IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND

STATE OF MARYLAND

V. : CRIMINAL NUMBER:

CALEB THORPE

DEFENDANT

INDICTMENT

COUNT ONE: RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that CALEB THORPE, on or about October
31, 2018, in Montgomery County, Maryland, did commit a rape in the first degree on
Victim 1, in violation of Section 3-303 of the Criminal Law Article against the peace,
government, and dignity of the State.

COUNT TWO: CONSPIRACY - RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that CALEB THORPE, on or about October
31, 2018, in Montgomery County, Maryland, did conspire with Will Smith, Jean-Claude
Abedi Hen, and Kristian Jamal Lee to unlawfully commit a rape in the first degree upon
Victim 1, in violation of Common Law of Maryland against the peace, government, and
dignity of the State.

COUNT THREE: ATTEMPT - FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that CALEB THORPE, on or about October
31, 2018, in Montgomery County, Maryland, did unlawfully attempt to commit a rape in
the first degree upon Victim 2, in violation of Section 3-309 of the Criminal Law Article
against the peace, government, and dignity of the State.
COUNT FOUR: CONSPIRACY - RAPE FIRST DEGREE
The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that CALEB THORPE, on or about October
31, 2018, in Montgomery County, Maryland, did conspire with Will Smith, Jean-Claude
Abedi Hen, and Kristian Jamal Lee to unlawfully commit a rape in the first degree upon
Victim 2, in violation of Common Law of Maryland against the peace, government, and
dignity of the State.

COUNT FIVE: ATTEMPT-FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that CALEB THORPE, on or about October
31, 2018, in Montgomery County, Maryland, did unlawfully attempt to commit a rape in
the first degree upon Victim 3, in violation of Section 3-309 of the Criminal Law Article
against the peace, government, and dignity of the State.

COUNT SIX: CONSPIRACY - RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that CALEB THORPE, on or about October
31, 2018, in Montgomery County, Maryland, did conspire with Will Smith, Jean-Claude
Abedi Hen, and Kristian Jamal Lee to unlawfully commit a rape in the first degree upon
Victim 3, in violation of Common Law of Maryland against the peace, government, and
dignity of the State.

COUNT SEVEN: ATTEMPT-FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that CALEB THORPE, on or about October
31, 2018, in Montgomery County, Maryland, did unlawfully attempt to commit a rape in
the first degree upon Victim 4, in violation of Section 3-309 of the Criminal Law Article
against the peace, government, and dignity of the State.
COUNT EIGHT: CONSPIRACY - RAPE FIRST DEGREE
The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that CALEB THORPE, on or about October
31, 2018, in Montgomery County, Maryland, did conspire with Will Smith, Jean-Claude
Abedi Hen, and Kristian Jamal Lee to unlawfully commit a rape in the first degree upon
Victim 4, in violation of Common Law of Maryland against the peace, government, and
dignity of the State.

TRUE BILL
FOREPERSON OF THE GRAND JURY

STATE'S ATTORNEY FOR

MONTGOMERY COUNTY, MARYLAND

Upon the information of:

Investigator Ed Day
 ADDENDUM TO CHARGING DOCUMENT

TO THE PERSON CHARGED:

1. This paper charges you with committing a crime.

2. If you have been arrested and remain in custody, you have the right to have a
judicial officer decide whether you should be released from jail until your trial.

3. If you have been served with a citation or summons directing you to appear
before a judicial officer for a preliminary inquiry at a date and time designated or
within five days of service if no time is designated, a judicial officer will advise
you of your rights, the charges against you, and penalties. The preliminary
inquiry will be cancelled if a lawyer has entered an appearance to represent you.

4. You have the right to have a lawyer.

5. A lawyer can be helpful to you by:

A. explaining the charges in this paper;

B. telling you the possible penalties;
C. explaining any potential collateral consequences of a conviction, including
immigration consequences;
D. helping you at trial;
E. helping you protect your constitutional rights; and
F. helping you to get a fair penalty if convicted.

6. Even if you plan to plead guilty, a lawyer can be helpful.

7. If you are eligible, the Public Defender or a court-appointed attorney will

represent you at any initial appearance before a judicial officer and at any
proceeding under Rule 4-216.1 to review an order of a District Court
commissioner regarding pretrial release. If you want a lawyer for any further
proceeding, including trial, but do not have the money to hire one, the Public
Defender may provide a lawyer for you. The court clerk will tell you how to
contact the Public Defender.

8. If you want a lawyer but you cannot get one and the Public Defender will not
provide one for you, contact the court clerk as soon as possible.

9. DO NOT WAIT UNTIL THE DATE OF YOUR TRIAL TO GET A LAWYER. If you
do not have a lawyer before the trial date, you may have to go to trial without
one.

Rule 4-202, Maryland Rules of Procedure.

 IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND

STATE OF MARYLAND

v. : Criminal Number:

CALEB THORPE
24124 Newbury Road,
Gaithersburg, MD 20882

Defendant.

LINE
Madame Clerk:
The Original District Court criminal number is 6D00392370 and the tracking
number is 181001947232.
Please enter the appearance of Peter A. Feeney as the attorney for the State of
Maryland in the above-captioned case.

Defendant's Information:
Address: SAME AS ABOVE
Pers. Info.: Race: Black, African American, Sex: Male, DOB: 08/13/2003, Height: ,
Weight: Unk, Hair: Unk, Eyes: Unk
Respectfully submitted,

John J. McCarthy
State's Attorney for
Montgomery County, Maryland

By:
Peter A. Feeney
Assistant State's Attorney
50 Maryland Avenue
Rockville, MD 20850
(240) 777-7300

CERTIFICATION

I HEREBY CERTIFY, on this 26th day of November, 2018, a copy of the above
pleading was delivered to Caleb Thorpe, 24124 Newbury Road, Gaithersburg, MD
20882 and Shelley Brown, Esquire, 809 Baltimore Road, Rockville, MD 20851.

Peter A. Feeney
 IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND

STATE OF MARYLAND

V. : CRIMINAL NUMBER:

WILL DANIEL SMITH

DEFENDANT

INDICTMENT

COUNT ONE: RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that WILL DANIEL SMITH, on or about
October 31, 2018, in Montgomery County, Maryland, did commit a rape in the first
degree on Victim 1, in violation of Section 3-303 of the Criminal Law Article against the
peace, government, and dignity of the State.

COUNT TWO: CONSPIRACY - RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that WILL DANIEL SMITH, on or about
October 31, 2018, in Montgomery County, Maryland, did conspire with Caleb Thorpe,
Jean-Claude Abedi Hen, and Kristian Jamal Lee to unlawfully commit a rape in the first
degree upon Victim 1, in violation of Common Law of Maryland against the peace,
government, and dignity of the State.

COUNT THREE: ATTEMPT - FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that WILL DANIEL SMITH, on or about
October 31, 2018, in Montgomery County, Maryland, did unlawfully attempt to commit a
rape in the first degree upon Victim 2, in violation of Section 3-309 of the Criminal Law
Article against the peace, government, and dignity of the State.
COUNT FOUR: CONSPIRACY- RAPE FIRST DEGREE
The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that WILL DANIEL SMITH, on or about
October 31, 2018, in Montgomery County, Maryland, did conspire with Caleb Thorpe,
Jean-Claude Abedi Hen, and Kristian Jamal Lee to unlawfully commit a rape in the first
degree upon Victim 2, in violation of Common Law of Maryland against the peace,
government, and dignity of the State.

COUNT FIVE: ATTEMPT-FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that WILL DANIEL SMITH, on or about
October 31, 2018, in Montgomery County, Maryland, did unlawfully attempt to commit a
rape in the first degree upon Victim 3, in violation of Section 3-309 of the Criminal Law
Article against the peace, government, and dignity of the State.

COUNT SIX: CONSPIRACY - RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that WILL DANIEL SMITH, on or about
October 31, 2018, in Montgomery County, Maryland, did conspire with Caleb Thorpe,
Jean-Claude Abedi Hen, and Kristian Jamal Lee to unlawfully commit a rape in the first
degree upon Victim 3, in violation of Common Law of Maryland against the peace,
government, and dignity of the State.

COUNT SEVEN: ATTEMPT-FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that WILL DANIEL SMITH, on or about
October 31, 2018, in Montgomery County, Maryland, did unlawfully attempt to commit a
rape in the first degree upon Victim 4, in violation of Section 3-309 of the Criminal Law
Article against the peace, government, and dignity of the State.
COUNT EIGHT: CONSPIRACY - RAPE FIRST DEGREE
The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that WILL DANIEL SMITH, on or about
October 31, 2018, in Montgomery County, Maryland, did conspire with Caleb Thorpe,
Jean-Claude Abedi Hen, and Kristian Jamal Lee to unlawfully commit a rape in the first
degree upon Victim 4, in violation of Common Law of Maryland against the peace,
government, and dignity of the State.

TRUE BILL
FOREPERSON OF THE GRAND JURY

STATE'S ATTORNEY FOR

MONTGOMERY COUNTY, MARYLAND

Upon the information of:

Investigator Ed Day
 ADDENDUM TO CHARGING DOCUMENT

TO THE PERSON CHARGED:

1. This paper charges you with committing a crime.

2. If you have been arrested and remain in custody, you have the right to have a
judicial officer decide whether you should be released from jail until your trial.

3. If you have been served with a citation or summons directing you to appear
before a judicial officer for a preliminary inquiry at a date and time designated or
within five days of service if no time is designated, a judicial officer will advise
you of your rights, the charges against you, and penalties. The preliminary
inquiry will be cancelled if a lawyer has entered an appearance to represent you.

4. You have the right to have a lawyer.

5. A lawyer can be helpful to you by:

A. explaining the charges in this paper;

B. telling you the possible penalties;
C. explaining any potential collateral consequences of a conviction, including
immigration consequences;
D. helping you at trial;
E. helping you protect your constitutional rights; and
F. helping you to get a fair penalty if convicted.

6. Even if you plan to plead guilty, a lawyer can be helpful.

7. If you are eligible, the Public Defender or a court-appointed attorney will

represent you at any initial appearance before a judicial officer and at any
proceeding under Rule 4-216.1 to review an order of a District Court
commissioner regarding pretrial release. If you want a lawyer for any further
proceeding, including trial, but do not have the money to hire one, the Public
Defender may provide a lawyer for you. The court clerk will tell you how to
contact the Public Defender.

8. If you want a lawyer but you cannot get one and the Public Defender will not
provide one for you, contact the court clerk as soon as possible.

9. DO NOT WAIT UNTIL THE DATE OF YOUR TRIAL TO GET A LAWYER. If you
do not have a lawyer before the trial date, you may have to go to trial without
one.

Rule 4-202, Maryland Rules of Procedure.

 IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND

STATE OF MARYLAND

v. : Criminal Number:

WILL DANIEL SMITH

23455 Arora Hills Drive,
Clarksburg, MD 20871

Defendant.

LINE
Madame Clerk:
The Original District Court criminal number is 1D00392372 and the tracking
number is 181001947254.
Please enter the appearance of Peter A. Feeney as the attorney for the State of
Maryland in the above-captioned case.

Defendant's Information:
Address: SAME AS ABOVE
Pers. Info.: Race: Black, African American, Sex: Male, DOB: 07/02/2003, Height: ,
Weight: Unk, Hair: Unk, Eyes: Unk
Respectfully submitted,

John J. McCarthy
State's Attorney for
Montgomery County, Maryland

By:
Peter A. Feeney
Assistant State's Attorney
50 Maryland Avenue
Rockville, MD 20850
(240) 777-7300

CERTIFICATION

I HEREBY CERTIFY, on this 26th day of November, 2018, a copy of the above
pleading was delivered to David Felsen, Esquire, 600 Jefferson Plaza, #201, Rockville,
MD 20852.

Peter A. Feeney
 IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND

STATE OF MARYLAND

V. : CRIMINAL NUMBER:

KRISTIAN JAMAL LEE

DEFENDANT

INDICTMENT

COUNT ONE: RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that KRISTIAN JAMAL LEE, on or about
October 31, 2018, in Montgomery County, Maryland, did commit a rape in the first
degree on Victim 1, in violation of Section 3-303 of the Criminal Law Article against the
peace, government, and dignity of the State.

COUNT TWO: CONSPIRACY - RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that KRISTIAN JAMAL LEE, on or about
October 31, 2018, in Montgomery County, Maryland, did conspire with Will Smith, Jean-
Claude Abedi Hen, and Caleb Thorpe to unlawfully commit a rape in the first degree
upon Victim 1, in violation of Common Law of Maryland against the peace, government,
and dignity of the State.

COUNT THREE: ATTEMPT - FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that KRISTIAN JAMAL LEE, on or about
October 31, 2018, in Montgomery County, Maryland, did unlawfully attempt to commit a
rape in the first degree upon Victim 2, in violation of Section 3-309 of the Criminal Law
Article against the peace, government, and dignity of the State.
COUNT FOUR: CONSPIRACY - RAPE FIRST DEGREE
The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that KRISTIAN JAMAL LEE, on or about
October 31, 2018, in Montgomery County, Maryland, did conspire with Will Smith, Jean-
Claude Abedi Hen, and Caleb Thorpe to unlawfully commit a rape in the first degree
upon Victim 2, in violation of Common Law of Maryland against the peace, government,
and dignity of the State.

COUNT FIVE: ATTEMPT-FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that KRISTIAN JAMAL LEE, on or about
October 31, 2018, in Montgomery County, Maryland, did unlawfully attempt to commit a
rape in the first degree upon Victim 3, in violation of Section 3-309 of the Criminal Law
Article against the peace, government, and dignity of the State.

COUNT SIX: CONSPIRACY - RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that KRISTIAN JAMAL LEE, on or about
October 31, 2018, in Montgomery County, Maryland, did conspire with Will Smith, Jean-
Claude Abedi Hen, and Caleb Thorpe to unlawfully commit a rape in the first degree
upon Victim 3, in violation of Common Law of Maryland against the peace, government,
and dignity of the State.

COUNT SEVEN: ATTEMPT-FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that KRISTIAN JAMAL LEE, on or about
October 31, 2018, in Montgomery County, Maryland, did unlawfully attempt to commit a
rape in the first degree upon Victim 4, in violation of Section 3-309 of the Criminal Law
Article against the peace, government, and dignity of the State.
COUNT EIGHT: CONSPIRACY - RAPE FIRST DEGREE
The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that KRISTIAN JAMAL LEE, on or about
October 31, 2018, in Montgomery County, Maryland, did conspire with Will Smith, Jean-
Claude Abedi Hen, and Caleb Thorpe to unlawfully commit a rape in the first degree
upon Victim 4, in violation of Common Law of Maryland against the peace, government,
and dignity of the State.

TRUE BILL
FOREPERSON OF THE GRAND JURY

STATE'S ATTORNEY FOR

MONTGOMERY COUNTY, MARYLAND

Upon the information of:

Special Investigator Ed Day
 ADDENDUM TO CHARGING DOCUMENT

TO THE PERSON CHARGED:

1. This paper charges you with committing a crime.

2. If you have been arrested and remain in custody, you have the right to have a
judicial officer decide whether you should be released from jail until your trial.

3. If you have been served with a citation or summons directing you to appear
before a judicial officer for a preliminary inquiry at a date and time designated or
within five days of service if no time is designated, a judicial officer will advise
you of your rights, the charges against you, and penalties. The preliminary
inquiry will be cancelled if a lawyer has entered an appearance to represent you.

4. You have the right to have a lawyer.

5. A lawyer can be helpful to you by:

A. explaining the charges in this paper;

B. telling you the possible penalties;
C. explaining any potential collateral consequences of a conviction, including
immigration consequences;
D. helping you at trial;
E. helping you protect your constitutional rights; and
F. helping you to get a fair penalty if convicted.

6. Even if you plan to plead guilty, a lawyer can be helpful.

7. If you are eligible, the Public Defender or a court-appointed attorney will

represent you at any initial appearance before a judicial officer and at any
proceeding under Rule 4-216.1 to review an order of a District Court
commissioner regarding pretrial release. If you want a lawyer for any further
proceeding, including trial, but do not have the money to hire one, the Public
Defender may provide a lawyer for you. The court clerk will tell you how to
contact the Public Defender.

8. If you want a lawyer but you cannot get one and the Public Defender will not
provide one for you, contact the court clerk as soon as possible.

9. DO NOT WAIT UNTIL THE DATE OF YOUR TRIAL TO GET A LAWYER. If you
do not have a lawyer before the trial date, you may have to go to trial without
one.

Rule 4-202, Maryland Rules of Procedure.

 IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND

STATE OF MARYLAND

v. : Criminal Number:

KRISTIAN JAMAL LEE

12540 Great Park Circle, Apt 102,
Germantown, MD 20876

Defendant.

LINE
Madame Clerk:
The Original District Court criminal number is 2D00392373 and the tracking
number is 181001947265.
Please enter the appearance of Peter A. Feeney as the attorney for the State of
Maryland in the above-captioned case.

Defendant's Information:
Address: SAME AS ABOVE
Pers. Info.: Race: Black, African American, Sex: Male, DOB: 09/16/2003, Height: ,
Weight: Unk, Hair: Unk, Eyes: Unk
Respectfully submitted,

John J. McCarthy
State's Attorney for
Montgomery County, Maryland

By:
Peter A. Feeney
Deputy State's Attorney
50 Maryland Avenue
Rockville, MD 20850
(240) 777-7300

CERTIFICATION

I HEREBY CERTIFY, on this 26th day of November, 2018, a copy of the above
pleading was delivered to Kristian Jamal Lee, 12540 Great Park Circle, Apt 102,
Germantown, MD 20876.

Peter A. Feeney
 IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND

STATE OF MARYLAND

V. : CRIMINAL NUMBER:

JEAN CLAUDE ABED! HERI

DEFENDANT

INDICTMENT

COUNT ONE: RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that JEAN CLAUDE ABEDI HERI, on or
about October 31, 2018, in Montgomery County, Maryland, did commit a rape in the first
degree on Victim 1, in violation of Section 3-303 of the Criminal Law Article against the
peace, government, and dignity of the State.

COUNT TWO: CONSPIRACY - RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that JEAN CLAUDE ABEDI HERI, on or
about October 31, 2018, in Montgomery County, Maryland, did conspire with Will Smith,
Kristian Jamal Lee, and Caleb Thorpe to unlawfully commit a rape in the first degree
upon Victim 1, in violation of Common Law of Maryland against the peace, government,
and dignity of the State.

COUNT THREE: ATTEMPT - FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that JEAN CLAUDE ABEDI HERI, on or
about October 31, 2018, in Montgomery County, Maryland, did unlawfully attempt to
commit a rape in the first degree upon Victim 2, in violation of Section 3-309 of the
Criminal Law Article against the peace, government, and dignity of the State.
COUNT FOUR: CONSPIRACY - RAPE FIRST DEGREE
The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that JEAN CLAUDE ABEDI HERI, on or
about October 31, 2018, in Montgomery County, Maryland, did conspire with Will Smith,
Kristian Jamal Lee, and Caleb Thorpe to unlawfully commit a rape in the first degree
upon Victim 2, in violation of Common Law of Maryland against the peace, government,
and dignity of the State.

COUNT FIVE: ATTEMPT-FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that JEAN CLAUDE ABEDI HERI, on or
about October 31, 2018, in Montgomery County, Maryland, did unlawfully attempt to
commit a rape in the first degree upon Victim 3, in violation of Section 3-309 of the
Criminal Law Article against the peace, government, and dignity of the State.

COUNT SIX: CONSPIRACY - RAPE FIRST DEGREE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that JEAN CLAUDE ABED! HERI, on or
about October 31, 2018, in Montgomery County, Maryland, did conspire with Will Smith,
Kristian Jamal Lee, and Caleb Thorpe to unlawfully commit a rape in the first degree
upon Victim 3, in violation of Common Law of Maryland against the peace, government,
and dignity of the State.

COUNT SEVEN: ATTEMPT-FIRST DEGREE RAPE

The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that JEAN CLAUDE ABED! HERI, on or
about October 31, 2018, in Montgomery County, Maryland, did unlawfully attempt to
commit a rape in the first degree upon Victim 4, in violation of Section 3-309 of the
Criminal Law Article against the peace, government, and dignity of the State.
COUNT EIGHT: CONSPIRACY - RAPE FIRST DEGREE
The Grand Jurors of the State of Maryland, for the body of Montgomery County,
upon their oaths and affirmations, present that JEAN CLAUDE ABEDI HERI, on or
about October 31, 2018, in Montgomery County, Maryland, did conspire with Will Smith,
Kristian Jamal Lee, and Caleb Thorpe to unlawfully commit a rape in the first degree
upon Victim 4, in violation of Common Law of Maryland against the peace, government,
and dignity of the State.

TRUE BILL
FOREPERSON OF THE GRAND JURY

STATE'S ATTORNEY FOR

MONTGOMERY COUNTY, MARYLAND

Upon the information of:

Special Investigator Ed Day
 ADDENDUM TO CHARGING DOCUMENT

TO THE PERSON CHARGED:

1. This paper charges you with committing a crime.

2. If you have been arrested and remain in custody, you have the right to have a
judicial officer decide whether you should be released from jail until your trial.

3. If you have been served with a citation or summons directing you to appear
before a judicial officer for a preliminary inquiry at a date and time designated or
within five days of service if no time is designated, a judicial officer will advise
you of your rights, the charges against you, and penalties. The preliminary
inquiry will be cancelled if a lawyer has entered an appearance to represent you.

4. You have the right to have a lawyer.

5. A lawyer can be helpful to you by:

A. explaining the charges in this paper;

B. telling you the possible penalties;
C. explaining any potential collateral consequences of a conviction, including
immigration consequences;
D. helping you at trial;
E. helping you protect your constitutional rights; and
F. helping you to get a fair penalty if convicted.

6. Even if you plan to plead guilty, a lawyer can be helpful.

7. If you are eligible, the Public Defender or a court-appointed attorney will

represent you at any initial appearance before a judicial officer and at any
proceeding under Rule 4-216.1 to review an order of a District Court
commissioner regarding pretrial release. If you want a lawyer for any further
proceeding, including trial, but do not have the money to hire one, the Public
Defender may provide a lawyer for you. The court clerk will tell you how to
contact the Public Defender.

8. If you want a lawyer but you cannot get one and the Public Defender will not
provide one for you, contact the court clerk as soon as possible.

9. DO NOT WAIT UNTIL THE DATE OF YOUR TRIAL TO GET A LAWYER. If you
do not have a lawyer before the trial date, you may have to go to trial without
one.

Rule 4-202, Maryland Rules of Procedure.

 IN THE CIRCUIT COURT FOR MONTGOMERY COUNTY, MARYLAND

STATE OF MARYLAND

v. : Criminal Number:

JEAN CLAUDE ABEDI HERI

23119 ARORA HILLS DRIVE,
CLARKSBURG, MD 208710000

Defendant.

LINE
Madame Clerk:
The Original District Court criminal number is 0D00392371 and the tracking
number is 181001947243.
Please enter the appearance of Peter A. Feeney as the attorney for the State of
Maryland in the above-captioned case.

Defendant's Information:
Address: SAME AS ABOVE
Pers. Info.: Race: Black, African American, Sex: Male, DOB: 06/25/2003, Height:
601, Weight: 242, Hair: Black, Eyes: Unknown
Respectfully submitted,

John J. McCarthy
State's Attorney for
Montgomery County, Maryland

By:
Peter A. Feeney
Assistant State's Attorney
50 Maryland Avenue
Rockville, MD 20850
(240) 777-7300

CERTIFICATION

I HEREBY CERTIFY, on this 26th day of November, 2018, a copy of the above
pleading was delivered to Jean Claude Abedi Hen, 23119 Arora Hills Drive, Clarksburg,
MD 20871 and Daniel Wright, Esquire, 20 Courthouse Square, #212, Rockville, MD
20850.

Peter A. Feeney