v.5? DATE: T0: . NOTE: THOMAS F. JARRIEL .Attorn or at Law 330 Mulberry Street Suite G-3 Macon, Georgia 31201 (478)254~5181 Phone (478)254-5685 Fax tomiarriolquahoomnm C0 VE SHEET Thomas Jamie] 104.4?1 6 Mike Bowers, Esq. 404-261?3656 Bartlett Per our cexams-reetion9 a copy of the Indictment follows. Thank you. N05 OF PAGFS (including cover sheet): 12 IN THE EVENT THAT YOU RECEIVE THIS FACSIMILE IN ERROR, PLEASE CALL ii 473?254?5181; The information ooni?ained in this telecopier transmission may be legally privileged and/or contain con?dential information intended only for the use ofthe individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this teleoopy is strictly prohibited. FRI: 82:52 PM 473 733 0439 ECP INDICTMENT NO. Hg? CQ- 379 CASE NO. BPD 150309-1267] -. .1. . INDICETMENT m' we am? {09 STATE OF GEORGIA, PEACH COUNTY The Gtand Jurors selected, chosen and sworn for the County of Peach, to-wit: (1) David Alexander Amen, Foreman; (2) . Deputy Foreman; (3) I,ind%ilnderwood, Secretary; (4) ennifcr High Bar?eld; (5) 6) ChesterC . .. . M) Beth Leigh Pierson; (10) Vernon Jer Wetcn; (ll) Cathy Maxie go; (12) Janet Benita Scott; (13) - (Elm ?(Mac-3S: .12! i5) John Sidney Bryant; (16) Laura Janette Valencia; (17) - . Christopher Wayne Carr; (18) Jimmy Arble Rogers; (19) Julie Melinda Love; (20) Skylar Reid Buecker; (21) Candace Moore Smith; (22) Lakeith Nical Rumph; (23) John T. Bax?eld; in the name and behalf of the citizens of Georgia, charge and accuse RONALD D. BARTLETT AND LEE BARTLETT {with hEaving committed the offense of THE SCHEME. THE ENTERPRISE, THE PATTERN 0E RACKETEERING ACTIVITY 1. At all times relevant, Defendants Ronald D. Bartlett and Lee Bartlett (collectively ?Defendants" or ?Bartletts?) owned and operated several businesses in Peach County and other counties in the State of Georgia including Captain Jack?s Crab Shack Jack?s?) located at 107 Chapman Road. Byron, Peach County, . Georgia; Friend?s Bar dz Grill (?Friends") located at 7405 Industrial Highway, Macon, Bibb County, Georgia and Chevy?s (Chevy?s?) located at 1229 Russell Parkway, Warner Robins, Houston County. Georgia. E.2 Beginning in or about January, 2013, the exact date being unknown to the Grand if Jury, and continuing through in or about May, 2015, the Defendants did BEURGIA FEAGH Clark's Ofilce, Superior Court - Filed in Office of tone/2015 sex 3:52 FAX an 733 0489 ECP Distributors 210. knowingiy execute a scheme, in Peach County and other counties, whereby they operated purported legitimate bitsinesses at which the Defendants placed Gambling Devices for purpoees of illegal gambling at the Captain Jack?e location. gThe Gambling Devices (?Gambling Devices?) placed at Captain Jack?s are illegal :Gambling Devices or, alternatively, considered Gambling Devices in that they were being operated by the Bartletts in an illegal manner. :The Gambling Machines ere purportedly legal and permissible Coin Operated Amusement Maeliines In fact, the Gambling Machines are iGainbling Devices and are illegal per se or are being operated in an illegal Emenner. iAit all relevant times, there were nine (9) Gambling Devices placed at Captain Jack?s; eight (is) placed at Friend?s and six (6) placed at Chevy?s. The Gambling Devices, which resemble ?Slot Machines," were placed at Captain iJaclt?s, Friendly?s and? Chevy?s for the purposes of providing a place for customers (?Customers?) to illegally gamble. Customers who play the Gambling Devices insert cash into the Gambling . Machines to gamble, select one of two or three games to play, place their bets, and hit the play button. Depending on how the virtual reels step during a play, the Customer could win or lose or have the opportunity to win or lose on every spin. - Games on the Gambling Machines include ways of winning that require no skill i whatsoever. The Defendants used a device at Captain Jack?s known as a ?Mntha Goose? to l?loozlott . 10/14/2016.sar ii is. is. 3:53 ms 733 0439 see Distributors electronically transmit gambling infomation such as bets and winnings to a central location typically behind the counter at the gambling location The winnings and other gambling information would be electronically transmitted to the clerk via the ?Mutha Goose? so that the clerk would know how much to pay the Customers. .gAt all times relevant hereto and prior to July 1, 2015., the Defendants paid ?themselves the monies derived from the illegal gambling activities described ilterein. .At all relevant times, the Defendants were required under State law to self-report the amount of money played on the Gambling Devices and the net pro?t realized I from the Gambling Machines on a basis. Based on the self-reporting documents submitted to the State of Georgia by the Defendants for the period from October, 2013 through April? 2015, Captain Jack?s Customers inserted cash into the Gambling Machines in, order to play the Gambling devices and gamble; $837,092.00 was purportedly redeemed for prizes and $393,176.00 was the purported net pro?t derived from the Gambling Machines. Based on the self-reporting documents submitted to the State of Georgia by the Defendants for the period from October, 2013 through June, 2015, Friend's 3 Customers inserted over $1,754,595.00 cash into the Gambling Devices in order to play the Gambling Machines and gamble; $1,305,295.00 was purportedly redeemed for prizes and $449,229.00 was the purported not pro?t derived from the Gambling Machines. . For 16. 1'183 0489 ECP Distributors Based on the self-reporting documents submitted to the State of Georgia by the Defendants for the period from October 2013 through June 2015 Chevy? 5 Customers inserted over $1 ,449, 606. 00 cash into the Gambling Devices in order to play the Gambling Machines and gamble; $1 02016? 00 was purportedly :redcemed for prizes and $429 439 00 was the purported net profit derived from the Gambling Machines. in order for it to be able to have the Gambling Devices located at its places of Ebusiness, the Defendants on behalf of Captain Jack?s, Friend?s and Chevy?s iapplied for and maintained (30AM Location Licenses issued by the State of Georgia on an annual basis, Defendants submitted an annual" Coin Operated . Amusement Machine Application Application") swearing under oath as to the truth and correctness of the application being submitted. Separate annual COAM Applications were submitted by the Defendants for each of their three businesses. Defendants made faISe reports on their 2013 and 2014 COAM Applications in .. that they falsely swore that they were our delinquent in taxes owed to the State. Defendants made false reports and under-reported their income with regard to the monies derived from the illegal gambling on their 2013 and 2014 income Georgia Tax Returns. The Defendants engaged in an interrelated pattern of criminal activity motivated by and the effect of which was pecuniary gain. Elena/011 - 1.0/14/2016 FRI 8:53 EEK 678 733 0-?339 Distributors [3005/1311 mm From on or about January, 2013 to on or about May, 2015, the exact dates being unknOWn to the Grand Jury, in Peach County, Georgia the Defendants RONALD D. BARTLETT and LEE along with others known and unknown to the C11and1111ry did commit the offense of violation of the GEORGIA RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT, OCGA {31644-1 at 5611., in that the said accused did, through a pattern of racketeering activity or the proceeds derived therefrom. acquire or maintain, directly and indirectly, an interest in or control of an enterprise, real property, and personal property, including money, such conduct prohibited activities. under OCGA contrary to the laws of said ?tatc, the good order, peace and dignity thereof. . 's COUNT ONE of this Bill of Indictment expressly incorporates by reference, as if fully set forth herein, the allegations of THE PARTIES, THE SCHEME1 THE ENTERPRISE, AND THE PATTERN OF RACKETEERING ACTIVITY as enumerated in Paragraphs lthrough 20 herein above. COUNT TWO That from on Or about January, 2013 to on or about May, 2015, the exam datee being ?unknown to the Grand Jury, in Peach County, Georgia the Defendants RONALD 1) 1.1.1an11? and LEE BARTLETT along with others known and unknown to the Grand .1111); did commit the offense of violation of the GEORGIA RACKETEER 1NFI1UENCED AND CORRUPT ORGANIZATIONS ACT, OCGA ?16~14-1 at 5311., in that the said accused, being employed by and associated with Captain lacks, an ?enteiprise? 213 defined by OCGA did conduct and participate in, directly toil-M2016 FRI, 3,134 on}: 4?18 783 0489 3CD Distributors and indirectly, Such enterprise through a pattern of racketeering activity as de?ned in such conduct constituting prohibited activities under OCGA to the laws of said State, the good order, peaceand dignity thereof. ZICOUNT TWO of this Bill of Indictment expressly incorporates by reference, as if fully set forth herein, the allegations of THE PARTIES, THE SCHEME, THE ENTERPRISE. AND THE PATTERN 0F RACKETEEIUNG ACTIVITY as enumerated in Paragraphs 1 through 20 herein above. . from on or about January, 2013 to on, or about May, 2015, the exact dates being unknown to the Grand Jury, in Peach County, Georgia the Defendants RONALD BARTLETT and LEE BARTLETT along with others known and unknown to the drone Jury did commit the offense of violation of the GEORGIA momma-ea AND CORRUFT ORGANIZATIONS ACT, OCGA ?16-14-1 at 534., in thai the said accused did conspire and endeavor to violate OCGA such condum constituting prohibited activities under OCGA ?l contrary to the laws of said State, the good order, peace and dignity thereof. COUNT THREE of this Bill of Indictment expressly incorporates by reference, as if fully set forth herein, the allegations of THE PARTIES, THE SCHEME, THE ENTERPRISE, AND THE PATTERN 0F RACKETEERING ACTIVITY as enumerated in Paragraphs 1 through 20 herein above. COUNT FQUR Then from on or about January, 2013 to on or about May, 2015, the exact dates heingiunknown to the Grand Jury, in Peach County, Georgia the Defendants RONALD in and LEE BARTLETT along with others known and unknomi to the Grand Jury did commit the offense of violation of the GEORGIA RACKETEER looexolt 13/14/2015. FRI: 8:54 FAX 478 733 0489 DismibuLora mount)?. AND ORGANIZATIONS ACT, OCGA ?l?-ld-l 8113313., inithat the said accused did conspire and endeavor to violate OCGA such ccinduci constituting prohibited activities under OCGA ?l6~l 44(0), contrary to the laws 01? said fitatc, the good order, peace and dignity thereof. THREE of this Bill of Indictment expressly, incorporates by raference, as if fully set forth herein, the allegations of THE PARTIES, THE SCHEME. THE ENTERPRISE. AND THE PATTERN 0F RACKETEERING ACTIVITY as enumerated in Paragraphs 1 through 7.0 heroin above. COUNT FIVE . ?That from on or about January 2013 to on or about May, 2015, the exact dates bieing unknown to the Grand my, in Peach County, Georgia the Defendants RONALD D. BARTLETT and LEE BARTLETT along with others known and unknown to the Grand Jury did commit the offense of COMMERCIAL GAMBLING in violation of OCGA ?16-12?22 for that the said accused intentionally did operate and did tiartici?pate in the earnings of a gambling place, in that the said accused operated gambling devices and machines at Captain ,Iack?s and did make cash pay-outs to persons who played such gambling devices and machines, contt?axy' to the laws of said State, the good order, peace and dignity thereof. COUNT SIX That from on or about January, 2013 to on or about May, 2015, the exact dates heing?unknown to the Grand Jury, in Peach County, Georgia the Defendants RONALD D. BARTLETT and LEE BARTLETT along with others known and unknown to the git?and Jury did commit, the offense on A GAMBLING DEVICE on terminate on? 3:54 Fm; e73 133 0439 not; Distributors EQUIPMENT in violation of OCGA 9516-12-24 (3) for that - the said accused did knowingly possess at Captain Jack?s certain devices and gambling machines which they knew to be designed for gambling purposes, contrary to the laws of said State, the good order peace and dignity thereof I SE iThat from on or about January, 2013 to on or about May, 2015 the exact dates being unknown to the Grand Jury, in Peach County, Georgia the Delondants RONALD I) BARTLETT and LEE BARTLETT along with others known and unknown to the Grand Jury did commit the offense of KEEPING A GAMBLING PLACE in violation of OCGA for that the said accused did knowingly permit real estate, a building, room, and property under their control, to wit: Captain Jack?s, to be used as a gambling place, contrary to the laws of said State, the good order, peace and dignity thereof. CQUNT EIQHT the Grand Jurors atoresaid in the name and behalf of the citizens of Georgia further charge and accuse Defendants RONALD D. BARTLETT and LEE . BARTLETT with the offense of FALSE WRITINGS AND STATEMENTS in violation of OCGA 16-10-20 for that the said accused, on the 12 day of June, 20M, in the County aforesaid, did unlawfully then and there knowingly and willfully falsify, bounded, and cover up by a trick, scheme, and device a material fact; did make a false, ?ctitious, and fraudulent statement and representation; and did make and use a false Elena/011 . 8:55 FM 413 733 0489 Distributors writing and document, knowing the same to contain a faise, ?ctitious, and fraudulent statement and entry in a matter within thejurisdiction of a department and agency of state govenuiient and the govermnent of a county, city, and other political subdivision of the state, to wit: the accused did complete and submit :1 Coin Operated Amusement Machine Application for the Georgia Lottery Corporation, a department and agency of state government, and did indicate the answer on said application in response to the questions ?Are you delinquent in taxes, fees or other obligations owed to the State of dcorgie??, said response being certi?ed and sworn to before a Notary Public, while kimowing that the said accused were in fact delinquent in income taxes and sales and use texcs owed to the State of Georgia, contrary to the laws of this State, the good order, peace end dignity thereof. PEACH SUPERIOR COURT K. DAVID 000x13, JR. i 3 DISTRICT ATTORNEY ?deeper TERM 2016 SPECIAL PRESENTMENT PROSECUTOR 8:55 FAX. 478 733 0439 Distributors lam/{111 1'0 Bill this day of 574' #2016. OREMAN WITNESSES: Dot. Melanie A Bickford Byron Police Department. any Williams, Lotterv Commission Scott Puxvis Georgia Department of Revenue Chris Edwards PLEA The defendant, LEE BARTLETT waives being formally arraigned and pleads guilty This day of 2016. DEFENDANT ASST: DISTRICT [10.13. 07/24/1941 3.334%. 415-646786 SID: DEFENDANTS ATTORNEY . ADA: KDC ,10/1??915 FRI 3:55 Fm: 476 783 0489 Distributors Ion/011. PLEQ The defendant, RONALD BARTLETT, waives being formally arraigned and pleads guilty. This day 01? 2016. DEFENDANT ASST. DISTRICT ATTORNEY 2524890775 om: 5 33399439553 SID: GA00520240 u?rw- ATTORNEY ADA: KDC