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Case: 25CI1:15-cr-01074-WLK Document #: 1 Filed: 10/30/2015 Page 1 of 2
INDI TMENT
pt de ree murder 97-3-19 agg assault 97-3-7
CIRCUIT COURT NO./-),....
' ....- ~
jQ t</LJJC
Shoot/ ehicle 97-25-47 felon/firearm 97-37-5 I 8
97-3-117 habitual offender 99-19-81 a ' ~
'C!J ~-()
THE TATE OF MISSISSIPPI Circuit Court 0
FIRS DISTRICT, HINDS COUNTY September Term, A.D., 201
u. <'o,.,
I\'
First Judicial District of
Hinds County.
The Grand Jurors for the State of Mississippi, taken from the body of good and
lawful persons of Hinds County, in the State of Mississippi, elected, impaneled, sworn and
charg d to inquire in and for said District, County and State aforesaid, in the name and by the
au tho ity of the State of Mississippi, upon their oaths present: That
MARCUS MALLETT
Constituting a common transaction or occurrence or a closely related series of
transactions or occurrences and/or constituting a common scheme or plan
in said District, County and State, on or about the 5th day of February, 2015
in the ounty aforesaid and within the jurisdiction of this Court, did willfully, unlawfully and
feloni usly kill Shanitra Ramsey, a human being, without authority oflaw, with deliberate
design to effect the death of said person or of any human being, by shooting the s~id, Shanitra
Rams yin the chest and stomach with a firearm, in violation of Section 97-~19 (1972), as
ed,
COU TTWO
unlaw ully and feloniously and purposely or knowingly cause or attempt to cause bodily
injury to Joshua Ledbetter, a human being, with a deadly weapon, to-wit: a firearm, or
other eans likely to produce death or serious bodily harm, by shooting the said Joshua
Ledbe ter in the leg with said firearm, in violation of Mississippi Code Annot*ted 97-3-7
(1972) as amended,
COU TTHREE
did wi fully, unlawfully, have in his/her possession a certain firearm, to-wit: an unknown
calibe firearm
he the said Marcus Mallett, having been previously convicted of a felony, to-wit: the crime of
auto b rglary in the Circuit Court of the First Judicial District of Hinds Count)', Mississippi,
on 11 13-2008, in cause number 08-0-797, in said Court, In violation of Se~tion 97-37-5,
Missis ippi Code, 1972, as amended,
Case: 25CI1:15-cr-01074-WLK Document #: 1 Filed: 10/30/2015 Page 2 of 2
PAGE TWO: MARCUS MALLETT
COU TFOUR
did wi fully, unlawfully and feloniously shoot a firearm, to-wit: an unknown c~liber
firear at or into a motor vehicle, to-wit: a Toyota Scion, MS TAG # LMF 506 the
prope of Enterprise Rent A Car, in violation of Section 97-25-47, Mississippi Code of
1972 nnotated, as amended and
COU T FIVE
did wilfully, unlawfully, feloniously and knowingly, whether against resistance or by
sudde or stealthy seizure or snatching, or by putting in fear, or attempting to do so, or by
anoth r means take a motor vehicle from the immediate actual possession of Shanitra
Rams , said motor vehicle described as a white Toyota Scion , MS TAG # IJMF 506, a
more articular description being to the Grand Jury unknown, being then an4 there the
prope of Enterprise Rent A Car, he the said Marcus Mallett being then an~ there
armed with a deadly weapon, to-wit: a firearm, or any object capable of inflic~ing death or
seriou bodily harm, In violation of Section 97-3-117, Mississippi Code, 1972, as amended,
he, th said Marcus Mallett, having been previously convicted of at least two felonies,
to-wit the crime of auto burglary in the Circuit Court of the First Judicial District of
Hinds County, Mississippi, on 11-13-2008, in Cause number 08-0-797 in said Court, and
the cri e of auto theft in the Circuit Court of the First Judicial District of Hin~s County,
Missis ippi, on 06-07-2012, in Cause number 10-0-623 in said Court, each of $aid felony
convic ions being upon charges separately brought and arising out of separat~ incidents at
differ nt times, and upon each of said convictions, the said Marcus Mallett, wras sentenced
to te s of one year or more in a penal institution of the above-named state, this
ent being returned pursuant to the provisions of Section 99-19-81, Mississippi Code,
s amended, and
contr ry to the form of the statute in such cases made an
and · ni of the State of Mississippi.
