Mj Donovan

7/27/2019 Mj Donovan

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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF OHIOWESTERN DIVISION

UNITED STATES OF AMERICA, CASE NO.Plaintiff, JUDGE

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v. 1119CR 092MARY JILL H. DO NOVANa/k/a "MJ",

Defendant.

THE GRAND JURY CHARGES THAT:

COUNT 1

INDICTMENT18 u.s.c. 218 U.S.C. 1512(b)(2)(B)18 U.S.C. 1512(c)(1)18 u.s.c. 1512(k)

(CONSPIRACY TO OBSTRUCT JUSTICE)

!J.DLOTI

1. At all times relevant to the conspiracy, in particular from the 21st day of April,2011, up to the 29th day of February, 2012, MARY JILL H. DONOVAN, a/k/a "MJ" was theattorney for J.B. in the Hamilton County Court of Common Pleas, Ohio, Case Number B-1102585, in which the State ofOhio charged J.B. with committing the crime ofHaving WeaponsUnder Disability, which is a felony.

2. At all times relevant to the conspiracy, in particular from the 4th day ofNovember, 2011, up to the 21st day of March, 2012, MARY JILL H. DONOVAN, a/k/a "MJ"was the attorney for P.S. in the Hamilton County Court of Common Pleas, Ohio, Case NumberB-11 07086, in which the State ofOhio charged P S. with committing the crimes ofTrafficking inMarihuana and Possession ofMarihuana, both ofwhich are felonies.

Case: 1:13-cr-00092-SJD Doc #: 1 Filed: 08/21/13 Page: 1 of 5 PAGEID #: 1


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3. On or about the 20th day of February, 2012, the exact date being unknown, theHamilton County Prosecutor's Office provided MARY JILL H. DONOVAN, a/k/a "MJ" withrecords of telephone calls recorded at the Hamilton County Justice Center and the Butler CountyJail, from J.B. to others not incarcerated in the Hamilton County Justice Center or Butler CountyJail, in advance of J.B.'s trial in the Hamilton County Court of Common Pleas in Case NumberB-1102585.

4. At all times relevant to the conspiracy, P.S. was a person involved with others,who are not named but are known to the Grand Jury, in a conspiracy to obtain United Statescurrency, and to obtain heroin and cocaine for the purpose of distribution in the Southern DistrictofOhio, by means of a robbery involving firearms.

5. At all times relevant to the conspiracy, I.A. was a person, known to the GrandJury, who served as an intermediary and communications-facilitator between J.B. and P.S.

6. At all times relevant to the conspiracy, R.T. was a person, known to the GrandJury, who served as an intermediary and communications-facilitator between J.B. and P.S.

7. At all times relevant to the conspiracy, "heroin" refers to the Schedule I controlledsubstance, and "cocaine" refers to the Schedule II controlled substance.

8. At all times relevant to the conspiracy, a "SIM" card is a Subscriber IdentityModule, on which is contained information derived from the use of the cellular phone into whichit has been inserted.

A. THE CONSPIRACY9. From on or about the 20th day of February, 2012, the exact date being unknown,

to and including on or about the 29th day of February, 2012, the exact date being unknown, inSouthern District of Ohio, the defendant MARY JILL H. DONOVAN, a/k/a "MJ", did

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unlawfully, knowingly and intentionally combine, conspire, confederate and agree with P.S.(separately indicted in the United States District Court in Case Number 1:12cr32-1) to corruptlydestroy an object, to-wit: a Subscriber Identity Module, a/k/a "SIM" card, or attempt to do so,with the intent to impair its integrity and availability for use in an official proceeding, to-wit, thefederal Grand Jury investigation of J.B. and others, in violation of Title 18, United States Code,Section 1512(c)(l), Section 1512(b)(2)(B) and Section 2.

B. MANNER AND MEANS TO ACCOMPLISH THE CONSPIRACY

10. The manner and means by which the defendant and co-conspirator conspired todestroy evidence include, but are not limited to the following:

a. On or about February 23, 2012, at approximately 9:04:52 PM, MARY JILL H.DONOVAN sent a text message to P.S.: "Change phones"

b. On or about February 23, 2012, at approximately 9:06:24 PM, P.S. sent a text message toMARY JILL H. DONOVAN in reply: "Ok"

c. On or about February 23, 2012, at approximately 9:07:23 PM, MARY JILL H.DONOVAN sent another text message to P.S.: "And the aim"

d. On or about February 23, 2012, at approximately 9:07:43 PM, MARY JILL H.DONOVAN sent another text message to P.S.: "Sim"

e. On or about February 23, 2012, at approximately 9:09:01 PM, MARY JILL H.DONOVAN sent another text message to P.S.: "Destroy the sim"

f. On or about February 23, 2012, at approximately 9:09:27 PM, P.S. sent a text message toMARY JILL H. DONOVAN in reply: "Doing it now"

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g. On or about February 23, 2012, at approximately 10:35:17 PM, P.S. sent a text messageto I.A. with an instruction to relate to J.B.: "Tell bra mj called me told me 2 get anotherand don't answer his calls tell I'm go get a burnout tommor phone hot"

h. On or about February 23, 2012, at approximately 10:35:54 PM, I.A. sent a text messageto P.S. in reply: "Ok"

1. On or about February 23, 2012, at approximately 10:56:34 PM, R.T. sent a text messageto P.S.: "Did mj say it was bad or good"

J. On or about February 23, 2012, at approximately 10:57:31 PM, P.S. sent a text messageto R.T. in reply: "She aint say"

k. On or about February 23, 2012, at approximately 10:58:43 PM, R.T. sent a text messageto P.S.: "Get rid of this line too bro"

1. On or about February 23, 2012, at approximately 10:59:04 PM, R.T. sent again a textmessage to P.S.: "Get rid of this line too bro"

m. On or about February 24, 2012, after receiving the text messages from MARY JILL H.DONOVAN directing him to destroy the SIM card, P.S. did destroy the SIM card in thephone and then obtained a different SIM card, changing his telephone number.

n. On or about February 25, 2012, P.S. went to the law office of MARY JILL H.DONOVAN and confirmed he had destroyed the SIM card.

All in violation of Title 18, United States Code, Section 1512(k).

COUNT 2(OBSTRUCTION OF JUSTICE)

On or about the 23rd day of February, 2012, in the Southern District of Ohio, thedefendant, MARY JILL H. DONOVAN, a/k/a "MJ", did knowingly corruptly persuade P.S.,

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instructing him to remove and destroy the Subscriber Identity Module, a!k/a "SIM" card in acellular telephone used by P.S., with the intent to cause and induce P.S. to destroy thatIdentity Module, alk/a "SIM" card and to impair that Subscriber Identity Module's, alk/a "SIM"card's integrity and availability for use in an official proceeding, to-wit, the federal Grand Juryinvestigation of J.B. and others.

In violation ofTitle 18, United States Code, Section 1512(b)(2)(B) and Title 18, UnitedStates Code, Section 2.

COUNT 3(OBSTRUCTION OF JUSTICE)

On or about the 23rd day of February, 2012, in the Southern District of Ohio, thedefendant MARY JILL H. DONOVAN, a/k/a "MJ", did corruptly destroy an object, to-wit: aSubscriber Identity Module, alk/a "SIM" card, or attempt to do so, with the intent to impair itsintegrity and availability for use in an official proceeding, to-wit, the federal Grand Juryinvestigation of J.B. and others.

In violation of Title 18, United States Code, Section 1512(c)(1) and Title 18, United StatesCode, Section 2.

KENNETH L. PARCRIMINAL CHIEF

A TRUE BILL.

G NDJURYFOREPERSON

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Mj Donovan

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