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L O R C O J N T V CimO F C O J R T S C R I M
County Court of Common P l eas
C ri mi nal C ourt Di vi si on
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State of Ohi o,
Plai nti ff
VS.
James Buxge,
Defendant
A True Bi l l I ndi ctment
Falsification
2921.13(A )(7), 2921.13(F)(1)
11 A ddi ti onal Count(s)
Dates of O ffense (on or about)
01/ 25/ 2011 to 02/ 11/ 2013
T he T erm O f
Special Grand Jur>
C ase Number 3
The State of Ofuo, "| 2 : ^ ^
T ^ SS. > , 0
Lorain Counrv co o ^ ^
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C ount O ne Falsification - Ml
2921.13(A )(7), 2921.13(F)(1)
Defendants James Bulge
Date of O ffense On or about January 24, 2012
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T?K /urors 0/ tiieGrii?id/un/ o/t/u; State, of Ohio, imthin cmd for the body of the County aforesaid, on their oaths, INTHE NAME
AND BY THEAUTHOFSTY OF THESTATE OF OHI O, do find and present, that the above named Def^dant, on or about the
date of the offtme set forth above, in the County of Ohio Lorain, unl aiDful l y
di d knc^vingly make a false statement, or knowi ngl y swear or affi j m the truth of a false
statement previ ously made, when the statement was i a wri ti ng on or i a cormection w i th a
report or return that is requi red or authori zed by law.
The offense is contrary to the farmof the statute in such case made and provided, atid against the peace and dignity of the State of
Ohio.
C ount T w o Tamperi ng w i th Records - F3
2913.42(A )(1), 2913.42(B)(4)
Defendants James Burge
Date of O ffense On O r about Januar>^ 24, 2012
The grand jurors, on their oaths, further find that the Defendant(s), in the county aforesaid, unl awful l y
di d, knowi ng he had no pri vi lege to do so, and w i th purpose to defraud or knowi ng he was
faci li tati ng a fraud on The State of Ohi o falsify, destroy, remove, conceal, alter, deface, or
muti late any wri ti ng, computer software, data, or record, to w i t 2011 Ohi o Financial
. L O R C O J N T Y C L E R K O F C O J R T S C R I ^ ^ .
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Disclosure Statement and the v.Titing, data, computer softv\ 'are, or record was kept by or
belonged to a local, state, or federal governmental entity.
The offense is contrary tothe form of the statute in such case made and provided, and against th peace and dignity of the Slate of
Ohio.
C ount T hree
Sol i ci ti ng I mproper Compensation - M l
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2921,43(A)(1), 2921.43(D)
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Defendants
James Burge
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Date of O ffense
O n or about February 1, 2011 to June 7,2011
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Tne grand jurors, on iheir oaths, further find that th Defendaniis), in the county aforesaid, unln^^ly
di d whi l e being a public servant knowi ngl y sohcit or accept any comj^nSpi^onTother than
as allowed by divisions (G), (H), and (I) of section 102.03 of the Revised C&3e, to perform
the public servant's official duties, to perform any other act or service i n the pubhc servant's
public capacit}^ for the general performance of the duties of the public servant's public
office or public emplov*ment, or as a supplement to the public servant's public
compensation.
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.
C ount F our Havi ng an U nl awf ul I nterest i n a PubHc Contract - F4
2921.42(A)(1), 2921.42(E)
Defendants James Burge
Date of O ffense O n or about February 1, 2011 to June 7, 2011
The grand jurors, on their oaths, further find that the D^endani(s), in the county aforesaid, unlawfully
di d -while being a public official knowi ngl y authorize or employ the authori ty or irifluence
of his office to secure authorization of any public contract i n whi ch he, a member of his
fami l y, or any of his business associates had an interest,
The offense is contrary tothe form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.
F oreperson of theG rand 3ur> '
S peg^ rvS seojtlng Attomey
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C ount F ive
Fal si fi cati on - M l
2921,13(A)(7), 2921.13(F)(1)
Defendants James Burge
Date of O ffense Qn or about Januar}' 25, 2011
Thx grand jurors, on their oaths, further find that the Defmdant(s), in the count)/aforesaid, unlawfully
d i d knowi ngl y make a falsestatement, or knowi ngl y swear or affi rm thetruth of a false
statement previ ousl y mad e, when the statement was i n wri ti ng on or i n connection with a
report or return that is requi red or authori zed by la\ v.
The offenseis contrary to the form of the statute in such case madeand provided, and against the peaceand dignity of the State of
Ohio.
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C ount S ix Tamperi ng wi t h Record s - F3
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2913.42(A)(1), 2913.42(B)(4)
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Defendants
James Burge
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Date of O ffense O n or about January 25, 2011
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Tne grand jurors, on their oaths, further find that the Dqendant(s), in the county aforesaid, unlawfully
d i d , knowi ng he had no pri vi l ege to d o so, and w i th purpose to d efraud or knowi ng he was
faciiiLating a fraud on The Stateof O hi o fal si fy, d estroy, remove, conceal, alter, d eface, or
muti l ate any wri ti ng, computer software, d ata, or record , to w i t 2010 O hi o Financial
Disclosure Statement and thewri ti ng, d ata, computer softw^are, or record was kept by or
belonged to a local, state, or fed eral goverrmiental enti ty.
I The offenseis contrary to the form of the statute in such case madeand provided, and against the peaceand dignity of the State of
1 Ohio.
' / / horeperwn of the Grand J ury
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Defendant s
r , ' ni l CO J N l Y Cim O F CO J R T S CR i M _
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Soliciting Improper Compensation - Ml
2921.43(A)(1), 2921.43(D)
James Burge
Dat e of O ffense Qn or about February 1,2011 toJ une 7,2011
Tke gr and jur or s, on their oatks, fur ther find that ike Defsndani(5), in the ccimty afor esaid, unlawfully
d i d whi l e bei ng a publ i c servant kno^vi ngl y sol i ci t or accept any compensati on, oti i er than
as al l owed by d i vi si ons (G), (H), and (I) of secti on 102.03 of the Revi sed Cod e, to perform
the publ i c ser\ ^ant's offi ci al d uti es, to perform any otl i er act or servi ce i n the publ i c
servant's publ i c capaci ty, for the general performance of the d uti es of the pubHc servant's
publ i c offi ce or publ i c empl oyment, or as a suppl ement to the publ i c ser\ ^ant's publ i c
compensati on.
The ojjhise is contr ar y to the for m of the statute in such case madt md pr ovided, and against the peace and dignity of the State of
Ohio.
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Count Ei ght
Defendant s
Dat e of O ffense
Having an Unlawful Interest in a Public Contcftcl,- ^
James Burs-e S 3:
2921.42(A)(1), 2921.42(E)
O n or about February 1, 2011 to June 7, 2011
The gr and jur or s, on their oaths, fur ther find that the Defendant(s), in the county afor esaid, unhaufuUy
d i d whi l e bei ng a publ i c offi ci al knowi ngl y authori ze or empl oy the authori ty or
i nfl uence of hi s offi ce to secure authori zati on of any publ i c contract i n whi ch he,
a member of hi s fami l y, or any of hi s busi ness associ ates had an i nterest.
The offense is contr ar y to the for m of the statute in such case made end pr ovided, and against the peace and dignity of the State of
Ohio.
Count N i ne
Defendant s
Dat e of O ffense
Falsification - Ml
2921.13(A)(7), 2921.13(F)(1)
James Burge
O n or about February 11,2013
The gr and jur or s, on their oaths, fur ther find that the Defendant(s), in the county afor esaid, unlmufully
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d i d knowi ngl y make a false statement, or knowi ngl y swear or affi rm the truth of a false
statement previ ousl y mad e, when the statement was i n wri ti ng on or i n cormecti on w i th a
report or return that i s requi red or authori zed by l aw.
Vi offtnzt is contrary to thi formof the statute in such case made and prauide d, and against the pe ace and dignity of the State of
Ohio.
C ount T e n Tampering wi t h Records - F3
2913.42(A)(1), 2913.42(B)(4)
De fe ndants James Burge
Date of O ffe nse Qn Or about February 11, 2013
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Vie grand jurors, on Hie ir oaths, furthe r find that t}ie De fe ndant(s), in the county afore said, unlawfully
d i d , knowi ng he had no pri vi l ege to d o so, and wi th purpose to d ehaud or knowi ng he was
faci l i tati ng a fraud on The State of Ohi o fal si f)^d estroy, remove, conceal, alter, d eface, or
mutUate any wri ti ng, computer software, d ata, or record , to wi t; 2012 Ohi o Fi nanci al
Di scl osure Statement and the wri ti ng, d ata, computer software, or record was kept by or
bel onged to a l ocal , state, or fed eral governmental enti ty.
The offe nse is contrary to the formof t}ie statute in such case made and provide d, and agairist the pe ace and dignity of the Stale of
Ohio.
C ount E l e ve n Soliciting Improper Compensation - Ml
2921.43(A)(1), 2921.43(D)
De fe ndants James Burge
Date of O ffe nse On or about February 1, 2011 to June 7, 2011
The grand jurors, on tMr oaths, furthe r find that the De fe ndantis), in the county afore said, unlawfully
d i d whi l e bei ng a publ i c servant knowi ngl y sol i ci t or accept any compensati on, other than
as al l owed by d i vi si ons (G), (H), and (I) of secti on 102,03 of the Revi sed Cod e, to perform
the publ i c servant's offi ci al d uti es, to perform any other act or servi ce i n the publ i c
servant's publ i c capaci t}^ for the general performance of the d uti es of the publ i c servant's
publ i c offi ce or publ i c empl oyment, or as a suppl ement to the publ i c servant's publ i c
compensati on.
Tne offe nse is contrary to the fiyrmof the statute in such case made and provide d, and against the pe ace and dignity of the State of
Ohio.
F cfe pe rson of the Grand J ury
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C ount T welve Having an Unlawful Interest in a PubHc Contract -
292a.42(A)(l), 2921.42(E)
Defendants James Burge
Date of O ffense On or about February 1, 2011 to June 7, 2011
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Tne grand jurors, on their oaths, further find that the Deffndant(s), in the county aforesaid, unlawfully
d i d whi l e being a pubHc official knowi ngl y authorize or empl oy the authority or infl uence
of his office to secure authorization of any pubHc contract i n whi ch he, a member of his
fairul y, or any of his business associates had an interest.
Vne otfenie 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.
A ll against the peace and dignit)- of the State of Ohio.
Ia&iew7. Dpa^e 0079278^
Special Pj^cuting A ttorney