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Ii", ",'~ IE NAME AND B'," i"HE AUTHORITY OF THt: STATE OF FLORIDA
IN THE CIRCUIT COURT OF THE FIRST JUDICIAL CIRCUIT OF
THE STATE OF FLORIDA IN AND FOR ESCAMBIA COUNTY,
AT THE WINTER TERM HEREOF,
IN THE YEAR OF OUR LOAD,
ONE TjiOUSAND, NINE HUNDRED AND NINETY-FIVE

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INDICTMENT

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The Grand Jurors of the State of Florida. I$Wtlllly
selected. impaneled and sworn. inquiring in and for the body of tOe Co~nty of
Escambia upon their oaths as Grand Jurors. do present that on orab6ut '
January 1, 1990 and continuing through on or about December 21, 1994, at
and in the County of Escambia. State of Florida. JOE A. FLOWERS,
SR.. did wilfully and unlawfully perform his duties as Comptroller of Escambia
County by purchasing mortgage securities which he was not authorized by law
to purchase. said conduct being in violation of the common law. as adopted
by Section 775.01. Florida Statutes and punishable as provided in Section
775.02, Florida Statutes.

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TME CONDITION OF THE ORIGINAL DOCUMENTS IS REFLECTED IN THE 'MACE

AHD fS' NOT THE FAULT OF THE MlCROfI.MM

PROCESS.

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COUNT ONE:

COUNT TWO: The Grand Jurors of the State of Florida, lawfully selected,
impaneled and sworn, inquiring in and for thf' body of the County of Escambia
upon their oaths as Grand Jurors. do present that on or about January 1, 1990
and continuing through on or about March 1. 1995, JOE A. FLOWERS,
SA., did wilfully and unlawfully perform his duties as Comptroller of
Escambia County by holding monies in accounts on behalf of Escambia
County which were not open for bid to all qualified depositories in the county.
and by failing or refusing to accept the highest and best bid for deposit of said
monies, contrary to the requirements of Section 28.33, Florida Statutes, said
condu:r being in violation of the common law, as adopted by Section 175.01.
Florida Statutes and punishable as provided In Section 775.02, Florida
Statutes.

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The Grand Jurors of the State 01 Florida. lawfully
.sefected. impaneled and sworn, inquiring in and lor the body of the County of
Escambia upon their oaths as Grand Jurors. do present that on or about
August 1. 1994 and continuing through on or about December 5. 1994. at and
in the County 01Escambia. State of Florida, JOE A. FLOWERS,
SR.,
did wilfully and unlawfully perform his duties as COmptroller of Escambia
County by entering into "reverse repurchase agreements with several
brokerage firms whereby he "sold" securities in the name of Escambia COunty
and later "repurchased" the same S8CuritieSat a higher price, which he was not
authorized by law to agree to do, said conduct being in violation of the common
law, as adopted by Section 775.01. Florida Statutes and punishable as
provided in Section 775.02. Florida Statutes.

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cONDtTtqN Of THE ORIGINAL DOCUMENTS IS REFLECTED IN THE

. All) IS ..NOT THE , AULT Of THE MlCROfLMIIO PROCESS.

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Assistant State Attorney

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The undersigned Assistant State AHorney haa advised the Grand Jury
retumlng this Indictment as authorized ~~}and required by ..IIW. '.,
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Contrary to the Statutes in such cases made and provided against the peace
and dignity of the State of Florida.
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COUNT FOUR:

The Grand Jurors of the State of Florida. lawfully

selected. impaneled and sworn, inquiring in and for the body of the County of
Eacanbia upon their oaths as Grand Jurors. do present that on or about May
20, 1992 and continuing through on or about May 20, 1994, at and in the
County of Escambia, State of Florida, JOE A. FLOWERS,
SR.,dld
wilfully and unlawfully perform his duties as COmptroller of Escambia COunty
by entering into leasa-purchase agreements with Unisys Leasing Corporation,
to acquire computer and imaging systems, contrary to the requirements of
Section 125.031. Florida Statutes, said conduct being In violation of the
common law. as adopted by Section 775.01. Florida Statutes and punishable
as provided in Section 775.02. Florida Statutes.

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COUNT THREE:

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