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COURT OF COMMON PLEAS

CLERMONT COUNTY, OHIO

STATE OF OHIO, * CASE NO: 2019 -CR-OO IS?

PLAINTIFF, *
* INDICTMENT FOR:

VS.
*
.. CTS. #1-2: AGGRAVATED MURDER
1< CTS. #3-14: ATTEMPTED AGGRAVATED
WADE EDWARD WINN, 'I<
MURDER
DEFENDANT. 'I<

*
'I<

THE STATE OF OHIO, CLERMONT COUNTY, ss. COURT OF COMMON PLEAS

IN THE JANUARY TERM, 2019, THE JURORS OF THE GRAND JURY IN AND FOR
CLERMONT COUNTY, OHIO, ON THEIR OATHS, IN THE NAME AND BY THE
AUTHORITY OF THE STATE OF OHIO, DO FIND AND PRESENT THAT:

COUNT 1: WADE EDWARD WINN on or about the 2nd day of February, 2019, in Cletmont
County, Ohio, purposely caused the death of a law enforcement officer whom the offender knew
or had reasonable cause to know was a law enforcement officer when the victim, at the time of
the commission of the offense, was engaged in the victim's duties, to wit: Deputy William
Brewer .
contrary to and in violation of Section 2903.01(E)(1) of the Revised Code of Ohio and
against the peace and dignity of the State of Ohio.

SPECIFICATION NUMBER 1 TO THE FIRST COUNT: The Grand Jurors further find and
specity that the victim of the offense was a law enforcement officer, as defined in section 2911.01 of the
Revised Code, whom the offender had reasonable cause to know or knew to be a law enforcement officer
as so defined, and either the victim, at the time of the commission of the offense, was engaged in the
victim's duties, or it was the offender's specific purpose to kill a law enforcement officer as so defined.

SPECIFICATION NUMBER 2 TO THE FIRST COUNT: The Grand Jurors further find and
specity that the offense at bar was part of a course of conduct involving the purposeful killing of or
attempt to kill two or more persons by the offender.

SPECIFICATON NUMBER 3 TO THE FIRST COUNT: The Grand Jurors further find and
specity that Wade Edward WiOD discharged a fireatm at a peace officer while committing the offense.
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PAGE 2/5 STATE V. WADE 19-CR-OO 157

COUNT 2: WADE EDWARD WINN on or about the 2nd day of February, 2019, in Clennont
County, Ohio, purposely caused the death of a law enforcement officer whom the offender knew
or had reasonable cause to know was a law enforcement officer when it was the offender's
specific purpose to kill a law enforcement officer, to wit: Deputy William Brewer
contrary to and in violation of Section 2903.0 1(E)(2) of the Revised Code of Ohio and
against the peace and dignity of the State of Ohio.

SPECIFICATION NUMBER 1 TO THE SECOND COUNT: The Grand Jurors further find
and specify that the victim of the offense was a law enforcement officer, as defined in section 2911.0 I of
the Revised Code, whom the offender had reasonable cause to know or knew to be a law enforcement
officer as so defined, and either the victim, at the time of the commission of the offense, was engaged in
the victim's duties, or it was the offender's specific purpose to kill a law enforcement officer as so
defined.

SPECIFICATION NUMBER 2 TO THE SECOND COUNT: The Grand Jurors further find
and specifY that the offense at bar was part of a course of conduct involving the purposeful killing of or
attempt to kill two or more persons by the offender.

SPECIFICATON NUMBER 3 TO THE FIRST COUNT: The Grand Jurors further find and
specifY that Wade Edward WiDD discharged a firearm at a peace officer while committing the offense.

COUNT 3: WADE EDWARD WINN on or about the 2nd day of February, 2019, in Clennont
County, Ohio, purposely or knowingly, and when purpose or knowledge is sufficient culpability for the
commission of an offense, engaged in conduct that, if successful, would constitute or result in the offense
of aggravated murder, to wit: did purposely attempt to cause the death of a law enforcement officer
whom the offender knew or had reasonable cause to know was a law enforcement officer when the
victim, at the time of the commission of the offense, was engaged in the victim's duties, to wit:
Lieutenant Dominic DeRose
contrary to and in violation of Section 2923.02(A) and 2903.0I(E)(I) of the Revised Code of
Ohio, a felony of the first degree and against the peace and dignity of the State of Ohio.

SPECIFICATON TO THE THIRD COUNT: The Grand Jurors further find and specifY that
Wade Edward Winn discharged a fireann at a peace officer while committing the offense.
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PAGE 315 STATE V. WADE, 19-CR-OO 16"'?j
COUNT 4: WADE EDWARD WINN on or about the 2 nd·3 rd day of February, 2019, in Clermont County,
Ohio, purposely or knowingly, and when purpose or knowledge is sufficient CUlpability for the commission of an
offense, engaged in conduct that, jf successful, would constitute or result in the offense of aggravated murder, to wit:
did purposely attempt to cause the death ofa law enforcement officer whom the offender knew or had reasonable
cause to know was a law enforcement officer when the victim, at the time of the commission of the offense, was
engaged in the victim's duties, to wit: Deputy Daniel Spears
contrary to and in violation of Section 2923.02(A) and 2903.01 (E)(1) of the Revised Code ofOhio, a
felony ofthe first degree and against the peace and dignity of the State of Ohio.

SPECIFICA TON TO THE FOURTH COUNT: The Grand Jurors further find and specifY that Wade
Edward Winn discharged a firearm at a peace officer while committing the offense.

COUNT 5: WADE EDWARD WINN on or about the 2 nd·3 rd day of February, 2019, in Clermont County,
Ohio, purposely or knowingly, and when purpose or knowledge is sufficient culpability for the commission ofan
offense, engaged in conduct that, if successful, would constitute or result in the offense of aggravated murder, to
wit: did purposely attempt to cause the death of a law enforcement officer whom the offender knew or had
reasonable cause to know was a law enforcement officer when the victim, at the time of the commission of the
offense, was engaged in the victim's duties, to wit: Deputy Michael Ross
contrary to and in violation of Section 2923.02(A) and 2903.01(E)(1) of the Revised Code of Ohio, a
felony of the first degree and against the peace and dignity of the State of Ohio.

SPECIFICATON TO THE FIFTH COUNT: The Grand Jurors further find and specifY that Wade
Edward Winn discharged a firearm at a peace officer while committing the offense.

COUNT 6: WADE EDWARD WINN on or about the 2 nd .3 rd day of February, 2019, in Clermont County,
Ohio, purposely or knowingly, and when purpose or knowledge is sufficient culpability for the commission of an
offense, engaged in conduct that, if successful, would constitute or result in the offense of aggravated murder, to wit:
did purposely attempt to cause the death of a law enforcement officer whom the offender knew or had reasonable
cause to know was a law enforcement officer when the victim, at the time of the commission of the offense, was
engaged in the victim's duties, to wit: Detective Nicholas Crouch
contrary to and in violation of Section 2923.02(A) and 2903.01(E)(I) of the Revised Code of Ohio. a
felony ofthe first degree and against the peace and dignity of the State ofOhio.

SPECIFICATON TO THE SIXTH COUNT: The Grand Jurors further find and specify that Wade
Edward WiDD discharged a firearm at a peace officer while committing the offense.

COUNT 7: WADE EDWARD WINN on or about the 2nd·3rd day of February, 2019, in Clermont County,
Ohio. purposely or knowingly, and when purpose or knowledge is sufficient culpability for the commission ofan
offense, engaged in conduct that, ifsuccessful, would constitute or result in the offense of aggravated murder, to wit:
did purposely attempt to cause the death of a law enforcement officer whom the offender knew or had reasonable
cause to know was a law enforcement officer when the victim, at the time of the commission of the offense, was
engaged in the victim's duties. to wit: Deputy Douglas Scott
contrary to and in violation of Section 2923.02(A) and 2903.01 (EXI) ofthe Revised Code of Ohio, a
felony of the first degree and against the peace and dignity of the State of Ohio.

SPECIFICATON TO THE SEVENTH COUNT: The Grand Jurors further find and specify that Wade
Edward WiDn discharged a firearm at a peace officer while committing the offense.
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PAGE 4/5 STATE V. WADE

COUNT 8: WADE EDWARD WINN on or about the 2nd~3'd day of February, 2019, in Clermont County,
Ohio, purposely or knowingly, and when purpose or knowledge is sufficient culpability for the commission of an
offense, engaged in conduct that, if successful, would constitute or result in the offense of aggravated murder, to wit:
did purposely attempt to cause the death of a law enforcement officer whom the offender knew or had reasonable
cause to know was a law enforcement officer when the victim, at the time of the commission of the offense, was
engaged in the victim's duties, to wit: Sergeant Michael White
contrary to and in violation of Section 2923.02(A) and 2903.0 I(E)(l ) of the Revised Code of Ohio, a
felony ofthe first degree and against the peace and dignity of the State of Ohio.

SPECIFICATON TO THE EIGHT COUNT: The Grand Jurors further find and specify that Wade
Edward Winn discharged a firearm at a peace officer while committing the offense.

COUNT 9: WADE EDWARD WINN on or about the 2nd day of February, 2019, in Clermont County,
Ohio, purposely or knowingly, and when purpose or knowledge is sufficient culpability for the commission of an
offense, engaged in conduct that, if successful, would constitute or result in the offense of aggravated murder, to
wit: did purposely attempt to cause the death of a law enforcement officer whom the offender knew or had
reasonable cause to know was a law enforcement officer when it was the offender's specific purpose to kill a law
enforcement officer; to wit: Lieutenant Dominic DeRose
contrary to and in violation of Section 2923.02(A) and 2903.0 I(E)(2) of the Revised Code of Ohio, a
felony ofthe first degree and against the peace and dignity of the State of Ohio.

SPECIFICATON TO THE NINTH COUNT: The Grand Jurors further find and specify that Wade
Edward Winn discharged a firearm at a peace officer while committing the offense.

COUNT 10: WADE EDWARD WINN on or about the 2nd_3rd day of February, 2019, in Clermont
County, Ohio, purposely or knowingly, and when purpose or knowledge is sufficient culpability for the commission
of an offense, engaged in conduct that, if successful, would constitute or result in the offense of aggravated murder,
to wit: did purposely attempt to cause the death of a law enforcement officer whom the offender knew or had
reasonable cause to know was a law enforcement officer when it was the offender's specific purpose to kill a law
enforcement officer; to wit: Deputy Daniel Spears
contrary to and in violation of Section 2923.02(A) and 2903.0 I(E)(2) of the Revised Code of Ohio, a
felony of the first degree and against the peace and dignity of the State of Ohio.

SPECIFICATON TO THE TENTH COUNT: The Grand Jurors further find and specify that Wade
Edward Winn discharged a firearm at a peace officer while committing the offense.

COUNT 11: WADE EDWARD WINN on or about the 2nd _3'd day of February, 2019, in Clermont
County, Ohio, purposely or knowingly, and when purpose or knowledge is sufficient culpability for the commission
of an offense, engaged in conduct that, if successful, would constitute or result in the offense of aggravated murder,
to wit: did purposely attempt to cause the death ofa law enforcement officer whom the offender knew or had
reasonable cause to know was a law enforcement officer when it was the offender's specific purpose to kill a law
enforcement officer; to wit: Deputy Michael Ross
contrary to and in violation of Section 2923.02(A) and 2903.0 I(E)(2) of the Revised Code of Ohio , a
felony of the first degree and against the peace and dignity of the State of Ohio.

SPECIFICATON TO THE ELEVENTH COUNT: The Grand Jurors further find and specify that
Wade Edward Wino discharged a firearm at a peace officer while committing the offense.
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PAGE SIS STATE V. WADE ~Ea~ /~9
COUNT ]2: WADE EDWARD WINN on or about the 2nd·3,d day of February, 2019, in Clermont
County, Ohio, purposely or knowingly, and when purpose or knowledge is sufficient culpability for the commission
of an offense, engaged in conduct that, if successful, would constitute or result in the offense of aggravated murder,
to wit: did purposely attempt to cause the death of a law enforcement officer whom the offender knew or had
reasonable cause to know was a law enforcement officer when it was the offender'S specific purpose to kill a law
enforcement officer; to wit: Detective Nicholas Crouch
contrary to and in violation of Section 2923,02(A) and 2903.01(E)(2) of the Revised Code of Ohio, a
felony of the first degree and against the peace and dignity of the State ofOhio. "

SPECIFICATON TO THE TWELTH COUNT: The Grand Jurors further find and specify that Wade
Edward Winn discharged a fireann at a peace officer while committing the offense,

COUNT 13: WADE EDWARD WINN on or about the 2nd_3,d day of February, 2019, in Clermont
County, Ohio, purposely or knowingly, and when purpose or knowledge is sufficient culpability for the commission
ofan offense, engaged in conduct that, if successful, would constitute or result in the offense of aggravated murder,
to wit: did purposely attempt to cause the death of a law enforcement officer whom the offender knew or had
reasonable cause to know was a law enforcement officer when it was the offender's specific purpose to kill a law
enforcement officer; Deputy Douglas Scott
contrary to and in violation of Section 2923.02(A) and 2903.01 (E)(2) of the Revised Code of Ohio, a
felony of the first degree and against the peace and dignity of the State of Ohio.

SPECIFICATON TO THE THIRTEENTH COUNT: The Grand Jurors further find and specify that
Wade Edward Winn discharged a fireann at a peace officer while committing the offense.

COUNT 14: WADE EDWARD WINN on or about the 2nd·3,d day of February, 2019, in Clennont
County, Ohio, purposely or knowingly, and when purpose or knowledge is sufficient culpability for the commission
of an offense, engaged in conduct that, if successful, would constitute or result in the offense of aggravated murder,
to wit: did purposely attempt to cause the death ofa law enforcement officer whom the offender knew or had
reasonable cause to know was a law enforcement officer when it was the offender's specific purpose to kill a law
enforcement officer; to wit: Sergeant Michael White
contrary to and in violation of Section 2923.02(A) and 2903.01 (E)(2) of the Revised Code of Ohio, a
felony ofthe first degree and against the peace and dignity of the State ofOhio.

SPECIFICATON TO THE FOURTEENTH COUNT: The Grand Jurors further find and specify that
Wade Edward WiDD discharged a firearm at a peace officer while committing the offense.

DiJF~
By: Assistant Prosecuting Attorney