Defendant gets drunk and hops around on his girlfriends car smashing the roof and damaging the hood and windows. +$1500.00 in damage.

Our little 250 lb jackrabbit isn't satisfied and starts hoping from car to car. He damages 13 cars total. All of them over $1,500.00

Can you total the damange as the same criminal episode and do a 3rd degree felony? ($25,000.00)

Here's the problem. In the indictment charging manual there isn't a provided paragraph for the aggregation of criminal mischeif charges. So, I took the similar paragraph from the theft charges and slightly modified it to make it fit.

The defense attorney is going to plea by information to a deferred probation of 5 years if and have the restitution paid off quickly.

My question: is my information going to work? or do I need 13 seperate SJF informations?

I've used:

did then and there intentionally or knowingly cause damage or destroy tangible property to-wit: (car description), by jumping and running on the vehicle, without the effective consent of (victim), the owner of said property, and did thereby cause pecuniary loss of $1,500 or more but less than $20,000 to the said owner.

13 times then added:

And it is further presented in and to said Court that all of the said damages were caused pursuant to one scheme continuing course of conduct, and the aggregate value of the loss sustained was $20,000 or more but less than $100,000.

Look at TPC 28.03(e). It seems to be the aggregating language for the Criminal Mischief statute permitting what you want to do. Here is what it says:

(e) When more than one item of tangible property, belonging
to one or more owners, is damaged, destroyed, or tampered with in
violation of this section pursuant to one scheme or continuing
course of conduct, the conduct may be considered as one offense, and
the amounts of pecuniary loss to property resulting from the damage
to, destruction of, or tampering with the property may be
aggregated in determining the grade of the offense.