Professional Documents
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ncvs/JX>S3
CITY OF GREENSBORO
Plaintiff,
VERIFIED COMPLAINT
vs.
NOW COMES the Plaintiff, pursuant to Chapter 19 ofthe North Carolina General Statutes,
more particularly, North Carolina General Statutes 19-2.1 and 19-2.2, and complaining ofthe
Defendant, alleges and says:
1.
The Plaintiff isthe State ofNorth Carolina on relation ofthe City ofGreensboro,
abody politic and corporate, organized and existing under the laws ofthe State ofNorth
Carolina and is specifically empowered pursuant to provisions ofNorth Carolina General
Statute 19-2.1 to bring this action.
2.
The subject real property ofthis action is located within Guilford County, North
Carolina.
3.
Defendant Khan and Khan, Inc., is acorporation organized and existing under the laws
ofthe State ofNorth Carolina with its principal office and place ofbusiness located in Guilford
County, North Carolina.
4.
Khan and Khan, Inc., owns the property housing the business known as the Greensboro
Inn, located at 135 Summit Avenue, Greensboro, Guilford County, North Carolina (hereinafter
the Property). The Property is further described in the Deed duly recorded in Deed Book 3508, Page 1592, in the Office ofthe Guilford County Register of Deeds, acopy ofwhich is attached
hereto and incorporated herein by reference asExhibit A.
5.
The Property described hereinabove, now and for some considerable period oftime prior
to the filing ofthis Complaint, has been established, continued, maintained, owned, and used by
Khan and Khan, Inc., as aplace for the purpose ofprostitution and the illegal possession and
sale ofcontrolled substances as defined in theNorth Carolina Controlled Substance Act.
6.
The Property described hereinabove now, and for some considerable period oftime prior
to the filing ofthis Complaint, has been established, continued, maintained, owned, and used by
Khan and Khan, Inc., as aplace wherein and whereon are carried on, conducted, or permitted,
repeated acts which create and constitute abreach ofthe peace, including but not limited to
armed robberies, assaults on females, assaults inflicting serious injury, aggravated assault, and
communicating threats.
7.
During Defendant's ownership ofthe Property, law enforcement authorities have made
at least fourteen drug charges against individuals upon the Property and have seized heroin,
cocaine, and marijuana from such individuals.
8.
Prior to filing this action, Defendant Khan and Khan, Inc., received written notice from
the Plaintiffthat a nuisance existed or was maintained on the Property. Acopy ofthe written notice isattached hereto and incorporated herein by reference asExhibit B.
9.
Police Officers K.D. Bennett, J.D. Brown, C.H. Peeden, Greensboro Police Sergeants A.H.
Hollis and J.E. Armstrong, and Greensboro Police Captain D.W. Scott have signed affidavits
containing information and describing factual circumstances and occurrences which support the
Plaintiffs cause of action. The affidavits are attached hereto and incorporated herein by
reference asfollows: the Affidavit ofOfficer K.D. Bennett is Exhibit C\ the Affidavit of Officer
J.D. Brown isExhibit D; the Affidavit of Officer C.H. Peeden isExhibit E\ the Affidavit of
Sergeant A.H. Hollis is Exhibit F; the Affidavit of Sergeant J.E. Armstrong is Exhibit G; and the
Affidavit of CaptainD.W. Scott is Exhibit H.
10.
ownership ofthe Property, various persons have admitted to or have been found guilty of
engaging in nuisance related criminal activity upon the Property, including the following:
(a)
(b) (c)
(d)
(e)
Natasha Ricker
Possession of Marijuana
Possession of cocaine with intent to
sell and deliver
D'Angelo Jackson
(f)
(g)
D'Angelo Jackson
Jeremiah Morehead
Communicating threats
(h) (0 0)
Kelvin McKinney
Darrell Sisk
Trespassing
Possession of Marijuana
Assault on a female
Natasha Ricker
CO
Mark Dockery
False imprisonment
Carla Alston
(1)
(m) (n)
Vincent Paige
Adrienne Jones
(o)
Adrienne Jones
Adrienne Jones
Possession of cocaine
Possession of cocaine
(P) (q)
(r)
Jameson Oliver
Karen D. Hall
(s)
(t) (u)
James R. Jones
Possession of cocaine
Malik Curry
(v)
Charlene Simpson
Possession ofcocaine
(w)
11.
John L. Stevenson
The Property has a general reputation among citizens within the community and among
the law enforcement community as a public nuisance, as the term is defined pursuant to North
Carolina General Statute 19-1, etseq., and as a place where numerous unlawful activities have
taken place and where police services are repeatedly needed.
12.
citizens have signed affidavits containing information and describing factual circumstances and occurrences which support the Plaintiff's cause ofaction. The affidavits are attached hereto and
incorporated herein by reference as follows: the Affidavit ofMs. Shelley Weidler is Exhibit I;
the Affidavit of Mr. Frank Burton is Exhibit J; the Affidavit of Mr. Ron Estes is Exhibit K; the
Affidavit ofMs. Holly Anderson is Exhibit L; the Affidavit of Mr. Richard Gantt isExhibit M;
and the Affidavit of Mr. Richard Levy is Exhibit N.
13.
The Property has been operated in such a manner as to make said place indecent,
disgraceful, and intolerable for the residents living nearby, and the general public traveling the
public streets adjacent to said premises, either as pedestrians or in motor vehicles, and unless
said nuisance isabated; these citizens will besubjected to theintolerable and dangerous
conditions and illegal activity existing upon said Property.
14.
The Defendant knew, orby the exercise ofdue diligence, should have known ofthe acts
or conduct complained of in the Plaintiffs cause ofaction have occurred on the Property for a
considerable period oftime before and up to the filing ofthis Complaint.
15. The Plaintiff isinformed, believes and therefore alleges that the real estate and
improvements thereon, and other personal property ofthe Defendant which may be found in and
around said Property, constitutes ageneral nuisance, and in the interest ofpublic morals and the
health and safety ofthe community, and in the interest ofpublic decency, should be condemned
and abated as provided byN.C. Gen. Stat. 19-2.1.
16.
That as demonstrated from the attached Affidavits, and the allegations contained herein,
there is reasonable apprehension ofimmediate and irreparable injury, loss, or damage that will
result before notice can be served and a hearing held on the Plaintiffs application for a
Temporary Restraining Order, in that upon information and belief, the public safety and public
morals ofthe community will continue to be irreparably disturbed by the existence ofthe
nuisance maintained on Defendant's premises; and that removal ofpersonal property and
contents ofthe place where the nuisance is alleged to exist will defeat the right ofthe Plaintiff
and the local government to the said property as provided in North Carolina General Statute
19-6. The Plaintifftherefore, is entitled to the issuance ofaTemporary Restraining Order,
without notice, pursuant to the provisions ofNorth Carolina General Statute 19-2.3 and 1A-1,
Rule 65(b), ofthe North Carolina Rules ofCivil Procedure, pending ahearing on Plaintiffs
application for apreliminary injunction, and until further orders ofthe Court; and for an Order
instructing the officer serving the prayed for Temporary Restraining Order to enter the Property
and forthwith make and return into the Court an inventory ofthe personal property and contents
situated inand used in conducting or maintaining the nuisance.
North Carolina General Statutes 19-2.3 and 1A-1, Rule 65(b), ofthe North Carolina Rules of
Civil Procedure, preserving the status quo and restraining the Defendant and all other persons
from:
(A)
(B)
Engaging in or allowing any other person to engage in any act upon the
Property which violates the laws ofthe state or local government.
2.
Issue an Order instructing the officer serving the prayed for Temporary Restraining
Order, to forthwith enter the Property and make and return into the Court an inventory ofthe
personal property, monies, and contents situated in and used in conducting or maintaining the
nuisance.
3.
Issue an order preliminarily enjoining the Defendant, its servants, agents or lessees,
from operation ofthe nuisance complained of, to the extent that said business shall be closed as
authorized by General Statute 19-2.5 pending trial in this case.
4. Allow ajury totry the issues of this action.
5.
6.
Issue an Order perpetually enjoining the Defendant and any other person or entity
Issue an Order perpetually enjoining the Defendant from operating or
from operating or maintaining apublic nuisance upon the Property described hereinabove.
maintaining apublic nuisance elsewhere within the jurisdiction ofthe State ofNorth Carolina.
7. Issue an order of forfeiture ofall personal property, monies, contents and other
considerations used in conducting and maintaining said nuisance as provided by North Carolina
General Statute 19-6,19-1.3,19-l(c), and any other section ofChapter 19, Article 1, ofthe
North Carolina General Statutes.
8.
Issue an Order of Forfeiture vesting title ofthe Property in the Guilford County
9.
been taken in as gross income from such unlawful commercial activity, to be forfeited to the
general funds ofthe Greensboro City and Guilford County governments as fruits ofan unlawful
enterprise, and for such other damages allowed under N.C. General Statute 19-6.
10. Tax against the Defendant the costs ofthis action as provided in North
Carolina General Statute 19-6 and 19-8, such costs to include, but not be limited to,
reasonable attorney's fees, court costs, and other costs for the investigation and prosecution of
this proceeding, and that such costs be declared alien on the real and personal property used in
maintaining the nuisance.
11.
and equitable.
Allow the Plaintiff such other and further relief as the Court deems just, proper
By:
James A. Clark N.C. State Bar No. 26558 Associate General Counsel
Greensboro, North Carolina 27402-3136 Telephone: (336) 373-2320 Facsimile: (336) 373-2078
E-mail: iim.clark@greensboro-nc.gov
VERIFICATION
Kenneth C. Miller, being duly sworn, deposed and says, that he is employed as the Chief
ofPolice ofthe City ofGreensboro, North Carolina, the Relator in this action, and as such he is
duly authorized to verify the foregoing Complaint; that he knows the contents thereof; that as to
those allegations to which he has personal knowledge, he knows that such allegations are true; that as to those allegations made upon information and beliefor which are based on the
knowledge and information ofother officers, agents or employees ofthe City ofGreensboro or
the State ofNorth Carolina, he believes them to be true.
(Official Seal)
^davof/W/W1^ .2011.
Mn,
Notary Public
************
JENNIFER G. SMITH-SUTPHIN
NOTARY PUBLIC
GUILFORD COUNTY.. NC
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i j The property herelnobove described was acquired by Grantor by instrument recorded i.. In
TO HAVE AND TO HOLD the aforesaid lot or parcel of land and all privilege, and appurtenance, thereto belonging to
the Grantee in fee simple.
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the same in fee simple, that title i. marketable snd free and clear of tiVenf^^^^SSSS^tA
And the Grantor covenant, with the Grantee that Orantorto s.i.edI of the1J^^ ^^^SjJy^^.'S
defend the title against tb. lawful described all subject to the following exeept-ons. claims of is person. *"**l^?et*Ua' htnitt*Wr Title to the property hereinabove
tt&fc s-.ass^sSi^2c-? gffl2 Public Registry, in Book 3346 at Page 841 of the Guilford County, North Carolina puoiirsistry
Se oalance upon slid indebtedness to be paid by the Grantees herein as apart
Grantors hereby transfer unto Grantees all their right title and interest
in and to that certain escrow account maintained by First Federal savings and Loan Association (of Raleigh, North Carolina).
of the consideration for this conveyance.
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BEGINNING at an iron pin at the intersection the southern margin of E. Lihasay Avenue, (formerly Bishop street) with the northwestern margin of Summit 58 min. West along the "^thwesteF" running thence South 31 deg. Avenue <f^iL the northwlstern margin of Summit Avenue (formerly Church Street) 106.77 feet to an
pipe; thence North 31 deg. 17 min. East 74.84 feet to an -on
EhSnce North 28 deg. 43 min. East 58.78 feet to an iron pipe in the southern margin of E. Lindsay Avenue (formerly Bishop Street); thence South 62 deg. 51 min. East along ^e southern^margin of E. Lindsay Avenue (formerly Dishop Street) 49.90 feet to an iron pipe; thence South 28 deg. 50 min. West 53.87 feet to an iron Street); thence South 62 deg. 51 min. East along the sth,|rn ?otte point of BEGINNING. And being the property conveyed to the
mawin of E. Lindsay Avenue (formerly Bishop Street) "9.75 tee
pip thence South 68 del. 31 min. East 2.46 feet to an iron pipe;
KpT> tnlncl North 28 del. E.50 Lindsay ^enue formerly an iron pipe min. East 50.97 feet to Bishop inPtne southern margin of
exceot that parcel conveyed to the City of Greensboro for a street ISent re^ed in Boole 3452 at Page "4, reference^ which is herewith made, all said documents being recorded in the Guiltora
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City of Greensboro
North Carolina
Januarv'27,2011
Greensboro, NC 27401
Greensboro, NC 27401
Dear Mr. Kahn,
Records at the North Carolina Secretary of State indicate that you are the President and Registered Agent ofthe
a motel currently occupies said property.
property looted at 135 Summit Ave., Greensboro, North Carolina. The Greensboro Inn winch ,s bemg operated as
S ofthe peace, including fights, assaults, and violations of the North Carolina Controlled Subsfcnee Act.
Citizens in the community have repeatedly complained to law enforcement authorit.es about such act.vtt.es
occurring atThe Greensboro Inn.
Ge ooTnn. Reported unlawful activities on the property include repeated acts which create and consu ute a
Chapter 19 ofthe North Carolina General Statutes defines apublic nuisance and gives the district attorneys attorney aeneral ocal <>overnmen., or aprivate citizen the right to seek court action to abate or stop anuisance. Possible
property, civil fines, accounting, liens and invalidation of leases.
Dunne the past several years, the Greensboro Police Department has responded to anumber ofcalls at The
SSde forfeiture ofproperty, court ordered closure ofproperty, permanent restrictions on the use of
Article 1, ofthe North Carolina General Statutes.
This letter is notice to you ofyour property being used in amaimer that could be illegal pursuant to Chapter 19,
The ilWal activities occurring at The Greensboro Inn must be eliminated before they become worse and endanger
PO
OFFICER K.D. BENNETT, appearing before the undersigned notary and being duly sworn
(or affirmed), says that:
1. I am not a party in this matter.
2.
Department, and have been so employed for more than five years. 3. For the last three years I have been assigned to the Vice Narcotics Unit ofthe
4.
5.
I have during the past several years visited the Property, visited the community
around the Property, and have had personal contact with citizens in and around the community
where the Property is located.
6.
Based upon my personal contacts in the community where the Property is located
I have come to know the general reputation ofthe Property and the general reputation ofpersons
who frequent the Property.
7.
The Property currently, and has for aconsiderable period oftime, maintained a
(A)
EXH&n
C
(B)
8.
9.
I have observed prostitutes, drug dealers, and drug users on the Property.
10.
Antoine McKenzie on the Property for possession of astolen firearm, possession ofa firearm by
paraphernalia. At the time ofhis arrest, McKenzie lived at the Greensboro Inn. In November
2008, McKenzie was arrested and charged with murder for killing aperson at abusiness near the
Greensboro Inn.
11.
I know in December 2007, Greensboro Police officers arrested Malik Curry on the
Property for possession of cocaine with intent to sell and deliver and possession ofmarijuana
with intent to sell and deliver. Curry was later convicted of those charges.' In February 2008,
Curry was arrested and charged with murder for ahomicide which occurred on October 28,2007.
12. I have checked or otherwise caused to be checked, final criminal conviction
records maintained by the Guilford County Clerk of Superior Court's Office of persons arrested for
violations of nuisance related criminal laws upon the Property. The names and criminal convictions
ofsuch persons are attached to this affidavit and include but are not limited to the information listed
(see attachments 12-1).
13.
Based upon reports from officers who have responded to calls at the Property, my
training, and reports from citizens inthe community, I feel it is not safe for any law enforcement officer to respond to a call for service at the Property without exposure to inordinate and undue
danger.
14.
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Day of /A/&M&*
(Official Seal)
Notary Public ^
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ATTACHMENTS-12-1
AME
OFFENSE
DATE OF
OFFENSE
DATE OF CONVICTION
September 13,2011
regory D. Manning
Robert J. Carico
Natasha Ricker
Michael D. Patton
February^ 2011
June 1,2011
March 23,2010 April 26,2010
October 26,2010
MayJ6,2011
January 1,2010
March 5, 2010
Possession of marijuana
D'Angelo L. Jackson
i
I
1 Communicating Threats
Possession of drug paraphernalia
October 27,2010
December 1,2010
July 22,1010 _
September5, 2010 January 19, 2009
i
Kelvin B. McKinney
Darrell L Sisk Natasha Ricker
..JunejUL2009
I
! 1
Mark Dockery
False imprisonment
Carta Alston
January 8, 2008
May 2,2007
Q01I-0W1-3U3
400 GUILFORD
ICA INQUIRY 51
11CRS066995
GR FILM:
DISPOSED
INDICTMENT
R
B
T. APTS.
S DOB/AGE
CRS
FILING DATE:
041911
LOUISBURG
NC
27549
TYP: P
VRA:
90-95(A)
CPD ISSUED: 012611
MOTIONS DATE: RSONCO:
WCC REST
SERVED: 012611
TO-BE-PAID
GU
GU
JU
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90-95(A)
51
ACCD:
HWY:
LIC:
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
041811
NEXTtt:
ADDL CHARGES: Y
20)[-0^5-XQP[
400 GUILFORD DISPOSED INDICTMENT ICA INQUIRY 53 11CRS067828 GR FILM: 1100789999 R S DOB/AGE CRS FILING DATE: 030811 B M 04181972 DL#: 02970070 NC
MANNING,GREGORY,DELOID
410 S SPRING ST APT D CSLR:
CIT#:
CSLRC:
GREENSBORO
NC
27406
TYP: P
VRA:
CHG/ARRN OFFN: F POSS STOLEN GOODS/PROP (F) 14-71.1 COMPLAINANT: ANDREWS,L CPD ISSUED: 020511 SERVED: 020511 OFFN DATE: 020511 ARRN DATE: MOTIONS DATE: DISP DATE: 031411 CONT. D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
PLEA VER MOD
FINE COSTS
WCC REST
JUDGE
ARH 14-71.1
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GL
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$
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SENT TYPE:
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400 GUILFORD DISPOSED MAGISTRATE ORDER
ICA INQUIRY 01 11CR 07657 9 GR FILM: R S DOB/AGE CR FILING DATE: 051611 W M 08211967 DL#: 07558033
CITtt:
CSLR:
274 05
DEF ATTY A FEMALE
NC
CARICO,ROBERT,JOSEPH
3603 N. 0'HENRY BLVD
GREENSBORO
NC
CLOSE,C
CPD ISSUED: 051611
MOTIONS DATE: RSONCO:
TYP: P
14-33(C)(2)
VRA: Y
SERVED: 051611
FINE
$
SUPERVISED
COSTS 208.00
WCC
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PAID
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14-33{C)(2)
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WITHDRAWN:
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CMV: N
HAZ: N
TRP/DIST:
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$20IPF/$55ATTY/$60APPT/15D-SPLT
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400 GUILFORD
DISPOSED
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MAGISTRATE ORDER
RICKER,NATASHA,LARAY
3328 A BECK ST
GREENSBORO
NC
27405
TYP: P
VRA:
CHG/ARRN OFFN: F PWISD MARIJUANA COMPLAINANT: BROWN,T,K OFFN DATE: 010110 ARRN DATE: CONT. D: 00 S: 00 C: 00 NR: 00
PLEA VER MOD
FINE
90-95(A) CPD ISSUED: 010110 SERVED: 010110 MOTIONS DATE: DISP DATE: 032310 RSONCO: GANG REL: DV CV: N
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ICA INQUIRY 01 R S DOB/AGE
W
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400 GUILFORD
DISPOSED
CITATION
NC
PATTON,DOUGLAS,MICHAEL
4700 CHARLOTTESVILLE
060710
GREENSBORO
NC
27410
CSLRC: TYP: W
AM GB1D VRA:
CHG/ARRN OFFN: M POSS OPEN CNTNR ALC BEV IN PASS AREA OF 18B-401 COMPLAINANT: DELL,T,D CPD ISSUED: 030510 SERVED: 030510 OFFN DATE: 030510 ARRN DATE: MOTIONS DATE: DISP DATE: 042610 CONT. D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
FINE
$
COSTS $ 125.00
WCC
$
REST
JUDGE SEB
18B-401
PAID YES
TO-BE-PAID
SENT LEN: pR0B. AREA CDACCD: N HWY: CDL: N CMV: N HAZ: N $20 IP FEE/060710 MTN TO
ARREST DATE:
SENT TYPE: C CONS F/JGMT: WITHDRAWN: APPEALED TO SUPERIOR OT V LIC: XPT6920 TRANS TO SUPERIOR TRP/DIST: V ST: NC V TYP: U APPELLATE EXT COMPL ALLOWED(FOSTER)
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081610
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4 00 GUILFORD DISPOSED
ICA INQUIRY 01
10CR 083769
GR FILM:
NC 102710
R
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S DOB/AGE
CR
MAGISTRATE ORDER
JACKSON,D'ANGELO,LEQUIN
135 SUMMIT AV tt 210
GREENSBORO
NC
27406
TYP: P
VRA:
CHG/ARRN OFFN: M COMMUNICATING THREATS COMPLAINANT: MENSEL.R OFFN DATE: 072210 ARRN DATE:
CONT. D: 00 S: 00 C: 00 NR: 00
PLEA VER MOD FINE
COSTS
14-27 7.1 CPD ISSUED: 072210 SERVED: 072210 MOTIONS DATE: DISP DATE: 102710
RSONCO:
WCC REST
GANG REL:
JUDGE
WME
DV CV: N
TO-BE-PAID
PAID
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CONV OFFN: M COMMUNICATING THREATS SENT LEN: 060 D SENT TYPE: A PROB: WITHDRAWN: AREA CD: ACCD: HWY: V LIC:
14-277.1
CONS F/JGMT:
APPEALED TO SUPERIOR TRANS TO SUPERIOR V TYP: APPELLATE
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST
ARREST DATE:
CHECK DIGIT:
SID:
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400 GUILFORD DISPOSED
ICA INQUIRY 01
10CR 087867
GR FILM:
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90-113.22
TRP/DIST:
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ARREST DATE:
NEXT8:
CHECK DIGIT:
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DISPOSED MAGISTRATE ORDER
ORANGE PARK
400 GUILFORD
MCKINNEY,KELVIN,BENARD
2241 CHABLIS COURT W
ICA INQUIRY 01
CITS:
CSLR:
CSLRC:
VRA.
COMPLIANT: BRENDLE,D,W
PLEA VER MOD FINE
20-106
SERVE :011909
14-71.1
CONS F/JGMT:
APPEALED TO SUPERIOR TRANS TO SUPERIOR V TYP: APPELLATE
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
ARREST DATE: 011909 CHECK DIGIT: GW3167Y SID: NC1344821A LID: KMBM3516B-400 NEXXjj. PF2 - NAME INQUIRY ADDL CHARGES:
"* ',''^3?;u
aoo4-0(*IO-353
400 GUILFORD
ICA INQUIRY 01
09CR 082335
GR FILM:
NC
SISK,DARRELL,LEE,JR
437A ARLINGTON ST GREENSBORO NC
CITft:
CSLR: CSLRC: AM 27406 DEF ATTY: WAIVED TYP: W VRA: CHG/ARRN OFFN: M FIRST DEGREE TRESPASS 14-159.12 COMPLAINANT: GOLBOURNE,R,L CPD ISSUED: 061009 SERVED: 061009 OFFN DATE: 061009 ARRN DATE: MOTIONS DATE: DISP DATE: 061109 CONT. D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
PLEA VER MOD
FINE COSTS WCC
REST
JUDGE
PAH
PAID
TO-BE-PAID
GU
GU
JU
CONV OFFN: M FIRST DEGREE TRESPASS SENT LEN: 001 D SENT TYPE: A PROB: WITHDRAWN: AREA CD: ACCD: HWY: V LIC:
14-159.12
CONS F/JGMT:
APPEALED TO SUPERIOR TRANS TO SUPERIOR TYP: APPELLATE
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
ARREST DATE: 061009 CHECK DIGIT: GW6817J SID: NC1338212A LID: DSBM5435L-400 NEXT)*: PF2 - NAME INQUIRY ADDL CHARGES:
^oiriic^:'''*-.^-:?:^
*r.'.VT-.>-:
OHvJPi*
DISPOSED
R S DOB/AGE
CR
RICKER,NATASHA,LARAY
3328 A BECK ST GREENSBORO
MAGISTRATE ORDER
NC
90-95(D)(4)
CPD ISSUED: 071409 SERVED: 071409 MOTIONS DATE: DISP DATE: 032310 RSONCO: GANG REL: DV CV: N
WCC REST
JUDGE PDS
PAID
TO-BE-PAID
90-95(D)(4)
01
PROB: WITHDRAWN: AREA CD: ACCD: HWY: V LIC: CDL: N CMV: N HAZ: N TRP/DIST: V ST:
ORD DESTROY
CHECK DIGIT:
PF2
SID:
LID:
NRBF6650L-400
- NAME INQUIRY
ADDL CHARGES:
:p!>
/ 26 S'
sooi-oHDi-n^
4 00 GUILFORD
DISPOSED
07CR 084580
CR
MAGISTRATE ORDER
DOCKERY,MARK,ANTHONY,SR
10541 US HWY 158 W RUFFIN NC
NC 052207 VRA: Y
CHG/ARRN OFFN:
COMPLAINANT:
OFFN DATE: CONT. D:
TYP: P 14-33(C)(2)
040707 SERVED:
STRADER,B,C
00 C:
040707
04 0707
MOTIONS DATE:
RSONCO: WCC REST
DISP DATE:
GANG REL:
JUDGE
SEB
052207
N
00 3:
DV CV:
FINE
COSTS
PAID
NO
TO- BE-PAID
052209
GU
GU
JU
M
$
ASSAULT ON A
$
-
110.00
CONV OFFN:
FEMALE
14-33(C)(2)
CONS F/JGMT:
APPEALED TO SUPERIOR
ACCD:
CDL: N
CMV:
HAZ: N
TRP/DIST:
V ST:
V TYP:
LID:
MDWM6721A-4 00
NEXT8:
INQUIRY
ADDL CHARGES:
:^e^J*<
2obi-olioi-nM
400 GUILFORD
DISPOSED
ICA INQUIRY 01
07CR 084582
GR FILM: NC
TRIAL DATE: 052207
AM
TYP: P
VRA:
R
W
S DOB/AGE
CR
MAGISTRATE ORDER
DOCKERY,MARK,ANTHONY,SR
10541 US HWY 158 W
COMMON LAW
SERVED:
040707
COSTS
WCC
REST
JUDGE
SEB
PAID
TO-BE-PAID
GU
GU
JU
CONV OFFN: M FALSE IMPRISONMENT SENT LEN: 045 D SENT TYPE: C PROB: 024 M SUPERVISED WITHDRAWN: AREA CD: ACCD: HWY: V LIC:
COMMON LAW
CONS F/JGMT:
APPEALED TO SUPERIOR
TRANS TO SUPERIOR
CDL: N CMV: N HAZ: N TRP/DIST: V ST: AT EXP OF 07CR84 580/COMPLY WITH 07CR84580
V TYP:
APPELLATE
ARREST DATE:
CHECK DIGIT:
SID:
LID:
MDWM6721A-4 00
NEXT#:
PF2
- NAME INQUIRY
ADDL CHARGES:
2001- 050%--X\\a
4 00 GUILFORD
DISPOSED WARRANT
ICA INQUIRY 01
07CR 087950
GR FILM:
R S DOB/AGE
B
CR
F 02251975 DL# :
CSLR:
GREENSBORO
NC
00000
TYP: A
VRA:
CHG/ARRN OFFN: F ASSAULT SERIOUS BODILY INJURY 14-32.4 COMPLAINANT: SMITH,M,W CPD ISSUED: 051007 SERVED: 072207 OFFN DATE: 050207 ARRN DATE: MOTIONS DATE: DISP DATE: 010808 CONT. D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
PLEA VER MOD FINE
COSTS WCC
REST
JUDGE
ARH
PAID
TO-BE-PAID
14-33(C)(1)
CONS F/JGMT:
APPEALED TO SUPERIOR TRANS TO SUPERIOR V TYP: APPELLATE
PROB: WITHDRAWN: AREA CD: ACCD: HWY: V LIC: CDL: N CMV: N HAZ: N TRP/DIST: V ST:
ARREST DATE: 072207 CHECK DIGIT: GV5259F SID: NC0617259A LID: CABF5969D-400 NEXTu. PF2 - NAT-IE INQUIRY ADDL CHARGES:
ATTACHMENTS-12-1
NAME
OFFENSE
DATE OF
IDATE OF
OFFENSE
CONVICTION
Vicent Paige
May 6, 2008
Adrienne Jones
{Possession of cocaine j
!Adrienne Jones
'
I
i
.
jPossession of cocaine
Assault on a child under 12
January_22, 2008
November 28, 2007
iJameson Oliver
i_
June 30,2007
I iKaren D.Hall
1
iPossession of cocaine
I
i
! I
October 17,2007
j
;
]
Janaury 14. 2008
!
!
1
'James R. Jones
j
iPossession of cocaine
;
i
Malik Curry
j
1
;
;
J
L-
i
r ;
I
Charlene Shipman
|
1
i Possession of cocaine
1
1
I
I
John L. Stevenson
3M1-0S2S-IXO
400 GUILFORD DISPOSED MAGISTRATE ORDER ICA INQUIRY 01 07CR 089715 GR FILM: FILING DATE: 052507 R S DOB/AGE CR B M 01051963 DL#: 22893284
NC
PAIGE,VINCENT,YOHANN
135 221 SUMMIT AVE GREENSBORO NC
CIT#:
27405
CSLR: CSLRC: DEF ATTY: WEATHERFORD,CASSANDRA,
TYP:
VRA:
CHG/ARRN OFFN: M POSSESS DRUG PARAPHERNALIA 90-113.22 COMPLAINANT: HARRIS,J,W CPD ISSUED: 052507 SERVED: 052507 OFFN DATE: 052507 ARRN DATE: MOTIONS DATE: DISP DATE: 050608
CONT. D: 00 S: 00 C: 00 NR:
PLEA VER MOD GU GU JU M FINE
00
COSTS WCC
RSONCO:
REST
GANG REL:
JUDGE WKH 90-113.22 PAID
DV CV: N
TO-BE-PAID
$
POSSESS DRUG
$
PARAPHERNALIA
SENT TYPE:
CONS F/JGMT:
APPEALED TO SUPERIOR
TRANS TO SUPERIOR
WITHDRAWN:
AREA CD:
ACCD:
HWY:
LIC:
V ST:
TYP:
APPELLATE
ARREST DATE:
CHECK DIGIT:
SID:
LID:
VPBM8280Y-400
NEXT#:
PF2
- NAME INQUIRY
ADDL CHARGES:
2601~0S^5'2HS
4 00 GUILFORD
DISPOSED
INDICTMENT
ICA INQUIRY 51 07CRS089746 GR FILM: 0800509999 R S DOB/AGE CRS FILING DATE: 080707 B F 05011964 DL#: 5531945 NC
CITS:
CSLR: CSLRC:
JONES,ADRIENNE,RENAY
2 6 08 DENISE DR
GREENSBORO
NC 27407
TYP: P
VRA:
90-95(A)
CPD ISSUED: 052507 SERVED: 052507 MOTIONS DATE: DISPDATE:
RSONCO:
V.'CC REST
00 NR:
00
COSTS
GANG REL:
JUDGE
RWS
DV
CV:
PAID
TO-BE-PAID
GU
GU
JU
$
F PWISD COCAINE
CONV OFFN:
90-95(A)
SENT LEN: 013 M - 016 M SENT TYPE: A pROB: WITHDRAWN: AREA CD: ACCD: HWY: V LIC:
CONS F/JGMT:
APPEALED TO SUPERIOR
TRANS TO SUPERIOR
080607
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
V TYP:
APPELLATE
ARREST DATE: 052507 CHECK DIGIT: GV4512B SID: NC0493025A LID: AJBF3949R-400 NEXT8; PF2 - NAME INQUIRY ADDL CHARGES:
foVf
001'QW(*"2-"3~1
ICA INQUIRY 51 S DOB/AGE 07CRS092700 GR FILM: 0804409999 CRS FILING DATE: 110507
NC TRIAL DATE: 012208 CSLRC: AM
TYP: P
VRA:
R B
JONES,ADRIENNE,RENAY
2608 DENISE DR
GREENSBORO
NC
27407
90-95(D)(2)
CPD ISSUED:
MOTIONS DATE:
RSONCO:
062307
SERVED:
062307
COSTS
WCC
REST
PAID
TO-BE-PAID
GU
GU
JU
$
-
$
SENT TYPE: WITHDRAWN: V LIC:
90-95(D)(2)
51
ACCD:
HWY:
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
110507
ARREST DATE: 062307 CHECK DIGIT: GV4873P SID: NC0493025A LID: AJBF3949R-400 NEXTS: PF2 - NAME INQUIRY ADDL CHARGES:
:<<> -,'
a ooi' onu'%'%'1
INDICTMENT
ICA INQUIRY 51 07CRS092040 GR FILM: 0804409999 R S DOB/AGE CRS FILING DATE: 110507 B F 05011964 DLS: 5531945 NC
CIT#:
CSLR: CSLRC:
TYP: P
JONES,ADRIENNE,RENAY
2608 DENISE DR
GREENSBORO NC 274 07 DEF ATTY: BAUCINO,WAYNE,T CHG/ARRN OFFN: F FELONY POSSESSION OF COCAINE
COMPLAINANT: ALTIZER,B,M OFFN DATE: 061607 ARRN DATE: CONT. D: 00 S: 00 C: 00 NR: 00
PLEA VER MOD FINE
COSTS
90-95(D)(2)
SERVED: 061607
DISP DATE: 012208
GANG REL:
JUDGE
RWS
DV CV: N
TO-BE-PAID
WCC
REST
PAID
GU
GU
JU
CONV OFFN: F FELONY POSSESSION OF COCAINE SENT LEN: SENT TYPE: PROB: WITHDRAWN: AREA CD: ACCD: HWY: V LIC:
90-95(D)(2)
CONS F/JGMT:
07CRS08 9746
51
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
110507
ARREST DATE: 061607 CHECK DIGIT: GV4788G SID: NC0493025A LID: AJBF3949R-400 NEXTS: PF2 - NAME INQUIRY ADDL CHARGES:
c:v*
aC01-0(P3d-Oct'
400 GUILFORD ICA INQUIRY 01 07CR 093399 GR FILM:
CIT#:
CSLR: DEF ATTY: WAIVED
14-33(C) (3)
CPD ISSUED: 063007 SERVED: 063007 MOTIONS DATE: DISP DATE: 112807 RSONCO: GANG REL: DV CV: N
WCC REST JUDGE
SEB
PAID
YES
TO-BE-PAID
GU
GU
JU
130.00
CONV OFFN: M ASSAULT ON A CHILD UNDER 12 SENT LEN: 075 D SENT TYPE: C SUPERVISED WITHDRAWN: PROB: 015 M AREA CD: ACCD: HWY: V LIC:
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
V TYP:
APPELLATE
ARREST DATE:
NEXTS:
063007 CHECK DIGIT: GV4994D SID: NC0768875A LID: JOBM5007K-400 PF2 - NAME INQUIRY ADDL CHARGES: Y
^.2Az...
~s<rr.
00l-0(*36-Ot?
ICA INQUIRY 02 07CR 093399 GR FILM: R S DOB/AGE CR FILING DATE: 063007 B M 09121970 DLS: 7014 607
NC
CITS:
CSLR: GREENSBORO NC 274 05 DEF ATTY: WAIVED TYP: W VRA: Y CHG/ARRN OFFN: M MISDEMEANOR PROBATION VIOL 15A-134 5 COMPLAINANT: CALVERT,M,J CPD ISSUED: 063007 SERVED: 063007 OFFN DATE: 063007 ARRN DATE: MOTIONS DATE: DISP DATE: 090208 CONT. D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
PLEA VER MOD PO
CONV OFFN: SENT LEN:
PROB: SENT TYPE:
FINE
COSTS
WCC
REST
JUDGE
MF
PAID
TO-BE-PAID
CONS F/JGMT:
APPEALED TO SUPERIOR
TRANS TO SUPERIOR
LIC:
WITHDRAWN:
AREA CD:
ACCD:
HWY
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
V TYP:
APPELLATE
ORD MOD PROB/AMEND JAIL TIME/OBT ASMNT-TASC/42309 ORD MOD PROB/CONT PROB/TRAMS TO UNSUPV PROB(ENOCHS)
ARREST DATE: 063007 CHECK DIGIT: GV4994D SID: PF2 - NAME INQUIRY NEXTS:
NC0768875A LID: JOBM5007K-400
ADDL CHARGES:
a0O7-0?H'3O|
400 GUILFORD DISPOSED
INDICTMENT
HALL,KAREN,DENISE
F 07141964 DLS:
CITS:
305 W. LEE ST. CSLR: CSLRC: AM GREENSBORO NC 27406 DEF ATTY: WEATHERFORD,CASSANDRA, TYP: P VRA: CHG/ARRN OFFN: F FELONY POSSESSION OF COCAINE 90-95(D)(2) COMPLAINANT: DENNY,B,R CPD ISSUED: 081407 SERVED: 081407 OFFN DATE: 081407 ARRN DATE: MOTIONS DATE: 051109 DISP DATE: 111708 CONT D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
PLEA VER MOD FINE COSTS WCC REST JUDGE
.00 RLD
PAID
R
TO-BE-PAID
GU
GU
JU
$ 00000.00
691.50
CONV OFFN: F FELONY POSSESSION OF COCAINE SENT LEN: 007 M - 009 M SENT TYPE: I PROB: 036 M SUPERVISED WITHDRAWN: AREA CD: ACCD: HWY: V LIC:
90-95(D)(2)
CONS F/JGMT:
APPEALED TO SUPERIOR:
TRANS TO SUPERIOR:
V TYP: APPELLATE:
101507
V ST:
ARREST DATE: 081407 CHECK DIGIT: GV5541M SID: NC0243094A LID: KHBFD-400 ADDL CHARGES: Y NEXTS: PF2 - NAME INQUIRY
^>tf
2061-0%\H-3o\
F 07141964 DLS:
HALL, KAREN,DENISE
305 W. LEE ST. GREENSBORO
CITS:
NC 274 06
CSLR: CSLRC: DEF ATTY: WEATHERFORD, CASSANDRA,
CHG/ARRN OFFN: M POSSESS DRUG PARAPHERNALIA 90-113.22 COMPLAINANT: DENNY,B,R CPD ISSUED: 081407 SERVED: 081407
OFFN DATE: 081407 ARRN DATE: CONT. D: 00 S: 00 C: 00 NR: 00
PLEA VER MOD
GU GU JU CONV OFFN: M SENT LEN:
PROB:
MOTIONS DATE: 051109 DISP DATE: 111708 RSONCO: GANG REL: DV CV: N
WCC REST
FINE
COSTS
JUDGE
RLD
PAID
TO-BE-PAID
$
SENT TYPE: WITHDRAWN:
90-113.22
CONS F/JGMT:
LIC:
07CRS097781
51
AREA CD:
ACCD:
HWY:
N
CDL:
CMV ; N
HAZ:
TRP/DIST:
ST:
ARREST DATE: 081407 CHECK DIGIT: GV5541M SID: NC0243094A LID: KHBFD-400
NEXTS:
ADDL CHARGES: Y
pooi-ion- oo?
400 GUILFORD
DISPOSED INDICTMENT
ICA INQUIRY 51
07CRS104032
GR FILM: 0900779999
NC
CLARKE,JOVON,DERRELL
1826 C MCKNIGHT MILL RD GREENSBORO NC 27405
CITS:
CSLR: CSLRC: DEF ATTY: CULBERTSON,KRISPEN
CHG/ARRN OFFN: F PWISD COCAINE COMPLAINANT: MARDIS,A OFFN DATE: 101707 ARRN DATE: CONT D: 00 S: 00 C: 00 NR: 00
PLEA VER MOD
FINE COSTS
90-95(A) CPD ISSUED: 101707 SERVED: 101707 MOTIONS DATE: DISP DATE: 042309 RSONCO: GANG REL: DV CV: N
WCC REST
JUDGE
CCE
PAID
TO-BE-PAID
GU
GU
JU
$
F PWISD COCAINE
CONV OFFN:
90-95(A)
SENT LEN: 006 M - 008 M SENT TYPE: A PROB: WITHDRAWN: AREA CD: ACCD: HWY: V LIC:
CONS F/JGMT:
APPEALED TO SUPERIOR TRANS TO SUPERIOR V TYP: APPELLATE
112607
TRP/DIST:
V ST:
ARREST DATE: 101707 CHECK DIGIT: GV6413Q SID: NC0907228A LID: JCBM7998D-400 NEXT#: PF2 - NAME INQUIRY ADDL CHARGES:
CLARKE,JOVON,DERRELL
704 APT D FLORIDA ST CSLR:
CITS:
CSLRC:
GREENSBORO NC 27406 DEF ATTY: CULBERTSON,KRISPEN TYP: R VRA: CHG/ARRN OFFN: F MAINTN VEH/DWELL/PLACE CS (F) 90-108(A)(7) COMPLAINANT: MARDIS,A CPD ISSUED: 101707 SERVED: 101707 OFFN DATE: 101707 ARRN DATE: MOTIONS DATE: DISP DATE: 042309 CONT D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
PLEA VER MOD FINE
COSTS
WCC REST
JUDGE CCE
PAID
TO-BE-PAID
90-108(A)(7)
51
ACCD:
HWY:
WITHDRAWN: V LIC:
112607
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
ARREST DATE: 101707 CHECK DIGIT: GV6413Q SID: NC0907228A LID: JCBM7998D-400 NEXT#: PF2 - NAME INQUIRY ADDL CHARGES:
,i^O^
aooi- \0\1-do5
M 01291963 DLS:
JONES,JAMES,RODERICK
905 BENNETT ST GREENSBORO
CSLR:
27401 DEF ATTY: RIERSON, JENNIFER, L NC CHG/ARRN OFFN: F FELONY POSSESSION OF COCAINE
COMPLAINANT: GREGORY,H,K
TYP: P
DISP DATE:
VRA:
101707
0114 08
MOTIONS DATE:
GANG REL:
DV CV:
FINE
COSTS
WCC
REST
JUDGE
.00 JMW
PAID
YES
TO-BE-PAID
GU
GU
JU
.00
545.50
WITHDRAWN: V LIC:
TRANS TO SUPERIOR:
V TYP: APPELLATE
112607
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
Cfi'
Q0D1-Wl-30~]
400 GUILFORD DISPOSED
INDICTMENT
M 02281990 DLS:
CURRY,MALIK,TASHEBAA
924 HACKETT ST GREENSBORO
CITS:
274 05
CSLR: DEF ATTY: LLOYD,W,DAVID CSLRC:
NC
90-95(A)
CPD ISSUED: 121907 SERVED: 121907 MOTIONS DATE: DISP DATE: 101209 RSONCO: GANG REL: DV CV: N
WCC REST
JUDGE
COSTS
PAID
TO-BE-PAID
GU
GU
JU
JOC
90-95(A)
51
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
020408
ARREST DATE: 122007 CHECK DIGIT: GV7272D SID: NC1196418A LID: MCBM0989T-400 NEXTS: PF2 - NAME INQUIRY ADDL CHARGES:
206vj;lh-3O7
M 02281990 DLS:
CURRY,MALIK,TASHEBAA
924 HACKETT ST GREENSBORO
CITS:
CSLR: DEF ATTY: LLOYD,W,DAVID CSLRC:
NC 27405 CHG/ARRN OFFN: F PWISD MARIJUANA COMPLAINANT: GREGORY,H,K OFFN DATE: 121907 ARRN DATE: CONT D: 00 S: 00 C: 00 NR: 00
PLEA VER MOD
FINE
AM TYP: P VRA: 90-95(A) CPD ISSUED: 121907 SERVED: 121907 MOTIONS DATE: DISP DATE: 10120 9 RSONCO: GANG REL: DV CV: N
REST
COSTS
WCC
JUDGE JOC
PAID
TO-BE-PAID
GU
GU
JU
90-95(A)
51
ACCD:
HWY:
WITHDRAWN: V LIC:
020408
CDL: N
CMV: N
HAZ: N
TRP/DIST:
V ST:
ARREST DATE: 122007 CHECK DIGIT: GV7272D SID: NC1196418A LID: MCBM0989T-400 NEXTS: PF2 - NAME INQUIRY ADDL CHARGES: Y
QQOl-12^-^1
400 GUILFORD DISPOSED INDICTMENT
ICA INQUIRY 51 07CRS109880 GR FILM: 0900479999 R S DOB/AGE CRS FILING DATE: 020408 B F 12091984 DLS: 27584180 NC
CITS:
CSLR:
NC 274 07
SHIPMAN,CHARLENE,MARIE
922 A HACKETT ST
CSLRC:
CHG/ARRN OFFN: F FELONY POSSESSION OF COCAINE 90-95(D)(2) COMPLAINANT: GREGORY,H,K CPD ISSUED: 121907 SERVED: 121907 OFFN DATE: 121907 ARRN DATE: MOTIONS DATE: 010509 DISP DATE: 072508
CONT D- 00 S: 00 C: 00 NR: 00
PLEA VER MOD FINE COSTS WCC
GREENSBORO
TYP: W
VRA:
RSONCO:
REST
GANG REL:
JUDGE PAID
R RES
DV CV: N
TO-BE-PAID
GU
GU
JU
$ 00100.00
616.50
.00
CONV OFFN: F FELONY POSSESSION OF COCAINE SENT LEN: 005 M - 006 M SENT TYPE: I PROB: 024 M SUPERVISED WITHDRAWN: AREA CD: ACCD: HWY: V LIC:
90-95(D)(2)
CONS F/JGMT:
APPEALED TO SUPERIOR:
CDL: N CMV: N HAZ: N TRP/DIST: V ST: ATTY FEE $150, SBI FEE $300/SPIVEY/GARLICK
ARREST DATE: 121907 CHECK DIGIT: GV7270H SID: NC1270339A LID: CSBF8202M-400 ADDL CHARGES: Y NEXTS: PF2 - NAME INQUIRY
*.
CV
Qb01-)^^l'002>
400 GUILFORD ICA INQUIRY 01 07CR 110559 GR FILM:
DEPOSED
R S DOB/AGE
CR
MAGISTRATE ORDER
CITS:
NC
305 W LEE ST CSLR: CSLRC: AM GREENSBORO NC 00000 DEF ATTY: COALTER,SCOTT TYP: A VRA: CHG/ARRN OFFN: F POSSESS STOLEN MOTOR VEHICLE 20-106 ,,
CPD ISSUED: 122907 SERVED: 122907 MOTIONS DATE: DISP DATE: 061208 RSONCO: GANG REL: DV CV: N
JUDGE LCM 20-106
PAID TO-BE-PAID
REST PLEA VER MOD FINE COSTS WCC RKST GL GU JU $ $ $ CONV OFFN: T SOLICIT POSSESS STOLEN MOTOR VEHICLE
AREA"CD:
ACCD:
HWY:
V LIC:
TRP/DIST: V ST:
TRANS TO SUPERIOR
V TYP: APPELLATE
ARREST DATE: 122907 CHECK DIGIT: GV7379X SID: NC0703095A LID: JSBML-400 NEXTS: PF2 - NAME INQUIRY ADDL CHARGES:
IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION FILE NO. | i CvS
AFFIDAVIT
POLICE OFFICER J.D. BROWN, appearing before the undersigned notary and being duly
sworn (or affirmed), says that:
1. I am not a party in this matter.
2.
Greensboro, North Carolina, and have been so employed for more than six years.
3.
Department.
4.
I am familiar with the property housing the business known as the Greensboro
Inn, located at 135 Summit Avenue, Greensboro, Guilford County, North Carolina (hereinafter
the "Property").
5.
As part ofmy duties, I maintain regular contact with citizens who reside in or
frequently visit the community where the Property is located. 6. Citizens who reside inor frequently visit the community where the Property is located
7.
The Property currently, and has for a considerable period of time, maintained a
general reputation as aplace where illegal controlled substances are repeatedly sold and used.
8. I have been advised by citizens who reside in or work in the community around
the Property, that many ofthe people who visit and loiter on and about the Property have
reputations as drug dealers, drug users, and prostitutes.
bAnlDI I
9.
I have been advised by citizens who reside in or work in the community around
the Property that they are afraid for their safety because of the general disruptive nature ofthe
Property and the criminal element attracted to the Property.
10. I have conducted covert surveillance on the Property.
11.
(B)
People arrive at the Property in cars; enter rooms for a short period of
time, leave the room, and getin the carand leave. A short time later,
another car arrives at the Property and the occupant repeats this process.
(C)
What I believe to be repeated illegal drug transactions, where persons acting in a secretive manner make exchanges with other persons who
approach them.
12.
worked undercover, I purchased counterfeit controlled substances and crack cocaine from a
person loitering on the Property.
13.
I have assisted other Greensboro Police Officers executing a search warrant at the
14.
I have responded to calls for police services at the Property and observed
examples ofthe illegal and disruptive activities complained of, including assault victims and
females assaulted during domestic disturbances.
15. I have access to and have researched or otherwise caused to be researched,
Official Greensboro Police Department Records relating to investigations and calls for police service to the Property, such records setting forth activities ofthe department and setting forth
matters observed pursuant to duty imposed by law as to which matters there was a duty to report.
The date and nature ofthese investigations and calls are attached to this affidavit and include but
are not limited to the information listed (see attachments 15-1).
16.
Based upon reports from other officers who have responded to calls atthe
Property, my training, and reports from neighbors as described hereinabove, I feel itis not safe
for any law enforcement officer to respond to a call for service atthe Property without exposure
to inordinate and undue danger.
17.
AMANDA HANNA
GUILFORD COUNTY, NC
NOTARY PUBLIC
d J
( \ s^zT
Affiant
l sV
day of
^^to^VrJAtoNA-.^1!1
NOTARY PUBLIC GUILFORD COUNTY, NC
ATTACHMENTS 15-1
DATE
2011
January 13,2011
purchased counterfeit crack cocaine from an occupant in room 313 at the Greensboro Inn. Suspect, Johney Matthews, was charged with sell and delivery of cocaine. Matthews was charged with sell anddelivery of counterfeit controlled substance.
January 18,2011
DRUG ACTIVITY: A confidential source of information,
purchased crack cocaine from an occupant in room 209 at the Greensboro Inn. Suspect, Javon Shields, was charged with sell and
delivery of cocaine.
January 18,2011
DRUG ACTIVITY: Suspect infirst January 18, 2011, counterfeit drug transaction (Johney Matthews) sold crack cocaine to an
undercover police officer in a room at the Greensboro Inn. Matthews was charged with sell and delivery of a controlled
substance.
January 19,2011
working under the direction of theGreensboro Police Department, purchased crack cocaine from Javon Shields in room 209 at the
Greensboro Inn.
January 19,2011
working under the direction of the Greensboro Police Department, purchased crack cocaine from Lance Whidbee in room 216 at the
Greensboro Inn. This transaction was the second time Whidbee
sold crack cocaine in less than one hour.
ATTACHMENTS 15-1
DATE
January 24,2011
January 26,2011
Shields. A search of the room yielded cocaine, hydrocodone, drug paraphernalia, and more than $800.00.
January 26,2011
DRUG ACTIVITY: Greensboro Police executed a search in room 116 at the Greensboro Inn. A search of the room yielded crack
domestic dispute which occurred inroom 115 atthe Greensboro Inn. Victim reported she was assaulted in the room by a male.
January 31,2011
NOTICE TO ABATE NUISANCE: Greensboro Police sent
written notice to the owner of the Greensboro Inn that a public nuisance exists on the Property. February 5,2011
ASSAULT/DRUG ACTIVITY: Greensboro Police responded to the Greensboro Inn in reference to a disturbance. Suspect, a renter
at the Property, assaulted the desk clerk. Afterarrest, suspect was found in possession of marijuana and drug paraphernalia.
March 22,2011
DRUG ACTIVITY: Greensboro Police charged one person on the parking lot at the Greensboro Inn for possession of cocaine.
ATTACHMENTS 15-1
DATE
April 2,2011
April 5,2011
April 14,2011
April 27,2011
May 12,2011
May 16,2011
May 24,2011
July 6,2011
ATTACHMENTS 15-1
DATE
September 2,2011
September 21,2011
working under the direction of the Greensboro Police Department, purchased crack cocaine from a person loitering near room 119 at
the Greensboro Inn. One person wasarrested.
November 14,2011
STOLEN PROPERTY: Greensboro Police recovered over
$5,000.00 in stolen property in room 221 at the Greensboro Inn. Thestolen property included items suchas expensive bicycles.
November 16,2011 DRUG ACTIVITY: A confidential source of information,
working under the direction of the Greensboro Police Department, purchased crack cocaine from a person loitering near room 119 at
the Greensboro Inn. One person was arrested.
November 24,2011
STOLEN PROPERTY: Greensboro Police recovered stolen
property from room 204 at the Greensboro Inn. The stolen property included a handgun. Three people were arrested.
ATTTACHMENTS 15-1
DATE 2010
January 1,2010
LARCENY: Greensboro Police responded to room 204 at the Greensboro Inn in reference to a larceny. A small television was
reported stolen from the room.
January 6,2010
January 9,2010
February 20,2010
March 5,2010
PROPERTY DAMAGE: Greensboro Police responded to room 315 at the Greensboro Inn in reference to a complaint of property damage; Victim reported her vehicle, which was in the parking lot, was damaged when someone broke the windshield and cut all four
tires.
July 13,2010
DRUG ACTIVITY: Greensboro Police charged one person in room 210 at the Greensboro Inn for possession of cocaine with intent to sell and deliver and possession of drug paraphernalia. At the time of the arrest, a nine year old child and a twelve year old
child were in the room.
ATTACHMENTS 15-1
DATE
July 20,2010
September 22,2010
assaulted in theroom by herboyfriend. The male wasarrested on twooutstanding warrants for assault by strangulation andassault
on a female.
September 23,2010
DRUG ACTIVITY: Greensboro Police charged one person in room 208 at the Greensboro Inn for possessionof cocaine.
DRUG ACTIVITY: A confidential source of information,
September 27,2010
working under the direction of the Greensboro Police Department, purchased crack cocaine from an occupant in room 110at the
Greensboro Inn.
October 12,2010
ASSAULT: Greensboro Police responded to room 209 at the . Greensboro Inn in reference to an assault. Female victim reported she was assaulted in the room by a male. DRUG ACTIVITY: Greensboro Police charged one person in room 109 at the Greensboro Inn for possession of MDMA (Schedule I controlled substance), Possession of cocaine with intent to sell and deliver, possession of marijuana, and possession of drug paraphernalia. At the time of the arrest, a four year old
child was in the room.
October 14,2010
November 30,2010
DRUG ACTIVITY: Greensboro Police charged one person leaving the Greensboro Inn for possession of cocaine. Subsequent investigation at the Property led to the arrest of a second person for possession of drug paraphernalia.
ATTACHMENTS 15-1
DATE
2009
January 19,2009
responded to a complaint of a domestic dispute in room 212 at the Greensboro Inn. Two people were arrested for assault with a deadly weapon and assault by strangulation.
March 24,2009
DRUG ACTIVITY: Greensboro Police charged one person in room 108 at the Greensboro Inn for possession of marijuana.
DISTURBANCE/DRUG ACTIVITY: Greensboro Police
April 4,2009
responded to the Greensboro Inn in Reference to an intoxicated subject causing a disturbance. One person was arrested for injury to real property and possession of a Schedule I controlled
substance.
June 5,2009
complaint of a robbery which occurred on June 3, 2009 at the Property. Victim also reported prostitution at the Greensboro Inn.
June 10,2009
TRESPASS: Greensboro Police received a complaint of a trespasser at the Property. Suspect, who was hiding in room 311,
July 14,2009
DRUG ACTIVITY: Greensboro Police arrested one person in room 207 at the Greensboro Inn for possession of marijuana with
intent to sell and deliver and possession of cocaine.
ATTACHMENTS 15-1
DATE
August 2,2009
DRUG ACTIVITY: Greensboro Police went to room 309at the Greensboro Inn to serve an outstanding arrest warrant. In addition
to the charge on the warrant, suspect was charged with possession ofmarijuana and possession ofdrug paraphernalia.
December 2,2009
ARMED ROBBERY: A robbery was reported to Greensboro Police at the Greensboro Inn. One person, who occupied room 206, was arrested for possession of counterfeit money.
ATTACHMENTS 15-1
DATE
2008
January 24,2008
DRUG ACTIVITY: Greensboro Police responded to the Greensboro Inn in reference to an intoxicated subject. One person
ofapossible drug overdose in room 203 at the Greensboro Inn. One person was charged with possession ofmarijuana possession
and possession ofdrug paraphernalia.
RECOVERED STOLEN PROPERTY: Greensboro Police
March 14,2008
March 28,2008
May 25,2008
July 13,2008
August 1,2008
September 7,2008
arrested for 2nd degree trespassing and resist, obstruct, and delay a
law enforcement officer.
September 25,2008
DRUG ACTIVITY: Greensboro Police officers arrested a person in room 304 on the Property for possession of a stolen firearm,
possession of a firearm by a convicted felon, possession of cocaine, possession of marijuana, and drug paraphernalia.
ATTACHMENTS 15-1
DATE
Novembers, 2008
reference to a larceny. One person was arrested for felony larceny after complainant reported $1200.00 was stolen from his room.
December 5,2008
DRUG ACTIVITY: Greensboro Police responded to the Greensboro Inn in Reference to a disturbance in room 135.
One
person was charged with possession ofdrug paraphernalia. Another person was arrested for possession ofcocaine and
possession of drug paraphernalia.
ATTACHMENTS 15-1
DATE
2007
February 3,2007
cards in the room. Two people arrested for possession of cocaine. One was charged with financial card theft.
February 10,2007
February 23,2007
a robbery at the Greensboro Inn, which occurred on February 21, 2007. The suspect was reported carrying a handgun.
DRUG ACTIVITY: Greensboro Police responded to a complaint
March 10,2007
May 2,2007
parking lot check in the Greensboro Inn. One person was charged for possession of stolen property aftera stolen vehicle was
recovered.
May 25,2007
Greensboro Inn. One person was arrested for possession of drug paraphernalia.
ATTACHMENTS 15-1
DATE
May 25,2007
oftwo people selling cocaine from room 210 at the Greensboro Inn. One person was arrested for possession ofCrack Cocaine and
drug paraphernalia.
June 8,2007
while parked at the Greensboro Inn. Employee ofthe Greensboro Inn told investigating officers the victim spent most ofthe day "in
and out" of his car withprostitutes and drug dealers.
June 15,2007
June 16,2007
illegal possession ofcontrolled substances atthe Greensboro Inn. One person was arrested for possession ofcocaine and drug
paraphernalia. TRESPASS: Greensboro Police receiveda complaint of a
June 27,2007
July 21,2007
August 14,2007
of illegal possession of controlled substances in room 204 at the Greensboro Inn. Two people were arrested for possession of
cocaine and possession of drug paraphernalia.
ATTACHMENTS 15-1
DATE
August 24,2007
DRUG ACTIVITY: Greensboro Police responded to room 210 at the Greensboro Inn in Reference to a disorderly subject. One citation was issued for possession of marijuana. RECOVERED DRUG PARAPHERNALIA: Greensboro Police
October 10,2007
DRUG ACTIVITY: Greensboro Police responded to a complaint of controlled substance sold from room 109 at the Greensboro Inn.
October 17,2007
DRUG ACTIVITY: Greensboro Police responded to a complaint of controlled substances being sold onthe premises of the
October 18,2007
LARCENY: Greensboro Police received a complaint of a firearm stolen from a vehicle parked at the Greensboro Inn.
ASSAULT/DOMESTIC VIOLENCE: Greensboro Police
October 25,2007
November 4,2007
November 8,2007
November 16,2007
complaint ofa robbery in room 114 at the Greensboro Inn. The suspect was armed with a semi-automatic handgun. Employee told police she believed the suspect and others loitering on the Property
earlierin the day were involved in the illegal drug trade.
ATTACHMENTS 15-1
DATE
November 18,2007
drug paraphernalia from room 218 at the Greensboro Inn. Complainant was motel manager who suspected the occupant of
the room sold illegal drugs.
December 17,2007
in room 214 at the Greensboro Inn. Two people were arrested for
occupant of the carand a person in Room 215 at the Greensboro Inn were arrested for possession of a stolen vehicle, simple assault,
and resisting a public officer.
OFFICER C.H. PEEDEN. appearing before the undersigned notary and being duly sworn
(or affirmed), says that:
1. I am not a party in this matter.
2.
Department, and have been so employed for approximately six and one half years. 3. For the last two years I have been assigned to the Vice Narcotics Unit ofthe
4.
5.
I have during the past several years visited the Property, visited the community
around the Property, and have had personal contact with citizens in and around the community
where the Property is located.
6.
Based upon my personal contacts inthe community where the Property is located
Ihave come to know the general reputation ofthe Property and the general reputation ofpersons
who frequent the Property.
7.
The Property currently, and has for a considerable period oftime, maintained a
(A)
(B)
(C)
Repeated acts which create and constitute a breach of the peace, including fights and assaults involving drug dealer who physically attack those who
owe them money.
8.
9.
(A)
(B)
10.
(A) (B)
(C)
11.
Since February 2011,1 have overseen a covert operation which resulted in the
controlled substances.
13.
14.
stayed in the motel office with an employee to ensure the employee did not notify occupants ofa
room of theimpending search warrant execution.
15.
occurrences ofdrug violations on the Property, and the violent activities which coincide with the illegal drug trade, Ibelieve the Greensboro Inn is adetriment to the community and clearly a
publicnuisance. 16. Furtheryour affiant saith not.
(ViwXAffiant
Q,j-w
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Sergeant A.H. Hollis, appearing before the undersigned notary and being duly sworn (or
affirmed), says that:
1.
2.
County, North Carolina, and have been so employed for more than twenty years. During the
majority ofmy law enforcement career, Ihave worked in the downtown area ofGreensboro.
3. Icurrently hold the rank ofSergeant and am assigned to the Greensboro Police
Department's Center City Resource Team. Members ofthe Center City Resource Team work
the majority oftheir shifts in the downtown area of Greensboro. 4. I am familiar with The Greensboro Inn, 135 Summit Avenue, Greensboro, North
5.
I have during the past several years responded to calls at the Property, visited the
community around the Property, and have had personal contact with citizens in and around the
community where the Property is located.
6.
Based upon my personal contacts in the community where the Property is located
Ihave come to know the general reputation ofthe Property, ofpersons who frequent the
Property, and ofthe people who own and operate the business on the Property. 7. The Property currently, and has for aconsiderable period oftime, maintained a
(A)
(B)
(C)
Repeated acts which create and constitute breaches ofthe peace, including but not limited to, assaults, affrays, robberies, and disturbances.
8.
Persons who commonly loiter on and about the property have general reputations
as persons who are known to engage in such acts as described in paragraph #7 hereinabove.
9. The owners and employees ofthe Greensboro Inn maintain ageneral reputation
(A)
(B)
(C)
(D)
Assault victims.
Affrays.
(E)
11.
I have seen marijuana, crack cocaine, powder cocaine, heroin, and drug
13.
While conducting surveillance and answering calls for police services at the
Property, Ihave observed examples of the illegal activities which citizens complain ofand to
which law enforcement authorities repeatedly respond.
14.
I have spoken to Ahman Khan about the illegal and disruptive activities occurring
at the Property.
15.
police officers assigned to the Center City Resource Team respond to the Greensboro Inn to look
for suspects.
16.
The illegal and disruptive activities described above at the Property, occur all
17.
Based upon reports from officers who have responded to calls at the Property, my
training, and reports from neighbors as described hereinabove, I feel it is not safe for any law
enforcement officer to respond to a call for service at the Property without exposure to inordinate
and undue danger.
18.
, /
) i
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Sergeant J.E. Armstrong, appearing before the undersigned notary and being duly sworn (or
affirmed), says that:
1.
2.
County, North Carolina, and have been so employed for twenty years.
3.
I currently hold the rank ofSergeant and am assigned to the Greensboro Police
Department's Center City Resource Team. Members ofthe Center City Resource Team work
the majority oftheir shifts in thedowntown area of Greensboro.
4.
For more than fifteen years, I have been familiar with the Greensboro Inn, 135
5.
I have during the past several years responded to calls atthe Property, visited the
community around the Property, and have had personal contact with citizens in and around the
community where the Property is located.
6.
Based upon my personal contacts in the community where the Property is located
Ihave come toknow the general reputation ofthe Property, ofpersons who frequent the Property, and ofthe people who own and operate the business on the Property.
7. I have been advised bysuch citizens that the Property currently, and has fora
(A)
(B)
(C)
8.
I have been advised by such citizens, that many ofthe people who visit and loiter
on and about the Property, have reputations as persons who are known for engaging in acts
described in Paragraph #7 above.
9.
I have been advised by citizens who reside in or work in the community around
the Property that they are afraid for their safety because ofthe general disruptive nature of the
Property and the disruptive nature ofthe people attracted to the Property.
10.
for:
The owners and operators ofthe Greensboro Inn maintain ageneral reputation
(A)
(B)
Knowing ofthe illegal activities occurring on the Property but fail to take
measures to prevent orreduce the illegal activities;
(C)
11.
(A)
(B)
(C)
(D)
(E)
Assaultvictims.
(F)
12.
While conducting surveillance and answering calls for police services at the
Property, Ihave observed examples ofthe illegal activities which neighbors complain ofand to
which law enforcement authorities repeatedly respond.
13.
control, purchase controlled substances from people staying inrooms on the Property.
14. At least one Greensboro Police Officer working under my direction has recovered
15.
activities occurring at the Property and offered to evict drug dealers and prostitutes from the
Property. The employee told me evicting the criminal element who loiters on the Property would
result in a loss of patrons at the Greensboro Inn.
16.
Based upon reports from officers who have responded to calls at the Property, my
training, and reports from neighbors as described hereinabove, I feel itis not safe for any law
enforcement officer to respond to acall for service at the Property without exposure to inordinate
and undue danger.
17.
18.
2011 ^vAN/^%.
,v-.Rwt:fc^
My Commission expires
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Captain D.W. Scott, appearing before the undersigned notary and being duly sworn (or affirmed),
says that: 1. I am not a party in this matter.
2.
Greensboro County, North Carolina, and have been so employed for more than nineteen years.
3.
this assignment Iwas the Commanding Officer ofthe Greensboro Police Department's Central
Division, which includes the property housing the business known as The Greensboro Inn, 135
Summit Avenue, Greensboro, North Carolina (hereinafter the"Property").
4.
As part ofmy duties, I maintain regular contact with citizens who reside in or
5.
Citizens who reside in or frequently visit the community where the Property is located
6.
The Property currently, and has for aconsiderable period oftime, maintained a
(B)
(C)
Repeated breaches of the peace including, but not limited to, fights,
assaults, and robberies.
7.
8.
People who loiter on the Property have reputations for engaging in the illegal
9.
The general reputation of the owners and operators of the Property is that they
know of the illegal and disruptive activities occurring on the Property, but are unable or
unwilling to prevent the activities from occurring.
10.
11.
12.
I know at least one bank robbery suspect has been arrested at the Property.
I have observed females I believe to be prostitutes loitering of the Property.
I have observed the following on the Property:
(A)
(B)
Fights;
Assaults;
(C)
13.
Because ofthe criminal element attracted to the Property, I believe the Greensboro
4il/
Sworn to (or affirmed) and subscribed before me this
l0'.ltl!lli,j.
Affiant
Z3)
Day of
Jc*
Shelley Weidler, appearing before the undersigned notary and being duly sworn (or affirmed),
says that: 1. I am not a party to this matter.
2.
3.
I am familiar with the property known as the Greensboro Inn, 135 Summit
4.
During the last four years, I have routinely engaged in sexual activities with men
5.
6.
I have used illegal drugs on the Property more than one thousand times.
I am familiar with the reputation of the Property.
7.
The Property currently, and has for a considerable period oftime, maintained a
8.
The general reputation ofAhman Khan isthat he knows ofthe illegal activities
occurring on the Property, but is unwilling to prevent the activities from occurring. I have personally observed Mr. Khan atthe Property while prostitution and drug sales oruse were
occurring and a large number of people traveling to and from particular hotel rooms.
9. I have personally seen at least one employee at the Property routinely notify a
person I know to be a drug dealer living at the Greensboro Inn when the police visit the Property.
EXHIBIT 3
10.
money:
I have engaged in the following sexual acts on the Property in exchange for
(A)
(B)
(C) 11.
Sexual acts with a male and another female at the same time.
I have engaged insexual acts with males on the Property inexchange for money
12.
I have observed people loitering on the Property in possession ofmore than three
13.
14.
than 25 times.
15.
On more than one hundred occasions, I have used cocaine with people who were
17.
1r)
day of
JL/s3[fi.<nncX
A' V 2Ql]
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Frank Burton, appearing before the undersigned notary and being duly sworn (or affirmed), says
that:
1.
2.
3.
4.
Since 1984, Burton's Pharmacy has been located at 120 E. Lindsay Street,
5.
I am familiar with the property known as the Greensboro Inn, 135 Summit
7.
Citizens who frequently, visit the community where the Property is located have
advised me ofthe general reputation ofthe Property and ofpersons who frequent the Property.
8.
The Property currently, and has for aconsiderable period of time, maintained a
general reputation as aplace where prostitutes loiter to solicit passers by, either on foot or in
vehicles.
9.
The Property currently, and has for aconsiderable period oftime, maintained a
general reputation as aplace frequented by drug dealers, and persons known for illegal activities.
10. I have heard of the Greensboro Inn referred to as the "crack motel" and a
11.
12.
Merchandise stolen from my business has been recovered at the Greensboro Inn.
13.
On one occasion, aplastic case containing watches was stolen from my business.
The case was recovered from atrash dumpster on the Property. The watches were not recovered. 14. Because of the illegal and disruptive nature of the Property, I am concerned about
the safety ofthe employees at my business. As aprecaution, Iescort female employees to their
cars when they leave my business at night. Additionally, for my personal safety, 1carry a
handgun when Ileave my business at night. The primary reason Ifollow these precautions is
because ofthe illegal and disruptive nature ofthose who loiter on the Property.
15.
16.
2011
AMANDA HANNA
NOTARY PUBLIC
^fA-s v~Vv---^
(U CHS
... GUILFORD COUNTY, NC
| My Commiacion Epiroa Ngy, 17.2015
My commission expires
Ron Estes, appearing before theundersigned notary and beingduly swom (or affirmed), says
that:
1. 2.
I am not a party to this matter. I am a resident of Greensboro, Guilford County, North Carolina.
3.
approximately 50 feet from the property known as The Greensboro Inn, 135 Summit Avenue,
Greensboro, North Carolina (hereinafter the "Property").
4. I can see the Property from my restaurant.
5.
Citizens who frequently visit the community where the Property is located have
advised me of the general reputation of the Property and of persons who frequent the Property. 6. The Property currently, and has for a considerable period of time, maintained a
general reputation as a place frequented by prostitutes and drug dealers. 7. The general reputation of the people who commonly loiter on and about the
Property, is that many are prostitutes, drug dealers, drug dealers, and persons known for engaging in illegal activities.
8. Some patrons of my business have told me they are afraid to visit my business
because of the illegal and disruptive nature of the Property. 9. I have seen or heard the following upon the Property:
(A)
EXHIBIT
conversation with the occupant of the cars, get in the cars and leave, and
return a short time later.
(B)
After returning, the females would loiter on the Property and repeat the
process described in Paragraph A.
(C)
What I believe to be repeated illegal drug transactions, where persons acting in asecretive manner remove unknown items from their pockets and make exchanges with other persons who approach them, either on foot
or in cars.
(D)
(E)
A female who commonly loiters on the Property assaulted bya male ina
nearby parking lot.
10.
properties.
11.
I have watched persons loitering upon the Property walk to myrestaurant and ask
12.
People who loiter on the Property have come into myrestaurant and used loud and
profane language. On at least one occasion, patrons at three different tables leftmyrestaurant when people who loiter on the Property became loud and used profane language inside my
restaurant.
13.
I have seen the illegal and disruptive activities described herein occur during all
14.
Iworry about my safety and the safety ofmy employees because ofthe illegal and
15.
Because ofthe illegal and disruptive nature ofthe Property, I have instructed the
male employees ofmy business to ensure female employees are accompanied to their vehicles
when leaving work late at night. 16. Because of the criminal element attracted to the Property, I believe the Property to
gs/L.
Affiant
AFFIDAVIT
Holly Anderson, appearing before the undersigned notary and being duly sworn (or affirmed),
says that:
1.
2.
3.
Iam the manager ofDowntown Hounds, abusiness which provides pet boarding
and training. Part ofmy duties include walking dogs in the downtown Greensboro area. 4. My place ofwork is located approximately 300 feet from the property known as
the Greensboro Inn, 135 Summit Avenue, Greensboro, North Carolina (hereinafter the
"Property").
4.
5.
Citizens who frequently visit the community where the Property is located have
advised me ofthe general reputation ofthe Property and ofpersons who frequent the Property.
6.
The Property currently, and has for aconsiderable period oftime, maintained a
7.
The general reputation ofthe people who commonly loiter on and about the
Property is that many are prostitutes, drug dealers, drug users, and persons known for engaging in
illegalactivities.
8.
Some patrons ofmy business have told me they are afraid to visit my business
9.
leave confinement facilities and return to the general population islocated near my business. 10. One inmate housed in the facility described in Paragraph 9above told me he has
(A)
Females loitering on the Property solicit males to engage in sexual acts for
money;
(B)
12.
a "blowjob."
I know the act ofafemale providing oral sex to a male iscommonly referred to as
13.
On one occasion, as a male friend and I walked past the Property, a female
loitering on the Property solicited my friend and told him, "Five dollars will get you ablowjob."
14. I have seen people who loiter on the Property use loud and profane language.
15.
16.
I have seen people vandalize my car and run directly to the Greensboro Inn.
I have seen the illegal and disruptive activities described herein occur during all
17.
18.
19.
Iworry about my safety, the safety ofmy employees, and the safety ofmy
Because ofthe criminal element attracted to the Property, Ibelieve the Property to
^no
QAffiant
IUw
Day of Nfaoer\Ar3(Lr
2011
AMANDA HANNA
NOTARY PUBLIC
GUILFORD COUNTY, NC
AFFIDAVIT
Richard Gantt, appearing before the undersigned notary and being duly sworn (or affirmed), says
that:
1.
2.
3.
I live approximately 300 feet from the Greensboro Inn, 135 Summit Avenue,
5.
Citizens who frequently visit the community where the Property is. located have
advised me ofthe general reputation ofthe Property and ofpersons who frequent the Property. . 6. The Property maintains ageneral reputation as a place frequented by prostitutes,
drug dealers, and people prone to engage in violent behavior such as assaulting others.
7.
8.
9.
fearful ofwalking to the downtown area ofGreensboro. As a result, I avoid walking on the same
sideof the street where the Property is located.
10.
The activities, which occur on the Property and the criminal elementwhich
frequents the Property, cause me to fear for my safety in my own home. As a result, I constantly
keep the doors locked atmy home. When I have visitors at my home, I instruct them to keep the
EXHIBIT
11.
Friends and colleagues who visit my home have expressed concern about their
personal safety, as well as mine, because ofthe reputation and disorderly nature ofthe Property,
the people who commonly loiter on or about the Property, and the criminal element drawn to the
community as aresult ofthe illegal activities which repeatedly occur at the Greensboro Inn.
12. I know several homes near my home are for sale. I know ofat least one instance
when apotential buyer cited the violent and disruptive nature ofthe Property and refused to
purchase a nearby home.
13.
I believe many people who frequent the Greensboro Inn are part ofacriminal
frriri1~ ~
---~~
AMANDA HANNA
NOTARY PUBLIC
&6eJL, jfxfal
Affiant
<y*t
GUILFORD COUNTY, NC
2011
H-fci-V*
Richard Levy, appearing before the undersigned notary and being duly sworn (or affirmed), says
that:
1.
2.
3.
I am familiar with the Greensboro Inn, 135 Summit Avenue, Greensboro, North
4.
I own real estate housing several residential condominium units which are located
approximately 300 feet from the Greensboro Inn. Imaintain an office in one ofthe condominium units
and frequently visit my office.
5. I can see the Property from my office.
6.
Citizens who reside in orfrequently visit the community where the Property is located
7.
The Property currently, and has for a considerable period oftime maintained a
general reputation as agathering place for people to sell illegal drugs and engage in violent
conduct such as affrays, robberies, and assaults.
8. I have seen intoxicated people fighting on the Property.
9.
10.
Because of the illegal activities occurring on the Property and the criminal
element attracted to the Greensboro Inn, I believe the value of real estate I own near the Property
LiXHIBlT
11.
Iam trying to sell several of the condominium units Iown, which are located near
12.
One potential buyer specifically noted the illegal nature Property when declining
13.
Because ofthe illegal and disruptive nature ofthe Property, I will not walk near
14.
I am concerned for my safety and the safety of local residents because of the
criminal element who is attracted to commonly loiter on and about the Property.
15. Further your affiant saith not.
AMANDA HANNA
NOTARY PUBLIC
GUILFORD COUNTY, NC
Affiant
<1
2011