Affidavit To Attorney General Businessman Journey by alicejenny


									Office of the United States Attorney General
Honorable Eric C. Holder, Attorney General
Justice Department, Main Justice Building
10th Street & Constitution Avenue, N.W.
Washington, DC 20530

                                      February 14, 2011

Dear Honorable Eric C. Holder,

This Affidavit is being submitted to The Honorable Eric C. Holder, The United States
Attorney General, with a copy to The Honorable Mr. Barack Obama, President of the
United States, The Honorable Michael DeWine, Attorney General, State of Ohio and to
The Honorable Sherrod Brown, U.S. Senator of Ohio. I am officially requesting the
United States Attorney General’s office conduct an investigation into past actions and
activities of Federal and State Department of Justice Officials, in Northern Ohio and
Lorain County Ohio.

                 ) ss:                         AFFIDAVIT

LARRY D. JONES, being first duly sworn, according to law, deposes and states as

My name is Larry D. Jones. My family and I have resided in the City of Elyria, in Lorain
County Ohio for the past 35 years.

On November 20, 2010, I completed serving a 37 month prison sentence, which included
33 months Federal incarceration and 3 months State of Ohio incarceration.

I was indicted in March 29, 2006, on a total of 38 felony counts, (Case # 1:06cr00148),
by the U. S. Attorney for the Northern District of Ohio and 19 felony counts by the
Lorain County Prosecutor,(Case # 06CR070308), dated March 29,2006. Records show
that On December 13, 2006, I was indicted on 18 additional felony counts by the Lorain
County Prosecutor in case # 06CR072431. My federal and state indictments combined
totaled approximately 75 counts.

I am officially and humbly requesting a thorough and in-depth investigation into, what
appears to be improper and possibly unlawful conduct and actions against me by Mr.
Gregory White, while serving as Lorain County Prosecutor and later as the United States
Attorney of the Northern District of Ohio. I contend that Mr. Dennis Will, while a
detective in the Lorain County Prosecutor’s Office and later as Lorain County Prosecutor,
Mr. John M. Siegel, Assistant U. S. Attorney and FBI Special Agent, Mr. David Lyons
aided and abetted U. S. Attorney Gregory White in his improper and unlawful actions.

This possible improper and unlawful conduct and action involves and are related to;
Cuyahoga County civil cases (01CV129861) & (01CJ002258) filed on 10/30/2001; and
(02CV130469) filed on 10/24/2001, this case was later transferred to Lorain County
Court of Common Pleas on 01/16/2002.; civil cases 03CJ008247 dated 6/26/2006 and
(03CJ009015) dated 09/05/2003; and Federal criminal case (1:06cr00148) dated
3/29/2006 and Federal civil case (1:04CV2254) dated 11/12/2004 and Federal
Bankruptcy case (05-19361) in 2005 and a March 2000 bank fraud in Elyria Ohio. These
actions also include the destruction of critical State Court documents and records; a high
profile drug case; the sealing of Federal Court records and bank loan documents.

I am also officially and humbly requesting the United States Attorney General, through
the Ohio Attorney General, Mr. Michael DeWine, conduct an in-depth and thorough
investigation into possible improper and unlawful conduct and actions against me, by Mr.
Dennis Will while serving as an investigator for the Lorain County Prosecutor’s office
and as Lorain County Prosecutor. I contend that Lorain County Prosecutors Tony Cillo
and Richard Noland and Lorain County Investigators Mr. Robert Gayle, Bob
Cunningham and Robert Finch, aided and abetted Prosecutor Dennis Will in his improper
and unlawful actions.

The possible improper and unlawful conduct and action involves; a high profile drug
case, various investigations, Lorain County Common Pleas court, criminal cases #
(06CR0724310 dated 12/13/2006, (06CR070308 dated 03/29/2003 and civil case #
(02CV130469) dated 01/16/2002 and Cuyahoga Common Pleas Court case # (CV-01-
451574), dated approximately 11/09/2001; and the destruction of critical Lorain County
Court of Common Pleas, court documents, evidence and records.

I think the evidence will also show that Mr. Gregory White as, Lorain County
Prosecutor and United States Attorney and Mr. Dennis Will as, Lorain County
Investigator and Lorain County Prosecutor, committed prosecutorial misconduct
and violated their moral, ethical and legal obligations in their conduct and actions
against me and violated my constitutional rights.

Under extreme duress, I finally agreed to accept a plea agreement offered by the U.S.
Attorney. The reason for accepting this plea under extreme duress, began when an
adversarial relationship between Mr. Gregory White and I formed in or around 1982.
This negative relationship began when Mr. White became aware that he and I had the
same two powerful republican individuals as mentors; Mr. Eric Nord, Chairman of
Nordson Corporation and Attorney Scribner Fauver, Partner in the Law firm of Fauver,
Tattersal & Gallagher.

At the time, I was a democrat but because of my very visible civic and business activities;
(brought a National Urban League Affiliate Chapter to Lorain County, started the first
mainstream business, member of a bank board and what would become many other
“firsts” by an African American in Lorain County) I became my mentor’s “favorite son”.
The relationship between Prosecutor White and I declined even more after I was
successful in getting a Minority Business Participation Program passed into law by the

Lorain County Commissioners in 1985. Mr. Virgil Muntean, the County Administrator
and I were responsible for the content in this Minority Business Program.

My relationship with Mr. White became poisonous in or around 1986 after I charged the
Lorain County Government with violating its sealed bid, bidding process. Prosecutor
White had to represent and defend the County against my charges.

My firm, Erie Shores Computer Inc. and the County Commissioners eventually reached
an out of court settlement in 1987 and County Prosecutor White was directed to complete
the settlement process. This settlement paid Erie Shores Computer $115,000.00 in

The approximate 8 months of hearings and proceedings had not gone well for Prosecutor
White. Hindsight clearly tells me that it was a mistake to require Prosecutor White to
travel to my legal firm’s offices, (Thompson, Hine & Flory), in downtown Cleveland to
sign the settlement agreement because, by the end of our meeting Prosecutor White was
no longer able to hide or hold his anger and threatened me. He stated as he starred at me,
red faced, from across the conference room table, “I’m going to get you” and quickly
exited the room. The three of us, (my attorneys and I), held a brief session to confirm
what we had just heard. My attorneys then suggested that I should be very careful in
Lorain County and not to expect any more business from the Lorain County Government;
and for approximately 11 years, Erie Shores Computer received no appreciable business
from the County government.

The fear of Prosecutor Gregory White by the law firms in Lorain County was the reason
Mr. Eric Nord arranged for me to obtain the legal services of the Cleveland law firm of
Thompson, Hine & Flory, where his good friend William Ginn was a Partner.

Both mentors cautioned me about their other mentee, Greg White and what they felt was
his inability to control his temper and his insensitivities toward certain social issues. Both
men suggested that I have as little future interaction with Greg as possible and I followed
their advice from 1987 through late 2003.

Mr. Eric Nord served on the Erie Shores Computer Inc. Board of Directors for 11 years,
(1988 thru 1998), and Scribner L. Fauver served as my family attorney and the Erie
Shores Corporate Legal Counsel for approximately 17 years, (1983 thru 2000).

My payment to Mr. Eric Nord and Attorney Scribner Fauver for their years of service to
Erie Shores Computer was my promise to them that I would keep the Erie Shores
Computer Inc. headquarters located in Lorain County. Both of these powerful leaders
believed that Erie Shores could be a catalyst for minority business creation in Lorain
County. Erie Shores was the first and only minority owned and operated, mainstream
firm in the county’s history.

The following is a partial listing of the information and evidence the justice officials
knew about or should have known about before my federal and state indictments.

Proceeding to indict me after having this mountain of evidence and information,
(from 1990 thru 2006), convinced me that the injustices being committed against me
by these powerful justice official, would totally destroy me if I continued to fight
against them. Therefore, I felt I had no choice but to accept the federal plea
agreement being offered by these justice officials.

   1. The Lorain County Prosecutor and United States Attorney received false and
      incriminating information against me in late 2000, submitted by the 2 individuals
      who, (later evidence would reveal) committed the FirstMerit Bank/Elyria, March
      2000 loan fraud. No charges were ever filed against these individuals. Erie Shores
      Computer Inc. was the guarantor of these loans, ($1,600,000 & $400,000) and my
      wife Barbara A. Jones and I were 2 of the signers of these loans.

   2. The evidence was crystal clear the two owners of Star Beverages Inc.
      DELAWARE; the firm and the owners approved for the March 2000 bank loans,
      had no personal assets and Star Beverage Inc. had no business assets, at the time
      these loans were approved by the bank. In addition, the firm’s $69,000,000
      beverage contract with the U.S. Navy was a fraud and the “Registered Beverage
      Formulas”, and the $17,000,000 Valuation of Star Beverage Inc. DELAWARE
      was also fraudulent; critical facts which the federal and state officials knew about
      or should have uncovered during their investigations.

       Having all of this evidence against this firm and its owners, Gregory White, the
       Lorain County Prosecutor and later as U.S. Attorney, filed no charges against the
       firm or its owners, nor were any actions taken against the FirstMerit Bank/Elyria
       officials or Hauser & Taylor LLC, the firm hired by the bank to perform due
       diligence on the signers of these two major loans.

   3. In September 2001, I filed charges against Star Beverage Inc. DELAWARE and
      its owners and was awarded a Cognovits Judgment, in the amount of
      $1,423,352.64 plus 10% interest per annum, from 10/30/2001, as the result of
      the fraud that occurred in the Star Beverage Inc. DELAWARE loan at FirstMerit
      Bank/Elyria. I was unable to collect any funds or assets from this judgment
      because Boyd, Perry and Star Beverage Inc. DELAWARE had not own any assets
      for many years.

       Even after my successful judgment against Star Beverage Inc. DELAWARE, and
       its owners, no federal or state charges were filed against the firm or its owners, or
       the bank officials or the firm that performed due diligence.

   4. A business associate and I were alerted by an experienced bank, business loan
      officer and financial expert that the $4,000,000 loan/line of credit, provided to
      Erie Shores Computer Inc., in July of 2001 by National City Bank was considered
      a “nigger loan” in the banking industry. This loan was considered a “nigger loan”
      because of the numerous requirements and restrictions, especially those contained

   in one of the loan documents which reduced the $4,000,000 loan/line of credit to
   an “asset based line” of credit.

   Even more damaging was the fact that National City Bank did not include the
   required and necessary “working capital” with this Asset Based line”. The lack of
   working capital rendered this $4,000,000 line of credit of no value to Erie Shores
   Computer Inc.

   The U.S. Attorney, FBI, Lorain County Prosecutor and County Investigators
   became aware of this discriminatory bank contract that National City Bank had
   signed with Erie Shores Computer Inc. on July 7, 2001, because I alerted them
   and because the Court Receiver and Federal and State Justice Officials, in or
   around late 2003, took possession of approximately 185 boxes of my personal and
   Erie Shores Computer’s corporate and business records. These officials took no
   action against the bank but in 2006 proceeded to file criminal charges against me

5. I became aware in mid 2008 that National City Bank had been allowed to
   withhold and not file in State Civil Court in 2003 and Federal Criminal Court in
   2006, the critical loan document, (“nigger loan”), that reduced the Erie Shores
   Computer $4,000,000 line of credit to an unusable asset based line.

   The U.S. Attorney knew that National City Bank had withheld this critical loan
   document from state and federal court and also knew there was no written
   document or verbal notice provided to Erie Shores or to me personally that
   National City Bank had reduced the $4,000,000 credit line, to a $3,000,000 line,
   as is stated in the federal indictment against me.

6. On December 3, 2003, I sent an overnight package, containing an Affidavit
   and two other documents, via Federal Express to United States Attorney,
   Gregory White. This Affidavit and documents contained critical information
   about the FirstMerit Bank/Elyria, March 2000 loan fraud and how funds
   from this fraud and earlier frauds were possibly involved in Middle East
   terrorist funding, the $4,000,000 National City Bank line of credit to Erie
   Shores Computer Inc. and the criminal role a fulltime attorney for the City
   of Cleveland played after the city awarded a technology contract to Erie
   Shores Computer.

   This affidavit contained critical information and documentation about
   proven terrorist activities that an associate and I had discovered were
   occurring in the inner city stores, in Cleveland and other large cities
   throughout Ohio.

   Most of the funds from the frauds committed by the owners of Star Beverage
   Inc. DELAWARE, (Dr. Arthur B. Boyd Jr. & Dr. Merceda Perry), were used

       to purchase Star brand beverages from Deep South Beverage Inc., in
       Fitzgerald, Georgia.

       Evidence uncovered showed that persons of Middle Eastern decent who
       owned these stores were doing the following:

          A. Hundreds of thousands of cases of the Star beverages were shipped to
             Arthur B. Boyd Jr. in the Cleveland area and to Merceda Perry in the
             Greensboro, North Carolina area.

          B. Arthur Boyd sold hundreds of thousands of dollars of the Star
             beverage drinks to the inner city stores throughout Ohio, for
             $2.00/case. Dr. Perry sold tens of thousands of cases of these beverages
             to outlets and stores in the Greensboro and Asheboro, North Carolina
             areas. They could afford to sell this beverage at a prices below cost
             because they purchased these beverages with funds defrauded from
             institutions and individuals, including some of the funds from the
             FirstMerit Bank/Elyria March 2000 loans. Boyd and Perry reported
             $00 sales to the federal government; therefore they paid no income
             taxes on hundreds of thousands of cases of beverages over an
             approximate 6 to 8 year period.

          C. The owners, (Middle Eastern Decent), of the inner city stores sold this
             beverage in their stores for between $.50 & $.70 per 12oz. can. These
             owners paid $00 sales tax or income tax on this beverage.

          D. It appears that a percentage of these funds from the beverage sales
             were funneled to the Cleveland Mosque and possibly other Ohio
             Masques and some of these funneled funds appear to have been sent
             to organizations assisting Middle Eastern terrorist organizations.

On December 12, 2003, (9 days after my Affidavit) an Associated Press article stated
that “the U. S. Government’s efforts to track the trail that terrorist organizations
used to bankroll acts of violence are flagging and must be improved”. “The Justice
Departments are struggling to understand how the financing of terrorist works”.

After all of this critical information was provided to U.S. Attorney, Gregory White,
he made no contact with me via phone, written or in person, to discuss the
information provided in my affidavit but evidence appears to show he used my
terrorist information almost immediately afterwards in official Justice

This was my first attempt to communicate with Gregory White since the agreement
signing in 1987 and he refused. Gregory White refusal as the U.S. Attorney to speak

or meet with me, after I provided the Justice Department these critical documents,
convinced me that he was still dealing with the personal vendetta against me. My
concerns were compounded when White’s actions, coupled with the fact that just a
few months prior, his mentee, Detective Dennis Will while investigating the criminal
activity of Attorney Michael Ross in the Columbus Ohio area, was informed about
Ross’ attempt to use my credit through a forged Power of Attorney and Detective
Will made no attempt to contact me or bring charges against Michael Ross.

   7. U.S. Attorney, Gregory White proceeded to indict me on criminal charges 27
      months after receiving my critical affidavit; after being made aware of the “nigger
      loan” document; after the civil settlement had been reached by National City
      Bank and Erie Shores Computer and after the evidence was revealed in the March
      2000, FirstMerit Bank/Elyria bank fraud that awarded me a Cognovits Judgment.

   8. The justice officials also did not take into consideration, during their federal and
      state investigations, the fact that approximately $2,000,000 of infusions and
      investments in Erie Shores Computer had been made by my wife, my sister and
      me. These infusions and investments were made before and after the July 7, 2001,
      National City Bank loan to Erie Shores Computer Inc., and the September 11,
      2001, (9/11) terrorist strike on New York and Washington. These infusions and
      investments were desperately needed after learning that this new $4,000,000 line
      of credit from National City Bank would not cover or include the financing of any
      Erie Shores’ federal, state or local governmental sales. This new credit line with
      National City Bank excluded the financing of more than 70% of Erie Shores
      Computer’s total historical sales volume.

       The federal crimes, (bank fraud and money laundering), that I agreed to in my
       plea agreement were suppose to have been committed during the same period the
       $2,000,000 of infusions and investments were being made in Erie Shores and
       New World Beverages. These major infusions indicated clearly that I had no
       criminal intent in my actions pertaining to the Erie Shores Computer $4,000,000
       line of credit from National City Bank.

        In addition I must assume that all three of the Erie Shores Computer Inc. office
       employees, (Vice President of Administration, Accountant & Bookkeeper), when
       they were interviewed by the federal and state authorities, informed these officials
       about the instructions I had given each of them in a number of meetings. The
       instructions given these three employees were; (A) To increase some Erie Shores
       invoices and create other invoices because I had been unsuccessful in obtaining
       any additional funds from the bank and funds were needed to keep Erie Shores
       operating without laying off any employees, (B) I assured these three Erie Shores
       employees that I had been promised additional investments in Erie Shores to
       cover the amount of increases that would be made by the increasing and creating
       of invoices. (C) I assured and promised all three employees that if anything went
       wrong and legal action was taken, I would accept full responsibility for these

   actions and (D) I also instructed my office team to keep an accurate record of the
   total amount of funds created through the invoice increases and creations so every
   penny could be repaid.

   The federal officials, (FBI, U.S. Attorney, IRS & State Investigators) who
   investigated my case, knew or should have known about my actions mentioned

9. Because of an ongoing investigation of Michael Ross, (a public official, attorney
   and CPA), over a 10 to 12 year period by state and federal officials; both entities
   knew or should have known that this public official was a sociopath with a serious
   drug problem. These officials also knew Attorney Ross had been financially
   scamming and abusing his clients, family members, associates and friends for
   many years but took no actions against him.

   The Attorney Ross, whom I met around 1994 and 1995, is not the same person I
   would come to know during 2003. I met a young energetic and extremely bright
   gentleman who could capture your attention with his conversation. An individual,
   who was raised by his grandparents, joined the U.S. Navy and travelled the world.
   Ross’ IQ and test scores awarded him the unique opportunity to attend the Case
   Western Reserve University, where he received his Law and CPA degrees.

   Only years later would I realize, (after meetings with three different Clinical
   Psychologists, who explained the sociopath, their abilities and behavior), the
   dangers this association with Ross had exposed to me, my family and Erie Shores.
   Ross had presented himself perfectly and gained my trust and confidence and also
   the trust and confidence of many other county, state and national leaders.

   Ross and I had met a number of times between 1994 and 1996 and had enough
   brief conversations where he had become aware that I owned Erie Shores
   Computer, served on a bank board and was a hospital trustee. In 1996, Ross asked
   and I agreed to hold a fund raiser for him to help finance his campaign, in his
   second attempt to win a Commissioner seat. The fund raiser was held at Spring
   Valley Country Club, where I was the first African American member.

   Ross was well aware of the lack of minorities employed in county government
   jobs in Lorain County. I had also updated him about my problems with Prosecutor
   White and the County Commissioners. Ross stated that he viewed Greg White as
   a racist, based on their many interactions during the years he, (Ross) served as the
   Safety Service Director for the City of Lorain, Ohio. Ross informed me that if
   elected he would focus on the hiring of minorities in county government; (at the
   time there were approximately 3 African American County employees), and the
   participation of minority firms in county government contracts.

   Erie Shores provided Ross some legal work and he was surprised at the size and
   profitability of the company; having major contracts with Wright Patterson Air

   Force Base, the City of Cleveland, Cuyahoga County, Cleveland Board of
   Education, State of Ohio and many other entities. Ross was also impressed that I
   had received “Top Secret Clearance” from the federal government.

   Ross made history becoming the first African American to be elected to a Lorain
   County Commissioner’s seat and only the second African American in Ohio’s
   history to hold a county wide elected seat. At this point, I personally felt this
   young man was on his way to becoming a state wide elected official and I felt
   blessed to be in a position to help make this happen. But hindsight tells me that
   Ross was already on a downhill path, because of his expensive lifestyle which
   included women, extensive travel, a gambling habit and a serious drug habit.

   During Ross’ four years as County Commissioner, he was seldom in the county to
   manage the County’s business, to attend Commissioner’s meetings or to vote on
   County legislation.

   Ross’ many previous victims knew of his dark side but more importantly, the
   Federal and State Justice Officials had known about Ross’ crimes for years but
   took no action to bring him to justice. Mr. Gregory White, along with other justice
   officials, business, civic and political leaders were well aware of my reputation as
   an upstanding and very public citizen in Northern Ohio and Lorain County for
   more than 25 years. In addition, United States Attorney Gregory White had
   received my sworn Affidavit and letter to Mr. William MacDonald , Vice
   Chairman of National City Bank, on December 3, 2003, (40 months prior to my
   March 29, 2006 arrest), explaining in detail the actions and activities between
   November 1999 and June of 2003, that lead to my misuse of the Erie Shores
   Computer Inc. $4,000,000 Asset Based line of credit.

10. Former Lorain County Prosecutor Gregory White, having served as
    prosecutor for more than 20 years and the present County Prosecutor,
    Dennis will, knew, (because it was their responsibility to know), that it was
    all but impossible for a County Commissioner or even two Commissioners to
    rig or commit bribery in the Lorain County sealed bid, bidding process;
    without the County Administrator’s direct involvement and assistance.

   Mr. Virgil Muntean was the Lorain County Administrator from around 1975
   through late 2000. I am sure Prosecutor White knew Mr. Muntean well and was
   sure he would never be involved in any bid tampering or bribery. Knowing this,
   U.S. Attorney White and Prosecutor Will proceeded to file numerous criminal
   charges, including bribery against former Commissioner Ross and me in 2005 and
   2006 but no charges were filed against the present or former County
   Administrator. These bribery charges were the first ever filed against a Lorain
   County Commissioner and a businessman in the County’s history.

   In or about mid 2000, prior to the Commissioners’ official actions and votes
   approving the Architectural and Construction Management firms, that would be

responsible for the design and construction of the new Lorain County Justice
Center, the three Commissioners voted to replace Virgil Muntean, the present
County Administrator with Mr. James Cordes. Mr. Muntean was highly upset and
disappointed with the Commissioners at their abrupt removal of him from his long
time position. So to appease Virgil the Commissioners created the temporary
position of “Capital Improvements Project Director” which Muntean held briefly,
until his retirement. The Capital Asset Manager’s position, (as Muntean referred
to it) was retired along with Muntean.

Almost immediately after the change in County Administrators, the County
Commissioners voted approval of the Architectural and Construction
Management firm that would design and build the $53 million Lorain County
Justice Center. Shortly after the Justice Center approval, the new County
Administer abruptly cancelled the computer maintenance contract that Erie
Shores Computer Inc. had been awarded by the County in a sealed bidding
process. No explanation was given why this contract had been cancelled. I would
later discover that this maintenance contract was assigned to Micro Advantage,
another local technology firm. Of course I protested this action but no corrective
action was taken on Erie Shores Computer’s behalf but the Avon Lake Prosecutor
eventually charged Mr. Robert Rousseau, the Chairman of the Lorain County
Republican Party, with “having an unlawful interest in a public contract”. It had
come to light that Mr. Rousseau was a paid consultant for Micro Advantage and
had used his influence to have the computer maintenance contract taken from Erie
Shores Computer and assigned, (not awarded or won) to Micro Advantage. Lorain
County Prosecutor Gregory White investigated Mr. Rousseau’s activities but took
no action. Prosecutor White later that year accepted the position of U.S. Attorney
for the Northern District of Ohio. A distant time later, Mr. Rousseau received a
slap on the wrist for his illegal actions.

11. In early 2000, the Old J.C. Penny building in downtown Elyria was leased
with an option to purchase by Star Beverage Inc. DELAWARE. This was the
facility located in a federal HUBZone that would produce the beverages to fulfill
the $69,000,000, U.S. Navy contract. Erie Shores Computer was the cosigner for
the lease of this building at $6,000 per month.

Shortly after the lease was signed and after approximately 14 tractor trailer loads
of beverage line equipment had been delivered to the building from the State of
Idaho, I received a telephone message form Mrs. Pauline Laboatta, who had
recently been defeated in the Elyria Mayoral Campaign. She alerted me about a
major chemical spill that the neighboring, Harshaw Chemical Company had made
a few years prior and warned me if any beverages were produced in this Old J.C.
Penny Building, the beverages would probably glow; therefore she would alert the
local and national media. A decision was quickly made not to produce any
beverages at this site, even though extensive soil tests proved there was no
contamination present.

   The owners of the building had not informed Star Beverage of the chemical spill
   and Star Beverage had no funds available, therefore Erie Shores had to assume the
   $6,000 monthly lease, as cosigner. The building could not be used for beverage

   In or around August of 2000, I became aware through a Chronicle Telegram
   article that stated Commissioner Blair’s interest in renovating the old train station,
   which was a very short distance from the J.C. Penny building. For Blair’s train
   station project to be successful additional parking spaces would be needed. This is
   when I called Virgil Muntean and informed him that the Old J. C. Penny building
   was for sale and that Erie Shores and I held the option on the property. Muntean
   and I toured the 35,000 square foot building and he was impressed with the size
   and excellent condition of the building and commented that instead of parking
   space, the facility could solve a long standing County problem by serving as a
   facility to house large County owned equipment.

   Virgil requested a quote from me so I used the services of Prudential Real Estate
   Agent, Mr. Daniel Harris whom I had used to negotiate the option to purchase the
   J.C. Penny building from its owners for a price of $250,000. Agent Harris
   suggested a $450,000 value for the building so I submitted an offer to sell of
   $450,000 to Muntean. Muntean countered with an offer of $400,000 and I
   accepted his offer. This was probably the largest project handled by Muntean
   while in the position of County Capital Asset Manager.

   Mr. Muntean was the only County Official I contacted and communicated with in
   the sale of the Old J.C. Penny building to the county. If state and federal officials
   had investigated this sale and purchase process in an unbiased way, the evidence
   would have confirmed that this transaction was handled between Mr. Muntean
   and me. Gregory White was the County Prosecutor at the time of my purchase of
   this building from the owners and the sale of this building to Lorain County. As
   Lorain County Prosecutor, Gregory White was actively involved in the purchase
   of this building by Lorain County.

12. I had no doubt that all the charges in State Criminal case # (06CR070308),
03/29/2006, against me were false and not provable, but by this time I also realized
that my innocence in this case was probably not enough because I had permitted
Michael Ross to use me and Erie Shores Computer in a scheme in the building of the
Lorain County Justice Center. The federal and state justice officials were not aware of
the Justice Center illegal activity until they were informed by my attorney and me.

   I only agreed to assist Ross with his scheme after he had totally convinced me that
   he had involved Erie Shores Computer and me personally, in a dangerous and
   possibly life threatening situation that could also include our family members. He
   confirmed the threat from these individuals was the reason he carried the 38 pistol
   with him at all times. Ross stated that he had lead these individuals to believe he
   was the corporate legal counsel and part owner of Erie Shores Computer. This is

when he informed me of his plan to repay his debt to these dangerous individuals
without Erie Shores having to lose any money. All I had to do was permit funds
from the Justice Center to be paid through Erie Shores Computer to Ross.

I knew I had a critical decision to make about this extremely serious situation in
which Ross had involved me, my family and my company. I had to decide
whether to report this situation to County Prosecutor White or assist Ross in
obtaining the needed funds. Because of the long standing threat and vendetta
against me by Prosecutor White, I was convinced that there was a great possibility
he would find a way to charge me, along with Ross in the scheme. Therefore, I
made the decision that my family, my firm and I, would be safer if I assisted Ross
in getting the funds he needed to cover this debt.

Initially Ross informed me that all I had to do was permit his funds from the
Justice Center project to flow through Erie Shores Computer. Ross had assured
me that Erie Shores would be the minority firm the County would use to provide
the minority set aside portion of the Justice Center services and equipment. Later
Ross asked me to provide one additional service for him and that was to
communicate and meet with the Architectural firm and Construction Management
firm’s decision makers and assist with the negotiations for the minority business
amount. Ross could not perform this task because he was the public official. After
my initial meetings with Mr. Finkel, Mr. Gordon and Mr. Carbone I was well
aware that they thought they were providing a way for additional services and
products to be provided to the minority firm and that this would pretty much
assure their firm the leading position in the bid awarding process. To complete
these negotiations prior to the awarding of the contracts was critical for Ross
because he was pretty sure he would not be reelected as a County Commissioner.
It also appeared that Ross was no longer interested in being a County

After being indicted by U.S. Attorney, Gregory White and Prosecutor Dennis Will
on charges unrelated to the Justice Center scheme, I later made a decision to
inform the federal and state justice officials about the illegal scheme involving the
construction of the Justice Center and the role Erie Shores Computer and I played
in it. Prior to my official meeting with the state and federal justice officials, I was
warned by my attorney against attempting to explain in detail, what I believed
was “extreme circumstances and facts” about why I had involved Erie Shores and
myself in this illegal activity. He felt that my statements would be viewed as an
excuse and become a negative in my federal charges and effect the plea
agreement. Instead I was assured that the federal plea agreement that I would sign
would cover my federal and state charges. I was also assured that my maximum
incarceration time would be 37 months; all served under federal control, no matter
how many state convictions were achieved against me from the indictments in
state cases, (06CR070308) and (06CR072431. It was also alluded that the large
volume of state indictments in both cases, were filed to assure major convictions
against Ross. State case (06CR072431), is the case that covers the Justice Center

   charges. Although court records show a 12/13/2006 date for my indictments in the
   Lorain County Justice Center activities, my attorney and I had met with federal
   and state officials prior to July 17, 2006 and finalized my plea agreement, which
   also covered my Justice Center charges.

   After my attorney and I met with the state and federal officials and shared the
   Justice Center information, I was assured that I would be allowed to report to the
   Lorain County Jail, where I would be booked on these additional Justice Center
   charges and released. After I reported and was released, law enforcement officials
   arrived again at my home to arrest me on the charges for which I had just been

13. In or around 2001, Ross called to inform me that he had assisted a young lady
with a bond and her release from the Lorain County Jail and she had asked him to
become her legal counsel. Later Ross phoned and asked if he and his new client could
stop by my office one evening after the dinner hour. (I will refer to this person in this
document as “young lady” because she later met with a violent death). This would be
the first of only 2 times I would see this young lady in person. The second time came
a few months later when I accompanied Ross to Westlake, Ohio to pick her up from
the health spa. She was an attractive lady, very physically fit and appeared to be in
her mid thirties.

   During our first meeting, she informed me that she had gotten into some trouble
   with the county authorities and Michael had agreed to help her. Ross would later
   inform me that this young lady was mixed up in a major drug dealing/transporting
   operation, possibly the largest in the county’s history. She was now contemplating
   becoming the main witness for Lorain County Prosecutor, Gregory White, against
   her employer. For her testimony, charges against her would be dropped and she
   would be given a new identity.

   Once this young lady agreed to become the Prosecutor’s main witness, Prosecutor
   White assigned Detective Dennis Will, (his mentee) to protect her. She had no
   relatives in the area so she became dependant on Ross for her legal and moral
   support. She trusted Ross and informed and updated him on her activities, in
   person and via cell phone, especially after Detective Will began protecting her.

   Ross had informed me earlier that he was quite sure his phone was tapped and
   now he stated he was sure someone was listening in on his conversations.

   The following are some of the comments and statements the young lady left on
   Ross’ cell phone voice mail over a period of several months. Ross permitted me
   to listen to these messages and record many of them on my compact cassette
   recorder. I also spoke to the young lady twice while she was on the phone with
   Ross and she confirmed the statements and comments she had attributed to
   Detective Dennis Will.

       The following are some of those comments and statements:

       a. Michael, I think he is coming on to me.
       b. This redneck is trying to get me to fire you as my attorney. He asked me why
          did I have that nigger representing me and that I should get rid of you.
          Michael, he is a redneck but I can control him because I think he is infatuated
          with me.
       c. I think he wants to get in my panties.
       d. He is so persistent, he concerns me at times; he wants to protect me too much.
       e. Michael, he acts like he is not getting any at home. Maybe I should let him see
          it, smell it and maybe lick it; what do you think, (then laughter), that should be
          enough to satisfy his fat ass.

I informed the State Investigators about this activity during two interviews.

 There were more recordings but I cannot recall the other content. Sometime later Ross
informed me that the trial had ended and Prosecutor White had won the case, mainly
because of the young lady’s testimony.

I secured this tape in my office personal file cabinet, where I would retrieve and listen on
occasion. In mid 2003 Erie Shores Computer was forced into Court Receivership by
National City Bank. After this I no longer had free access to my office or my building
and around September of 2003, the Receiver seized all approximately 185 boxes of Erie
Shores’ corporate files and records and all of my personal business records. These
personal records included all personal items in my personal file cabinet, including the
cassette with the young lady’s recorded statements about Detective Will. After these
records were seized, they were turned over to U.S. Attorney White and then shared with
the Lorain County Prosecutor. These approximately 185 boxes of records have been in
the possession of the justice officials since they were seized in 2003.

On the morning of June 5, 2003, I received a frantic call from this young lady on my cell
phone. At the time of the call I was in Cleveland Ohio, entering a mediation session with
Microsoft Corporation’s corporate and local attorneys; a meeting where Erie Shores and I
were supposed to have Ross’ legal representation. The young lady was crying and
sounded very angry and frightened. She stated, “Larry have you seen Michael”. I can’t
reach him and he is not returning my calls. Can you locate him? I informed the young
lady that I had not seen Ross for a number of weeks.

I could not delay my meeting with Microsoft so I explained this to her. Her final
comments to me were; “they have used me and gotten what they wanted, including
Michael, and now I’m alone and Mr. Jones, I am scared. After my meeting with
Microsoft ended, I did not attempt to reach the young lady because I had no answers for

Ross did not show up for this critical meeting with Microsoft because he knew at this
point that I was probably aware of the lies he had told me about the dangers to my family

related to the Justice Center project. Ross terminated all contact and communication with

   14. At this point, Ross had received all of the $600,000 from the Justice Center
       project that was paid through Erie Shores Computer and through my
       personal bank accounts. Neither Erie Shores Computer nor I personally kept
       any of the funds from the Justice Center scheme. At this point my services
       and Erie Shores’ services were no longer important or valuable to Ross so he
       proceeds to commit crimes against me.

       In or around August or September of 2003, I received a call from Gregory A.
       Filbrun, President & CEO of First Commerce, Inc., a mortgage broker in the
       Columbus Ohio area. He stated he was calling me to confirm that I had provided
       Michael Ross my Power of Attorney, to use my credit to refinance four of his,
       (Ross’) properties. I informed Mr. Filbrun that no Power of Attorney had been
       provided to Ross. I immediately called Attorney John Keyse-Walker and alerted
       him of Ross’ actions and Attorney Keyse Walker phoned Mr. Filbrun and warned
       him not to use the fraudulent Power of Attorney in his possession. Attorney
       Keyse-Walker followed up his phone call to Filbrun with his demands in writing.

       Mr. Filbrun placed a second call to me a day or so after his first call. This is when
       he informed me that a Detective Dennis Will and a Lorain County Deputy had
       visited his office a couple of days prior to his first call to me. Detective Will was
       investigating possible illegal actions in which Ross were involved that involved
       one of his, (Filbrun) former clients. Filbrun stated that this is when he informed
       Detective Dennis Will about Ross’ attempt to forge my Power of Attorney.
       Filbrun stated that he was assured by Detective Will that he would be contacting
       me concerning Ross and his attempt to forge my Power of Attorney, as soon as he
       returned to Lorain County. I eagerly awaited this critical contact from Detective
       Will but it never came. Mr. Filbrun later provided Attorney Keyse-Walker a copy
       of the forged Power of Attorney. He had also provided Detective Will a copy of
       this forged document while he was in Columbus.

       Approximately 45 to 60 days after Ross’ Power of Attorney actions, he proceeded
       to use the information from one of my personal Visa Cards and charged
       approximately $6,700 to relocate his family from Lorain Ohio to the State of
       Georgia. I contacted Attorney Keyse-Walker again for legal guidance concerning
       Ross’ crimes against me. Attorney Keyse-Walker proceeded to caution me about
       taking any legal actions against Ross at the time because of the major problems I
       was already experiencing related to the Erie Shores Computer’s $4,000,000 line
       of credit with National City Bank and the Court Receivership of the company. A
       decision was made to file no charges against Ross.

   15. The main person, Arthur B. Boyd Jr., (in state civil case # (02CV130469), with
       filing dates of 10/24/2001 & 01/16/2002, where documents were destroyed and

   the case actual identification was changed), was forced into involuntary
   bankruptcy, in Federal Bankruptcy Court in mid 2005.

16. Attorney Larry Zukerman met with U.S. Attorney Gregory White and
    approximately 7 members of the U.S. Attorney’s team a few weeks prior to my
    indictment. After this meeting, Attorney Zukerman commented that this meeting
    was the most powerful meeting he had ever attended in the U.S. Attorney’s office.
    His first question of me was; Jones, what have you done to U.S. Attorney White?
    Whatever it is, it appears to be personal. He, (White) stated that nothing moves in
    Lorain County unless you are involved or know about it. It also appears that he
    thinks you are involved in the Mayor White and Nate Gray activities somehow,
    because of the comments made and because the Assistant U.S. Attorney who
    successfully prosecuted Nate Gray was present at the meeting.

17. Attorney Zukerman informed me that he and U.S. Attorney White had reached an
    agreement that if I was indicted, I would be permitted to turn myself over to the
    appropriate authorities. Instead a few weeks later, I was secretly indicted and
    approximately 7 U.S. Marshal Vehicles and 2 Deputy Sheriff vehicles arrived at
    my home to arrest me; while approximately the same number of marshals and
    deputies showed up at my office building to arrest me. I wasn’t at either location.

   After I was indicted on the extremely large number of federal and state charges,
   (approximately 75 total), Attorney Zukerman stated to me; Jones, you are in very
   serious trouble. If he, (Greg White) wants you, he is going to get you. This
   appears to be personal so just be aware that you are up against overwhelming
   power. I know this is your first time dealing with the federal justice system. It
   appears that your state and federal indictments will remain separate and you will
   be tried in federal and state court for maximum impact. Attorney Zukerman
   estimated the cost to defend me in the state and federal cases would amount to
   more than $250,000, in addition to the approximately $65,000 already paid.

   Attorney Zukerman later suggested that I should consider accepting the plea that
   was being offered by the U.S. Attorney and I refused, but when the federal
   officials later involved my sister and daughter, and knowing that my wife would
   be next, I had second thoughts about the plea agreement. Then another warning
   came from Attorney Zukerman; “Jones, Greg White wants you and your entire
   family could be destroyed in his efforts to get you”. This warning made me
   seriously consider accepting the plea being offered.

   The threat made against me by Lorain County Prosecutor, Gregory White in
   1987 and the actions and investigations, including what appeared to be
   massive cover-ups and withholding of critical evidence and information over
   an extended period of time, (approximately 86 months), by Lorain County
   Prosecutor and U.S. Attorney Gregory White and Lorain County Detective
   and Prosecutor Dennis Will, sealed my legal fate and the financial fate of my
   family and business.

When I accepted the plea agreement, I was well aware that Gregory White and
Dennis Will, the two most powerful men in the Federal and State of Ohio Justice
Departments, had personal vendettas against me and numerous reasons to want
me afraid and silenced.

Until these present charges against me, my most serious violations were speeding
tickets. I was certain at this point that neither the evidence, my rights nor justice
would play an important role on my behalf. This knowledge forced me into
mental states that lead me to conclude that I had no other choice than to accept the
plea agreement being offered.

This Plea made under extreme duress, forced me to admit that I committed
crimes that I had not committed. I was also forced to admit to and later
testify against Michael Ross about a number of crimes he did not commit.

The following critical decisions and actions by officials in the Federal and
State Departments of Justice confirms that these powerful individuals were
willing to take whatever steps necessary to cover their trails of deceit, cover-
ups and blatant misuse and abuse of judicial power and force.

A. My first concern and shock came in or around mid 2005, when FBI Special
   Agent, David A. Lyons and Lorain County investigator, Ralph Gale arrived at
   my home to officially inform me that I was under investigation by the U. S.
   Justice Department; an investigation that had already been active since late
   2000. Special Agent Lyons posed questions to me about the Erie Shores
   Computer loan/line of credit with National City Bank.

   I then posed the following questions to Agent Lyons, whom I had
   communicated with in person, via phone and in writing since late 2001; what
   is the status of the $69,000,000 Star Beverage Inc. contract, with the U. S.
   Navy and what entity,(which Star Beverage firm), has present ownership of
   this contract? Agent Lyons’ response was; “we knew long ago that this
   contract was a fraud”. I then asked Special Agent Lyons; what actions had
   the authorities taken against Dr. Arthur Boyd, (his partner Dr. Merceda Perry
   had died in 2002), for the FirstMerit Bank/Elyria, March 2000 loan fraud?
   Special Agent Lyons did not respond to this question.

   Between late 2001 and mid 2002, I provided Special Agent Lyons critical
   information and numerous documents that an associate and I had discovered
   and compiled about financial and related scams that Dr. Boyd had committed,
   before the March 2000 FirstMerit Bank/Elyria fraud.

B. My second concern and shock came in mid 2008, after I instructed my
   daughter to order a complete copy of my federal criminal case, (1:06cr00148).
   She was shocked when she was informed that only a portion of my case

           records were available to me because the other portion had been sealed. My
           daughter stated that even the lady assisting her with the documents,
           commented that this was very unusual.

       C. My third concern and shock came between January and June of 2010, after
          sending 4 certified letters to National City Bank/PNC Bank requesting a
          complete copy of the Erie Shores Computer Inc., July 7, 2001, $4,000,000
          loan/line of credit documents. After my third certified request, I had received
          only one of the five requested documents. Since my fourth certified request, I
          have yet to receive even a response form the bank. It appears that most of the
          Erie Shores Computer Inc. loan documents, (including the “nigger loan”
          document), are also sealed.

       D. My fourth and probably the most serious concern and shock came after I sent
          a certified letter to the Lorain County Court of Common Pleas Clerk, on
          February 17, 2010 requesting a copy of the documents, information, motions,
          depositions and per-trial records of civil case 02CV130469, filed on
          10/24/2001 and again on 01/16/2002. This case was initially file in Cuyahoga
          County Court of Common Pleas; Case # (CV-01-451574) as Plaintiff Arthur
          Boyd Jr., MD, a shareholder and Arthur Boyd Jr., Individually against
          Defendants, Star Beverage Inc. DELAWARE; FirstMerit Corporation,
          FirstMerit Trust Co., Erie Shores Computer Inc., Larry D. Jones, Merceda
          Perry, M.D. and Richard Buie. Then on January 16, 2002 this suit was
          transferred to the Lorain County Court of Common Pleas and filed as `Boyd
          Jr. vs. Star Beverage, Case # 02CV130469.

       The Lorain County Court of Common Pleas Legal Counsel responded to my
       request for information and documents on March 8, 2010 and informed me that all
       evidence and documents including depositions in case 02CV130469 had been
       destroyed by court order dated December 20, 2007. I had submitted my first
       written request for this information and documents on November 20, 2007,
       approximately 26 days prior to self surrendering to federal prison. I received no
       response or any alert that a document destruction approval order had been given.

       This court order approval for the destruction of approximately five years, (2001
thru 2005), of critical documents and evidence in civil case 02CV130469, appeared to
have been extremely premature and highly unusual. This destruction was also a major
blow to any future legal proceedings and actions in the FirstMerit Bank/Elyria, March
2000 bank fraud case and critical evidence in the Erie Shores Computer Inc., 2003
Receivership Case and my federal criminal case. The evidence and information in this
case were directly related and connected to and the main reason Arthur Boyd Jr. had been
forced into involuntary bankruptcy in 2005 and fraud charges filed against him in federal
court on November 12, 2004.

        The evidence already produced in case 02CV130469, (had the case proceeded to
trial), should have been enough for a jury to convict Boyd, Perry and Star Beverage Inc.

DELAWARE, in the FirstMerit Bank/Elyria, March 2000 bank fraud. This trial would
also have provided critical evidence showing why I had to take extraordinary actions
during the 39 month period of inactivity by the Justice Department in this case. These
were attempts to protect Erie Shores Computer, (the firm that guaranteed the Star
Beverage Inc. DELAWARE loans), from financial disaster.

       E. My fifth shock came in June of 2010 when I went on line to the Ohio
          Secretary of State’s web page and the section for, “registered businesses”, in
          the State of Ohio. I wanted to confirm again, as I had done a number of times
          between 2002 and 2005, the 8 to 10 firms registered to and by Arthur Boyd Jr.

           Boyd was the person whom, (had civil case 02CV130469 proceeded to
           trial), would have had to explain why he had incorporated two,(2)
           additional, identical Star Beverage firms; one incorporated in February
           2000, approximately 45 days prior to the March 2000 loans to Star
           Beverage Inc. DELAWARE. These two firms were identical to the Star
           Beverage Inc. DELAWARE firm that had been approved for the two
           major loans, ($1,600,000 & $400,000), from FirstMerit Bank/Elyria.

           Between 2002 and 2005, the Secretary of State’s web page listed
           approximately 8 to 10 firms registered to and by Arthur Boyd Jr. As of June
           2010, the Secretary of State’s web page listed no firms registered to or by
           Arthur Boyd Jr.; therefore indicating that no firms had ever been registered by
           Arthur Boyd Jr.

             *******         *******        *******        *******         *******

           In the realm of law enforcement, no function of government is more
           important and essential to this nation than the protection of its citizens
           from crime.

           I have always, as a law abiding citizen of this great nation, supported the
           duties and responsibilities of the Department of Justice, its investigative,
           prosecutorial, sentencing and incarceration of criminals in a fair and unbiased

           I also believe strongly that The President of the United States, Mr. Barack
           Obama and The United States Attorney General, Mr. Eric C. Holder, are
           committed to preserving the rights of all persons, including those accused of a
           crime and that they also uphold the constitutional protections against arrogant
           and arbitrary actions, by governmental officials of any sort; especially those in
           the Department of Justice.
           I believe the proper way to ensure good procedure by enforcement authorities,
           is to discipline those who violate the law. I also believe this same discipline
           should hold true for the unfair and unlawful actions of those employed by the
           Department of Justice.

It is a fact that, at times these very individuals and agencies become
overzealous and innocent citizens are caught up in their nets. Unfortunately it
is also factual that some who hold these, “all powerful positions” sometimes
use their power to settle personal vendettas and grudges.

I will always remember Monday, July 17, 2006 when I appeared before
Federal Court Judge James S. Gwin, to accept the plea that had been
offered. Upon turning to exit the courtroom, I saw U.S. Attorney,
Gregory White standing by the only exit in the rear of the courtroom. I
had no idea why he was standing there or what I would say or do to him;
but by the time I was close enough to touch him, I extended my hand and
shook his. U.S. Attorney White, as he accepted my handshake, looked at
me, then dropped his head and said; “man, I am sorry”. At that moment,
I could think of no response to his apology.

I look forward with great anticipation, to these thorough and in-depth
investigations, by the United States Attorney General and the Ohio Attorney
General offices.

I can assure the Attorney Generals and other Justice Officials; I have provided
and will continue to provide true and factual information. In addition to this
Affidavit, I will also submit to polygraph tests at appropriate times.

I am assuming and expecting that all individuals who are now or will become
a part of these investigations will also submit to polygraph testing.

          Affiant further sayeth naught

                                              LARRY D. JONES
                                              A United States Citizen

SWORN TO BEFORE ME and subscribed in my presence this 14th day of
February, 2011.

                                             Notary Public


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