11933700? IN THE CIRCUIT COURT FOR RALfl'lfifiEEelei: ln' my," MUM HY DEVISIUN STATE OF MARYLAND v. KEVIN LAMONT HICK DOB: 06/15/1970 SID: 1595271 Tracking Number: 1770240048 33 (TRUE BILL) GRAND JURY FOREPERSON FILED: December 3, 2019 Conspiracy to Maintain and Promote Criminal Organimilon by Unlawful Mums (Common Law; Maryland Criminal law Anicle 1-202; 1403) Manage a Criminal Gang (Maryland Criminnl Law Anicle Conspiracy Io Panicipnie in Gang (Maryland Criminal Law 94mm>> Puncipalion In Gang (Maryland Criminal an Anicla Assault -- 2nd Degree Assault (Maryland Cnminal Law Article 3--103) Conspiracy Commit Second-Degree Assault (Common Law; Maryland Cnl'ninal Law Ann'cla 3--203) Misconduct in Office (Common Law) Conspiracy to Commit Misconduct ln Offioc (Common law) WITNESSES: Det. Norval Cooper Department of Public Safety and Correctional Services Special Operations Unit Det. George Cannida Department of Public Safety and Correctional Services Special Operations Unit CO-DEFENDANTS: State of Maryland v. Kenyatta BARRETT Davon BUISE Britian BUTLER Ronald CRAWFORD arrell DOCKETT Eugene EARLY Lance HATHAWAY Kemar HINES Teron KNIGHT Dorian PAREDES Pawan RAI Damon RHUE Darnell SLACUM Gerald SOLOMON Ian STEWART Jerry SUBER Davon TELP Corey THIESS Carlos THOMAS Carlton THOMPSON Aaron Uchenna UMEOKAFOR Donte WILLIAMS Monte WILLIAMS Tracking no Tracking no Tracking no Tracking no Tracking no. Tracking no Tracking no. Tracking no. Tracking no. Tracking no. Tracking no. Tracking no. Tracking no. Tracking no. Tracking no. Tracking no. Tracking no. Tracking no. Tracking no. Tracking no. Tracking no. 1770 Tracking no. Tracking no. Tracking no A .177024004990 .177024005130 .177024005115 .177024004931 177024004942 .177024004953 177024004975 177024005012 177024004964 177024005152 1 1770 ~J-l six! 66 Bulk-B CG: GOO CDC GHQ) 1770 l?ll-i cc Ali-h UIGNH rip-I \lsl GG nib-F- cc: GOG OOH . 177024005045 STATE OF MARYLAND IN THE v. CIRCUIT COURT Kevin HICKSON FOR BALTIMORE CITY Defendant CASE NOThe Grand Jurors for the State of Maryland for Baltimore charge: COUNT ONE (COMMON LAW CONSPIRACY T0 MAINTAIN AND PROMOTE CRIMINAL ORGANIZATION BY UNLAWFUL MEANS) The Jurors of the State of Maryland for the body Of Baltimore City, do on their oath present that, from at least March 25, 2016 through September 4, 2019, in various correctional facilities in the State of Maryland, the aforesaid DEFENDANT, with other persons whose names are known and unknown to the Jurors, did knowingly, intentionally, and unlawfully conspire, confederate, combine, and agree to maintain, further, facilitate, enrich, promote, and protect a criminal enterprise that operated as its main hub the area in and around the following correctional facilities: Metropolitan Transition Center, Baltimore Central Booking and Intake Center, and Baltimore City Detention Center Jail Industries Building, all located in Baltimore City, Maryland, and Jessup Correctional Institution located in Anne Arundel County, Maryland, by unlawful criminal means including, but not limited to, assault in the first and second degrees, intimidation of witnesses, Obstruction of justice, and acts of violence, in violation of the Common Law of Maryland; against the peace, government, and dignity of the State. Background 1. The Department of Public Safety and Correctional Services is one of the largest agencies in the State of Maryland with nearly 12,000 employees and a budget of more than $1 billion, whose jurisdiction covers the entire State of Maryland, which has a population of more than 6 million people. DP SCS operates 27 institutions, including Baltimore City?s pre?trial facility, as well as 45 Parole and Probation of?ces throughout the state. 2. is primarily tasked with ensuring safety so that all Marylanders can enjoy living and working in the State. This task is achieved by ensuring security in institutions and supplying offenders and former-offenders the tools necessary to stay out of the criminal justice system. 3. The Baltimore Central Region Tactical Unit (TAC) is a specialized unit within the Division of Pretrial and Detention Services, which reports directly to the Commissioner and the Deputy Commissioner of Pretrial. According to their mission statement, TAC: is to respond to critical and routine incidents to mitigate disorder, protect the community, employees and arrestees/detainees/inmates in the department?s custody and support line staff to maintain order and security of all facilities under the Division of Pretrial Detention and Services. 4. Further, vision statement dictates: that through constant and rigorous training planning and intelligence gathering regimen, the TAC Team will provide the best premium quality support service available. It is our team goal to train hard, train often and execute at a level that far exceeds the industry standard. 5. TAC members identify themselves by, among other things, wearing unique uniforms, including t-shirts, hats and other accessories, and displaying TAC insignia patches and logos on their uniforms. 6. The TAC team primarily maintained their headquarters at the Jail Industries Building located in Baltimore City, Maryland. 7. The TAC team has a paramilitary command structure that consists of a TAC commander, assistant commanders stationed at the institutions where TAC operates, TAC team leaders, and TAC team members. 8. The TAC team members are associates with one of five team groups: A. Contraband/Paperwork Team B. Squad 1 (Rapid Response) C. Squad 2 (Strip Search/Tactical) D. Squad 3 (Tactical/Search) E. Squad 4 (Search/Tactical) 9. The TAC team has a speci?c operational territory which consists of, in pertinent part, the following detention facilities: A. Metropolitan Transition Center (MTC) B. Baltimore Pretrial Facility at essup Correctional Institute (BPFJ) C. Jail Industries Building (J1) D. Baltimore City Booking and Intake Center (BCBIC) 10. The TAC commander is Lt. (now acting Capt.) Kevin HICKSON. Hickson is a founding member of TAC. Hickson is also the organizer, supervisor, promoter, and manager of the Enterprise that exists within TAC. 11. The Enterprise is speci?cally comprised of the Defendants and others known and unknown to the Grand Jury. The Enterprise consists of individuals who are high-ranking members, who direct, manage, and supervise the lower?ranking members, and who oversee the day-to-day operations of the group. The members and associates of the Enterprise generally have speci?c roles and directives within the organization. The members and associates sometimes work different shifts, with some members working in the early hours of the day, and some members not beginning until the evening. 12. The purpose of the Enterprise is to maintain its dominance in its operational territory. To achieve this purpose, the Enterprise engages in illegal and excessive force through assaults of inmates, use of threats against inmates, and various retaliatory tactics to assure complete compliance with authority, which bolsters overall reputation within the territory and suppresses any dissention and discord among the overall prison population. 13. The Enterprise has committed and is continuing to commit acts of violence and intimidationaincluding violent assaults, witness intimidation and tampering, destruction of evidence, alteration of evidence, falsi?cation of of?cial public documents, and obstruction of justice?in order to maintain dominance of its operational territory, enhance its reputation, and shield its members and operations from law enforcement. Participating in these acts either directly or indirectly, will o?en earn individuals the respect of their fellow members, and will secure, maintain, and advance their position in the Enterprise. Manner, Means, and Methods of the Conspiracy 14. The Enterprise seeks, among other things, to build a reputation as a premier unit within in order to separate themselves from other units. The manner, means, and methods by which the defendants and their associates achieve the objectives of the conspiracy include, but are not limited to, the following: 15. Members and associates of the Enterprise do, individually and collectively, use excessive force while on tactical missions in order to bolster their reputation among inmates and other correctional officers. 16. Members and associates of the Enterprise do, individually and collectively, cover up their illegal/improper actions by falsifying documents, falsifying statements, tampering with and fabricating evidence, and witness intimidation through threats of retaliation. 17. Members and associates of the Enterprise generally permit only other members and associates of their unit to be present during the application of the excessive force and various other illegal activity. 18. Members and associates of the Enterprise utilize social media to broadcast, promote, and advertise their reputation and successes. They post group photos displaying the success of the unit and proudly proclaim their membership in the Enterprise. 19. Members and associates of the Enterprise use verbal and nonverbal communication during the commission of the Enterprise?s illegal activities, including winks, nods and other body language, to warn each other about the presence of non?members or of?cials charged with oversight, as well as to communicate with those interested in engaging in the illegal assaults of inmates. 20. Members and associates of the Enterprise alert other members about the covert or overt presence of oversight investigators or non TAC members in the area, and will attempt to conceal criminal acts if they believe they are under observation or surveillance, in order to prevent detection and intervention by law enforcement. 21. Members and associates of the Enterprise will obstruct justice, and threaten and intimidate individuals whom the organization suspects have cooperated with law enforcement. Overt Acts in Furtherance of the Conspiracy 22. In furtherance of the conspiracy and to achieve the objectives thereofmand for the bene?t of, at the direction of, and in association with the Enterprise?the Defendants, as named below, and others known and unknown, knowingly and will?illy directed, participated in, performed, and caused to be performed the following acts, among others, in and throughout Maryland, including in Baltimore City and Anne Arundel County, and elsewhere: 23. On March 25, 2016, Lt. (now acting Capt.) Kevin HICKSON and Cpl. Ronald CRAWFORD conspired with each other and unknown others to commit assault in the second degree and did commit assault in the second degree against Montrell Powell in Jail Industries Building in Baltimore, Maryland. 24. On March 20, 2017, Lt. (now acting Capt.) Kevin HICKSON and Cpl. Dorian PAREDES conspired with each other and unknown others to commit assault in the second degree and did commit assault in the second degree against Rashad Harris in Metropolitan Transition Center in Baltimore, Maryland. 25. On April 10, 2017, Cpl. Eugene EARLY, Cpl. Teron KNIGHT, and Cpl. Aaron conspired with each other and unknown others to commit assault in the second degree and did commit assault in the second degree against Contey Dorsey in Jail Industries Building in Baltimore, Maryland. 26. On May 16, 2017, Cpl. Teron KNIGHT and Cpl. Pawan RAI conspired with each other and with both known and unknown others to commit assault in the ?rst degree and did commit assault in the ?rst degree against Teddy Shannon in Jail Industries Building in Baltimore, Maryland. 27. On May 16, 2017, Cpl. Lance HAT HAWAY and Cpl. Pawan RAI conspired with each other and unknown others to commit assault in the second degree and did commit assault in the second degree against Stephen Thompson in Jail Industries Building in Baltimore, Maryland. 28. On May 17, 2017, Lt. (now acting Capt.) Kevin HICKSON and Cpl. Carlos THOMAS and Cpl. (now Sgt.) Monte WILLIAMS conspired with each other and with both known and unknown others to commit assault in the second degree and did commit assault in the second degree against Raekwon Commodore in Jail Industries Building in Baltimore, Maryland. 29. On May 19, 2017, Cpl. Kenyatta BARRETT and Cpl. Jerry SUBER conspired with each other and with both known and unknown others to commit assault in the second degree and did commit assault in the second degree against Bryan Thompson in Jail Industries Building in Baltimore, Maryland. 30. On May 19, 2017, Cpl. Lance HATHAWAY conspired with both known and unknown others to commit assault in the second degree and did commit assault in the second degree against Antoine Mayo in Jail Industries Building in Baltimore, Maryland. 10 31. On September 19, 2017, Cpl. Ronald CRAWFORD and Cpl. Davon TELP conspired with each other and with both known and unknown others to commit assault in the second degree and did commit assault in the second degree against DaSean Harris in Metropolitan Transition Center in Baltimore, Maryland. 32. On September 19, 2017, Lt. (now acting Capt.) Kevin HICKSON and Cpl. Davon TELP conspired with each other and unknown others to commit assault in the second degree and did commit assault in the second degree against Brian Scott in Metropolitan Transition Center in Baltimore, Maryland. 33. On October 4, 2017, Sgt. (now Lt.) arrell DOCKETT, Cpl. Davon TELP, and Cpl. (now Sgt.) Monte WILLIAMS, conspired with each other and with both known and unknown others to commit assault in the ?rst degree and did commit assault in the ?rst degree against Andre Rawles in essup Correctional Institution in Anne Arundel County, Maryland. 34. On October 4, 2017, Sgt. (now Lt.) Jarrell DOCKETT, Cpl. Davon TELP, and Cpl. (now Sgt.) Monte WILLIAMS conspired with each other and with both known and unknown others to commit assault in the second degree and did commit assault in the second degree against Christopher Wise in essup Correctional Institution in Anne Arundel County, Maryland. 35. On January 29, 2018, Cpl. Ronald CRAWFORD and Cpl. Donte WILLIAMS conspired with each other and with both known and unknown others to commit assault in the ?rst degree and did commit assault in the ?rst degree against Antwan Heath in Metropolitan Transition Center in Baltimore, Maryland. 36. On January 29, 2018, Cpl. Kemar HINES and Cpl. Darnell SLACUM conspired with each other and with both known and unknown others to commit assault in the second degree and did commit assault in the second degree against Daquan Johnson in Metropolitan Transition Center in Baltimore, Maryland. 37. On February 1, 2018, Cpl. Damon RHUE and Cpl. Davon TELP conspired with each other and with both known and unknown others to commit assault in the second degree and did commit assault in the second degree against Robbie Hyman in Baltimore Central Booking and Intake Center in Baltimore, Maryland. 38. On February 9, 2018, Lt. (now acting Capt.) Kevin HICKSON and Cpl. Darnell SLACUM conspired with each other and with both known and unknown others to commit assault in the second degree and did commit assault in the second degree against Cliff Frazier in Jessup Correctional Institution in Anne Arundel County, Maryland. 39. On March 8, 2018, Cpl. Pawan RAI and Cpl. Uchenna UMEOKAFOR conspired with each other and with both known and unknown others to commit assault in the ?rst degree and did commit assault in the ?rst degree against Davon Gilmore in Jessup Correctional Institution in Anne Arundel County, Maryland. 11 40. On March 8, 2018, Cpl. Eugene EARLY, Cpl. Pawan RAI, and Cpl. Ian STEWART conspired with each other and with both known and unknown others to commit assault in the ?rst degree and did commit assault in the ?rst degree against Shamar Scott in Baltimore Central Booking and Intake Center in Baltimore, Maryland. 41. on June 6, 2018, Cpl. Britian BUTLER and Cpl. Kemar HINES conspired with each other and unknown others to commit assault in the second degree and did commit assault in the second degree against Shaymar Barnes in Jessup Correctional Institution in Anne Arundel County, Maryland. 42. On June 29, 2018, Cpl. Britian BUTLER conspired with both known and unknown others to commit assault in the second degree and .did commit assault in the second degree against Dewayne Venable in Metropolitan Transition Center in Baltimore, Maryland. 43. On June 29, 2018, Cpl. Davon BUISE conspired together and with known and unknown others to commit assault in the second degree and did commit assault in the second degree against Ryan Scott in Metropolitan Transition Center in Baltimore, Maryland. 44. On June 29, 2018, Cpl. Carlton THOMPSON conspired together and with known and unknown others to commit assault in the second degree and did commit assault in the second degree against Derrick Bryant in Metropolitan Transition Center in Baltimore, Maryland. 45. On July 1, 2018, Sgt. Gerald SOLOMON, Cpl. Britian BUTLER, and Cpl. Teron KNIGHT conspired with each other and unknown others to commit assault in the second degree and did commit assault in the second degree against Darrell Carter in Baltimore Central Booking and Intake Center in Baltimore, Maryland. 46. On July 1, 2018, Sgt. Gerald SOLOMON, Cpl. Britian BUTLER, and Cpl. Teron KNIGHT conspired with each other and unknown others to commit assault in the second degree and did commit assault in the second degree against Jeffrey Nelson-Johnson in Baltimore Central Booking and Intake Center in Baltimore, Maryland. 47. On September 4, 2019, Sgt. Gerald SOLOMON, Cpl. Davon BUISE, and Cpl. Lance HATHAWAY, and Cpl. Corey THIESS conspired with each other and unknown others to commit assault in the second degree and did commit assault in the second degree against Raymond Thornton in Baltimore Central Booking and Intake Center in Baltimore, Maryland. [Common Law] 12 COUNT Two (MANAGE A CRIMINAL GANG) The Jurors of the State of Maryland for the body of Baltimore City, do on their oath present that, beginning in at least as early as March 2016 through September 4, 2019, in the City of Baltimore and Anne Arundel County, DEFENDANT did organize, supervise, promote, and manage a criminal gang in violation of the Criminal Law Article, Section 9-805, of the Maryland Code, against the peace, government, and dignity of the State. Note: the background, manner, means, methods, use of violence. and additional overt acts listed in Count 1 above are incorporated by reference herein. 9?805] CIIS 1 I393 (formerly I 0619) COUNT THREE (PARTICIPATION IN A CRIMINAL GANG - CONSPIRACY) The Jurors of the State of Maryland for the body of Baltimore City, do on their oath present that, aforesaid DEFENDANT, late of said City, since at least as early as March 25, 2016 through September 4, 2019, in Baltimore City and Anne Arundel County, Maryland, did conspire with others known and unknown to the Jurors, to participate in a criminal gang, knowing that the members of said gang engage in criminal gang activity and knowingly and willfully directed and participated in an underlying crime for the bene?t of, at the direction of, and in association with a criminal gang, referred to herein as the Enterprise, in violation of the Criminal Law Article, Section of the Maryland Code against the peace, government, and dignity of the State. Note: the background, manner, means, methods, use of violence, and additional overt acts listed in Count 1 above are incorporated by reference herein. CJIS 1-1395 COUNT FOUR (PARTICIPATION IN A CRIMINAL GANG) The Jurors of the State of Maryland for the body of Baltimore City, do on their oath present that, aforesaid DEFENDANT, since at least as early as March 25, 2016 through September 4, 2019, in Baltimore City and Anne Arundel County, along with others known and unknown to the Jurors, did participate in a criminal gang, referred to herein as the Enterprise, knowing that the members of said gang engage in criminal gang activity and knowingly and willfully directed and participated in an underlying crime committed for the bene?t of, at the direction of, and in association with a criminal gang, in violation of the Criminal Law Article, Section of the Maryland Code against the peace, government, and dignity of the State. 13 Note: the background, manner, means, methods, use of violence, and additional overt acts listed in Count 1 above are incorporated by reference herein. CJIS 1-1394] COUNT FIVE (SECOND-DEGREE ASSAULT) The Jurors of the State of Maryland for the body of Baltimore City, do on their oath present that, on or about March 25, 2016, in the Jail Industries Building in the City of Baltimore, Maryland, DEFENDANT did assault Montrell Powell in the second degree in violation of the Criminal Law Article, Section 3-203, of the Maryland Code, against the peace, government and dignity of the State. 3?203] c1151 1415 COUNT SIX (SECOND-DEGREE ASSAULT) The Jurors of the State of Maryland for the body of Baltimore City, do on their oath present that, on or about March 20, 2017, in the Metropolitan Transition Center in the City of Baltimore, Maryland, DEFENDANT did assault Rashad Harris in the second degree in violation of the Criminal Law Article, Section 3-203, of the Maryland Code, against the peace, government and dignity of the State. 3-203] CJISI 1415 COUNT SEVEN (SECOND-DEGREE ASSAULT) The Jurors of the State of Maryland for the body of Baltimore City, do on their oath present that, on or about May 17, 2017, in the Jail Industries Building in the City of Baltimore, Maryland, DEFENDANT did assault Raekwon Commodore in the second degree in violation of the Criminal Law Article, Section 3-203, of the Maryland Code, against the peace, government and dignity of the State. 3-203] CJISI 1415 14 COUNT EIGHT (SECOND-DEGREE ASSAULT) The Jurors of the State of Maryland for the body of Baltimore City, do on their oath present that, on or about September 19, 2017, in the Metropolitan Transition Center in the City of Baltimore, Maryland, DEFENDANT did assault Brian Scott in the second degree in violation Of the Criminal Law Article, Section 3-203, of the Maryland Code, against the peace, government and dignity of the State. 3-203] CJIS 1 1415 COUNT NINE ASSAULT) The Jurors of the State Of Maryland for the body of Baltimore City, do on their oath present that, on or about February 9, 2018, in the essup Correctional Institution in Anne Arundel County, Maryland, DEFENDANT did assault Cliff Frazier in the second degree in violation of the Criminal Law Article, Section 3?203, of the Maryland Code, against the peace, government and dignity of the State. 3-203] CJISI 1415 COUNT TEN (CONSPIRACY ASSAULT) The Jurors of the State Of Maryland for the body of the City of Baltimore, do on their oath present that the aforesaid late of said City, heretofore on or about March 25, 2016, in the Jail Industries Building in the City of Baltimore, Maryland, unlawfully alleged to have conspired with Cpl. RONALD CRAWFORD, together and with each other, and with certain other persons whose names are unknown to the Jurors aforesaid, to assault Montrell Powell in the second degree in violation of the common law of Maryland and Criminal Law Article, Section 3?203 Of the Annotated Code of Maryland; against the peace, government and dignity Of the State. [Common Law; 3-203] CJIS 1 C1415 15 COUNT ELEVEN (CONSPIRACY ASSAULT) The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath present that the aforesaid late of said City, heretofore on or about March 20, 2017, in the Metropolitan Transition Center in the City of Baltimore, Maryland, unlawfully alleged to have conspired with Cpl. DORIAN PAREDES, together and with each other, and with certain other persons whose names are unknown to the Jurors aforesaid, to assault Rashad Harris in the second degree in violation of the common law of Maryland and Criminal Law Article, Section 3-203 of the Annotated Code of Maryland; against the peace, government and dignity of the State. . [Common Law; 3-203] C118 1 C1415 COUNT TWELVE (CONSPIRACY SECOND-DEGREE ASSAULT) The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath present that the aforesaid late of said City, heretofore on or about May 17, 2017, in Jail Industries Building in the City of Baltimore, Maryland, unlawfully alleged to have conspired with Cpl. CARLOS THOMAS and Cpl. (now Sgt.) MONTE WILLIAMS, together and with each other, and with certain other persons whose names are known and unknown, to assault Raekwon Commodore in the second degree in violation of the common law of Maryland and Criminal Law Article, Section 3-203 of the Annotated Code of Maryland; against the peace, government and dignity of the State. [Common Law; 3-203] CIIS I 1415 COUNT THIRTEEN (CONSPIRACY SECOND-DEGREE ASSAULT) The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath present that the aforesaid late of said City, heretofore on or about September 19, 2017, in the Metropolitan Transition Center in the City of Baltimore, Maryland, unlawfully alleged to have conspired with Cpl. DAVON TELP, together and with each other, and with certain other persons whose names are unknown to the Jurors aforesaid, to assault Brian Scott in the second degree in violation of the common law of Maryland and Criminal Law Article, Section 3-203 of the Annotated Code of Maryland; against the peace, government and dignity of the State. 16 [Common Law; 3-203] CJIS 1 1415 COUNT FOURTEEN (CONSPIRACY ASSAULT) The Jurors of the State of Maryland for the body of the City Of Baltimore, do on their oath present that the aforesaid DEF late of said City, heretofore on or about February 9, 2018, in the Jessup Correctional Institution in Anne Arundel County, Maryland, unlawfully alleged to have conspired with Cpl. DARNELL SLACUM, together and with each other, and with certain other persons whose names are known and unknown, to assault Cliff Frazier in the second degree in violation of the common law of Maryland and Criminal Law Article, Section 3-203 Of the Annotated Code of Maryland; against the peace, government and dignity of the State. [Common Law; 3-203] CJIS 1 1415 (MISCONDUCT IN OFFICE) The Jurors of the State of Maryland for the body of Baltimore City, do on their oath present that, at least as early as March 25, 2016 through September 4, 2019, in Anne Arundel County, the City of Baltimore, and other Maryland Counties, DEFENDANT, being then and there a public of?cer, to wit: a correctional Officer for the Department of Public Safety and Correctional Services, unlawfully, knowingly, and corruptly, did commit a wrongful and improper act under color of his of?ce, to wit: the commission of second degree assault against individuals con?ned within Maryland Correctional facilities, and as a continuing course of conduct, by failing to report assaults, acts of intimidation, falsi?cation of Of?cial documents, and corruption within the TAC organization to the appropriate authorities within the Department Of Public Safety and Correctional Services, and by failing to protect the health, safety, and wellbeing of detained inmates within the custody Of the Department, in violation of the common law Of Maryland against the peace, government, and dignity of the State. [Common Law] 17 COUNT SIXTEEN (CONSPIRACY TO COMMIT MISCONDUCT IN OFFICE) The Jurors of the State of Maryland for the body of Baltimore City, do on their oath present that, at least as early as March 25, 2016 through September 4, 2019, in the City of Baltimore and in Anne Arundel County, the DEFENDANT, being then and there a public of?cer, to wit: a correctional of?cer for the Department of Public Safety and Correctional Services, unlawfully, knowingly, and corruptly, did conspire together and with certain other persons whose names are known and unknown to the Jurors aforesaid, a wrongful and improper act under color of his of?ce, to wit: the commission of ?rst and second degree assaults against individuals con?ned within Maryland Correctional facilities, and as a continuing course of conduct, by failing to report assaults, acts of intimidation, falsi?cation of Of?cial documents, and corruption within the TAC organization to the appropriate authorities within the Department of Public Safety and Correctional Services, and by failing to protect the health, safety, and wellbeing of detained inmates within the custody of the Department, in violation of the common law of Maryland against the peace, government, and dignity of the State. [Common Law] ?1 Marilyn J. Mosby State?s ttorney for Daltimore City Michael Hudak Assistant State?s Attorney for Baltimore City 18 IN DICTMENT TRUE BILL Foreperson Filed on (2019) CO-DEFENDANTS: Kenyatta BARRETT Tracking no. 177024004990 Davon BUISE Tracking no. 177024005130 Britian BUTLER Tracking no. 177024005115 Ronald CRAWFORD Tracking no. 177024004931 Jarrell DOCKETT Tracking no. 177024004942 Eugene EARLY Tracking no. 177024004953 Lance HATHAWAY Tracking no. 177024004975 Kemar HINES Tracking no. 177024005012 Teron KNIGHT Tracking no. 177024004964 Dorian PAREDES Tracking no. 177024005152 Pawan RAI Tracking no. 177024004986 Damon RHUE Tracking no. 177024005056 Darnell SLACUM Tracking no. 177024005056 Gerald SOLOMON Tracking no. 177024005104 Ian STEWART Tracking no. 177024005093 Jerry SUBER Tracking no. 177024005001 Davon TELP Tracking no. 177024005060 Corey THIESS Tracking no. 177024005141 Carlos THOMAS Tracking no. 177024005126 Carlton THOMPSON Tracking no. 177024005126 Aaron Tracking no. 177024005185 Uchenna UMEOKAFOR Tracking no. 177024005082 Donte WILLIAMS Tracking no. 177024005071 Monte WILLIAMS Tracking no. 177024005045 19