IN THE COURT OF COMMON PLEAS
PIKE COUNTY, OHIO

STATE OF OHIO, Case No. 20190R000068
Plaintiff 
Vs. Judge Chris A. Martin
Charles S. Reader, SUPERSEDING INDICTMENT
Defendant 

 

The jurors of the Grand Jury of the State of Ohio, within and for the body of the
County of Pike, on their oaths, in the name and by the authority of the State of Ohio, do
?nd and present that:

COUNT ONE

CHARLES READER, between June 22, 2017 and December 20, 2018, at the
County of Pike, and in the State of Ohio, or by some manner enumerated in Section
2901.12 of the Ohio Revised Code whereby prop-er venue is placed in the County of Pike,
while employed by, or associated with an enterprise, to wit: The Pike County Sheriff's
of?ce, did conduct or participate in, directly or indirectly, the affairs of the enterprise
through a pattern of corrupt activity, to wit: did engage in various acts of theft, in violation
of RC. 2913.02, receiving stolen property, in violation of RC. 2913.51, tampering with
records, in violation of RC. 2913.42, tampering with evidence, in violation of RC.
2921.12, and theft in of?ce, in violation of RC. 2921.41, including, but not limited to the
acts alleged in the conduct set out in this indictment in Counts Two through Nine, Twelve,
Thirteen, Fifteen, and Sixteen of this Indictment, inclusive, as if fully rewritten herein,
when the proceeds of the violation, the payments made in the violation, the amount of a
claim for payment or for any other bene?t that is false or deceptive rand-thaw


the violation, or when the total of any of the above proceeds, paanh?lrlI?IlsO 

FEB 21 2020

JUSTIN P. BREWSTER
PIKE COUNTY CLERK

 

payment or other bene?t in any combination of violations exceeds one thousand dollars

in violation of Section of the Ohio Revised Code.
Engaging in a Pattern of Corrupt Activity- A felony of the ?rst degree

COUNT TWO
CHARLES READER, between June 22, 2017 and December 20, 2018, at the County of

Pike, and in the State of Ohio, or by some manner enumerated in Section 2901.12 of the
Ohio Revised ?Code whereby proper venue is placed in the County of Pike, in his capacity
as a public of?cial, to wit: Sheriff of Pike County, Ohio, did knowingly commit a theft
offense, to wit: theft, in violation of RC. 2913.02, and/or receiving stolen property, in
violation of RC. 2913.51, and/or tampering with records, in violation of RC. 2913.42,
CHARLES READER having used his of?ce in aid of committing the offense, when. the
value of the property or services stolen is one thousand dollars or more and
is less than seven thousand ?ve hundred dollars in violation of Section

of the Ohio Revised Code.
Theft in Of?ce- A felony of the fourth degree

COUNT THREE
CHARLES READER, between July 22, 2017 and December 20, 2018, at the County of

Pike, and in the State of Ohio, or by some manner enumerated in Section 2901.12 of the

Ohio Revised Code whereby proper venue is placed in the County of Pike, in his capacity

as a public of?cial, to wit: Sheriff of Pike County, Ohio, did knowingly commit a theft

offense, to wit: theft, in violation of RC. 2913.02, and/or receiving stolen property, in

violation of RC. 2913.51, and/or tampering with records, in viola 190mg, :glgg?t?g3OURT
FEB 21 2020

JUSTIN P. BREWSTER
COUNTY CLERK

 

CHARLES READER having used his of?ce in aid of committing the offense, when the
value of the property or services stolen is one thousand dollars or more and
is less than seven thousand ?ve hundred dollars in violation of Section

2921 of the Ohio Revised Code.
Theft in Of?ce- A felony of the fourth degree
COUNT FOUR

CHARLES READER, on or about December 20, 2018, at the County of Pike, and
in the State of Ohio, or by some manner enumerated in Section 2901.12 of the Ohio
Revised Code whereby proper venue is placed in the County of Pike, knowing that an
of?cial proceeding or investigation was in progress, or is about to be or likely to be
instituted, did make, present, or use any record, document, or thing, to wit: an evidence
bag dated 09-19-2017 containing $7,000.00 in United State currency, knowing it to be
false and with purpose to mislead a public of?cial who is or may be engaged in such
proceeding or investigation, or with purpose to corrupt the outcome of any such

proceeding or investigation in violation of Section of the Ohio Revised

 

COde' 
COMMON PLEAS COURT
Tampering with Evidence- A felony of the third degree FEB 2 1 2020
FIVE JUSTIN P. BREWSTER
PIKE COUNTY CLERK

 

 

CHARLES READER, between September 19, 2017 and December 20, 2018, at the
County of Pike, and in the State of Ohio, or by some manner enumerated in Section
2901.12 of the Ohio Revised Code whereby proper venue is placed in the County of Pike,

in his capacity as a public of?cial, to wit: Sheriff of Pike County, Ohio, did knowingly

 

commit a theft offense, to wit: theft, in violation of RC. 2913.02, and/or receiving stolen
property, in violation of'R.C. 2913.51, and/or tampering with records, in violation of RC.
2913.42, CHARLES READER having used his of?ce in aid of committing the offense,
when the value of the property or services stolen is one thousand dollars or
more and is less than seven thousand ?ve hundred dollars in violation of

Section of the Ohio Revised Code.
Theft in Of?ce- A felony of the fourth degree
COUNT SIX

CHARLES READER, on or about December 20-, 2018, at the County of Pike, and
in the State of Ohio, or by some manner enumerated in Section 2901.12 of the Ohio
Revised Code whereby proper venue is placed in the County of Pike, knowing that an
of?cial proceeding or investigation was in progress, or is about to be or likely to be
instituted, did make, present, or use any record, document, or thing, to wit: an evidence
bag dated 03-09-2018 containing $621.00 in United State currency, knowing it to be false
and-with purpose to mislead a public of?cial who is or may be engaged in such proceeding
or investigation, or with purpose to corrupt the outcome of any such proceeding or

investigation in violation of Section 2921 of the Ohio Revised Code.

Tampering with Evidence- A felony of the third degree

 


COMMON PLEAS COURT

FEB 21 2020

JUSTIN P. BREWSTER
PIKE COUNTY CLERK

 

 

 

COUNT SEVEN
CHARLES READER, between March 9, 2018 and December 20, 2018, at the County of

Pike, and in the State of Ohio, or by some manner enumerated in Section 2901.12 of the
Ohio Revised Code whereby proper venue is placed in the County of Pike, in his capacity
as a public of?cial, to- wit: Sheriff of Pike County, Ohio, did knowingly commit a theft
offense, to wit: theft, in violation of RC. 2913.02, and/or receiving stolen property, in
violation of RC. 2913.51, and/or tampering with records, in violation of RC. 2913.42,-
CHARLES READER having used his of?ce in aid of committing the offense, when the
value of the property or services stolen is one thousand dollars or more and
is less than seven thousand ?ve hundred dollars in violation of Section

2921 of the Ohio Revised Code.
Theft in Of?ce- A felony of the ?fth degree

COUNT EIGHT
CHARLES READER, on or about August 19, 2017, at the County of Pike, and in

the State of Ohio, or by some manner enumerated in Section 2901.12 of the Ohio Revised
Code whereby proper venue is placed in the County of Pike, in his capacity as a public
of?cial, to wit: Sheriff of Pike County, Ohio, did recklessly use or authorize the use of the
authority or in?uence of his of?ce to secure a thing of value, to wit: a 2013 Nissan Versa,
that thing of value being of such character as to manifest a substantial and improper
in?uence upon CHARLES READER with respect to his duties, in violation of Section

of the Ohio Revised Code.

 

Fl 
COMMON PLEAS COURT

FEB 2 1 2020

Con?ict of Interest- A misdemeanor of the ?rst degree

JUSTIN P. BREWSTER
PIKE COUNTY CLERK

 

 

 

COUNT NINE

CHARLES READER, during a period of time beginning August 19, 2017 through
November 9, 2017, at the County of Pike, and in the State of Ohio, or by some manner
enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is
placed in the County of Pike, by deception, did cause another to execute a writing, to wit:
title to a 2013 Nissan Versa, that disposed of or encumbered property, the value of the
pr0perty or the obligation involved being one thousand dollars of more and
less than seven thousand ?ve hundred dollars in violation of Section

of the Ohio Revised Code.
Securing Writings by Deception- A felony of the ?fth degree

COUNT TEN
CHARLES READER, between June 22, 2017 and December 20, 2018, at the County of

Pike, and in the State of Ohio, or by some manner enumerated in Section 2901.12 of the
Ohio Revised Code whereby proper venue is placed in the County of Pike, and with
purpose to deprive the owner of property or services, did knowingly obtain or exert control
over the said property or services by deception, when the value of the property or services
stolen is seven thousand ?ve hundred dollars or more and is less than one
hundred and ?fty thousand dollars in violation of Section of

the Ohio Revised Code.

Theft- A felony of the third degree

   
   
 
  

  

Fl 
COMMON PLEAS COURT

FEB 21 2020

JUSTIN P. BREWSTER
COUNTY CLERK

 

COUNT ELEVEN
CHARLES READER, on or about August 19, 2017, at the County of Pike, and in

the State of Ohio, or by some manner enumerated in Section 2901.12 of the Ohio Revised
Code whereby proper venue is placed in the County of Pike, in his capacity as a public
of?cial, to wit: Sheriff of Pike County, Ohio, did recklessly use or authorize the use of the
authority or in?uence of his of?ce to secure a thing of value, to wit: a 1991 Chevrolet
Silverado, that thing of value being of such character as to manifest a substantial and
improper in?uence upon CHARLES READER with respect to his duties, in violation of

Section of the Ohio Revised Code.

Con?ict of Interest- A misdemeanor of the ?rst degree

COUNT TWELVE

CHARLES READER, between the time period of August 19, 2017 through December 15,
2017, at the County of Pike, and in the State of Ohio, or by some manner enumerated in
Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in the County
of Pike, and with purpose to deprive the owner of property or services, to with a 1991
Chevrolet Silverado, did knowingly obtain or exert control over the said property or
services by deception, when the property stolen was a motor vehicle, in violation of

Section of the Ohio Revised Code.

      
   
       

   

Theft? A felony of the fourth degree 


COMMON PLEAS COURT
FEB 21 2020

JUSTIN P. BREWSTER
PIKE COUNTY CLERK

   

COUNT THIRTEEN

CHARLES READER, between the time period of August 19, 2017 through December 15,
2017, at the County of Pike, and in the State of Ohio, or by some manner enumerated in
Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in the County
of Pike, in his capacity as a public of?cial, to wit: Sheriff of Pike County, Ohio, did
knowingly commit a theft offense, to wit: Theft, in violation of Section 2913.02 of the Ohio
Revised Code, CHARLES READER having used his of?ce in aid of committing the
offense, when the value of the property or services stolen is less than one thousand

dollars in violation of Section 2921 of the Ohio Revised Code.

Theft in Of?ce? A felony of the ?fth degree

COUNT FOURTEEN
CHARLES READER, on or about June 26, 2017, at the County of Pike, and in the

State of Ohio, or by some manner enumerated in Section 2901.12 of the Ohio Revised
Code whereby proper venue is placed in the County of Pike, in his capacity as a public
of?cial, to wit: Sheriff of Pike County, Ohio, did recklessly solicit or accept a thing of value,
to wit: did request and/or accept a loan of $1 ,500.00 from Vl?lliam Stansberry, Jr. who, at
the time, was an employee of the Pike County Sheriff?s Of?ce, that thing of value being
of such character as to manifest a substantial and imprOper in?uence upon CHARLES

READER with respect to his duties, in violation of Section of the Ohio Revised

   
 

  
 

Code.

COMMON PLEAS COURT
Con?ict of Interest- A misdemeanor of the ?rst degree
FEB 21 2020

 
 

JUSTIN P. BREWSTER
COUNTY CLERK

    

COUNT FIFTEEN
CHARLES READER, on or about October 18, 2017, at the County of Pike, and in

the State of Ohio, or by some manner enumerated in Section 2901.12 of the Ohio Revised
Code whereby proper venue is placed in the County of Pike, in his capacity as a public
of?cial, to wit: Sheriff of Pike County, Ohio, did recklessly solicit or accept a thing of value,
to wit: did request and/or accept a loan of $1,000.00 from Frederick L. Foill who, at the
time, was a vendor of Pike County, that thing of value being of such character as to
manifest a substantial and improper in?uence upon CHARLES READER with respect to

his duties, in violation of Section of the Ohio Revised Code.

Con?ict of Interest- A misdemeanor of the ?rst degree

COUNT SIXTEEN

CHARLES READER, during a period of time beginning May 1, 2018 and ending
June 30, 2018, at the County of Pike, and in the State of Ohio, or by some manner
enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is
placed in the County of Pike, in his capacity as a public of?cial, to wit: Sheriff of Pike
County, Ohio, did recklessly solicit or accept a thing of value, to wit: did request and/or
accept a loan of $2,500.00 from Ryan Bentley who, at the time, was an employee of the
Pike County Sheriff's Of?ce, that thing of value being of such character as to manifest a
substantial and improper in?uence upon CHARLES READER with respect to his duties,

in violation of Section of the Ohio Revised Code.

 

Fl 
COMMON PLEAS COURT

FEB 21 2020

Con?ict of Interest- A misdemeanor of the ?rst degree

P. BREWSTER
COUNTY CLERK

 

COUNT SEVENTEEN
CHARLES READER, on or about August 7, 2018, at the County of Pike, and in

the State of Ohio, or by some manner enumerated in Section 2901.12 of the Ohio Revised
Code whereby proper venue is placed in the County of Pike, in his capacity as a public
of?cial, to wit: Sheriff of Pike County, Ohio, did recklessly solicit or accept a thing of value,
to wit: did request and/or accept a loan of $2,000.00 from Jim Dixon who, at the time, was
an employee of the Pike County Sheriff?s of?ce, that thing of value being of such character
. as to manifest a substantial and improper in?uence upon CHARLES READER with

respect to his duties, in violation of Section of the Ohio Revised Code.

Con?ict of Interest- A misdemeanor of the ?rst degree

COUNT EIGHTEEN
CHARLES READER, on or about August 26, 2018, at the County of Pike, and in

the State of Ohio, or by some manner enumerated in Section 2901.12 of the Ohio Revised
Code whereby proper venue is placed in the County of Pike, in his capacity as a public
of?cial, to Wit: Sheriff of Pike County, Ohio, did recklessly solicit or accept a thing of value,
to wit: did request and/or accept a loan of $2,000.00 from Frederick L. Foill who, at the
time, was a vendor of Pike County, that thing of value being of such character as to
manifest a substantial and improper in?uence upon CHARLES READER with respect to

his duties, in violation of Section of the Ohio Revised Code.

Con?ict of Interest- A misdemeanor of the ?rst degree

      
   
       

   


COMMON PLEAS COURT

FEB 21 2020

JUSTIN P. BREWSTER
COUNTY CLERK

   

Contrary to the form of the statute in such case made and provided, and against the peace

and dignity of the State of Ohio.

ROBERT F. SMITH (0023434)
Special Prosecuting Attorney

A True Bill:

12am? .

FOREPERSON OF THE GRAND JURY

 


COMMON PLEAS COURT

FEB 21 2020

JUSTIN P. BREWSTER
PIKE COUNTY CLERK