23 26 27 28 IND ENB. WOLFSON FILED IN OPEN COURT B. Se Beat Distiet Atomey GTENEND GRIERSON THAN COOPER mapa et ee oan aaetan 89155-2212 eM el ttomey for Plaintiff IARIE ROMEA, DEPUTY DISTRICT COURT CLARK COUNTY, NEVADA THE STATE OF NEVADA, Plaintiff, CASENO; C-17-321180-1 ai DEPTNO: JOHN MICHAEL BONAVENTURA, Defendant. INDICTMENT STATE OF NEVADA COUNTY OF CLARK ‘The Defendant above named, JOHN MICHAEL BONAVENTURA, accused by the Clark County Grand Jury of the crime(s) of UNLAWFUL INTERCEPTION OF WIRE COMMUNICATIONS (Category D Felony - NRS 200.620, 200.690 - NOC $0355); THEFT (Category B Felony - NRS 205.0832, 205.0835.4 - NOC 55991) and MISCONDUCT OF A PUBLIC OFFICER (Category E Felony - NRS 197.110 - NOC 52303), committed at and within the County of Clark, State of Nevada, on or between January 1, 2013 and January 2, 2015, as follows: COUNT 1 - UNLAWFUL INTERCEPTION OF WIRE COMMUNICATIONS did on or between January 1, 2013 and January 31, 2013 willfully, unlawfully, knowingly, and feloniously intercept or attempt to intercept a wire communication, without the knowledge or consent of STEVE SEBELIUS and/or LOUIS TOOMIN, by recording a telephone communication of said STEVE SEBELIUS and/or LOUIS TOOMIN without their eanamencravenanaNDéol oe.knowledge or consent, the defendant being criminally liable under one or more of the following principles of criminal liability, to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be ‘committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendant aiding or abetting and/or conspiring in the following manner, to wit: by entering into a course of conduct whereby Defendant coordinated with and/or directed an unknown coconspirator to record said wire communication, Defendant and unknown coconspirator acting in concert throughout. COUNT 2 - UNLAWFUL INTERCEPTION OF WIRE COMMUNICATIONS did on or between January 1, 2013 and January 31, 2013 willfully, unlawfully, knowingly, and feloniously intercept or attempt to intercept a wire communication, without the knowledge or consent of LAWRENCE MOWER and/or LOUIS TOOMIN, by recording a telephone communication of said LAWRENCE MOWER and/or LOUIS TOOMIN without their knowledge or consent, the defendant being criminally liable under one or more of the following principles of criminal liability, to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendant aiding or abetting and/or conspiring in the following manner, to wit: by entering into a course of conduct whereby Defendant coordinated with and/or directed an unknown coconspirator to record said wire ‘communication, Defendant and unknown coconspirator acting in concert throughout. COUNT 3 - UNLAWFUL INTERCEPTION OF WIRE COMMUNICATIONS did on or between March 14, 2014 and April 8, 2014 willfully, unlawfully, knowingly, and feloniously intercept or attempt to intercept a wire communication, without the knowledge or consent of STEPHANIE BARKER and/or ROB BARE and/or ROBERT GOWER and/or ROBERT POOL, by recording a telephone communication of said STEPHANIE BARKERand/or ROB BARE and/or ROBERT GOWER and/or ROBERT POOL without their knowledge or consent, the defendant being criminally liable under one or more of the following principles of criminal liability, to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiriig, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendant aiding or abetting and/or conspiting in the following manner, to wit: by entering into a course of conduct whereby Defendant coordinated with and/or directed an unknown coconspirator to record said wire communication, Defendant and unknown coconspirator acting in concert throughout, COUNT 4- UNLAWFUL INTERCEPTION OF WIRE COMMUNICATIONS did on or between March 14, 2014 and December 1, 2014 willfully, unlawfully, knowingly, and feloniously intercept or attempt to intercept a wire communication, without the knowledge or consent of CLARENCE COLLINS, aka, TOM COLLINS, by recording a telephone communication of CLARENCE COLLINS, aka, TOM COLLINS without his knowledge or consent, the defendant being criminally liable under one or more of the following principles of criminal liability, to wit: (1) by directly committing this crime; and/or @) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendant aiding or abetting and/or conspiring in the following manner, to wit: by entering Defendant coordinated with and/or directed an unknown coconspirator to record said wire communication, Defendant and unknown coconspirator acting in concert throughout. nm m uw mM into a course of conduct whereby _wstsenoncnnmaagim nent D0e%COUNTS - THEFT did on or between November 27, 2013 and January 2, 2015 willfully, knowingly, feloniously, and without lawful authority, use the property of CLARK COUNTY and/or the LAS VEGAS TOWNSHIP CONSTABLE’S OFFICE entrusted to him, or placed in his possession for a limited, authorized period of determined or prescribed duration or fora limited use, having a value of $3,500.00 or more, belonging to CLARK COUNTY and/or the LAS VEGAS TOWNSHIP CONSTABLES OFFICE, in the following manner, to wit: by wrongfully increasing the salary of employee, Louis Toomin, approximately $2,099.00 bi- weekly for the above described time period, Defendant’s actions done in part to repay a personal debt owed to Louis Toomin, Defendant’s actions resulting in a loss to the county in excess of $3,500.00. COUNT 6 - MISCONDUCT OF A PUBLIC OFFICER did on or between November 27, 2013 and January 2, 2015 then and there willfully, knowingly, feloniously, and without lawful authority, being a public officer, employed or used ‘any person, money, or property under the public officer's official custody, for the private benefit or gain of the public officer or another, to wit: by increasing the salary of employee, Louis Toomin, Defendant's actions done in part to repay a personal debt owed to Louis ‘Toomin, Defendant's actions resulting in a monetary loss to the county. DATED this 2" day of February, 2017. STEVEN B. WOLFSON Clark County District Attorne ‘Nevada Bar #00! 1565 i BY Chief’ t Aton Nevada Bar¥01a195 ENDORSEMENT: A True Bill ‘ounty Grand Jury ‘wuaneeanonemeaaa ni an.Dock25 26 28 ( Names of Witnesses and testifying before the Grand Jury: BARE, ROB, c/o CCDA, 200 Lewis Avenue, Las Vegas, NV BARKER, STEPHANIE, c/o CCDA, 200 Lewis Avenue, Las Vegas, NV COLLINS, TOM, c/o CCDA, 200 Lewis Avenue, Las Vegas, NV COLVIN, JESSICA, c/o CCDA, 200 Lewis Avenue, Las Vegas, NV DOWNING, JAMES, LVMPD FIESELMAN, JOHN, c/o CCDA, 200 Lewis Avenue, Las Vegas, NV GOWER, ROBERT, c/o CCDA, 200 Lewis Avenue, Las Vegas, NV GRAZIANO, ¢/o CCDA, 200 Lewis Avenne, Las Vegas, NV HAYNES, COLIN, LVMPD MERRILL, RANDY, c/o CCDA, 200 Lewis Avenue, Las Vegas, NV MOWER, LAWRENCE, c/o CDA, 200 Lewis Avenue, Las Vegas, NV POOL, ROBERT, c/o CCDA, 200 Lewis Avenue, Las Vegas, NV RAMIREZ, VINCENTE, c/o CCDA, 200 Lewis Avenue, Las Veges, NV SEBELIUS, STEPHEN, c/o CCDA, 200 Lewis Avenue, Las Vegas, NV STANTON, AARON, LVMPD TOOMIN, LOUIS, c/o CCDA, 200 Lewis Avenue, Las Vegas, NV Additional Witnesses known to the District Attorney at time of filing the Indictment; CUSTODIAN OF RECORDS, CCDC CUSTODIAN OF RECORDS, LVMPD COMMUNICATIONS: CUSTODIAN OF RECORDS, LVMPD RECORDS 16AGJ172X/me-GI typ BV #140602-1445 wsotoaniencmvmssacieeoo8, DOK