Case Document 1 Filed 07/24/18 Page 7013 IN THE UNITED STATES DISTRICT COURT CLERK U.S. DISTRICT COURT FOR THE WESTERN DISTRICT OF WEST. DESI. OF UNITED STATES OF AMERICA Criminal No. @4013 V. ERIKA ROMANOWSKI (18 U.S.C. 1512(c)(2), 1001(a)(2)) INDICTMENT The grand jury charges: At all times material to this Indictment: COUNT ONE 1. Defendant ERIKA ROMANOWSKI was employed as a clerk at the Allegheny County Sheriff?s Of?ce (ACSO), with a work station in of?ce space in the Allegheny County Courthouse in Pittsburgh, 2. Defendant ERIKA ROMANOWSKI worked in a secure, non-public area of ACSO, where she had access to sensitive law enforcement information, including information related to ongoing federal law enforcement investigations with which ACSO assisted. 3. By virtue of her employment at ACSO, defendant ERIKA ROMANOWSKI was aware of the need to protect sensitive law enforcement information from improper disclosure, as such disclosure could result in efforts by the targets of ongoing criminal investigations to change their behavior to evade detection or apprehension. 4. From in and around February 2018 to in and around June 2018, the Federal Bureau of Investigation (FBI) and United States Drug Enforcement Administration (DEA)?federa1 law enforcement agencies?conducted a multi-agency federal grand jury investigation into the criminal activities of a large?scale, violent drug trafficking organization operating in the West Case Document 1 Filed 07/24/18 Page 2 of 4 End of Pittsburgh, (hereinafter ?the federal grand jury investigation?). The federal grand jury investigation included numerous court?authorized Wiretaps. 5. Person A and Person were targets of the federal grand. jury investigation, and Person was a senior member of the drug traf?cking organization. 6. ACSO provided operational and other assistance to the FBI and DEA during the pendency of the federal grand jury investigation. 7. During the federal grand jury investigation, defendant ERIKA ROMANOWSKI maintained a social association with Person A and Person B, and she regularly communicated with Person A by telephone and text message. 8. During the federal grand jury investigation, defendant ERIKA ROMANOWSKI disclosed to Person A and Person sensitive, non?public law enforcement information in an effort to protect Person from investigation and prosecution by federal law enforcement. 9. On or about April 23, 2018, a senior ACSO of?cial stated that he had received a telephone call from federal authorities, who requested assistance with a round up in the West End neighborhood. The senior ACSO of?cial made this statement in a non?public area of ACSO and in defendant ERIKA presence. 10. Shortly after the senior ACSO of?cial referenced the round up by federal authorities, defendant ERIKA ROMANOWSKI placed a telephone call to Person A, but the call did not connect. When Person A returned defendant ERIKA call a few minutes later, defendant ERIKA ROMANOWSKI stated, can?t talk right now, but where?s [Person In response, Person A con?rmed that Person was at his house, and defendant ERIKA ROMANOWSKI stated, ?Tell him to stay there until I call you back.? I 1. In another call the same morning, Person A asked defendant ERIKA ROMANOWSKI, ?Can you text?? Defendant ERIKA ROMANOWSKI responded, ?To me that?s the same as talking.? Defendant ERIKA ROMANOWSKI further informed Person A 2 Case Document 1 Filed 07/24/18 Page 3 of 4 9 during the call that ?they were doing a round up . . . that?s why I said to stay home for now.? When Person A clari?ed, round up on the west side,? defendant ERIKA ROMANOWSKI responded, ?Yup.? 12. During another telephone call later in the day, defendant ERIKA ROMANOWSKI told Person A, didn?t hear all the details. I just heard they were hitting houses over there . . . the feds called for back-up.? Later, in the early evening, defendant ERIKA ROMANOWSKI spoke by telephone with Person A again and stated, don?t hear speci?cs, and I?m not sitting up there no more, so I wouldn?t hear nothing on the radio. They just said the feds were over there hitting houses and they needed back up for transport.? 13. On or about April 23, 2018, Person A communicated with Person multiple times about the information defendant ERIKA ROMANOWSKI disclosed to Person A, including relaying defendant ERIKA directive that Person stay at his house. 14. From in and around February 2018 to in and around April 2018, in the Western District of defendant ERIKA ROMANOWSKI corruptly obstructed, in?uenced, and impeded an of?cial proceeding, that is, a proceeding before a federal grand jury and a proceeding before a court of the United States, and attempted to do so, by knowingly disclosing sensitive law enforcement information to Person A and Person B. In violation of Title 18, United States Code, Section 1512(c)(2). Case Document 1 Filed 07/24/18 Page 4 of 4 COUNT TWO 15. The allegations contained in paragraphs 1 through 14 of this Indictment are hereby repeated, realleged, and incorporated by reference as though fully set forth herein. 16. On or about June 20, 2018, in the Western District of in a matter within the jurisdiction of the Federal Bureau of Investigation (FBI), a department or agency of the United States, defendant ERIKA ROMANOWSKI did knowingly and willfully make materially false, ?ctitious, and fraudulent statements and representations, that is, in the course of an interview by FBI Special Agents conducting an of?cial investigation, defendant ERIKA ROMANOWSKI repeatedly denied ever having disclosed sensitive law enforcement information to Person A or Person B, when, in truth and in fact, as defendant ERIKA ROMANOWSKI then and there well knew, between in and around February 2018 and in and around April 2018, she had, in fact, disclosed sensitive, non?public law enforcement information to Person A and Person B. In violation of Title 18, United States Code, Section 1001(a)(2). A TRUE BILL, #WZ??ngw? FOREPERSON WM scorr w. BRADY United States Attorney PA ID No. 88352