Bence Indictment

<GRANDJURORSIGNATURE>
<PROSECUTORSIGNATURE>

Foreperson of the Grand Jury

Prosecuting Attorney

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Cuyahoga County Court of Common Pleas
Criminal Court Division

State of Ohio, A True Bill
Indictment For
Plaintiff Engaging In A Pattern Of Corrupt Activity - F1
VS. 2923.32(A)(1)
Larry Bence
Donna F. Bence
Abon Cards and Coins
Limited
Benjamin Berry,

Defendants 24 Additional Count(s)

Dates of Offense (on or about) The Term Of Case Number
03/01/2013 to 07/23/2014 May of 2014 587924-14-CR

The State of Ohio,

}

SS.

Cuyahoga County

Count 1
Engaging In A Pattern Of Corrupt Activity - F1

2923.32(A)(1)
Defendants
Larry Bence, Donna F. Bence, Abon Cards and Coins Limited, Benjamin Berry
Date of Offense
On or about March 1, 2013 to July 22, 2014
The Jurors of the Grand Jury of the State of Ohio, within and for the body of the County aforesaid, on their oaths, IN THE NAME
AND BY THE AUTHORITY OF THE STATE OF OHIO, do find and present, that the above named Defendant(s), on or about the
date of the offense set forth above, in the County of Cuyahoga, unlawfully
while employed by, or associated with, any enterprise did conduct or participate in, directly
or indirectly, the affairs of the enterprise through a pattern of corrupt activity or the collection
of an unlawful debt and at least one of the incidents of corrupt activity was a felony of the
first, second, or third degree, aggravated murder, or murder, or at least one of the incidents
was a felony under the law of this state that was committed prior to July 1, 1996, and
constituted a felony of the first, second, or third degree, aggravated murder, or murder or was
committed on or after July 1, 1996, or one of the incidents of corrupt activity was a felony
under the law of the United States or of another state that, if committed in this state on or
after July 1, 1996, would have constituted a felony of the first, second, or third degree,
aggravated murder, or murder under the law of this state.

On or between the 1
st
day of March, 2013 and July 22
nd
2014, in the County of Cuyahoga,
State of Ohio, or by some manner enumerated in Section 2901.12 of the Revised Code
whereby proper venue is placed in Cuyahoga County, DEFENDANTS, were associated with
an Enterprise, as defined in Section 2923.31(C) of the Revised Code.
Cuyahoga County Court of Common Pleas A True Bill Indictment





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This Enterprise is an illicit enterprise under O.R.C. 2932.22, whether or not this Enterprise
existed separate and apart from the pattern of corrupt activity described in this Indictment.

This Enterprise functioned as a continuing unit by engaging in the diverse forms of illegal
activities, as stated in this Indictment. In so doing, the DEFENDANTS NAMED BELOW
are persons associated with the Enterprise who participated in and/or managed the affairs of
the Enterprise, as explained in this Indictment. As such, these persons provided continuity
and structure to the Enterprise in order to accomplish its illegal purposes the pattern of
corrupt activity, to wit:

Supplying shoppers with lists of desirable items for which the defendants organization
would pay a (well-below retail but substantial for items of questionable origin) premium,
thereby encouraging and guiding said shoppers to the preferred items that they should steal
from various national-chain retail establishments in and around Cuyahoga County and
numerous adjoining counties, providing a viable and profitable outlet for shoppers or
individuals with stolen items to transact, and, upon negotiating for possession of the those
items, placing the stolen items on internet sales websites such as E-Bay intending to sell the
items for less than retail, thereby undercutting and defrauding area retailers of both their
merchandise and available customers on a national level.

The Enterprises illegal activities are further illustrated and explained in the charged predicate
acts in this Indictment.

This Enterprise and the Persons Associated with the Enterprise were joined in purpose over a
period of time, although their various roles were different in order to accomplish the main
purposes of the Enterprise. These activities occurred with the knowledge and/or support of
and/or were aided and abetted by each of the persons associated with the Enterprise.

The Enterprise in this matter consisted of LARRY BENCE, DONNA BENCE, ABON
CARDS & COINS LIMITED, BENJAMIN BERRY and others yet to be named, each of
whom did conduct or participate in, directly or indirectly, the affairs of said enterprise, to-wit:
a group of persons associated in fact for the purposes of engaging in Telecommunications
Fraud and Theft (by deception) and/or Receiving Stolen Property, through a pattern of
corrupt activity as defined in Section 2923.31(I)(2)(a) or (I)(2)(c) of the Revised Code, which
in this case underlies conduct constituting organized retail theft as presented in Section





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2923.31(I)(5)(a)(i) of the Revised Code. These Predicate Acts constitute the pattern of
corrupt activity as defined in Section 2923.31(E) of said enterprise, which include criminal
violations of the Ohio Revised Code TITLE 29, and violations of TITLE 13 (Money
laundering offenses) as alleged in the following COUNTS FOUR through TWENTY-FIVE
of the indictment, which are incorporated herein as if fully restated, as well as other, related
fraudulent acts.

Furthermore, pursuant to Section 2923.32(B)(1), at least one of the incidents of corrupt
activity, as defined in Section 2923.31(I)(2)(a) or (I)(2)(c) is a felony of the third degree or
higher (any and all counts of Telecommunications Fraud, Money Laundering, as well as
others), contrary to and in violation of Section 2923.32(A)(1) of the Ohio Revised Code, and
thereby, this COUNT ONE, Engaging in a Pattern of Corrupt Activity, constitutes a Felony of
the First degree, contrary to and in violation of the Ohio Revised Code, Title 29, in
2923.32(A)(1) and against the peace and dignity of the State of Ohio.
Forfeiture of a Weapon - 2941.1417(A)
The Grand Jurors further find and specify that
the defendant(s) is/are the owner(s) and/or possessor(s) of a Winchester Super X 2 shotgun, serial #
11BMX03836; Jaran Tower musket, serial # 4576; Marlin 99 .22 rifle, no serial #; Marlin 99 .22
rifle with Tasco Scope and Red Dot, serial # 26307279; Sahara 755 .22, no serial #; Terni 308 rifle
with id#mn2331, serial # A4977; Smith & Wesson 67I handgun, serial # ADH7946; Springfield
1911 .45 handgun, serial #WW21685; Ruger Blackhawk handgun, serial # 47-84969; Harrington &
Richardson 20 gauge shotgun, serial # AN261250; Black Diamond .50 muzzle loader, serial #
43871; Connecticut Valley Arms muzzle loader, serial # 61-13-054-816-98; Thompson Omega 50
muzzle loader, serial # 41793; Stevens 67 12 gauge shotgun, serial # E736927; M1 Carbine 1917
rifle, serial # 71649; Swiss rifle, serial # 647134; Connecticut Valley Arms 50 muzzle loader, serial
# 61-13-061-843-07; Czech Tex pistol, serial # 82830; REG IND RG14 .22 handgun, serial #
L6844573; Harrington & Richardson .32 handgun serial # CTGE; Rohm .22 handgun, serial #
892099, which is contraband and/or property derived from or through the commission or facilitation
of an offense, and/or is an instrumentality the offender(s) used or intended to use in the commission
or facilitation of a felony offense.
the defendant(s) is/are the owner(s) and/or possessor(s) of a Tanfoglio ST27 .25, serial # 679721; Hi
Point Model JCP .40 cal. handgun, no serial #: Smith & Wesson 6906 9mm handgun, serial#
V800946; Rossi .44 cal. handgun, serial # ab137106; Smith & Wesson Model 732 .32 cal. handgun,
no serial #; Springfield Armory Model XP45 .45 cal. handgun, serial # XD626133; Colt .45 cal.





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revolver, serial # SA29102; Taurus Millennium model PT 140 semi-automatic pistol, serial #
STB78098; Colt Huntsman .22 cal. revolver, serial # 117499C; Sig Sauer P232 9 mm semi-
automatic pistol, serial # 290773; Sealed Eight, super shot .22 revolver, serial # L22689; H & R gun
fighter 660 revolver, serial # V25028; RG 15S .22 revolver, serial # 20608; Iver Johnson Arms
revolver, serial # 66149; Kimber Tactical Custom #2 .45 cal. semi-automatic pistol, serial
#K110911; Smith & Wesson 27-2 semi-automatic pistol, serial #N456114; H & R Inc. 949 .22 cal.
revolver, serial # m19832; Navy Arms Company .44 cal. revolver, serial # 218446; Japan 69 ACT
black powder ultra-hi revolver, which is contraband and/or property derived from or through the
commission or facilitation of an offense, and/or is an instrumentality the offender(s) used or intended
to use in the commission or facilitation of a felony offense.
Forfeiture of Property - 2941.1417(A)
the defendant(s) is/are the owner(s) and/or possessor(s) of seven (7) crates of ammunition, various
calibers and makes which is contraband and/or property derived from or through the commission or
facilitation of an offense, and/or is an instrumentality the offender(s) used or intended to use in the
commission or facilitation of a felony offense.
the defendant(s) is/are the owner(s) and/or possessor(s) of 2007 GMC Sierra 1500, VIN
1GTEK19JX72581675 which is contraband and/or property derived from or through the commission
or facilitation of an offense, and/or is an instrumentality the offender(s) used or intended to use in the
the defendant(s) is/are the owner(s) and/or possessor(s) of 2004 Chevy Silverado 2500 HD, VIN
1GCHK29414E232212 which is contraband and/or property derived from or through the
the defendant(s) is/are the owner(s) and/or possessor(s) of 1990 Wells Cargo enclosed trailer, VIN
C200G20L10400 which is contraband and/or property derived from or through the commission or






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the defendant(s) is/are the owner(s) and/or possessor(s) of one real property land parcel
#0270101209000 and appurtenant structures which is contraband and/or property derived from or
through the commission or facilitation of an offense, and/or is an instrumentality the offender(s) used
or intended to use in the commission or facilitation of a felony offense.
the defendant(s) is/are the owner(s) and/or possessor(s) of FirstMerit Bank Account Number
8170219495 which is contraband and/or property derived from or through the commission or
the defendant(s) is/are the owner(s) and/or possessor(s) of a Mechanics Bank account which is
contraband and/or property derived from or through the commission or facilitation of an offense,
and/or is an instrumentality the offender(s) used or intended to use in the commission or facilitation
of a felony offense.
the defendant(s) is/are the owner(s) and/or possessor(s) of JP Morgan Chase accounts which is
the defendant(s) is/are the owner(s) and/or possessor(s) of $34,488.00 in U.S. currency which is
The offense is contrary to the form of the statute in such case made and provided, and against the peace and dignity of the State of
Ohio.






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Count 2
Conspiracy - F2

2923.01(A)(1)
Defendants
Date of Offense
The grand jurors, on their oaths, further find that the Defendant(s) unlawfully

did, with purpose to commit or promote or facilitate the commission of Engaging in an Pattern of
Corrupt Activity, O.R.C. 2923.32(A)(1), plan or aid in planning the commission of the specified
offense with another person or persons, Larry Bence and/or Donna Bence and/or Benjamin Berry
others yet to be named to wit:

individuals with items to transact, and, upon negotiating for possession of the those items,
placing them on internet sales websites such as E-Bay intending to sell the items for less than
retail, thereby undercutting and defrauding area retailers of both their merchandise and
available customers on a national level.

FURTHERMORE, and the object of the conspiracy was a felony of the first degree.







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Ohio.






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Count 3
Conspiracy - F2

2923.01(A)(2)
Defendants
Date of Offense

did, with purpose to commit or promote or facilitate the commission of Engaging in an Pattern of
Corrupt Activity, O.R.C. 2923.32(A)(1), agree with another person or persons, Larry Bence and/or
Donna Bence and/or Benjamin Berry and/or Abon Cards & Coins Limited, and/or other yet to be
named that one or more of them would engage in conduct that would facilitate the commission of the
specified offense, to wit:

individuals with items to transact, and, upon negotiating for possession of the those items,
placing them on internet sales websites such as E-Bay intending to sell the items for less than
retail, thereby undercutting and defrauding area retailers of both their merchandise and
available customers on a national level.

FURTHERMORE, and the object of the conspiracy was a felony of the first degree.
Ohio.
the defendant(s) is/are the owner(s) and/or possessor(s) of a Winchester Super X 2 shotgun, serial #
11BMX03836; Jaran Tower musket, serial # 4576; Marlin 99 .22 rifle, no serial #; Marlin 99 .22
rifle with Tasco Scope and Red Dot, serial # 26307279; Sahara 755 .22, no serial #; Terni 308 rifle
with id#mn2331, serial # A4977; Smith & Wesson 67I handgun, serial # ADH7946; Springfield
1911 .45 handgun, serial #WW21685; Ruger Blackhawk handgun, serial # 47-84969; Harrington &
Richardson 20 gauge shotgun, serial # AN261250; Black Diamond .50 muzzle loader, serial #
43871; Connecticut Valley Arms muzzle loader, serial # 61-13-054-816-98; Thompson Omega 50
muzzle loader, serial # 41793; Stevens 67 12 gauge shotgun, serial # E736927; M1 Carbine 1917
rifle, serial # 71649; Swiss rifle, serial # 647134; Connecticut Valley Arms 50 muzzle loader, serial





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# 61-13-061-843-07; Czech Tex pistol, serial # 82830; REG IND RG14 .22 handgun, serial #
L6844573; Harrington & Richardson .32 handgun serial # CTGE; Rohm .22 handgun, serial #
892099, which is contraband and/or property derived from or through the commission or facilitation
of an offense, and/or is an instrumentality the offender(s) used or intended to use in the commission
or facilitation of a felony offense.






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Ohio.

Count 4
Telecommunications Fraud - UF

2913.05(A)
Defendants
Larry Bence, Abon Cards and Coins Limited
Date of Offense
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
FURTHERMORE, and the offender committed a violation of division (A) of Section 2913.05 if the
Revised Code and the violation occured as part of a course of conduct involving other violations of
division (A) of Section 2913.05 if the Revised Code or violations of, attempts to violate,
conspiracies to violate, or complicity in violations of section 2913.02, 2913.04, 2913.11, 2913.21,
2913.31, 2913.42, 2913.43, or 2921.13 of the Revised Code.
Ohio.






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Count 5
Telecommunications Fraud - F2

2913.05(A)
Defendants
Date of Offense
having devised a scheme to defraud, did knowingly disseminate, transmit, or caused to disseminated
or transmitted by means of wire, radio, satellite, telecommunication, telecommunications device, or
telecommunication services any writing, data, sign, signal, picture, sound, image with purpose to
execute or otherwise further the scheme to defraud.
FURTHERMORE, and the value of the benefit obtained by the offender or of the detriment to the
victim of the fraud is one hundred fifty thousand dollars or more but less than one million dollars.
Ohio.

Count 6
Aggravated Theft - F3

2913.02(A)(3)
Defendants
Larry Bence
Date of Offense
did with purpose to deprive the owner, Target and/or numerous other major retailers, of various
electronic items and/or the related monetary value or services, knowingly obtain or exert control
over either the property or services by deception and the property or services stolen is valued at
$150,000 or more and less than $750,000.
Ohio.






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Count 7
Receiving stolen property - F3

2913.51(A)
Defendants
Date of Offense
did receive, retain, or dispose of various electronic items and/or the related monetary value, the
property of Target and/or numerous other major retailers, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense and the value of
the property involved was $150,000 or more.
Ohio.

Count 8
Receiving stolen property - F3 (purchased 194 16 GB Apple 5S iPhones and 49
16 GB Apple iPad Minis for $25,000)

2913.51(A)
Defendants
Date of Offense
On or about July 23, 2014
did receive, retain, or dispose of one hundred ninety-four (194) 16 GB Apple 5S iPhones and forty-
nine (49) iPad Minis, all in factory-sealed boxes, the property of Target, knowing or having
reasonable cause to believe that the property had been obtained through commission of a theft
offense and the value of the property involved was $150,000 or more.
Ohio.






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Count 9
Money Laundering - F3

1315.55(A)(1)
Defendants
Date of Offense
did conduct or attempt to conduct a transaction knowing that the property involved in the transaction
was the proceeds of some form of unlawful activity with the purpose of committing or furthering the
commission of corrupt activity.
Ohio.

Count 10

1315.55(A)(1)
Defendants
Larry Bence, Donna F. Bence, Abon Cards and Coins Limited
Date of Offense
On or about April 17, 2013 to July 22, 2014
Ohio.

Count 11

1315.55(A)(1)
Defendants
Date of Offense
Ohio.





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Count 12
Receiving stolen property - F5 (electronics purchased for $335.00)

2913.51(A)
Defendants
Date of Offense
On or about May 15, 2014
did receive, retain, or dispose of four (4) "FITBIT" devices, one (1) 10x 4GB Sony flash drive, one
(1) Motorola XOOM Tablet, four (4) 250 GB Seagate hard drives, one (1) 64 GB Apple iPad, serial
# DLXFLAKSDJHH, and one (1) 8 GB Apple iPod, serial #8M9313DY75J, the property of Target,
knowing or having reasonable cause to believe that the property had been obtained through
commission of a theft offense and the value of the property involved was $1,000 or more and was
less than $7,500.
Ohio.

Count 13
Receiving stolen property - M1 (64 GB Apple iPad, serial # DLXFLAKSDJHH
sold for $265.00)

2913.51(A)
Defendants
Date of Offense
did receive, retain, or dispose of 64 GB Apple iPad, serial # DLXFLAKSDJHH sold for $265.00, the
property of Target, knowing or having reasonable cause to believe that the property had been
obtained through commission of a theft offense.
Ohio.






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Count 14
Receiving stolen property - M1 (iPod, serial #8M9313DY75J, sold for $75.57
and Seagate hard drive sold for $33.69)

2913.51(A)
Defendants
Date of Offense
did receive, retain, or dispose of iPod, serial #8M9313DY75J, sold for $75.57 and Seagate hard
drive sold for $33.69, the property of Target, knowing or having reasonable cause to believe that the
property had been obtained through commission of a theft offense.
Ohio.

Count 15
Receiving stolen property - M1 (two (2) 16 GB Apple iPad Minis, serial
numbers DMQM2G9NF196 and F7QM291WFP84, and Otterbox Defender
iPhone5 case sold for $220.00)

2913.51(A)
Defendants
Date of Offense
On or about June 3, 2014
did receive, retain, or dispose of two (2) 16GB iPad Minis, serial numbers DMQM2G9NF196 and
F7QM291WFP84, and one (1) Otterbox Defender iPhone 5 case, the property of Target, knowing or
having reasonable cause to believe that the property had been obtained through commission of a
theft offense.
Ohio.






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Count 16
Receiving stolen property - M1

2913.51(A)
Defendants
Larry Bence, Abon Cards and Coins Limited, Benjamin Berry
Date of Offense
did receive, retain, or dispose of two (2) cordless drills and extra lithium battery packs, the property
of Home Depot, knowing or having reasonable cause to believe that the property had been obtained
through commission of a theft offense.
Ohio.

Count 17

2913.51(A)
Defendants
Date of Offense
did receive, retain, or dispose of one (1) 64 GB Apple iPad, serial # DN6FN0L2DKPK, one (1)
Xbox 360 Game Console (Modern Warfare Edition), serial# 556910213806, the property of Target,
knowing or having reasonable cause to believe that the property had been obtained through
commission of a theft offense.
Ohio.






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Count 18

2913.51(A)
Defendants
Date of Offense
did receive, retain, or dispose of two (2) 16 GB iPad Minis, serial numbers DMQM2G9NF196 and
F7QM291WFP84 for $510.00, the property of Target, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense.
Ohio.

Count 19
Receiving stolen property - F5 (three (3) 32 GB Apple iPods, serial numbers
C3LFMVQWDCP9, CCQGG8J4DNQY, C3RGKBTVDNQY, and two (2)
Dyson Multi-floor cleaners, serial numbers GJ3-US-FAA6483S and GJ3-US-
FAA6479A, purchased for $600.00)

2913.51(A)
Defendants
Date of Offense
did receive, retain, or dispose of three (3) 32 GB Apple iPods, serial numbers C3LFMVQWDCP9,
CCQGG8J4DNQY, C3RGKBTVDNQY, and two (2) Dyson Multi-floor cleaners, serial numbers
GJ3-US-FAA6483S and GJ3-US-FAA6479A, the property of Target and Kroger, knowing or having
offense and the value of the property involved was $1,000 or more and was less than $7,500.
Ohio.






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Count 20

2913.51(A)
Defendants
Date of Offense
did receive, retain, or dispose of two (2) 32 GB Apple iPods, serial numbers CCQGG8J4DNQY and
C3LFMVQWDCP9 for $475.75, the property of Target, knowing or having reasonable cause to
believe that the property had been obtained through commission of a theft offense.
Ohio.

Count 21
Receiving stolen property - F5 (twenty (20) 16 GB Apple iPad minis,
purchased for $2,000.00)

2913.51(A)
Defendants
Date of Offense
did receive, retain, or dispose of twenty (20) 16 GB Apple iPad minis valued at $4,980.00, the
property of WalMart, knowing or having reasonable cause to believe that the property had been
obtained through commission of a theft offense and the value of the property involved was $1,000 or
more and was less than $7,500.
Ohio.






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Count 22

2913.51(A)
Defendants
Date of Offense
did receive, retain, or dispose of three (3) 16 GB iPad Minis, serial numbers F7VLTKKDFP84,
F7TLTHMHFP84, and 8M9313DY75J for $749.85, the property of WalMart, knowing or having
offense.
Ohio.

Count 23

2913.51(A)
Defendants
Date of Offense
did receive, retain, or dispose of Springfield 1911 .45 cal. handgun, serial #WW21685, the property
of John Doe, knowing or having reasonable cause to believe that the property had been obtained
through commission of a theft offense and the property involved was a firearm or dangerous
ordnance, as defined in section 2923.11 of the Revised Code.
the defendant(s) is/are the owner(s) and/or possessor(s) of Springfield 1911 .45 cal. handgun, serial
#WW21685, which is contraband and/or property derived from or through the commission or
Ohio.






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Count 24

2913.51(A)
Defendants
Date of Offense
did receive, retain, or dispose of Remington model 1100 12 gauge shotgun, serial # 60131V, the
property of John R. Lamkin, knowing or having reasonable cause to believe that the property had
been obtained through commission of a theft offense and the property involved was a firearm or
dangerous ordnance, as defined in section 2923.11 of the Revised Code.
the defendant(s) is/are the owner(s) and/or possessor(s) of Remington model 1100 12 gauge shotgun,
serial # 60131V, which is contraband and/or property derived from or through the commission or
Ohio.






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Count 25
Possessing Criminal Tools - F5

2923.24(A)
Defendants
Date of Offense
did possess or have under the person's control any substance, device, instrument, or article, to wit: a 2004
Chevy Silverado 2500 HD, VIN 1GCHK29414E232212 and/or a 2007 GMC Sierra 1500, VIN
1GTEK19JX72581675 and/or a 1990 Wells Cargo enclosed trailer, VIN C200G20L10400 and/or all
computers and computer hardware seized from Abon Cards & Coins Limited with purpose to use it
criminally.
FURTHERMORE, the a 2004 Chevy Silverado 2500 HD, VIN 1GCHK29414E232212 and/or a 2007 GMC
Sierra 1500, VIN 1GTEK19JX72581675 and/or a 1990 Wells Cargo enclosed trailer, VIN C200G20L10400
and/or all computers and computer hardware seized from Abon Cards & Coins Limited involved in the
offense were intended for use in the commission of a felony, to wit: O.R.C. 2913.51, Receiving Stolen
Property and/or O.R.C. 2923.32(A)(1) Engaging in a Pattern of Corrupt Activity.
The offense is contrary to the form of the statute in such case made and provided, and against the peace and
dignity of the State of Ohio.

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