Cristina Ortega, #9567

Deputy Davis County Attorney

P. O. Box 618
800 West State Street
Farmington UT 84025
Telephone: (801) 451-4300
Fax:
(801) 451-4328
_____________________________________________________________________________
IN THE DISTRICT COURT OF THE SECOND JUDICIAL DISTRICT
IN AND FOR THE COUNTY OF DAVIS, STATE OF UTAH
THE STATE OF UTAH
Plaintiff,
vs.
MARIO ANTHONY JONES
DOB: 06/2/1991,
Defendant.

INFORMATION
CASE #

The undersigned prosecutor states on information and belief that the defendant, either
directly or as a party, at County of Davis, State of Utah, committed the crime(s) of:
COUNT 1
VOYEURISM (MINOR VICTIM), a Third Degree Felony, in violation of Utah
Code Ann. 76-9-702.7(1), as follows: That the above named defendant, on or about May 6,
2016, did intentionally use a camcorder, motion picture camera, photographic camera of any
type, or other equipment that was concealed or disguised to secretly or surreptitiously videotape,
film, photograph, record or view by electronic means an individual under 14 years of age: (a) for
the purpose of viewing any portion of the individual's body regarding which the individual had a
reasonable expectation of privacy, whether or not that portion of the body was covered with
clothing; (b) without the knowledge or consent of the individual; and (c) under circumstances in
which the individual had a reasonable expectation of privacy.

COUNT 2
VOYEURISM, a Class A Misdemeanor, in violation of Utah Code Ann. 76-9702.7(1), as follows: That the above named defendant, on or about April 3, 2016, did
intentionally use a camcorder, motion picture camera, photographic camera of any type, or other
equipment that was concealed or disguised to secretly or surreptitiously videotape, film,
photograph, record or view by electronic means an individual: (a) for the purpose of viewing any
portion of the individual's body regarding which the individual had a reasonable expectation of
privacy, whether or not that portion of the body was covered with clothing; (b) without the
knowledge or consent of the individual; and (c) under circumstances in which the individual had
a reasonable expectation of privacy.
This Information is based on evidence obtained from witness Clint E Bobrowski.
PROBABLE CAUSE STATEMENT: The undersigned prosecutor is a Deputy
Davis County Attorney and has received information from the investigating officer, Clint E
Bobrowski of the Layton Police Department, and the information herein is based upon such
personal observations and investigation of said officer.
On May 6, 2016, in Davis County, the defendant was in a bathroom stall at
Barnes and Noble Bookstore. A thirteen year old boy entered the bathroom and entered a stall
next to the defendant. As the thirteen year old boy was seated on the toilet he observed a white
cell phone being held by the defendant. The defendant appeared to be recording this thirteen year
old boy. The thirteen year old boy made a noise by clearing his throat in order to alert that he
was aware that he was being recorded. He then observed that the individual holding the phone
jerked the phone away from his bathroom stall. The thirteen year old boy then immediately
exited the bathroom and notified his father about what the defendant did.

The defendant initially told law enforcement that he did in fact place his cell
phone underneath the bathroom stall to record the thirteen year old boy as a prank. He also
initially denied that that he recorded the thirteen year old boy. However, after further
investigation on the defendant's cell phone, three separate video recordings were identified of an
adult male being recorded, without his knowledge, in the same bathroom on April 3, 2016. The
video footage was shot over a bathroom stall in the same bathroom recording this adult male
masturbating without his knowledge that he was being recorded.
The defendant initially stated he downloaded the aforementioned videos of the
adult male but ultimately admitted to law enforcement that the aforementioned adult male was
unaware he was being recorded by the defendant for sexual gratification. The defendant further
admitted that on May 6, 2016, he was bored and wanted to sexually gratify himself so he waited
in the bathroom stall of Barnes and Noble and waited for someone to come inside to you use the
bathroom. He then heard someone come inside and activated his recording device on his cell
phone and placed it underneath the bathroom stall in an attempt to capture images to use to
sexually gratify himself. He stated he discovered the individual was a minor when he heard the
individual make a high pitched sound when he cleared his throat. He then proceeded to delete the
video recording.
Authorized September 6, 2016
for presentment and filing:
TROY S. RAWLINGS
Davis County Attorney

By /s/ Cristina Ortega

Deputy Davis County Attorney