INDICTMENT CAUSE NO. 60g THE STATE OF TEXAS vs. MARLENA ROSANNE JACKSON DOB: 11/29/1969 OFFENSE: COUNT ONE: ENGAGING IN ORGANIZED ELECTION FRAUD (F1) COUNT TWO: ILLEGAL VOTING (F2) COUNTS THREE: FRAUDULENT USE OF MAIL BALLOT APPLICATION ENHANCED (F3) COUNTS THIRTY-FOUR FORTY: UNLAWFUL POSSESSION OF BALLOT ENVELOPE ENHANCED (SJF) COUNTS FORTY-ONE SEVENTY-ONE: ELECTION FRAUD ENHANCED (SJF) COUNTS TAMPERING WITH A GOVERNMENTAL RECORD WITH INTENT TO HARM OR DEFRAUD (SJF) IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS: THE GRAND JURORS, duly selected, empaneled, sworn, charged, and organized as such for the County Of Gregg, State of Texas, at the July?December, 2020 term of the 188th District Court for said County, upon their oaths present in and to said Court that from on or about the 22nd day of January A.D., 2018 and continuing until on or about the 6th day Of March A.D., 2018, and anterior to the presentment of this Indictment, in the County and State aforesaid, MARLENA ROSANNE JACKSON, hereinafter called Defendant, did then and there, COUNT ONE Engaging in Organized Election Fraud (F1) with the intent to establish, maintain, and participate in a vote harvesting organization, said organization consisting of Shannon Brown, Marlena Jackson, Dewayne Ward, and Charlie Burns, who collaborated in carrying on election offenses under Titles 1 through 7 of the Texas Election Code, knowingly commit the Offenses Of illegal voting, unlawful assistance, fraudulent use of a mail ballot application multiple times in the same election, unlawful possession Of a ballot or carrier envelope Of another multiple times in the same election, and unlawfully assisting a voter voting a ballot by mail, by committing said Offenses as the primary actor or by acting with the intent to promote or assist the commission Of said Offenses by soliciting, encouraging, directing, aiding, or attempting to aid members Of said organization to commit said Offenses, Page 1 of 21 Marlena Jackson COUNT TWO Illegal Voting And further that Defendant, on or about the 13th day of February A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas did then and there knowingly mark Andrew Erwin?s ballot, without speci?c direction from Andrew Erwin on how to mark the ballot, COUNT THREE Fraudulent Use of Mail Ballot Application Enhanced And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Corby Martin, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT FOUR Fraudulent Use of Mail Ballot Application Enhanced lF3) And further that Defendant, on or about the 221?d day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Linda Carrier, Speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT FIVE Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Davonia Bradley, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT SIX Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Rayford Jordan, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT SEVEN Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Victoria Miller-Burns, speci?cally: Defendant marked the application to reflect that the voter was disabled, when in fact the voter was not disabled, Page 2 0f21 Marlena Jackson COUNT EIGHT Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Lorine Bagley, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT NINE Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Eric Taylor, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT TEN Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Yolita Johnson, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT ELEVEN Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Lorenzo Washington, speci?cally: Defendant marked the application to reflect that the voter was disabled, when in fact the voter was not disabled, COUNT TWELVE Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22?Cl day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Terri Thomas, speci?cally: Defendant indicated by signature that she assisted the voter in completing an application for ballot by mail, when in fact Shannon Brown, a candidate on the ballot in the upcoming election, assisted the voter with said application, COUNT THIRTEEN Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 23rd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Robert Harvey Jr., speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, Page 3 of 21 Marlena Jackson COUNT FOURTEEN Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Roceta Anderson, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT FIFTEEN . Fraudulent Use of Mail Ballot Application Enhanced IFS) And further that Defendant, on or about the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Kaylon Earl, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT SIXTEEN Fraudulent Use of Mail Ballot Application Enhanced And further that Defendant, on or about the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Ricardo Pencheon, specifically: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT SEVENTEEN Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 25111 day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Shannon Martin, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT EIGHTEEN Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 251h day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Jennifer Martin, specifically: Defendant indicated by signature the she assisted the voter in completing an application for ballot by mail, when in fact Shannon Brown, a candidate on the ballot in the upcoming election, assisted the voter with said application, COUNT NINETEEN Fraudulent Use of Mail Ballot Application Enhanced IFS) And further that Defendant, on or about the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Mary Odom, speci?cally: Defendant indicated by signature that she assisted the voter in completing an application for ballot by mail, when in fact another person assisted the voter with said application, Page 4 of 21 Marlena Jackson COUNT TWENTY Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 26Ih day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Tiesean McCray, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 26th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas did then and there knowingly provide false information on an application for ballot by mail for a voter, Otis Jones, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 26th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Kenneth Pierson, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 26th day of January A.D., 2O 18 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on application for ballot by mail for a voter, Athena Johnson, speci?cally: Defendant indicated by signature that she assisted the voter in completing an application for ballot by mail, when in fact another person assisted the voter with said application, COUNT Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 261h day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Roderick Smith, speci?cally: Defendant indicated by signature that she assisted the voter in completing an application for ballot by mail, when in fact another person assisted the voter with said application, COUNT TWENTY-FIVE Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 1':3t day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas did then and there knowingly provide false information on an application for ballot by mail for a voter, Beshad Faggans, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, Page 5 of 21 Marlena Jackson COUNT TWENTY- SIX Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 1st day of February AD, 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Veronica Moore, speci?cally: Defendant indicated by signature that she assisted the voter in completing an application for ballot by mail, when in fact Shannon Brown, a candidate on the ballot in the upcoming election, assisted the voter with said application, COUNT SEVEN Fraudulent Use of Mail Ballot Application Enhanced And further that Defendant, on or about the 2?d day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Coby Johnson, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT Fraudulent Use of Mail Ballot Application Enhanced And further that Defendant, on or about the 2nd day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Cason Johnson, speci?cally: Defendant marked the application to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT Fraudulent Use of Mail Ballot Application Enhanced And further that Defendant, on or about the 14th day of February AD, 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Keyianna Lister, speci?cally: Defendant indicated by signature that she assisted the voter in completing an application for ballot by mail, when in fact Shannon Brown, a candidate on the ballot in the upcoming election, assisted the voter with said app?ca?on, COUNT THIRTY Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 14th day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly provide false information on an application for ballot by mail for a voter, Tamika Buchanan, speci?cally: Defendant indicated by signature that she assisted the voter in completing an application for ballot by mail, when in fact Shannon Brown, a candidate on the ballot in the upcoming election, assisted the voter with said application, Page 6 of 21 Marlena Jackson COUNT THIRTY-ONE Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there intentionally cause false information to be provided on an application for ballot by mail for a voter, Andrew Erwin, speci?cally: Defendant caused the application to be marked to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 26th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there intentionally cause false information to be provided on an application for ballot by mail for a voter, Elizabeth Choice, speci?cally: Defendant caused a forged signature of the voter to be appear on her application for ballot by mail, COUNT Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly submit an application for ballot by mail for voter Kaylon Earl without the voter?s knowledge and authorization, speci?cally: Defendant submitted an application that purported to be a request by the voter to receive ballots by mail for the Democratic Party for elections occurring in 2018, when in fact the voter did not wish to make such a request, And it is further alleged that Defendant committed the offenses described in Counts Three through Thirty-Three in the March 6, 2018 Democratic primary election, COUNT Unlawful Possession of Ballot Ballot Envelope Enhanced (SJF) And further that Defendant, on or about the 12th day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Linda Carrier, COUNT Unlawful Possession of Ballot Ballot Envelope Enhanced (SJF) And further that Defendant, on or about the 13?? day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Robert Harvey Jr, COUNT THIRTY-SIX Unlawful Possession of Ballot Ballot Envelope Enhanced (SJ F) And further, that Defendant, on or about the l31h day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Andrew Erwin, Page 7 of 21 Marlena Jackson COUNT Unlawful Possession of Ballot] Ballot Envelope Enhanced (SJF) And further that Defendant, on or. about the 15th day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Rayford Jordan, COUNT Unlawful Possession of Ballot] Ballot Envelope Enhanced (SJF) And further that Defendant, on or about the 20th day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Coby Johnson, COUNT Unlawful Possession of Ballot/Ballot Envelope Enhanced (SJF) And further that Defendant, on or about the 20Lh day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Cason Johnson, COUNT FORTY Unlawful Possession of Ballot/ Ballot Envelope Enhanced (SJF) And further that Defendant, on or about the 21st day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Ricky Johnson, And it is further alleged that Defendant committed the offenses described in Counts Thirty?Four through Forty in the March 6, 2018 Democratic primary election, COUNT Election Fraud Enhanced (SJF) And further that Defendant, on or about the 12th day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there, while in the presence of the ballot and during the voting precess, knowingly make an effort to in?uence the independent exercise of the vote of Linda Carrier, speci?cally: Defendant in?uenced Linda Carrier to vote for candidate Shannon Brown for Gregg County Commissioner, Precinct 4, COUNT Election Fraud Enhanced (SJ F) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Yolita Johnson, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Yolita Johnson?s mail ballot application to be marked ?disability,? when Yolita Johnson was in fact not disabled and was not eligible to vote by mail, Page 8 of 21 Marlena Jackson COUNT Election Fraud Enhanced (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Corby Martin, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Corby Martin?s mail ballot application to be marked ?disability,? when Coby Martin was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced (SJ F) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Lorine Bagley, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Lorine Bagley?s mail ballot application to be marked ?disability,? when Lorine Bagley was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Eric Taylor, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Eric Taylor?s mail ballot application to be marked ?disability,? when Eric Taylor was in fact not disabled and was not eligible to vote by mail, COUNT FORTY-SIX Election Fraud Enhanced (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Davonia Bradley, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Davonia Bradley?s mail ballot application to be marked ?disability,? when Davonia Bradley was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Linda Carrier, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Linda Carrier?s mail ballot application to be marked ?disability,? when Linda Carrier was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced (SJ And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Victoria Miller?Burns, to obtain a ballot under false pretenses, speci?cally: Page 9 of 21 Marlena Jackson Defendant caused the eligibility reason on Victoria Miller?Burns? mail ballot application to be marked ?disability,? when Victoria Miller?Burns was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced And further that Defendant, on or about the 22nd day of January AD, 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Rayford Jordan, to obtain a ballot under false pretenses, speci?cally: Defendant. caused the eligibility reason on Rayford Jordon?s mail ballot application to be marked ?disability,? when Rayford Johnson was in fact not disabled and was not eligible to vote by mail, COUNT FIFTY Election Fraud Enhanced And further that Defendant, on or about the 22nd day of January AD, 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Terri Thomas, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Terri Thomas? mail ballot application to be marked ?disability,? when Terri Thomas was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Andrew Erwin, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Andrew Erwin?s mail ballot application to be marked ?disability,? when Andrew Erwin was in fact not disabled and was not eligible to vote by mail, COUNT FIFTY-TWO Election Fraud Enhanced And further that Defendant, on or about the 23rd day of January AD, 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Robert Harvey Jr., to obtain a ballot under false pretenses, specifically: Defendant caused the eligibility reason on Robert Harvey Jr.?s mail ballot application to be marked ?disability,? when Robert Harvey Jr. was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced And further that Defendant, on or about the 251h day of January AD, 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Roceta Anderson to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Roceta Anderson ?3 mail ballot application to be marked ?disability,? when Roceta Anderson was in fact not disabled and was not eligible to vote by mail, Page 10 of 21 Marlena Jackson COUNT Election Fraud Enhanced (SJF) And further that Defendant, on or about the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Shannon Martin to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Shannon Martin?s mail ballot application to be marked ?disability,? when Shannon Martin was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced (SJF) And further that Defendant, on or about the 25Lh day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Jennifer Martin to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Jennifer Martin?s mail ballot application to be marked ?disability,? when Jennifer Martin was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced (SJF) And further that Defendant, on or about the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Ricardo Pencheon to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Ricardo Pencheon?s mail ballot application to be marked ?disability,? when Ricardo Pencheon was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced (SJ F) And further that Defendant, on or about the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Kaylon Earl to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Kaylon Earl?s mail ballot application to be marked ?disability,? when Kaylon Earl was in fact not disabled and was not eligible to vote by mail, COUNT . Election Fraud Enhanced (SJF) And further that Defendant, on or about the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Mary Odom to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Mary Odom?s mail ballot application to be marked. ?disability,? when Mary Odom was in fact not disabled and was not eligible to vote by mail, COUNT FIFTY-NINE Election Fraud Enhanced And further that Defendant, on or about the 26th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Roderick Smith, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Roderick Smith ?3 mail ballot application to be marked Page 11 of 21 Marlena Jackson ?disability,? when Roderick Smith was in fact not disabled. and was not eligible to vote by mail, COUNT SIXTY Election Fraud Enhanced And further that Defendant, on or about the 261h day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Athena Johnson, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Athena Johnson ?8 mail ballot application to be marked ?disability,? when Athena Johnson was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced (SJF) And further that Defendant, on or about the 26th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did. then and there cause Loretta aggans to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Loretta Faggans? mail ballot application to be marked ?disability,? when Loretta Faggans was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced (SJF) And further that Defendant, on or about the 26th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Tiesean McCray, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Tiesean McCray?s mail ballot application to be marked ?disability,? when Tiesean McCray was in fact not disabled and was not eligible to vote by mail, COUNT - Election Fraud Enhanced And further that Defendant, on or about the 26th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Otis Johnson, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Otis Johnson?s mail ballot application to be marked ?disability,? when Otis Johnson was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced And further that Defendant, on or about the 261'n day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Kenneth. Pierson, to obtain a ballot under false pretenses, specifically: Defendant caused the eligibility reason on Kenneth Pierson?s mail ballot application to be marked ?disability,? when Kenneth Pierson was in fact not disabled and was not eligible to vote by mail, Page 12 of 21 Marlena Jackson COUNT Election Fraud Enhanced (SJF) And further that Defendant, on or about the 1st day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Veronica Moore, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Veronica Moore?s mail ballot application to be marked ?disability,? when Veronica Moore was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced (SJ F) And further that Defendant, on or about the 1551 day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Aubrey Durham, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Aubrey Durham?s mail ballot application to be marked ?disability,? when Aubrey Durham was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced And further that Defendant, on or about the 1st day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Beshad Faggans, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Beshad Faggans? mail ballot application to be marked ?disability,? when Beshad aggans was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced And further that Defendant, on or about the 2nd day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Coby Johnson, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Coby Johnson?s mail ballot application to be marked ?disability,? when Coby Johnson was in fact not disabled and was not eligible to vote by mail, COUNT SIXTY Election Fraud Enhanced (SJF) And further that Defendant, on or about the 2nd day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Cason Johnson, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Cason Johnson?s mail ballot application to be marked ?disability,? when Cason Johnson was in fact not disabled and was not eligible to vote by mail, COUNT SEVENTY Election Fraud Enhanced (SJF) And further that Defendant, on or about the 141h day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Keyannia Lister, to obtain a ballot under false pretenses, specifically: Defendant Page 13 of 21 Marlena Jackson caused the eligibility reason on Keyannia Lister?s mail ballot application to be marked ?disability,? when Keyannia Lister was in fact not disabled and was not eligible to vote by mail, COUNT Election Fraud Enhanced And further that Defendant, on or about the 141h day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Tamika Buchanan, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Tamika Buchanan?s mail ballot application to be marked ?disability,? when Tamika Buchanan was in fact not disabled and was not eligible to vote by mail, And it is further alleged that Defendant committed the offenses described in Counts orty?One through Seventy?One in the March 6, 2018 Democratic primary election, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for voter Corby Martin, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJ F) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Terri Thomas, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT SEVENTY-FOUR Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Davonia Bradley, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, specifically: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, Page 14 of 21 Marlena Jackson COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Victoria Miller-Burns, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the applicationwas false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT SEVENTY--SIX Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter 'Rayford Jordan, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22%1 day of January A.D., 2018 and before the presentment Of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Lorine Bagley, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJ F) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Eric Taylor, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, - COUNT SEVENTY-NINE Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for Page 15 of 21 Marlena Jackson voter Lorenzo Washington, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT EIGHTY Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Yolita Johnson, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Andrew Erwin, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud And further that Defendant, on or about the 23rd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Robert Harvey Jr., with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or abOut the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Shannon Martin, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, I Page 16 of 21 Marlena Jackson COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 25th day of January AD, 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Jennifer Martin, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJ F) And further that Defendant, on or about the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Roceta Anderson, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, specifically: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 25th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Kaylon Earl, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 25Ih day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority, and candidate Kasha Williams, an application for ballot by mail for voter Ricardo Peneheon, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, specifically: the application was false in that the eligibility reason on the-application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJ F) And further that Defendant, on or about the 26?h day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud a voter, Elizabeth Choice, the Gregg County election. authority, and candidate Kasha Williams, an Page 17 0f 21 Marlena Jackson application for ballot by mail fOr voter Elizabeth Choice, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: Defendant forged the voter?s signature on an application for ballot by mail before submitting it to the election office, - COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 26th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for voter Tiesen McCray, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT NINETY Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 26th day of January AD., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for voter Otis Jones, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJ F) And further that Defendant, on or about the 26th day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for voter Athena Johnson, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application Was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJ F) And further that Defendant, on or about the 261h day of January A.D., 2018 and before the presentment of this'indictment, in Gregg County, Texas, did then. and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for voter Kenneth Pierson, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, Page 18 0f 21 Marlena Jackson COUNT Tampering with a Governmental Record with Intent to Harm or Defraud And further that Defendant, on or about the 13' day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for voter Veronica Moore, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 1st day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent toharm 0r defraud, the Gregg County election authority and candidate Kasha Williams an application for ballot by mail for voter Beshad aggans, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT NINETY-FIVE Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 2nd day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for voter Coby Johnson, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud And further that Defendant, on or about the 2nd day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for voter Cason Johnson, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud And further that Defendant, on or about the 141h day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for Page 19 of 21 Marlena Jackson voter Tamika Buchanan, with knowledge of its falsity and with the intent that it be taken by theelection authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, AGAINST THE PEACE AND DIGNITY OF THE STATE. Foreperson the Grand Jury Page 20 of 21 Marlena Jackson THE STATE OF TEXAS COUNTY OF GREGG I, Trey Hattaway, Clerk of the District Court within and for the County and State aforesaid, do hereby certify that the foregoing contains a true and correct copy of the Indictment in Cause No. of the State of Texas vs. MARLENA ROSANNE JACKSON as now on ?le in this of?ce. I IN TESTIMON WHEREOF I hereto set my hand and seal, this 23 day of 2023:. Trey Hattaway Clerk of the District Court Gregg County, Texas WITNESSES Page 21 of 21 Marlena Jackson INDICTMENT CAUSE NO. 50955 THE STATE OF TEXAS vs. SHANNON EVERETTE BROWN DOB: 10/20/1970 OFFENSE: COUNT ONE: ENGAGING IN ORGANIZED ELECTION FRAUD (F2) COUNTS TWO EIGHT: FRAUDULENT USE OF MAIL BALLOT APPLICATION ENHANCED (F3) COUNTS NINE TEN: UNLAWFUL POSSESSION OF ENVELOPE ENHANCED (SJF) COUNTS ELEVEN EIGHTEEN: ELECTION FRAUD ENHANCED (SJF) COUNTS NINETEEN TAMPERING WITH A GOVERNMENTAL RECORD WITH INTENT TO HARM OR DEFRAUD (SJF) IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS: THE GRAND JURORS, duly selected, empaneled, sworn, Charged, and organized as such for the County of Gregg, State of Texas, at the July?December, 2020 term of the 188th District Court for said County, upon their oaths present in and to said Court that from on or about the 22nd day of January AD, 2018 and continuing until on or about the 6th day of March AD, 2018, and anterior to the presentment of this Indictment, in the County and State aforesaid, SHANNON EVERETTE BROWN, hereinafter called Defendant, did then and there, COUNT ONE Engaging in Organized Election Fraud (F2) with the intent to establish, maintain, and participate in a vote harvesting organization, said organization consisting Of Shannon Brown, Marlena Jackson, Dewayne Ward, and Charlie Burns, who collaborated in committing election Offenses under Titles 1 through 7 of the Texas Election Code, knowingly commit the Offenses of illegal voting, unlawful assistance, fraudulent use of a mail ballot application multiple times in the same election, unlawful possession of a ballot or carrier envelope of another multiple times in the same election, and unlawfully assisting a voter voting a ballot by mail, by committing said Offenses as the primary actor or by acting with the intent to promote or assist the commission of said Offenses by soliciting, encouraging, directing, aiding, or attempting to aid members of said organization to commit said offenses, Page 1 of 7 Shannon Everette Brown COUNT TWO Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant on or about the 22nd day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there intentionally cause false information to be provided on an application for ballot by mail for a voter, Davonia Bradley, speci?cally: Defendant caused the application to be marked to reflect that the voter was disabled, when in fact the voter was not disabled, COUNT THREE Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22nd day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there intentionally cause false information to be provided on an application for ballot by mail for a voter, Yolita Johnson, speci?cally: Defendant caused the application to be marked to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT FOUR Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22nd day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there intentionally cause false information to be provided on an application for ballot by mail for a voter, Terri Thomas, specifically: Defendant caused the application to be marked to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT FIVE Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22rld day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there intentionally cause false information to be provided on an application for ballot by mail for a voter, Ricky Johnson, specifically: Defendant caused the application to be marked to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT SIX Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 22nd day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there intentionally cause false information. to be provided on an application for ballot by mail for a voter, Eric Taylor, speci?cally: Defendant caused the application to be marked to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT SEVEN Fraudulent Use of Mail Ballot Application Enhanced (F3) And further that Defendant, on or about the 231'(1 day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there intentionally cause false information to be provided on an application for ballot by mail for a voter, Robert Harvey Jr., speci?cally: Defendant caused the application to be marked to re?ect that the voter was disabled, when in fact the voter was not disabled, COUNT EIGHT Fraudulent Use of Mail Ballot Application Enhanced (F3) Page 2 of 7 Shannon Everette Brown And further that Defendant, on or about the 181 day of February A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there intentionally cause false information to be provided on an application for ballot by mail for a voter, Veronica Moore, speci?cally: Defendant caused the application to be marked to reflect that the voter was disabled, when in fact the voter was not disabled, And it is further alleged that Defendant committed the offenses described in Counts Two through Eight in the same election, COUNT NINE Unlawful Possession of Ballot [Ballot Envelope Enhanced (SJ And further that Defendant, on or about the 17th day of February A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or carrier envelope of a voter, Davonia Bradley, COUNT TEN Unlawful Possession of Ballot/Ballot Envelope Enhanced (SJ F) And further that Defendant, on or about the 61h day of March A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or carrier envelope of a voter, Tamika Buchanan, And it is further alleged that Defendant committed the offenses described in Counts Nine and Ten in the same election, COUNT ELEVEN Election Fraud Enhanced (SJF) And further that Defendant, on or about the 12th day of February A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there, while in the presence of the ballot and during the voting process, knowingly make an effort to in?uence the independent exercise of the vote of Linda Carrier, speci?cally: Defendant in?uenced Linda Carrier to vote for candidate Shannon Brown for Gregg County Commissioner, Precinct 4, COUNT TWELEVE Election Fraud Enhanced (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Yolita Johnson, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Yolita Johnson?s mail ballot application to be marked ?disability,? when Yolita Johnson was in fact not disabled and was not eligible to vote by mail, COUNT THIRTEEN Election Fraud Enhanced (SJF) And further that Defendant, on or about the 22?d day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Terri Thomas, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Terri Thomas? mail ballot application to be marked ?disability,? when Terri Thomas was in fact not disabled and was not eligible to vote by mail, Page 3 of 7 Shannon Everette Brown COUNT FOURTEEN Election Fraud Enhanced And further that Defendant, on or about the 22nd day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Davonia Bradley to obtain a ballot under false pretenses, specifically: Defendant caused the eligibility reason on Davonia Bradley?s mail ballot application to be marked ?disability,? when Davonia Bradley was in fact not disabled and was not eligible to vote by mail, COUNT FIFTEEN Election Fraud Enhanced (SJF) And further that Defendant, on or about the 22rld day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Eric Taylor, to obtain a ballot under false pretenses, specifically: Defendant caused the eligibility reason on Eric Taylor?s mail ballot application to be marked ?disability,? when Eric Taylor was in fact not disabled and was not eligible to vote by mail, COUNT SIXTEEN Election Fraud Enhanced (SJ And further that Defendant, on or about the 23rd day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Robert Harvey Jr., to obtain a ballot under false pretenses, specifically: Defendant caused the eligibility reason on Robert Harvey Jr?s mail ballot application to be marked ?disability,? when Robert Harvey Jr. was in fact not disabled and was not eligible to vote by mail, COUNT SEVENTEEN Election Fraud Enhanced (SJ F) And further that Defendant, on or about the 13t day of February 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Veronica Moore, to obtain a ballot under false pretenses, specifically: Defendant caused the eligibility reason on Veronica Moore?s mail ballot application to be marked ?disability,? when Veronica Moore was in fact not disabled and was not eligible to vote by mail, COUNT EIGHTEEN Election Fraud Enhanced (SJ And further that Defendant, on or about the 14th day of February A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there cause Tamika Buchanan, to obtain a ballot under false pretenses, speci?cally: Defendant caused the eligibility reason on Tamika Buchanan?s mail ballot application to be marked ?disability,? when Tamika Buchanan was in fact not disabled and was not eligible to vote by mail, And it is further alleged that Defendant committed the offenses described in Counts Eleven through Eighteen in the same election, Page 4 of 7 Shannon Everette Brown COUNT NINETEEN Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for voter Terri Thomas, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT TWENTY Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for voter Yolita Johnson, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNTY Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams an application for ballot by mail for voter Davonia Bradley, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled. COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 23rd day of January AD, 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for voter Robert Harvey Jr., with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, COUNT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the l41h day of February A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams, an application for ballot by mail for Page 5 of 7 Shannon Everette Brown voter Tamika Buchanan, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, AGAINST THE PEACE AND DIGNITY OF THE STATE. Foreperson 0 th Grand Jury Page 6 of 7 Shannon Everette Brown THE STATE OF TEXAS COUNTY OF GREGG I, Trey Hattaway, Clerk of the District Court within and for the County and State aforesaid, do hereby certify that the foregoing contains a true and correct copy of the Indictment in Cause No. 50453-8 of the State of Texas vs. SHANNON BROWN as now on ?le in this of?ce. IN TESTIMONY WHEREOF 1 hereto set my hand and seal, this 25; day of Sad: 2070 . VI Trey Hattaway Clerk of the District Court De Gregg County, Texas WITNESSES Page 7 of 7 Shannon Everette Brown INDICTMENT CAUSE NO. 60g 6?}3 THE STATE OF TEXAS vs. CHARLIE BURNS, JR. DOB: 06/09/1936 OFFENSE: COUNT ONE - ENGAGING IN ORGANIZED ELECTION FRAUD (F3) COUNT TWO FRAUDULENT USE OF APPLICATION FOR BALLOT BY MAIL (SJF) COUNTS THREE SEVEN POSSESSION OF A BALLOT OR CARRIER ENVELOPE ENHANCED (SJF) COUNT EIGHT TAMPERING WITH A GOVERNMENTAL RECORD WITH INTENT TO HARM OR DEFRAUD (SJF) IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS: THE GRAND JURORS, duly selected, empaneled, sworn, Charged, and organized as such for the County of Gregg, State of Texas, at the July?December, 2020 term of the 188th District Court for said County, upon their oaths present in and to said Court that from on or about the 22nd day Of January A.D., 2018 and continuing until on or about the 6th day of March AD, 2018, and anterior to the presentment of this Indictment, in the County and State aforesaid, CHARLIE BURNS, JR., hereinafter called Defendant, did then and there COUNT ONE Engaging in Organized Election Fraud (F3) with the intent to establish, maintain, and participate in a vote harvesting organization, said organization consisting Of Shannon Brown, Marlena Jackson, Dewayne Ward, and Charlie Burns, who collaborated in carrying on election Offenses under Titles 1 through 7 Of the Texas Election Code, knowingly Commit the offenses of fraudulent use of a mail ballot application and possessing a ballot or carrier envelope of another multiple times in the same election, by acting with the intent to promote or assist the commission of said Offense by soliciting, encouraging, directing, aiding, or attempting to aid members of said organization to commit said offense, COUNT TWO Fraudulent Use of Application for Ballot by Mail (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there intentionally cause false information to be provided on an application for ballot by mail for a voter, Davonia Bradley, speci?cally: Defendant caused the application to be marked to re?ect that the voter was disabled, when in fact the voter was not disabled, Page 1 of 4 - Charlie Burns, Jr. COUNT THREE Possession of a Ballot or Carrier Envelope Enhanced (SJF) And further that Defendant, on or about the 16th of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Otis Jones, COUNT FOUR Possession of a Ballot or Carrier Envelope Enhanced F) And further that Defendant, on or about the 17th of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Natasha Bush, COUNT FIVE Possession of a Ballot or Carrier Envelope Enhanced And further that Defendant, on or about the 17th of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Davonia Bradley, COUNT SIX Possession of a Ballot or Carrier Envelope Enhanced (SJF) And further that Defendant, on or about the 17m of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Veronica Moore, COUNT SEVEN Possession of a Ballot or Carrier Envelope Enhanced And further that Defendant, on or about the 22nd day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Roceta Anderson, And it is further alleged that Defendant committed the offenses described in Counts Three through Seven in the March 6, 2018 Democratic primary election, Page 2 of 4 - Charlie Burns, Jr. COUNT EIGHT Tampering with a Governmental Record with Intent to Harm or Defraud (SJF) And further that Defendant, on or about the 22nd day of January A.D., 2018, and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly make, present, or use, with intent to harm or defraud the Gregg County election authority and candidate Kasha Williams an application for ballot by mail for voter Davonia Bradley, with knowledge of its falsity and with the intent that it be taken by the election authority as a genuine governmental record, speci?cally: the application was false in that the eligibility reason on the application was marked ?disability,? when in fact the voter was not disabled, AGAINST THE PEACE AND DIGNITY OF THE STATE. (1 Foreperson of the Grand Jury Page 3 of 4 Charlie Burns, Jr. THE STATE OF TEXAS COUNTY OF GREGG I, Trey Hattaway, Clerk of the District Court within and for the County and State aforesaid, do hereby certify that the foregoing contains a true and correct copy of the Indictment in Cause No. @qgi?a of the State of Texas vs. CHARLIE BURNSthis of?ce. IN TESTIMONY WHEREOF I hereto set my hand and seal, this 25 day of 37-90% 20:2. Trey Hattaway By Clerk of the District Court Deputy Gregg County, Texas WITNESSES Page 4 of 4 Charlie Burns, Jr. INDICTMENT CAUSE NO. 50947? E) THE STATE OF TEXAS vs. DEWAYNE WARD DOB: 09/28/1961 OFFENSE: COUNT ONE - ENGAGING 1N ORGANIZED ELECTION FRAUD (F1) COUNT TWO UNLAWFUL POSSESSION OF BALLOT BALLOT ENVELOPE WITHOUT REQUEST OF VOTER ENHANCED (F2) COUNTS THREE SIX UNLAWFUL POSSESSION OF BALLOT BALLOT ENVELOPE (SJF) IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS: THE GRAND JURORS, duly selected, empaneled, sworn, charged, and organized as such for the County of Gregg, State of Texas, at the July?December, 2020 term Of the 188th District Court for said County, upon their oaths present in and to said Court that from on or about the 22?cl day of January AD, 2018 and continuing until on or about the 6th day of March A.D., 2018, and anterior to the presentment of this Indictment, in the County and State aforesaid, DEWAYNE WARD, hereinafter called Defendant, did then and there COUNT ONE Engaging in Organized Election Fraud {Fl} DEWAYNE WARD, hereinafter styled Defendant, from on or about the 22nd day of January A.D., 2018 and continuing until on or about the 6th day of March AD, 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there, with the intent to establish, maintain, and participate in a vote harvesting organization, said organization consisting of Shannon Brown, Marlena Jackson, Dewayne Ward, and Charlie Burns, who collaborated in carrying on election Offenses under Titles 1 through 7 Of the Texas Election Code, knowingly commit, multiple times in the same election, the Offenses of unlawful possession of a ballot or carrier envelope without the request Of the voter and unlawful possession Of a ballot or carrier envelope Of another, by committing said offenses as the primary actor or by acting with intent to promote or assist the commission Of said Offenses by soliciting, encouraging, directing, aiding, or attempting to aid members of said organization to commit said Offenses, COUNT TWO Unlawful Possession of Ballot/Ballot Envelope without Request of Voter Enhanced And further that Defendant, on or about the 6th day of March A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or Of?cial carrier envelope Of a voter, Tamika Buchanan, without the request Of the voter, Page 1 Of 3 - Dewayne Ward COUNT THREE Unlawful Possession of Ballot [Ballot Envelope Enhanced (SJF) And further that Defendant, on or about the 24th day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Mary Odom, COUNT FOUR . Unlawful Possession of Ballot Ballot Envelope Enhanced (SJF) And further that Defendant, on or about the 26th day of February A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Aubrey Durham, COUNT FIVE Unlawful Possession of Ballot] Ballot Envelope Enhanced And further that Defendant, on or about the 61h day of March AD, 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Keyannia Lister, COUNT SIX Unlawful Possession of Ballot] Ballot Envelope Enhanced And further that Defendant, on or about the 6th day of March A.D., 2018 and before the presentment of this indictment, in Gregg County, Texas, did then and there knowingly possess the of?cial ballot or of?cial carrier envelope of a voter, Roderick Smith, And it is further alleged that Defendant committed the offenses described in Counts Two through Six in the March 6, 2018 Democratic primary election, AGAINST THE PEACE AND DIGNITY OF THE STATE. Foreperson of 6 Grand Jury Page 2 of 3 Dewayne Ward THE STATE OF TEXAS COUNTY OF GREGG I, Trey Hattaway, Clerk of the District Court within and for the County and State aforesaid, do hereby certify that the foregoing contains a true and correct copy of the Indictment in Cause No. of the State of Texas vs. DEWAYNE WARD as now on file in this of?ce. IN TESTIMONY WHEREOF I hereto set my hand and seal, this Z3 day of $047. 2070 . H?dvv?I' Trey Hattaway Clerk of the District Court uty Gregg County, Texas WITNESSES Page 3 of 3 Dewayne Ward