— Ur IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY, OHIO STATE OF OHIO, AZ G/ 04 053 A Plaintiff vs. (DICTMENT PETER A. FINGERHUT THOMAS E. STALF Judge David M. Gormley GREGORY A. BELL, Defendants. On the term, Term III Special Session 1S:2 Hd 81 das £202 Count One: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf and Peter A. Fingerhut, on or about 2/23/2011 through 8/18/2021, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did with purpose to deprive the owner, The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association, of property or services, to wit: money/assets, knowingly obtain or exert control over either the property or services by deception, and the value of the property or services stolen more than one million five hundred thousand dollars or more, in violation of 2913.02(A)(3), 2913.02(B)(2) of the Ohio Revised Code, Aggravated Theft, a felony of the first degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Two: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find «and present: Gregory A. Bell, on or about 1/1/2011 and continuing through 5/1/2021 in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did with purpose to deprive the owner, The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association, of money/assets or services, knowingly obtain or exert control over either the property or services by deception, the value of the property or services stolen being more than $500,000.00 or more, but less than $1,000,000.00, in violation of Ohio Revised Code §2913.02(A)(3), 2913.02(B)(2) of the Ohio Revised Code, Aggravated Theft, a felony of the second degree,The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Three: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about December 18, 2018, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did knowingly solicit or accept for himself or another person any valuable thing or.valuable benefit, to. wit: $10,000.00, to corrupt or improperly influence him or another public servant or party official with respect to the discharge of his or the other public servant's or party official's duty, either before or after he was elected, appointed, qualified, employed, summoned, or sworn as a public servant or party official, in violation of Ohio Revised Code §2921.02, Bribery, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Four: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about December 18, 2019, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did knowingly solicit or accept for himself or another person any valuable thing or valuable benefit, to wit: $10,000.00, to corrupt or improperly influence him or another public servant or party official with respect to the discharge of his or the other public servant's or party official's duty, either before or after he was elected, appointed, qualified, employed, summoned, or sworn as a public servant or party official, in violation of Ohio Revised Code §2921.02, Bribery, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Five: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about December 18, 2018, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did with purpose to induce another to do an unlawful act expose or threaten to expose any matter tending to subject Business 1 to hatred, contempt, or ridicule, or to damage Business 1's personal or business repute, or to impair Business 1's credit, in violation of Ohio Revised Code §2905.11(A)(5), Extortion, a felony of the third degree.The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Six: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about December 18, 2019, in Delaware County or by some manner enumerated in Section 2901.12 of the Obio Revised Code whereby proper venue is placed in Delaware County, Ohio, did with purpose to induce another to do an unlawful act expose or threaten to expose any matter tending to subject Business | to hatred, contempt, or ridicule, or to damage Business 1's personal or business repute, or to impair Business 1's credit, in violation of Ohio Revised Code §2905.11(A)(5), Extortion, a felony of the third degree, The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Seven: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Thomas E. Stalf, on or about April 15, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on United States/IRS/United States Department of Treasury falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: 2016 Federal Income Taxes and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count ight: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Thomas E. Stalf, on or about April 15, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on State of Ohio falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: 2016 State of Ohio Income Taxes and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity, in violation of Ohio Revised Code §2913.42, ‘Tampering with Records, a felony of the third degree.The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Nine: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about April 15, 2016, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on United States/IRS/United States Department of Treasury falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: 2015 Federal Income Taxes and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Ten: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about April 15, 2016, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on State of Ohio falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: 2016 State of Ohio Income Taxes and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity, in violation of Ohio Revised Code §2913.42, ‘Tampering with Records, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Eleven: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about April 15, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on United States/IRS/United States Department of Treasury falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: 2016 Federal Income Taxes and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity, inviolation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Twelve: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about April 15, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on State of Ohio falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: 2017 State Income Taxes and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio, Count Thirteen: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about April 15, 2018, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on United States/IRS/United States Department of Treasury falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: 2017 Federal Income Taxes and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the third degree. The offense is contrary to the form of the statute in such cases made and provided, and against the peace and dignity of the State of Ohio. Count Fourteen: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about April 15, 2018, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on the State of Ohio falsify, destroy, remove, conceal,alter, deface, or mutilate any writing, computer software, data, or record, to wit: 2017 State of Ohio Income ‘Taxes and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity, in violation of Ohio Revised Code, §2913.42, ‘Tampering with Records, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Fifteen: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about April 15, 2020, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on the United States/IRS/United States Department of Treasury falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: 2019 Federal Income Taxes and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Sixteen: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about April 15, 2020, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on State of Ohio falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: 2019 State of Ohio Income Taxes and the writing, data, computer software, or record was kept by or belonged to a local, state, or federal governmental entity, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Seventeen: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Gregory A. Bell, on or about November 6, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed inDelaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Credit Card Authorization Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code Section 2913.42, Tampering with Records, a felony of the fourth degree, The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Kighteen: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about October 23, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Credit Card Authorization Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Nineteen: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf and Peter A. Fingerhut, on or about January 17, 2015, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code waereby proper venue is placed in Delaware County, Ohio, did, knowing they had no privilege to do so, and with purpose to defraud or knowing they were facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association, falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoo Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio.Count Twenty: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find aand present. ‘Thomas E. Stalf, on or about March 11, 2015, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form, and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the ‘peace and dignity of the State of Ohio. Count Twenty-One: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf and Peter A. Fingerhut, on or about April 4, 2016, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing they had no privilege to do so, and with purpose to defraud or knowing they were facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the ‘peace and dignity of the State of Ohio. Count Twenty-Two: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Thomas E. Stalf, on or about January 31, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card UsageForm and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Twenty-Three: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf and Gregory A. Bell in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing they had no privilege to do so, and with purpose to defraud or knowing they were facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Twenty-Four: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stal, on or about June 9, 2015, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollar, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of OhioCount ‘Twenty-Five: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas EB, Stalf, on or about July 13, 2015, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing hhe was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollar, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such cases made and provided, and against the peace and dignity of the State of Ohio Count Twenty-Six: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf, on or about September 28, 2015, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Twenty-Seven: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about September 30, 2015, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, 10in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. ‘The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Twenty-Right: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf and Peter A. Fingerhut, on or about December 4, 2015, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing they had no privilege to do so, and with purpose to defraud or knowing they were facilitating a fraud on The Columbus Zoo and ‘Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code § 2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Twenty-Nine: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Thomas E. Stalf, on or about January 6, 2016, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree, The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Thirty: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: uwPeter A. Fingerhut, on or about April 20, 2016, in Delaware County or by some manner ‘enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Thirty-One: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Thomas E. Stalf and Gregory A. Bell, on or about April 26, 2016, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Thirty-Two: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about July 30, 2016, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. 2The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Thirty-Three: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about September 3, 2016, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Thirty-Four: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf, on or about February 3, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Oho Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Thirty-Five: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Thomas B. Stalf, on or about February 8, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in BDelaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the im was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio Count Thirty-Six: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about May 1, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim ‘was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Thirty-Seven: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present Gregory A. Bell, on or about May 1, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. 14Count Thirty-Kight: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf and Peter A. Fingerhut, on or about June 18, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the ‘peace and dignity of the State of Ohio. Count Thirty-Nine: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present ‘Thomas E. Stalf and Gregory A. Bell, on or about June 18, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and wes less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. ‘The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Forty: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about July 28, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any 15writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such cases made and provided, and against the peace and dignity of the State of Ohio. Count Forty-One: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about July 28, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Forty-Two: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Thomas E. Stalf, on or about October 11, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. 16Count Forty-Three: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Gregory A. Bell, on or about November 6, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such cases made and provided, and against the peace and dignity of the State of Ohio. Count Forty-Four: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Gregory A. Bell, on or about December 29, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Forty-Five: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A, Fingerhut, on or about January 20, 2018, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Columbus Zoological Park Credit Card Usage v7Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Forty-Six: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E, Stalf, Gregory A. Bell, and Peter A. Fingerhut, on or about September 20, 2016, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Check Request Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Forty-Seven: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Gregory A. Bell and Peter A. Fingerhut, on or about August 16, 2016, , in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Check Request Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Forty-ight: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: 18Gregory A. Bell and Peter A. Fingerhut, on or about November 22, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Check Request Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the ‘peace and dignity of the State of Ohio. Count Forty-Nine: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Gregory A. Bell and Peter A. Fingerhut, on or about September 1, 2017, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Check Request Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio, Count Fifty: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas A. Stalf, Gregory A. Bell and Peter A. Fingerhut, on or about August 21, 2018, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Check Request Form and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. 19The offense is contrary to the form of the statute in such cases made and provided, and against the peace and dignity of the State of Ohio. Count Fifty-One: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about August 21, 2018, in Delaware County or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on The Columbus Zoo and Aquarium aka the Columbus Zoological Park Association falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Invoice from The Ohio State University and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars, in violation of Ohio Revised Code §2913.42, Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Fifty-Two: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf, on or about the 8th day of February, 2017, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on Columbus Zoo and Aquarium falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Credit Card Authorization Form and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars in violation of Ohio Revised Code §2913.42(A)(1), 2913.42(B)(3)(b), Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Fifty-Three: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut and Thomas E. Stalf, on or about the 19th day of September, 2017, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, having devised a scheme to defraud, did knowingly disseminate, transmit, or cause to be disseminated or transmitted by means of a 20wire, radio, satellite, telecommunication, telecommunications device, or telecommunication service any writing, data, sign, signal, picture, sound, or image with purpose to execute or otherwise further the scheme to defraud and the violation occurred as part of a course of conduct involving other violations of division (A) of this section or violations of, attempts to violate, conspiracies to violate, or complicity in violations of section 2913.02, 2913.04, 2913.11, 2913.21, 2913.31, 2913.42, 2913.43, or 2921.13 of the Revised Code and the value of the benefit obtained by the offender or of the detriment to the victim of the fraud is seven thousand five hundred dollars or more but less than one hundred fifty thousand dollars in violation of Ohio Revised Code §2913.05(A), 2913.05(B); 2913.05(C), Telecommunications Fraud, a felony of the third degree, The offense is contrary to the form of the statute in such case made and provided, and against the ‘peace and dignity of the State of Ohio. Count Fifty-Four: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 19th day of July, 2016, in the county of Delaware or by some ‘manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, having devised a scheme to deftaud, did knowingly disseminate, transmit, or cause to be disseminated or transmitted by means of a wire, radio, satellite, telecommunication, telecommunications device, or telecommunication service any writing, data, sign, signal, picture, sound, or image with purpose to execute or otherwise further the scheme to defraud and the violation occurred as part of a course of conduct involving other violations of division (A) of this section or violations of, attempts to violate, conspiracies to violate, or complicity in violations of section 2913.02, 2913.04, 2913.11, 2913.21, 2913.31, 2913.42, 2913.43, or 2921.13 of the Revised Code and the value of the benefit obtained by the offender or of the detriment to the victim of the fraud is one thousand dollars or more but less than seven thousand five hundred dollars in violation of Ohio Revised Code §2913.05(A), 2913.05(B); 2913.05(C), Telecommunications Fraud, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Fifty-Five: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present Peter A. Fingerhut, on or about the 12th day of April, 2019, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, having devised a scheme to defraud, did knowingly disseminate, transmit, or cause to be disseminated or transmitted by means of a wire, radio, satellite, telecommunication, telecommunications device, or telecommunication service any writing, data, sign, signal, picture, sound, or image with purpose to execute or otherwise further the scheme to defraud and the violation occurred as part of a course of conduct involving other 2violations of division (A) of this section or violations of, attempts to violate, conspiracies to violate, or complicity in violations of section 2913.02, 2913.04, 2913.11, 2913.21, 2913.31, 2913.42, 2913.43, or 2921.13 of the Revised Code and the value of the benefit obtained by the offender or of the detriment to the victim of the fraud is seven thousand five hundred dollars or more but less than one hundred fifty thousand dollars in violation of Ohio Revised Code §2913.05(A), 2913.05(B); 2913.05(C), Telecommunications Fraud, a felony of the third degree. The offense is contrary 10 the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Fifty-Six: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 7th day of May, 2019, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, having devised a scheme to defraud, did knowingly disseminate, transmit, or cause to be disseminated or transmitted by means of a wire, radio, satellite, telecommunication, telecommunications device, or telecommunication service any writing, data, sign, signal, picture, sound, or image with purpose to execute or otherwise further the scheme to defraud and the violation occurred as part of a course of conduct involving other violations of division (A) of this section or violations of, attempts to violate, conspiracies to violate, or complicity in violations of section 2913.02, 2913.04, 2913.11, 2913.21, 2913.31, 2913.42, 2913.43, or 2921.13 of the Revised Code and the value of the benefit obtained by the offender or of the detriment to the victim of the fraud is one thousand dollars or more but less than seven thousand five hundred dollars in violation of Ohio Revised Code §2913.05(A), 2913.05(B); 2913.05(C), Telecommunications Fraud, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Fifty-Seven: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 7th day of May, 2019, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on Columbus Zoo and Aquarium falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: An Invoice and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars in violation of Ohio Revised Code §2913.42(A)(1), 2913.42(B)(3)(b), Tampering with Records, a felony of the fifth degree. 22The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Fifty-Kight: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 15th day of July, 2014, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on Columbus Zoo and Aquarium falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Dublin Irish Festival Invoice and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars in violation of Ohio Revised Code §2913.42(A)(1), 2913.42(B)(3)(b), Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Fifty-Nine: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 4th day of December, 2015, in the county of Delaware ot by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he} had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on Columbus Zoo and Aquarium falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Dublin Irish Festival Invoice and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars in violation of Ohio Revised Code §2913.42(A)(1), 2913.42(B)(3)(b), Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Sixty: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present Peter A. Fingerhut, on or about the 18th day of July, 2016, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on Columbus Zoo and Aquarium falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: 23Dublin Irish Festival Invoice and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars in violation of Ohio Revised Code §2913.42(A)(1), 2913.42(B)(3)(b), Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Sixty-One: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 16th day of December, 2016, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on Columbus Zoo and Aquarium falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Dublin Irish Festival Invoice and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars in violation of Ohio Revised Code §2913.42(A)(1), 2913.42(B)(3)(©), Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Sixty-Two: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaviare County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut and Thomas B. Stalf, on or about the 11th day of December, 2017, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on Columbus Zoo and Aquarium falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Dublin Irish Festival Invoice and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars in violation of Ohio Revised Code §2913.42(A)(1), 2913.42(B)(3)(©), Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Sixty-Three: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: 24Peter A. Fingerhut, on or about the 17th day of December, 2017, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on Columbus Zoo and Aquarium falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Dublin Irish Festival Invoice and the value of the data or computer software involved in the offense or the loss to the victim was seven thousand five hundred dollars or more and was less than one hundred fifty thousand dollars in violation of Ohio Revised Code §2913.42(A)(1), 2913.42(B)(3)(c), Tampering with Records, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Sixty-Four: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A, Fingerhut, on or about the 10th day of December, 2018, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did, knowing he had no privilege to do so, and with purpose to defraud or knowing he was facilitating a fraud on Columbus Zoo and Aquarium falsify, destroy, remove, conceal, alter, deface, or mutilate any writing, computer software, data, or record, to wit: Dublin Irish Festival Invoice and the value of the data or computer software involved in the offense or the loss to the victim was one thousand dollars or more and was less than seven thousand five hundred dollars in violation of Ohio Revised Code §2913.42(A)(1), 2913.42(B)(3)(b), Tampering with Records, a felony of the fifth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Sixty-Five: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 18th day of July, 2016, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, having devised a scheme to defraud, did knowingly disseminate, transmit, or cause to be disseminated or transmitted by means of a wire, radio, satellite, telecommunication, telecommunications device, or telecommunication service any writing, data, sign, signal, picture, sound, or image with purpose to execute or otherwise further the scheme to defraud and the violation occurred as part of a course of conduct involving other violations of division (A) of this section or violations of, attempts to violate, conspiracies to violate, or complicity in violations of section 2913.02, 2913.04, 2913.11, 2913.21, 2913.31, 2913.42, 2913.43, or 2921.13 of the Revised Code and the value of the benefit obtained by the offender or of the detriment to the victim of the fraud is one thousand dollars or more but less 25,than seven thousand five hundred dollars in violation of Ohio Revised Code §2913.05(A), 2913.05(B); 2913.05(C), Telecommunications Fraud, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Sixty-Six: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find «and present: Peter A. Fingerhut, on or about the 10th day of December, 2018, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, having devised a scheme to defraud, did knowingly disseminate, transmit, or cause to be disseminated or transmitted by means of a wire, radio, satellite, telecommunication, telecommunications device, or telecommunication service any writing, data, sign, signal, picture, sound, or image with purpose to execute or otherwise further the scheme to defraud and the violation occurred as part of a course of conduct involving other violations of division (A) of this section or violations of, attempts to violate, conspiracies to violate, or complicity in violations of section 2913.02, 2913.04, 2913.11, 2913.21, 2913.31, 2913.42, 2913.43, or 2921.13 of the Revised Code and the value of the benefit obtained by the offender or of the detriment to the victim of the fraud is one thousand dollars or more but less than seven thousand five hundred dollars in violation of Ohio Revised Code §2913.05(A), 2913.05(B); 2913.05(C), Telecommunications Fraud, a felony of the fourth degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Sixty-Seven: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 13th day of January, 2020, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, having devised a scheme to defraud, did knowingly disseminate, transmit, or cause to be disseminated or transmitted by means of a wire, radio, satellite, telecommunication, telecommunications device, or telecommunication service any writing, data, sign, signal, picture, sound, or image with purpose to execute or otherwise further the scheme to defraud and the violation occurred as part of a course of conduct involving other violations of division (A) of this section or violations of, attempts to violate, conspiracies to violate, or complicity in violations of section 2913.02, 2913.04, 2913.11, 2913.21, 2913.31, 2913.42, 2913.43, or 2921.13 of the Revised Code and the value of the benefit obtained by the offender or of the detriment to the victim of the fraud is one thousand dollars or more but less than seven thousand five hundred dollars in violation of Ohio Revised Code §2913.05(A), 2913.05(B); 2913.05(C), Telecommunications Fraud, a felony of the fourth degree. 26The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Sixty-Eight: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present; Peter A. Fingerhut, on or about the 10th day of December, 2018, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did conduct or attempt to conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity in violation of Ohio Revised Code §1315.55(A)(3), 1315.99(C), Money Laundering, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Sixty-Nine: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 29th day of September, 2017, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did conduct or attempt to conduct a transaction with the Purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity in violation of Ohio Revised Code §1315.55(A)G), 1315.99(C), Money Laundering, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Seventy: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf, on or about the 11th day of October, 2017, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is, placed in Delaware County, Ohio, did conduct or attempt to conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corupt activity in violation of Ohio Revised Code §1315.55(A)@), 1315.99(C), Money Laundering, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. aCount Seventy-One: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingeriut, on or about the 23rd day of October, 2017, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did conduct or attempt to conduct a transaction with the Purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity in violation of Ohio Revised Code §1315.55(A)@), 1315.99(C), Money Laundering, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Seventy-Two: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 20th day of January, 2018, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is, placed in Delaware County, Ohio, did conduct or attempt to conduct a transaction with the Purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity in violation of Ohio Revised Code §1315.55(A)(3), 1315.99(C), Money Laundering, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Seventy-Three: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf, on or about the 5th day of March, 2018, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did conduct or attempt to conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity in violation of Ohio Revised Code §1315.55(A)3), 1315.99(C), Money Laundering, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Seventy-Four: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: 28Peter A. Fingerhut and Thomas E. Stalf, on or about the 18th day of June, 2017, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did conduct or attempt to conduct a ‘transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity in violation of Ohio Revised Code §1315.55(A)(3), 1315.99(C), Money Laundering, a felony of the third degree, The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Seventy-Five: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf, on or about the 18th day of February, 2017, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did conduct or attempt to conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity in violation of Ohio Revised Code §1315.55(A)(3), 1315.99(C), Money Laundering, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Seventy-Six: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: ‘Thomas E. Stalf, on or about the 27th day of April, 2016, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did conduct or attempt to conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity in violation of Ohio Revised Code §1315.55(A)(3), 1315.99(C), Money Laundering, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Seventy-Seven: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 9th day of December, 2015, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did conduct or attempt to conduct a transaction with the Purpose to promote, manage, establish, carry on, or facilitate the promotion, management, 29establishment, or carrying on of corrupt activity in violation of Ohio Revised Code §1315.55(A)@), 1315.99(C), Money Laundering, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Seventy-Eight: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Peter A. Fingerhut, on or about the 9th day of June, 2015, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did conduct or attempt to conduct a transaction with the Purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity in violation of Ohio Revised Code §1315.55(A)(@), 1315.99(C), Money Laundering, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Seventy-Nine: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Thomas E. Stalf, on or about the 6th day of April, 2015, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did conduct or attempt to conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity in violation of Ohio Revised Code §1315.55(A)G), 1315.99(C), Money Laundering, a felony of the third degree. The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of Ohio. Count Kighty: The Jurors of the Grand Jury of the State of Ohio, within and for the body of Delaware County, on their oaths, in the name and by the authority of the State of Ohio, do find and present: Thomas E, Stalf and Peter A. Fingerhut, in the county of Delaware or by some manner enumerated in Section 2901.12 of the Ohio Revised Code whereby proper venue is placed in Delaware County, Ohio, did while employed by, or associated with, any enterprise did conduct or participate in, directly or indirectly, the affairs of the enterprise through a pattem of corrupt activity and at least one of the incidents of corrupt activity was a felony of the first, second, or third degree, in violation of Ohio Revised Code §2923.32, Engaging in a Pattern of Corrupt Activity, a felony of the first degree. 30INTRODUCTION During the period January 1, 2011 through August 1, 2021, the individuals listed below engaged in criminal activity by acting individually and collectively in a largescale covert scheme to defraud the Columbus Zoo of over $2,290,000.00. The Columbus Zoo is the jewel of Delaware County. Upper management of the Columbus Zoo including but not limited to its CEO, CFO, and Director of Marketing hijacked the purse strings of the Columbus Zoo, colluding to conceal the nature of their spending or thievery which amounts to more than $2,290,000.00 of Columbus Zoo money on the following: a. Concert tickets ». Tickets to sporting events in the Columbus area and elsewhere ¢. Golf club memberships at Kinsale and Wedgewood 4. Trips to Germany, Hawaii, Great Wolf Lodge ¢. Clothing, sports equipment £ Meals, beverages, and alcohol g. Electronics hb. Fumiture i, Services j. Miscellaneous non-Zoo related items, e.g., ‘Tunes, SiriusXM k. Motor vehicles 1. Suites, loges and special seats at Nationwide Arena and the Schottenstein Center m. Entertainment tickets all for personal or family use. ‘To accomplish the theft, three key members of management, Defendants Stalf, Fingerhut, and Greg Bell, conspired to develop and execute a way to mask the personel spending so that they could live off Columbus Zoo money. When it came time to pay for the tickets, suites, loges or food, beverages and alcohol related to those events, it was agreed upon that coding would be used such as: tickets for board members and donors, meals for board members or donors, food and drinks for donors, food and drinks for board members, and one that Fingerhut liked the most, “promotional support.” By using these codes, reasons, or excuses for the charge on a Zoo-owned credit card or a Zoo Check Request form as a reason that the Zoo should cut a check to pay a bill, these officials were able to get past the accounting system and checks and balance system which the Zoo had in place so that they could steal in excess of $2,290,000.00. ‘The Zoo has/had a policy in Section 6.3 of its employee handbook which provided: “Purchasing Personal Items: Personal items cannot be charged to the Zoo. This is true regardless of whether or not the charges incurred are subsequently reimbursed back to the Zoo by employees.” 31This policy was grossly violated. To farther accomplish their scheme to defraud the Zoo, Greg Bell, Stalf, John Doe 1, and Fingerhut stole from the Zoo’s barter system. The Zoo had a barter account. The account was managed by barter management companies IMS and ITEX, each of which operate similarly. The Zoo “sells” or lists for exchange tickets to the Zoo, Zoombezi Bay, and the Safari Golf Course on the barter account and, in return, receives credit to spend at other vendors within the barter network. This arrangement has been in place for several decades. If a vendor such as an office supply company wanted to trade office supplies for Zoo tickets, such would occur. The Zoo’s credit balance increased significantly over the years since there were fewer reciprocal options for the Zoo to spend its credit. Stalf, Fingerhut, Bell and others stole Zoo assets or money from the Barter account to go to sporting events or on trips, i.e. Game 6 of the 2016 World Series, high end bicycles, party buses or a family vacation in Florida. To further the scheme to defraud, Fingerhut threatened a Zoo vendor, Business 1, with harm to it unless it paid him $10,000.00 in 2019 and $10,000 in 2020. For nearly a decade Fingerhut victimized Business 1 by exploiting Business 1's relationship with the Zoo for his personal benefit to pay for gift cards, vacations, expensive cigars and other items. Further, Fingerhut and Greg Bell, with the knowledge of Stalf, instructed Business 1 to falsify billing invoices to the Zoo so that the Zoo would pay for personal expenses of Fingerhut, Greg Bell, and Stalf including but not limited to a birthday party, entertainment, trips, tickets to sporting events and other expenses. To further accomplish their scheme to defraud, upper management treated Zoo cash, Zoo alcohol, Zoo beer, and Zoo assets as if he or they owned it. Once the Board of Directors of the Zoo ordered those in charge of operating the Zoo to cease purchasing tickets, seats, suites, and loges, Fingerhut had vendors receive a bill from Nationwide Arena, PromoWest or the Dublin Irish Festival and pay the bill themselves, then bill the zoo for the amount of the invoice from Nationwide Arena. PromoWest or the Dublin Irish Festival thereby hiding the true reason for the expenditure. To further the scheme to defraud and/or to further his stature with the Zoo and in the community, Stalf demanded favors, services or other benefits from Business 4, a z00 vendor. ‘THE ENTERPRISE This Enterprise is an association and/or organization and/or a group of persons and/or companies associated in fact, although not a legal entity, including but not limited to Tom Stalf (former CEO of the Zoo), Greg Bell (Former CFO of the Zoo), Peter Fingerhut, John Doe 1, Jane Doe 1, Jane Doe 2, John Doe 5, John Doe 6, Business 5, Grant Bell, and others known and not known all of whom are persons associated with the Enterprise (collectively, “Persons associated with the Enterprise” or “Persons”). This Enterprise existed as an “Association in Fact Enterprise” under R.C. Section 2932.32 because it: (1) was an ongoing organization with a commonality of purpose or a guiding mechanism to direct the organization or (2) was a continuing unit with an ascertainable structure and/or (3) had an organizational structure that was distinct from the 32pattem of predicate acts. As an altemative to point (3), this Enterprise is an illicit enterprise under R. C. Section 2932.32 because it had an organizational structure distinct from the pattern of predicate acts whether or not this enterprise performed any legal acts. The persons and/or companies associated with the Enterprise performed, from time to time, some lawful acts while working for entities connected with the Enterprise, and as a result, this Enterprise existed separate and apart from the pattern of corrupt activity described in this Indictment. A. THE PARTIES 1. Thomas “Tom” E. Stalf was the CEO of the Zoo until he resigned in the Spring of 2021 Stalf had free rein to operate and control Zoo operations thus hiding his conduet and the conduct of others from the Board of Directors. 2. Gregory “Greg” D. Bell was the CFO of the Zoo until he also resigned in the Spring of 2021. Peter “Pete” A. Fingerhut was the Director of Marketing of the Zoo until he was let go in early 2021. 4. John Doe 5 was a Zoo employee who arranged for Tom Stalf to meet John Doe 4 of Business 4. 5. John Doe 4 owns Business 4. Business 4 and John Doe 4 provided Stalf with benefits in return for work at the Zoo, 6. John Doe was a person who worked for the Zoo. 7. Grant Bell worked in purchasing for the Zoo and is the son of Greg Bell. 8. Business 1 is 2 company or Zoo vendor extorted by Fingerhut to pay him two (2) $10,000.00 cash payments in addition to providing Fingerhut with other “favors.” 9. Business 2 is a company owned by a Zoo employee. 10, Business 5 was a vendor to the Zoo. 11. Business 6 was a vendor to the Zoo. 12, John Doe 6 owned and operated Business 5 and Business 6 13. John Doe 2 is a Franklin County, Ohio Businessman. 14, John Doe 3 is a Franklin County, Ohio Businessman, 15. Jane Doe 1 owned a company which was a Zoo vendor. 16. Jane Doe 2 is a relative of an executive at the Zoo, » B. THE PLAN OF THE ENTERPRISE AND ITS HIERARCHY The plan of the Enterprise and its function was to steal money from the Zoo and/or to “shake down" vendor(s) or threaten directly or indirectly such vendor(s) so that the executives who ran the day to day operations of the Zoo could enrich themselves and to hide what they were doing using an elaborate scheme of deception and to continue to steal money and services. Enrichment occurred in many ways including but not limited to: sporting events, food and drink at sporting events, vacations, directly pocketing cash, and motor vehicles. Many benefited from this thievery, some unwittingly, including spouses, relatives and adult children of these men. The primary tool used to enrich themselves was the Credit Card Authorization or Usage form or the Check Authorization form used by the Zoo to pay its bills. Defendant Fingerhut had his 33expense reports approved by CFO Bell. CFO Bell had his expense reports approved by Defendant Stalf and Defendant Stalf had his expense reports approved by CFO Bell. The three conspired to create a system of abuse whereby the three men, minimally accompanied by John Doe 1, were successful in exercising control by deception of more than $2,290,000.00 in Zoo funds. CFO Bell signed most if not all of the authorization forms knowing that the forms were fraudulent. In some instances, not only was the reason for the expense false, the expense itself was false. When Zoo staff questioned questionable expenses, their questions were ignored. When Greg Bell attempted to follow the law and provide Stalf and Fingerhut with an income document, Bell’s job was threatened by Stalf. The Board of Directors was not aware of and did not endorse the conduct of Stalf, Bell, Fingerhut, or anyone else who may have broken the law in this Enterprise. In addition to the Credit Card Authorization or usage form and the Check Authorization form, members of this Enterprise stole the following, often times with the knowledge of one another: alcohol, beer, items offered for exchange on the Barter network such as high-end bicycles, Game 6 World Series tickets, cash, services such as satellite radio, patio furniture, clothing, golf clubs, a safe, an RV, vacations, barter items, party bus rides for birthdays and weddings and other items. In addition, Zoo funds were deceptively used for family vacations, trips to Germany, Florida and Hawaii, traveling to Oklahoma for an Ohio State vs. Oklahoma football game, and several questionable trips to Florida, Tennessee, Washington D.C., New York, and other places. Within the scope of the Enterprise and to further it affairs, Fingerhut, Stalf, Greg Bell, and John Doe 1 were aware of the contents of the Zoo employee policy handbook which in part in Section 6.3 provided that: “Purchasing Personal Items: Personal items cannot be charged to the Zoo. This is true regardless of whether or not the charges incurred are subsequently reimbursed back to the Zoo by employees.” Within the scope of this Enterprise and to further is affairs, Fingerhut, Stalf, Greg Bell, Grant Bell and John Doe 1 possessed or had access to credit cards which were in the name of the Zoo and for which expenses related to the Zoo could be purchased. Within the scope of this Enterprise and to further its affairs, Fingerhut used his Zoo-issued eredit card to make thousands of dollars of purchases of goods, items, or personal property at Kinsale Country Club and Scioto Reserve. Within the scope of this Enterprise and to further its affairs, members of the Fingerhut family also charged personal items to the Zoo-issued credit card possessed by Peter Fingerhut at either of these two golf courses, such as boxing classes, clothing, and alcohol. Within the scope of this Enterprise and to further its affairs, when complaints about Fingerhut and his family spending Zoo money at these country clubs were made to Stalf, Stalf ignored them.Within the scope of this Enterprise and to further its affairs, Tom Stalf and/or his family used his Zoo-issued credit card to make thousands of dollars of purchases of goods, items, or personal property at Kinsale Country Club and Scioto Reserve and use the credit at such clubs to supply food and beverages to friends of their children. Within the scope of this enterprise and to further its affairs, Greg Bell and/or his family used his Zoo-issued credit card to make thousands of dollars of purchases of goods, items, or personal property at Kinsale Country Club and Scioto Reserve. Within the scope of this enterprise and to further its affairs, Fingerhut falsified credit card authorization forms or check authorization forms by placing false reasons for the expense on such form thereby masking or concealing the true expense so that that the Zoo would pay for Fingerhut to carouse, travel, eat, socialize, and further conduct his personal life, Within the scope of this Enterprise and_to further its affairs, Stalf falsified credit card authorization forms or check authorization forms by placing false reasons for the expense on such form thereby masking or concealing the true expense so that that the Zoo would pay for Stalf and his family’s personal entertainment, socialize, and further conduct his personal life. Within the scope of this Enterprise and to further its affairs, Greg Bell falsified credit card authorization forms or check authorization forms by placing false reasons for the expense on such form thereby masking or concealing the true expense so that that the Zoo would pay for Bell and his family’s personal entertainment, socialize, and further conduct his personal life. Within the scope of this Enterprise and to further its affairs, Fingerhut negotiated the leasing of a suite and a loge at Nationwide Arena knowing it would be for personal use for himself, Stalf, Greg Bell, John Doe 1, and their families. Within the scope of this Enterprise and to further its affairs, Fingerhut negotiated the leasing of a suite at the Schottenstein Center knowing it would be for personal use for himself, Stalf, Greg Bell, John Doe 1, and their families. Within the scope of this Enterprise and to further its affairs, Fingerhut, Stalf and Bell at one point in time signed the leases in question. Fingerhut specifically requested that the Zoo name not be placed on the suite or loge as is customary thereby concealing the fact that the Zoo, a non-profit 501(c)(3), leased a suite. Within the scope of this Enterprise and to further its affairs, Fingerbut used a falsified Credit Card Usage form or Check Authorization or Usage form to purchase tickets at Nationwide Arena, at the Schottenstein Center, at other venues in the Columbus area, to travel to Norman, Oklahoma for an Ohio State/Oklahoma football game, and to purchase alcohol, food, and beverages at Nationwide Arena, the Schottenstein Center, Huntington Park, and other entertainment venues in the Columbus area, as well as restaurants, bars and similar establishments in Ohio. 35Within the scope of this Enterprise and to further its affairs, Fingerhut, Greg Bell, and Stalf converted and spent more than $1,800,000.00 of Zoo money at Nationwide Arena, the Schottenstein Center, Huntington Park, and other similer venues over a period of time on personal expenses at hockey games, concerts, baseball games, basketball games, or other events at these venues. Within the scope of this Enterprise and to further its affairs, John Doe 1 and Stalf used Business 5 as a strawman to sell personal vehicles to the Zoo at a profit, concealing the fact that it was the Zoo buying their personal car(s). Within the scope of this Enterprise and to further its affairs, John Doe 1 purchased vehicles for the Zoo using Business 5°s name. Business 5 then sold such vehicles to the Zoo at a price determined by John Doe 1 and Greg Bell and at a profit for Business 5. Business 5/John Doe 5 on several occasions kicked money back from the sale of these vehicles to John Doe 1 or a member of his family. Within the scope of this Enterprise and to further its affairs, Stalf stole bottles of alcohol and beer ‘from the Zoo warehouse for parties at his personal residence several times a year over a 5 to 6- year period of time. Within the scope of this Enterprise and to further its affairs, Stalf, Greg Bell, and John Doe 1 used the Zoo barter system to enrich themselves by having the Zoo pay for items on the barter system for their own personal use such as World Series Tickets for Stalf, high-end bicycles for Stalf, limo rides for Stalf, limo rides for John Doe 1 or members of his family, personal items for Greg Bell and/or his family, and condos for a Florida vacation for Stalf and his family. Within the scope of this enterprise and to further its affairs, John Doe 1 and a member of his family started a family business run by John Doe 1 and a family member and, concealing the identity of ownership of this business, provided a service to the Zoo which was unnecessary. In addition, John Doe 1 overbilled the Zoo for the services he performed and used the Zoo credit card he possessed or had access to, to buy the goods and materials for this company to operate. Greg Bell was aware of this operation and permitted it to happen. Within the scope of this enterprise and to further its affairs, Stalf purchased an RV with Zoo moneys, having Greg Bell wire the funds to the seller under the pretense that the RV would be housed at the Wilds in Muskingum county and used at the Wilds when in fact Stalf converted the RV to his personal RV. Stalf used the RV to travel to Put-In-Bay for a weekend and other places. Within the scope of this enterprise and to further its affairs, Greg Bell and Stalf rented Zoo- owned real estate to family members at far less than the fair market value of the rental value of said property, and furthermore, the Zoo paid to remodel the property Stalf had his relatives live in and paid for the patio furniture for said property through the Barter system. Within the scope of this enterprise and to further its affairs, the Zoo paid for satelite radio for the personal vehicles of members of this Enterprise including family members and/or their spouses. 36Within the scope of this enterprise and to further its affairs, John Doe 4 paid Tom Stalf benefits including trips to sporting events on an airplane John Doe 4 leased and constructing a bam addition at a Joss to Business 4. Within the scope of this enterprise and to further its affairs, after John Doe 4 provided Stalf with benefits and agreed to and did provide more benefits to Stalf, Stalf awarded John Doe 4/ Business 4 with a $2,300,000.00 no bid contract. Within the scope of this Enterprise and to further its affairs, after the construction of several cabins at the Wilds, Stalf ordered Greg Bell to pay John Doe 4 the sum of $125,000.00 to pay for a change order with no supporting data, four months after the final payment was made on the contract for the full approved amount of the project and during a time when Business 4 was in financial trouble. Within the scope of this enterprise and to further its affairs, Stalf ordered Greg Bell to pay the suspicious change order mentioned above almost immediately after Zoo/Wilds staff began to question the alleged change order in violation of Zoo payment protocol. Within the scope of this Enterprise and to further its affairs, Fingerhut solicited in December of 2018 and in December of 2019, and received each time, $10,000.00 in cash from Business 1. Within the scope of this Enterprise and to further its affairs, Fingerhut advised Business 1 that unless it provided him with $10,000.00 in December of 2018 that the contract that Business 1 had with the Zoo would be put up for bid and a competitor of Business | could get the contract. Within the scope of this Enterprise and to further its affairs, Fingerhut then bought representatives lunch or dinner when he was extorting $10,000.00 from them and billed the expense of the lunch or dinner to the Zoo under false pretenses. He did such on consecutive years and also placed on his outlook calendar that he was meeting that these people. Within the scope of this Enterprise and to further its affairs, Greg Bell and Fingerhut coerced Business 1 into paying for Fingerhut’s wife’s birthday party. Further, Fingerhut coerced Business 1 into paying for a hundreds of dollars of gift cards for Fingerhut as well as a Hawaii vacation for Fingerhut and his family, a trip to Germany, and Fingerhut’s table at the Dublin Irish Festival. Within the scope of this Enterprise and to further its affairs, Peter Fingerhut cut and pasted vendor invoices, changing the true purpose of an invoice into a false purpose such as “Promotional Spending” so that Fingerhut could trick the Zoo into paying for his personal expenses. Within the scope of this Enterprise and to further its affairs, Peter Fingerhut and Tom Stalf generated income for themselves which is reportable as 1099 income, When the Form 1099 was prepared and in the process of being provided to them by Greg Bell, Stalf threatened to fire Bell if Bell handed them or him the 1099. Further, the 1099 was destroyed or not provided. 37Within the scope of this Enterprise and to further its affairs, Stalf and Fingerhut committed Tampering with Records by lying on their Federal and/or State Income tax returns by not reporting income eared. Within the scope of this Enterprise and to further its affairs, after developing a scheme to defraud the Zoo Stalf, Greg Bell, and/or Fingerhut used a telecommunication device or telecommunications devices to email data or records in furtherance of their scheme to defraud. Within the scope of this Enterprise and to further its affairs, after developing a scheme to defraud the Zoo, Fingerhut induced Zoo Vendors to use a telecommunication device or telecommunications devices to email data or records in furtherance of his scheme to defraud the Zoo. Within the scope of this Enterprise and to further its affairs, Peter Fingerhut lied to State Agents ‘when he was interviewed by State Agents in May 2023, Within the scope of this Enterprise and to further its affairs, Greg Bell, Fingerhut and Stalf conducted or attempted to conduct a transaction with the purpose to promote, manage, establish, carry on, or facilitate the promotion, management, establishment, or carrying on of corrupt activity, to wit: theft, when they conducted a credit card or check transaction conceming their true expenditures at Nationwide Arena, the Schottenstein Center or other similar places Within the scope of this Enterprise and to further its affairs, Greg Bell pocketed cash from the sale of Zoo property. Within the scope of this Enterprise and to further its affairs, Stalf used the Barter system to: 1, Secure Les Misérables Tickets for his wife 2. Secure Game 6 or other World Series tickets for himself in 2016 3, Secure Hamilton tickets 4, Secure limo service 5. Agree with his wife on the securing of patio furniture 6. Vacation with the family in Florida 7. Seoure van Transportation 8, Assist with moving his in-laws Within the scope of this Enterprise and to further its affairs, John Doe | used the barter system to secure concert tickets for his adult children and for other personal desires. C, COMMON PURPOSE OF THE ENTERPRISE This Enterprise functioned as an ongoing organization with commonality of purpose or a guiding mechanism to direct the organization. From at least January 1, 2011, to August 1, 2021 the common purpose of the Enterprise regarding its ongoing illegal conduct was to steal money or covert money, property, or services owned by the Zoo, permanently depriving the Zoo of such property or services and to hide their conduct. Additionally, member(s) of the criminal 38Enterprise made false statements to investigators, i.e. Peter Fingerhut, investigating the activities of the enterprise and those within it in an attempt to cover up acts committed. As stated above, each Person Associated with the Enterprise performed separate acts on behalf of and in furtherance of the Enterprise. The persons associated with this Enterprise were members of other entities so they needed to act in a structured and in an organized manner to enable the overall organization to successfully complete these schemes. Likewise, this occurred with the knowledge and/or support of other Persons Associated with the Enterprise in order that this Enterprise, as an association in fact, could continue and thrive because of the activities of each of the persons of the Enterprise. This Enterprise functioned as a continuing unit with an ascertainable structure while it was engaging in the diverse forms of illegal activities. In doing so from the time stated herein, the Persons Associated with the Enterprise participated in and/or managed the affairs of the Enterprise as previously stated. As such, these persons provided continuity and structure to the Enterprise in order to accomplish its illegal purposes—the pattem of corrupt activity as set forth in this count. This Enterprise and the Persons Associated with the Enterprise were joined in purpose over a period of time, with various roles that were different, and with methods that changed in order to accomplish the main purpose of the Enterprise. ‘The structure of the organization, as an Enterprise in fact: Fingerhut negotiated contracts for the leasing of suites and loges purportedly on behalf of the Zoo but in reality, on behalf of himself, Greg Bell and Stalf. Greg Bell, Stalf, and Fingerhut signed off on the contracts at one point in time or another. Then each began their scheme to defraud the Zoo of money. Greg Bell as the CFO approved all payments and expenditures. Stalf as the CEO was aware that himself, Greg Bell, Fingerhut, and John Doe 1 were converting Zoo property to their own use, and he permitted it, Stalf found property he liked on the Barter network or elsewhere he then ordered Greg Bell to pay for it out of Zoo money despite the fact the property was for his personal or his family’s personal use, Stalf and Fingerhut solicited and receive benefits from Zoo Vendors to corrupt themselves. This Enterprise is comprised of the Persons Affiliated with the Enterprise, all of whom acted with the purpose described in this Indictment, and all of whom conducted their activities over a period of time for a common purpose. This Enterprise, as an informal association comprised of the Persons Associated with the Enterprise, functioned as a continuing unit, separate from the pattern of activity in which it engaged because one or more persons associated with this Enterprise performed legal acts as described herein. The non-exclusive list of lawful activities described herein occurred while this Enterprise functioned as a continuing unit and with an organization structure which engaged in diverse forms of illegal activities as stated in this Indictment. While the persons associated with the Enterprise may have performed, from time to time, some lawful acts as described above, while working for entities connected with the Enterprise, these Persons, however, also performed illegal acts as part of and in furtherance of this Enterprise, as stated in this Indictment. Based on the foregoing, this Enterprise existed separate and apart from 39