.C.G.A. 20-4-940, did knowingly, willfiilly, and falsely swear a. That he did not cheat on the CRCT at Dobbs Elementary School; b. That he did not give students answers on the c. That he did not encourage students to erase and change their answers on the 87) ANGELA WILLIAMSON, in the County of Fulton and State of Georgia, on or about the 9th day of June, 2012, having been administered a lawful oath by a hearing officer authorized to conduct Fair Dismissal Act hearings pursuant to O.C.G.A. 20-4-940, did knowingly, vvillfuily, and falsely swear that she did not give students answers tn the CRCT at Dobbs Elementary School; 88) SHAYLA SMITH, in the County of Fulton and State of Georgia, on or about the 27"' day of August, 2012, having been administered a lawful oath by a hearing officer authorized to conduct Fair Dismissal Act hearings pursuant to O.C.G.A. 20-4-940, did knowingly, willfully, and falsely swear that she never gave any students answers on any 89) ANGELA WILLIAMSON, with the offense of FALSE SWEARENG, in violation of O.C.G.A. 16-10-71, for the said accused, in the Ccunty of Fulton and State of Georgia, on or about the 1" day of December, 2012, having been administered a lawful oath by a hearing officer authorized to conduct Fair Dismissal Act hearings pursuant to O.C.G.A. 20-4-940, did knowingly, willfully, and falsely swear a. That she did not prompt or give students correct answers to the CRCT at Dobbs Elementary School; b. That she did not cheat at any point on the 2009 CRCT at Dobbs Elementary Scheoh which conduct constitutes racketeering activity pursuant to O.C.G.A. 40 ACTS OF RACKETEERING CONCERNING DUNBAR ELEMENTARY SCHOOL LERA MIDDLEBROOKS served as Principal of Dunbar Elementary School, in which capacity she was employed by and associated with APS. In her capacity as Principal, LERA IVEEDDLEBROOKS conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. FAMELA CLEVELAND served as a teacher at Dunbar Elementary School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, PAMELA CLEVELAND conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. SHANE ROBERTSON served as a teacher at Dunbar Elementary School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, SHANE ROEENSON conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. GLORIA EVEY served as a teacher at Dunbar Elementary School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, GLORIA IVEY conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. Y. 2009: FALSE STATEMENTS AND WRETINGS, O.C.G.A. 6 16-10-20 90) LERA MIDDLEBROOKS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 215' day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Rose Neal to knowingly and willfiilly make and use false documents and writings, by asking her to participate in faisifying students' answer sheets on the 2009 CRCT for Dunbar Elementary School; 91) LEEA SHANE RGBENSGN, PAMELA CLEVELAND and DIANE BUCKNER WEBB, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by changing students' answers from wrong to right on the 2009 CRCT answer sheets for students at Dunbar Elementary School; 92) GLGREA EVEY, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, in owing the same to contain false entries, by falsifying students' answer sheets on the 2009 CRCT, thereby causing them to falsify their 2009 CRCT answers sheets at Dunbar Elementary School; 93) LERA MIDDLEBROOKS, in the County of Fulton and State of Georgia, did knowingly and willfully make and use a false document and writing, by completing, signing, and submitting a CRCT School Certification Form for Dunbar Elementary School to APS dated the day of May, 2009, knowing the same to contain false statements, to wit: (1) The written plans for testing were followed, including ail directives in the Examiner's Mantra], the Testing Coordinator': Manila], and system correspondence; (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/circumstance has been reported to the system coordinator; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. Z. 2010: FALSE STATEMENTS AND WRITENGS, 0.C.G.A. 8 16-10-20 94) GLGRIA IVEY, in the County of Fulton and State of Georgia, on or about the 18"' day of October, 2010, did knowingly and willfully make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone giving students answers to the 95) DIANE WEBB in the County of Fulton and State of Georgia, on or about the 19"' day of October, 2010, did knowingly and willfiilly make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge 42 96) CLEVELANB, in the County of Fulton and State of Georgia, on or about the 19th day of October, 2010, did knowingly and willfully make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone erasing or changing answers on students' CRCT answer sheets; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the arid GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. AA. 2010: INFLUENCENG WITNESSES, 0.C.G.A. 97) LERA IVEIDBLEBROOKS, in the County of Fulton and State of Georgia, on or about the tit)' day of Aprii, 201i, did knowingly intimidate Rose Neal, with the intent to hinder or delay the communication of information related to the commission of a criminal offense to GBI and other law enforcement officers investigating cheating in which conduct constitutes racketeering activity pursuant to O.C.G.A. ACTS RACKETEERING CONCERNING HUMPHRIES ELEMENTARY LISA, served as a teacher at Huinphries Elementary School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, LISA conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. INGREB ABELLA--SLY served as a teacher at Huniphries Elementary School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, INGRIB ABELLA conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. WENDY AHIVIEB served as a teacher at Elementary School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, WENDY AHMED conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. 43 BB. 2009: FALSE STATEMENTS ANE 8.C.G.A. 16-10-20 98) LISA TERRY, INGRID ABELLA-SLY and WENDY AHMED with the offense of FALSE STATEMENTS ANE WRITINGS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of Aprii, 2.809 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2009 CRCT, thereby causing them to falsify their 2009 CRCT answers sheets at Humphries Elementary School; er within the jurisdiction of APS, a poiiticai subdivision of the State of Georgia; the in a matt A: and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. CC. 2009: THEFT BY TAKING. G.C.G.A. 8 16-8-2 99) LISA TERRY, INGRIB ABELLA-SLY and WENBY AHMED, in the County of Fulton and State of Georgia, on or about the 18"' day of December, 2009, and while employees of a government institution in breach of their duties as such government employees, did unlawfully take U.S. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue each of the accused a bonus check based on falsified test results on the 2009 CRCT for Elementary Schooh which conduct constitutes racketeering activity pursuant to O.C.G.A. 16-1432 ED. 2010: FALSE STATEMENTS AND WRITINGS, O.C.G.A. 8 16-10-20 100) TNGRID ABELLA-SLY, in the County of Fulton and State of Georgia, on or about the 27"' day of flctober, 2019, did knowingly and willfully make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone giving students answers to the 101) WENDY ATTMED, in the County of Fulton and State of Georgia, on or about the 27"' day of Gctober, 2010, did knowingly and willfully make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone giving students answers to the all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. 44 ACTS OF RACKETEERINO CONCERNENG KENNEDY MIDDLE SCHOOL LUCIOUS BROWN served as Principal of Kennedy Middle School, in which capacity he was employed by and associated with APS. In his capacity as Principal, LUCIOUS BROWN conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. CAROL DENNES served as the secretary at Kennedy Middle School, in which capacity she was einployed by and associated with APS. In her capacity as a secretary, CAROL BENNIS conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. TAMEKA GOODSON served as an Instructional Coach at Kennedy Middle School, in which capacity she was employed by and associated with APS. In her capacity as an Instructional Coach, TAMEKA GOOESON conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. EE. 2009: FALSE STATEMENTS ANB WRETENGS. O.C.G.A. 8 16-10-20 102) LUCIOUS BROWN, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Barbara McDaniel to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT for Kennedy Middle School, 103) LUCEOUS BROWN, CAROL BENNIS and TAMEKA GOODSON, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfiilly make and use false documents and writings, knowing the same to contain false entries, by changing students' answers from wrong to right on the 2009 CRCT answer sheets for students at Kennedy Middle School; 104) LUCTOUS in the County of Fulton and State of Georgia, did knowingly and willfully make and use a false document and writing, by completing, signing, and submitting a CRCT School Certification Form for Kennedy Middle School to APS dated the 30"' day of April, 2009, knowing the same to contain false statements, to wit: (1) The written plans for testing were followed, including all directives in the Examz'ner's Manual, the Testing Coordinator': Manual, and system correspondence; and (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/circumstance has been reported to the system coordinator; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. ACTS RACKETEERTNG ACABEIVTY TABEQF.-KA JORDAN served as a teacher at Deerweod Academy, in which capacity she was employed by and associated with APS. In her capacity as a teacher, TABEEKA JGRDAN conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. FTR2008: FALSE STATEMENTS AND WRITINGS. 0.C.G.A. 8 16-10-20 105) TABEEKA JGRDAN, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Lavonia Ferrell to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the Summer 2008 CRCT Retest for students at Deerwood Academy; 106) TABEEKA JGRDAE, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Margaret Merkerson to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the Summer 2008 CRCT Retest for students at Deerwood Academy; 46 ?07) TABEEKA EGREAN, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2008 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by erasing and changing students' answers from wrong to right on the Summer 2008 CRCT Retest for students at Deerwood Academy; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. 16-14-3 GG. 2009: FALSE STATEIVIENTS AND WRITINGS, 16-10-20 108) TABEEKA JORDAN, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 1" day of May, 2008, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Lavonia Ferrell to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 answer sheets for students at Deerwood Academy; 109) TABEEKA JORDAN, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Margaret Merkerson to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT answer sheets for students at Deerwood Academy; 110) TABEEKA JORDAN, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the 30th day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2009 CRCT answer sheets for students at Deerwood Academy; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state govemrnent, which conduct constitutes racketeering activity pursuant to O.C.G.A. 47 EH. 2009: THEFT BY TAKING, 0.C.G.A. 16-8-2 111) TABEEKA JORDAN, in the County of Fulton and State of Georgia, on or about the 18th day of December, 2009, and while an employee of a government institution in breach of her duties as such government einployee, did unlawfully take U.S. currency, the property of APS, with the intention of depriving said owner of said property by causing APS to issue the accused a bonus check based on falsified test results on the 2009 CRCT for Deerwood Academy; which conduct constitutes racketeering activity pursuant to O.C.G.A. l6--l4--3 ACTS OF RACKETEERING CGNCERNENG VENETIAN HILLS ELEMENTARY SCHOOL CLAREETTA DAVES served as Principal of Venetian Hills Elementary School, in which capacity she was employed by and associated with APS. In her capacity as Principal, CLARIETTA DAVIS conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. H. 2009: FALSE STATEMENTS AND 0.C.G.A. 112) 113) CLARIETTA DAVIS, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2099 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Milagros to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT answer sheets for students at Venetian Hills Elementary Schooh CLAREETTA DAVES, in the County of Fulton and State of Georgia, during the CRCT testing period on or between the 21" day of April, 2009 and the 30"' day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the .2009 CRCT answer sheets for students at Venetian Hills Elementary School; 48 in the County of Fulton and State of Georgia, did knowingly and willfully make and use a false document and writing, by completing, signing, and submitting a CRCT School Certification Form for Venetian Hills Elementary School to APS dated the 30"' day of apni, 2009, knowing the same to contain false statements, to wit: iwa inn. The written plans for testing were followed, including all directives in the I Examzners Manual, the Testing Coorclinczzorkr Manrzal, and system correspondence; and (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/circurnstance has been reported to the system coordinator; all in a matter within the jurisdiction of APS, a politicai subdivision of the State of Georgia; the and GOSA3 departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. M. 2009: Eh' e,c.c.a. E6-8-2 H5) QEJAREETEA EAVES, in the County of Fulton and State of Georgia, during the CRCT testing period on or about the 38"' day of Becentben, 26095 and while an employee of a governrnent institution in breach of her duties as such government employee, did unlawfully take U.S. currency, the property of APS, with the intention of depriving said owner of said property by causing APS to issue the accused a bonus check based on falsified test results on the 2009 CRCT for Venetian Hills Elementary School; which conduct constitutes racketeering activity pursuant to O.C.G.A. ACTS RAEKETEERENG BE, Sflfififiti DQNALE EULLGCEK served as testing coordinator at Usher/Collier Heights Elementary Schooi, in which capacity he was employed by and associated with APS. In his capacity as testing coordinator, Bfibliaifi conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. 49 n. rare-as let' i' bl: $5 C1213 if" EM Cf} km] Elite} in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2009 and the day oi" 238%, the exact date(_s_) being unknown to the Grand Jurors at this time, did solicit Mary Ware to knowingly and willfully make and use false documents and writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT answer sheets for students at Usher/Collier Heights Elementary School; ?mm\ fact. norrain '3 in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the day of Einrii, 2:639 and the 3% day or' 2069, the exact date(s) being unknown to the Grand Jurors at this time, did solicit Stacy Smith to knowingly and willfully make and use false documents and "writings, by asking her to participate in falsifying students' answer sheets on the 2009 CRCT answer sheets for students at Usher/Collier Heights Elementary Schooh paw; pma G0 wax B@l'alialJ% BELLQEK, in the County of Fulton and State of Georgia, on or between the 28"' clay of riiprilt 289% and the 43"' day of lyiay, 2009, did knowingly and willfully make and use a false document and writing, knowing the same to contain false stateinents, by completing, signing; and submitting a CRCT School Certification Form for Usher/Collier Heights Elementary School to A138, to wit: (1) The written plans for testing were followed, including all directives in the Manual, the Testing Coordinator': Mammal, and system correspondence; and (2) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/circumstance has been reported to the system coordinator; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. 50 Zfiitrz stararvratvrs ailalfi 8 3.329} fifttraitit E?llillfitjg, in the County of Fulton and State of Georgia, on or about the 25"' day of 2616, did knowingly and willfully make false statements to a G81 agent, to wit: a. That he did not assist with anyone with getting tests to change answers on students' CRCT answer sheets; b. That he was not aware of any teachers erasing anything on students' CRCT tests in 2009; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GGSA, being departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. it/Kiwi 203$: FALSE 8 to-ffi-71 32%} BEJLEJQQK, in the County of Fulton and State of Georgia, on or about the 23" day or" iaprtt, 2032, having been administered a lawful oath by a hearing officer authorized to conduct Fair Dismissal Act hearings pursuant to 204-940, did knowingly', willfully', and fatsely swear that he followed the testing guidelines and did not allow teachers iinproper access to testing materials; which conduct constitutes racketeering activity pursuant to O.C.G.A. 16-14-~3 AVES QQNCERNENG BENTEEN ELEMENYARY SQEEQQL SHMLA. served as a teacher at Benteen Elernentary School, in which capacity she was employed by and associated with APS. In her capacity as a teacher, EVANS conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. Lin served as testing coordinator at Benteen Elementary School, in which capacity she was employed by and associated with APS. In her capacity as testing coordinator, conspired and endeavored to violate the Georgia RICO Act through a pattern of raclteteering activity, as described herein below in this Count. hlhi. 288%: E'riiti:LSE statements fisitifi 16-104% tit} in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 223;" day of Aerii, 2099 and the day of? Aprii, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully tnake and use faise documents and writings, knowing the same to contain false entries, by falsifying students' answer sheets on the 2009 CRCT, thereby causing them to falsify their 2009 CRCT answers sheets at Benteen Elementary School; 322} in the County of Fulton and State of Georgia, on or about the day of fisgrii, 2089, did knowingly and willfully make and use a false document and Writing, knowing the same to contain false staternents, by completing, signing, and submitting a CRCT School Certification Form for Benteen Elementary School to APS, to wit: (1) The written plans for testing were followed, including all directives in the Exa.mz'ner's Manual, the Testing C0ordz'naIor's and system. correspondence; and (2) There was ethical behavior on the part of all staff and all students involved in the test administration; any suspected testing irregularity/circuinstance has been reported to the system coordinator; all in a matter within the jurisdiction a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. 52 zoos: E3, 3 and tfit/a,NS, in the County of Fulton and State of Georgia, on or about the 38"' day of 290%, and while employees of a government institution in breach of their duties as government employees, did unlawfully take US. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue each of the accused a bonus check based on falsified test results on the 2009 CRCT for Benteen Elementary School; which conduct constitutes racketeering activity pursuant to O.C.G.A. PRZOEO: E'rtt,SiS ANS o.co.a. 36-18-29 124%} CQPEEQANEB with the offense of STATEMENTS AND WRETENGS, in violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 10"' day of November, Zdtd, did knowingly and willfully make false statements to a GBI agent, to wit: a. That she knew nothing about anyone cheating on the test; b. That she followed testing protocol and tests were put back in the vault after the materials were returned front teachers; c. That she was not involved in cheating at Benteen Elementary School; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. ACES fiti' B311 sranron WEELLEE served as Principal at DH. Stanton Elementary School, in which capacity she was employed by and associated with APS. In her capacity as testing coordinator, conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. 4 served as testing coordinator at DH. Stanton Elementary School, in which capacity she was employed by and associated with in her capacity as testing coordinator, .t3P_fiaF<<5lCiS conspired and endeavored to violate the Georgia RICO Act through a pattern of racketeering activity, as described herein below in this Count. QQ, ZOG9: FALSE AWE in the County of Fulton and State of Georgia, on or between the 39"' eta}! at' Aprii, 2999 and the 30"' day of May, 2889, the exact date(s) being unlcnown to the Grand Jurors at this time, did knowingly and n/ilhiully make and use false documents and writings, knowing the same to contain false entries, by subniitting to APS attendance records for students at DH. Stanton Elementary School reflecting students as present when they were absent from school; 326) and in the County of Fulton and State of Georgia, on or about the is' day of May, 2009, did knowingly and willfully make and use a false document and writing, knowing the same to contain false statements, by completing, signing, and subinitting a Schooi Certification Form for DH. Stanton Elementary School to APS, to wit: (1) Ail test materials were stored in a locked central location prior to, during, and afier the test administration each day; (2) The written plans for testing were followed, including all directives in the Examinefs It/Ianuai, the Testing Coordinator is Jl/Iczmial, and system correspondence; and (3) There was ethical behavior on the part of [staff] involved in the test administration; any suspected testing irregularity/circunistance has been reported to the system coordinator; all in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GGSA, departments or agencies of state government, which conduct constitutes racketeering activity pursuant to O.C.G.A. 54 <22 Le} Effi ed 59* we Ca') It. On or about the 33;" dag! at F/ilaya 289%, after Carver High School Principal Tony Overstreet was notified that his contract with APS would not be renewed, Superintendent BEEJERLY HALL told Mr. Overstreet that she was "not interested in incremental gains." 2. On or between the day ct' 2005 and the at day of august? 2065, the APS Office of Internal Resolution investigated a cheating ailegation by Leah Cauley, a teacher at CW. Hill Elementary School. At the conclusion of OlR's investigation, EEVEIRLY EARL approved a 20 day suspension for the teacher OER confirmed to have cheated. BEVERLY EEALL terminated the vvhistleblower, Leah Cauley. 3. On or between the dim day of dariearg/3 2066 and the day et Eannaryfi Z966, Stacey Johnson told MECHAEL the Executive Director of SRT-2, that WALLEIR was pressuring teachers to cheat on the spring 2006 CRCT. FVEEQEAEEL FETTS did not report the allegation to for investigation. /z -9. On or between the at day ct" Eanaary, 2806 and the 28"' day of Febreary, 2006, Tameka Grant informed that WAELER was pressuring teachers to cheat on the spring 2006 CRCT. Although IVEEQEAEL was the Executive Director of SRT--2, he did not report the allegation to APS for investigation. S. On or between the item day at" dannarf/9 2906 and the 23" day of danaary, 206%, BEVERLY HALL received a complaint which alleged cheating on the Eighth Grade Writing Assessnient at Parks Middle School. As Superintendent of APS, HALL had a statutory duty to report testing violations to the pursuant to O.C.G.A. 20-2409, but she failed to make the required report. a. On or about the day at Eannaryg Zdtl?, after receiving a complaint that WAEJLER was pressuring teachers to cheat on the Spring 2006 CRCT, attended a faculty meeting at Parks Middle School and told the staff to "stop cornplaining" about 'ta/amen because no complaints would affect his status as the principal of Parks Middle School. it On or about the 'r3fi' day of Jianuary, .1-Z966, earn; and PETFS received a complaint which alleged that was falsifying student attendance and records for student participation in after school tutorial services. The Complaint further alleged that was sexually harassing female employees and pressuring teachers to cheat on the Spring .2006 CRCT at Parks Middle School. BEVERLY narr, sent a memorandum with a copy of the complaint to FEW, Chief Human Resources Officer for APS. The memorandum read, "Please investigate and inform me." scratched out the words "inform me." 3fi On or about the day of Eanuary, 2636, WALLER submitted a letter to ratcrranr requesting that vvhistleblowers Stacey Johnson and Tameka Grant he administratively transferred out of Parks Middle School. 9. On or about the 37"' day of Jtanuary, 22606, MEEPEAEL was interviewed by Reginal Dukes, a private investigator hired by APS to investigate the Parks Middle School complaints. At the time of the interview, had directly received a complaint from Stacey iohnson that WAELER was pressuring teachers to cheat on the upcoming spring 2006 CECT. When Regina]. Dukes asked if any concerns had come to his attention relevant to Dukes' investigation, MECEAEL PETES intentionally Withheld his knowledge of this complaint. 36. On or about the Sm day of iiebruary, 2006, after being retaliated against by CHRESTOPHER ENAEJEJER when she reported that WALLER was pressuring teachers to cheat, Stacey Johnson resigned. Before Ms. Johnson could collect her belongings, VXAELEE directed a school resource officer to escort her off the property. At the time she teft, she informed PETTS about "t?Vai4EsER's pattern of sexual harassment and retaliation against her. Although MECBAEL was the Executive Director of SRT--2, he failed to report the allegations to APS for investigation. On or about the day or" March, 2006, Reginal Dukes, an external investigator hired by APS to investigate the .Parks Middle School complaints, sent APS his preliminary findings. Mr. Dukes reported that, among other things, the Georgia Eighth Grade Writing Assessment "may have been compromised" after WALLER "persuaded,[sic] coerced teachers to cheat on the test" and EVALLER was "threatening and intimidating teachers not to reveal information pertinent to [Dukes'] investigation." Despite Dukes' report, took no action against WAELLER. 56 FM: t' it On or about the 7103' day of ltday, Z006, Reginal Dukes met with EARL, MECEAEE and FEW to discuss his investigative conclusions. At this meeting, Withheld his knowledge of the complaints he received from Stacey Johnson and Tameka Grant that VJALEER had pressured teachers to cheat on the Spring 2006 CRCT. 33. Ga or between the is" day May, 2006 and the 39*" day er rune, 2006, BEVERLY narir. received Reginal Dukes' final investigative conclusions that emplo' ees at Pa rs Middle School cheated on the Eighth Grade Writing Assessment by preparing students with a nearly identical writing prompt prior to the administration of the test. The Writing prompt is the topic statement that students are required to Write an essay~style discussion to test their writing abilities. Mr. Dukes also advised that there was reason for concern about the accuracy of student attendance and grades at Parks Middle School; that further investigation was needed into questionable managerial practices; and that the security of the Spring 2006 CRCT may have been compromised. BEVERLY Etatati had a statutory duty to report testing violations to the pursuant to O.C.G.A. 20-2-109, but she did not make the required report. Haiti took no action against after receiving the final report. fifigl On or between the 30"' day oi' May, 2006 and the 303' day of May, 2006, BEVERLY HALE received the Spring 2006 CRCT results for APS, which included the results for Parks Middle School. The results showed large score gains for Parks Middle School compared to the school's performance the previous year. As a result of the Spring 2006 CRCT results, Parks Middle School achieved both AYP and its APS targets for the first time. Despite BEVERLY natars knowledge of Dukes' report concerning cheating at Parks Middle School, BEVERLY HALL did not report this information to the On or about the day at' May, 2006 and the 20"' day of Becemher, 2006, after observing the Spring 2006 CRCT results showing large score increases at Parks Middle School, and despite her knowledge of Reginal Dukes' investigative conclusions and previous complaints that had pressured teachers to cheat, HALE, approved monetary bonuses for WAELER and the Parks Middle School employees. 57 12;' E96 Cu or about the at" day or' 2966, Tameka Grant was transferred out of Parks Middle School by This action was taken after Tameka Grant complained directly to EETTS earlier that year that was pressuring teachers to cheat on the Spring 2006 CRCT. 37. On or between the 28"' day of September, 2006, EEALE met with Justina Collins, a Cascade Elementary School parent who raised concerns about the irnprobability of her daughter's high CRCT scores reiative to her actuai academic perfonnance. Following that meeting, on or about the Eda' day or" hlovernher, Z066, BEVERLY HALL sent Ms. Collins a letter stating that no testing violations occurred with respect to her daughters CRCT administration. 38. On or between the is' day off Apritg 2097 and the 38"' day of august, 2987, BEVERLY EAEL met with a representative of the Annie E. Casey Foundation regarding the Foundation's interest in helping retain as Principal of Parks Middle School. Despite EEVEE: tr' knowledge of Reginal Dukes' investigative conclusions and previous complaints that pressured teachers to cheat, EAEE encouraged the Annie E. Casey Foundation to pay additional money for the purpose of keeping him employed at APS, without informing the Foundation of the cheating complaints at the school. On or about the 34-ih day of august, 2007, BEVERLY was interviewed by the Annie E. Casey Foundation about the dramatic turnaround at Parks Middle School. Despite HiaEE's knowledge of Reginal Dukes' investigative conclusions and previous complaints, including the complaints that EHEESEGEHEE: pressured teachers to cheat on the Spring 2006 CRCT, rrarr withheld this information and instead praised for his leadership at Parks Middle School. Ed. On or about the 24?" day or' Gctoher, 2087, submitted a letter of recornrnendation on behalf of for the Atlanta Families Award which included a payment of $7500. MECEEAELL touted "dynarnic work ethic" and "noteworthy accornplishrnents throughout his lucrative career within the Atlanta Public School Systern," even though PETS had knowledge of sexual harassment complaints and complaints that he pressured teachers to cheat on the Spring 2006 CRCT. 58 "mi .. 'a 2 On or about the 32" day ct EMS, the State of Georgia Superintendent of Schools Office forwarded an anonymous letter to stating that cheating had occurred on the CRCT at Coan Middle School for the last three years. BEVERLEX HALE did not complete an investigation into this allegation. 22. On or between the 33" day ct Eanttaryfi 2608 and the Si" day of December? 2008, Imogene Redwine, a special education teacher at Brown Middle School, initiated a grievance about being placed on a PDP for her students' low test scores. During the grievance process, Ms. snbmitted a cheating complaint to OIR and notified Executive Director SHARON that she was being harassed and retaliated against by the principal. SHAROIEI denied the grievance and Ms. Redvvine was notified that her complaints of cheating and retaliation were unfounded. 23. On or between the day of Ag3t'ii, 2008 and tire day ct" 2008, Keylina Clark, a parent at Blalociq Elementary School, reported to SRT--4 Executive Director, TAMARA QOYMAN that her chiid's teacher gave students the answers during the Spring 2008 CRCT at Blalock Elernentary School. Despite TAMARA promise that she would investigate the matter? Ms. Clark never received any fiirtlier regarding her concerns. did not report the complaint to APS for investigation. 24. On or about the Eu' day et' Jniy, Z098, Keylina Clark contacted OIR and filed a cheating complaint after receiving no response from 'E'Al'vilaRA regarding her complaint that her child's teacher gave students answers during the Spring 2008 CRCT at Blalock Elementary School. On or about the 32"' day ot September, 290%, BEVERLY EALL issued a letter to Ms. Clark informing her that there was no reasonable basis to conclude that a violation occurred. On or between the is' day ct' Eebrtiarys 2009 and the 23.5' day at aprii, 2909, Principal of DH. Stanton Elementary School, Witlidrevv students prior to the Spring 2009 CRCT administration because she believed the students would not perform well on the test and would negatively affect the school's AYP and targets. 59 il\? On or about the ietfi' day et Aprii, Kathleen l\/iathers, the Director for GOSA, spoke with regarding GOSA's concerns about testing improprieties during the Suinnier 2008 Retest at Deervvood Academy. lvls. l\/lathers strongly urged to increase the testing security for the Spring 2009 CRCT administration at Deerwood Academy. BEAJEEQEJEZ indicated that she would provide the additional security, but failed to do so. 273 On or between the ref" day er Aprii, zoos and the 25"' er August, 2009, FEW withheld Reginal Dukes' Pairs Middle School investigative report and other responsive OIR cheating related documents from the Atlanta Journal Constitution in response to an Open Records Act request or "all complaints supporting docnnientation, findings and any and all related docurnents made to the Office of Internal Resolution since March 2006 concerning allegations of Employee Wrongdoing involving all types of parties in the following categories: (Testing, Grading, Applications, other instruction), Public Funds/Property and Improper Rernunerative Conduct." On or between the i th day of Aprii, 2&6? and the 253' day of August, 2099, FREE withheld OlR's complete list of complaints involving testing rnisconduct fi'on1 the A1 in response to an Open Records Act request for "all complaints supporting docnnientation, findings and any and all reiated docurnents made to the Office of Internal Resolution since March 2006 concerning allegations of Employee Wrongdoing involving all types of parties in the following categories: (Testing, Grading, Applications, other instruction), Public Funds/Property and Improper Remunerative Conduct." On or about the tiifi' day of Wiley, 2869, SHARON issued a rnernorandum of understanding to Dr. Jackie Boyce regarding an incident at Herndon Elementary School where students told Dr. Boyce that their teacher had given. them answers on the CRCT. SHARON stated that the allegation of cheating had been investigated and was determined to be unfounded. SEARON also reprimanded Dr. Boyce about the incident. Contrary to statement that the matter had been investigated, the allegation was never submitted to (HR for investigation. On or about the day of dune, 28%, after several unsuccessful attempts by Kathleen l\/lathers to meet with Eitailte to deliver GOSA's preliminary repoit concerning the Deerwood Academy Summer 2008 CRCT Retest Audit, tvvo GOSA employees attended leadership retreat, Where HAEJEJ was speaking. The GOSA einployees hand delivered the report to EARL, despite her attempts to avoid receiving the report. 60 On or about the Eli' day of dune, 289%, hired an external investigator, Attorney Penn Payne, to investigate the allegations in GOSA's Deerwood Academy audit report. On or between the oi" done, 20%? and the 35"} day of duly, 280?, BEVERLY HALE instructed to ensure that OIR destroy drafts of Penn Payne's Deerwood Academy investigation, including lvis. ?ayne's initial draft, which stated that cheating may have occurred. EEW instructed Colinda Howard, the Director of OIR, to destroy the drafts. EEW ensured the documents were destroyed by watching Ms. Howard shred all drafts. 32. On or about the 7% day or" July, 2999, issued a letter to Kathleen Mathers representing that internal investigation was complete and found no basis to substantiate allegations that cheating took place at Deerwood Academy. BEVERLY HALE issued this statement although Ms. Payne's investigation was not complete and BEVERLY E-EAEE had not received Ms. Payne's final report on the Deerwood Academy investigation. 33. On or about the Lil" day of August, 2809, the State of Georgia Superintendent of School's Office forwarded an anonymous letter to BEVERLY and which stated that "retaliation runs rampant within against educators who speak out about cheating. The letter appealed 'for an investigation into cheating be conducted in APS schools. BEVERLY Etiiaitiia and EEW did not complete an investigation into this allegation. 34. On or about the Tflfi' day of November 2009, EEVEREY HALE announced that two experts were being hired to investigate claims of possible cheating raised by an October, 2009 Atlanta Journal Constitution article regarding APS schools that had "highly improbable" test score gains. Doug Reeves, an instructional consultant, was asked to make a "brief inquiry" into the instructional practices in the schools and give an opinion as to whether those practices could have contributed to the score increases. Andrew Porter, a statistician, was asked to determine the "accuracy and validity of the AJC's findings and identify alternative explanations for what [was] found." EAEE promised that upon completion, both reports would be made public. 61 Ca.' fil On or about the 27"" of flaps:-ti, was interviewed by KPMG representatives, Aneil Shanna and Chris Roane in connection with the Blue Ribbon Cornmissiorfs investigation into cheating on the 2009 CRCT. Despite his knowledge about the previous complaints he received from both Stacey Johnson and Tameka Grant, and his knowledge of Reginal Dukes' investigative conclusions from 2006, when MECHAEE NETS was asked about his knowledge of cheating on the CRCT, he withheld this inforination. 36. sf On or about the 33"' day at Fviay, Andrew Porter emailed his final rcport to 33EVnauai Mr. Porter's report concluded that while the test results did not prove that cheating occurred, "they do point to student achievement gains and losses that are highly unusual and for which cheating could be one explanation." BEVERLY Edits did not cornmunicate further with Mr. Porter regarding his report and failed to make the report public as promised. 37, On or between the 19"' day ot' duty, and the day at July, 2010, APS received an Open Records Act request from the AJC for "[t]he report completed by Andrew Porter, dean of the University of Graduate School of Education, concerning CRCT results." APS denied having a copy of the report because BEVERLY Edits claimed to have deleted the report from her computer. 38, On or between the is: day of August, Zflifi and the 36"' day of August, ZOEG, attended a staff meeting at Parks Middle School and told Parks' employees, including Kelli Smith, Dorothea Wilson, and others, that by admitting knowledge of cheating to (381 agents and the Governor's Special Investigators they would only get themselves in trouble. On or between Fetoruary, 2905 and August, 2610, CERESTOPHER WALLER engaged in conduct intended to pressure, intimidate and coerce teachers to cheat and conceal cheating at Parks Middle School each year on the CRCT, This conduct included threats, retaliation, and sexual harassment. to. On or between the ti" day of danuary, 2095 and the 33" day of Beceniber, ZOEO, BEVERLY HALL publicly misrepresented the academic performance of schools throughout APS, including but not limited to Parks Middle School. ?9 On or about the fl" day of Septernher, 283% and the t5' day of ;tune, 2931, received a subpoena to produce all cheating complaints to the Governor's Special Investigators. Contrary to the subpoena, withheld Reginal Dukes' Parks Middle School investigative report and other responsive OER cheating related documents. we On or about the 24:32" day or' la/tay, Zfitt, after receiving a second subpoena from the Governor's Special investigators specifically requesting the Reginal Dukes' investigative file, MELLECENT EEW ordered Nicole Lawson, an OR employee, to compose a rnernoranduin to close the 2006 Parks Middle School investigation tile. then edited the note to state that Reginal Dukes' finding that Parks Middle School cheated on the Georgia Eighth Grade Writing Assessment was unfounded. On or between the 25"' day of Aprii, 2964 and the 28" day of dune, Z810, BEVERLY HALL reviewed numerous CRCT cheating investigations concerning schools throughout APS. rrarjr approved r"rndings that unsubstantiated cheating in most of those investigations. On or between the 23" day or april, 2909 and the 30%' day of aprii, 2009, during the 2009 CRCT administration, the culture at APS created by BEVERLY EARL was such that cheating occurred at many schools in APS, including but not limited to: Beecher Hills Elernentary School, Bethune Elementary School, Coan Middle School, Woodson Elementary School, EL. Stanton Elementary School, Fain Elementary School, Grove Park Elementary School, Hutchinson Elementary School, Jackson Elementary School, M. A. Jones Elementary School, Parkside Elementary School, Thornasville Heights Elementary School, Tooiner Elementary School, and Finch Elenientary School. APS employees at these schools admitted to cheating but have not been charged due to their confessions, cooperation, and truthful testirnony. 63 :31 It: 3" ie--i6--2% and the GRAND JURORS aforesaid, in the name and on hehalf of the citizens of the State of Georgia, do charge and accuse BE'i/Efiift' BALL, with the offense of FALSE ifihifi in violation of O.C.G.A. l6--l O--20, for the said accused, in the County of Fulton and State of Georgia, on or about the 2nd day of Gctober, 2009, did knowingly and willfully make and use a false document and writing, by completing and submitting a Superintendent's Test Certification to the knowing the same to contain false statements, to wit: that adhered to all written regulations and procedures relating to testing and test adniinistration, including the distribution and collection of test materials, test security, use of test results and department testing dates and the reporting of irregularities established in the Student Asse srnent lxtandhook, System and Schooi Test Coordinator Manuals"; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government; contrary to the iaws of said State, the good order, peace and dignity thereof; 3: Bi! i6-8-2 and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse with the offense of TAEGNG, in violation of O.C.G.A. for the said accused in the County of Fulton and State of Georgia, on or about the idfi' day of 2969, and while employees of a government institution in 'breach of their duties as government ernpioyees, did unlawfully take US. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue her a monetary bonus based on 2009 CRCT results for schools in APS which she knew were false; contrary to the laws of said State, the good order, peace and dignity thereof; CGUNY 1610-93 and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse EAMARA with the offense of ENEFLUENEENG WETNESSES, in Violation of G.C.G.A. 16-l0-93, for the said accused, in the County of Fulton and State of Georgia, on or about the 37"' day of Novernher, 2656, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly intimidate Jimrnye Hawkins, and other principals under her supervision, with the intent to hinder or delay the communication of information related to the cornmission of a criminal offense to GBI and other law enforcement officers investigating cheating in contrary to the laws of said State, the good order, peace and dignity thereof; 64 "lit rm: 331: and the GRAND JURORS aforesaid, in the name and on behaif of the citizens of the State of Georgia, do charge and accuse FESTS with the offense of ENFLUENCENG in violation of O.C.G.A. 16-10-93, for the said accused, in the County of Fulton and State of Georgia, on or between the is' day of August, 2016., and the 315' day of august, 2019, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly intimidate Dorothea Wilson, and other staff at Parks Middle School, with the intent to hinder or delay the communication of information related to the commission of a criminal offense to and other law enforcement officers investigating cheating in contrary to the laws of said State, the good order, peace and dignity thereof; d: FALSE i6--it}--2fl and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse SEEARGN with the offense of FALSE STATEMENTS ANB in violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or between the day of Aprii, 2009 and the day of May, 2099, the exact dates being unknown to the Grand Jurors at this time, did knowingiy and wilifully conceal and cover up the material fact that during the 2009 CRCT at Perlcerson Elementary School a proctor was told by students that their teacher gave them correct answers, in violation of the testing rules and regulations set forth by the in a niatter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, depaitinents or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; Efiilhtif 7: FALSE AWE WRETENGS, to-i0~2G and the GRAND JURGRS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse with the offense of FALSE STATEMENTS in violation of O.C.G.A. 16-40-20, for the said accused, in the County of Fulton and State of Georgia, on or between the i9th day of April, 2089 and the Sm day at b?iay, .2909, the exact dates being unknown to the Grand Jurors at this time, did knowingly and willfully make a false document, to wit: a standardized test feedback form, by causing a test monitor to omit his written observation that during the 2009 CRCT at Herndon Elementary School said monitor witnessed a teacher pointing out correct answers to students causing said students to change their answers from wrong to right, in violation of the testing rules and regulations set forth by the in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 65 in-td--7? and the EURORS aforesaid, in the narne and on behalf of the citizens of the State of Georgia, do charge and accuse SEARGN with the offense of FALSE SWEARENG, in violation of O.C.G.A. l6--lO-7l, for the said accused, in the County of Fulton and State cf Gecrgia, on or about the 3rd day at May, having been administered a lawful oath or aftirination, did knowingly and willfully make false statements to the Governor's Special investigators, to wit: a. That she did net receive a testing irregularity report horn Jackie Boycered anybody to change inforrnation or misrepresent That she reported the allegation that a teacher gave students the answers on the CRCT to the Research, Planning, and Accountability office; contrary to the laws of said State, the good order, peace and dignity thereof; FARKS SQEGGL FAESAE AWE e.e.n.a. tenth-2% and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse WALLER, GREGQRY REEB, Sialhlfiflia and KEMBERLEK GBEN with the offense of FALSE STATEMENTS .fi3N.B WRETENGS, in violation of O.C.G.A. 16-10-20, for the said accused, in the County of Eulton and State of Georgia, during the CRCT testing period, on or between the 23" day at amt, 2699 and the as" day at Aprii, 2909, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by changing students' answers from wrong to right on the 2009 CRCT answer sheets for students at Parks Middle School, in a matter within the jurisdiction of APS, a political subdivision of the State cf Georgia, the and GOSA, departrnents or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; It3ifirit.LSE and the JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse WALEJER with the offense of FALSE in Violation of 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 30"' day ot' esprit, 2009, did knowingly and willfully make and use a false document and writing, knowing the same to contain false stateinents, by completing, signing, and submitting a CRCT School Certification Form for Parks Middle School to APS, to wit: (1) The Written plans for testing were followed, including all directives in the Examiner is iwanrzai, the Testing 's and system correspondence; There was ethical behavior on the part of ail staff and all students involved in the test administration; any suspected testing irregularity/circuinstance has been reported to the system coordinator; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departnients or agencies of state governrnent; contrary to the laws of said State, the good order, peace and dignity thereof; ETALSE lalfifi to-1529-29 and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse EHRESTQPEER WALKER and SANERA WARD with the offense of ETAEJSE AND WREETNGS, in violation of O.C.G.A. 16-10~20, for the said accused, in the County of Fulton and State of Georgia, on or about the 28"' day of April, 2918, did knowingly and willfully make and use a false document and writing, knowing the same to contain false statements, by completing, signing, and submitting a CRCT School Certification Form for Parks Middle School to APS, to wit: (1) The written plans for testing were followed, including all directives in the Examiner" is Mammal, the Testing Manual, and system correspondence; (2) There was ethical behavior on the part of all staff and all students involved in the test adniinistration; any suspected testing irregularity/circurnstance has been reported to the system coordinator; in a matter Within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state governnient; contrary to the laws of said State, the good order, peace and dignity thereof; 67 finial? and the GRAND IURORS aforesaid, in the name and on hehalf of the citizens of the State of Georgia, do charge and accuse SAISBRA it/afiifii, with the offense of FALSE ANB in violation of G.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the Ztifi' day ef Gctoloer, 2030, did knowingly and willfully make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone erasing or changing answers on students' CRCT answer sheets, in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departirients or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; iailtlij WRETENQS, E6-it)-29 and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse SEARLEETE With the offense of FALSE :'3a'fia'i'EMEN'i'S ans WRETENGS, in violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 26"' day ef Getober, 2610, did knowingly and willfilly make false statements to a GBI agent, to Wit: that she did not participate in, assist with or have knowledge of anyone erasing or changing answers on students' CRCT answer sheets, in a nia'tter within the jurisdiction of APS, a politicai subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; RLEEJSE AWE WRETEIQGS, 16-3%-2% and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse STARLETTE with the offense of FALSE STATEMENTS ANS in violation of O.C.G.A. 1640-20, for the said accused, in the County of Fulton and State ef Georgia, on or about the St!' day of December, 2316, did knowingly and willfully make a false stateinent to a GBI agent, to wit: that she only participated in erasing and changing answers on students' CRCT answer sheets in 2.009; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; ea rate-ea Efl fa. and the GRAND IURORS aforesaid, in the name and on behalf of the oi izens of the State of Georgia, do charge and accuse with the offense of FALSE STAETEMENTS WRTTENGS, in violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 23"' day of Gctotoer, 201%, did knowingly and willfully make a false statement to a GBI agent, to wit: that he did not participate in, assist with or have knowledge of anyone erasing or changing answers on students' CRCT answer sheets; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GGSA, departments or agencies of state governrnent; contrary to the laws of said State, the good order, peace and dignity thereof; 36: ETAELSE SWEARENG, 3640-7 and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse CERESTQFE-TEE WALKER, with the offense of FALSE SWEARTNG, in violation of O.C.G.A. 16-10-71, for the said accused, in the County of Fulton and State of Georgia, on or about the 18"' day at Aprit, 2013, having been administered a lawful oath or affirmation, did knowingly and willfully make false statements to the Governor's Special Investigators, to wit: a. That he was not aware of any itnproprieties whatsoever with respect to how CRCT testing was conducted at Parks Middie Sehoo That he was not aware of any adult changing answers on students' CRCT answer sheets; c. That he did not have any knowledge of teachers at Parks Middle School keeping tests later than they should have; contrary to the laws of said State, the good order, peace and dignity thereof, E7: ?5833 ('ml pm] 'ill and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse Gfihflfihfi' with the offense of FALSE in violation of O.C.G.A. l6--iO~7l, for the said accused, in the County of Fulton and State of Georgia, on or about the 33$' day of rfiprii, Zdii, having been administered a lawful oath or affirmation, did knowingly and willfully make false statements to the Governor's Special lnvestigators, to wit: a. That he was not aware teachers were cheating on the CRCT at Parks Middle School; That he did not est or wrect teachers to cheat; That he did not have any knowiedge of teachers at Parks Middle School keeping tests later than they should have; contrary to the laws ofsaid State, the good order, peace and dignity thereof; ES: SWEAREFSQ, and the GRAND EURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse EEVRREIE EALL, with the offense of FALSE SWEARENS, in violation of O.C.G.A. l6-lG--7i, for the said accused, in the County of Fulton and State of Georgia, on or about the 38"' day of May, 201i, having been administered a lawful oath or affirmation, did knowingly and willfully rnake false statements to the Governor's Special Investigators, to wit: a. That she never received complaints about Parks Middle School or WALEER after he became principal; b. That she never met with Reginal Dukes in connection with his investigation into complaints about WAEJLER at Parks Middle School; contrary to the laws of said State, the good order, peace and dignity thereof; 70 in-id-7% and the G-RAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse FEW, with the offense of FALSE SWEARKNG, in violation of l6~lO--7l, for the said accused, in the County of Fulton and State of Georgia, on or about the 1" day er" Jane, having been adniinistered a lawful oath or affinnatiori, did knowingly and willfully make false statements to the Govenior's Special Investigators, to Wit to wit: a. That she never ordered the destruction of early drafts of the Deerwood investigation completed by outside investigator Penn Payne; b. That she did not meet with Reginal Dukes in connection with his investigation into complaints about WALEER at Parks Middle School; contrary to the laws of said State, the good order, peace and dignity thereof; ELEMENYARY 233: FALSE SEATEMEFJYS AND WRETENGS, 1640-20 and the GRAND EURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse and RGGERS with the offense of sraraatanrs ARTE WREYENQS, in violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 23" day at aprii, 2009 and the 39:" day of April, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by changing students' answers from wrong to right on the 2009 CRCT answer sheets for students at Gideons Elementary School in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 71 EFAELSE ?fslfi re-rare and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse ARMSTEAB and SHEREBAN ROGERS with the offense of FALSE, SEATEMENTS ANB in violation of l6--lD--2.0, for the said accused, in the County of Fulton and State of Georgia, on or about the day of May, recs, did knowingly and willfully rnake and use a false document and writing, knowing the same to contain false statements, by completing, signing, and submittirig a CRCT School Certification Penn for Gideons Elementary School to APS, to wit: (1) The written plans for testing were followed, including all directives in the Examz'ner's the Testing Coordinator 's fl?ianiiai, and system correspondence; (2) There was ethical behavior on the part of all staff and ail students involved in the test adrninistration an sus ected testin irre larit /circuinstance has been re oited to the a system coordinator; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 22: FALSE SEATEFVEENTS AME WRETENGS, oleoa. and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse SHEREDAN RGGERS with the offense of FALSE ANB in violation of O.C.G.A. l6~--lO-20, for the said accused, in the County of Fulton and State of Georgia, on or about the day of Gctober, 2610, did knowingly and willfully make false statements to a GBI agent, to wit: a. That she did not return CRCT booklets to teachers so they could change answers; b. That she did not instruct teachers to change answers on CRCT answer sheets; and c. That she was not present while other teachers changed students' answers on the CRCT answer sheets; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; ff: 3: rm': km and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse with the offense of ENFLUENCENG in violation of O.C.G.A. i6-lO--93, for the said accused, in the County of Fulton and State of Georgia, on or between the St?" day of Sane, and the day of November', 263%, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly intimidate Oliver Banks, and other Gideons Elementary School employees, with the intent to hinder or delay the communication of information related to the commission of a criminal offense to G131 and other law enforcement officers investigating cheating in contrary to the laws of said State, the good oider, peace and dignity thereof; LZEGBBS SCEEGGL Qfiilhli" 24: FALSE sraiesanats fialsfi to-30-23 and the GRAND IURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse SANA EVANS, ANGELA WELEJEAMSGN, DERRECK enoanyi/area and with the offense of FALSE STATEMENTS AND in Violation of O.C.G.A. l6--10--20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period, on Of between the 21" day of April, 2009 and the set day ei April, 2069, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by giving students correct answers to the 2009 CRCT, thereby causing them to falsify their 2009 CRCT answers sheets at Dobbs Elenieritary School, in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 73 r'"1 l'sl'?'S ANS in-*t0--2% live UT: Cf} El and the GRAND URGES aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse risen. EVANS with the offense of ETALSE STATEMENTS ANE ENRETENGS, in violation of O.C.G.A. l6-lO-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 30"' day or' April, 200%, did knowingly and willfully make and use a false document and writing, knowing the same to contain false statements, by completing, signing, and submitting a CRCT School Certification Fonn for Dobbs Elementary School to APS, to wit: (1) The written plans for testing were followed, including all directives in the Emmz'n.er 15' Manual, the Testing Coorci'.z'nai'or 's Mnmzal, and sy ten: correspondence; (2) There was ethical behavior on the part of all staff and all students involved in the test adininistration; any suspected testing irregularity/circumstance has been reported to the system coordinator; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; as: and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse and SHAYLA SMETE with the offense of FALSE AWE WRETENGS, in violation of O.C.G.A. l6-10-20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 20"' day of April, 2030 and the 30"' day of Aprii, 20%, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by giving students correct answers to the 2010 CRCT, thereby causing them to falsify their 2010 CRCT answers sheets at Dobbs Elementary School, in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 74 Afsifi in-f;G--Z% Fifi ;'i?ti'sS and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse EESSA EURE with the offense of FALSE STATEMENYS ANE in violation of G.C.G.A. l6-lG~20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21" day of April, 2689 and the sat' day oi' raprii, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by changing students' answers horn wrong to right on the 2009 CRCT answer sheets for students at Dobbs Elementary School in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, depaitineiits or agencies of state government; contrary to the iaws of said State, the good order, peace and dignity thereof; ZS: FALSE ANS WRETENGS, E6410-20 and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse EANA with the offense of FALSE AWE in violation of G.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 29"' day of April, 2610, did knowingly and wilifully make and use a false doctirnent and writing, knowing the same to contain false staternents, by completing, signing, and submitting a CRCT School Certification Fonn for Dobbs Elernentary School to APS, to wit: (1) The written plans for testing were followed, including all directives in the Examiner is rldanzral, the Testing Coordinator is Manual, and system correspondence; (2) There was ethical behavior on the part of all staff and all students involved in the test administration; any suspected testing irregularity/circurnstance has been reported to the system coordinator; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; Wr fl, are-as 9-. pi" i" and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse EERRECK enoanwarnn with the offense of FALSE fiifti?i} in violation of O.C.G.A. l6--10~2G, for the said accused, in the County of Fulton and State of Georgia, on or about the day of February, did knowingly and willfully make false statements to a GBI agent, to wit: that he did not participate in, assist with or have knowledge of anyone giving students answers during the in a inatter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; i6-- .0-ZG Jugj VGEUNT Sit: and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse EESSA GEJRB with the offense of FALSE STATEMENTS fiiltifl WREKEENGS, in violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 23" day of February, Zdli, did knowingly and vvillfiilly niake false statements to a GBE agent, to wit: that she did not participate in, assist with or have knowledge of anyone giving students answers during the in a matter within the jurisdiction of APS, a politicat subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; Iii: FALSE SYAYEMENTS ANS WRETENGS, raises and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse QANA EVANS with the offense of FALSE ANB in violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 27"' day of February, 261%, did kiiowingly and willfully rnake false statements to a GBI agent, to wit: a. That she did not hear anything about cheating at Dobbs Elementary School; b. That she did not allow teachers to cheat at Dobbs Elernentary School; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 76 32: sraretvtarsts to-203% and the GRAND EURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse ANGELA with the offense of FALSE ante in violation of O.C.G.A. 1610-20, for the said accused, in the County of Fulton and State of Geotgia, on or about the 1" day of March, 2031, did knowingly and willfully make false statements to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone giving students answers during the in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 33: EALSEC G, and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse ANGELA WELLEAMSGN, with the offense of FALSE SWEARENQ, in violation of O.C.G.A. 16-10-71, for the said accused, in the County of Fulton and State of Georgia, on or about the day of June, 2032, having been adininistered a lawful oath by a hearing officer authorized to conduct Fair Dismissal Act hearings pursuant to O.C.G.A. 20-4-940, did knowingly, willfully, and falsely swear that she did not give students answers to the CRCT at Bobbs Elementary School; contrary to the laws of said State, the good order, peace and dignity thereof; 34: SWEARENG, o.c.o.a. to-id-73 and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse with the offense of FALSE SWEARENG, in Violation of O.C.G.A. 1640-71, for the said accused, in the County of Fulton and State of Georgia, on or about the 25"' day of April, 2012, having been administered a lawful oath by a hearing officer authorized to conduct air Dismissal Act hearings pursuant to O.C.G.A. 20-4-940, did knowingly, willfully, and falsely swear: a. That he did not cheat on the CRCT at Dobbs Elementary School; b. That he did not give students answers on the c. That he did not encourage students to erase and change their answers on the contrary to the laws of said State, the good order, peace and dignity thereof; 77 Sid: EAESE and the GRAND aforesaid, in the name and on behalf of the citizens of the State of Georgia, do cha.rge and accuse SMETE, with the offense of EALSE in Violation of O.C.G.A. l6-10>>-7i, for the said accused, in the County of Fulton and State of Georgia, on or about the 27% day of August, 2632, having been administered a lawful oath by a hearing officer authorized to conduct Fair Dismissal Act hearings pursuant to O.C.G.A. 20-4- 940, did knowingly, willfully, and falsely swear that she never gave any students answers on any contrary to the laws of said State, the good order, peace and dignity thereof; EGEIEE as; EAESE in-lid-"FE and the GRAND JURGRS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse ANGEEA with the offense of EAESE in violation of O.C.G.A. l6--lO--71, for the said accused, in the County of Fulton and State of Georgia, on or about the 3" day of December, 2912, having been administered a lawful oath by a hearing officer authorized to conduct Fair Dismissal Act hearings pursuant to O.C.G.A. 20-4-940, did knowingly, willfully, and falsely swear: a. That she did not prompt or give students correct answers to the CRCT at Dobbs Elementary School; lo. That she did not cheat at point on the 2069 CRCT at Dobbs Elementary School; contrary to the laws of said State, the good order, peace and dignity thereof; BENBAR ELEMENTARY SCEGGE CGENTE 37: EAELSE SEAEEMENTS AND WRETENGS, and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse SHANE RGEENSGN, and EEANE with the offense of EAESE SEAEEMENTS AND WRETENGS, in Violation of O.C.G.A. l6~10--20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 23" day of Aprii, 2009 and the 30" day at aprii, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by changing students' answers from wrong to right on the 2009 CRCT answer sheets for students at Dunbar Elementary School; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the Georgia Department of Education and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; Etffailfslil' and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse with the offense of FALSE AND in violation of O.C.G.A. 16-lO~20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the day of Aprii, 2969 and the 39"' day of Aprii, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by giving students correct answers to the 2009 CRCT, thereby causing them to falsify their 2009 CRCT answers sheets at Dunbar Elementary School; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GOSA, departments or agencies of state government; contrary to the iaws of said State, the good order, peace and dignity thereof; 39: FALSE STATEMENTS ARTE and the GRAND EURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse with the offense of FALSE STATEMEFJTS in violation of O.C.G.A. l6-iO--20, for the said accused, in the County of 'iulton and State of Georgia, on or about the at" day of May, 2009, did lrnowingly and wiilfully rnalce and use a false document and writing, knowing the same to contain false statements, by completing, signing, and submitting a CRCT School Certification Forrn for Dunbar Elementary School to APS, to wit: (1) The written plans for testing were followed, including all directives in the Manual, the Testing Coordinator 's Mhmtai, and system correspondence; (2) There was ethical behavior on the part of all staff and all students involved in the test administration; any suspected testing irregularity/ circumstance has been reported to the system coordinator; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; ENFLEENCENG 16-E033 and the GRANB JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse EJERA with the offense of iNFiUilEl?iCIlhlt? in violation of O.C.G.A. 16-10-93, for the said accused, in the County of Fulton and State of Georgia, on or about the till' day of April 2011, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly intimidate Rose Neal, with the intent to hinder or delay the communication of information related to the cornrnission of a criminal offense to G131 and other law enforcement officers investigating cheating in contrary to the laws of said State, the good order, peace and dignity thereof; 79 i in-It@-28 the GRAND EURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse GLGREA with the offense of FALSE ANL3 in Violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the iSfi' day at Gctotier, 2016, did knowingly and willfully rnake a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone giving students answers to the in a matter within the jurisdiction of APS, being a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; CGUNTC FALSE STALETVEETQTS AWE i?-10-26 and the GRAND EURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse with the offense of FALSE AND WRETENGS, in Violation of O.C.G.A. l6--lO--20, for the said accused, in the County of Fulton and State of Georgia, on or about the 19"' day of October, Zdit], did knowingly and willfully make false statements to a GBE agent, to wit: that she did not participate in, assist with or have lcnowledge of anyone erasing or changing answers on students' CRCT answer sheets; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the GOSA, and the GBE, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; ?ifiz FALSE AND E6-id-Z0 and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse PAMELA ELEVELANB with the offense of FALSE STATEMENTS Ahlfi in Violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 19"' day of Gctober, 2638, did knowingly and willfully make false statements to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone erasing or changing answers on students' CRCT answer sheets; in a matter within the jurisdiction of AP S, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof, SCEZGGE it-ii: AND ltd-id-2% and the GRAND URORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse LESA TERRY, ENGRED and WENDY anryiao with the offense of FALSE AND WRETENGS, in violation of O.C.G.A. 1640-20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the Zi" day or? rtiprii, 2809 and the 30"' day of Aprii, 280%, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by giving students correct answers to the 2009 CRCT, thereby causing them to falsify their 2009 CRCT answers sheets at Humphries Elementary School; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; t-S: "itiflhif Eta' ie--S-Z and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse i4iSia ENGRED and with the offense of THEFT BY in violation of O.C.G.A. 16-8-2, for the said accused in the County of ton and State of Georgia, on or about the tell' day of Deceinher, 28%, and while employees of a government institution in breach of their duties as government employees, did unlawfully take US. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue each of the accused a bonus check based on falsified test results on the 2009 CRCT for Humphries Elementary School; contrary to the laws of said State, the good order, peace and dignity thereof; tie: FAEJSE AND WRETENGS, l?--1fi-20 and the GRAND EURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse EFJGRED with the offense of FALSE in violation of O.C.G.A. l6--lO-20, for the said accused, in the County of Fulton and State of Georgia, on or about the day of Gctoher, 201%}, did knowingly and willfully make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone giving students answers to the in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 4347: Zaldfi and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse fiitih/EEG with the offense of FALSE STATEMENTS iifllit WRETENGS, in Violation of O.C.G.A. 16-10-20, for the said accnsed, in the County of Fulton and State of Georgia, on or about the 27"' day of Getoioer, 2910, did knowingly and willfully make a false statement to a GBI agent, to wit: that she did not participate in, assist with or have knowledge of anyone giving students answers to the in a matter within the jurisdiction of AFB, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state governnient; contrary to the laws of said State, the good order, peace and dignity thereof; fsdififiifi CGEINT Iitiz EYALSEF, ANS WRETENGS, o.e.o.a. and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse LUCEGEJS ERGWN, CARGL BENNES and TAMEKA with the offense of FALSE in violation of O.C.G.A. 36-10-20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 21.3." day of April, 2009 and the 36"' day of Aprii, 2869, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by changing students' answers from wrong to right on the 2009 CRCT answer sheets for students at Kennedy Middle School; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; ialsifi raises and the GRAND IURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse LUCEGHS with the offense of FALSE SYATEMENTS fithffi WRETENGS, in violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 30%" day of april, 2809, did knowingly and willfully make and use a false document and writing, knowing the same to contain false statements, by completing, signing, and submitting a CRCT School Certification Form for Kennedy Middle School to APS, to wit: (1) The written plans for testing were followed, including all directives in the Examiner 's jldfamzal, the Testing Coom"imtc:~ is jlianaal, and systern correspondence; and (2) There was ethical behavior on the part of all staff and all students involved in the test adrninistration; an sus ected testin irre larit /circumstance has been re orted to the 311 system coordinator; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; Sta: FALSE SYATEMENTS AWE EWREMNGS, G.EUR.G.A. rerazo and the GRAND IURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse TABEEKA EGEBAN with the offense of FALSE AND in violation of O.C.G.A. 16-l0-20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 235' day of April, 2009 and the Bfith day of Anril, 2009, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by erasing and changing students' answers from wrong to right on the 2009 CRCT answer sheets for students at Deerwood Academy; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 83 ?1t: and the RERORS aforesaid, the narne and on behalf of the citizens of the State of Georgia, do charge and accuse EGREAN with the offense of BY in Violation of O.C.G.A. 16-8-2, for the said accused in the County of Fulton and State of Georgia, on or about the day of Eaecernber, 2009, and while an employees of a government institution in breach of her duties as government employees, did unlawfully take US. currency, the property of APS, with the intention of depriving said owner of said property by causing APS to issue the accused a bonus check based on falsified test results on the 2009 CRCT for Deerwood Academy; contrary to the laws of said State, the good order, peace and dignity thereof; t'C'llN'?' FAESE ?ahlfi l6--l0-26 and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse with the offense of FALSE ANB WREHNGES, in Violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period on or between the 23" day at" Aprii, 286? and the Btfith day of Aprii, Zt")i"J9, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, the same to contain false entries, by erasing and changing students' answers front wrong to right on the 2009 CRCT answer sheets for students at Venetian Hills Elementary School; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia; the and GQSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; S3: and the EURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse GAVES with the offense of FALSE in violation of O.C.G.A. I6-10-20, for the said accused, in the County of Fnlton and State of Georgia, on or about the 36th day or" April, 2009, did knowingly and willfully make and use a false document and writing, knowing the same to contain false statements, by completing, signing, and submitting a CRCT School Certification Form for Venetian Hills Elementary School to APS, to wit: (1) The written plans for testing were followed, including all directives in the Esraminers the Testing Coordinator is iwaiiziai', and system correspondence; and There was ethical behavior on the part of all staff and all students involved in the test administration; any suspected testing iiregularity/circumstance has been reported to the system coordinator; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; S451: Eh' iihl?ihlfi, to-S-2 and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse einninrra BAVES with the offense of BY TAKENG, in violation of O.C.G.A. 16-8-2, for the said accused in the County of Fulton and State of Georgia, on or about the 318th day of Becember, 2009, and while an employee of a governrnerit institution in breach of her duties as a government employee, did unlawfully take US. currency, the property of APS, with the intention of depriving said owner of said property by causing APS to issue the accused a bonus check based on falsified test results on the 2009 CRCT for Venetian Hills Elementary School, contrary to the laws of said State, the good order, peace and dignity thereof; SEE-ifiifiia SS: FALSE E643-29 and the GRAND IURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse nonarn BUELGCK with the offense of FALSE fi:_Nfi in violation of O.C.G.A. l6--lO-20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the 23" day of fiiprit, 2099 and the Efifi' day at aprii, 280%, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by erasing and changing students' answers fiom wrong to right on the 2009 CRCT EL). swer sheets for students at Usher/Collier Heights Elementary School; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state contrary to the laws of said State, the good order, peace and dignity thereof; se: f'iaiilSE AWE WRETENGS, and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse BGNALB with the offense of FALSE ann in violation of O.C.G.A. for the said accused, in the County of Fulton and State of Georgia, on or between the 28"' day of April, 2009 and the Lit" day er" it/lay, did imowingly and willfully make and use a false document and writing, knowing the same to contain false statements, by completing, signing, and submitting a CRCT School Certification Form for Usher/Collier Heights Elementary School to APS, to wit: (1) The written plans for testing were followed, including all directives in the Examiner '5 Manual, the Testing Coordinator is Manila], and system correspondence; and (2) There was ethical behavior on the part of all staff and all students involved in the test administration; any suspected testing irregularity/circumstance has been reported to the system coordinator;; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 86 S7: 36-39-28 1 we and the GRAND IURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse BGNALD with the offense of FALSE ANS in violation of O.C.G.A. 16-1 0-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 26"' day of Gctoher, 2010, did knowingly and willfully make false statements to a agent, to wit: a. That he did not assist with anyone with getting tests to change answers on students' CRCT answer sheets; That he was not aw re of any teachers erasing anything or students' CRCT tests in 2009; in a matter within the jurisdiction of APS, a politicai subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; SS: LTAESE and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse BGNAEE BEJLEJGEEQ, with the offense of FALSE SWRARENG, in violation of O.C.G.A. 16-10-71, for the said accused, in the County of Fuiton and State of Georgia, on or about the 23rd day of Aprii, ZSEZ, having been administered a iawful oath by a hearing officer authorized to conduct air Dismissal Act hearings pursuant to O.C.G.A. 20-4-940, did knowingly, willfully, and falsely swear that he followed the testing guidelines and did not allow teachers improper access to testing materials; contrary to the laws of said State, the good order, peace and dignity thereof; BENTREN ELEMENTARY SCEEGGL SS: FALSE AWE WRETENGS, is-recs and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse EVANS with the offense of FALSE STATEMENTS ANB in violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, during the CRCT testing period, on or between the day of esprit, 2009 and the 30"' day of iaerii, 2809, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by giving students correct answers to the 2009 CRCT, thereby causing them to falsify their 2009 CRCT answers sheets at Benteen Elementary School; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GGSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 87 C'?27Ul'el'f ea; res-2* and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse, QGFELAND and SHEELA EVANS with the offense of YAEQENQ, in violation of O.C.G.A. 16-8-2, for the said accused in the County of Fulton and State of Georgia, on or about the t8th day of Beceinber, 2069, and while employees of a government institution in breach of their duties as government employees, did unlawfully take US. currency, the property of APS, with the intention of depriving said owner of said property, by causing APS to issue each of the accused a bonus check based on falsified test results on the 2009 CRCT for Benteen Elementary School; contrary to the laws of said State, the good order, peace and dignity thereof; er: ?FfiiliJSE AND and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse THERESEA, with the offense of FALSE STATEMENTS ARTE in violation of O.C.G.A. 16-10-20, for the said accused, in the County of fiulton and State of Georgia, on or about the 30"' day of April, 2009, after said accused committed a testing violation by obtaining and using an actual copy of the 2009 CRCT to prepare students prior to the test administration, did knowingly and willfully make and use a false docnrnent and writing, knowing the same to contain false statements, by completing, signing, and submitting a CRCT School Certification Form for Benteen Elementary School to APS, to wit: (1) The written plans for testing were followed, including all directives in the Examiner is Marina], the Testing Coordinator '5 Manttal, and system correspondence; and (2) There was ethical behavior on the part of all staff and all students involved in the test administration; any suspected testing irregnlarity/circumstance has been reported to the system coordinator; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state governinent; contrary to the laws of said State, the good order, peace and dignity thereof; 62: 7' 16-35?-2% no and the GRANB EURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse TETERESTA CQPEELANB with the offense of fiilslfa in violation of 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the iatlfl' day ot'Noven1bes, 203:0, did knowingly and willfully make false statements to a GBI agent, to wit: d. That she knew nothing about anyone cheating on the test; That she followed testing protocol and tests were put back in the vault after .. 4- inffi the materials weie 1eLl.u1lCU from teachers, (0 That she was not involved in cheating at Benteen Elementary School; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; CGTJISIT ea: EVAEJSE WRETEIQSS, and the GRAND EURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse Sfitiltilfia with the offense of TS anon in Violation of O.C.G.A. 16-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the 18"' day of November, 2630, did knowingly and willfully make false statements to a G131 agent, to wit: g. That she did not give students answers to the h. That she did not answer questions to the CRCT for students; i. That she did not participate in any cheating at Benteen Elementary School; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; 89 I E5. SEBGGL er: FALSE o.c.o.a. lo-10-2% and the GRAND EURORS aforesaid, in the narne and on behalf of the citizens of the State of Georgia, do charge and accuse hi/llLElt? with the offense of fiihlfi in violation of O.C.G.A. l6--l0--20, for the said accused, in the County of Fulton and State of Georgia, on or between the 36"' day of April, 2809 and the 39"' day or" May, 2989, the exact date(s) being unknown to the Grand Jurors at this time, did knowingly and willfully make and use false documents and writings, knowing the same to contain false entries, by submitting to APS attendance records for students at DH. Stanton Elementary School reflecting students as present when they were absent frorn school; in a matter within the jurisdiction of APS, a political subdivision of the State of Georgia, the and GOSA, departments or agencies of state government; contrary to the laws of said State, the good order, peace and dignity thereof; es: FALSE STAEEMENYS ANS WRETENGS, 16-16-20 and the GRAND JURORS aforesaid, in the name and on behalf of the citizens of the State of Georgia, do charge and accuse and FRANCES with the offense of FALSE also in violation of O.C.G.A. lo-10-20, for the said accused, in the County of Fulton and State of Georgia, on or about the day of May, 29%, did knot-vvingiy and willfully make and use a false docinnent and writing, rowing the same to contain false statements, by completing, signing, and submitting a CRCT School Certification Form for DH. Stanton Elementary School to APS stating that: (1) All test inaterials were stored in a locked central location prior to, during, and after the test administration each day; (2) The Written plans for testing were followed, including all directives in the Examz'ner's Manual, the Testing Coordinators and system correspondence; and (3) There was ethical behavior on the part of all staff and all students involved in the test administration; any suspected testing irregularity/circunistance has been reported to the system coordinator; contrary to the laws of said State, the good order, peace and dignity thereof. FAEJL L. EEGWARB, JR, District Attorney 90 FOR IMMEDIATE RELEASE Friday, March 29, 2013 GRAND JURY INDICTS 35 IN CONNECTION WITH ATLANTA PUBLIC SCHOOLS CHEATING SCANDAL Former Superindent Beverly Hall Accused of Leading 'Conspiracy' Atlanta- A Fulton County Grand Jury has returned indictments against former APS Superintendent Dr. Beverly Hall and 34-subordinates in connection with a test cheating scandal. Each of the defendants is charged with Georgia RICO (Racketeer Influenced and Corrupt Organizations) conspiracy. The 65-count indictment also includes charges of False Statements and Writings, False Swearing, Theft by Taking and Influencing Witnesses in connection with the alleged conspiracy to alter Criterion Referenced Competency Tests (CRCT) scores. The District Attorney's 21-month criminal investigation follows a 2011 probe initiated by the Governor's Office into testing irregularities and cheating allegations on 2008-2009 CRCT exams in dozens of Atlanta Public Elementary Schools. The District Attorney's Office created a special unit of prosecutors and investigators to explore potential criminal activity connected with the allegations. The investigation included a review of testing activity associated with at least 50 APS schools as well as hundreds of interviews with school administrators, staff, parents and students. Prosecutors allege the 35 named defendants conspired to either cheat, conceal cheating or retaliate against whistleblowers in an effort to bolster CRCT scores for the benefit of financial rewards associated with high test scores. The alleged activity dates back to as early as 2005. In addition to Dr. Beverly Hall, the indicted defendants include four highlevel executive administrators, six principals, two assistant principals, six testing coordinators, 14 teachers, a school improvement specialist and a school secretary. Grand Jury warrants have been issued for the arrest of each defendant. The case will now be assigned to a Fulton County Superior Court Judge and scheduled for trial. ########### 1 Defendants Dr. Beverly Hall - Superintendent Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings False Swearing Theft by Taking Millicent Few, Esq.- Human Resources (Executive Staff) Violation of Racketeer Influenced and Corrupt Organizations Act False Swearing School Resource Team Executive Directors: 3 1. Dr. Sharon Davis-Williams (SRT-1) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements (2 counts) False Swearing 2. Mr. Michael Pitts (SRT-2) Violation of Racketeer Influenced and Corrupt Organizations Act Influencing Witnesses 3. Ms. Tamara Cotman (SRT-4) Violation of Racketeer Influenced and Corrupt Organizations Act Influencing Witnesses Principals: 6 1. Mr. Christopher Waller (Parks Middle School) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (3 counts) False Swearing 2. Dr. Luscious Brown (Kennedy Middle School) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) 3. Ms. Dana Evans (Dobbs Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (4 counts) 4. Ms. Clarietta Davis (Venetian Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) Theft by Taking 2 5. Mr. Armstead Salters (Gideons Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) Influencing Witnesses 6. Ms. Willie Davenport (D.H. Stanton Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) Assistant Principal: 2 1. Mr. Gregory Reid (Parks Middle School) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (3 counts) False Swearing 2. Ms. Tabeeka Jordan (Deerwood Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings Theft by Taking Testing Coordinators: 6 1. Ms. Sandra Ward (Parks Middle School) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (3 counts) 2. Ms. Francis Mack (D.H. Stanton Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings 3. Mr. Sheridan Rogers (Gideons Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (3 counts) 4. Ms. Lera Middlebrooks (Dunbar Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) Influencing Witnesses 5. Mr. Donald Bullock (Usher-Collier Heights Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (3 counts) False Swearing 3 6. Ms. Theresia Copeland (Benteen Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act Theft by Taking False Statements and Writings (2 counts) School Improvement Specialist: 1 1. Dr. Tameka Goodson (Kennedy Middle School) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings Teachers: 13 1. Ms. Starlette Mitchell (Parks Middle School) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (3 counts) 2. Ms. Kimberly Oden (Parks Middle School) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings 3. Ms. Shayla Smith (Dobbs Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) False Swearing 4. Ms. Angela Williamson (Dobbs Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) False Swearing (2 counts) 5. Ms. Dessa Curb (Dobbs Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) 6. Mr. Derrick Broadwater ( Dobbs Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (3 counts) False Swearing 7. Ms. Pamela Cleveland (Dunbar Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) 4 8. Ms. Shani Robinson (Dunbar Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings 9. Ms. Diane Buckner-Webb (Dunbar Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) 10. Ms. Gloria Ivey ( Dunbar Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) 11. Ms. Lisa Terry (Humphries Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings Theft by Taking 12. Ms. Ingrid Abella-Sly (Humphries Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) Theft by Taking 13. Ms. Wendy Ahmed (Humphries Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) Theft by Taking 14. Ms. Sheila Evans (Benteen Elementary) Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings (2 counts) Theft by Taking Secretary: 1 Ms. Carol Dennis (Kennedy Middle School Violation of Racketeer Influenced and Corrupt Organizations Act False Statements and Writings 5 Charges and Sentence Ranges Violation of Racketeer Influenced and Corrupt Organizations Act O.C.G.A. 16-14-4 (C) 5-20 years False Statements and Writings O.C.G.A 16-10-20 1-5 years False Swearing O.C.G.A. 16-10-71 1-5 years Theft by Taking O.C.G.A. 16-8-2 1-15 years Influencing Witnesses O.C.G.A. 16-10-93 1-5 years 6