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onoan - gffitile County Ohio Crk of Court ofthe Common Pleas: 2018 Dec 27 2:06 PN-YECROED00 }s Franklin Coumy INDICTMENT FOR: Unlawful Securities Practices (ORC 1707-44) (F3) (7 Counts); Unlawfol Securities Practices, (ORC 1707.44) (F3) @ Counts); Unlawful Seeurities Practices (ORC 1707.44) (F3) (2 Counts); Unlawful Securities Practices (ORC 1707.44) (P1) (2 Counts); Grand ‘Tuell (ORC 2913.02) (Fs) (1 Count); Unluwiul Seeuri Practices (ORC 1707.44) (F2) (1 Count); Unlaful Securities Practices {ORC 1707.44) (F2) (€ Count); Grazd ‘Thett (ORC 2913.02) (F4) (1 Count); UnlawFal Seeuri Practices (ORC 1707.44) (£2) (1 Count); Theft Erom a Person in a Protected Class (ORC 2913.02) (F3) (1 Count). ‘Total: 19 Counts. Grond Jury Term, Beginning September 14, 2018 Practices, $1707.44, F3 Defendants Jeffery Luke Westerman Date af Olfenve On or about January 1, 2014 io December 31, 2014 ‘Ths Jurors of the Grad Jury of the State of Ohio, duly selected, impancied, swora and charged to inquire of crimes and offenses committed within the bady af Tranklia County, inthe State af Ohio, Upon their oulh do find and present that Jeffery Luke Westerman late of said County, on or about January 1, 2014 to December 31,2014, within ee Coumy of Franklin aforesuid ia violation of section 1707-44 af the Ohia Revised Code, with purpass to deccivo, did make, record, or publish ot ‘cause ta he made, recorded, or published, a tcpott of a transaction in securities which was false in any material respect, Huriermere, the value of ne funds or securities invalved im the afTense or the loss to the vic“: seven Thousaad five hundred dollars or raore but less thon Thicty-seven thous Tive hundred dolar, Connt One Unlawtul Seeusi Count Two -Unlawfil Securities Practices, $1707.44, F3. Defendants —_Seffery Luke Westerman Dateof Offense On or about January 1, 2015 to December 31,2025 ‘The Jurors of the Grand Jury of the State of Ohio, duty selected, impaneled, sven and charged ta ‘nguine of crimes and offenses coumitted wid the body of Franklin County, in the State of Ohio, ‘upon their oath do find and present that Jeffery Luke Westerman lale of said County, on or about January 1, 2015 to December 11, 2015, within the County af Franklin aforesaid, in violation of section 1707.44 at the Ohia Revised Cade, with purpose ip deosive, did male, record, or publish or ause to be mad, recorded, or published, azepor of a transaction it secatilies whic was false in any material respect, Furthermore the value of the funds or securities invalved in the affanse or the loss (o the victim is seven thousund five hundzed dollars ox more but less than thirty-seven thousand Five bundced dollars, B08: _fienkin County Obio Clark af Courts of te Ganimen Pleae- 2018 Hee 27 2:08 Pat-1BCRODEI02 0 - Ke Count Three Unlawful Securities Practices, $1707.44, 83, Defendants Tel fery Lark Westerman Date of Offense On or about January 1, 2013 to December 31, 2013 ‘The Jurors of the Grand Jury ofthe State of Ohio, duly selected, impanclod, sviom and charged lo ‘inquire of ecimss and offenses committed within the body of Franklin Coutty, in the State of Ohio, ‘pon theie oath da find and present thal Ieffery Lake Westerman lute of said Counly, on or abou January I, 2013 to December 31, 2013, within uke County of Franklin aforesaid, in violation of section 1707.44 of he Ohio Revised Cade, with purpose to deceive, did make, record, or publish or cause w be made, recorded, ar published, a report of a wansaction in securities which was flso iu any malcrial respect. Furthermore, the value of the funds or securities involved in the offense or the lose to the vietim is seven thoasundl five hundred dollars or more but les than thirty-seven thousand five Jundred dollars, Count Four Unlawful Securities Practices, $1707.44, F3 Detendants ——_Jelfery Luke Westerman Date af Offense On or about Jannary 1. 2013 to December 31, 2013, ‘The Jurors of dhe Grand Jury of the State of Ohi, duly selected, impsncled, sworn and charged to inquiee af erimes and offenses commited within the body of Franklin County, in the State of Ohio, upon their oath do fin and presen: that Jeffery Luke Westerman lute of said County, nor out January 1, 2013 to December 31,2013, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose to deceive, did make. record, or publish or ‘cause us he made, recorded, or published, 4 repor. of « ransaction in securities which was false in any material respect, Furthermore, the value ofthe funds ot securities involved inthe offense or The Joss tn the victim s seven thousand five hundred dollars or mure but less than thisty-seven thousund five ‘hundred dollars. Count Five Unlawful Seeurites Practices, $1707.44, E3 Defendants Jeffery Luke Westerman Date of Offense On or about June 26, 2015 ‘The Jurors of the Grand Jury of the Stawe of Obio, daly selected, impaneled, sworn and charged to inquire of crimes and offenses committed within the body of Franklin County, in the Stat: of Ohio, ‘pon their oath uo ind und present that Jeffery Luke Westerman late of said County, on or about June 26.2015, within the County of Franklin atarossid, in violation of rection 1707.44 of due Ohio Revised Code, did Keowingly make er emuse to be made a false representation converting a matavial 2nd relevant fut, ia any oral statoment of in any prospectus, eicular, description, application, of writen stussment, forthe purpose of sclling any socuritcs in thls state. Tucchermore, the value ofthe funds or securities involved in the offense oF te loss to the victim is seven thousand live hundred dallars or ‘more but loss th thirty-seven thousaad Five hundred dallas, onogd — fit County Obio Clerk of Courts ofthe Common Pless: 2018 Deo 2 2:06 PU-YECRODEDOD Count Six Unlawful Securities Practices, §1707.44, F3 Defendants Jeffery Luke Westerman Date of Offense On or about June 26, 2015 to Deceinber 10, 2018 The Jurors af the Grand Jury ofthe Stave of Ohio, duly selected, impaneled, sworn and charged to ‘nguine of crimes and offenses committed within the body of Hranklin County, in the State of Ohio, pon their aath do ind and present Ut Jeffery Luke Westerman late of said County, on or abont Tune 26, 2015 to December 10, 2018, within the County of Franklin aforesaid, in violation of section 170744 ofthe Obie Rovised Cade, dd, in purchasing or sclling sceuritics, knowingly engage in any acl or practice that was, in Chapter 1707. declared illegal, defined as fraudulent, or prohibited, io wits used IRA fonds for personal expences. Pucihermore, the value of the fends or securities involved in the offense or Ihe Joss lo the victim is seven thousand five hundred dollars or more buLless than thiny-seven thousand five hundred dollars. Count Seven —_inluwfut Securities Practices, $1707.44, F'3 Defendants Jeffery Luke Westerman Date of Offense On or about January §, 2014 to December 31, 2014 ‘The Jurors of the Grand Jury of he Stats of Ohio, duly selected, impaneled, sworn and charged to inquice of crimes and a(fenses commited within the hady of Pranklin County, inthe State of Ohio, upon their oath do find and presen that Jeffery Loke Westerman late of said County, on or about January 1, 2014 to Docember 31, 2014, within the County of Franklin aforesaid, in violation of section 1767-44 ofthe Ohio Reviged Code, with purpose to deceive, did make, record, or publish or ‘couse uo be mau, revorded, ox published, a repo. af a Lrensaction in securities whieh was felse in any ‘material respset, Furthermore, the value ofthe funds or sceuricos involved inthe offense or the loss ‘a the victim s seven thousand five hundred dollars or more but less than thirty-seven thousand five ‘bundved dolla. Count Eight Unlawful Securities Practices, $1707.44, E3 Defeudants —_Jetfery Luke Westerman Date of Offense On cr about January 1, 2014 to December 31, 2014 ‘Tae Jurors of the Grand Jury of te Stare of Ohio, duly selected, impancled, swom and charged to ‘inquire of cimes and offenses comumitted within the bedy of Franklin County. in the Stite of Ohin, pon thelr sath do Dnd and present Uat Jeffery Lake Westeriman late of said County, an or about January 1, 2014 to Deseraber 31, 2014, withia the Couaty of Franklin aforesaid, in viodation of section 1707.44 of the Ohia Revised Chde, with purpose to deceive, did make, cecord, or publis ot ‘cause o be made, recorded, or published, a report ofa iranaaction in securities which was False in any ‘maueral spect. Furthermore the value ofthe [unds ur securities involved inthe aTense or the loss 1 the victim i seven thousand fivs hundred dollars or more Be lest than thicty-seven thousand five unde dallas, onogo - xefferitin County Ohlo Clerk of Courts of the Comman Pss-2018 Dec 27 2:08 P-16CRO06909 Count Nine Un rafal Seeurities Practices, $1707.44, F3, Defeadauts __Teffery Luke Westerman Date af Offense Ou or about January 1, 2013 to December 31, 2013 ‘The Jurors of the Grand Jury ofthe Stale of Ohio, duly selected, imaaneled, sworn and charged to inguise of erimes and offenses committed within Ure body of Franklin County, in the State of Obie, upon Lacir oath do find and present that Jeffery Luke Westerman late of said County, on ar about January 1, 2013 to December 31, 2013, within the Counzy of Frankie aforesaid, in violation of section 1707.44 vf he Ohio Revised Cade, wilh purpose lo deceive, did make, rocord, or publish or ‘cause in bo meds, recorded, or published, a report of a transaction in securities which was false in any material respect. Furtherinore, the value of the funds cr yecurities involved in the offense or he Loss to the victim is even thors five hundroa dollars ar mors but les then thirty-seyen Theusand Five Tondred dolls, Count Ten Utlawful Seeurilies Practices, $1707.44, F1 Defendants Jeffery Luke Westerman Date of Ofense On or sbout Janvary 1, 2014 to December 31. 2014 ‘The Jurors of the Grand Jury ofthe State of Ohio, duly selected, impaneled, sworn and charged to ‘inquire of crimes and offenses coomnitied within the body of Franklin County, ia the State of Ohio, ‘upon dete auth do find and present that To[fery Luke Woslerman late of said County, on or sbant January 1, 2014 to December 31, 2014, within the Coonty of Fraukdin aforesaid, in violation of soction 1707-44 of Lie Ohio Revised Chuls, wih purpose ta deweive, id rouke, reve <r publish or ‘cause un he made, reeortea, ex publised, & operat a rransaction in socestics which wae false in any material respact, Furthermore, the value of the funds or secures iavolved inthe offense or the loss vo the victim is one hundred ‘fly housaad dollars or mare. Count Eleven Unlawful Securities Practicuy, §1707.44, FI Defendants Jeffery Luke Westerman Date of Offense On or about January 1, 2013 to December ‘32, 2013 ‘The Jesors of the Grand Jury of de Staw of Obio. duly selected, impaneted, sworu wd charged t Inguine of erimes and nffense carmmitted within ihe bedly of Franklin County, in the State af Ohio, ‘upon their oath do Find end present that Jeffery Lalke Westcrmaa late of sald County, on or about January 1, 2013 to December 31, 2013, within the County of Franklin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose to deceive, did niake, record, or publi or cause tobe made, recorded, or published, @ eport of unaucton in securities wrich was ise in any material respect. Furthermore, Uns value of the funds oe saaritiex invalved inthe aTense ar the Toss fa the vietien ix ore hundred fifty thousand dallars or more, paowe — xeffshbtia County Ono Clerk of Courts ofthe Common Ploxs- 2018 Dee 27 2:08 PM-18CRI06900 Count Twelve Grand Theft, §2913.02, Fa Defendants ——_deffery Luke Westerman Date of Offense Ou ar about November :8, 2013 te December 31, 2013 ‘The Jurors of the Grand uy of the State of Ohio, duty selected, impaneled, sworn and charged ta ‘nguire of crimes and offenses committed within the body of Franklin County. in the State of Ohio, ‘upon their oath do Fin and present that Jeffery Luke Westerman late of said County, on ar about November 18, 2013 to December 31, 2013, within the County of Franklin afovesai in violation of section 2913.02 af the Ohia Revised Cade, did with porpase to deprive the owner, Racky Miaody, of property ar services, to wis: cash, knowingly obtain or excrt cantral aver cithcr the praperly or services beyond the scope of the express oc implied consent of the awner ar person auchorized to give consent, Forthermore, the property or services stolen is valued at seven thousand five hundred dallars ‘or mere and less than one hundred fifty thousand dollar, ‘Count Thirteen Unlawful Securities Practioes, $1707.44, £2, Dek tums Jeffery Loke Westerman Date of Offense On or about February 24, 2016 vo August 31, 2017 ‘The Jurors of the Grand Jury of the Suis of Ohio, duly selected, impuneled, sworn aad charged to inguire of erimes and offenses committed within the hody of Franklin County, in the Stale af Ohio, upon their ath do find and presen: that Jeffery Luke Westerman late of said County, on or abapt February 24, 2016 19 August 31, 2017, within the County af Franklin aforesaid, in violation of section 1997.44 of the Ohio Revised Code, cid knowingly make or caune to he made a false sepresentation ‘concerning a material and rolovant Ect, in any ofal statement or io any’ prospectos, circular, Aescripcion, application, of written statement, for the purpose of selling any sccurities in this state. Funhermore, the value of the funds or securities involved in the offense or the lass to the vietim is iBirly-seven thousand five hundred dollars or mare but less than ane hundred Fifty housand dollars Count Fourteen Unlawful Securities Practices, $1707.44, F2 Defendants Jeffery Luke Westerman Date of Offense Ou o¢ shout February 24, 2016 10 August 31, 2017 ‘The Furors of the Grand Jury ofthe State of Ohio, duly selected, impancled, sworn and charged to {nguite of crimes and offenses commited witvin the body of Franklin County, in the State of Ohio, ‘upon their oath da find and present that Tellery Luke Westerman late of said County. on of about Februnry 24, 2016 to August 31, 2017, within the County of Franklin aforesuid, ia violation of section 1707-44 of the Ohio Revised Code, di, in purchssing or selling securilis, knowingly engage in uny act or practice that way, in Chaptcr 1707, declared illegal, deinet 4s frandent, or protibiled, to wit: niged IRA funds for personal expenses, Furthermore, the value of the funds or securities involved in the offense ofthe loss tote victim is thirty-seven thousand five hundred dollars or more bot less thar ‘one hundred fifty thousand dollars. onoao - Ké6 Franktin County Ohlo Clerk of Cours of the Common Pleas-2018 Dee 27 2:08 PM-taCRONESCB Count Fifteen Grand Theft, $2913.02, F4 Defendants Jeffery Luke Westerman Date of Offense Ou or sbout Febeuary 24, 2016 to August 31, 2017 ‘The Jurors of the Grand Jury af the State of Ohio, duly selected, impaneled, som and charged to Inquire of erimes and offenses commited within the body of Franklin County. in the Stale of Ohio, upon thcix oath da find and present chat JeiTery Luke Westerman late of said County, eu or about February 24, 2016 fo August 31, 2017, within the Counuy of Franklin aforesaid, in violation of section 2913.02 of the Onio Revised Cade, did with purpose to deprive tho owner, Rodney Moody, of property or services, to wit: cash, kaowingly obuain or exert canteol aver either the property or Services Reyond the scone of the express Or implied congen!.of the owner or person authorized to give ‘consent, Furthermore the propeity or scrviers stolen is valued at seven thousand five hundred dollars Count Sixteen Unlawful Securities Practices, §170744, F2 Defendants Jeffery Luke Westerman Date af Oftenve On or shoot Jemuary 1, 2014 in Devernber 31, 2014 ‘The Jurors of the Grad Jury of the State of Ohio, duly selected, impaneled, sworn and charged to {inquire of crimes and offenses committed withia the body of Franklin County, in the Stare of Ohio, ‘pon their outh do find and prescnt that Jeffery Luke Westerman lat of said County, on or about January 1, 2014 to December 31, 2014, within the County of Frankdin aforesaid, in violation of section 1707.44 of the Ohio Revised Code, with purpose 10 deceive, did make, record, ox publish or ‘eauso'to be made. reeorded, or published, a report of a tangaction in securiticy which was false in any anateral respect. Furthermore, the value of the funds or securities involved in the offense or the loss tw the viclim is thieyy-seven thousand five hundred dallars or nore but less dhan one bundeed fy Thoosund dollars, Count Unlawful Securities Practices, $1707.44, F3 Seventeen Defendants Jeffery Luke Westerman Date of Offense On or about Novorber 7, 2016 ‘The Jurors of the Grand Jury of the Ste of Ohio, duly yelected. impancled, sworn and charged > inquire of crienes and offenses eomioytied within the bady of Franklin County, in the State of Ohio, ‘upon theis oath do Tid and present that JeCTary Luke Westernaa late af said County, on or sbaut November 7, 2016, within the Covnty of Franklin aforesaid, in vilatian af soction 1707.44 af the Ohio Revised Code, did knowingly make or cause io be made a false roprescnistion concerning a ‘material and relevant fact, in any oral statenuentor in any prospectus, circular, description, application, or written stafement, for the purpose of selling any securities in this state. Furthermore, the value of he Funds or securities involved in the offense or the lst 1o de victim is seven thousand [ve hundred dollars ar more hat lcs than thirty-seven thousuad five hundred dollars, onoeo — ffl Sounty Ohio Clerk of Court of he Common Plaae- 2019 Dee 27 2:08 PH-1aCROG620E Count Rightoen Unlawful Securities Practices, $1707.44, £3 Defendants Jeffery Luke Wemerman Date of Offense Ou or about November 7, 2016 to Deceniber 10, 2018 ‘The Jurors ofthe Grand Jury of the Siate of Ohio, duly selected, impancled, sworn and charged to inguite of crimes and offenses committed within the body of Franklin County. in the State of Ohio, ‘upon their oath do find and present that Jelfery Luke Westerman late of said County. en ar about November 7, 2016 te December 10, 2018, within the County of Franklin aforesaid. ia violation of section 1707.44 of the Obie Revised Code, di, in purchasing or selling szcurites, knowingly engage fn any aet or practice that was, in Chapter 1707, declared illegal, defined as fraudulent, or prohibited, to-wit: used investment funds Cor personal eapenses, Furthertnore, the value ofthe funds or securities involved in de offease ar the lass us the victim is seven thousand five hundred dallas or rere but less than thiny-soven thousand five hundred dollars. Count Nineteen ‘Theft From a Persan in a Protected Class, $2913.02, 13 Defondanty ——_Tofflry Luke Westerman Date of Offense On or about November 7, 2016 to December 10, 2018 ‘The Jusrs of the Grand Jury of ue State of Ohio, duly selected, impaneled, sworn and charged to inquite of crimes ond offenses committed within the body of Franklin County, ia the Stale af Ohio, uupem their gat do find and present that Jcfiery Luke Westcrmaa fat of said County. on or bat November 7, 2016 to December 10, 2018. sithin the County of Franklin aforesaid, in violation of section 2913.02 af the Ohia Revised Coat, did with purpore to deprive the owner, Laswrence Lubbers, of property or services to wit cash, knawingly abtain or exert control aver wither the property or serviecs beyond the scope af the express or impliod consent of the owner or person authorized 0 give consent. Furltermore, che victim of the offense is an elderly person, disabled adult active duty service member, or spouse of an active duly service member snd the properly or secvices stolen is ‘value al seven thousand five hundved dollars ar more. onoso - Ko0! Braniain County Ohio Clerk of Courts ol the Cammon Blese- 2018 Dee 27 2:06 PN-18CROO6300 AL 0€ the above conduct being contrary to che form of the siatue in such cases made and provided, and against the peace and digeity ofthe State of Ohio, ATRVE BIN, Ron OBrien Prosecuting Attorney ‘County, Ohio Assistant Prosecuting Attorney to LE Toreperson, Grand fury