Patrick Stallworth Federal Indictment

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Case 2:20-cr-00206-LSC-SGC Document 1 Filed 07/28/20 Page 1 of 4 FILED

2020 Jul-29 AM 11:03


U.S. DISTRICT COURT
N.D. OF ALABAMA

PFE / LCP: August 2020


Grand Jury #1

UNITED STATES DISTRICT COURT


NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION

UNITED STATES OF AMERICA )


)
v. ) Case No.
)
PATRICK DEVONE STALLWORTH )
Defendant. )

INDICTMENT
COUNT ONE
[18 U.S.C. § 1201(a)(1)]

The Grand Jury charges that:

On or about October 12, 2019, in Jefferson County, in the Northern District

of Alabama, and elsewhere, the defendant,

PATRICK DEVONE STALLWORTH,

did willfully and unlawfully seize, confine, inveigle, kidnap, abduct, and carry away

a minor individual, Victim #1, whose identity is known to the Grand Jury, and

otherwise held Victim #1 for his own benefit and purpose, and used and caused to

be used a means, facility and instrumentality of interstate commerce, including, but

not limited to, a Toyota Sequoia motor vehicle in committing and in furtherance of

the commission of the offense. Such offense resulting in the death of Victim #1.
Case 2:20-cr-00206-LSC-SGC Document 1 Filed 07/28/20 Page 2 of 4

All in violation of Title 18, United States Code, Section 1201(a)(1).

COUNT TWO
[18 U.S.C. § 1201(c)]

The Grand Jury charges that:

On or about October 12, 2019, in Jefferson County, in the Northern District

of Alabama, and elsewhere, the defendant,

PATRICK DEVONE STALLWORTH,

did knowingly and intentionally combine, conspire, confederate, and agree with

others known and unknown to the Grand Jury, to commit an act that would constitute

the offense of kidnapping, that is the defendant conspired with other known and

unknown individuals to unlawfully seize, confine, inveigle, kidnap, abduct, and

carry away a minor individual, Victim #1, whose identity is known to the Grand

Jury, and otherwise held Victim #1 in violation of Title 18, United States Code,

Section 1201(a)(1).

OBJECT OF THE CONSPIRACY

It was the purpose and object of the conspiracy for the defendant and his co-

conspirators to unlawfully seize, confine, inveigle, kidnap, abduct, carry away and

hold Victim #1.

2
Case 2:20-cr-00206-LSC-SGC Document 1 Filed 07/28/20 Page 3 of 4

OVERT ACTS

In furtherance of the conspiracy, and to accomplish its purpose, the defendant

and/or one of his co-conspirators committed and caused to be committed, in the

Northern District of Alabama and elsewhere, at least one of the following overt acts,

among others:

1. On or about October 12, 2019, STALLWORTH traveled in a Toyota

Sequoia with a co-conspirator to the Tom Brown Village Housing Development

located in Birmingham, Alabama.

2. On or about October 12, 2019, STALLWORTH and a co-conspirator

abducted Victim #1 from the Tom Brown Village Housing Development.

3. On or about October 12, 2019, STALLWORTH and a co-conspirator

traveled in a Toyota Sequoia with Victim #1 to a Jet Pep gas station and store located

in Birmingham, Alabama.

4. On or about October 12, 2019, STALLWORTH and a co-conspirator

traveled in a Toyota Sequoia with Victim #1 to an apartment complex located on

Shadowood Circle in Centerpoint, Alabama.

3
Case 2:20-cr-00206-LSC-SGC Document 1 Filed 07/28/20 Page 4 of 4

All in violation of Title 18, United States Code, Section 1201(c).

A TRUE BILL

/s/ Electronic Signature


FOREPERSON OF THE GRAND JURY

PRIM F. ESCALONA
United States Attorney

/s/ Electronic Signature


LLOYD C. PEEPLES

/s/ Electronic Signature


ROBIN B. MARK

/s/ Electronic Signature


M. BLAKE MILNER
Assistant United States Attorney

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