Cuyahoga County Court of Common Pleas
Criminal Court Division
State of Ohio,
A True Bill Indictment For
Plaintiff
Participating In A Criminal Gang - F2
†$
VS.
Bryan Wilson
Jamal Cammack
Allante Bush
Rayshawn Foster,
Defendants
Dates of Offense (on or about)
The Term Of
01/01/2015 to 10/17/2016
The State of Ohio,
Cuyahoga County
Count 1
Defendants
Date of Offense
38 Additional Count(s)
Case Number
September of 2016
}
610468-16-CR
SS.
Participating In A Criminal Gang - F2
†$
Bryan Wilson, Jamal Cammack, Allante Bush, Rayshawn Foster
On or about January 1, 2015 to October 17, 2016
The Jurors of the Grand Jury of the State of Ohio, within and for the body of the County aforesaid, on their oaths, IN THE NAME
AND BY THE AUTHORITY OF THE STATE OF OHIO, do find and present, that the above named Defendant(s), on or about the
date of the offense set forth above, in the County of Cuyahoga, unlawfully
did actively participate in a criminal gang, with knowledge that the criminal gang engages in or had
engaged in a pattern of criminal gang activity, and did purposely promote, further, or assist any
criminal conduct, as defined in division (C) of section 2923.41 of the Revised Code, or did purposely
commit or engage in any act that constituted criminal conduct, as defined in division (C) of section
2923.41 of the Revised Code, to wit: ..
The criminal gang "56 Bricks" aka "Bricks Squad", a subset of the Heartless Felons, has three or
more individuals that have each committed or aided and abetted in the commission of two or more of
the following offenses:
A. Any felony; or
1. Allante Bush (Trafficking: CR-12-563112, CR-16, 603748, CR-16-608440,
CR-16-610319)
2. Jamal Cammack (Aggravated Riot: CR-11-556997)
3. Rayshawn Foster (Trafficking: CR-10-539361, CR-12-566505;
CR-15-592563; Drug Possession: CR-12-565274,
CR-12-567695)
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 1 of 22
Cuyahoga County Court of Common Pleas
A True Bill Indictment
4. Bryan Wilson (Felonious Assault: CR-10-540887; Burglary: CR-10-542317,
CR-10-542318; Trafficking: CR-16-609657)
5. Shaquille Crenshaw (Involuntary Manslaughter: CR-12-568206)
6. Donte Ferguson (Criminal Gang Activity: CR-14-586873)
7. Dominique King (Murder: CR-11-556997)
8. Antonio Kirk (Aggravated Riot: CR-11-556997)
B. Any offense of violence (felony or misdemeanor); or
C. 1. Improperly handling firearms in a motor vehicle, 2923.16,
2. Contributing to unruliness or delinquency of a child 2919.24,
3. Witness/Victim Intimidation 2921.04,
4. Criminal Damaging 2909.06,
5. Aggravated Trespass 2911.211,
6. Marihuana Drug Trafficking 2925.03,
7. Interference with custody 2919.23,
8. Failure to Disperse 2917.04,
9. Ethnic Intimidation 2927.12, or
10. Unlawful Sexual Conduct with a Minor 2907.04
AND
1. At least one of the offenses committed by members of the group is a
felony;
2. One of the offenses occurred after 1/1/99;
3. The last offense committed cannot be more than five years after the
other offense listed;
4. The offenses listed are committed on separate dates unless the offenses
are committed by two or more people
AND
That one of that Group's primary activities are to commit one or more of the criminal offenses
listed above.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 2 of 22
Cuyahoga County Court of Common Pleas
Count 2
Defendants
Date of Offense
A True Bill Indictment
Trafficking - F1
†$
Jamal Cammack
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\SUHSDUHIRUVKLSPHQWVKLSWUDQVSRUWGHOLYHUSUHSDUHIRUGLVWULEXWLRQRUGLVWULEXWHD
controlled substance or a controlled substance analog, when the offender knows or has reasonable
cause to believe that the controlled substance or a controlled substance analog is intended for sale or
UHVDOHE\WKHRIIHQGHURUDQRWKHUSHUVRQWKHGUXJLQYROYHGLQWKHYLRODWLRQLVKHURLQRUDFRPSRXQG
PL[WXUHSUHSDUDWLRQRUVXEVWDQFHFRQWDLQLQJKHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRU
exceeds fifty grams but is less than two hundred fifty grams.
Narcotics were recovered during the execution of the search warrant at the Lakeshore Apartment.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 3
Defendants
Date of Offense
Trafficking - F1
†$
Bryan Wilson, Jamal Cammack, Allante Bush, Rayshawn Foster
On or about August 15, 2016 to September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\SUHSDUHIRUVKLSPHQWVKLSWUDQVSRUWGHOLYHUSUHSDUHIRUGLVWULEXWLRQRUGLVWULEXWHD
controlled substance or a controlled substance analog, when the offender knows or has reasonable
cause to believe that the controlled substance or a controlled substance analog is intended for sale or
UHVDOHE\WKHRIIHQGHURUDQRWKHUSHUVRQWKHGUXJLQYROYHGLQWKHYLRODWLRQLVKHURLQRUDFRPSRXQG
PL[WXUHSUHSDUDWLRQRUVXEVWDQFHFRQWDLQLQJKHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRU
exceeds fifty grams but is less than two hundred fifty grams.
)LUHDUP6SHFLILFDWLRQ\HDU†$
The Grand Jurors further find and specify that
the offender had a firearm on or about his person or under his control while committing the offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 3 of 22
Cuyahoga County Court of Common Pleas
Count 4
Defendants
Date of Offense
A True Bill Indictment
Trafficking - F4
†$
Jamal Cammack
On or about August 15, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\VHOORURIIHUWRVHOODFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJWKHGUXJ
involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRUH[FHHGVRQHJUDPEXWLVOHVVWKDQILYHJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 5
Defendants
Date of Offense
Drug Possession - F4
†$
Jamal Cammack
On or about August 15, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\REWDLQSRVVHVVRUXVHDFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJDQGWKH
drug involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRUH[FHHGVRQHJUDPEXWLVOHVVWKDQILYHJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 6
Defendants
Date of Offense
Trafficking - F4
†$
Jamal Cammack
On or about August 19, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\VHOORURIIHUWRVHOODFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJWKHGUXJ
involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRUH[FHHGVRQHJUDPEXWLVOHVVWKDQILYHJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 4 of 22
Cuyahoga County Court of Common Pleas
Count 7
Defendants
Date of Offense
A True Bill Indictment
Drug Possession - F4
†$
Jamal Cammack
On or about August 19, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\REWDLQSRVVHVVRUXVHDFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJDQGWKH
drug involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRUH[FHHGVRQHJUDPEXWLVOHVVWKDQILYHJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 8
Defendants
Date of Offense
Trafficking - F5
†$
Jamal Cammack, Rayshawn Foster
On or about August 22, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\VHOORURIIHUWRVHOODFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJWKHGUXJ
involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGLVOHVVWKDQJUDP
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 9
Defendants
Date of Offense
Drug Possession - F5
†$
Jamal Cammack, Rayshawn Foster
On or about August 22, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\REWDLQSRVVHVVRUXVHDFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJDQGWKH
drug involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWLQYROYHGLVOHVVWKDQRQHJUDP
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 5 of 22
Cuyahoga County Court of Common Pleas
Count 10
Defendants
Date of Offense
A True Bill Indictment
Trafficking - F4
†$
Jamal Cammack
On or about August 24, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\VHOORURIIHUWRVHOODFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJWKHGUXJ
involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRUH[FHHGVRQHJUDPEXWLVOHVVWKDQILYHJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 11
Defendants
Date of Offense
Drug Possession - F4
†$
Jamal Cammack
On or about August 24, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\REWDLQSRVVHVVRUXVHDFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJDQGWKH
drug involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRUH[FHHGVRQHJUDPEXWLVOHVVWKDQILYHJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 12
Defendants
Date of Offense
Trafficking - F5
†$
Jamal Cammack
On or about August 29, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\VHOORURIIHUWRVHOODFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJWKHGUXJ
involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGLVOHVVWKDQJUDP
)LUHDUP6SHFLILFDWLRQ\HDU†$
The Grand Jurors further find and specify that
the offender had a firearm on or about his person or under his control while committing the offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 6 of 22
Cuyahoga County Court of Common Pleas
Count 13
Defendants
Date of Offense
A True Bill Indictment
Drug Possession - F5
†$
Jamal Cammack
On or about August 29, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\REWDLQSRVVHVVRUXVHDFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJDQGWKH
drug involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWLQYROYHGLVOHVVWKDQRQHJUDP
)LUHDUP6SHFLILFDWLRQ\HDU†$
The Grand Jurors further find and specify that
the offender had a firearm on or about his person or under his control while committing the offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 14
Defendants
Date of Offense
Having Weapons Under Disability - F3
†$
Jamal Cammack
On or about August 29, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\DFTXLUHKDYHFDUU\RUXVHDQ\ILUHDUPRUGDQJHURXVRUGQDQFHDQGKHZDVXQGHU
indictment for or has been convicted of any felony offense of violence, to wit: the said Jamal
Cammack, with counsel, on or about the July 9, 2012, in the Court of Common Pleas, Cuyahoga
County, Ohio, Case No. CR-11-556997, having been indicted for or convicted of the crime of
Aggravated Riot, in violation of Revised Code Section 2917.02 of the State of Ohio.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 7 of 22
Cuyahoga County Court of Common Pleas
Count 15
Defendants
Date of Offense
A True Bill Indictment
Having Weapons Under Disability - F3
†$
Bryan Wilson
On or about September 6, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\DFTXLUHKDYHFDUU\RUXVHDQ\ILUHDUPRUGDQJHURXVRUGQDQFHDQGKHZDVXQGHU
indictment for or has been convicted of any felony offense of violence, to wit: the said Bryan Wilson,
with counsel, on or about the 15th day of February, 2011, in the Court of Common Pleas, Cuyahoga
County, Ohio, Case No. CR540887, having been indicted for or convicted of the crime of Felonious
Assault, in violation of Revised Code Section 2903.11 of the State of Ohio.
)RUIHLWXUHRID:HDSRQZKLOHXQGHU'LVDELOLW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of a gun/firearm, Serial No. PBR6291, which
is contraband and/or property derived from or through the commission or facilitation of an offense,
and/or is an instrumentality the offender(s) used or intended to use in the commission or facilitation
of a felony offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 16
Defendants
Date of Offense
Trafficking - F4
†$
Bryan Wilson
On or about September 6, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\SUHSDUHIRUVKLSPHQWVKLSWUDQVSRUWGHOLYHUSUHSDUHIRUGLVWULEXWLRQRUGLVWULEXWHD
controlled substance or a controlled substance analog, when the offender knows or has reasonable
cause to believe that the controlled substance or a controlled substance analog is intended for sale or
UHVDOHE\WKHRIIHQGHURUDQRWKHUSHUVRQWKHGUXJLQYROYHGLQWKHYLRODWLRQLVFRFDLQHRUDFRPSRXQG
PL[WXUHSUHSDUDWLRQRUVXEVWDQFHFRQWDLQLQJFRFDLQHDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRU
exceeds five grams but is less than ten grams of cocaine.
)LUHDUP6SHFLILFDWLRQ\HDU†$
The Grand Jurors further find and specify that
the offender had a firearm on or about his person or under his control while committing the offense.
)RUIHLWXUHRID&HOO3KRQHLQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s) is the owner(s) and/or possessor(s) of a cell phone, which is contraband and/or
property derived from or through the commission of an offense, and/or is an instrumentality the
offender(s) used or intended to use in the commission of a felony, to-wit: said cell phone being used
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 8 of 22
Cuyahoga County Court of Common Pleas
A True Bill Indictment
to communicate with customers, suppliers and co-traffickers and/or other persons involved in
shipping and/or selling of drugs.
)RUIHLWXUHRID*XQLQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of gun, serial #PBR6291, which is
contraband and/or property derived from or through the commission or facilitation of an offense,
and/or is an instrumentality the offender(s) used or intended to use in the commission or facilitation
of a felony offense, to-wit: said firearm being used to protect drugs and/or drug proceeds.
)RUIHLWXUHRID6FDOHLQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of a digital scale, which is contraband and/or
property derived from or through the commission of an offense, and/or is an instrumentality the
offender(s) used or intended to use in the commission or facilitation of a felony offense, to wit: said
scale used to weigh drugs.
)RUIHLWXUHRI0RQH\LQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s), Bryan Wilson, is/are the owner(s) and/or possessor(s) of $11.00 in U.S. currency,
which is contraband and/or property derived from or through the commission of an offense, and/or is
an instrumentality the offender(s) used or intended to use in the commission of or facilitation of
felony offense, to wit: said money being drug proceeds and/or used to purchase more drugs and/or
drug paraphernalia and/or used to facilitate the transfer and/or transportation of drugs and/or drug
paraphernalia.
)RUIHLWXUHRI3URSHUW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of packaging material which is contraband
and/or property derived from or through the commission or facilitation of an offense, and/or is an
instrumentality the offender(s) used or intended to use in the commission or facilitation of a felony
offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 9 of 22
Cuyahoga County Court of Common Pleas
Count 17
Defendants
Date of Offense
A True Bill Indictment
Drug Possession - F5
†$
Bryan Wilson
On or about September 6, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\REWDLQSRVVHVVRUXVHDFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJDQGWKH
drug involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWLQYROYHGLVOHVVWKDQRQHJUDP
)LUHDUP6SHFLILFDWLRQ\HDU†$
The Grand Jurors further find and specify that
the offender had a firearm on or about his person or under his control while committing the offense.
)RUIHLWXUHRID&HOO3KRQHLQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s) is the owner(s) and/or possessor(s) of a cell phone, which is contraband and/or
property derived from or through the commission of an offense, and/or is an instrumentality the
offender(s) used or intended to use in the commission of a felony, to-wit: said cell phone being used
to communicate with customers, suppliers and co-traffickers and/or other persons involved in
shipping and/or selling of drugs.
)RUIHLWXUHRID*XQLQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of gun, serial #PBR6291, which is
contraband and/or property derived from or through the commission or facilitation of an offense,
and/or is an instrumentality the offender(s) used or intended to use in the commission or facilitation
of a felony offense, to-wit: said firearm being used to protect drugs and/or drug proceeds.
)RUIHLWXUHRID6FDOHLQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of a digital scale, which is contraband and/or
property derived from or through the commission of an offense, and/or is an instrumentality the
offender(s) used or intended to use in the commission or facilitation of a felony offense, to wit: said
scale used to weigh drugs.
)RUIHLWXUHRI0RQH\LQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s), Bryan Wilson, is/are the owner(s) and/or possessor(s) of $11.00 in U.S. currency,
which is contraband and/or property derived from or through the commission of an offense, and/or is
an instrumentality the offender(s) used or intended to use in the commission of or facilitation of
felony offense, to wit: said money being drug proceeds and/or used to purchase more drugs and/or
drug paraphernalia and/or used to facilitate the transfer and/or transportation of drugs and/or drug
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 10 of 22
Cuyahoga County Court of Common Pleas
A True Bill Indictment
paraphernalia.
)RUIHLWXUHRI3URSHUW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of packaging material which is contraband
and/or property derived from or through the commission or facilitation of an offense, and/or is an
instrumentality the offender(s) used or intended to use in the commission or facilitation of a felony
offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 18
Defendants
Date of Offense
Drug Possession - F4
†$
Bryan Wilson
On or about September 6, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\REWDLQSRVVHVVRUXVHDFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJDQGWKH
drug involved in the violation is a compound, mixture, preparation, or substance containing
FRFDLQHDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRUH[FHHGVILYHJUDPVEXWLVOHVVWKDQWHQJUDPV
)LUHDUP6SHFLILFDWLRQ\HDU†$
The Grand Jurors further find and specify that
the offender had a firearm on or about his person or under his control while committing the offense.
)RUIHLWXUHRID&HOO3KRQHLQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s) is the owner(s) and/or possessor(s) of a cell phone, which is contraband and/or
property derived from or through the commission of an offense, and/or is an instrumentality the
offender(s) used or intended to use in the commission of a felony, to-wit: said cell phone being used
to communicate with customers, suppliers and co-traffickers and/or other persons involved in
shipping and/or selling of drugs.
)RUIHLWXUHRID*XQLQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of gun, serial #PBR6291, which is
contraband and/or property derived from or through the commission or facilitation of an offense,
and/or is an instrumentality the offender(s) used or intended to use in the commission or facilitation
of a felony offense, to-wit: said firearm being used to protect drugs and/or drug proceeds.
)RUIHLWXUHRID6FDOHLQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of a digital scale, which is contraband and/or
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 11 of 22
Cuyahoga County Court of Common Pleas
A True Bill Indictment
property derived from or through the commission of an offense, and/or is an instrumentality the
offender(s) used or intended to use in the commission or facilitation of a felony offense, to wit: said
scale used to weigh drugs.
)RUIHLWXUHRI0RQH\LQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s), Bryan Wilson, is/are the owner(s) and/or possessor(s) of $11.00 in U.S. currency,
which is contraband and/or property derived from or through the commission of an offense, and/or is
an instrumentality the offender(s) used or intended to use in the commission of or facilitation of
felony offense, to wit: said money being drug proceeds and/or used to purchase more drugs and/or
drug paraphernalia and/or used to facilitate the transfer and/or transportation of drugs and/or drug
paraphernalia.
)RUIHLWXUHRI3URSHUW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of packaging material which is contraband
and/or property derived from or through the commission or facilitation of an offense, and/or is an
instrumentality the offender(s) used or intended to use in the commission or facilitation of a felony
offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 19
Defendants
Date of Offense
Possessing Criminal Tools - F5
†$
Bryan Wilson
On or about September 6, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did possess or have under the person's control any substance, device, instrument, or article, to wit:
cell phone and/or digital scale and/or gun and/or money and/or packaging material with purpose to
use it criminally.
FURTHERMORE, the cell phone and/or digital scale and/or gun and/or money and/or packaging
material involved in the offense were intended for use in the commission of a felony, to wit: Drug
Trafficking, R.C. 2925.03 and/or Drug Possession, R.C. 2925.11.
)RUIHLWXUHRID&HOO3KRQHLQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s) is the owner(s) and/or possessor(s) of a cell phone, which is contraband and/or
property derived from or through the commission of an offense, and/or is an instrumentality the
offender(s) used or intended to use in the commission of a felony, to-wit: said cell phone being used
to communicate with customers, suppliers and co-traffickers and/or other persons involved in
shipping and/or selling of drugs.
)RUIHLWXUHRID*XQLQD'UXJ&DVH†$
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 12 of 22
Cuyahoga County Court of Common Pleas
)RUIHLWXUHRID*XQLQD'UXJ&DVH†$
A True Bill Indictment
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of gun, serial #PBR6291, which is
contraband and/or property derived from or through the commission or facilitation of an offense,
and/or is an instrumentality the offender(s) used or intended to use in the commission or facilitation
of a felony offense, to-wit: said firearm being used to protect drugs and/or drug proceeds.
)RUIHLWXUHRID6FDOHLQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of a digital scale, which is contraband and/or
property derived from or through the commission of an offense, and/or is an instrumentality the
offender(s) used or intended to use in the commission or facilitation of a felony offense, to wit: said
scale used to weigh drugs.
)RUIHLWXUHRI0RQH\LQD'UXJ&DVH†$
The Grand Jurors further find and specify that
the defendant(s), Bryan Wilson, is/are the owner(s) and/or possessor(s) of $11.00 in U.S. currency,
which is contraband and/or property derived from or through the commission of an offense, and/or is
an instrumentality the offender(s) used or intended to use in the commission of or facilitation of
felony offense, to wit: said money being drug proceeds and/or used to purchase more drugs and/or
drug paraphernalia and/or used to facilitate the transfer and/or transportation of drugs and/or drug
paraphernalia.
)RUIHLWXUHRI3URSHUW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of packaging material which is contraband
and/or property derived from or through the commission or facilitation of an offense, and/or is an
instrumentality the offender(s) used or intended to use in the commission or facilitation of a felony
offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 20
Defendants
Date of Offense
Trafficking - F4
†$
Jamal Cammack
On or about September 7, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\VHOORURIIHUWRVHOODFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJWKHGUXJ
involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRUH[FHHGVRQHJUDPEXWLVOHVVWKDQILYHJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 13 of 22
Cuyahoga County Court of Common Pleas
Count 21
Defendants
Date of Offense
A True Bill Indictment
Drug Possession - F4
†$
Jamal Cammack
On or about September 7, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\REWDLQSRVVHVVRUXVHDFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJDQGWKH
drug involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRUH[FHHGVRQHJUDPEXWLVOHVVWKDQILYHJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 22
Defendants
Date of Offense
Trafficking - F5
†$
Jamal Cammack
On or about September 7, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\VHOORURIIHUWRVHOODFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJWKHGUXJ
involved in the violation is cocaine or a compound, mixture, preparation, or substance containing
FRFDLQHLQDQDPRXQWRIOHVVWKDQJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 23
Defendants
Date of Offense
Drug Possession - F5
†$
Jamal Cammack
On or about September 7, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\REWDLQSRVVHVVRUXVHDFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJDQGWKH
drug involved in the violation is a compound, mixture, preparation, or substance containing
FRFDLQHDQGWKHDPRXQWRIWKHGUXJLQYROYHGLVOHVVWKDQJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 14 of 22
Cuyahoga County Court of Common Pleas
Count 24
Defendants
Date of Offense
A True Bill Indictment
Having Weapons Under Disability - F3
†$
Rayshawn Foster
On or about September 13, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\DFTXLUHKDYHFDUU\RUXVHDQ\ILUHDUPRUGDQJHURXVRUGQDQFHDQGKHZDVXQGHU
indictment for or has been convicted of a felony offense involving the illegal possession, use, sale,
administration, distribution, or trafficking in any drug of abuse, to wit: the said Rayshawn Foster,
with counsel, on or about the January 12, 2011, in the Court of Common Pleas, Cuyahoga County,
Ohio, Case No. CR-10-539361, having been indicted for or convicted of the crime of Drug
Trafficking, in violation of 2925.03 of the State of Ohio.
)RUIHLWXUHRID:HDSRQZKLOHXQGHU'LVDELOLW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of 1 rock Island Armory black and wooden
handle .45 caliber handgun with magazine contain (9) live rounds, which is contraband and/or
property derived from or through the commission or facilitation of an offense, and/or is an
instrumentality the offender(s) used or intended to use in the commission or facilitation of a felony
offense.
)RUIHLWXUHRI3URSHUW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of 1 rock Island Armory black and wooden
handle .45 caliber handgun with magazine contain (9) live rounds which is contraband and/or
property derived from or through the commission or facilitation of an offense, and/or is an
instrumentality the offender(s) used or intended to use in the commission or facilitation of a felony
offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 15 of 22
Cuyahoga County Court of Common Pleas
Count 25
Defendants
Date of Offense
A True Bill Indictment
Improperly Handling Firearms In A Motor Vehicle - F4
†%
Rayshawn Foster
On or about September 13, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly transport or have a loaded firearm in a motor vehicle in such a manner that the firearm
is accessible to the operator or any passenger without leaving the vehicle.
)RUIHLWXUHRID:HDSRQ†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of 1 rock Island Armory black and wooden
handle .45 caliber handgun with magazine contain (9) live rounds, which is contraband and/or
property derived from or through the commission or facilitation of an offense, and/or is an
instrumentality the offender(s) used or intended to use in the commission or facilitation of a felony
offense.
)RUIHLWXUHRI3URSHUW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of 1 rock Island Armory black and wooden
handle .45 caliber handgun with magazine contain (9) live rounds which is contraband and/or
property derived from or through the commission or facilitation of an offense, and/or is an
instrumentality the offender(s) used or intended to use in the commission or facilitation of a felony
offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 26
Defendants
Date of Offense
Trafficking - F3
†$
Jamal Cammack
On or about September 21, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\VHOORURIIHUWRVHOODFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJWKHGUXJ
involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRUH[FHHGVILYHJUDPVEXWLVOHVVWKDQWHQJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 16 of 22
Cuyahoga County Court of Common Pleas
Count 27
Defendants
Date of Offense
A True Bill Indictment
Drug Possession - F3
†$
Jamal Cammack
On or about September 21, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\REWDLQSRVVHVVRUXVHDFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJDQGWKH
drug involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQWKHDPRXQWRIWKHGUXJLQYROYHGH[FHHGVILYHJUDPVEXWLVOHVVWKDQWHQJUDPV
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 28
Defendants
Date of Offense
Having Weapons Under Disability - F3
†$
Allante Bush
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\DFTXLUHKDYHFDUU\RUXVHDQ\ILUHDUPRUGDQJHURXVRUGQDQFHDQGKHLVDIXJLWLYH
from justice.
)RUIHLWXUHRID:HDSRQZKLOHXQGHU'LVDELOLW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of Glock Semi Auto Pistol Serial Number
DZ101 and/or Sig Sauer Serial number 27A142854, which is contraband and/or property derived
from or through the commission or facilitation of an offense, and/or is an instrumentality the offender
(s) used or intended to use in the commission or facilitation of a felony offense.
)RUIHLWXUHRI3URSHUW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of Glock Semi Auto Pistol Serial Number
DZ101 and/or Sig Sauer Serial number 27A142854 which is contraband and/or property derived
from or through the commission or facilitation of an offense, and/or is an instrumentality the offender
(s) used or intended to use in the commission or facilitation of a felony offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 17 of 22
Cuyahoga County Court of Common Pleas
Count 29
Defendants
Date of Offense
A True Bill Indictment
Improperly Handling Firearms In A Motor Vehicle - F4
†%
Allante Bush
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly transport or have a loaded firearm in a motor vehicle in such a manner that the firearm
is accessible to the operator or any passenger without leaving the vehicle.
)RUIHLWXUHRID:HDSRQ†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of Glock Semi Auto Pistol Serial Number
DZ101, which is contraband and/or property derived from or through the commission or facilitation
of an offense, and/or is an instrumentality the offender(s) used or intended to use in the commission
or facilitation of a felony offense.
)RUIHLWXUHRI3URSHUW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of Glock Semi Auto Pistol Serial Number
DZ101 which is contraband and/or property derived from or through the commission or facilitation
of an offense, and/or is an instrumentality the offender(s) used or intended to use in the commission
or facilitation of a felony offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 18 of 22
Cuyahoga County Court of Common Pleas
Count 30
Defendants
Date of Offense
A True Bill Indictment
Improperly Handling Firearms In A Motor Vehicle - F4
†%
Allante Bush
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did knowingly transport or have a loaded firearm in a motor vehicle in such a manner that the firearm
is accessible to the operator or any passenger without leaving the vehicle.
)RUIHLWXUHRID:HDSRQ†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of Sig Sauer Serial number 27A142854,
which is contraband and/or property derived from or through the commission or facilitation of an
offense, and/or is an instrumentality the offender(s) used or intended to use in the commission or
facilitation of a felony offense.
)RUIHLWXUHRI3URSHUW\†$
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of Sig Sauer Serial number 27A142854
which is contraband and/or property derived from or through the commission or facilitation of an
offense, and/or is an instrumentality the offender(s) used or intended to use in the commission or
facilitation of a felony offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 31
Defendants
Date of Offense
Endangering Children - M1
†$
Allante Bush
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
being a parent, guardian, custodian, person having custody or control, or person in loco parentis of a
child under eighteen years of age, did recklessly create a substantial risk to the health or safety of
D.M. (DOB: 12/3/10), by violating a duty of care, protection, or support.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 19 of 22
Cuyahoga County Court of Common Pleas
Count 32
Defendants
Date of Offense
A True Bill Indictment
Endangering Children - M1
†$
Allante Bush
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
being a parent, guardian, custodian, person having custody or control, or person in loco parentis of a
child under eighteen years of age, did recklessly create a substantial risk to the health or safety of
C.S. (DOB: 3/25/08), by violating a duty of care, protection, or support.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 33
Defendants
Date of Offense
Endangering Children - M1
†$
Allante Bush
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
being a parent, guardian, custodian, person having custody or control, or person in loco parentis of a
child under eighteen years of age, did recklessly create a substantial risk to the health or safety of
Z.A. (DOB: 8/24/12), by violating a duty of care, protection, or support.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 34
Defendants
Date of Offense
Receiving stolen property - M1
†$
Allante Bush
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of Glock Semi Auto Pistol Serial Number DZ101, the property of
Willoughby Police Department, knowing or having reasonable cause to believe that the property had
been obtained through commission of a theft offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 20 of 22
Cuyahoga County Court of Common Pleas
Count 35
Defendants
Date of Offense
A True Bill Indictment
Receiving stolen property - M1
†$
Allante Bush
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did receive, retain, or dispose of Sig Sauer Serial number 27A142854, the property of Huron County
Sheriff's Office, knowing or having reasonable cause to believe that the property had been obtained
through commission of a theft offense.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 36
Defendants
Date of Offense
Resisting Arrest - M2
†$
Jamal Cammack
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did recklessly or by force, resist or interfere with a lawful arrest of himself or another.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 37
Defendants
Date of Offense
Possessing Criminal Tools - F5
†$
Jamal Cammack
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did possess or have under the person's control any substance, device, instrument, or article, to wit:
Digital Scale and/or U.S. Currency and/or Cell Phones and/or Suspected Crack Cocaine and/or
Suspected Heroin with purpose to use it criminally.
FURTHERMORE, the Digital Scale and/or U.S. Currency and/or Cell Phones and/or Suspected
Crack Cocaine and/or Suspected Heroin involved in the offense were intended for use in the
commission of a felony, to wit: 2905.03.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 21 of 22
Cuyahoga County Court of Common Pleas
Count 38
Defendants
Date of Offense
A True Bill Indictment
Drug Possession - F1
†$
Jamal Cammack
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
GLGNQRZLQJO\REWDLQSRVVHVVRUXVHDFRQWUROOHGVXEVWDQFHRUDFRQWUROOHGVXEVWDQFHDQDORJDQGWKH
drug involved in the violation is heroin or a compound, mixture, preparation, or substance containing
KHURLQDQGWKHDPRXQWRIWKHGUXJLQYROYHGHTXDOVRUH[FHHGVILIW\JUDPVEXWLVOHVVWKDQWZR
hundred fifty grams.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
Count 39
Defendants
Date of Offense
Possessing Criminal Tools - F5
†$
Jamal Cammack
On or about September 27, 2016
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully
did possess or have under the person's control any substance, device, instrument, or article, to wit:
Cell Phones and/or U.S. Currenncy and/or Digital Scales and/or Latex Gloves with purpose to use it
criminally.
FURTHERMORE, the Cell Phones and/or U.S. Currenncy and/or Digital Scales and/or Latex Gloves
involved in the offense were intended for use in the commission of a felony, to wit: 2925.03.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>
Foreperson of the Grand Jury
Prosecuting Attorney
Page 22 of 22