1. law, govt and politics

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GUILTY PLEA and PLEA AGREEMENT
United States Attorney
Northern District of Georgia
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
CRIMINAL NO .
CLIFFORD J . HARRIS, JR . ,
1 : 07 - CR - 344 - CAP
(S)
a/k/a T .I ., a/k/a Charles Harris ,
Defendant, having received a copy of the above-numbered criminal
Information and having waived indictment by a grand jury, hereby
pleads
GUILTY
to all counts of the Criminal Information . The
Defendant, his counsel, and the United States Attorney for the
Northern District of Georgia ("the Government"), as counsel for the
United States, subject to approval by the Court, have entered into
this binding plea agreement pursuant to Rules 11(c) (1) (C)
and
ll(c)(3) of the Federal Rules of Criminal Procedure, the terms of
which are as follows :
GENERAL PROVISIONS
1 . The Defendant admits that he is pleading guilty because he is
in fact guilty of the crimes charged in Counts One, Two, and
Three of the Information . A statement of facts supporting
Defendant's plea of guilty is attached hereto as Plea Exhibit
No .
1.
Page 1 of 17
2 . The United States Attorney for the Northern District of
Georgia agrees not to bring further criminal charges against
the defendant related to the charges to which he is pleading
guilty or related to any items seized from the Defendant's
person, vehicle, or residence in connection with this
investigation . The defendant understands that this provision
does not bar prosecution by any other federal, state, or local
jurisdiction .
3 . The Defendant understands that by pleading guilty to this
Information, he is giving up the right to plead not guilty and
the right to be tried by a jury . At a trial, the Defendant
would have the right to an attorney, and if the Defendant
could not afford an attorney, the Court would appoint one to
represent the Defendant . During the trial, the Defendant
would be presumed innocent and the Government would have the
burden of proving him guilty beyond a reasonable doubt . The
Defendant would have the right to confront and cross-examine
the witnesses against him . If the Defendant wished, he could
testify on his own behalf and present evidence in his defense,
and he could subpoena witnesses to testify on his behalf . If,
however, the Defendant did not wish to testify, that fact
could not be used against him . If the Defendant were found
guilty after a trial, he would have the right to appeal the
conviction . The Defendant understands that by pleading
Page 2 of 17
guilty, he is giving up all of these rights and there will not
be a trial of any kind . The Defendant also understands that
he ordinarily would have the right to appeal his sentence and,
under some circumstances, to attack the sentence in postconviction proceedings . By entering this Plea Agreement, the
Defendant may be waiving some or all of those rights to appeal
or collaterally attack his sentence, as specified below .
Finally, the Defendant understands that, to plead guilty, he
may have to answer questions posed to him by the Court
concerning the rights that he is giving up and the facts of
this case, and the Defendant's answers, if untruthful, may
later be used against him in a prosecution for perjury or
false statements .
4 . The Defendant understands that, based on his plea of guilty,
he will be subject to the following maximum and mandatory
minimum penalties on each count :
(a) Maximum term of imprisonment : Ten
(b)
(10)
years .
Mandatory minimum term of imprisonment : None .
(c) Term of supervised release : 3 Years .
(d) Maximum fine : $250,000 .
(e) Mandatory special assessment : $100 .
The Defendant understands that, before imposing sentence in
this case, the Court will be required to consider the
provisions of the United States Sentencing Guidelines, 18
Page 3 of 17
U .S .C . § 3553(a), and the binding terms of the plea agreement
as outlined below .
5 . The Government reserves the right to inform the Court and the
Probation Office of all facts and circumstances regarding the
Defendant and this case, and to respond to any questions from
the Court and the Probation Office and to any misstatements of
fact or law .
ACCEPTANCE OF RESPONSIBILITY
6 . The Defendant agrees to fully and completely accept
responsibility for the criminal conduct outlined in the
Information and for the relevant conduct outlined in the
attached statement of facts .
7 . The Government will recommend that the defendant receive the
two-level adjustment for acceptance of responsibility pursuant
to Section 3E1 .1 of the Sentencing Guidelines, and the
additional one-level adjustment if the offense level is 16 or
higher . The Government will not be required to recommend
acceptance of responsibility if, after entering this Plea
Agreement, the defendant engages in conduct inconsistent with
accepting responsibility . Thus, by way of example only,
should the defendant falsely deny or falsely attempt to
minimize his involvement in relevant offense conduct, give
conflicting statements about his involvement, fail to pay the
Page 4 of 17
special assessment, or participate in additional criminal
conduct, including unlawful personal use of a controlled
substance, the Government will not be required to recommend
acceptance of responsibility .
DEFERRED SENTENCING PROVISIONS
8 . Following entry of his plea of guilty, the Defendant's
sentencing shall be deferred for a period of approximately 12
months from the date of the entry of his plea, so long as the
Court determines the Defendant is in compliance with the
provisions of Paragraph 9 of this Plea Agreement . The purpose
of this deferment is to allow the Defendant to perform the
extensive community service that he has proposed to the
Government and the Court . The parties agree that the Court
should find that there is good cause for the 12-month delay
between the plea and sentencing .
9.
During the 12 months from the plea date to the sentencing
date, the Defendant shall :
(a) Remain under the conditions of his pre-trial bond, as
modified in the revised Bond Order, which is attached as
Plea Exhibit No . 2 . Any exceptions to these conditions
of bond must be approved in advance by the Court, with
notice to the Government and Pretrial Services .
(b) Not violate any federal, state, or local laws .
Page 5 of 17
(c) Perform extensive community service as outlined in,
though not limited to, Defendant's proposal, attached as
Plea Exhibit No . 3, which is designed to :
(1) promote respect for the law and law enforcement ;
(2) oppose violence, illegal and reckless use of
firearms, illegal drugs, and gang activity ; and,
(3) focus on at-risk young people .
The Defendant will perform at least 1000 hours of this
community service during the 12-month period between the
plea and sentencing .
SENTENCING PROVISIONS
10 . At the time of sentencing, if the Court finds that the
Defendant has fulfilled all of the obligations set forth in
paragraphs 6 through 9 of this Plea Agreement, then based upon
the factors set forth in 18 U .S .C .
§ 3553(a), the Court will
sentence the Defendant to the following :
(a) Custody of the Bureau of Prisons for a period of one (1)
year and one
(b)
(1)
day ;
Supervised release to follow for a period of three
(3)
years, which shall include all standard and special
conditions adopted by the Court and the following
additional conditions :
(1)
a total of 365 days of home detention, with credit
Page 6 of 17
for the days the Defendant served on home
incarceration and under the home detention program
(as set forth in paragraph 7 of Plea Exhibit No . 2)
while on bond (which shall be based upon nights the
Defendant stays at his home), to be served
intermittently as necessary to allow Defendant to
work and perform community service ; and,
(2) a total of 1500 hours of community service, as
outlined in Paragraph 9(c) of this Plea Agreement,
with credit for community service performed while
awaiting sentencing .
(c) Pay a fine of $100,000 at the time of sentencing ; and,
(d) Pay a special assessment in the amount of $300, before
the time of sentencing .
(e) The 1500 hours of community service will be calculated as
follows :
(1)
For every actual hour the defendant spends
performing community service, an hour will be
credited to him, if the activity exceeds 4
hours . Otherwise, for every separate public
service activity, he will be credited with 4
hours of community service .
(2) The defendant will receive no more than 8
hours credit for community service in any one
day .
Page 7 of 17
(f) Until the home detention and community service are
completed (including during the deferred sentencing
period), the defendant and his counsel agree to provide
to the Court, the Probation Off ice, and to the Government
a monthly report by the 5t`' business day following the
end of each month detailing the defendant's home
detention days and community service credits for that
month . The defendant and his counsel will also provide
documentation supporting the report on request of the
Court, the Probation Office, or the Government .
( q) The Defendant will not claim eligibility or apply for the
Bureau of Prisons Residential Drug Abuse Program .
11 . If the Court, however, at the time of sentencing finds that
the Defendant has not fulfilled all of the obligations set
forth in paragraphs 6 through 9 of this Plea Agreement, then
based upon the factors set forth in 18 U .S .C .
§ 3553(a), the
Court may impose a custodial sentence of up to fifty-seven
(57) months, unless the Court finds that the Defendant has not
accepted responsibility pursuant to paragraphs 5 and 6, in
which case the Court may impose a custodial sentence of up to
ninety-seven (97) months, in addition to the other sentencing
components listed in Paragraph 10 . In such an eventuality,
the Government and the Defendant may recommend and argue for
a custodial sentence of any length below such ceiling .
Page 8 of 17
12 . If the Court imposes a sentence consistent with Paragraphs 10
and 11 of this Plea Agreement, the Defendant shall not have
the right to withdraw his guilty plea . If the Court, however,
imposes a sentence other than as set out in Paragraph 11 of
this Plea Agreement, the Defendant will be given an
opportunity to withdraw his guilty plea .
FORFEITURE PROVISIONS
13 . Defendant acknowledges that all property, firearms, firearms
ammunition, and related items covered by this agreement were
involved in or used in the violations of 18 U .S .C . § 922(g)
and other violations, and are subject to forfeiture pursuant
to 26 U .S .C . § 5872 and 18 U .S .C . 9 924(d) (1) and 28 U .S .C . §
2461(c) .
14 . The defendant hereby agrees to forfeit and abandon all of his
rights, title or interest to the property, firearms, firearms
ammunition, and related items described in the Abandonment
Form, attached as Plea Exhibit No .
4.
15 . The defendant hereby voluntarily abandons all right, title and
interest in and rights and claims to the above-described
property in order that appropriate disposition may be made
thereof by the appropriate agency of the United States .
Further, the defendant hereby voluntarily withdraws the claim
of ownership he made to the property, if any, and waives any
right to personal notice of the government's intent to forfeit
Page 9 of 17
the above-described property administratively, and any right
to challenge the forfeiture of the above-described property
under Federal law . Furthermore, the defendant agrees not to
file a Petition for Remission or Mitigation in connection with
the forfeiture of the above-described property . If the United
States elects to forfeit the property judicially, the
defendant agrees to the entry of orders of forfeiture and
waives the requirements of Federal Rules of Criminal Procedure
11 (b) (1) (J) , 32 .2 and 43 (a) regarding notice of the forfeiture
in the charging instrument, notice at the plea hearing that
forfeiture is part of sentencing, announcement of the
forfeiture at sentencing, and incorporation of the forfeiture
in the judgment .
16 . Defendant warrants that defendant is the sole owner of all of
the property listed above, and agrees to release, hold
harmless and indemnify the United States, its agents and
employees from any and all claims, suits, or demands made upon
them of whatever nature, in connection with, arising from or
relating in any way to the seizure, forfeiture, custody and
disposition of the above-described property . The defendant
further agrees to waive all constitutional, statutory, and
equitable challenges in any manner (including direct appeal,
habeas corpus, or any other means) to any forfeiture carried
out in accordance with this Plea Agreement on any grounds .
Forfeiture of Defendant's property shall not be treated as
Page 10 of 17
satisfaction of any fine, restitution, cost of imprisonment,
or any other penalty this court may impose upon Defendant in
addition to forfeiture .
APPEAL AND OTHER WAIVERS
17 . LIMITED WAIVER OF APPEAL : To the maximum extent permitted by
federal law, the Defendant voluntarily and expressly waives
the right to appeal his sentence and the right to collaterally
attack his sentence in any post-conviction proceeding on any
ground . The Defendant understands that this Plea Agreement
does not limit the Government's right to appeal, but if the
Government appeals the sentence imposed, the Defendant may
also file a direct appeal of his sentence .
18 . The defendant states that, because he knows that he is
actually guilty of the offenses to which he is entering pleas
of guilty, he now knowingly waives the right to request DNA
testing of any evidence in this case in the current
proceeding, in any post-conviction proceeding under 18 U .S .C .
§
3600, and in any other type of proceeding in which DNA
testing may be requested . The defendant fully understands
that, as a result of this waiver of the right to DNA testing,
he will never have another opportunity to have the evidence in
this case submitted for DNA testing or to employ the results
of DNA testing to support a claim that he is innocent of the
offense to which he is pleading guilty . Understanding those
Page 11 of 17
rights, the defendant hereby knowingly and voluntarily gives
up the right to request DNA testing .
19 . The Defendant hereby waives all rights, whether asserted
directly or by a representative, to request or receive from
any department or agency of the United States any records
pertaining to the investigation or prosecution of this case,
including, without limitation, any records that may be sought
under the Freedom of Information Act, 5 U .S .C . § 552, or the
Privacy Act of 1974, 5 U .S .C . § 552a .
CONCLUDING PROVISIONS
20 . The parties agree that they will jointly recommend that this
plea agreement be accepted by the Court at the time the guilty
plea is entered . Pursuant to Rules ll(c)(1)(C) and 11(c)(3),
of the Federal Rules of Criminal Procedure, the Court is bound
by the provisions agreed to above once the Court accepts the
terms of this Plea Agreement at the plea hearing .
21 . The United States agrees to dismiss the original Indictment in
this case upon sentencing of the Defendant .
22 . There are no other agreements, promises, representations, or
understandings between the Defendant and the Government .
Page 12 of 17
'"
e
In Open Court this ~ day of
A
u i~
2008 .
V
SIGNAT
S
SIGNATURE
;
.-/ant
(Def
( Defense At t orney )
CLIF ORD J . HARRIS, JR .
DEFENDANT
EDWARD T . M . GARLAND
SIGNATURE
SIGNAT UR E
(Defense Attorney)
STEVE SADOW
WIG
8
( De f ense Attorne y)
DONALD F . SAMUEL
[ De f ense Attorney)
T L . THOMAS
FOR THE UNITED STATES :
r
A&d
SI GNATURE sistant U S Attor (j)
SIGNATURE
TODD C . ALLEY
FRANCEY K S
cl~
(A
i st t U S Attorney)
L
SIGNATURE
SIGNATURE
THOMAS DEVLI JR .
CHIEF, VIO CRIME
DAVID E . NAHMIAS
UNITED STATES ATTORNEY
I, CLIFFORD J . HARRIS, JR ., have read the Information against
me and have discussed it with my attorneys . I understand the
charges and the elements of each charge that the Government would
Page 13 of 17
have to prove to convict me at a trial . I have read the foregoing
Plea Agreement and have carefully reviewed every part of it with my
attorneys . I understand the terms and conditions contained in the
Plea Agreement, and I voluntarily agree to them . I also have
discussed with my attorneys the rights I may have to appeal or
challenge my sentence, and I understand that the appeal waiver
contained in the Plea Agreement will prevent me, with the narrow
exception stated, from appealing my sentence or challenging my
sentence in any post-conviction proceeding . No one has threatened
or forced me to plead guilty, and no promises or inducements have
been made to me other than those discussed in the Plea Agreement .
The discussions between my attorneys and the Government toward
reaching a negotiated plea in this case took place with my
permission . I am fully satisfied with the representation provided
to me by my attorneys in this case .
3 _;'05
SIGNA
RE
e
DATE
nd nt
CL I FORD J . HARRIS, JR .
Page 14 of 17
We are CLIFFO RD J .
HARRIS ,
JR .' s lawyers .
We have c arefully
reviewed the charges and the Plea Agreement with our client . To
our knowledge, the client is making an informed and voluntary
decision to plead guilty and to enter into this Plea Agreement .
SIGNATURE (Defense Attorney)
EDWARD T . M .
SIG21ATURE
GARLAND
STEVE
_
SADOW
(Defense At t orne y)
DONALD F . SAMUEL
3 L7 [mil "
T URE
D )PE
( Defense Attorney)
ICE A . SINGER
Page
15 of 17
INFORMATION BELOW MUST BE TYPED OR PRINTED
NAME (Attorney for Defendant)
Clifford J . Harris, Jr .
NAME (Defendant)
STREET
STREET
CITY & STATE
ZIP CODE
CITY & STATE
PHONE NUMBE
PHONE NUMBER
STATE BAR OF GEORGIA NUMBER
Filed in Open Court
Z~Q a
r
B
Page 16 of 17
ZIP CODE
U. S . DEPARTMENT OF JUSTICE
Statement of Special Assessment Account
This statement reflects your special assessment only . There may be other penalties imposed at
sentencing .
ACCOUNT INFORMATION
CRIMINAL ACTION NO. :
DEFENDANT'S NAME:
PAY THIS AMOUNT :
1 :07-CR-344-CAP (S)
CLIFFORD J . HARRIS, JR .
$300 .00
INSTRUCTIONS :
1 . MAKE CHECK OR MONEY ORDER PAYABLE TO :
CLERK OF COURT, U . S . DISTRICT COURT
2.
PAYMENT MUST REACH THE CLERK'S OFFICE BEFORE YOUR
SENTENCING DATE
3. PAYMENT SHOULD BE SENT OR HAND DELIVERED TO :
Clerk of Court, U .S. District Court
2211 U .S. Courthouse
75 Spring Street S .W.,
Atlanta, Georgia 30335
(Do not Send Cash)
4.
INCLUDE DEFENDANT 'S NAME ON CHECK OR MONEY ORDER
5. ENCLOSE TH IS COU PON TO
APPLICATION OF PAYMENT
6.
INSURE PROPER AND PRO MPT
BRING PROOF OF PAYMENT T O THE SENTENCING HEARING
Page 17 of 17
PLEA E XHIB IT NO . 1
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA
CRIMINAL INFORMATION
V.
CLIFFORD J . HARRIS, JR .,
a/k/a "T .I .," a/k/a Charles
Harris
NO . 1 :07-CR-344-CAP
Superseding
STIPULATED STATEMENT OF FACTS
The parties in the above-styled case and agree and stipulate
that the following facts form the factual basis for the Defendant's
guilty plea . If the case proceeded to trial, the Government's
evidence would prove as follows :
1 . The Defendant was convicted on June 1, 1998, in the Superior
Court of Cobb County, Georgia, of a Violation of the Georgia
Controlled Substances Act for Possession With Intent to
Distribute Crack Cocaine, a felony offense . As a convicted
felon, the Defendant could not lawfully buy, receive, or
possess firearms or ammunition of any kind .
2 . On May 2, 2006, the Defendant participated in an appearance at
a nightclub in Cincinnati, Ohio . During the appearance,
individuals in the crowd became unruly and combative, forcing
the Defendant and others to leave the nightclub in a pair of
vans . The van carrying the Defendant was later shot at
multiple times by unknown individuals in another vehicle while
the vehicles were driving down the road . During the incident,
the Defendant's friend and assistant, Philant Johnson, was
shot and killed, and his head of security, Ron Hausley, was
shot and injured . Hausley returned fire on the shooters, who
have never been identified or arrested .
3 . During September and October of 2007, one of the Defendant's
bodyguards purchased nine (9) firearms for the Defendant at
the Defendant's request . These firearms were delivered to the
Defendant's residence at 429 Creekview Lane, College Park,
Georgia, by the bodyguard . The Defendant took possession of
these firearms and placed some or all in a hidden compartment
(which was secured by a biometric lock) inside a closet in the
Defendant's bedroom .
4 . On October
10,
2007, the Defendant arranged for this same
bodyguard to pick up $12, 000 in cash from the Defendant` s bank
account at SunTrust Bank . The Defendant told the bodyguard to
use the cash to buy machine guns for the Defendant . On
October 10, 2007, the bodyguard purchased three machine guns
for the Defendant, and also bought two silencers to deliver to
the Defendant, from an undercover ATF agent .
5 . The machine guns and silencers were not registered to the
bodyguard or to the Defendant in the National Firearms
Registration and Transfer Record, as would be required for a
lawful purchase of machine guns or silencers . The bodyguard
was arrested for unlawfully purchasing the firearms and
silencers .
6 . After his arrest, the bodyguard agreed to assist the ATF in
investigating the Defendant's conduct in arranging and paying
for the purchase of machine guns . The bodyguard made several
monitored/recorded telephone calls to the Defendant, during
Page 2 of 7
which the two discussed delivery of the firearms . The
Defendant said he wanted to take possession of the "items" or
"product" (meaning the machine guns) . The Defendant and the
bodyguard agreed to meet in the parking lot of the Publix
shopping center at the corner of North Avenue and Piedmont
Avenue, in Atlanta, Georgia . The meeting was arranged for the
afternoon of Saturday, October
1 3, 2007 .
7 . On October 13, 2007, ATF agents placed a body wire on the
bodyguard to monitor any conversation between the bodyguard
and the Defendant . ATF agents also positioned themselves in
a surveillance van at a vantage point from which they could
view and video record the meeting . The Defendant arrived at
the shopping center driving a Ranger Rover sport utility
vehicle, with a female and male passenger inside .
8 . The bodyguard got into the back seat of the Range Rover and
showed the Defendant the machine guns and silencers, which the
bodyguard had carried to the meeting in a duffel-type bag .
The Defendant asked the bodyguard, "Is there anything special
I need to know?" After this, the Defendant and the bodyguard
discussed the semi-automatic and fully-automatic functioning
of the machine guns . The Defendant then inspected the
weapons, and noted that the silencers were designed for "no
flash, no bang ." The Defendant also asked the bodyguard
whether ammunition was included for the machine guns, and
asked what caliber rounds were used in the weapons . The
Defendant then discussed with the bodyguard why he was not
getting any money back from the purchase of the machine guns
and stated, "Ain't none of them new, ain't none of them brand
new ."
Page 3 of 7
9 . After the bodyguard gave a signal, ATF agents moved in to
arrest the Defendant . During a subsequent search of the Range
Rover sport utility vehicle the Defendant was driving, ATF
agents found a loaded Heckler and Koch, Model USP Compact,
.40
caliber pistol, s/n 26-088326, tucked between the driver's
seat, where the Defendant had been sitting, and the center
console . This firearm had been purchased by the bodyguard on
September 6, 2007, and the defendant knew it was in his
vehicle .
10 .
Additionally, during the search of the Defendant's Range Rover
incident to the Defendant's arrest, ATF agents found :
a . A loaded Springfield Armory U .S .A ., Model XD-45ACP,
.45
caliber pistol, s/n US694153, located in the back
passenger seat ;
b . A loaded Masterpiece Arms, Model 45 ACP,
.45 caliber
pistol, s/n A4555 (which had been purchased by the
bodyguard for the Defendant and delivered to the
Defendant at his residence on September 26,
2007),
located in a piece of luggage in the rear storage area
(the luggage also contained clothing and personal items
belonging to the Defendant) ;
c . One Walther firearm magazine, loaded with
.40 caliber
ammunition, located in the right front pocket of an
Armani coat in the back passenger seat ;
d . One set of Point Blank camouflage body armor, located in
the rear storage area ; and,
e . A total of over $10,000 in U .S . currency, located on the
Defendant's person and sealed in plastic inside a
backpack on the backseat .
Page 4 of 7
11 . Following his arrest, the Defendant was interviewed by ATF
agents . Prior to the interview, the Defendant was advised of
his Miranda rights and waived those rights . During the
interview with ATF agents, the Defendant admitted that he
handled the machine guns in the vehicle .
12 . Later on that same day, October 13, 2007, ATF agents,
accompanied by U .S . Marshals, Fulton County Police officers,
and Fulton County Sheriff's deputies, executed a federal
search warrant at the Defendant's residence at 429 Creekview
Lane, in College Park . During the search of the residence,
law enforcement officers found :
a . Inside the Defendant's (master) bedroom :
i . several boxes and loose rounds of various caliber
firearms ammunition in the nightstand, under the
bed, and by the television ;
ii . a Taurus,
.357 revolver box, s/n ZI80533, on the
floor near the rear door of the bedroom ;
iii . a Heckler and Koch, Model P2000,
.40 caliber pistol
box, s/n 123039698, on a bench at the foot of the
master bed ; and,
iv, various documents and items of mail bearing the
name Clifford Harris ;
b . Inside the Defendant's bedroom closet :
i . a Colt, Model Carbine, 5 .56 mm caliber rifle, s/n
LE033297, with one magazine and ammunition (which
had been purchased by the bodyguard for the
Defendant on September 26, 2007) ;
Page 5 of 7
A
V
ii . a Century International Arms, Model AK Pistol,
7 .62x39 mm caliber pistol, s/n AKMP01683, with one
drum magazine and ammunition (which had been
purchased by the bodyguard for the Defendant on
September 26,
2007) ;
iii . a DPMS, Panther Arms, Model LR-308,
.308 caliber
rifle, s/n 14056, with one magazine (which had been
purchased by the bodyguard for the Defendant on
September 26,
2007) ;
and,
iv . various rounds of ammunition .
c . Inside a compartment behind a false wall within the
Defendant's bedroom closet (which was secured with a
biometric lock which required the Defendant's fingerprint
to open and the records for which indicate was last
accessed on October 12, 2007, by the Defendant) :
i . a Bushmaster, Model Carbon 15,
.223 mm caliber
pistol, s/n D07 1 59, with a "Streamlight" tactical
laser illuminator attached, and with one CMAG dualdrum magazine and ammunition ;
ii . a Colt, Model Anaconda,
.44 magnum caliber
revolver, s/n MM70228, with ammunition ;
iii . a Calico, Model Liberty III, 9 mm caliber pistol,
s/n B004397, with one magazine (which had been
purchased by the bodyguard for the Defendant on
September 6, 2007) ;
iv, an FN-5/7 pistol box, undetermined s/n ;
v . a Smith & Wesson, Model 500ES, firearm box, s/n
DAJ7148 ;
vi . a Heckler and Koch pistol box, s/n 25-111182
(which
had contained a firearm purchased by the bodyguard
for the Defendant on September 6,
Page 6 of 7
2007) ;
r
vii . a DPMS Panther, Model LR308 firearm box, s/n 14056
(which had contained a firearm, referred to above,
purchased by the bodyguard for the Defendant on
September 26, 2007) ;
viii . various rounds of loose and boxed ammunition ; and,
ix . various documents and other personal items bearing
the name and/or the image of Clifford Harris .
13 .
All of the firearms named in Counts One, Two and Three of the
superseding Criminal Information were manufactured outside the
State of Georgia and, therefore, affected interstate commerce .
This
p~ r
SIGNATURE ( bef
day
ndan
)
CLIFFORD RIS, JR .
of
2008 .
SIGNATURE
EDWARD
(Defense Attorney)
T . M . GARLAND
ji4lAw~
SIC-MATURE (Defense A t t o rney)
S I G NA TURE
STFSADOW
DONALD F . SAMUEL
NATURE
(Defense Attorney )
NATURE
( Defense Att o
JANICE A . SINGER
IGHT L . THOMAS
.
( Defense Att orne
4" le2 / aa., ~'~
(/
YVI~4
SIGNATURE sslstant U S Att y)
SIGNATU RE (
TODD C . ALLEY
FRANCEY ES
Page 7 of 7
nt
U S
Att o rne y)
PLEA EXHIBIT
NO . 2
r
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA
CRIMINAL INFORMATION
V.
CLIFFORD J . HARRIS, JR .,
a/k/a "T .I .," a/k/a Charles
Harris
NO . 1 :07-CR-344-CAP
Superseding
ORDER SETTING MODIFIED CONDITIONS OF RELEASE
IT IS HEREBY ORDERED that the release of the Defendant,
Clifford J . Harris, Jr ., a/k/a "T .I .," a/k/a Charles Harris, is
subject to the following conditions :
1 . The Defendant shall not commit any offense in violation of
federal, state, or local law while on release in this case .
2 . The Defendant shall immediately advise the Court, defense
counsel, and the U .S . Attorney in writing before any change in
address or telephone number ;
3 . The Defendant shall appear at all proceedings as required and
shall surrender for service of any sentence imposed as
directed .
IT IS FURTHER ORDERED that the Defendant be released provided
that :
4 . The Defendant promises to appear at all proceedings as
required and to surrender for service of any sentence imposed .
Page 1 of 9
IT IS FURTHER ORDERED that the release of the Defendant is
subject to the following additional conditions :
5 . The Defendant is placed in the custody of Judicial Corrections
Services,
Inc ./Robert H . McMichael II, 34 Peachtree Street,
Suite 1000, Atlanta, Georgia, 30303, telephone number 404-5913180 (o) ; 404-273-2383
(c), or other Court-approved monitor,
who agrees :
a . to supervise the Defendant in accordance with all the
conditions of release ;
b . to use every effort to assure the appearance of the
Defendant at all scheduled court proceedings ; and,
c . to notify the Court and the Government immediately in the
event the Defendant violates any conditions of release or
disappears .
6 . T he Defendant shall :
a . report to the United States Probation officer who is
supervising his pretrial release ;
b . maintain the cash and property bond initially posted in
this case ;
c . maintain his lawful, verifiable employment consistent
with the conditions of his release and the terms of the
Plea Agreement in this case ;
d . leave his passport in the custody of Pretrial Services
and not obtain or attempt to obtain another passport ;
Page 2 of 9
e . avoid contact with all informants in this case (as
identified to him by the Government) ;
f . refrain from possessing a firearm, destructive device, or
other dangerous weapons or ammunition in his home, on his
person, in his automobile, or in his place of business ;
g . refrain from any use of alcohol ;
h . refrain from the use or unlawful possession of any
narcotic drug or other controlled substance, as defined
in 21 U .S .C .
9 802,
unless prescribed by a licensed
medical practitioner ;
i . submit to any method of testing required by the Pretrial
Services office or the supervising officer for
determining whether the Defendant is using a prohibited
substance, which testing may be utilized with random
frequency ; and,
j . refrain from obstructing or attempting to obstruct or
tamper, in any fashion, with the efficiency and accuracy
of any prohibited substance testing or electronic
monitoring which is/are required as a condition of
release .
7 . The Defendant shall participate in a home detention program,
the conditions of which are :
a.
Monitoring :
i . continued electronic location verification, in the
Page 3 of 9
form of an active
CPS
system, paid for by the
Defendant ;
ii, continued 24-hour monitoring by Judicial
Corrections Services,
or other Court-approved
monitor, as outlined above, paid for by the
Defendant's employer ;
b.
Travel Restrictions :
i . Defendant shall be permitted to travel outside the
Northern District of Georgia only for employment
purposes and community service under his plea
agreement, and only after he receives the
permission of Pretrial Services ;
ii . Defendant shall not be in any bar or nightclub (but
not including a restaurant) other than for a
contractually obligated paid performance or
appearance, as verified in advance by defense
counsel ;
c.
Curfew :
i . while at his home, Defendant shall maintain a
curfew of 11 :00 p .m . to 6 :00 a .m ., unless a
contractual performance or appearance requires a
later appearance, in which case his curfew shall be
from 1 :00 a .m . to 8 :00 a .m . ;
ii . while traveling for employment purposes or
Page 4 of 9
t
community service activities, the Defendant shall
maintain a curfew in his sleeping quarters of 11 :00
p .m . to 6 :00 a .m ., unless a contractual performance
or appearance requires him to remain at or go to
his employment, in which case the defendant shall
maintain a curfew of 1 :00 a .m . to 8 :00 a .m . ;
iii . curfew times may also be modified on specific days
for good cause and with prior approval of Pretrial
Services ;
d.
Visitation :
i . while there will be no restrictions on the number
of visitors during non-curfew hours, visitors to
Defendant's home, hotel room, or other place of
lodging shall be required to provide valid photo
identification, date of birth, and social security
number, which will be recorded on a list maintained
by the monitor, and all visitors must consent to a
criminal background check conducted at the
discretion of Pretrial Services or the Government ;
ii . all visitors will be searched for weapons and/or
contraband prior to being admitted into Defendant's
home, hotel room, other place of lodging, or
vehicle in which Defendant is an occupant ;
iii . there will be no visitors, other than Defendant's
Page 5 of 9
i mmediate family and Tamika Cottle ,
in Defendant ' s
home, hotel room or other place of lodging, during
curfew hours, except as approved in advance by
Pretrial Services and the Government ;
iv . the monitor will have the unfettered discretion to
turn away any visitor or to limit the total number
of visitors at any time ;
e . Monthly Reports :
By the 5th business day following the end of each month
(unless Pretrial Services requests them more frequently),
the monitor shall provide a monthly report to the Court,
Pretrial Services, and the Government regarding
Defendant's compliance with his curfew, copies of any
contracts for appearances or performances at nightclubs
or bars, and the list of visitors for the month ;
f.
Other :
i . Defendant shall consent to random, unannounced
searches by Pretrial Services of his residence, or
any place in which he is staying, any vehicles on
his premises or in which he is an occupant, and to
the seizure of any contraband or items prohibited
by the conditions of release ;
ii . no safes or other secured facilities shall be
permitted in Defendant's residence or in any
Page 6 of 9
vehicle in which he is a passenger ;
iii . no person other than law enforcement agents or the
employees of the monitoring service shall possess
firearms, dangerous weapons, destructive devices,
or ammunition in or on the premises of Defendant's
residence, his hotel room or place of lodging, or
in any vehicle in which Defendant is an occupant ;
iv . the obligations of the monitoring service, as
ordered by the Court on October 26, 2007, unless
modified by this Order, shall continue until such
time as they are relieved of such obligations by
the Court .
8 . The Defendant is aware of and agrees to the following
penalties and sanctions :
A violation of any of the foregoing conditions of release may
result in the immediate issuance of a warrant for Defendant's
arrest, a revocation of release, ann order of detention, and a
prosecution for contempt of court and could result in a term of
imprisonment, a fine, or both .
The commission of a Federal offense while on release will
result in an additional sentence of a term of imprisonment of not
more than ten years, if the offense is a felony ; or a term of
imprisonment of not more than one year, if the offense is a
misdemeanor . This sentence shall be in addition to any other
sentence .
Page 7 of 9
Federal law makes it a crime punishable by up to 10 years of
imprisonment, and a $250,000 fine or both to obstruct a criminal
investigation . It is a crime punishable by up to ten years of
imprisonment and a $250,000 fine or both to tamper with a witness,
victim or informant ; to retaliate or attempt to retaliate against
a witness, victim or informant ; or to intimidate or attempt to
intimidate a witness, victim, juror, informant, or officer of the
court . The penalties for tampering, retaliation, or intimidation
are significantly more serious if they involve a killing or
attempted killing .
If after release, the Defendant knowingly fails to appear as
required by the conditions of release, or to surrender for the
service of sentence, he may be prosecuted for failing to appear or
surrender and additional punishment may be imposed . If the
Defendant is convicted of :
a) an offense punishable by death, life imprisonment, or
imprisonment for a term of fifteen years or more,
Defendant shall be fined not more than $250,000 or
imprisoned for not more than 10 years, or both ;
b) an offense punishable by imprisonment for a term of five
years or more, but less than fifteen years, Defendant
shall be fined not more than $250,000 or imprisoned for
not more than five years, or both ;
c) any other felony, the Defendant shall be fined not more
than $250,000 or imprisoned not more than two years, or
Page 8 of 9
both ;
d) a misdemeanor, Defendant shall be fined not more than
$100,000 or imprisoned not more than one year, or both .
A term of imprisonment imposed for failure to appear or
surrender shall be in addition to the sentence for any other
offense .
In addition , a fa i lure to appear or surrender may result
in the forfeiture of any bond posted .
This 27th day of March, 2008 .
HONORABLE ALAN J .
UNITED STATES NAG
bv~
SIGNA
E
(D e fer
SIGNATURE
CLI- ~ORD J
SIGNATURE
IS ,
JR .
( Defense Att orney )
EDWARD T . M . CARL
(D e fens e Attorney)
SIGNATURE
( Defense ACto
)
DONALD F . SAMUEL
S TIrV'E-'SCOW
(Defeifse AttoYaey )
G NATURE (Defense At top
L . THO MAS
~
ANICE A . SINGER
Witnesse by :
- // /9 YZ4-"'
SIGNATURE (
TODD C . ALL EY,
FRANCEY S, AUSA
AUS
Page 9 of 9
i
O/x
amt v S Attorney)
SIGNATU AssisCanC U S At ey)
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA
CRIMINAL INFORMATION
V.
NO . 1 :07-CR-344-CAP
Superseding
CLIFFORD J . HARRIS, JR .,
a/k/a "T .I .," a/k/a Charles
Harris
ADDENDUM TO THE ORDER SETTING MODIFIED CONDITIONS OF RELEASE
Judicial Corrections Services, Inc ./Robert H . McMichael, II,
agrees : to supervise the defendant in accordance with all the
conditions of release ordered in the Modified Conditions of
Release ; to use every effort to assure the appearance of the
defendant at all scheduled court proceedings ; and to notify the
Court immediately in the event the defendant violates any
conditions of release or disappears .
S igned :
br ~ mj~*
Robert H .
~
McMichael ,
Date :
II
Page Z of Z
6,3 -.,2--p "' O
PLEA EXHIBIT NO . 3
1 . IT'S COOL TO BE SMART : This organization is a component of the
Boys and Girls Clubs of America . Harris has already devoted
considerable time to this organization and will continue to do so . This
program is geared around a mentoring project . The executive director
wants Mr . Harris to become the National Spokesman for the project .
Over 3,000 selected boys in Atlanta and other markets will participate
in the program with one-on-one contact with Mr . Harris . At least
once a month, Mr. Harris will teach a class to the boys . In addition,
he will conduct public service announcements that will air on Radio
One stations throughout the metro Atlanta area . Similar programs
throughout the country that partner with IT'S COOL TO BE SMART
will utilize Mr. Harris's services as well .
2. NAACP : The NAACP Youth Development and Empowerment Tour,
based in Henry County, Georgia, has asked Mr. Harris to participate
in this year's event . The Tour's objectives include educational
development, community involvement, economic development, civic
consciousness, spiritual enrichment, anti-drug programs, anti-gang
initiatives, anti-alcoholism programs and commitment to
empowerment . Mr. Harris's commitment to this program, including
participation in the tour which travels throughout the metro Atlanta
counties, will involve soliciting the support and participation of other
"rappers" and personalities . We have learned that local members of
the judiciary and the law enforcement community - including various
District Attorneys and Solicitors in the metro Atlanta area - have
indicated their enthusiasm with Mr . Harris's willingness to work in
the community .
3 . Boys and Girls Clubs of America : This part of the community service
plan is the most ambitious and involves a nationwide commitment to
achieving the same goals as those outlined above, through the aegis of
the Boys and Girls Clubs of America . We have been in touch with
various leaders of the Clubs and have developed a plan . The plan
includes a public service announcement campaign, which will be aired
as "trailers" in movie theaters, as well as on BET and MTV . These
r
announcements would advocate staying in school, stress the
avoidance of violence, gangs, drugs and guns, discourage sexual
promiscuity, and encourage community involvement . The public
service announcements will be preceded by a nationwide tour of
Clubs that includes twenty-five cities . It is hoped (though not yet
guaranteed), that this nationwide event will induce Oprah Winfrey
(and possibly other talk show hosts) to invite Mr . Harris to appear on
her show. Interviews on various radio shows, such as the Tavis
Smiley show, the NPR Bryant Park Project and other shows with
national exposure have been approached about inviting Mr . Harris to
appear to spread the message . We anticipate that print media,
including Ebony, JET, Black Enterprise and 0 Magazine will
approach Mr . Harris about interviews, as well .
4 . Journee Smollett : Ms . Smollett is a 21-year old actress who recently
starred in Oprah Winfrey's "The Great Debaters ." She has created the
"Catch Me Before I Fall Initiative" . This program focuses on utilizing
celebrities to participate in community-based speaking engagements,
and using the media to broaden awareness of the issues of violence,
drugs and gangs . Ms. Smollett, who has already met with Mr . Harris,
has expressed a keen interest in utilizing him as part of this program
not only as a speaker, but also as a recruiter of other celebrities to
participate in the initiative .
IT' S COOL TO BE SMART I Information Kit
YQw rt/.
Music Mentor pro gram For Teen Gi
f
~
PROGRAM
IS
GOALS OF THE MUSIC MENTOR
TO HIGHLIGHTA
DIFFERENT SIDE OF THE MUSIC
INDUSTRY BUSINESS THAT IS AVAILABLE
FOR OUR TEEN GIRLS OTHER THAN
IMAGES SHOWN IN MUSIC VIDEOS
Clifford Harris support for new youth project for young
men in 2008-2009
It's Cool To Be Smart "Stop Teen on Teen
Violence" Mentoring Project for Young Men
IT'S C OOL TO BE SMART MISSION
Founded in 2003, IT'S COOL TO BE SMART is a
mentoring program for teenage youth that collaborates
with celebrities from film, television and music . The
organization has touched the lives of more 3000 youth
across the country, including cities such as Atlanta,
Washington DC, New York, Los Angeles and Chicago .
The program's mission is to empower youth to become
future business leaders by creating mentorship
opportunities with influential people in the entertainment
industry throughout the nation .
The national organization is currently supported by the
Georgia Department of Human Resources.
ABOUT THE MENTORING PROJECT FOR
YOUNG MEN
As mentioned our organization has a history of working
with many known celebrities such as Clifford Harris
(aka T .I .), Screen Writer and ICTBS Board Member,
Antwone Fisher, the late Gerald Levert, Grammy
Song Writer, Sean Garrett( Mary J . Blige, Chris Brown, Usher, Beyonce', Jay-Z)
and many others, who have supported the efforts for the It's Cool To Be Smart
organization .
TAB "A"
ITS COOL TO BE SMART I Information K it
i
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T
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WIWI
Music Mentor program for Teen
THE GOALS OF THE MUSIC MENTOR
PROGRAM IS TO HIGH LIGHT A
DIFFERENT SIDE O F THE MU SIC
INDUSTRY BUSINES S THAT IS AVAILABLE
FOR OUR TE EN GIRLS OTHER THAN
IMAGES SHOWN IN MUSIC VIDEOS
Ailk
In 2008-2009, our next national community project is called It's Cool To Be Smart
"Stop Teen on Teen Violence for Young Men" . Our pilot for the project was kicked
off with actor, Mr. Anwan Glover, from the proclaimed HBO show "The Wire" .
Overview of Proj ect that will involve Mr. Clifford Harris
It's Coo l To Be Smart "Stop Teen on Teen Violence"
At this time, It's Cool To Be Smart will establish a more effective and fairer criminal and
juvenile justice policies throughout the nation in collaboration with our partnering youth
organizations . Our new at risk project for boys is called It's Cool To Be Smart "Stop
Teen on Teen Violence" . This mentoring project will aim to lower overall rates of
incarceration of young men and help eliminate unequal treatment of African Americans .
Also our main goal with this project is to lower the rate of repeat offenders from entering
back into the criminal justice system in Atlanta Georgia .
During this project, It's Cool To Be Smart will be
requesting Mr . Clifford Harris to become the
National Spokesperson of this project and collaborate
with other supporters and actors from "The
WIRE"," "Law & Order", "New York Under
Cover" and Screen Writer, Author and ICTBS
Board Member Antwone Fisher . The project will
involve Mr . Harris and other actors to become
mentors for over 3000 selected boys in Atlanta and
our partnering markets such as Washington DC .,
Chicago, New York, and Los Angeles (boys selected
will have history of being in the Juvenile system) All
celebrity mentors will have a background on working
with "At Risk Youth" .
The project will start during the spring of 2008- May
of 2009 in Dekalb County of Atlanta Georgia at one of our partnering schools . Mentoring
Classes will be held every Tuesday and Thursday for and hour and will start at 3 :30pm5:00pm . The areas of discussion for this project will focus on the following : Building
family bonds; Gang Prevention ; Positive re- integration into the community and school ;
Establishing a positive pattern of behavior; allowing yourself to trust positive people .
IT'S COOL TO BE SMART I Information Kit
i
,' F~
W-e
Music Mentor pmaram For Teen
THE GOAL S OF THE M US IC MENTOR
PROGRAM IS TO HIGHLIGHT A
DIFFERENT SIDE OF THE MUSIC
INDUSTRY BUSINESS THAT IS AVAI LAB LE
FOR OUR TEEN GIRLS OTHER THAN
IMAGES SHOWN IN MUSIC V IDEO S
Clifford Harris main objective for the Project :
•
Mr. Harris will be involved in reviewing essays and creative writing from the
students(top essays will be highlighted on Radio One)
Once a month, Mr. Harris will be scheduled to talk with the selected students
concerning their essays as well share some of his work as a writer of his music
•
Mr. Harris will be conducting public service announcements that will air on
our partnering Radio One stations
•
Mr. Harris will also be involved on speaking panels with other mentors such as
Screen Writer, Antwone Fisher, actors Malik Yoba, Anwan Glover and Michael
Delorenzo. These quarterly panel Discussions are called "Real Talk" and are
Hosted by our Radio One partners and will be provided for the selected youth of
the program, that have suffered a lost of family member due to a senseless
crime. These panel discussions have always consisted of paned celebrities that
focus on problems that the youth our having in their communities, schools and
the Juvenile system.
Thank you for your review of the overview of the 2008-2009 project with Mr . Clifford
Harris.
Sincerely,
Curtis Benjamin
Executive Director
It's Cool To Be Smart
t
Bishop Eddie L. L ong
Senior Pastor
January 29, 2008
Attorney Dwight Thomas
1745 Martin Luther King Drive
Atlanta, GA 30314
RE. Clifford "T I." Harris, Jr.
Dear Attorney Thomas .
It is truly my pleasure to greet you today . Here at New Birth we believe that
2008 holds unbelievable potential for all of us to reach new levels, not only in our
personal lives but also in our service to others . We believe we are blessed to be a
blessing and this is truly the year to manifest it!
I am excited about the opportunity to share our Easter Celebration services with
Mr. Harris . For almost ten years New Birth has hosted our Easter Services at the
Georgia Dome and we have attracted well over 75,000 attendees per year . Each
year we host outreach activities on the Saturday before Easter Sunday, and then
celebrate with our church service the following day . Our Saturday outreach
services include various life skill development opportunities for youth, single ~
adults, married couples, men, and women of all ages . We are humbled that for
the past 12 years, our Easter Celebration at the Georgia Dome has continued to
be one of the largest gatherings in the world
We believe large gatherings like our outreach and Easter Service are prime
opportunities for impacting our community as we provide the services
mentioned above. By partnering with Mr. Harris, we can expand our reach even
further than the thousands that have been blessed in the past years In addition,
we can also provide crucial, life saving assistance with heightened awareness,
educational, and prevention measures for different community challenges . For
example, our efforts will address the HIV/ AIDS epidemic and the lack of
donated blood, both which have disproportionate and devastating effects within
the African American community .
Below are ideas for how this partnership will evolve . Mr. Harris can assist us by :
Doing PSA`s to encourage people to come out to be tested and educated
on the HIV/AIDS epidemic
TAB "C"
PO. Box 1019. Uthania GA 30058
770.696.9669 770.696.9587 fax
www.newbirth org
h
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~
r~r
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c
•
t-1,fe are keenly aware that Mr I Iczrris' :n t7rrence {rd( reach rzn ;rurhf rtce
that normally doesn't respond to the church cc?tnniunzty, but tirspcrraztei11
need the assistance beitia offered
Encouraging industry contacts/celebrity's to participate and assist with
the overall budget (attached)
e Mr. Hats can call upon relationships he has established to assist fit
contributing to th is effort
• Attending the Saturday outreach event s and the S unday Easter service
c L'4 ebeliez>et1iat lrrs preserrce at tizeec,e?7ts 7i~tll izot ojililbE= ahlnssirto to
hirn, but it -will encourage people to actuallil have the courage to bet tested
(on Saturday) and hare the interest in the service (on Suntc~yj .
On behalf of the New Birth family I would like to thank you for the opportunity
to partner with you for our annual Easter Outreach . We hope you will lend your
support and help increase our church's effort to increase awareness and
participation in such a worthy cause . Please feel free to contact me with any
suggestions or questions .
Amazed by His Grace,
k-
L4
D~Bishop Eddie Lon g
Senior Pastor
PO Box 1019, L:thonia GA 30058
770 696 9669 770.696 9681 fax
wsvw.nesnr6irth org
` / National Association For The Advancment Of Colored People
Henry County Branch
PO_ BOX 521 REX GA 30273
(404 ) 992-8834
It is no secret that the American youth have been influenced by material
Officers
things. Sometimes referred to as the "Hip-Hop" generation, youth often find a so-
President
a= Edwards Jr.
called sense of "self ' in Rap/Hip-Hop music . Often this sense of self can control
Vice President
Thomas ester
Secrets
inette stem
Treasurer
aruce t ester
the thought process and actions of its listeners . They feel in order to be accepted
or considered "down", they need to portray the actions displayed in rap songs .
However, youth have missed the true meaning of rap music . Many rappers today
are speaking of the life they used to live through their music . Somehow this
message becomes misconstrued and the listeners act out this music by joining
gangs, committing violent crimes, resorting to the sale and use of drugs, etc . It is
now time to implement a program where infamous rappers take time out of their
bus y schedules and spend time with their listeners . During the allotted time ,
rappers will engage in dialogue with their listeners to give them a better
understanding of rap music . During this time they will give a clear explanation of
what they really mean and display the ir value to society.
Just as America confronts conflicts that face us abroad, we must confront the
issues on the home front . Detention centers and prisons can no longer be the
answer for solving this growing epidemic. This program is a desperately needed
alternative .
Daniel L . Edwards III
TAB "D"
People making a difference
~ ~ National Association For The Advancment O f Colored People
Henry County Branch
~J
P,O
BOX
521
REX GA . 30273
(404) 992- 8834
The NAACP
Youth Development and Empowerment Tour
To Educate, Encourage & Empower
Officers
President
a~eT~ Edwards 7r.
Vice President
Thomas ester
Introduction
The NAACP Youth Development and Empowerment Tour will be a metro-wide youth
summit that will focus on reconnecting with youth to empower better leaders for the
sire future . The informative campaign will educate young adults on youth discipline, the
'°e" e acem cause & effects of perilous actions, the development and sustainability of strong and
Treasurer
am~ ester
vibrant communities, civil awareness, economic empowerment and other significant
social issues. The NAACP Youth Development and Empowerment Tour will in fact
educate, encourage and empower.
Objectives
The NAACP Youth Development and Empowerment Tour objective will be to
educate youth on how to make decisions on social aspects of their lives through :
Education Development
Community Involvement
Economic Development
Civic Consciousness
Financial development
Spiritual Enrichment
Commitment to Empowerment
How will we accomplish this?
The NAACP will solicit the support of rappers, ex-gang members, professional
athletes and other icons whom youth identify as role models. Clifford Harris Jr ., most
commonly known as `71" is actively involved in developing this effort . Youth will be
encouraged to follow positive messages that rebuild their communities . We will
develop leaders through this comprehensive campaign .
What will w e promote?
• Anti-Drug Progr a ms
Educate our youth on the affect the use and moreover the sale of drugs has on
their community . Educate the youth on the negative impact of chasing
luxurious homes, fancy cars and name brand clothing through sale of drugs .
Educate youth on the ramifications of participating in such illegal activity.
People making a difference
Anti-Gang Initiative
To educate our youth on the affect gang affiliation has on their likeliness to be
involved in a violent crime, thus leading to incarceration . According to the
Department of Justice :
On an average year, gang members committed about 373,000 violent
victimizations leading to incarceration .
About 12% of all aggravated assaults that occurred in recent years were
believed to be committed by gang-members, thus leading to incarceration .
5% - 7% of all homicides and 8% - 10% of homicides committed with a
firearm were gang related, thus leading to incarceration .
•
Anti-Violence Programs
To educate youth on the affect violent activity has on their commun ity from
domestic violence to intimate violence both which further tears at the lining of our
community. According to the Department of Justice
•
•
•
About 4 in 10 inmates serving time in jail for intimate violence had a
criminal justice status -- on probation or parole or under a restraining order
-- at the time of the violent attack on an intimate .
About 1 in 4 convicted violent offenders confined in local jails had
committed their crime against an intimate; about 7% of State prisoners
serving time for violence had an intimate victim .
About half of all offenders convicted of intimate violence and confined in
a local jail or a State prison had been drinking at the time of the offense .
Jail inmates who had been drinking prior to the intimate violence
consumed an average amount of ethanol equivalent to 10 beers.
About 8 in 10 inmates serving time in State prison for intimate violence
had injured or killed their victim
Anti-Alcoholism
Educate youth on the affect alcohol has on the thinking ability to make smart
decisions. According to the Department of Justice statistics :
Among the 5 .3 million convicted offenders in recent years, nearly 2
million, or about 36%, were estimated to have been drinking at the time of
the offense. The vast majority, about 1 .5 million, of these alcohol-involved
offenders were sentenced to supervision in the community : 1 .3 million on
probation and more than 200,000 on parole .
Alcohol use at the time of the offense was commonly found among those
convicted of public-order crimes, a type of offense most highly
represented among those on probation and in jail . Among violent
offenders, 41% of probationers, 41% of those in local jails, 38% of those
in State prisons, and 20% of those in Federal prisons were estimated to
have been drinking when they committed the crime .
Created by Peachtree Advertising Agency In c
Anti-Imprisonment
Inform youth of the negative impact imprisonment has on the household and
economic viability of their community. Imprisonment leads to the inability of
children to progress because of poor living conditions and therefore communities
go without potential leaders to help rebuild, revitalize and rehabilitate failing
communities . According to the Department of Justice, statistics indicate :
The prevalence of imprisonment in recent years was higher for
-- black males (16 .6%) and Hispanic males (7.7%) than for white males
(2.6%)
-- black females (1 .7%) and Hispanic females (0.7%) than white females
(0.3%)
•
•
•
If the conditions of our youth remain unchanged, an estimated I of every
15 (6 .6%) will serve time in a prison during their lifetime .
Lifetime chances of a person going to prison are higher for
-- men (11 .3%) than for women (1 .8%)
-- blacks (18.6%) and Hispanics (10%) than for
whites (3 .4%)
Based on current rates of first incarceration, an estimated 32% of black
males will enter State or Federal prison during their lifetime, compared to
17% of Hispanic males and 5 .9% of white males .
More than 6 in 10 persons in local jails in recent years were racial or
ethnic minorities, unchanged from previous statistics . An estimated 40%
were black; 19%, Hispanic, 1% American Indian; 1% Asian; and 3% of
more than one race/ethnicity .
Target Audience
The target audience of flue empowering campaign will be youth ranging in age from 12
to 19 who reside in Metro Atlanta. These youth will be targeted in public schools,
detention centers and community churches .
How will we attract the youth?
The NAACP Youth Development and Empowerment Tour will use the youth role models
of today such as Clifford Harris Jr . (TI) and other popular individuals from communities
such as music, entertainment and sports using their examples to exemplify the cause &
effect of gang, drug or violent activity . The fact is that youth listen to people that they
can relate to .
A uxili a ry Pro gram s
The NAACP Youth Development Youth Empowerment program will focus on current
additional issues of youth and develop outlets to reverse the downward spiral trend .
Created by Peachtree Advertising Agency Lrc
.,
Auxiliary programs will include :
•
•
•
•
Youth Debate Teams
o To influence and educate youth on how to deal
their communities and schools .
Youth Operated Newspaper
o To provide youth with an avenue to voice their
objectives of their communities and internal
effective solutions .
Youth Fashion Council
o To encourage youth to dress professionally and
trend of improper dress ethics .
with social issues in
opinions, concerns and
issues to come up with
to reroute the current
Youth STD Council
o To educate youth on the affects of STD's and their impact on the
community . Encourage abstinence from premature sex, unprotected
sex or hazardous sex patterns .
Venues and Loc ation s
The NAACP Youth Development and Empowerment Tour will take place in venues in
and surround the metro Atlanta area including DeKatb, Fulton, Gwinnett, Clayton, Cobb
and Henry counties . The NAACP Youth Development and Empowerment Tour will take
place in venues that can accommodate a few hundred to a few thousand youth .
Prospective venues include :
Public Schools
College Auditoriums
Community Centers
Georgia World Congress Center
Georgia International Convention Center
Cobb Galleria Center
Gwinnett Center
For more information:
Contact
Daniel Edwards Jr., President
Henry County NAACP Branch
404-992-8834
pastordan795 a;vahoo .cain
Created by Peacittree Ad%whstngAgency Inc
OFFICE OF THE
F
DISTRICT ATTORNEY
FLINT JUDICIAL CIRCUIT
SUPERIOR COURTS
1716
TOMMY K. FLOYD
D IST R IC T ATTORN E Y
HENRY COUNTY
OFF 77 0-954-2106
FAX. 770-954-2135
February 7, 2008
Rev. Daniel Edwards, Jr .
President, Henry County NAACP
P.O. Box 521
Rex, Georgia 30273
Dear Rev. Edwards :
I read with interest your letter entitled "The NAACP Youth Development and
Empowerment Tour To Educate, Encourage and Empower" .
I think this approach has the potential of being highly successful . My experience
has been that young people are greatly influenced by the athletes and artists of
the day . To have the artists you've described reach out to this impressionable
group cannot help but have a positive impact .
Therefore, I wholeheartedly endorse this proposal and will do whatever I can to
help with this worthy endeavor .
Sincerely,
om K . F'lo d
Distr ct Attorney
ns
HENRY COUNTY COURTHOUSE
One Courthouse Square 211 Floor - West Tower McDonough, Georgia 30253
Catch Me Before I Fall Initiative
I. Goal- I see as the overarching goal of the effort is to r educe t he
"cradle to pri son pipeline" disparities, particularly among African
American and Lafiina youth although it hits all vulnerable youth . This can
only be accomplished by ch anging attitudes across the board from you th to
parents to those who develop public policy. So how do we do that
incrementally?
2_ ftecfives. The overall objective is to change attitudes, but that is
too overwhelming to do unless you identify what supports changing attitudes.
So the objectives become :
(a) Good education (starting with K - 12): this also means improving the
eclucattional system;
(b) Improve health care (a healthy person is in a better place to pursue
dreams};
(c) Stop the violence all levels and everywhere_ (Period_ Enough said_) But
when it comes to public policy it also means improving the juvenile ju stice
system.. Stopping the violence is really linked to self r espect and
s biiity_ if c respec ts him or hersel f and others, they will no longer
violate others whether verbally or physically.
(d) Community activism/public service- It has become a trite phase, but
the African adage, "It takes a vil e," still holds true. And only by working
together in o ur various communities and neighborhoods can we really make
cam.
Tire objectives in bold ore the ones I suggest we focus on. It is best to
focus on one or two objectives, initially t o have greater pa . The key with
everything is focus.
3. Target Audiences -- W awareness car gee can touch everyone
directly, so who are the best people you and TI should target.
TAB •,E••
(a) Youth (our peers)
(b) Media
(c) Industry peers
(d) Community-based Organizers (focused on youth and topical issues (public
service, juvenile justice, violence, etc)
(e) Legislative/Public Policy Officials (Federal, statewide, local)
(f) National Civic/Social Organizations (focused on youth initiatives such as
NAACP ACT, etc .)
{g) Local activists
4. Target Cities
Los Angeles
Detroit
Atl
Philly
Baltimore
DC
Oakland
5. Key Messages
(all within the theme of avo iding Cradle to prison pipeline, catch me before I
fall, -etc ... Have no more than three key messages we want to deliver at all
times then repeat, repeat, repeat. The message we connect the dots about
how eac h one of us has a responsibility to make c hanges (inside and outside)
to stave off violence and improve our communities.
6. Strategy/Tactics
z see athree-pnr t strategy that includes the
1) community-based speaking engagements ,
2) using the media to broaden awareness of the issue
3) i nfluenci ng public policy by meeting w ith local legislators or their staff to
way in on the issues and pol ici es.
Strategy 1 : Create a 7-city awareness campaii g n.
As part of the 7-city tour, each stop should include a speaking engagement
to a junior or senior high school and community-based youth
center/organization and perhaps an affiliate to one national organizat ion
(i.e., perhaps the local campus NAACP members o f either a HBCU or large
college campus---in Atlanta there Morehouse and Spellman exist . ).
Rationale: By talking to high schools, we reach those still in school; the
community-based organization allows us to reach those who may have
dropped out; and by talking to a campus group of young people, you reach the
future leaders who will be developing the policies .
(a) Develop a campaign -type theme/message.
(b) Develop focused remarks or talk ing po ints. T.I. can focus on his personal
story and why he is now doing this using good examples . Hone three key
points we want to make that also can be linked to the object ives, media
i nterviews and public policy . The overriding focus may be arts as an outlet
and then connect it to stopping the violence , community activism, my
HIV/AIDS effort ... T.I, can discuss how he is now a nd why and perhaps
show others in his industry leveraging their status to make a difference .
Activism comes i n al l forms from speaking out to simply voting. It' s just
doing some for the greater good to help improve your life and the l ives of
others---sisters, brothers, etc . Have at least one handout---a message, a
thought, something the audience to refer to or hang on their wall as words
of wisdom and inspiration .
(c) Identify local sites . At least 3 h igh schools (am or afternoon
engagement); 3 community organizat ions (late afternoon talk) and 1 campus
(options[ ; late evening) to book one-hour speaking engagements . If you
commit one day per city or 1/2 day do h i gh afternoon and commun ity
organization early even i ng (6 pm) .
(d) Book time and date .
Strategy 2 : Build broad-based awareness through media outreach .
***Flo 's idea***Possibly do some local med ia. It may mean one local radio
show, one local community -based newspaper and perhaps a local TV station.
This allows you to get your message to the rest of the community who can ' t
attend the closed events . The purpose w ill not be to build a crowd at the
high school or community events , unless you do such .
The media is to start the message drumbeat.
Strategy 3 : Change public policies---meet with local public policy makers
This part of ce leb issue speaking is often overlooked . Only the most issuesavvy ones do it. But it's an important step to meet either with the local
state rep or his or her staff person to define the i ssue you ' re interested
'.
and one policy that you would like to see implemented or changed to help
change attitudes . This will take some research, but that is where you rely
on CDF or ANSA, etc ., to provide some generally info . It's not that they will
expect you to be experts on the issues, but it is to let them know what you
are passionate about . You won't have to know local details about the issue,
although that would be impressive, but many national issues start locally .
Issues include juvenile justice, support of the arts and why (its an outlet),
etc.
Another option is to meet with local civic or soc ial leaderships to voice your
stance on the issue.
Generally , these meetings are drop -by ' s last i ng no more than 15 to 20
minutes . They are not publicized .
Strategy 4 : Follow-up .
(a) Send thank you letters.
(b) Set up some mechanism to keep engaging the youth and delivering the
message: a blog or web site.
7. Timel ine
I suggest developing a 3-month plan, maybe starting with LA, if it's the
easiest to start right away .
January: Develop strategy and talking points ; identify sites; book
engagements , media & meetings.
February: Start tour to
cities.
March: Continue tour
PLEA
EXHIBIT NO .
4
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,
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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA
CRIMINAL ACTION
V.
NO . 1 :07-CR-344-CAP
Superseding
CLIFFORD J . HARRIS, JR .
ABA NDONM ENT OF PRO P ERTY FOR M
I, CLIFFORD J . HARRIS, JR ., voluntarily abandon all rights and
claim to the following property in order that appropriate
disposition may be made thereof by the Bureau of Alcohol, Tobacco,
Firearms, and Explosives (ATF) :
1 . One Colt, Model Carbine, 5 .56 mm caliber rifle, s/n LE033297,
with one magazine and ammunition ;
2 . One Bushmaster, Model Carbon 15, .223 mm caliber pistol, s/n
D07159, with a "Streamlight" tactical laser illuminator
attached, and with one CMAG dual-drum magazine and ammunition ;
3 . One Century International Arms, Model AK Pistol, 7 .62x39 mm
caliber pistol, s/n AKMP01683, with one drum magazine and
ammunition ;
4 . One Calico, Model Liberty III, 9 mm caliber pistol, s/n
B004397, with one magazine ;
5 . One Colt, Model Anaconda,
MM70228, with ammunition ;
.44 magnum caliber revolver, s/n
6 .
One DPMS, Panther Arms, Model LR-308,
14056, with one magazine ;
.308 caliber rifle, s/n
7 .
One Heckler and Koch, Model USP Compact, .40 caliber pistol,
s/n 25-088326, with one magazine and ammunition ;
8 .
.45 caliber
One Springfield Armory U .S .A ., Model XD-45ACP,
pistol, s/n US694153, with one magazine and ammunition ;
9 .
One Masterpiece Arms, Model 45 ACP,
.45 caliber pistol, s/n
I
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A4555, with one black-in-color silencer, and a magazine and
ammunition ;
10 . One Walther firearm magazine, loaded with
ammunition ;
.40 caliber
11 . One set of Point Blank camouflage body armor ;
12 . Various firearms magazines and boxes/assorted loose rounds of
ammunition of various type and caliber ;
13 .
One FN-5/7 pistol box, undetermined s/n ;
14 .
One Smith & Wesson, Model 500ES, firearm box, s/n DAJ7148 ;
15 .
One Heckler and Koch pistol box, s/n 25-111182 ;
16 .
One DPMS Panther, Model LR308 firearm box, s/n 14056 ;
17 .
One Heckler and Koch, Model P2000,
123039698 ; and,
18 .
One Taurus,
.357 revolver box, s/n ZI80533 .
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SIGNATURE (D e f ens e A ttorney)
V11RIS,
JR .
EDWARD T . M . GARLAND ~
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(Defense At torney )
SIGNATURE
(De f e nse A tto
ey)
DONALD F . SAMUEL
u se Attorney)
. THOMAS
S $GNi
DWI
FIGNATURE
( Defense Attoi
JANICE A . SINGER
Witnes ed by :
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SIGNAT
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(Assistant U S
TODD C . ALL E Y,
toraey)
A A
SIGNATURE
( A i t U S Attorney)
FRANCEY S, AUSA