UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION
UNITED STATES OF AMERICA, CASE NO.
Plaintiff, JUDGE
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v. 1119CR 092
MARY JILL H. DO NOV AN
a/k/a "MJ",
Defendant.
THE GRAND JURY CHARGES THAT:
COUNT 1
INDICTMENT
18 u.s.c. 2
18 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 the
attorney for J.B. in the Hamilton County Court of Common Pleas, Ohio, Case Number B-
1102585, in which the State of Ohio charged J.B. with committing the crime of Having Weapons
Under Disability, which is a felony.
2. At all times relevant to the conspiracy, in particular from the 4th day of
November, 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 Number
B-11 07086, in which the State of Ohio charged P .S. with committing the crimes of Trafficking in
Marihuana and Possession of Marihuana, both of which are felonies.
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3. On or about the 20th day of February, 2012, the exact date being unknown, the
Hamilton County Prosecutor's Office provided MARY JILL H. DONOVAN, a/k/a "MJ" with
records of telephone calls recorded at the Hamilton County Justice Center and the Butler County
Jail, from J.B. to others not incarcerated in the Hamilton County Justice Center or Butler County
Jail, in advance of J.B.'s trial in the Hamilton County Court of Common Pleas in Case Number
B-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 States
currency, and to obtain heroin and cocaine for the purpose of distribution in the Southern District
of Ohio, by means of a robbery involving firearms.
5. At all times relevant to the conspiracy, I.A. was a person, known to the Grand
Jury, 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 Grand
Jury, 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 controlled
substance, and "cocaine" refers to the Schedule II controlled substance.
8. At all times relevant to the conspiracy, a "SIM" card is a Subscriber Identity
Module, on which is contained information derived from the use of the cellular phone into which
it has been inserted.
A. THE CONSPIRACY
9. 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, in
Southern 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 corruptly
destroy 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, the
federal 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 to
destroy 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 to
MARY JILL H. DO NOV AN 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 to
MARY JILL H. DO NOV AN 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 message
to I.A. with an instruction to relate to J.B.: "Tell bra mj called me told me 2 get another
and 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 message
to P.S. in reply: "Ok"
1. On or about February 23, 2012, at approximately 10:56:34 PM, R.T. sent a text message
to 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 message
to 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 message
to 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 text
message 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 the
phone 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.
DO NOV AN 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, the
defendant, 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 a
cellular telephone used by P.S., with the intent to cause and induce P.S. to destroy that
Identity 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 Jury
investigation of J.B. and others.
In violation of Title 18, United States Code, Section 1512(b )(2)(B) and Title 18, United
States Code, Section 2.
COUNT 3
(OBSTRUCTION OF JUSTICE)
On or about the 23rd day of February, 2012, in the Southern District of Ohio, the
defendant MARY JILL H. DONOVAN, a/k/a "MJ", did corruptly destroy an object, to-wit: a
Subscriber Identity Module, alk/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, the federal Grand Jury
investigation of J.B. and others.
In violation of Title 18, United States Code, Section 1512(c)(1) and Title 18, United States
Code, Section 2.
KENNETH L. PAR
CRIMINAL CHIEF
A TRUE BILL.
G NDJURYFOREPERSON
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