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II II II II II II

DISTRICT COURT OF MARYLAND FOR Montgomery County


Located at 191 East Jefferson St, Rockville, Maryland 20850 Case No. 1000392372
STATE OF MARYLAND VS. SMITH, WILL DANIEL
23455 ARORA HILLS DRIVE
CLARKSBURG, MD 20871-0000

CC#: 180054805 Tracking No: 181001947254


Phone(H): Phone(W):
Charge I Statute I Arrest Charge I Statute I Arrest
RAPE FIRST DEGREE I CR 3 303 RAPE FIRST DEGREE I CR 3 303 I
ATT 1ST DEG RAPE CR 3 309 I ATT 1ST DEG RAPE I CR 3 309 I
CON-RAPE FIRST DEGREE I CL I CON-RAPE FIRST DEGREE I CL

Date: 11/21/2018
ARREST WARRANT II II
Warrant Control No, D180722754
STATE OF MARYLAND, Montgomery County
TO ANY PEACE OFFICER:
An Order of the Court was entered on 11/21/2018, ordering the arrest of SMITH, WILL DANIEL to be brought
before this Court for an Initial Appearance.
YOU ARE ORDERED to immediately arrest the above named person who resides or may be located at:
23455 ARORA HILLS DRIVE, CLARKSBURG, MD 20871.
IF THE DEFENDANT IS NOT IN CUSTODY FOR ANOTHER OFFENSE,
Initial appearance is to be held in county in which Warrant was issued.
YOU ARE FURTHER DIRECTED:
to immediately take this person before a judicial officer of the District Court; or if the Warrant so specifies,
before a judicial officer of the circuit court. An appearance by,video satisfies the requirements of this directive.
IF THE DEFENDANT IS IN CUSTODY FOR ANOTHER OFFENSE, this Warrant is to be lodged as a
detainer for the continued detention of the Defendant for the offense charged in the charging document. When the
Defendant is served with a copy of the charging document arld Warrant, the Defendant shall be taken before a
j udicial officer of the District Court; or if the Warrant so specifies, before a jusiLcitileeRAthe Circuit Court.

Date: 11/21/2018 Time:12:55 AM COMMISSIONER 6637 ID: 6637


Judge/Commissioner/Clerk Of the CircuitiCourt
DESCRIPTION: Driver's License # Race: 1 Sex: M Ht: 54" Wt: 143 Hair: BLK Eyes:
DOB: 07/02/2003 SID # SSN

Complexion Tattoos, Marks, Scars Other


Given to Law Enforcement Agency: MCPD HEADQUARTERS
RETURN OF SERVICE
LI I certify that at M on at
TIME DATE
, I executed this Arrest Warrant by arresting the person named above
PLACE
and delivered a copy of the Arrest Warrant to him/her.
El I left a copy of the Warrant and Charging Document as a detainer for the continued detention of the person named
above at:
Detention Facility

Address

Signature of Peace Officer Title Agency Sub-Agency ID Number


CC-DC-CR-142A (02/2017)
II II II III
DISTRICT COURT OF MARYLAND FOR Montgomery County
Located at 191 East Jefferson St, Rockville, Maryland 20850 Case No. 1D00392372
STATE OF MARYLAND VS. SMITH, WILL DANIEL
23455 ARORA HILLS DRIVE
COMPLAINANT:
CLARKSBURG, MD 20871
Officer: DET WILLIAMS
Agency/Subagency: MCP HQ15 CC#: 180054805 SID:
Officer ID: 2384 LID: DL#:
Race: 1 Sex: M Ht: 5' 4" Wt: 143 Hair: BLK Eyes:
DOB: 07/02/2003 Phone(H): Phone(W):

STATEMENT OF CHARGES
UPON THE FACTS CONTAINED IN THE APPLICATION OF Officer: DET WILLIAMS IT IS FORMALLY
CHARGED THAT SMITH, WILL DANIEL at the dates, times and locations specified below:
NUM CHG/CIT STATUTE PENALTY DESCRIPTION OF THE CHARGE

001 11102 CR 3 303 0L RAPE FIRST DEGREE


On or About 10/31/2018
25921 RIDGE ROAD, DAMASCUS, MONTGOMERY
COUNTY MD
...did unlawfully commit a rape in the first degree upon VICTIM B, in violation of
CR 3-303 of the Annotated Code of Maryland.
Against the Peace, Government, and Dignity of the State.
002 1 1102 CR 3 303 0L RAPE FIRST DEGREE
On or About 10/31/2018
25921 RIDGE ROAD, DAMASCUS, MONTGOMERY
COUNTY MD
...did unlawfully commit a rape in the first degree upon VICTIM C, in violation of
CR 3-303 of the Annotated Code of Maryland.
Against the Peace, Government, and Dignity of the State.
003 2 1120 CR 3 309 0L AU 1ST DEG RAPE
On or About 10/31/2018
25921 RIDGE ROAD, DAMASCUS, MONTGOMERY
COUNTY MD
did unlawfully attempt to commit a rape in the first degree upon VICTIM A, in
violation of CR 3-309 of the Annotated Code of Maryland.
Against the Peace, Government, and Dignity of the State.
004 2 1120 CR 3 309 0L AU 1ST DEG RAPE
On or About 10/31/2018
25921 RIDGE ROAD, DAMASCUS, MONTGOMERY
COUNTY MD
did unlawfully attempt to commit a rape in the first degree upon VICTIM D, in
violation of CR 3-309 of the Annotated Code of Maryland.
Against the Peace, Government, and Dignity of the State.
005 1C1102 CL 0L CON-RAPE FIRST DEGREE
On or About 10/31/2018
25921 RIDGE ROAD, DAMASCUS, MONTGOMERY
COUNTY MD
did conspire with CALEB THORPE, KRISTIAN "KJ" JAMAL LEE, JEAN
CLAUDE "JC" ABEDI to unlawfully commit a rape in the first degree upon
VICTIM B, in violation of CR 3-303 of the Annotated Code of Maryland.
Against the Peace, Government, and Dignity of the State.
006 1C1102 CL 0L CON-RAPE FIRST DEGREE
On or About 10/31/2018
25921 RIDGE ROAD, DAMASCUS, MONTGOMERY
COUNTY MD
did conspire with CALEB THORPE, KRISTIAN "KJ" JAMAL LEE, JEACN
CLAUDE "JC" ABEDI to unlawfully commit a rape in the first degree upon
VICTIM C, in violation of CR 3-303 of the Annotated Code of Maryland.

Date: 11/21/2018 Time: 12:55 AM Judicial Officer: 663'7


Tracking No. 181001947254
CONTINUATION PAGE 1 OF STATEMENT OF CHARGES

DISTRICT COURT OF MARYLAND FOR Montgomery County


Located at 191 East Jefferson St, Rockville, Maryland 20850 Case No. 1D00392372
STATE OF MARYLAND VS. SMITH, WILL DANIEL

Against the Peace, Government, and Dignity of the State.

Date: 11/21/2018 Time: 12:55 AM Judicial Officer: 6631


Tracking No. 181001947254
DISTRICT COURT OF MARYLAND FOR Montgomery (City/Comity)
LOCATED AT (COURT ADDRESS)
RELATED CASES:
DC Case: 1D00392372
191 East Jefferson Street
Rockville, MD 20850
Ull 1111
COMPLAINANT
Detective Williams Will Daniel Smith
Printed Name Printed Name
7300 Calhoun Place, Suite 300 23455 Arora Hills Drive
Address Address
Rockville, MD, 20855 240-773-5400 Clarksburg, MD 20871 Unknown
City, State, 21p Telephone City, state, Zi Telephone
MCPD, SVID, 2384 CC# 180054805
Agency, sub-agency, and RD. # (Officer Only)

DEFENDANT'S DESCRIPTION: Driver's License # None Sex. M Race B lit. 5'04 wt. 143_
Hair Blk Eyes link Complexion Dark Other None DOB 07/02/2003 ID

above named Defendant because on or about 10/31/2018 at 25921 Ridge Road, Montgomery County,
Date Place
Damascus, Maryland 20872 , the above named Defendant
SEE CONTINUATION
(Concise statement of facts sFowing that there is probable cause to believe that a crime has been committed and that he Defendant has committed it):

(Continued on attached 5 pages) (DC-CR-001A)


I solemnly affirm under the penalties of perjury that the contents of this Applic tion are tie to the best of my knowledge,
information, and belief.
ta
i t:2°— ig ce s Signature

(A) Prmte N ame

I have read or had read to me and I understand the Notice on the back of this form.

Date Applicant's Signature

Printed Name

Subscribed and sworn to before me this _at day of _


Time: 19 sa AMJ PM Judge/Commissioner
- A:1140
I understand that a charging document will be issued and that I must appear for .61.p.,,
on _CraviismoNERK
at
Time
, D when notified by the Clerk, at the court location shown at the top of this form.
Applicant's Signature

Applicant requests reasonable protection for safety of the alleged victim or the victim's family_
(Describe)

[1] I have advised applicant of shielding right. El Applicant declines shielding.


El I declined to issue a charging document because of lack of probable cause.
---------- ----- Date CominisiZer

Printed Name

[ Trit 181001947254
DC-CR-001 (Rev. 10/2017)
DISTRICT COURT OF MARYLAND FOR Montgomery
(City/County)
LOCATED AT (COURT ADDRESS)

191 East Jefferson Street


Rockville, MD 20850 DC Case: 1D00392372

DEFENDANTS NAME (LAST, FIRST, MI.)


Smith, Will Daniel

APPLICATION FOR STATEMENT OF CHARGES (CONTINUED) Page . 2_ of co_


On November 01, 2018, the Montgomery County Police Special Victims Investigations Division was notified of a sexual assault
allegation at Damascus High School located at 25921 Ridge Road, Damascus, Montgomery County, Maryland 20872 involving the
Junior Varsity football team.

The Damascus High School principal reported an assault involving a broom.

The school identified four juvenile victims: Victim A, Victim B, Victim C, and Victim D/Suspect D who is not being identified
because he is a juvenile and is not being charged as an adult. Victim A, Victim B, Victim C, and Victim D/Suspect D are known to
your affiant and referred to as such for the remainder of this application.

The school identified possible suspects Will Daniel Smith (DOB: 07/02/2003), Kristian "KJ" Jamal Lee (DOB: 09/16/2003), and
Jean Claude "JC" Abedi (DOB: 06/25/2003).

On November 01, 2018 Victim B (who was the first person assaulted but was the second person interviewed) was interviewed at the
Special Victims Investigations Division in Rockville, Montgomery County, Maryland.

Victim B disclosed that on October 31, 2018 at approximately 1430 hours., he was inside the Freshman locker room at Damascus
High School getting ready for football practice.

Victim B further stated that unknown subject(s) turned off the lights to the locker room. Victim B stated that two of his teammates:
Jean Claude "JC" Abedi and Kristian "KJ" Jamal Lee approached him holding a broom with tan bristles and a wooden handle.

JC Abedi and KJ Lee grabbed Victim B by his shoulders and threw him onto the floor. Victim B further reported that one of them
held his feet down. Victim B disclosed that while he was face down on the ground, either JC Abedi or KJ Lee pulled Victim B's
pants down to his knees and proceeded to poke his buttocks with the wooden broomstick.

Victim B stated that his plaid boxer shorts were still on his body and the broomstick was inserted into his anus a few inches. Victim
B stated that it hurt, and he knew that the broomstick went into his anus. Victim B stated JC Abedi and KJ Lee were both laughing,
and Victim B was shouting "let me go". Victim B stated that JC Abedi and KJ Lee removed the broomstick and got off him. JC
Abedi and KJ Lee then proceeded to do the same thing to other male members on the Junior Varsity football team.

On November 01, 2018, Victim C (who was the second person assaulted but was the third person interviewed) was interviewed at the
Special Victims Investigations Division in Rockville, Montgomery County, Maryland.

Victim C disclosed that on October 31, 2018 at approximately 1450— 1500 hours, he was inside the Freshman locker room at
Damascus High School getting ready for football practice. Victim C stated that he observed JC Abedi, KJ Lee, and Will Smith pull
down Victim B's pants and insert a broomstick into his buttocks.

i
Date
Z. Applicant's Signature

Printed Name

Tr.# 181001947254
DC-CR-001A (Rev. 04/2015)
DISTRICT COURT OF MARYLAND FOR Montgomery
(City/County)
LOCATED AT (COURT ADDRESS)

191 East Jefferson Street

Rockville, MD 20850 DC Case 1D00392372

DEFENDANTS NAME (LAST, FIRST, MI.)


Smith, Will Daniel

APPLICATION FOR STATEMENT OF CHARGES (CONTINUED) Page _3 of (p

Victim C stated that someone in the locker room stated that it would be good to do it to Victim C and JC Abedi, KJ Lee, and Will
Smith held Victim C face down on a bench in the locker room and pulled down his uniform practice pants and blue boxer shorts.
Victim C stated that someone put the broomstick between his buttocks and "stabbed" his buttocks several times with the tip of the
broomstick. Victim C stated that he did not think the broomstick penetrated his anus, but that they "stabbed" his buttocks several
times. Victim C described the broomstick as a wooden handle with a "cut on the tip of it". Victim C stated that he told JC Abedi, KJ
Lee, and Will Smith to stop and they replied that it was a "tradition". Victim C reported that this occurred for approximately ten
seconds until they proceeded to do the same thing to another member of the Junior Varsity football team.

Victim C stated that after they finished with him, they proceeded to Victim A where they pulled Victim A's hooded sweatshirt over
top of his head, punched him in the face, knocked him on his back, and stomped on him.

Victim C further stated that JC Abedi, KY Lee, and Will Smith attempted to assault Victim D with the broomstick, but Victim D was
struggling too much.

On November 01, 2018, Victim D/Suspect D, who is not being identified because he is a juvenile and is not being charged as an
adult, was read the Advice of Rights form and a custodial interview was conducted at the Special Victims Investigations Division in
Rockville, Montgomery County, Maryland.

Victim D/Suspect D stated that on October 31, 2018 around 1445 - 1450 hours, he was in the Freshman locker room when someone
turned off the lights. Victim D/Suspect D stated that a bunch of people "took him down" after the lights went out. Victim D/Suspect
D further stated that he heard Victim B screaming and observed JC Abedi, Suspect E, Caleb Thorpe, KJ Lee, and Will Smith around
and over top of Victim B. Victim D/Suspect D stated that Victim A stood up a few minutes later and that he "got the broom".

Victim D/Suspect D further reported that Victim C was the next person to "get the broom" after they pulled his pants down.

Victim D/Suspect D then reported that IC Abedi stated that it was his turn and they all rushed to Victim D/Suspect D who fought
them off him. Victim D/Suspect D further stated that JC Abedi began to stomp him while Suspect E had the broom and was trying to
poke Victim D/Suspect D with the broomstick on his football girdle and practice pants. Suspect D stated that someone yelled "coach
is coming!" and everyone ran away.

Victim D/Suspect D then reported that he observed JC Abedi attempting to assault Victim A with the broomstick. Victim D/Suspect
D first reported that he went to assist Victim A but then stated that he was messing around and Suspect D was trying to push the
broomstick into Victim A's buttocks "a little bit".

On November 01, 2018, Victim A (who was the last person assaulted but was the first person interviewed) was interviewed at the
Special Victims Investigations Division in Rockville, Montgomery County, Maryland.

,Arlicant's signature—

IL/1)(1
L Printed Name

Tr.# 181001947254

DC-CR-001A (Rev. 04/2015)


DISTRICT COURT OF MARYLAND FOR Montgomery
(City/County)
LOCATED AT (COURT ADDRESS) DC Case • 1000392372
191 East Jefferson Street
Rockville, MD 20850

DEFENDANTS NAME (LAST, FIRST, MI.)


Smith, Will Daniel

APPLICATION FOR STATEMENT OF CHARGES (CONTINUED) Page I-1 of Li)

Victim A disclosed that on October 31, 2018 at approximately 1530 hours., he was standing at his locker in the Freshman locker
room at Damascus High School and someone turned off the lights. Victim/Suspect D, SC Abedi, Will Smith, and Caleb Thorpe
(DOB: 08/13/2003) approached Victim A and threw him onto the ground.

Victim A stated that JC Abedi attempted to remove Victim A's pants, but Victim A would not let him. Victim A further reported that
they attempted to insert the broomstick into his buttocks, but he was able to stop them. Victim A stated that he began to cry and went
outside to try to relax.

Victim A reported that he the only time that he observed the "brooming" was yesterday (October 31, 2018) but has heard people refer
to "giving the broom to people".

At 1430 hours, Jean Claude Abedi, Kristian Jamal Lee, and Will Smith were placed under arrest. Each was transported by a patrol
officer to the Special Victims Investigations Division.

On November 01, 2018, Jean Claude was read the Advice of Rights Form and a custodial interview was completed at the Special
Victims Investigations Division in Rockville, Montgomery County, Maryland.

SC Abedi stated that 20 minutes before football practice, Will Smith came into the locker room with the broom. JC Abedi stated that
Will Smith said, "let's give Freshman the broom" and Will Smith began poking Victim C with the broomstick as Victim C stated
"stop, stop, stop". SC Abedi stated that Victim C's pants were down, and the broomstick was touching Victim C's buttocks and it
went into Victim C's buttocks four to five times.

JC Abedi further stated that he began wrestling with Victim B.

JC Abedi stated that he saw a lot of Freshman on the ground near Victim A, but that Will Smith did not "use the broom" on Victim A.
Will Smith did have the broom in his hand but did not poke Victim A with it.

JC Abedi further stated that they talked about the broom to scare the Freshman and that the broom is always in the locker room.

On November 01, 2018 Will Daniel Smith was read the Advice of Rights Form and a custodial interview was completed at the
Special Victims Investigations Division in Rockville, Montgomery County, Maryland. Will Smith stated that "the broom" started
from generations ago.

Will Smith stated that he entered the locker room with JC Abedi and KS Lee while Will Smith is pumping the broom in the air. The
lights turned off in the locker room and Will Smith approached Victim C with the broom and inserted the broomstick into Victim C's
buttocks over top of his pants. SC Abedi and KS Lee pulled Victim C's pants down and Will Smith stated that he walked away.

Will Smith further stated that he inserted the broomstick into Victim B's buttocks while JC Abedi and KJ Lee were holding down
Victim B.

LL Date
tg ,pp)ic#Tit's Signature
....

LOrnS _
Printed Name

Tr.# 181001947254

DC-CR-001A (Rev. 04/2015)


DISTRICT COURT OF MARYLAND FOR Montgomery
(City/County)
LOCATED AT (COURT ADDRESS)
DC Case 1D00392372
191 East Jefferson Street
Rockville, MD 20850

DEFENDANTS NAME (LAST, FIRST, MI.)


Smith, Will Daniel

APPLICATION FOR STATEMENT OF CHARGES (CONTINUED) Page 5 of (.0

On November 01, 2018, Kristian Jamal Lee was read the Advice of Rights Form and a custodial interview was completed at the
Special Victims Investigations Division in Rockville, Montgomery County, Maryland.

KJ Lee stated that he observed JC Abedi, another student, and an unknown subject near Victim C. KJ Lee confessed that he pushed
Victim C and encouraged the other subjects while they were "giving him the broom". KJ Lee stated that JC Abedi, another student,
and the unknown subject removed Victim C's pants and inserted the broomstick into his buttocks.

KJ Lee stated that he observed JC Abedi and Will Smith approach Victim A while Will Smith had the broom. KJ Lee confessed that
he pushed Victim A once and watched as JC Abedi and Will Smith attempted to sexually assault Victim A with the broomstick.

KJ Lee stated that he further observed Victim D attempt to run from JC Abedi and Will Smith, who was holding the broom. KJ Lee
stated about five people tackled Victim D to the ground and threw clothing on top of him.

On November 02, 2018, Caleb Thorpe was read the Advice of Rights Form and a custodial interview was completed at the Special
Victims Investigations Division in Rockville, Montgomery County, Maryland.

Caleb Thorpe confessed to helping bring Victim C down to the ground. He further stated that he laid on Victim C for a second.

Caleb Thorpe further stated that he was watching from the outside of the locker room as other subjects were stomping on Victim B.
Caleb Thorpe confessed to sitting on top of Victim B's face and pushing Victim B.

Caleb Thorpe confessed to pushing Victim A.

Caleb Thorpe further stated that there was a Junior Varsity football group chat on mobile application Snapchat, Incorporated where
members of the team discussed the incidents that occurred inside the locker room.

A Search Warrant was executed on the locker room on November 1,2018, at 1841 hours. Items of evidentiary value were located
within the Locker-Room, seized, and entered into evidence, to include a broom with a brown handle.

---
----- —.15-ate

Tr.# 181001947254
DC-CR-001A (Rev. 04/2015)
DISTRICT COURT OF MARYLAND FOR Montgomery
(City/County)
LOCATED AT (COURT ADDRESS)

191 East Jefferson Street


Rockville, MD 20850 DC Case 1000392372

DEFENDANTS NAME (LAST, FIRST, MI.)


Smith, Will Daniel

APPLICATION FOR STATEMENT OF CHARGES (CONTINUED) Page .._62 of (1)

Based on the above facts and circumstances, of which occurred in Montgomery County, Maryland, Will Daniel Smith did conspire
with Jean Claude Abedi , Kristian "KJ" Jamal Lee, and Caleb Thorpe to commit First Degree Rape.

Your affiant believes sufficient probable cause exists to charge Will Daniel Smith (DOB: 07/02/2003) in violation of the following
Annotated Code of Maryland:

CR 3-303 1st Degree Rape of Victim B


CR 3-303 Attempt 1st Degree Rape of Victim A
CR 3-303 Attempt 1st Degree Rape of Victim C
CR 3-303 Attempt 1st Degree Rape of Victim D
CR 3-303 Conspiracy to Commit 1st Degree Rape

Your affiant was instructed by the Montgomery County State's Attorney's Office to apply for the above listed charges.

All events occurred in Montgomery County, Maryland.

- ZO D Y :
li anis Sinature

l'rinted Name

Tr.# 181001947254
DC-CR-001A (Rev. 04/2015)