22CP210500, 22CP210896,

CC
22CP211078, 22CP212559, INDICTMENT
22CP212599, 23CP220152 7.
Dunaway
Fulton County Superior Court
"FILED** ET Clerk No. AYSC.00/723
Date: 04/23/2024 FULTON SUPERIOR COURT
Che Alexander, Clerk of Court
THE STATE OF GEORGIA 1 VIOLATION OF THE GEORGIA RICO
(RACKETEER INFLUENCED AND CORRUPT
ORGANIZATIONS) ACT
0.C.G.A. § 16-14-4(a)
EARNEST WILLIAMS,
AKA EARNEST LEVELT 2 FALSE SWEARING
WILLIAMS, 0.C.G.A. § 16-10-71
AKA "NESTO"
Counts 1-39 3 FILING FALSE DOCUMENTS
DA No.: 22DA07995 0.C.G.A. § 16-10-20.1

ERICA KING, 4 BIGAMY

AKA ERICA HUGHLEY, 0.C.G.A. § 16-6-20
AKA ERICKA HUGHLEY
Counts 7-14, 17-21, 32-35, 37-38 5 THEFT BY TAKING
DA No.: 22DA07755 0.C.G.A. § 16-8-2

6 THEFT BY TAKING
O.C.G.A. § 16-8-2

7 CONSPIRACY TO COMMIT
UNAUTHORIZED PRACTICE OF LAW
O.C.G.A. §§ 16-4-8 & 15-19-51

FILING FALSE DOCUMENTS

0.C.G.A. § 16-10-20.1

9 IDENTITY FRAUD
O.C.G.A. § 16-9-121

10 IDENTITY FRAUD
0.C.G.A. § 16-9-121

11 IDENTITY FRAUD
0.C.G.A. § 16-9-121

12 FILING FALSE DOCUMENTS

0.C.G.A. § 16-10-20.1
13 IDENTITY FRAUD
O.C.G.A. § 16-9-121

14 IDENTITY FRAUD
O.C.G.A. § 16-9-121

15 THEFT BY TAKING
O.C.G.A. § 16-8-2

16 THEFT BY TAKING
O.C.G.A. § 16-8-2

17 CONSPIRACY TO COMMIT
UNAUTHORIZED PRACTICE OF LAW
O.C.G.A. §§ 16-4-8 & 15-19-51

18 FALSE STATEMENTS AND WRITINGS

O.C.G.A. §§ 16-10-20

19 IWENTITY FRAUD
O.C.G.A. § 16-9-121

20 IDENTITY FRAUD
0.C.G.A. § 16-9-121

21 IDENTITY FRAUD
O.C.G.A. § 16-9-121

22 THEFT BY TAKING
O.C.G.A. § 16-8-2

23 THEFT BY TAKING
0.C.G.A. § 16-8-2

24 THEFT OF SERVICES
0.€.G.A. § 16-8-5

25 DEPOSIT ACCOUNT FRAUD

O.C.G.A. § 16-9-20

26 IDENTITY FRAUD
0.C.G.A. § 16-9-121

27 IDENTITY FRAUD
O.C.G.A. § 16-9-121

28 IDENTITY FRAUD
O.C.G.A. § 16-9-121

2
wa

29 IDENTITY FRAUD
O.C.G.A. § 16-9-121

30 IDENTITY FRAUD
0.C.G.A. § 16-9-121

31 THEFT BY TAKING
O.C.G.A. § 16-8-2

32 CONSPIRACY TO COMMIT
UNAUTHORIZED PRACTICE OF LAW
O.C.G.A. §§ 16-4-8 & 15-19-51

33 FILING FALSE DOCUMENTS

O.C.G.A. § 16-10-20.1

34 IDENTITY FRAUD
0.C.G.A. § 16-9-121

35 IDENTITY FRAUD
O.C.G.A. § 16-9-121

36 THEFT BY TAKING
0.C.G.A. § 16-8-2

37 CONSPIRACY TO COMMIT
UNAUTHORIZED PRACTICE OF LAW
O.C.G.A. §§ 16-4-8 & 15-19-51

38 IDENTITY FRAUD
O.C.G.A. § 16-9-121

39 THEFT BY TAKING
O.C.G.A. § 16-8-2

al 23 2024

ae
and Jury Foreperson

T. WILLIS, District Attorney

3
3 1

The Defendant waives copy of The Defendant waives copy of The Defendant waives copy of
indictment, list of witnesses, indictment, list of witnesses, indictment, list of witnesses,
formal arraignment and pleads formal arraignment and pleads formal arraignment and pleads
Guilty. Guilty. Guilty.

Defendant Defendant Defendant

Attorney for Defendant Attorney for Defendant Attorney for Defendant

Assistant District Attorney Assistant District Attorney Assistant District Attomey

This day of This day of This day of

The Defendant waives copy of The Defendant waives copy of The Defendant waives copy of
indictment, list of witnesses, indictment, list of witnesses, indictment, list of witnesses,
formal arraignment and pleads formal arraignment and pleads formal arraignment and pleads
Guilty. Guilty. Guilty.

Defendant Defendant Defendant

Attorney for Defendant Attomey for Defendant Attorney for Defendant

Assistant District Attorney Assistant District Attorney Assistant District Attorney

This day of This day of This day of

4
>

STATE OF GEORGIA, COUNTY OF FULTON

IN THE SUPERIOR COURT OF SAID COUNTY

THE GRAND JURORS, selected, chosen, and sworn for the County of Fulton, to wit:

1. TIMOTHY SIMON, Foreperson PACTOSEPH HOOT

2. MICHAEL ROUSSEAU., Asst. FP 15. DARNELL JONES
3 PTH, Secretary AMISH
4-KENFARAioPETERSONa Asst-Sec, 17. KATHERINE MCQUAY
5. JAMES CANNELLA JR. 18. DILIP PETIGARA
6. KATORYA COLEY 19, MATTHEW RAULS
7. STEPHANIE CRABTREE 20, KATRINA REYNOLDS
8-PATANACROSS- 21. CHRISTIAN STUCK
9, KEVIN DONNELLY
23. DAWN ZUCCARELLI
11. ANDREW GIAGRANDE 24. LEANNE BASSI
12. PATRICK GREATHOUSE 25. CHRISTINE LEUNG GARCIA
13. GARY HORTON 26. MATTHEW JAMESON

5
dy

COUNT of 39 11

The Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do hereby
EARNEST WILLIAMS with the offense of VIOLATION OF THE
charge and accuse
GEORGIA RICO (RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS)
ACT, 0.C.G.A. § 16-14-4(a), for the said accused, individually and as a person concerned in the
commission of a crime, in Fulton County, Georgia, on and between December 1, 2009, and
June 30, 2022, acquired and maintained, directly and indirectly, an interest in and control of real
property and personal property, including but not limited to United States currency, personal
vehicles, motorcycles, coach buses, trailers, automotive parts, and a residence, through a pattern
of racketeering activity, as described below and incorporated by reference as if fully set forth
herein, contrary to the laws of said State, the good order, peace, and dignity thereof:

6
 MANNER AND METHODS OF THE: RICO SCHEME

From at least December 1, 2009, through June 30, 2022, EARNEST WILLIAMS

engaged in a pattern of racketeering activity in Fulton County, Georgia, elsewhere in the State of

Georgia, and in other states. The RICO scheme was designed to defraud unsuspecting

individuals, businesses, and governmental entities, with the primary purpose of depriving

numerous victims of their property. WILLIAMS stole United States currency, personal vehicles,

motorcycles, coach buses, trailers, automotive parts, and other various services and property,

often by falsely promising to help his victims engage in new business ventures, to promote their

existing business ventures, or to help them build their brand or image. Many of WILLIAMS's

victims were women, and WILLIAMS often used the illusion of romantic or close personal

relationships with those victims to manipulate them and to steal from them.

As part of the scheme, WILLIAMS knowingly entered into a fraudulent marriage with

Shirley Strawberry, a famous radio show host. WILLIAMS used the void marriage and the

high-profile celebrity connections he made because of the void marriage in furtherance of other

frauds. During the course of the scheme, WILLIAMS recruited multiple co-conspirators,

including Erica King. On multiple occasions, WILLIAMS solicited King to fraudulently assume

the identities of multiple attorneys licensed to practice law in Georgia in order to deceive law

enforcement and the courts, including by appearing in court and by falsely and fraudulently

representing WILLIAMS in hearings. As part of the pattern of racketeering activity,

WILLIAMS engaged in various related criminal activities including, but not limited to, theft by

taking, theft by conversion, theft by deception, theft of services, theft by bringing stolen property

into the state, acts involving theft, false swearing, filing false documents, false statements and

writings, identity fraud, and deposit account fraud.

7
 ACTS OF RACKETEERING ACTIVITY
The said accused engaged in the following acts of racketeering activity in furtherance of
one or more incidents, schemes, and transactions that had the same and similar intents, results,
accomplices, victims, and methods of commission, and otherwise were interrelated by
distinguishing characteristics and were not isolated incidents. This interrelated pattern of
criminal activity was motivated by pecuniary gain.

Act 1.

On and between December 1, 2009, and January 31, 2010, the exact date being unknown
to the Grand Jury, EARNEST WILLIAMS committed the felony offense of THEFT BY
CONVERSION, in violation of O.C.G.A. § 16-8-4, in DeKalb County, Georgia, by, having
lawfully obtained United States currency, the property of Drucilla Scott, the value of which
exceeded $500.00, under an agreement to make a specified application of such funds, knowingly
converting the funds to his own use in violation of the agreement. This was an act of racketeering
activity pursuant to O.C.G.A. § 16-14-3(5)(A){xi).

Act 2.

On and between January 1, 2013, and December 31, 2013, the exact date being unknown
to the Grand Jury, EARNEST WILLIAMS committed the felony offense of THEFT BY
TAKING, in violation of O.C.G.A. § 16-8-2, in Fulton County, Georgia, by unlawfully taking
United States currency, the property of Jasmine Collins, the value of which was at least.
$5,000.00 but less than $25,000.00, with the intention of depriving said owner of said property.
This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

Act 3.

On or about October 3, 2013, EARNEST WILLIAMS committed the felony offense of

THEFT OF SERVICES, in violation of O.C.G.A. § 16-8-5, in Fulton County, Georgia, by
knowingly obtaining construction and remodeling services which were available only for
compensation, the value of which was at least $1,500.01 but less than $5,000.00, from Mario
Alvarado by deception and with the intent to avoid payment. This was an act of racketeering
activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

Act 4,

On or about October 18, 2013, EARNEST WILLIAMS committed the felony offense of
THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in Fulton County, Georgia, by
unlawfully taking United States currency, the property of Crystal Waters, the value of which was
at least $5,000.00 but less than $25,000.00, with the intention of depriving said owner of said
property. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

8
a

Act 5.

On or about November 24, 2013, EARNEST WILLIAMS committed the felony offense
of THEFT BY DECEPTION, in violation of O.C.G.A. § 16-8-3, in Fulton County, Georgia, by
unlawfully obtaining United States currency, the property of Melvin Stokes, the value of which
was at least $5,000.00 but less than $25,000.00, by deceitful means by selling a 1989 Prevost
vehicle to Stokes while intentionally failing to disclose a substantial and valid known lien and
other legal impediments to the enjoyment of the vehicle, and with the intention of depriving said
owner of said property. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-
3(5)(A)(xii).

Act 6.

On or about December 16, 2014, EARNEST WILLIAMS committed the felony offense
of FALSE SWEARING, in violation of O.C.G.A. § 16-10-71, in Fulton County, Georgia, by
unlawfully, having been administered a lawful oath and having executed a document knowing
that it purported to be an acknowledgement of a lawful oath, knowingly and willfully making the
false statements that each of EARNEST WILLIAMS's prior marriages had been dissolved by
divorce and that EARNEST WILLIAMS was not subject to any legal impediment or other
reason EARNEST WILLIAMS should not be married, said false statements having been made
in Marriage License Application Number 2014-6319 filed in the Probate Court of Fulton County,
Georgia, a matter other than a judicial proceeding. This was an act of racketeering activity
pursuant to O.C.G.A. § 16-14-3(5)(A)(xxv).

Act 7.

On or about December 16, 2014, EARNEST WILLIAMS committed the felony offense
of FILING FALSE DOCUMENTS, in violation of O.C.G.A. § 16-10-20.1, in Fulton County,
Georgia, by unlawfully and knowingly causing to be filed, entered, and recorded a document
titled "MARRIAGE LICENSE APPLICATION LICENSE #2014-6319" in the Probate Court of
Fulton County, Georgia, knowing and having reason to know that the document was false and
contained the materially false statements that each of EARNEST WILLIAMS's prior marriages
had been dissolved by divorce and that EARNEST WILLIAMS was not subject to any legal
impediment or other reason EARNEST WILLIAMS should not be married. This was an act of
racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xxii).

9
 Act 8.

On and between May 1, 2017, and August 31, 2017, the exact date being unknown to the
Grand Jury, EARNEST WILLIAMS committed the felony offense of THEFT BY
DECEPTION, in violation of Kentucky Rev. Stat. § 514.040, in Fayette County, Kentucky, by
obtaining United States currency, the property of Shontail Hocker, the value of which exceeded
$10,000.00, by deception and with intent to deprive said owner of said property, by creating and
reinforcing a false impression as to intention and state of mind. This was an act involving theft
which is chargeable under the laws of the state of Kentucky and which is punishable by
imprisonment for more than one year and an act of racketeering activity pursuant to O.C.G.A. §
16-14-3(5)(B).

Act 9,

On or about November 3, 2017, EARNEST WILLIAMS committed the felony offense

of THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in DeKalb County, Georgia, by
unlawfully taking a 1998 Prevost vehicle, the property of Carlos Torres, the value of which
exceeded $24,999.99, with thé intention of depriving said owner of said property. This was an
act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

Act 10.

On or about November 11, 2017, EARNEST WILLIAMS committed the felony offense
of DEPOSIT ACCOUNT FRAUD, in violation of O.C.G.A. § 16-9-20, in DeKalb County,
Georgia, by making, drawing, and delivering a check, an instrument for the payment of money
on a bank, to Carlos Torres in the amount of $9000.00 for the present consideration of a 1998
Prevost vehicle, knowing that said check would not be honored by the drawee. This was an act.
involving theft which is chargeable under the laws of the state of Georgia and which is
punishable by imprisonment for more than one year and an act of racketeering activity pursuant
to O.C.G.A. § 16-14-3(5)(B).

Act 11.

EARNEST WILLIAMS committed the felony offense of

On or about January 4, 2018,
THEFT BY BRINGING STOLEN PROPERTY INTO STATE, in violation of O.C.G.A. §
16-8-9, in Fulton County, Georgia, by bringing a2011 Rolls Royce Ghost vehicle, the property
of Specialty Car Collection, the value of which exceeded $24,999.99, into the State of Georgia
knowing said property had been stolen in Los Angeles, California. This was an act of
racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xti).

10
 Act 12.

On or about January 22, 2018, EARNEST WILLIAMS committed the felony offense of
THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in Fulton County, Georgia, by
unlawfully taking United States currency, the property of Wan Smith, the value of which was at
least $5,000.00 but less than $25,000.00, with the intention of depriving said owner of said
property. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

Act 13.

On or about February 3, 2018, EARNEST WILLIAMS committed the felony offense of

GRAND THEFT AUTO, in violation of Cal. Pen. Code. §§ 484 and 487, in Los Angeles
County, California, by feloniously stealing, taking, and driving away a 2008 Fleetwood
Providence vehicle, the personal property of Rebecca Baker. This was an act involving theft
which is chargeable under the laws of the state of California and which is punishable by
imprisonment for more than one year and an act of racketeering activity pursuant to O.C.G.A. §
16-14-3(5)(B).

Act 14.

EARNEST WILLIAMS committed the felony offense of

On or about February 3, 2018,
MAKING OR DELIVERING CHECK WITH INSUFFICIENT FUNDS, in violation of Cal.
Pen. Code. § 476a, in Los Angeles County, California, by, for himself, willfully, with intent to
defraud, making a check in the amount of $20,000.00 to Rebecca Baker for the payment of
money knowing at the time of that making that he had not sufficient funds in the bank for the
payment of that check and all other checks then outstanding in full upon its presentation. This
was an act involving theft which is chargeable under the laws of the state of California and
which is punishable by imprisonment for more than one year and an act of racketeering activity
pursuant to O.C.G.A. § 16-14-3(5)(B).

Act 15.

On or about October 13, 2018, EARNEST WILLIAMS committed the felony offense of
THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in Henry County, Georgia, by
unlawfully taking a Big Tex 20PH trailer, the property of Big Tex Trailer World, the value of
which was at least $5,000.00 but less than $25,000.00, with the intention of depriving said owner
of said property. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-
3(5)(A)(xii).

11
 Act 16.

On or about October 13, 2018, EARNEST WILLIAMS committed the felony offense of
DEPOSIT ACCOUNT FRAUD, in violation of O.C.G.A. § 16-9-20, in Henry County,
Georgia, by making, drawing, and delivering Check Number 888, an instrument for the payment
of money on Wells Fargo Bank, a bank located within the State of Georgia, to Big Tex Trailer
World in the amount of $9589.03 for the present consideration of a Big Tex 20PH trailer,
knowing that said check would not be honored by the drawee. This was an act involving theft
which is chargeable under the laws of the state of Georgia and which is punishable by
imprisonment for more than one year and an act of racketeering activity pursuant to O.C.G.A. §
16-14-3(5)(B).

Act 17.

On or about November 15, 2018, EARNEST WILLIAMS committed the felony offense
of GRAND THEFT, in violation of Cal. Pen. Code. §§ 484 and 487, in Orange County,
California, by feloniously stealing and taking labor and personal property of Source Motors, Inc.,
including a fender well rack, MOMO steering wheel and adapter, headlights, center console rack,
D-ring guard, windshield brush guard, and mirror set, the value of which exceeded $950.00. This
was an act involving theft which is chargeable under the laws of the state of California and
which is punishable +by imprisonment for more than one year and an act of racketeering activity
pursuant to O.C.G.A. § 16-14-3(5)(B).

Act 18.

On or about November 15, 2018, EARNEST WILLIAMS committed the felony offense
of MAKING OR DELIVERING CHECK WITH INSUFFICIENT FUNDS, in violation of
Cal. Pen. Code. § 476a, in Orange County, California, by, for himself, willfully, with intent to
defraud, making and delivering a check in the amount of$6361.88 to Source Motors, Inc., for
the payment of money knowing at the time of that making and delivering that he had not
sufficient funds in the bank for the payment of that check and all other checks then outstanding
in full upon its presentation. This was an act involving theft which is chargeable under the laws
of the state of California and which is punishable by imprisonment for more than one year and an
act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(B).

Act 19,

On and between January 31, 2019 and March 27, 2019, EARNEST WILLIAMS
committed the felony offense of THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in
Fulton County, Georgia, by unlawfully taking United States currency and a 2012 Ford Transit .

Connect vehicle, the property of Rasheda Sanders, the value of which was at least $5000.00 but
less than $25,000.00, with the intention of depriving said owner of said property. This was an act
of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

12
 Act 20.

On or about March 23, 2019, EARNEST WILLIAMS committed the felony offense of
THEFT BY TAKING, in violation of 0.C.G.A. § 16-8-2, in Cobb County, Georgia, by
unlawfully taking a Big Tex 22GN trailer, the property of Big Tex Trailer World, the value of
which was at least $5,000.00 but less than $25,000.00, with the intention of depriving said owner
of said property. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-
3(5)(A)(xii).

Act 21.

On or about March 23, 2019, EARNEST WILLIAMS committed the felony offense of
DEPOSIT ACCOUNT FRAUD, in violation of O.C.G.A. § 16-9-20, in Cobb County, Georgia,
by making, drawing, and delivering a check, an instrument for the payment of money on a bank,
to Big Tex Trailer World in the amount of$1,500.00 or more for the present consideration of a
Big Tex 22GN trailer, knowing that said check would not be honored by the drawee. This was an
act involving theft which is chargeable under the laws of the state of Georgia and which is
punishable by imprisonment for more than one year and an act of racketeering activity pursuant
_ to O.C.G.A. § 16-14-3(5)(B).

Act 22,

On and between July 24, 2020, and September 16, 2020, EARNEST WILLIAMS
committed the felony offense of THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in
Fulton County, Georgia, by unlawfully taking United States currency, the property of Calvin
Cauthen, the value of which was at least $5,000.00 but less than $25,000.00, with the intention of
depriving said owner of said property. This was an act of racketeering activity pursuant to
0.C.G.A. § 16-14-3(5)(A)(xii).

Act 23.

On or about February 1, 2021, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of FILING FALSE DOCUMENTS, in violation of O.C.G.A. §
16-10-20.1, in Fulton County, Georgia, by knowingly filing a document titled "AMENDED
ANSWER, DEFENSES, AND COUNTERCLAIMS?" in the matter of VISTARAY USA, INC.
vs. Shirley Strawberry, Case Number 20ED167485, in the Magistrate Court of Fulton County,
Georgia, knowing and having reason to know that the document was false and contained the
materially false statement and representation that the document had been prepared and filed by
attorney April Holloway and attorney Nicholas Benzine. This was an act of racketeering activity
pursuant to O.C.G.A. § 16-14-3(5)(A)(xxii).

13
 Act 24.

On or about February 1, 2021, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in
Fulton County, Georgia, by willfully and fraudulently, without authorization and consent, using
the name of attorney April Holloway, identifying information conceming a person, in a false
document titled "AMENDED ANSWER, DEFENSES, AND COUNTERCLAIMS" filed in
Fulton County Magistrate Court Case Number 20ED167485. This was an act of racketeering
activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 25,

On or about February 1, 2021, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in
Fulton County, Georgia, by willfully and fraudulently, without authorization and consent, using
the name of attorney Nicholas Benzine, identifying information concerning a person, in a false
document titled "AMENDED ANSWER, DEFENSES, AND COUNTERCLAIMS?" filed in
Fulton County Magistrate Court Case Number 20ED167485. This was an act of racketeering .

activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 26.

On or about February 1, 2021, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in
Fulton County, Georgia, by willfully and fraudulently, without authorization and consent, using
the name of attorney April Holloway, identifying information concerning a person, by falsely
representing to Judge Todd Ashley that King was attorney April Holloway while purporting to
represent EARNEST WILLIAMS and Shirley Strawberry in a dispossessory hearing in Fulton
County Magistrate Court Case Number 20ED167485. This was an act of racketeering activity
pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 27.

On or about February 3, 2021, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of FILING FALSE DOCUMENTS, in violation of O.C.G.A. §
16-10-20.1, in Fulton County, Georgia, by knowingly filing a document titled "NOTICE OF
APPEAL" in the matter of VISTARAY USA, INC. vs. Shirley Strawberry, Case Number
20ED167485 in the Magistrate Court of Fulton County, Georgia, knowing and having reason to
know that the document was false and contained the materially false statement and
representation that the document had been prepared and filed by attorney April Holloway and
attorney Nicholas Benzine. This was an act of racketeering activity pursuant to O.C.G.A. § 16-
14-3(5){A)(xxii).

14
ba

Act 28.

Onor about February 3, 2021, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in
Fulton County, Georgia, by willfully and fraudulently, without authorization and consent, using
the name of attorney April Holloway, identifying information concerning a person, in a false
document titled "NOTICE OF APPEAL" filed in Fulton County Magistrate Court Case Number
20ED167485. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 29.

On or about February 3, 2021, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in
Fulton County, Georgia, by willfully and fraudulently, without authorization and consent, using
the name of attorney Nicholas Benzine, identifying information concerning a person, in a false
document titled "NOTICE OF APPEAL" filed in Fulton County Magistrate Court Case Number
20ED167485. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 30.

On or about March 15, 2021, EARNEST WILLIAMS committed the felony offense of
THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in Fulton County, Georgia, by
unlawfully taking a 2020 Harley-Davidson FLTRXS vehicle, the property of Regina Delaney,
the value of which exceeded $24,999.99, with the intention of depriving said owner of said
property. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

Act 31.

On or about March 15, 2021, EARNEST WILLIAMS committed the felony offense of
THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in Fulton County, Georgia, by
unlawfully taking a Big Tex 14TL trailer, the property of Regina Delaney, the value of which
was at least $5,000.00 but less than $25,000.00, with the intention of depriving said owner of
said property. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

Act 32.

On or about March 24, 2021, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of FALSE STATEMENTS AND WRITINGS, in violation of
O.C.G.A. § 16-10-20, in Fulton County, Georgia, by knowingly and willfully making the false
statements to Sandy Springs Police Department Detective I. Tomlin that King was attorney April
Holloway and that King was an attorney who lawfully represented EARNEST WILLIAMS
during a criminal investigation being conducted by Tomlin, said statements being within the
jurisdiction of the Sandy Springs Police Department, a department of the government of Sandy
Springs, Georgia. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-
3(5)(A)(xxii).

15
 Act 33.

On or about March 24, 2021, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in
Fulton County, Georgia, by willfully and fraudulently, without authorization and consent, using
the name of attorney April Holloway, identifying information concerning a person, by falsely
representing to Sandy Springs Police Department Detective I. Tomlin in a three-way telephone
conversation with EARNEST WILLIAMS that King was attorney April Holloway while
purporting to represent EARNEST WILLIAMS during a criminal investigation being
conducted by Tomlin. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-
3(5)(A)(xx).

Act 34.

On or about April 1, 2021, EARNEST WILLIAMS solicited and coerced Erica King to
commit the felony offense of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in
Fulton County, Georgia, by willfully and fraudulently, without authorization and consent, using
the name of attorney April Holloway, identifying information concerning a person, by falsely -

representing to Sandy Springs Police Department Detective I. Tomlin in a one-on-one telephone

conversation that King was attorney April Holloway while purporting to represent EARNEST
WILLIAMS during a criminal investigation being conducted by Tomlin. This was an act of
racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 35.

On and between April 5, 2021, and April 9, 2021, EARNEST WILLIAMS solicited and
coerced Erica King to commit the felony offense of IDENTITY FRAUD, in violation of
O.C.G.A. § 16-9-121, in Fulton County, Georgia, by willfully and fraudulently, without
authorization and consent, using the name of attorney April Holloway, identifying information
concerning a person, by falsely representing to Sandy Springs Police Department Detective I.
Tomlin in e-mail communications that King was attorney April Holloway while purporting to
represent EARNEST WILLIAMS during a criminal investigation being conducted by Tomlin.
This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 36.

On or about August 15, 2021, EARNEST WILLIAMS committed the felony offense of
THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in Fulton County, Georgia, by
unlawfully taking a 1998 Prevost Royale vehicle, the property of Gayle Bickham, the value of
which exceeded $24,999.99, with the intention of depriving said owner of said property. This
was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

16
 Act 37.

On or about August 15, 2021, EARNEST WILLIAMS committed the felony offense of
THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in Fulton County, Georgia, by
unlawfully taking a 2021 Mercedes-Benz GLE vehicle, the property of Gayle Bickham, the value
of which exceeded $24,999.99, with the intention of depriving said owner of said property. This
was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

Act 38.

On or about November 21, 2021, EARNEST WILLIAMS committed the felony offense
of THEFT OF SERVICES, in violation of O.C.G.A. § 16-8-5, in Fulton County, Georgia, by
knowingly obtaining vehicle repair services which were available only for compensation, the
value of which was at least $1,500.01 but less than $5,000.00, from Palmer Dodge Chrysler Jeep
Ram by deception and with the intent to avoid payment. This was an act of racketeering activity
pursuant to O.C.G.A. § 16-14-3(5)(A)(xi1).

Act 39.

On or about November 21, 2021, EARNEST WILLIAMS solicited and coerced

unindicted co-conspirator Individual 1, whose identity is known to the Grand Jury, to commit the
felony offense of DEPOSIT ACCOUNT FRAUD, in violation of O.C.G.A. § 16-9-20, in
Fulton County, Georgia, by making, drawing, and delivering Check Number 212, an instrument
for the payment of money on Navy Federal Credit Union, a bank located within the State of
Georgia, to Palmer Dodge Chrysler Jeep Ram in the amount of $2774.40 for the present
consideration of vehicle repair services, knowing that said check would not be honored by the
drawee. This was an act involving theft which is chargeable under the laws of the state of
Georgia and which is punishable by imprisonment for more than one year and an act of
racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(B).

Act 40.

EARNEST WILLIAMS committed the felony offense

On or about December 1, 2021,
of FINANCIAL TRANSACTION CARD FRADD, in violation of O.C.G.A. § 16-9-33, in
Bartow County, Georgia, by, with intent to defraud Precinct One Auto Sales, Inc. and Melody
Skretchen, obtaining goods and services of a value of $2000.00 by giving, orally and in writing,
a Mastercard financial transaction card account number ending in 8161 to Precinct One Auto
Sales, Inc., the provider of the goods and services, for billing purposes without the authorization
and permission of Melody Skretchen, the cardholder, for such use. This was an act of
racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xvii).

17
 Act 41.

On or about December 1, 2021, EARNEST WILLIAMS committed the felony offense

of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in Fulton County, Georgia, by
willfully and fraudulently, without authorization and consent, using a Mastercard credit card
number ending in 8161 belonging to Melody Skretchen, identifying information concerning a
person, for an unauthorized purchase in the amount of $2000.00 at Precinct One Auto Sales, Inc.
This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 42,

EARNEST WILLIAMS committed the felony offense

On or about December 1, 2021,
of FINANCIAL TRANSACTION CARD FRAUD, in violation of O.C.G.A. § 16-9-33, in
Gwinnett County, Georgia, by, with intent to defraud Lara's Trucks, Inc. and Melody Skretchen,
obtaining goods and services of a value of $1071.12 by giving, orally and in writing, a Visa
financial transaction card account number ending in 9747 to Lara's Trucks, Inc., the provider of
the goods and services, for billing purposes without the authorization and permission of Melody
Skretchen, ihe cardholder, for such use. This was an act of racketeering activity pursuant to
0.C.G.A. § 16-14-3(5)(A)(xvii).

Act 43.

On or about December 1, 2021, EARNEST WILLIAMS committed the felony offense

of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in Fulton County, Georgia, by
willfully and fraudulently, without authorization and consent, using a Visa credit card number
ending in 9747 belonging to Melody Skretchen, identifying information concerning a person, for
an unauthorized purchase in the amount of$1071.12 at Lara's Trucks, Inc. This was an act of
racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 44,

EARNEST WILLIAMS committed the felony offense

On or about December 2, 2021,
of FINANCIAL TRANSACTION CARD FRADD, in violation of O.C.G.A. § 16-9-33, in
Gwinnett County, Georgia, by, with intent to defraud Lara's Trucks, Inc. and Melody Skretchen,
obtaining goods and services of a value of $800.00 by giving, orally and in writing, a Visa
financial transaction card account number ending in 9747 to Lara's Trucks, Inc., the provider of
the goods and services, for billing purposes without the authorization and permission of Melody
Skretchen, the cardholder, for such use. This was an act of racketeering activity pursuant to
O.C.G.A. § 16-14-3(5)(A)(xvii).

18
 Act 45.

On or about December 2, 2021, EARNEST WILLIAMS committed the felony offense

of IDENTITY FRADD, in violation of O.C.G.A. § 16-9-121, in Fulton County, Georgia, by
willfully and fraudulently, without authorization and consent, using a Visa credit card number
ending in 9747 belonging to Melody Skretchen, identifying information concerning a person, for
an unauthorized purchase in the amount of $800.00 at Lara's Trucks, Inc. This was an act of
racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 46.

On or about December 2, 2021, EARNEST WILLIAMS committed the felony offense

of FINANCIAL TRANSACTION CARD FRAUD, in violation of O.C.G.A. § 16-9-33, in
Gwinnett County, Georgia, by, with intent to defraud Lara's Trucks, Inc. and Melody Skretchen,
obtaining goods and services of a value of $1000.00 by giving, orally and in writing, a
Mastercard financial transaction card account number ending in 8161 to Lara's Trucks, Inc., the
provider of the goods and services, for billing purposes without the authorization and permission
of Melody Skretchen, the cardholder, for such use. This was an act of racketeering activity
pursuant to O.C.G.A. § 16-14-3(5)(A)(xvii).

Act 47.

On or about December 2, 2021, EARNEST WILLIAMS committed the felony offense

of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in Fulton County, Georgia, by
willfully and fraudulently, without authorization and consent, using a Mastercard credit card
number ending in 8161 belonging to Melody Skretchen, identifying information concerning a
person, for an unauthorized purchase in the amount of $1000.00 at Lara's Trucks, Inc. This was
an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 48.

On or about December 4, 2021, EARNEST WILLIAMS committed the felony offense

of FINANCIAL TRANSACTION CARD FRADD, in violation of O.C.G.A. § 16-9-33, in
Gwinnett County, Georgia, by, with intent to defraud Lara's Trucks, Inc. and Melody Skretchen,
obtaining goods and services of a value of $1000.00 by giving, orally and in writing, a Visa
financial transaction card account number ending in 4860 to Lara's Trucks, Inc., the provider of
the goods and services, for billing purposes without the authorization and permission of Melody
Skretchen, the cardholder, for such use. This was an act of racketeering activity pursuant to
O.C.G.A. § 16-14-3(5)(A) (xvii).

19
 Act 49,

On or about December 4, 2021, EARNEST WILLIAMS committed the felony offense

of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in Fulton County, Georgia, by
willfully and fraudulently, without authorization and consent, using a Visa credit card number
for
ending in 4860 belonging to Melody Skretchen, identifying information concerning a person,
an unauthorized purchase in the amount of $1000.00 at Lara's Trucks, Inc. This was an act of
racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

Act 50.

On and between January 1, 2022, and January 31, 2022, the exact date being unknown to
the Grand Jury, EARNEST WILLIAMS did commit the felony offense of THEFT BY
TAKING, in violation of O.C.G.A. § 16-8-2, in Fulton County, Georgia, by unlawfully taking a
2018 Nissan Altima vehicle, the property of Melody Skretchen, the value of which was at least
$5,000.00 but less than $25,000.00, with the intention of depriving said owner of said property.
This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

Act 51.

On or about February 7, 2022, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of FILING FALSE DOCUMENTS, in violation of O.C.G.A. §
16-10-20.1, in Fulton County, Georgia, by knowingly filing a document titled "NOTICE OF
APPEARANCE AND SUBSTITUTION OF COUNSEL" in the matter of REGINA DELANEY
vs. ERNESTO WILLIAMS, Case Number 21MAGC-00111, in the Magistrate Court of Fulton
County, Georgia, knowing and having reason to know that the document was false and contained
the materially false statement and representation that the document had been prepared and filed
by attorney April Holloway. This was an act of racketeering activity pursuant to O.C.G.A. § 16-
14-3(5)(A)(xxii).

Act 52.

On or about February 7, 2022, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in.
Fulton County, Georgia, by willfully and fraudulently, without authorization and consent, using
the name of attorney April Holloway, identifying information concerning a person, in a false
document titled "NOTICE OF APPEARANCE AND SUBSTITUTION OF COUNSEL" filed in
Fulton County Magistrate Court Case Number 21IMAGC-00111. This was an act of racketeering
activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xx).

20
1

Act 53.

On or about February 7, 2022, EARNEST WILLIAMS solicited and coerced Erica King
to commit the felony offense of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in
Fulton County, Georgia, by willfully and fraudulently, without authorization and consent, using
the name of attorney April Holloway, identifying information conceming a person, by falsely
representing to Judge Ashley Drake that King was attorney April Holloway while purporting to
represent EARNEST WILLIAMS in a warrant application hearing in Fulton County Magistrate
Court Case Number 21MAGC-00111. This was an act of racketeering activity pursuant to
0.C.G.A. § 16-14-3(5)(A)(xx).

Act 54,

On and between March 28, 2022, and April 17, 2022, EARNEST WILLIAMS
committed the felony offense of THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in
Fulton County, Georgia, by unlawfully taking United States currency, the property of Christine
Mays, the value of which exceeded $24,999.99, with the intention of depriving said owner of
said property. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

Act 55.

On or about May 4, 2022, EARNEST WILLIAMS did commit the felony offense of
THEFT BY TAKING, in violation ofO.C.G.A. § 16-8-2, in Forsyth County, Georgia, by
unlawfully taking a 2021 Harley-Davidson FLTRXS vehicle, the property of Olivia Washington,
the value of which exceeded $24,999.99, with the intention of depriving said owner of said
property. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

Act 56.

On or about June 10, 2022, EARNEST WILLIAMS solicited and coerced Erica King to
commit the felony offense of IDENTITY FRAUD, in violation of O.C.G.A. § 16-9-121, in
Fulton County, Georgia, by willfully and fraudulently, without authorization and consent, using
the name of attorney Eileen Moorman, identifying information concerning a person, in a
fraudulent demand letter addressed to Mark Krol while purporting to represent Black Heritage
Radio Association Trust. This was an act of racketeering activity pursuant to O.C.G.A. § 16-14-
3(5)(A) (xx).

Act 57.

On or about June 30, 2022, EARNEST WILLIAMS committed the felony offense of
THEFT BY TAKING, in violation of O.C.G.A. § 16-8-2, in Fulton County, Georgia, by
unlawfully taking a 2002 Prevost Liberty vehicle, the property of Gayle Bickham, the value of
which exceeded $24,999.99, with the intention of depriving said owner of said property. This
was an act of racketeering activity pursuant to O.C.G.A. § 16-14-3(5)(A)(xii).

21
 COUNT 2 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of FALSE SWEARING,
O.C.G.A. § 16-10-71, for the said accused, in Fulton County, Georgia, on or about December
16, 2014, unlawfully, having been administered a lawful oath and having executed a document
knowing that it purported to be an acknowledgement of a lawful oath, knowingly and willfully
made the false statements that each of EARNEST WILLIAMS's prior marriages had been
dissolved by divorce and that EARNEST WILLIAMS was not subject to any Jegal impediment
or other reason EARNEST WILLIAMS should not be married, said false statements having
been made in Marriage License Application Number 2014-6319 filed in the Probate Court of
Fulton County, Georgia, a matter other than a judicial proceeding, and said crime was unknown
until at least April 12, 2024, contrary to the laws of said State, the good order, peace, and dignity
thereof;

COUNT 3 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of FILING
FALSE
DOCUMENTS, O.C.G.A. § 16-10-20.1, for the said accused, in Fulton County, Georgia, on or
about December 16, 2014, unlawfully and knowingly caused to be filed, entered, and recordeda
document titled "MARRIAGE LICENSE APPLICATION LICENSE #2014-6319" in the
Probate Court of Fulton County, Georgia, knowing and having reason to know that the document
was false and contained the materially false statements that each of EARNEST WILLIAMS's
prior marriages had been dissolved by divorce and that EARNEST WILLIAMS was not subject
to any legal impediment or other reason EARNEST WILLIAMS should not be married, and
said crime was unknown until at least April 12, 2024, contrary to the laws of said State, the good
order, peace, and dignity thereof:

COUNT 4 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense ofBIGAMY, O.C.G.A. §
16-6-20, for the said accused, in Fulton County, Georgia, on or about January 9, 2015,
unlawfully, while being married to Martha Halliburton-Williams and knowing that his lawful
spouse was living, married Shirley Clark Strawberry and carried on a bigamous cohabitation
with Shirley Clark Strawberry, and said crime was unknown until at least April 12, 2024,
contrary to the laws of said State, the good order, peace, and dignity thereof;

22
 COUNT 5 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of THEFT BY TAKING,
O.C.G.A. § 16-8-2, for the said accused, in Fulton County, Georgia, on and between January
31, 2019, and March 27, 2019, unlawfully took United States currency and a 2012 Ford Transit
Connect vehicle, the property of Rasheda Sanders, the value of which was at least $5000.00 but
less than $25,000.00, with the intention of depriving said owner of said property, contrary to the
laws of said State, the good order, peace, and dignity thereof;

COUNT 6 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of THEFT BY TAKING,
O.C.G.A. § 16-8-2, for the said accused, in Fulton County, Georgia, on and between July 24,
2020, and September 16, 2020, unlawfully took United States currency, the property of Calvin
Cauthen, the value of which was at least $5,000.00 but less than $25,000.00, with the intention of
depriving said owner of said property, contrary to the laws of said State, the good order, peace,
and dignity thereof;

COUNT of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
CONSPIRACY TO COMMIT UNAUTHORIZED PRACTICE OF LAW, O.C.G.A. §§ 16-
4-8 & 15-19-51, for the said accused, individually and as persons concermed in the commission
of a crime, in Fulton County, Georgia, on and between February 1, 2021, and March 18, 2021,
unlawfully conspired to cause ERICA KING, a person not a duly licensed attorney at law, to
practice and appear as an attorney at law for EARNEST WILLIAMS before the Magistrate
Court of Fulton County, Georgia, to hold herself out to Judge Todd Ashley as being entitled to
practice law, and to render legal services in Fulton County Magistrate Court Case Number
20ED167485;

And ERICA KING, a person not a duly licensed attorney at law, did practice and appear
as an attorney at law for EARNEST WILLIAMS before the Magistrate Court of Fulton County,
Georgia, did hold herself out to Judge Todd Ashley as being entitled to practice law, and did
render legal services in Fulton County Magistrate Court Case Number 20ED 167485, which were
overt acts to effect the object of the conspiracy, and said crime was unknown until at least June
10, 2022, contrary to the laws of said State, the good order, peace, and dignity thereof,

23
 COUNT 8 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
FILING FALSE DOCUMENTS, O.C.G.A. § 16-10-20.1, for the said accused, individually
and as persons.concerned in the commission of a crime, in Fulton County, Georgia, on or about
February 1, 2021, unlawfully and knowingly filed a document titled "AMENDED ANSWER,
DEFENSES, AND COUNTERCLAIMS" in the matter of VISTARAY USA, INC. vs. Shirley
Strawberry, Case Number 20ED167485, in the Magistrate Court of Fulton County, Georgia,
knowing and having reason to know that the document was false and contained the materially
false statement and representation that the document had been prepared and filed by attorney
April Holloway and attorney Nicholas Benzine, contrary to the laws of said State, the good
order, peace, and dignity thereof;

COUNT 9 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
IDENTITY FRAUD, O.C.G.A. § 16-9-121, for the said accused, individually and as persons
concerned in the commission of a crime, in Fulton County, Georgia, on or about February 1,
2021, unlawfully, willfully, and fraudulently, without authorization and consent, used the name
of attomey April Holloway, identifying information concerning a person, in a false document
titled "AMENDED ANSWER, DEFENSES, AND COUNTERCLAIMS?" filed in Fulton County
Magistrate Court Case Number 20ED167485, contrary to the laws of said State, the good order,
peace, and dignity thereof;

COUNT 10 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
IDENTITY FRAUD, O.C.G.A. § 16-9-121, for the said accused, individually and as persons
concerned in the commission of a crime, in Fulton County, Georgia, on or about February 1,
2021, unlawfully, willfully, and fraudulently, without authorization and consent, used the name
of attorney Nicholas Benzine, identifying information concerning a person, in a false document
titled "AMENDED ANSWER, DEFENSES, AND COUNTERCLAIMS" filed in Fulton County
Magistrate Court Case Number 20ED167485, contrary to the laws of said State, the good order,
peace, and dignity thereof;

24
a

COUNT 11 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
IDENTITY FRAUD, O.C.G.A. § 16-9-121, for the said accused, individually and as persons
concerned in the commission of a crime, in Fulton County, Georgia, on or about February 1,
2021, unlawfully, willfully, and fraudulently, without authorization and consent, used the name
of attorney April Holloway, identifying information concerning a person, by falsely representing
to Judge Todd Ashley that ERICA KING was attorney April Holloway while purporting to
represent EARNEST WILLIAMS and Shirley Strawberry in a dispossessory hearing in Fulton
County Magistrate Court Case Number 20ED 167485, contrary to the laws of said State, the good
order, peace, and dignity thereof;

COUNT 12 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
FILING FALSE DOCUMENTS, O.C.G.A. § 16-10-20.1, for the said accused, individually
and as persons concerned in the commission of a crime, in Fulton County, Georgia, on or about
February 3, 2021, unlawfully and knowingly filed a document titled "NOTICE OF APPEAL"
in the matter of VISTARAY USA, INC. vs. Shirley Strawberry, Case Number 20ED167485, in
the Magistrate Court of Fulton County, Georgia, knowing and having reason to know that the
document was false and contained the materially false statement and representation that the
document had been prepared and filed by attorney April Holloway and attorney Nicholas
Benzine, contrary to the laws of said State, the good order, peace, and dignity thereof;

COUNT 13 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
IDENTITY FRAUD, O.C.G.A. § 16-9-121, for the said accused, individually and as persons
concerned in the commission of a crime, in Fulton County, Georgia, on or about February 3,
2021, unlawfully, willfully, and fraudulently, without authorization and consent, used the name
of attorney April Holloway, identifying information concerning a person, in a false document
titled "NOTICE OF APPEAL" filed in Fulton County Magistrate Court Case Number
20ED167485, contrary to the laws of said State, the good order, peace, and dignity thereof;

25
 COUNT 14 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense
of
IDENTITY FRAUD, O.C.G.A. § 16-9-121, for the said accused, individually and as persons
concerned in the commission of a crime, in Fulton County, Georgia, on or about February 3,
authorization and used the name
2021, unlawfully, willfully, and fraudulently, without consent,
of attorney Nicholas Benzine, identifying information concerning a person, in a false document
titled "NOTICE OF APPEAL" filed in Fulton County Magistrate Court Case Number
20ED167485, contrary to the laws of said State, the good order, peace, and dignity thereof:

COUNT 15 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
:

hereby charge and accuse EARNEST WILLIAMS with the offense of THEFT BY TAKING,
0.C.G.A. § 16-8-2, for the said accused, in Fulton County, Georgia, on or about March 15,
2021, unlawfully took a 2020 Harley-Davidson FLTRXS vehicle, the property of Regina
Delaney, the value of which exceeded $24,999.99, with the intention of depriving said owner of
said property, contrary to the laws of said State, the good order, peace, and dignity thereof;

COUNT 16 of 39

And the Grand Jurors aforesaid, in the name and behaff of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of THEFT BY TAKING,
0.C.G.A. § 16-8-2, for the said accused, in Fulton County, Georgia, on or about March 15,
2021, unlawfully took a Big Tex 14TL trailer, the property of Regina Delaney, the value of
which was at least $5,000.00 but less than $25,000.00, with the intention of depriving said owner
of said property, contrary to the laws of said State, the good order, peace, and dignity thereof;

26
 COUNT 17 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
CONSPIRACY TO COMMIT UNAUTHORIZED PRACTICE OF LAW, O.C.G.A. §§ 16-
4-8 & 15-19-51, for the said accused, individually and as persons concemed in the commission
of acrime, in Fulton County, Georgia, on and between March 24, 2021, and April 5, 2021,
unlawfully conspired to cause ERICA KING, a person not a duly licensed attorney at law, to
hold herself out to Sandy Springs Police Department Detective I. Tomlin as being entitled to
practice law and to render legal services during a criminal investigation being conducted by
Tomlin;

And ERICA KING, a person not a duly licensed attorney at law, did hold herself out to
Sandy Springs Police Department Detective I. Tomlin as being entitled to practice law and did
render legal services during a criminal investigation being conducted by Tomlin, which were
overt acts to effect the object of the conspiracy, and said crime was unknown until at least June
10, 2022, contrary to the laws of said State, the good order, peace, and dignity thereof;

COUNT 18 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20, for the said accused,
individually and as persons concerned in the commission of a crime, in Fulton County, Georgia,
on or about March 24, 2021, unlawfully, knowingly, and willfully made the false statements to
Sandy Springs Police Department Detective I. Tomlin that ERICA KING was attorney April
Holloway and that ERICA KING was an attorney who lawfully represented EARNEST
WILLIAMS during a criminal investigation being conducted by Tomlin, said statements being
within the jurisdiction of the Sandy Springs Police Department, a department of the government
of Sandy Springs, Georgia, contrary to the laws of said State, the good order, peace, and dignity
thereof;

27
3

COUNT 19 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
IDENTITY FRAUD, O.C.G.A. § 16-9-121, for the said accused, individually and as persons
concerned in the commission of a crime, in Fulton County, Georgia, on or about March 24,
2021, unlawfully, willfully, and fraudulently, without authorization and consent, used the name
of attorney April Holloway, identifying information concerning a person, by falsely representing
to Sandy Springs Police Department Detective I. Tomlin in a three-way telephone conversation
with EARNEST WILLIAMS that ERICA KING was attorney April Holloway while
purporting to represent EARNEST WILLIAMS during a criminal investigation being
conducted by Tomlin, contrary to the laws of said State, the good order, peace, and dignity
thereof;

COUNT 20 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
IDENTITY FRAUD, O.C.G.A. § 16-9-121, for the said accused, individually and as persons -

concemed in the commission of a crime, in Fulton County, Georgia, on or about April 1, 2021,
unlawfully, willfully, and fraudulently, without authorization and consent, used the name of
attorney April Holloway, identifying information concerning a person, by falsely representing to
Sandy Springs Police Department Detective I. Tomlin in a one-on-one telephone conversation
that ERICA KING was attorney April Holloway while purporting to represent EARNEST
WILLIAMS during a criminal investigation being conducted by Tomlin, contrary to the laws of
said State, the good order, peace, and dignity thereof;

COUNT 21 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
IDENTITY FRAUD, O.C.G.A. § 16-9-121, for the said accused, individually and as persons
concerned in the commission of a crime, in Fulton County, Georgia, on and between April 5,
2021, and April 9, 2021, unlawfully, willfully, and fraudulently, without authorization and
consent, used the name of attorney April Holloway, identifying information concerning a person,
by falsely representing to Sandy Springs Police Department Detective I. Tomlin in e-mail
communications that ERICA KING was attorney April Holloway while purporting to represent
EARNEST WILLIAMS during a criminal investigation being conducted by Tomlin, contrary to
the laws of said State, the good order, peace, and dignity thereof;

28
a

COUNT 22 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of THEFT BY TAKING,
0.C.G.A. § 16-8-2, for the said accused, in Fulton County, Georgia, on or about August 15,
2021, unlawfully took a 1998 Prevost Royale vehicle, the property of Gayle Bickham, the value
of which exceeded $24,999.99, with the intention of depriving said owner of said property, :

contrary to the laws of said State, the good order, peace, and dignity thereof;

COUNT 23 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of THEFT BY TAKING,
O.C.G.A. § 16-8-2, for the said accused, in Fulton County, Georgia, on or about August 15,
2021, unlawfully took a 2021 Mercedes-Benz GLE vehicle, the property of Gayle Bickham, the
value of which exceeded $24,999.99, with the intention of depriving said owner of said property,
contrary to the laws of said State, the good order, peace, and dignity thereof}

COUNT 24 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of THEFT OF
SERVICES, 0.C.G.A. § 16-8-5, for the said accused, individually and as a person concerned.: in
the commission of a crime, in Fulton County, Georgia, on or about November 21, 2021,
unlawfully and knowingly obtained vehicle repair services which were available only for
compensation, the value of which was at least $1,500.01 but less than $5,000.00, from Palmer
Dodge Chrysler Jeep Ram by deception and with the intent to avoid payment, contrary to the
laws of said State, the good order, peace, and dignity thereof;

COUNT 25 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of DEPOSIT ACCOUNT
FRAUD, O.C.G.A. § 16-9-20, for the said accused, individually and as a person concerned in
the commission of a crime, and together with unindicted co-conspirator Individual 1, whose +

identity is known to the Grand Jury, in Fulton County, Georgia, on or about November 21, 2021,
unlawfully made, drew, and delivered Check Number 212, an instrument for the payment of
money on Navy Federal Credit Union, a bank located within the State of Georgia, to Palmer
Dodge Chrysler Jeep Ram in the amount of $2774.40 for the present consideration of vehicle
repair services, knowing that said check would not be honored by the drawee, contrary to the
laws of said State, the good order, peace, and dignity thereof;

29
 COUNT 26 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of IDENTITY FRAUD,
O.C.G.A. § 16-9-121, for the said accused, in Fulton County, Georgia, on or about December 1,
2021, unlawfully, willfully, and fraudulently, without authorization and consent, used a
Mastercard credit card number ending in 8161 belonging to Melody Skretchen, identifying
information concerning a person, for an unauthorized purchase in the amount of $2000.00 at
Precinct One Auto Sales, Inc., contrary to the laws of said State, the good order, peace, and
dignity thereof;

COUNT 27 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of IDENTITY FRAUD,
O.C.G.A. § 16-9-121, for the said accused, in Fulton County, Georgia, on or about December 1,
2021, unlawfully, willfully, and fraudulently, without authorization and consent, used a Visa
credit card number ending in 9747 belonging to Melody Skretchen, identifying information
concerning a person, for an unauthorized purchase in the amount of$1071.12 at Lara's Trucks,
Inc., contrary to the laws of said State, the good order, peace, and dignity thereof;

COUNT 28 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of IDENTITY FRAUD,
O.C.G.A. § 16-9-121, for the said accused, in Fulton County, Georgia, on or about December 2,
2021, unlawfully, willfully, and fraudulently, without authorization and consent, used a Visa
credit card number ending in 9747 belonging to Melody Skretchen, identifying information
concerning a person, for an unauthorized purchase in the amount of $800.00 at Lara's Trucks,
Inc., contrary to the laws of said State, the good order, peace, and dignity thereof;

COUNT 29 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of IDENTITY FRAUD,
O.C.G.A. § 16-9-121, for the said accused, in Fulton County, Georgia, on or about December 2,
2021, unlawfully, willfully, and fraudulently, without authorization and consent, used a
Mastercard credit card number ending in 8161 belonging to Melody Skretchen, identifying
information concerning a person, for an unauthorized purchase in the amount of $1000.00 at
Lara's Trucks, Inc., contrary to the laws of said State, the good order, peace, and dignity thereof;

30
 COUNT 30 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of IDENTITY FRAUD,
O.C.G.A. § 16-9-121, for the said accused, in Fulton County, Georgia, on or about December 4,
2021, unlawfully, willfully, and fraudulently, without authorization and consent, used a Visa
credit card number ending in 4860 belonging to Melody Skretchen, identifying information
concerning a person, for an unauthorized purchase in the amount of $1000.00 at Lara's Trucks,
Inc., contrary to the laws of said State, the good order, peace, and dignity thereof;

COUNT 31 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of THEFT BY TAKING,
O.C.G.A. § 16-8-2, for the said accused, Fulton County, Georgia, on and between January 1,
2022, and January 31, 2022, the exact date being unknown to the Grand Jury, unlawfully took a
2018 Nissan Altima vehicle, the property of Melody Skretchen, the value of which was at least
$5,000.00 but less than $25,000.00, with the intention of depriving said owner of said property,
contrary to the laws of said State, the good order, peace, and dignity thereof;

COUNT 32 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
CONSPIRACY TO COMMIT UNAUTHORIZED PRACTICE OF LAW, O.C.G.A. §§ 16-
4-8 & 15-19-51, for the said accused, individually and as persons concerned in the commission
of a crime, in Fulton County, Georgia, on or about February 7, 2022, unlawfully conspired to
cause ERICA KING, a person not a duly licensed attorney at law, to practice and appear as an
attorney at law for EARNEST WILLIAMS before the Magistrate Court of Fulton County,
Georgia, to hold herself out to Judge Ashley Drake as being entitled to practice law, and to
render legal services in Fulton County Magistrate Court Case Number 21MAGC-00111;

And ERICA KING, a person not a duly licensed attorney at law, did practice and appear
as an attorney at law for EARNEST WILLIAMS before the Magistrate Court of Fulton County,
Georgia, did hold herself out to Judge Ashley Drake as being entitled to practice law, and did
render legal services in Fulton County Magistrate Court Case Number 21 MAGC-00111, which
were overt acts to effect the object of the conspiracy, and said crime was unknown until at least
June 10, 2022, contrary to the laws of said State, the good order, peace, and dignity thereof;

31
 COUNT 33 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
FILING FALSE DOCUMENTS, O.C.G.A. § 16-10-20.1, for the said accused, individually
and as persons concerned in the commission of a crime, in Fulton County, Georgia, on or about
February 7, 2022, unlawfully and knowingly filed a document titled "NOTICE OF
APPEARANCE AND SUBSTITUTION OF COUNSEL" in the matter of REGINA DELANEY
vs. ERNESTO WILLIAMS, Case Number 21MAGC-00111, in the Magistrate Court of Fulton
County, Georgia, knowing and having reason to know that the document was false and contained
the materially false statement and representation that the document had been prepared and filed
by attorney April Holloway, contrary to the laws of said State, the good order, peace, and dignity
thereof;

COUNT 34 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
IDENTITY FRAUD, O.C.G.A. § 16-9-121, for the said accused, individually and as persons
concemed in the commission of a crime, in Fulton County, Georgia, on or about February 7,
2022, unlawfully, willfully, and fraudulently, without authorization and consent, used the name
of attorney April Holloway, identifying information concerning a person, in a false document
titled "NOTICE OF APPEARANCE AND SUBSTITUTION OF COUNSEL" filed in Fulton
County Magistrate Court Case Number 21 MAGC-00111, contrary to the laws of said State, the
good order, peace, and dignity thereof;

COUNT 35 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
IDENTITY FRAUD, O.C.G.A. § 16-9-121, for the said accused, individually and as persons
concemed in the commission of a crime, in Fulton County, Georgia, on or about February 7,
2022, unlawfully, willfully, and fraudulently, without authorization and consent, used the name
of attorney April Holloway, identifying information concerning a person, by falsely representing
to Judge Ashley Drake that ERICA KING was attorney April Holloway while purporting to
represent EARNEST WILLIAMS in a warrant application hearing in Fulton County Magistrate
Court Case Number 21MAGC-00111, contrary to the laws of said State, the good order, peace,
and dignity thereof;

32
4 z

COUNT 36 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of THEFT BY TAKING,
O.C.G.A. § 16-8-2, for the said accused, in Fulton County, Georgia, on and between March 28,
2022, and April 17, 2022, unlawfully took United States currency, the property of Christine
Mays, the value of which exceeded $24,999.99, with the intention of depriving said owner of
said property, contrary to the laws of said State, the good order, peace, and dignity thereof;

COUNT 37 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
CONSPIRACY TO COMMIT UNAUTHORIZED PRACTICE OF LAW, O.C.G.A. §§ 16-
4-8 & 15-19-51, for the said accused, individually and as persons concerned in the commission
of a crime, in Fulton County, Georgia, on or about June 10, 2022, unlawfully conspired to cause
ERICA KING, a person not a duly licensed attorney at law, to hold herself out to Mark Krol as
being entitled to practice law and to render legal services by sending a fraudulent demand letter
to Mark Krol while purporting to represent Black Heritage Radio Association Trust;

And ERICA KING, a person not a duly licensed attorney at law, did hold herself out to
Mark Krol as being entitled to practice law and did render legal services by sending a fraudulent
demand letter to Mark Krol while purporting to represent Black Heritage Radio Association
Trust, which were overt acts to effect the object of the conspiracy, contrary to the laws of said
State, the good order, peace, and dignity thereof}

COUNT 38 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS and ERICA KING with the offense of
WENTITY FRAUD, O.C.G.A. § 16-9-121, for the said accused, individually and as persons
concerned in the commission of a crime, in Fulton County, Georgia, on or about June 10, 2022,
unlawfully, willfully, and fraudulently, without authorization and consent, used the name of
attorney Eileen Moorman, identifying information concerning a person, in a fraudulent demand
letter addressed to Mark Krol while purporting to represent Black Heritage Radio Association
Trust, contrary to the laws of said State, the good order, peace, and dignity thereof;

33
 COUNT 39 of 39

And the Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, do
hereby charge and accuse EARNEST WILLIAMS with the offense of THEFT BY TAKING,
O.C.G.A. § 16-8-2, for the said accused, in Fulton County, Georgia, on or about June 30, 2022,
unlawfully took a 2002 Prevost Liberty vehicle, the property of Gayle Bickham, the value of
which exceeded $24,999.99, with the intention of depriving said owner of said property, contrary
to the laws of said State, the good order, peace, and dignity thereof;

And further, as to the offenses charged in this indictment, the period in which a
prosecution must be commenced under 0.C.G.A. § 17-3-1 and other applicable statutes does not
include the dates beginning March 14, 2020, and ending June 30, 2021, pursuant to the Supreme
Court of Georgia Order Declaring Statewide Judicial Emergency issued on March 14, 2020, and
subsequent Orders Extending Declaration of Statewide Judicial Emergency issued on April 6,
May 11, June 12, July 10, August 11, September 10, October 10, November 9, and December 9,
2020, and January 8, February 7, March 9, April 8, May 8, and June 7, 2021;

FANI T. WILLIS
District Attorney

34
 WITNESS LIST

Sr. Inv. B. Ansel FCDA

-

Det. N. Fields Roswell PD

-

35