IN THE CIRCUIT COURT FOR THE TENTH JUDICIAL CIRCUIT
OF FLORIDA, POLK COUNTY, FALL TERM
TWO THOUSAND AND TWENTY
STATE OF FLORIDA, Case No.: 53-2019-CF-008981-A000-XX
Plaintiff,
vs. SUPERCEDING INDICTMENT FOR:
STANLEY ERIC MOSSBURG,
Defendant.
4)
5)
6)
2)
8)
9)
10)
FIRST DEGREE MURDER
F.S. 782.04. (CF)
FIRST DEGREE MURDER
F.S. 782.04. (CF)
BURGLARY OF A DWELLING WITH.
AN ASSAULT OR BATTERY WHILE
ARMED WITH A FIREARM
F.S. 810.02(2), 777.011 & 775.087 (LF)
ROBBERY WITH A FIREARM
F.S. 812.13 & 775.087. (PBL)
ROBBERY WITH A FIREARM
F.S, 812.13 & 775.087. (PBL)
ARMED KIDNAPPING
FS. 775.087 & 787.01 (LF)
ARMED KIDNAPPING
FS. 775.087 & 787.01 (LF)
ATTEMPTED 1ST DEGREE MURDER
OF LAW ENFORCEMENT OFFICER
(FIREARM)
F.S. 775.0823, 775.087, 777.04, 782.04,
& 782.065 (MANDATORY LIFE)
ATTEMPTED 1ST DEGREE MURDER
OF LAW ENFORCEMENT OFFICER
(FIREARM)
F.S. 775.0823, 775.087, 777.04, 782.04,
& 782.065 (MANDATORY LIFE)
ATTEMPTED 1ST DEGREE MURDER
OF LAW ENFORCEMENT OFFICER
(FIREARM)
ES, 775.0823, 775.087, 777.04, 782.04,
& 782.065 (MANDATORY LIFE)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.18)
19)
20)
21)
22)
23)
24)
26)
RESISTING OFFICER WITH
VIOLENCE
F.S. 843.01 (F3)
RESISTING OFFICER WITHOUT
VIOLENCE
F.S. 843.02 (M1)
GRAND THEFT(MOTOR VEHICLE)
5. 812.014 (F3)
BURGLARY OF A CONVEYANCE
F.S. 810.02
TAMPERING WITH PHYSICAL
EVIDENCE
F.S. 918.13 (F3)
BATTERY ON A POLICE DOG
F.S. 843.19 (M1)
UNLAWFUL POSSESSION OF A.
STOLEN CREDIT CARD
F. S. 817.60 (F3)
UNLAWFUL POSSESSION OF A
STOLEN CREDIT CARD
F. 8. 817.60 (F3)
UNLAWFUL POSSESSION OF A
STOLEN CREDIT CARD
F. S, 817.60 (F3)
FELONY PETIT THEFT
F. S$. 812.014 (F3)
FELONY PETIT THEFT
F.S. 812.014 (F3)
FELONY PETIT THEFT
F.S. 812.014 (F3)
CRIMINAL L
IDENTIFICATION OF A DECEASE]
PERSON
FS. 817.568. (F3)
CRIMINAL USE OF PERSONAL
IDENTIFICATION OF A DECEASED
PERSON
F.S. 817.568. (F3)
“RIMINAL USE OF PERSONAL
IDENTIFICATION INFORMATION
FS. 817.568. (F3)
FRAUDULENT USE OF CREDIT
CARD (3+ TIMES)
F.S. 817.61. (F3)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.27) POSSESSION OF A FIREARM BY A
CONVICTED FELON YEAR
MANDATORY MINIMUM)
F.S. 775.087 & 790.23 (F2)
IN THE NAME AND BY AUTHORITY OF THE STATE OF FLORIDA
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 13, 2019 and October 14, 2019, in the County of Polk and State of Florida, did
unlawfully from a premeditated design to effect the death of a human being, kill KENNETH REX
BEVER, a human being, by stabbing KENNETH REX BEVER with a knife, contrary to Florida
Statute 782.04,
(CAPITAL FELONY)
COUNT TWO
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 13, 2019 and October 14, 2019, in the County of Polk and State of Florida, did
unlawfully from a premeditated design to effect the death of a human being, kill MARGUERITE
ETHEL MOREY, a human being, by stabbing MARGUERITE ETHEL MOREY with a knife,
contrary to Florida Statute 782.04.
(CAPITAL FELONY)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.COUNT THRE
The Grand Jurors of the State of Florida, empancled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 13, 2019 and October 14, 2019, in the County of Polk and State of Florida, did
knowingly enter or remain in a dwelling, the property of [EEE KENNETH REX
BEVER, AND/OR MARGUERITE ETHEL MOREY, with the intent to commit an_offense
therein, and in the course of committing the burglary made an assault or battery upon|
NNETH REX BEVER, AND/OR MARGUERITE ETHEL MOREY, and in the
course thereof, STANLEY ERIC MOSSBURG carried, displayed, used, threatened to use or
attempted to use a knife and/or firearm, said knife and/or firearm being in his actual possession,
contrary to Florida Statutes 775.087 and 810.02. (LIFE FEL) (LEVEL 9) (10 YEAR
MANDATORY MINIMUM)
COUNT FOUR
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 13, 2019 and October 14, 2019, in the County of Polk and State of Florida, by
force, violence, assault, or putting in fear, did knowingly take away property of some value, to-
wit, personal property, from the person or custody of MARGUERITE ETHEL MOREY, with the
intent to permanently or temporarily deprive MARGUERITE ETHEL MOREY of the property,
and in the course of committing the robbery STANLEY ERIC MOSSBURG actually possessed
and carried a knife and/or a firearm, a deadly weapon, contrary to Florida Statutes 812.13 and
775.087. (1 DEG FEL, PBL) (LEVEL 9) (10 YEAR MANDATORY MINIMUM)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.COUNT FIVE
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 13, 2019 and October 14, 2019, in the County of Polk and State of Florida, by
force, violence, assault, or putting in fear, did knowingly take away property of some value, to-
wit, personal property, from the "aii the intent to
permanently or temporarily depriv the property, and in the course of
committing the robbery STANLEY ERIC MOSSBURG actually possessed and carried a knife
and/or a firearm, a deadly weapon, contrary to Florida Statutes 812.13 and 775.087. (1 DEG FEL,
PBL) (LEVEL 9) (10 YEAR MANDATORY MINIMUM)
COUNT SIX
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 13, 2019 and October 14, 2019, in the County of Polk and State of Florida,
without lawful authority did forcibly, secretly or by threat, confine, abduct or imprison.
MARGUERITE ETHEL MOREY, against her will, with the intent to inflict bodily harm upon or
terrorize MARGUERITE ETHEL MOREY or another person, or forcibly, secretly or by threat,
confine, abduct or imprison MARGUERITE ETHEL MOREY, against her will, with the intent
to commit or facilitate the commission of a felony, to-wit, Robbery or Burglary; and in the
course thereof, STANLEY ERIC MOSSBURG carried, displayed, used, threatened to use or
ewe to use a knife and/or a firearm, and said knife and/or firearm was in the actual
ssion of STANLEY ERIC MOSSBURG, contrary to Florida Statutes 775.087 and 787.01.
(LIFE FELONY) (LEVEL 10) (10 YEAR MANDATORY MINIMUM)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.COUNT SEVEN
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 13, 2019 and October 14, 2019, in the County of Polk and State of Florida,
without lawful authority did forcibly, secretly or by threat, confine, abduct or imprison
against his will, with the intent to inflict bodily harm upon or terrorize
son, or did forcibly, secretly or by threat, confine, abduct or imprison
igainst his will with the intent to commit or facilitate the commission of a
felony, to-wit, Robbery or Burglary; and in the course thereof, STANLEY ERIC MOSSBURG
carried, displayed, used, threatened to use or attempted to use a knife and/or a firearm, and said
knife and/or firearm was in the actual possession of STANLEY ERIC MOSSBURG, contrary to
Florida Statutes 775.087 and 787.01, (LIFE FELONY) (LEVEL 10) (10 YEAR MANDATORY,
MINIMUM)
COUNT EIGHT
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentinent make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 14, 2019 and October 15, 2019, in the County of Polk and State of Florida, did
unlawfully attempt to commit murder in the first degree upon SAM D BUNCH I, from a
premeditated design to effect death, knowing that SAM D BUNCH II] was a law enforcement
officer, while SAM D BUNCH III was engaged in the lawful performance of a duty by discharging
a firearm at SAM D BUNCH III, and in the course of committing said attempted murder did have
in his actual possession a firearm, contrary to Florida Statutes 775.0823, 775.087, 777.04, 782.04
and 782.065. (LIFE FEL) (LEVEL 9) (10 YEAR MANDATORY MINIMUM)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.COUNT NINE
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 14, 2019 and October 15, 2019, in the County of Polk and State of Florida, did
unlawfully attempt to commit murder in the first degree upon JASON D VARNADORE, from a
premeditated design to effect death, knowing that JASON D VARNADORE was a law
enforcement officer, while JASON D VARNADORE was engaged in the lawful performance of
a duty by discharging a firearm at JASON D VARNADORE, and in the course of committing said
attempted murder did have in his actual possession a firearm, contrary to Florida Statutes
775.0823, 775.087, 777.04, 782.04 and 782.065. (LIFE FEL) (LEVEL 9) (10 YEAR
MANDATORY MINIMUM)
COUNT TEN
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that *
STANLEY ERIC MOSSBURG
between October 14, 2019 and October 15, 2019, in the County of Polk and State of Florida, did
unlawfully attempt to commit murder in the first degree upon KENNETH VON LEUE, from a
premeditated design to effect death, knowing that KENNETH VON LEUE was a law enforcement
officer, while KENNETH VON LEUE was engaged in the lawful performance of a duty by
discharging a firearm at KENNETH VON LEUE, and in the course of committing said attempted
murder did have in his actual possession a firearm, contrary to Florida Statutes 775.0823, 775.087,
777.04, 782.04 and 782.065. (LIFE FEL) (LEVEL 9) (10 YEAR MANDATORY MINIMUM)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 14, 2019 and October 15, 2019, in the County of Polk and State of Florida, did
knowingly and willfully resist, obstruct or oppose SAM D BUNCH II], KENNETH VON LEUE,
or JASON D VARNADORE, an officer of the Polk County Sheriff's Office, in the execution of a
legal process or in the lawful execution of a legal duty, by offering or doing violence to the person
of said officer, contrary to Florida Statute 843.01. (3 DEG FEL) (LEVEL 5)
COUNT TWELVE
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 14, 2019 and October 15, 2019, in the County of Polk and State of Florida, did
knowingly and willfully, resist, obstruct or oppose CHRISTOPHER BRETT BULMAN, an officer
of the Polk County Sheriff's Office, in the execution of a legal process or in the lawful execution
ofa legal duty, without offering or doing violence to the person of such officer, contrary to Florida
Statute 843.02. (1 DEG MISD)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.COUNT THIRTEEN
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 13, 2019 and October 14, 2019, in the County of Polk and State of Florida, did
knowingly obtain or use, or endeavor to obtain or use a motor vehicle, to-wit, a Hyundai Tucson,
which was the property of MARGUERITE ETHEL MOREY, with the intent to permanently or
temporarily deprive MARGUERITE ETHEL MOREY of the property or benefit therefrom or to
appropriate the property to the use of STANLEY ERIC MOSSBURG or to the use of any person
not entitled thereto, contrary to Florida Statute 812.014. (3 DEG FEL) (LEVEL 4)
COUNT FOURTEEN
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 13, 2019 and October 14, 2019, in the County of Polk and State of Florida, did
knowingly enter or remain in a conveyance, the property of MARGUERITE ETHEL MOREY,
with intent to commit an offense therein, contrary to Florida Statute 810.02. (3 DEG F EVEL
4)
COUNT FIFTEEN
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 13, 2019 and October 14, 2019, in the County of Polk and State of Florida, did
alter, destroy, conceal or remove a record, document, or thing, to-wit: blood at the crime scene,
with the purpose to impair its verity or availability in a proceeding or investigation knowing that,
a criminal trial, proceeding or investigation by a duly constituted law enforcement agency of this,
State was pending or was about to be instituted, contrary to Florida Statute 918.13. (3 DEG FEL)
(LEVEL 3)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.COUNT SIXTEEN
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 14, 2019 and October 15, 2019, in the County of Polk and State of Florida,
actually and intentionally, did maliciously, touch, strike, or cause bodily harm to a police dog, fire
dog, SAR dog, or police horse, contrary to Florida Statute $43.19, (1 DEG MISD)
OUNT SEVENTEEN
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
on or about October 14, 2019, in the County of Polk and State of Florida, knowingly did possess,
receive, or retain custody of a credit or debit card that had been taken from the possession, custody,
or control of the cardholder, KENNETH REX BEVER, without his consent and with the intent to
impede the recovery of the credit or debit card by the KENNETH REX BEVER, contrary to
Florida Statute 817.60. (3 DEG FEL) (LEVEL 1)
COUNT EIGHTEEN
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
on or about October 14, 2019, in the County of Polk and State of Florida, knowingly did possess,
receive, or retain custody of a credit or debit card that had been taken from the possession, custody,
or control of the cardholder, ithout his consent and with the intent to impede
the recovery of the credit or debit card by the contrary to Florida Statute
817.60. (3 DEG FEL) (LEVEL 1)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.COUNT NINETEEN
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
on or about October 14, 2019, in the County of Polk and State of Florida, knowingly did possess,
receive, or retain custody of a credit or debit card that had been taken from the possession, custody,
or control of the cardholder, MARGUERITE ETHEL MOREY, without her consent and with the
intent to impede the recovery of the credit or debit card by the MARGUERITE ETHEL MOREY,
contrary to Florida Statute $17.60. (3 DEG FEL) (LEVEL 1)
COUNT TWENTY
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
on or about October 14, 2019, in the County of Polk and State of Florida, did knowingly obtain or
use, or endeavor to obtain or use money which was the property of KENNETH REX BEVER,
with the intent to permanently or temporarily deprive KENNETH REX BEVER of the property or
benefit therefrom or to appropriate the property to the use of STANLEY ERIC MOSSBURG or
to the use of any person not entitled thereto, the value of the stolen property being $100 or more,
the said STANLEY ERIC MOSSBURG having previously been convicted of theft two or more
times on January 8, 2014, in Spartanburg County, South Carolina and on October 17, 2006, in
SPARTANBURG County, South Carolina, contrary to Florida Statute 812.014. (3 DEG FEL)
(LEVEL 1)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.COUNT TWENTY ONE
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
on or about October 14, 2019, in the County of Polk and State of id knowingly obtain or
use, or endeavor to obtain or use money which was the property of h the
intent to permanently or temporarily deprive of the property or benefit
therefrom or to appropriate the property to the use of STANLEY ERIC MOSSBURG or to the
use of any person not entitled thereto, the value of the stolen property being $100 ot more, the said
STANLEY ERIC MOSSBURG having previously been convicted of theft two or more times on
January 8, 2014, in Spartanburg County, South Carolina and on October 17, 2006, in
SPARTANBURG County, South Carolina, contrary to Florida Statute 812.014. (3 DEG FEL)
(LEVEL 1)
UNT TWE
NTY TWO
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
on or about October 14, 2019, in the County of Polk and State of Florida, did knowingly obtain or
use, or endeavor to obtain or use money which was the property of MARGUERITE ETHEL
MOREY, with the intent to permanently or temporarily deprive MARGUERITE ETHEL MOREY
of the property or benefit therefrom or to appropriate the property to the use of STANLEY ERIC
MOSSBURG or to the use of any person not entitled thereto the value of the stolen property being,
$100 or more, the said STANLEY ERIC MOSSBURG having previously been convicted of theft
two or more times on January 8, 2014, in Spartanburg County, South Carolina and on October 17,
2006, in Spartanburg County, South Carolina, contrary to Florida Statute 812.014. (3 DEG FEL)
(LEVEL 1)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.COUNT TW
Y THREE
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
on or about October 14, 2019, in the County of Polk and State of Florida, did willfully and
fraudulently use, or possess with intent to fraudulently use, personal identification information
concerning KENNETH REX BI , a deceased individual, contrary to Florida Statute 817,568.
(3 DEG FEL) (LEVEL 1)
COUNT TWENTY FOUR
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
‘on or about October 14, 2019, in the County of Polk and State of Florida, did willfully and
fraudulently use, or possess with intent to fraudulently use, personal identification information
concerning MARGUERITE ETHEL MOREY, a deceased individual, contrary to Florida Statute
817.568. (3 DEG FEL) (LEVEL 1)
cour
TWENTY FIVE
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
‘on or about October 14, 2019, in the County of Polk and State of Florida, willfully and without
authorization, did fraudulently use, or possess with intent to fraudulently use, personal
identi formation concerning I ithout first obtaining the consent of
contrary to Florida Statute 817.568. (3 DEG FEL) (LEVEL 4)
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.COUNT TWENTY SIX
The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
on or about October 14, 2019, in the County of Polk and Siate of Florida, did, with intent to
defraud, obtain money, goods, property or services, more than twice within a six month time
period, by representing that he was the holder of credit card devices which had been issued to
KENNETH REX BEVER, MARGUERITE ETHEL MOREY, and/or
without the authority of KENNETH REX BEVER, MARGUERITE ETHEL MOREY, and/or
contrary to Florida Statute 817.61. (3 DEG FEL) (LEVEL 2)
COUNT TWENTY SEVEN
‘The Grand Jurors of the State of Florida, empaneled and sworn to inquire and true
presentment make in and for the County of Polk and State of Florida, upon their oath do
present that
STANLEY ERIC MOSSBURG
between October 13, 2019 and October 15, 2019, in the County of Polk and State of Florida, did,
afier having been convicted of a felony, knowingly own or be in the care, custody, possession, or
control of a firearm, and said firearm was in the actual possession of STANLEY ERIC
MOSSBURG, contrary to Florida Statutes 775.087 and 790.23. (2 DEG FEL) (LEVEL 5) (3
YEAR MANDATORY MINIMUM)
Y
ATRUE BILL _ GH __ Foreperson of the Grand Jury.
Presented in open Court this 20th day of February, 2020.
Filed Polk County Clerk of Court 02/20/2020 11:18 AM.STATE OF FLORIDA
COUNTY OF POLK.
The undersigned states that she, as Assistant State Attorney of the Tenth Judicial
Circuit in and for Polk County, Florida, as authorized and required by law, has advised
the Grand Jury returning this Indictment.
BRIAN HAAS.
STATE ATTORNEY
TENTH JUDICIAL CIRCUIT
STANLEY ERIC MOSSBURG e Attorney
WIM, DOB: 11/08/1983 Fla, Bar No. 0046375
Filed Polk County Clerk of Court 02/20/2020 11:35 AM.