Information - Circuit court
Original complaint - Court
Bindover/Transler = Ceulvduvenie court
‘Complaint copy - Prosecutor
Approved, SCAO Warrant Court (Complaint copy - Defendanvatorney
‘STATE OF MICHIGAN “AMENDED CASENO.
564, JUDICIAL DISTRICT fA
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‘STATE OF MICHIGAN, COUNTY OF EATON
‘The complaining witness says that on the date and at the location described, the defendant, contrary to law,
COUNT I: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
On of about 2010-2013, John Geddert did knowingly subject or attempt to subject another person, BA to forced labor or services by
causing or threatening to cause physical harm to another person and it caused another person injury contrary to MCL 750.462
(750.4628)
FELONY: 15 years and/or $15,000.00.
COUNT 2; HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY.
On or about 2008-2013, John Geddert did knowingly subject or attempt to subject another person, MT to forced labor or services by
‘causing or threatening to cause physical harm to another person and it caused another person injury contrary to MCL 750.462
(750.462B]
FELONY: 15 years and/or $15,000.00.
COUNT 3: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY.
On or about 2008-2013, John Geddert did knowingly subject or attempt to subject another person, BPH to forced labor or services by
causing or threatening to cause physical harm to another person and it caused another person injury contrary to MCL 750.462
[750.4628]
FELONY: 15 years and/or $15,000.00.
COUNT 4: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
On or about October 15, 2013, John Geslert did knowingly subject or attempt to subject another persony Mi.to forced labor or services
by causing or threatening to cause physical harm to another person and it caused another person injury gontrary to MCL. 750.462
(750.4628) Aine,
FELONY: 15 years and/or $15,000.00,
FEB 25,
The complaining witness asks that defendant be apprehended and dealt wth according to law.
by.
| declare under he penalies of peru tat this complaint has
been examined by me and that fe contents are vue tothe best
of my information, knowledge, and belle,
Warrant authorized on
d-asaval
Ciseeurity for costs posted
Date
Mc 200 (12/19) FELONY SET, Complaint MCL 784.1 ot seq, MCL 786.1 ef seq, MCL 767.1 ef seq, MCR 6.110COUNT 5: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
On or about 2008-2009, John Geddert did knowingly subject or attempt to subject another person, AC to forced
labor or services by causing or threatening to cause physical harm to another person and it caused another
person injury contrary to MCL 750.462b [750.4626]
FELONY: 15 years andior $15,000.00.
COUNT 6: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
On or about 2008-2012, John Geddert did knowingly subject or attempt to subject another person, IH to forced
labor or services by causing or threatening to cause physical harm to another person and it caused another
person injury contrary to MCL. 750.462b [750.4628]
FELONY: 15 years and/or $15,000.00.
COUNT 7: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
On or about 2010-2013, John Geddert did knowingly subject or attempt to subject another person, CW to
forced labor or services by causing or threatening to cause physical harm to another person and it caused
another person injury contrary to MCL 750.462b [750.4628]
FELONY: 15 years and/or $15,000.00.
COUNT 8: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
On or about 2012-2016, John Geddert did knowingly subject or attempt to subject another person, LS to forced
labor or services by causing or threatening to cause physical harm to another person and it caused another
person injury contrary to MCL 750.462b [750.4628]
FELONY: 15 years andlor $15,000.00,
COUNT 9: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
‘On or about 2008-2012, John Geddert did knowingly subject or attempt to subject another person, BL to forced
labor or services by causing or threatening to cause physical hatm to another person and it caused another
person injury contrary to MCL 750.462b [750.4628]
FELONY: 15 years and/or $15,000.00,
COUNT 10: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
On or about 2008, John Geddert did knowingly subject or attempt to subject another person, TM to forced
labor or services by causing or threatening to cause physical harm to another person and it caused another
person injury contrary to MCL 750.462b (750.4628)
FELONY: 15 years and/or $15,000.00.
COUNT 41: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
On or about 2009-2011, John Geddert did knowingly subject or attempt to subject another person, EF to forced
labor or services by causing or threatening to cause physical harm to another person and it caused another
person injury contrary to MCL 750.462b [750.4628]
FELONY: 15 years and/or $15,000.00.
COUNT 12: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
On or about 2008, John Geddert did knowingly subject or attempt to subject another person, KC to forced labor
or services by causing or threatening to cause physical harm to another person and it caused another person
injury contrary to MCL 750.462b [750.462]
FELONY: 16 years and/or $15,000.00COUNT 43: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
On or about 2010-2011, John Geddert did knowingly subject or attempt to subject another person, KC to forced
labor or services by causing or threatening to cause physical harm to another person and it caused another
person injury contrary to MCL 750.462b [750.4628]
FELONY: 15 years and/or $15,000.00.
COUNT 14: HUMAN TRAFFICKING - FORCED LABOR RESULTING IN INJURY
On or about 2008-2013, John Geddert did knowingly subject or attempt to subject another person, LL to forced
labor or services by causing or threatening to cause physical harm to another person and it caused another
person injury contrary to MCL 750.462b [750.4628]
FELONY: 15 years and/or $15,000.00.
COUNT 15: HUMAN TRAFFICKING OF A MINOR FOR FORCED LABOR
On or about 2015, John Geddert did knowingly recruit, entice, harbor, transport, provide or obtain KG, a minor,
for forced labor or services; contrary to MCL 750.462e(b). [750.462E8]
FELONY: 20 years and/or $20,000.00, MCL 750.462f(2). A consecutive sentence may be ordered for the
commission of any other crime, including another violation of law arising out of the same transaction. MCL
750.462{(5). Court may order reimbursement to any other governmental agency for expenses. MCL.
750.462f(6); MCL 7681f.
COUNT 46: HUMAN TRAFFICKING OF A MINOR FOR FORCED LABOR
On or about 2015-2018, John Geddert did knowingly recruit, entice, harbor, transport, provide or obtain RL, a
minor, for forced labor or services; contrary to MCL 750.462e(b). [750.462E8]
FELONY: 20 years and/or $20,000.00, MCL 750.462f(2). A consecutive sentence may be ordered for the
commission of any other crime, including another violation of law arising out of the same transaction. MCL
750.462{(5). Court may order reimbursement to any other governmental agency for expenses. MCL
750.462{(6); MCL 7691f.
COUNT 17: HUMAN TRAFFICKING OF A MINOR FOR FORCED LABOR
On or about 2015-2018, John Geddert did knowingly recruit, entice, harbor, transport, provide or obtain AD, a
minor, for forced labor or services; contrary to MCL 750.462e(b). [750.462EB)
FELONY: 20 years and/or $20,000.00, MCL 750.462{(2). A consecutive sentence may be ordered for the
commission of any other crime, including another violation of law arising out of the same transaction. MCL
750,462{(5). Court may order reimbursement to any other governmental agency for expenses. MCL
750.4621(6); MCL 7691f.
COUNT 18: HUMAN TRAFFICKING OF A MINOR FOR FORCED LABOR
On or about 2016, John Geddert did knowingly recruit, entice, harbor, transport, provide or obtain MM, a minor,
for forced labor or services; contrary to MCL 750.462e(b). [750.462EB]
FELONY: 20 years and/or $20,000.00, MCL 750.462f(2). A consecutive sentence may be ordered for the
commission of any other crime, including another violation of law arising out of the same transaction. MCL
750.462((5). Court may order reimbursement to any other governmental agency for expenses. MCL
750.462f(6); MCL 7691f.COUNT 19: HUMAN TRAFFICKING OF A MINOR FOR FORCED LABOR
On or about 2015, John Geddert did knowingly recruit, entice, harbor, transport, provide or obtain SL, a minor,
for forced labor or services; contrary to MCL. 750.462e(b). [750.462E8]
FELONY: 20 years and/or $20,000.00, MCL 750.462{(2). A consecutive sentence may be ordered for the
commission of any other crime, including another violation of law arising out of the same transaction. MCL.
750.462{(5). Court may order reimbursement to any other governmental agency for expenses. MCL
750.4624(6); MCL 7691f.
COUNT 20: HUMAN TRAFFICKING OF A MINOR FOR FORCED LABOR
On or about 2015-2016, John Geddert did knowingly recruit, entice, harbor, transport, provide or obtain CP, a
minor, for forced labor or services; contrary to MCL 750.462e(b). [750.462E8]
FELONY: 20 years and/or $20,000.00, MCL 750.462{(2). A consecutive sentence may be ordered for the
commission of any other crime, including another violation of law arising out of the same transaction. MCL
750.462{(5). Court may order reimbursement to any other governmental agency for expenses. MCL
750.462{(6); MCL 7691.
COUNT 21: CRIMINAL ENTERPRISES - RACKETEERING PROCEEDS
being a person who knowingly received proceeds directly or indirectly from a pattern of racketeering activity,
consisting of two or more of the following incidents of racketeering, to wit
‘on of about April 1, 2011 to January, 2018, in 9410 Davis Highway, Dimondale, MI 48821, defendant did
commit the following offense for financial gain, to wit: Human Trafficking MCL 750.462b (BA, MK, BPH, MJ, IH,
CW, LS, BL, LL, KG, RL, AD, MM, SL, or CP);
which had the same or a substantially similar method of commission, and which amount to or posed a
threat of continued criminal activity, did directly or indirectly use or invest any of those proceeds, or proceeds
derived from the use or investment of those proceeds, in the establishment or operation of an enterprise, to wit:
Twistars, USA; contrary to MCL 750.159i(3).. [750.15913]
FELONY: 20 Years and/or $100,000.00; criminal forfeiture of proceeds, substituted proceeds, and
instrumentalities of racketeering listed on attached notification (see MCL 750.159)(4)); court may order court
costs, costs of investigation, and/or costs of prosecution
COUNT 22: CRIMINAL SEXUAL CONDUCT - FIRST DEGREE (Multiple Variables)
On or about January 2012, John Geddert did engage in sexual penetration, to-wit: finger in genital opening,
with AM, under the following circumstances), the victim was at least 13 but less than 16 years of age and
defendant coerced the victim to submit by exerting his/her authoritative position and/or defendant effected
sexual penetration through force or coercion and the victim sustained personal injury, contrary to MCL
750.520b. _{750.520B]
SORA NOTICE
This is a Tier Ill Offense under the Sex Offender Registration Act (SORA) unless the court finds that the
victim was between the ages of 13 to 15 inclusive, consented to the conduct, and the defendant was not more
than 4 years older than the victim. MCL 28.722(w)(iv)
HIVISTD TESTING NOTICE
Take notice that pursuant to MCL. 333.5129, upon bindover to circuit court or recorder’s court, the district
court judge shall order the defendant to be tested for sexually transmitted infection, hepatitis B infection, and for
the presence of HIV or an antibody to HIV if the judge determines there is reason to believe the violation
involved sexual penetration or exposure to a body fluid of the defendant. If the district judge determines that
testing is not required, upon conviction, the court must order the defendant to be tested.
FELONY: Life; mandatory lifetime electronic monitoring; mandatory AIDS/STD testing; DNA to be taken upon
arrest. The Court may impose a consecutive sentence under MCL 750.520b(3)COUNT 23: CRIMINAL SEXUAL CONDUCT - SECOND DEGREE (Multiple Variables)
On or about January 2012, John Geddert did engage in sexual contact with AM, under the following
circumstance(s), the victim was at least 13 but less than 16 years of age and defendant coerced the victim to
‘submit by exerting his/her authoritative position and/or defendant effected sexual penetration through force or
coercion and the victim sustained personal injury; contrary to MCL 750.520c. [750.520C]
SORA NOTICE
This is a Tier Il Offense under the Sex Offender Registration Act (SORA) if the victim is 13 or older. MCL
28.722(u)(i) & (x). Is a Tier Ill Offense if victim is under 13. MCL 28.722(w)(v). Itis a Tier Ill Offense if the
defendant has a prior conviction for a Tier Il Offense. MCL 28.722(u) & (v).
HIVISTD TESTING NOTICE
Take notice that pursuant to MCL 333.5129, upon bindover to circuit court or recorder's court, the district
court judge shall order the defendant to be tested for sexually transmitted infection, hepatitis B infection, and for
the presence of HIV or an antibody to HIV if the judge determines there is reason to believe the violation
involved sexual penetration or exposure to a body fiuid of the defendant. If the district judge determines that
testing is not required, upon conviction, the court must order the defendant to be tested.
FELONY: 15 years; mandatory AIDS/STD testing; DNA to be taken upon arrest.
COUNT 24: LYING TO A PEACE OFFICER - VIOLENT CRIME INVESTIGATION
‘On or about September 27, 2016, John Geddert after being informed by Sam Miller MSUPD that the officer was
conducting a criminal investigation, did knowingly and wilfully make a statement or statements to the officer
that he or she knew was false or misleading regarding the following material fact or facts relating to the
investigation, Nassar had a limited role at Twistars as the team physician or since 1996 and has never heard
anyone complain about Nassar's treatments or he was not aware of any of his athletes receiving any kind of
Intervaginal treatments while at the Twistars facility or males are not allowed in the female locker room., and
the officer was conducting a criminal investigation for 750.520b; contrary to MCL 750.479¢(2)(d).
[750.479C2D]
FELONY: 4 years and/or $5,000.00
Court shall order law enforcement to collect a DNA identification profiling sample before sentencing or
disposition, if not taken at arrest.