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Indictment of Robert WomackThe Amador County Grand Jury was asked to review 21 charges against Robert Womack, and indicted him on 19 of those charges. The original documents are presented in the links above as GIF images. Alternately, the whole document can be downloaded as a multi-page TIF file. Note to readers: The misspelling of "futherance" is not mine--that is how it was written in the original document. IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF AMADOR
The Grand Jury of the County of Amador, State of California, accuses the Defendant(s) of committing, in the County of Amador, State of California, before the finding of this Indictment, the following crime(s): COUNT 1: CONSPIRACY TO COMMIT A CRIME, TO WIT: HAZARDOUS WASTE DISPOSAL, HAZARDOUS WASTE TRANSPORTATION, HAZARDOUS WASTE STORAGE AND/OR WATER POLLUTION, On or about April 30, 1998 and continuing until approximately November 11, 1998, the defendants, ROBERT ROLAND WOMACK, DAVID STERLING MASON III, MARK TAYLOR SHERRILL AND UNNAMED CO-CONSPIRATORS, did commit a FELONY, namely a violation of Section 182(a)(1) of the Penal code, CONSPIRACY TO COMMIT A CRIME, who at the time and place last aforesaid, did willfully and unlawfully conspire together and with another person and/or persons whose identity is unknown at this time to commit the crime(s) of HAZARDOUS WASTE DISPOSAL, HAZARDOUS WASTE TRANSPORTATION, HAZARDOUS WASTE STORAGE AND/OR WATER POLLUTION, violations of Chapter 6.5 of the California Health and Safety Code and of Section 5650(a)(1) of the Fish and Game Code. OVERT ACT NUMBER 1 On or about April 30, 1998 and continuing until May 8, 1998, ROBERT ROLAND WOMACK. DAVID STERLING MASON III, MARK TAYLOR SHERRILL, AND UN-NAMED CO-CONSPIRATORS, did participate in and/or allowed via tacit approval the demolition of a gasoline station at 505 Sutter Street, Jackson, California OVERT ACT NUMBER 2: On or about April 30, 1993 and continuing until approximately May 8, 1998, ROBERT ROLAND WOMACK, DAVID STERLING MASON III, MARK TAYLOR SHERRILL, AND UN-NAMED CO-CONSPIRATORS, failed to follow the explicit instructions of the City of Jackson Building Department personnel regarding their need to contact County of Amador Environmental Health regarding the underground storage tanks located at 505 Sutter Street, Jackson, California prior to removal. OVERT ACT NUMBER 3: On or about May 2, 1993 and continuing until approximately May 1993, ROBERT ROLAND WOMACK, DAVID STERLING MASON III MARK TAYLOR SHERRILL AND UN-NAMED CO-CONSPIRATORS transported, stored, and disposed of unknown quantities of hazardous wastes including but not limited to: two one thousand gallon gasoline underground storage tanks, unknown contents of the tanks, associated underground storage tank piping, and soil contaminated with gasoline and its toxic constituents from 505 Sutter Street, Jackson, California to unknown locations.OVERT ACT NUMBER 4 On or about May 4, 1998 and continuing until approximately November 11, 1998, ROBERT ROLAND WOMACK, MARK TAYLOR SHERRILL AND UN-NAMED CO-CONSPIRATORS provided false information to the Board of Supervisors of Amador County and to Amador County District Attorney Investigator Ron Hall related to the unlawful removal of a set of underground storage tanks from 505 Sutter Street, Jackson, California and associated piping/soil after ROBERT ROLAND WOMACK, MARK TAYLOR SHERRILL AND UN-NAMED CO-CONSPIRATORS attempted to dissuade witnesses from attending or giving testimony at any trial, proceeding, or inquiry authorized by law. OVERT ACT NUMBER 5: On or about September 2,1993, ROBERT ROLAND WOMACK, DAVID STERLING MASON III, MARK TAYLOR SHERRILL AND UN-NAMED CO-CONSPIRATORS jointly told inaccurate misleading and false information to the Amador County District Attorney's Office in the presence of District Attorney Investigators Ron Hall and Lance Hayden related to the unlawful removal of a set of underground storage tanks from 505 Sutter Street, Jackson, California. OVERT ACT NUMBER 6: On or about late June 1998 and continuing until a search warrant was executed on October 30, 1998, ROBERT ROLAND WOMACK, DAVID STERLING MASON III, MARK TAYLOR SHERRILL AND UN-NAMED CO-CONSPIRATORS, provided an altered videotape as evidence in this matter related to the unlawful removal of a set of underground storage tanks and associated piping/soil from 505 Sutter Street, Jackson, California, on May 2 and May 3, 1998 OVERT ACT NUMBER 7: On or about May 2, 1998, ROBERT ROLAND WOMACK, DAVID STERLING MASON III, MARK TAYLOR SHERRILL AND UN-NAMED CO-CONSPIRATORS pulled two one thousand-gallon gasoline underground storage tanks without appropriate permits and without appropriate oversight. OVERT ACT NUMBER 8: On or about May 2, 1998, ROBERT ROLAND WOMACK, DAVID STERLING MASON III, MARK TAYLOR SHERRILL AND UN-NAMED CO-CONSPIRATORS pulled two one thousand gallon gasoline underground storage tanks without appropriate permits. These activities were in violation of the Fire Code and placed the workers and the public and adjacent property owners at risk of an explosion. OVERT ACT NUMBER 9: On or about May 2, 1998, ROBERT ROLAND WOMACK, DAVID STERLING MASON III, MARK TAYLOR SHERRILL AND UN-NAMED CO-CONSPIRATORS pulled two one thousand gallon gasoline underground storage tanks without appropriate permits. These activities were in violation of the Water Code and the Fish and Game Code and placed adjacent waterways at risk of contamination with petroleum tainted water. COUNT 2: DISPOSAL OF HAZARDOUS WASTE On or about May 2, 1998, and continuing until the date of this indictment, the defendant(s), ROBERT ROLAND WOMACK, and MARK TAYLOR SHERRILL, did commit a FELONY, namely, a violation of Section 25189.5(b) of the Health and Safety Code, DISPOSAL OF HAZARDOUS WASTE, in that the said defendant(s) did knowingly and unlawfully dispose or cause the disposal of a hazardous waste, or reasonably should have known that he was disposing or causing the disposal of hazardous waste, including but not limited to: two one thousand gallon underground storage tanks, various waste piping, gasoline contaminated soil, and gasoline contaminated waste water at a facility or at numerous unknown facilities which did not have a permit from the Department of Toxic Substances Control issued pursuant to Chapter 6.5 of the Health and Safety Code, or at any point which is not authorized according to Chapter 6.5 of the Health and Safety Code. COUNT 3: TRANSPORTATION OF HAZARDOUS WASTE On or about May 2, 1998, the defendant(s), ROBERT ROLAND WOMACK, and MARK TAYLOR SHERRILL did commit a FELONY, namely, a violation of Section 25189.5(c) of the Health and Safety Code, TRANSPORTATION OF HAZARDOUS WASTE, in that the said defendant(s) did knowingly and unlawfully transport or cause the transportation of hazardous waste, or reasonably should have known that they were causing the transportation of a hazardous waste, these wastes included but were not limited to: two one thousand gallon gasoline underground storage tanks, unknown tank contents, associated underground storage tank piping, and/or gasoline contaminated soil originally from 505 Sutter Street Jackson, California to unknown locations. COUNT 4: TRANSPORTATION OF HAZARDOUS WASTE On or about May 3, 1998, the defendant(s), ROBERT ROLAND WOMACK, and MARK TAYLOR SHERRILL, did commit a FELONY, namely, a violation of Section 25189.5(c) of the Health and Safety Code, TRANSPORTATION OF HAZARDOUS WASTE, in that the said defendant(s) did knowingly and unlawfully transport or cause the transportation of hazardous waste, or reasonably should have known that they were causing the transportation of a hazardous waste, these wastes included but were not limited to: two one thousand gallon gasoline underground storage tanks, unknown tank contents, associated underground storage tank piping, and/or gasoline contaminated soil originally from 505 Sutter Street Jackson, California to unknown locations. COUNT 5: TRANSPORTATION OF HAZARDOUS WASTE On or about September 8, 1998, the defendant(s), ROBERT ROLAND WOMACK, AND, d id commit a FELONY, namely, Section 5189.5(c) or the Health an Safety Code, TRANSPORTATION OF HAZARDOUS WASTE, in that the said defendant(s) did knowingly and unlawfully transport or cause tile transportation of hazardous waste, or reasonably should have known that they were causing the transportation of a hazardous waste, these wastes included but were not limited to: two one thousand gallon gasoline underground storage tanks, unknown tank contents, associated underground storage tank piping, and/or gasoline contaminated soil originally from 505 Sutter Street Jackson, California to Jim Thorpe Oil, in Lodi, California. COUNT 6: TREATMENT OR STORAGE OF HAZARDOUS WASTE: On or about May 2, 1998, the defendant(s), ROBERT ROLAND WOMACK, AND MARK TAYLOR SHERRILL did commit a FELONY, namely, a violation of Section 25189.5(d) of the Health and Safety Code, TREATMENT OR STORAGE OF HAZARDOUS WASTE, in that the said defendant(s) did knowingly and unlawfully treat or store a hazardous waste or reasonably should have known that they were causing the treatment or storage of a hazardous waste, these wastes included but were not limited to: two one thousand gallon gasoline storage tanks, unknown tank contents, associated underground storage tank piping and/or gasoline contaminated soil at a facility which does not have a Permit, AT THE PROPERTY OF MARK TAYLOR SHERRILL LOCATED AT 14385 HWY. 88, JACKSON, CALIFORNIA, from the Department of Toxic Substances Control issued pursuant to Chapter 6.5 of the Health and Safety Code, or at any point which is not authorized according to Chapter 6.5 of the Health and Safety Code COUNT 7: TREATMENT OR STORAGE OF HAZARDOUS WASTE On or about May 3, 1998 through September 7, 1998, the defendant(s), ROBERT ROLAND WOMACK, AND MARK TAYLOR SHERRILL, did commit a FELONY, namely, a violation of Section 25189.5(d) of the Health and Safety Code, TREATMENT OR STORAGE OF HAZARDOUS WASTE, in that the said defendant(s) did knowingly and unlawfully treat or store a hazardous waste or reasonably should have known that they were causing the treatment or storage of a hazardous waste, these wastes included but were not limited to: two one thousand gallon gasoline underground storage tanks, unknown tank contents, associated underground storage tank piping, and/or gasoline contaminated soil at a facility which does not have a permit, AT UNKNOWN PROPERTIES LOCATED WITHIN CALIFORNIA, from the Department of Toxic Substances Control issued pursuant to Chapter 6.5 of the Health and Safety Code, or at any point which is not authorized according to Chapter 6.5 of the Health and Safety Code. COUNT 8: DISSUADING A WITNESS IN FUTHERANCE OF A CONSPIRACY During the first half of May 1998 the defendant, ROBERT ROLAND WOMACK, did commit a FELONY, namely, a violation of Section 136.1 (c)(2) of the Penal Code, DISSUADING A WITNESS IN FUTHERANCE OF A CONSPIRACY, in that the said defendant did knowingly and maliciously attempt to prevent or dissuade William A, Wolin and unknown other witnesses or victims from attending or giving testimony at any trial, proceeding, or inquiry authorized by law. COUNT 9: DISSUADING A WITNESS IN FUTHERANCE OF A CONSPIRACY During the first half of May 1998, the defendant, ROBERT ROLAND WOMACK, did commit a FELONY, namely, a violation of Section 136.1 (c)(2) of the Penal Code, DISSUADING A WITNESS IN FUTHERANCE OF A CONSPIRACY, in that the said defendant did knowingly and maliciously attempt to prevent or dissuade William A. Wolin and unknown other witnesses or victims from attending or giving testimony at any trial, proceeding, or inquiry authorized by law. COUNT 10: EAVESDROPPING ON OR RECORDING CONFIDENTIAL COMMUNICATION On or about September 2, 1998, the defendant, ROBERT ROLAND WOMACK, did commit a FELONY, namely, a violation of Section 632(a) of the Penal Code, EAVESDROPPING ON OR RECORDING CONFIDENTIAL COMMUNICATIONS, in that the said defendant did intentionally and without the consent of all parties to a confidential communication record the confidential communication in the presence of one another by means of a tape recorder. COUNT 11: WATER POLLUTION On or about May 2, 1998 through May 3, 1998, the defendant(s), ROBERT ROLAND WOMACK AND MARK SHERRILL did commit a MISDEMEANOR, namely, a violation of 5650(a)(1) of the Fish and Game Code, WATER POLLUTION, in that the said defendant(s) did unlawfully deposit in, permit to pass into, or place where it can pass into the waters of this state petroleum contaminated soli and petroleum contaminated wastewater. COUNT 12: DISSUADING A WITNESS IN FUTHERANCE OF A CONSPIRACY During July 1998, the defendant, MARK TAYLOR SHERRILL, did commit a FELONY, namely, a violation of Section 136.1 (c)(2) of the Penal Code, DISSUADING A WITNESS IN FUTHERANCE OF A CONSPIRACY, in that the said defendant did knowingly and maliciously attempt to prevent or dissuade NICK HERNANDEZ and unknown other witnesses or victims from attending or giving testimony at any trial, proceeding, or inquiry authorized by law. COUNT 13: DISSUADING A WITNESS IN FUTHERANCE OF A CONSPIRACY During late October or Early November 1998, the defendant, MARK TAYLOR SHERRILL, did commit a FELONY, namely, a violation of Section 136.1 (c)(2) of the Penal Code, DISSUADING A WITNESS IN FUTHERANCE OF A CONSPIRACY, in that the said defendant did knowingly and maliciously attempt to prevent or dissuade NICK HERNANDEZ and unknown other witnesses or victims from attending or giving testimony at any trial, proceeding, or inquiry authorized by law. COUNT 14: FAILURE TO SECURE PAYMENT OF COMPENSATION During May, 1998, the defendant, ROBERT ROLAND WOMACK, MANAGER OF KRL PARTNERSHIP, did commit a MISDEMEANOR, namely a violation of Section 3700.5 of the Labor Code, FAILURE TO SECURE PAYMENT OF COMPENSATION, in that the said defendant did knowingly fail to secure payment of compensation as required. COUNT 15: FRAUDULENT USE OF LICENSE NUMBER During May, 1998, the defendant, ROBERT ROLAND WOMACK, did commit a FELONY, namely, a violation of Section 7027.3 of the Business and Professions Code, FRAUDULENT USE OF A LICENSE NUMBER, in that the said defendant did willfully, intentionally and with intent to defraud, use a contractor's license which did not correspond to the number on a currently valid contractor's license held by the defendant. COUNT 16: CONTRACTING WITHOUT A LICENSE During May, 1998, the defendant, ROBERT ROLAND WOMACK, did commit a MISDEMEANOR, namely a violation of Section 7028(a) of the Business and Professions Code, CONTRACTING WITHOUT A LICENSE, in that the said defendant did unlawfully engage in the business of or acted in the capacity of a contractor without having a license. COUNT 17: PERJURY On or about January 16, 1998, the defendant, ROBERT ROLAND WOMACK, did commit a FELONY, namely a violation of Section 118 of the Penal Code, PERJURY, in that the said defendant certified under penalty of perjury, in a case in which such certification is permitted by law under penalty of perjury, to wit, on an Application for Original Registration, did state as true a material matter which he knew to be false, to wit: false personal information on the Application for Original Registration for a 1998 Lincoln Navigator, vehicle identification number XXXXXXXXXXXXXXXXX. COUNT 18: PERJURY On or about November 13, 1998, the defendant, ROBERT ROLAND WOMACK, did commit a FELONY, namely a violation of Section 118 of the Penal Code, PERJURY, in that the said defendant certified under penalty of perjury, in a case in which such certification is permitted by law under penalty of perjury, to wit, on an Application for Original Registration, did state as true a material matter which he knew to be false, to wit: signed under the penalty of perjury an application form from the California Department of Motor Vehicles a document that listed in the missing title statement a claim that the original title had been lost or stolen for a 1934 Ford, license number XXXXXXX, vehicle identification number XXXXXXXX. COUNT 19: PERJURY On or about November 13,1998, the defendant, ROBERT ROLAND WOMACK, did commit a FELONY, namely a violation of Section 118 of the Penal Code, PERJURY, in that the said defendant certified under penalty of perjury, in a case in which such certification is permitted by law under penalty of perjury, to wit, on an Application for Duplicate Title, did state as true a material matter, which he knew to be false, to wit: signed under the penalty of perjury an application form from the California Department of Motor Vehicles a document that listed in the missing title statement a claim that the original title had been lost or stolen for a 1957 Ford, license number XXX XXXX, vehicle identification number XXXXXXXXXX. COUNT 20: PERJURY On or about November 13,1998, the defendant, ROBERT ROLAND WOMACK, did commit a FELONY, namely a violation of Section 1 IS of the Penal Code, PERJURY, in that the said defendant certified under penalty of perjury, in a case in which such certification is permitted by law under penalty of perjury, to wit: on an Application for Duplicate Title, did state as true a material matter which he knew to be false, to wit: signed under the penalty of perjury an application form from the California Department of Motor Vehicles a document that listed in the missing title statement a claim that the original title had been lost or stolen for a 1972 Chevrolet, license number XXX XXX, vehicle identification number XXXXXXXXXXXXX. COUNT 21. PERJURY On or about November 13, 1998, the defendant, ROBERT ROLAND WOMACK, did commit a FELONY, namely a violation of Section 118 of the Penal Code, PERJURY, in that the said defendant certified tinder penalty of perjury, in a case in which such certification is permitted by law under penalty of perjury, to wit: on an Application for Duplicate Title, did state as true a material matter which he knew to be false, to wit: signed under the penalty of perjury an application form from the California Department of Motor Vehicles a document that listed in the missing title statement a claim. that the original title had been lost or stolen for a 1991 Yamaha motorcycle, license number XXXXXXX vehicle identification number XXXXXXXXXXXXXXXXX.
Date: 12-1-98 |
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