FULL TEXT: Indictment of Rodney Turner

IN THE DISTRICT COURT OF WYANDOTTE COUNTY, KANSAS

CRIMINAL DEPARTMENT

THE STATE OF KANSAS, Plaintiff, Case Number 2008CR

vs.

RODNEY L. TURNER, Defendant.

INDICTMENT

The Grand Jury charges:

COUNT ONE:

    That in the County of Wyandotte, State of Kansas during the period from September 1, 2003, through June 30, 2004, Defendant Rodney Turner, did unlawfully, and willfully obtain or exert unauthorized control over property, to-wit: money, of a value of at least $25,000, with the intent to permanently deprive the owner, to-wit: the Board of Public Utilities, of the possession, use or benefit of said property, in violation of K.S.A. 21-3701. (Theft, Severity Level 7, Nonperson Felony).


COUNT TWO
That in the County of Wyandotte, State of Kansas during the period from July 1, 2004, through April 30, 2008, defendant  Rodney Turner, did unlawfully, and willfully obtain or exert unauthorized control over property, to-wit: money, of a value of $100,000 or more, with the intent to permanently deprive the owner, to-wit: the Board of Public Utilities, of the possession, use or benefit of said property, in violation of K.S.A. 21-3701. (Theft, Severity Level 5 Nonperson Felony).



COUNT THREE
    That in the County of Wyandotte, State of Kansas on or about the 29th day of August, 2003, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit:: $7,275, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FOUR

That in the County of Wyandotte, State of Kansas on or about the 30th day of September, 2003, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,425, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FIVE

That in the County of Wyandotte, State of Kansas on or about the 1st day of November, 2003, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,275, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT SIX

That in the County of Wyandotte, State of Kansas on or about the 1st day of December, 2003, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,050, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)


COUNT SEVEN

That in the County of Wyandotte, State of Kansas between December 30, 2003, through January 1, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $6,825, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT EIGHT

That in the County of Wyandotte, State of Kansas on or about the 3rd day of February, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,275, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT NINE

That in the County of Wyandotte, State of Kansas on or about the 1st day of March, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,350, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT TEN

That in the County of Wyandotte, State of Kansas on or about the 1st day of April, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,125, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)


COUNT ELEVEN

That in the County of Wyandotte, State of Kansas on or about the 3rd day of May, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,425, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT TWELVE

That in the County of Wyandotte, State of Kansas on or about the 1st day of June, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,500, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT THIRTEEN

That in the County of Wyandotte, State of Kansas on or about the 2nd day of July, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $8,175, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FOURTEEN

That in the County of Wyandotte, State of Kansas on or about the 2nd day of August, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,800, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)


COUNT FIFTEEN

That in the County of Wyandotte, State of Kansas on or about the 31st day of August, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $8,175, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT SIXTEEN

That in the County of Wyandotte, State of Kansas on or about the 29th day of December, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $9,225, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT SEVENTEEN

That in the County of Wyandotte, State of Kansas on or about the 29th day of December, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $10,200, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT EIGHTEEN

That in the County of Wyandotte, State of Kansas on or about the 29th day of December, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $12,750, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)

COUNT NINTEEN

That in the County of Wyandotte, State of Kansas on or about the 29th day of December, 2004, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $9,712.50, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT TWENTY

That in the County of Wyandotte, State of Kansas on or about the 1st day of February, 2005, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,575, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT TWENTY-ONE

That in the County of Wyandotte, State of Kansas on or about the 1st day of March, 2005, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $6,750, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT TWENTY-TWO

That in the County of Wyandotte, State of Kansas on or about the 1st day of April, 2005, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,200, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)

COUNT TWENTY-THREE

That in the County of Wyandotte, State of Kansas on or about the 1ST day of May, 2005, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,500, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT TWENTY-FOUR

That in the County of Wyandotte, State of Kansas on or about the 1st day of June, 2005, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $6,900, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT TWENTY-FIVE

That in the County of Wyandotte, State of Kansas on or about the 1st day of July, 2005, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,050 which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT TWENTY-SIX

That in the County of Wyandotte, State of Kansas on or about the 1st day of August, 2005, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $6,750, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)
COUNT TWENTY-SEVEN

That in the County of Wyandotte, State of Kansas on or about the 1st day of September, 2005, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $7,050, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT TWENTY-EIGHT

That in the County of Wyandotte, State of Kansas on or about the 1st day of October, 2005, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $6,300, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT TWENTY-NINE

That in the County of Wyandotte, State of Kansas on or about the 1st day of November, 2005, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $8,700, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT THIRTY

That in the County of Wyandotte, State of Kansas on or about the 1st day of December, 2005, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $6,900, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)

COUNT THIRTY-ONE

That in the County of Wyandotte, State of Kansas on or about the 3rd day of January, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $5,850, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT THIRTY-TWO

That in the County of Wyandotte, State of Kansas on or about the 1st day of February, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $5,250, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT THIRTY-THREE

That in the County of Wyandotte, State of Kansas on or about the 3rd day of March, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $5,100, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT THIRTY-FOUR

That in the County of Wyandotte, State of Kansas on or about the 6th day of April, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $5,850, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)

COUNT THIRTY-FIVE

That in the County of Wyandotte, State of Kansas on or about the 10th day of May, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $6,000 which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT THIRTY-SIX

That in the County of Wyandotte, State of Kansas on or about the 1st day of June, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $500 but less than $25,000, to-wit: $6,300, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT THIRTY-SEVEN

That in the County of Wyandotte, State of Kansas on or about the 5th day of July, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $6,600, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT THIRTY-EIGHT

That in the County of Wyandotte, State of Kansas on or about the 2nd day of August, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $6,150, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)

COUNT THIRTY-NINE

That in the County of Wyandotte, State of Kansas on or about the 1st day of September, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $6,450, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT FORTY

That in the County of Wyandotte, State of Kansas on or about the 2nd day of October, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $6,150, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FORTY-ONE

That in the County of Wyandotte, State of Kansas on or about the 1st day of November, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $6,300, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FORTY-TWO

That in the County of Wyandotte, State of Kansas on or about the 1st day of December, 2006, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $5,850, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)

COUNT FORTY-THREE

That in the County of Wyandotte, State of Kansas on or about the 2nd day of January, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $5,550, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT FORTY-FOUR

That in the County of Wyandotte, State of Kansas on or about the 7th day of February, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $5,100, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FORTY-FIVE

That in the County of Wyandotte, State of Kansas on or about the 9th day of March, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $4,500, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FORTY-SIX

That in the County of Wyandotte, State of Kansas on or about the 10th day of April, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $5,100, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)

COUNT FORTY-SEVEN

That in the County of Wyandotte, State of Kansas on or about the 14th day of May, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $4,800, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT FORTY-EIGHT

That in the County of Wyandotte, State of Kansas on or about the 1st day of June, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $4,500, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FORTY-NINE

That in the County of Wyandotte, State of Kansas on or about the 6th day of July, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $5,100, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FIFTY

That in the County of Wyandotte, State of Kansas on or about the 8th day of August, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $5,550, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)

COUNT FIFTY-ONE

That in the County of Wyandotte, State of Kansas between the 1st day of September, 2007, and the 30th day of September, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $5,400, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT FIFTY-TWO

That in the County of Wyandotte, State of Kansas on or about the 15th day of October, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $4,650, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FIFTY-THREE

That in the County of Wyandotte, State of Kansas on or about the 2nd day of November, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $4,425, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FIFTY- FOUR

That in the County of Wyandotte, State of Kansas on or about the 4th day of December, 2007, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $3,750, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)

COUNT FIFTY-FIVE

That in the County of Wyandotte, State of Kansas on or about the 3rd day of January, 2008, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $6,900, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)





COUNT FIFTY-SIX

That in the County of Wyandotte, State of Kansas on or about the 21st day of February, 2008, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $8,400, which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




COUNT FIFTY-SEVEN

That in the County of Wyandotte, State of Kansas on or about the 18th  day of April, 2008, defendant Rodney Turner did unlawfully, knowingly, and with intent to defraud, present a claim or demand for an amount of at least $1,000 but less than $25,000, to-wit: $8,850 which was false in whole or in part, to a public officer or body authorized to audit, allow, or pay such claim, in violation of K.S.A. 21-3904. (Presenting a False Claim, Severity Level 9 Nonperson Felony)




A true bill.


 

                    _________________________________
                    Presiding Juror
                    Date:  ___________________________







JEROME A. GORMAN #10792
District Attorney





STATE’S WITNESSES:

Nannette Wolfe        E. Leon Daggett        Carl Wolfe
Don Gray            Robert Milan            Terry Eidson
Loretta Colombel        Mary Gonzalez        Mark Jones
John Pettey            Harold “Hal” Walker        Carolyn O’Reilly
Jeri Ann Williams        Kevin Williams        Lori Austin
James Epp            Stephen Rehm            Lauri Brough
James A. Mason        Rick Yarnell            Paul Pauesick
Susan Allen            Jim Head            Mary Ryan
John Sadrakula        Jeff Marks            Matt Berberick
Dennis Tillery            Judy Head            Orin Moats
T. J. Reardon            John Feeback            Chad Charleton
Judy Blomberg        William C. Delaney        Brad Cordts   
John DiMartino        James Carmack        Marc Conklin
Regional Forensic Computer Lab Personnel