Case: Doc 1 Filed: 02/24/20 Page{Kr-In {13509} Criminal Compiaim UNITED STATES DISTRICT COURT for {he Southern District othio United States ofAmerica v. Case Na TAMAYA DENNARD mfen?mi?) CRIMENAL I, the compiainant in this case, state that the foiiowing is true to the best of my knowledge and belief. On or about the date?) of SEE in the county of Hamiiton in the Southern District of Ohio the dcfendant(s} violated: Code Sectian O?eme 18 118.0. 1346 and 1343 Honest Services Wire Fraud, 18 6'66 Bribery Concerning Program? Receiving Federal Funds, and 18 195? Attempted Extortian Under Coior 0? Right. This criminal Complaint is basad on these facts: 8&8 Af?davit Continued on the attached she?ct. . . Complamam 5 Signature Nathan Hoibrock. Spaciai Agent, FBI ?ame and ride Sworn to befnre me and signed in my presence. nae: 242w X. Judge signamre C5 Cincinnati, Ohio Hon. Karen US. Magistrate Judge Printed name- and ride City and state: Case: Doc 1 Filed: 02/24/20 Page: 2 of 17 PAGEID 26 EN THE UNITED CGURT FSR THE SOUTHERN 0F QHXG UNITEB STATES V. Case No. TAMAYA QENNARB Filed Under Seal AFFIDAVIT EN 6F A CRIMINAL COMPLAINT 1, Nathan Holbrook, being ?rst duly sworn, hereby depose and state as follows: AND AGENT BACKGROUNH l. I make this af?davit in support of a criminal complaint against TAMAYA DENNARD, I am a Special Agent with the Fedora] Bureau of Investigation (FBI), and have been so employed for over eightyoars; In July 20} I, I was assigned to the. Morrillville Rosideni Agoncy Of?ce {to work'whito collar crimes and public corrUpiion investigations: In joining the FBI as a Special Agent, initially spent ?ve months at the FBI training. academy in Quantioo, Virginia, whom I studied. Immorous investigative techniques: including those involved in Wl?te collar/public corruption inwstigationsl 2. I was a member of the Northwest Indiana Public Corruption Task Forco from August 2011 until December. 2017. This task force focused on public corruption investigations throughout Northwest Indiana and was compromised of several federal lawenforcomem agencies, including the FBI and ihe Internal Revenue Service (IRS). As part ofmy duties while a member of this task. force, I was involved in numerous. public corruption invosiigations including investigations of elected public of?cials, non?elected govommonz omployoos, and corrupt law enforcement of?cers. in the course of these investigations, and through my involvement in other Case: 1:20?mj?00198wKLL DOC #2 1 Filed: 02/24/20 Page: 3 Of 17 PAGEID 27 investigations with other experienced white collao?public corruption investigatora have participated in white collar andfor public corruption invesiigations involving the use of Title communication intercepts, con?dential surreptitious undercover recordings, electronic tracking devices, pen registers and trap and trace devices, and various types of search warrants for GPS locate in?mnaiion, government offices; and government computer systems. 3. In Jenner)? of 2018, was transferred. to the Cincinnati Division of the FBI and assigned to a white collarfpublic corruption unit, speci?cally to investigate public corruption in Southern Ohio to include bribe?w, extortion, and theft of funds from programs receiving government money. Since my assignment to the Cincinnati Division. 1 have conducted or parzicipaied in public corruption investigations utilizing advanced techniques to include the use of: Undercover Employees con?dential human sources; consensual undercover recordings; Tiile Ills; physical surveillance; pen registers and trap and. trace devices; and the analysis of financial records. .4. Prior to my service with the FBI, was employed as a Manager- of Clinical Operations for a major national healthcare provider in Ohio. managing the operations of seven regional facilities, My formal education includes a Bachelor of Science degree and a Master?s Degree in Easiness Administration (MBA). S. The information set forth in this af?davii was obtained during the course of my employment with the FBI, through personal observations, the statements of witnessesfcooperators, and. recordings of conversations, Since this affidavit is being submitted for the limited purpose of obtaining a criminal complaint, have not included every fact knoim to me concerning this investigation. I have set forth only the facts necessary to establish probable cause that federal. crimes have been committed. Case: DOC 1 Filed: 02/24/20 Page: 4 0f 17 PAGEED 28 6. As set forth in this af?davit, there is probable cause to believe that commi?cd honest services wire fraud. in violation of l8 [1.8.0 1346 and 1343, bribery concerning programs receiving federal funds. if} violation of IS U.S.C. 666. and attempted cxlortion under color of righi, in violation of 18 U.S.C. 1951. PROBABLE CAUSE 7. The City of Cincinnati is a municipal corporation and political subdivision of the State of Ohio located in the Southem District of Ohio. The City of Cincinnati received federal benefits in excess of$103000 during the Waive-month period preceding September 2019. 8. Cincinnati City Council is the legislative body for the City of Cincinnaii. The: Council is comprised of nine members. and is responsible for cn'acting ordinances. imposing taxes, and making appropriations. establishing policy, and hiring some city of?cials. The current council members are serving four-year terms.? 9. DENNARD isa black female, her date of binh is March 22. 1979. DENNARD is approximately five feet, four inches tall and has brown hair and brow: eyes. Social Securiw Account Number is 683. According to website, following her graduation from the University of Cincinnati with a degree in international business. she went to work for Duke Energy. DENNARD reportedly left Duke Energy to for Cincinnati City Councilmember PG. DENNARD left of?ce in 2015 to take the role of political director for campaign for United States Scnalc. In. November of 2018, city voters approved an amendment to the Cincinnati Charter to Iimii Council. terms to two years beginning with council members elected in 20321. 3 Case: DOC #2 1 Filed: 02/24/20 Page: 5 of 17 PAGEID 29 30. DENNARD was elected to the Cimizmaii City Conneil in November of 2017, ?nishing in sixth place for the ziinewmemher council, :0 serve a four?year term. is the. current President Pro Tem for the council and is else the Chairperson fer the Equity, inclusion, Youth, and the Arts Committee; Vice. Chairperson for the Major Projects and Smart Government Committee; and a member of the Budget and Finance Committee. i. i. As a current member of Cincinnati City Council, BENNARD is an agent of the City 0f Cincinnati, that is, she is employed. as elected member: of the City of Cincinnati City Council, and a ?public of?cial,? who ewes a duty ofhenesl services to the citizens of the City of Cincinnati and to the-Cincinnati City Council. l2. As set forth belew, behveen at least-August 2019 and December 2019, BERNARD engaged in a scheme to defraud {he citizens of Cincinnati of her honest services as a council member. Mere speci?cally, she engaged in acts and a?empted acts of bribery- and 'extortien, attempting to exchange her vetes- fer money, 13. CHIS is employed by a law ?rm located in the greater Cincinnati area, whose business affects interstate commerce. CH8 specializes in negotiating large~scale development projects in the Cincizmati region. Through employment with his/her ?rm and expertise in negotiating development projeeis, CH8 became invelved in a proposed large scale- development project for the downtown Cincinnati. river bank (hereinafter referred to as the ?bank?s development?) that affects and has an impact on interstate commerce, As described below, CH3 contacted law enforcement after an i?tera?ction with BENNARD, believing thal CH8 had a moral and ethical. ebli'gation te report criminal wrengdoing and to assist law enfercemem. A?er contacting law enfememeniz, CNS aeled at the directizm 0f law enforcement to assist law enforcement in its investigatien of criminal activity. Case: Doc #1 1 Filed: 02/24/20 Page: 6 0f 17 PAGEED 30 14. The bank?s development. encompasses a large section of tho Ohio River bank in Cincinnati, Ohio and has undergone phases of development; The next phasc of dove-lopmem involves adding a music venue. to the. area. In order for the bank?s development project to progress, Hilltop Companies: (hereinafter referred to as ?Hillio?? mus: be relocated from its current location just west, of Paul Brown Stadium. Hilltop has multiple business locations to include Butler, Moysvillc, Batilct?owc, Patriot: and Cincinnati} OH, Hilltop produces ready mix concrete and aggregate product to include crushed stone, sand, and gravel. CHSE ?rm a stakeholder in the bank?s development? which. has advocated for and would bene?t from the relocation of-Hilltop from its current location on the river bank in downtown Cincinnati. 15. One potential solution for the relocation of?Hilltop required a land swap the City of Cincinnati and Hilltop. Hilltop had a parcel of land under contract, referred to as the West Mill Creek site; which would be swapped for the same size of land owned by the City of referred Io as the East Mill Creek site. The land swap deal required approval of the Budget and Finance Committed followed by approval of City Council. 16, On or around August 12, 20l9, an email Was sent to members of City Council, including for-the purpose of scheduling meetings-with council members to discuss the bank?s development and the Hilltop land swap. 17. On Wednesday, August 1492019, DENNARD sent an email to CH8 requesting-:0 meet CH8. CH8 told me height: Was surprised to receive the direct communication from because CHS had only met DENNARD one time fer approxlmalcly 15 minutes. around March or April onO 9. Although n01 speci?cally stated, (31-18 33513de purpose ofthe. meeting was to update BENNARB on the. bank?s development and Hilltop land swap. OHS agreed to meet DENNARB in person on August 15, 2019.. Case: Doc 1 Filed: 02/24/20 Page: 7 of 17 PAGEED 31 18. On the morning 01" Augusi 35, 2019, at appmximaiely am, BERNARD, sent the fellowing 10in message 10 CHSZ: morzzi?g Tamaya. I had a bi! qu2 emergency 802218 up (his morning. Can we piease schedzde a mi! for {his q?emaon? I apologize for may izwca?veniezme ?3 CH8 repiied: CHIS: No problem Tamaya. Hope a? 2?5 oqu. .4 ca}! wouia' be?n?r bu! a meen??g f0 walk {Izroug}: (he. visuals of the issue ux'ouid be most. helpful Have? a. packet r00, Can mee! beg/2w 2 and a?er 3:30 today any place that works?)? 29. On Friday, August 2019, DENNARD called CH8 at approximately 1:05 pm.? The can lashed approximately ten minutes. CH8 told me about the hefsh'e had with During the can, BENNARD requested $10,000 from. CBS to pay for personal axpenses. DENNARD explaimd the mbney was needed to pay rent, place a dm?vn payment on a. car, and pay attorney fecs. Later in 111$: phone call, DENNARD requested $15,000 from CHS to pay for personal expenses; CBS told me. haz?she- offered suggestions to on how :0 handle personal ?nancial. dif?culties, bui did not offer to pmvidc mane-y t0 DENNARD. CHS naked saying saveral times daring their conversation that BERNARD did ?not know haw this works?? Later that same day, at approximately 7:24 pm, CH3 sent the foliowing text :0 DENNARD: CH8: Tamayw mil} no"; be {Ibis to wee? with you. Unfarrunafeiy, I 31327! :70: be able #0 discuss or- you wfrir your persoaal sifuaffon. 2 Recards obtained via grand jury subpoena indie-med. target telephone number was subscribed t0 3 I have reviewed all text me by CH8, 4 The {telephone call was not recorded as it was placed prior to the aasist?anbe to the FBI, but has been. veri?ed as having occurred thmugh telephone rewards. 6 messages described. in this af?davit. The text messages were provided to Case: Doc 1 Fiied: 02/24/20 Page: 8 of 17 PAGEID 32 Also on the same day, August 16, 2019, 3: approximately 8:30 pm, BENNARB sent the following text message to CH8: DE-NNARB: Afzsr speaking you {ads}; 1124: Iike a xt?ez?gh?t had been {?ied of quy sizoufdezis? Yaw seemed gezz'ufzze?? in (master? in helping me and 1 gemn'neb: need help. The ?0236 of our conversatian Was prgfid? This sex! is dig? and ?ash; as {fsomeihing is sfappz?ngyou. if my pai?z'cs? i do}? ?3 have any Biker avenues. I sailed because I literalfy am 024! qfoprians, (3m: you please {eff me why maple won ?r help? What I need 2'0 gs! my head above wafer is a pi?mzce :0 many $15110 are abie. 1 have $200 in my account 1 go! info a mug}: spot: frying r0 Izsfp my mom. and new I have r-zozhirag. I appreciate 3.3011 faking my cal! and being 116?!ng heip Ioday 20. On Saturday August 37, 2019; at appmximately 7:06 am, DENNARE), sent 10 CH8 a photograph of a dacumeni title TO LEAVE THE addressed to DENNARD, with zhe accompanying text message: DENNARB: ?[fyozz are willing I0 med with me, I sure (ha: 1 be able to heip CH8 Io DENNARB on the same day at appmximately 9:24 am, stating: CH8: Tamaya? I sugges!? you comm! Legai Aid abam your eviction notice and?nanc?zi situazz?sn. bad abomya ur mutation, ?411761143 14-11}: I (?ared same show where you might get. same {wigs appears now you are asking me persanai?pfor 1:63p (3596:? my ro/e wirh fire? ?3 Cifsnf] if ur'ouid be (ozai?y inappropriate for me to repressn! you: or provide any ?nancial assistance. Please den suggesf it again 22. Therea?er, CH8 contacted federal law regarding communications and request for meney from someone with 'husinass before Ciiy Ccunciis CH8 provided copies of {he text: messages described above and began assisting the FBI, by reinitiating contact with DENNARD a: direction. 23. On August 31, 20195 at directions CHS conducted a consensualiy recorded telephone call it: DENNARD, which she did not answer. CH8 left a message for BENNARD saying that CBS was thinking shun: BENNARD and felt bad about situatisa and wanted see if there was still a way that hrs/she couid 1181p. Case: Doc 1 Filed: 02/24/20 Page: 9 of 17 PAGEED #1 33 24. On Wednesday, Septembor 4, 2019, sent the: following text. message to CBS: Hello. :7 oppz?ocioie your voicomail. I oppreoz?ozgyow' wiz?lz'zzgness to help our. Please let me Ioww lzove {one f0 meet soon. 25. \1 ia text messages: CHS and RENNARD agreed to meet the following morning at. 8:00 am. 26. On Thursday? September 5, 2019:, CBS met DENNARB. CH8 was equipped with an FBI audio recording device to capture the meeting. Early in the meeting, iold CH8 about personal financial troubles: after which DENNARB requested $10,000. I reviewed the recordi?g of?th? meeting which included the following conversation: BENNARD: 1: ?s more oflike {tying {0 go? a cor and, likefsofd, money/"or Haifplaoe to live and {hen jos: lode bi! ofbreofizz?ng room. A?d I think, you Iaww, 11?s kim? of hard. to go! Ilsa! head space. CH8: Soyou I moon what do you, who! do you Ihfokyozz ?re gonna need, I mean?. DENNARB: Probably like fend CH8: Ten? DENNARD: Yeah. like your know aparmwni, it ?5 like you gorro puz down ?rst month ?5 ran: and like a deposit. And ofso car, probably bee}: looking, probably like {put down Meng??ve to {brag thousand dollars {0 go! car, you know, no! as new can Following the: request of $103000, CHS proceeded to explain the land swap deal to DENNARB and told DENNARD that the mayor is opposed to the. Hillt'Op land swap, CBS and BENNARD discussed the positions of that other council members regarding approval of the Hilltop land swap. told BERNARD that he/sho needed Gouncil support to get the Hilltop land swap proposal in a commi?ae. CH8: 1 think 71m! ?3 fhe?rs! {king if can we go! {he Signorw'es on resoa?uiim rim! (ken pm i! in?ow ofoozmcil Io sayyes [ex "5 32:. {his into our oommi?ea [ex 25* use our oommi?eo procem you know ro?gure out {he merits (king. 3? Case: Doc 1 Filed: 02/2420 Page: 10 of 17 PAGEED 34 BENNARD: 1 do}: ?1 win}: it will be an issue {be six gel? if inn; we can do for), we can driver do a motion, we can suspend the six (guy, you know Wharf 1 BENNARB explained that during a council meeting, a council member can malw a motion to SUSpend the. rules which would require six votes, Once the rules are suspended council can vote on ?anything we need it; vote on,? DENNARB told CHS ?thf: super majority is everything,? DENNARB explained that even if the mayor did place an issue on the agenda, the council can still bring it forward, 27. Later in {ha conversation, DENNARE) again told CHS that DENNARD needcd $10,000. DENNARD told CHS, referring to the $10,000, ?and than like I said something I can payback probably like no more than $200 a manth.? CBS asked BENNARD if she wanted the money wired to her bank acmum. DENNARD {old CH she never did a wire before, but? whatcvar is ?feasible or easiest.? CH3 explaine? to DENNARD that a wire would requira a bank account number and the bank?s routing number or CHS (1011161 give a check. BENNARD responded, ?Check is we]. Like. and then I would like (U1) like have a note or something, like, you know what I mean. [like some sari oflike SQ I?m net, you know} want to make sure I ?m 136ng what do they call it, I?m ethical,? BERNARD Suggested a note to repay the $10,080. 28. At the. end of the meeting, CHS asked BENNARB in text her the bank taming- number and account. number, CH8 explained the money wonld not come- from him, but rather it wuuld come f?mm a limiied liability company account. CH8 and HENNARD than had the following conversation: CH8: Dc} yaw {kink yam 102014}, can we (2mm: supperr wit/7 wha! we ?re milling (1602:! here? DENNARD: Sure, Yeah. CH5: Yeah, we ?re goed (m rhaz? Case: Doc 1 Filed: 02/24/20 Page: 11 of 17 PAGEID 35 BENNALRB: Yeah. CH8: Okay DENNARE: if, I don Erujer me, lei me read, because I ?m 31le .1,sz 2?61 me, far we spend son-2:52 time will: {his {min}: and 1' reach our to yaw. 29. Laue? the same day as the meeting, sent CH8 the following taxi message: Hi I wanted {a folk :0 3:26. is doable. 1 have. emailed a note 0f6 years and payments This {ext message also contained bank routing informatiom followed by a requesi for {he transaction to occur more quickly: DENNARD: II. would awe-some were: fni?ated today so (ha! I can return {Iris rental car CH3 respoaded to the text message by eXplaining that hes/she was busy with work meetings and requested to talk later that day (September 5, 2019). DENNARD replied: BENNARI): I understand. If?! gets {00 in'mfor .5: MW, 1 car} aim pick up a. Check? 30? The next morning, Friday, September 6, 201.9, DENNARD sent CH8 the following text message: DENNARD: If forafiy gfyou don ?1 have time (0 {01k Kym; colea?jusr [er me know 9711:5572? the wire could be maimed, that WOIil?d be most fielggfui. 31. Later on the same day; September 6: 2019, CBS conducted a consensually recorded telephone- call to BENNARB. I reviewed the rec-arding. Busing the call, CH8 and DENNARD discussed the $15,000 requested by DENNARD in. a previous text message. CHS told DENNARD that hefshe could give her {he money on Monday moming (September 9: 2019). asked CHS ifthat was as 30011 as heishe could do it (deliver the money} DENNARB told CH8 that she had applied for an apar?ment and wanted to move fasi' because- there was a Case: Doc #1 1 Filed: 02/24/20 Page: 12 0f 17 36 waiting list for the. aparimem. CH8 101d to plan to obtain {116 money from CH8 early an Monday and can do someihing lac/she wi ll. At {his point in the {elephone call the. following conversation engued: SO giveyoz: zen now?, DENNARQ: .Mmm- Izmm CH5: you ire goad 316:}? 321;}. . .yaza?re good with suppaz'm;g Hz'ilfop is pmpasa/ (0 do {be [and 51-13010.? Mmm-hmm. Yes. CBS: 1? comes bejbre cam-261'! 2? DENNARD: CHS: Azza? than, and {12921 I think as {his {hing goes through, 1 mama if.? . . probably the 12335:, the 22203: :?mporranf vote wil! be the, the ?rs: vote and {hereic probably going to be a second vote and {fyou can hair! on, you ?71012 I cart give yon ?m?ve {homand a?er that second vore {film '5 good with yoza DENNARD: Um, yeah, mm, ziza?s?fz?ne. A: the end of the telephone conversation, DENNARD again requested that CHS let her knew if helshe can do something sooner even if it?s not the full $103060? 32; On Saturday, September 7, 2019, CH3 stated that he/she ?was not able- to move funds ycsterday. I will have what you requested Monday morning though,? BENNARD responded that her account was negative and that ?Monday is an etemity away.? She than sent. following text messages: DENNARD: Wit); this music wnue, 1 (1022 have a dog in rhe?gim DENNARD: if ?5 to be. more weakly. 33. On Sunday? September 8, .2019, CH8 and BERNARD exchanged the following lext messagss: CH3: Will" have win}: we arozmd 10:30, Does that you? ll Case: DOC 1 Filed: 02/24/20 Page: 13 0f 17 PAGEID 37 lemzkyau. 1' {Ismail}: Heed iz??rsi Iki?g. I ?m on bermwed time with this renfal 34? On the morning of Menday, September 9, 2019: CBS and exchanged the feliewing fest messages: BEWARE: (9000? morm'ng, )3 there a way (0 meet up sooner ibis warning Khan 10:30. The rental car company opens a! 8. CH8: He}! Tamera- 1 conic! swing by Cq?ee Emperium or: {he may {a a" meezfnge 9:20-9:30 okay? BENNARB: Marzipan. Thar weak! be: great 13- certi?ed because I den ?1 have or aiiowing things {0 clear, 35. Later in the morning on September 93 2019, at approximateiy 9:23 am, CH8 met DENNARD in downtown Cin?einnali? CHS again was equippec? with an audio recording device. During the meeting, CHS provided BENNARD with a $10,000 check. I reviewed the recording. During the brief meeting the following conversation ensued: CH8: 1721's could be our rabie. So here, this is the zen ?wusmzd rim: we taiked about; Alrigfzz. okay. CH8: And 2111, that :2 6.2151256? .15: check DENNARB: {bar 13* perfect Thank you. CBS: 50 that wz?lz' g0 3-1312: firrougk, BENNARB: I ?m going rig}?! the bank on (Me Thank yea. CH5: Alrz?gfzr? BENNARD: Apprecz'afe yaw. 36. As the above communications demenstraie, DENNARD agreed to voie for the Hilitop land swap prepesal in eXChange- for $38,080. She further agreed to a. payment of $5000 following a second vote. Altheugh she previeusiy mentioned a promissory note in passing3 she never broughi it up again, Case: Doc 1 Filed: 02/24/20 Page: 14 of 17 PAGEID 38 37. Bank records indicate that deposited the: $10,000 check: provided by CH3 into a account centralized by on September 9, 2019. 38. On September 18, 2019, BENNARD called CHS and left a voice message stating she ?needs a huge favor? from CH8. Sha followed up with a taxi the next day that stated, will need remaining by tomorrow. Have an. emergency.? After exchanging multiple messages, the CH3 stated, ?Sorry, will get back {a yen. Just been slammed,? BENNaRD-responded by stating, understand. You?re incredibly busy, I thought I was. last mead the remaining by tomcnow. We don?t have ta talk. One less thing for you 10 d0." She. follows up with a text that stated, ?This is imperative. That?s why I?ve baan tying to reach you for the last 3 days." 3'9. That same day, September 20, 2019, CH3 and DENNARD spoke by telephone. The call was consensually recarded and 1 reviewed the recording. During the call, BENNARD stated she. wauld vote for the bill but that she needed the $5,000 new. Speci?cally, DE-NNARD ccn?nncd that she. needed ?the other and that ?you don": haw to worry about? her vote. Later that? day, CHS arrangad far $5,000 cash delivary to QENNARD, which was completed the same day. 40. Also on or about September 20, 2019, 1113 same day received the $5,000 cash, DENNARD hooked two seats on a September 22, 2019 ?ight from Cincinnati Nerlhem Kentucky Airport bound for Dcsiin?Fon. Waltan Airport. 0:2 or abeut Saptambar 22, 2019, DENNARB deposited $4,600 Cash in a persanal bank account. Then, on or about Saptember 27, 2019, DENNARI) boakad two seats on a September 29, 2019 ?ight from St, Petersburg?Claam?ater International Airport to Cincinnati Northern Kentucky Airport. One: sea: was reserved in name, {he ascend seat was resenred in the name 0f an. assaciate of EENNARB, Financial records indicate. DENNA RD spam in excess of $4,000 on. the Flarida trip l3 Case: Doc 1 Filed: 02/24/20 Page: 15 of 17 PAGEID 39 from September 225 2W9 to Septembar 29, 2019 to include accommodations at the Opal Sands Resmf in Clearwater Baach, Florida and airfare. 41. On October 2., 2019, City Council rejacied the land swap deal, with Dennard voting in favor of {he deal {apposing the mayofs motion against the deal) as promised. 42, Follmving the vote, has caniinued contacting CH8 far money, while tying the. payments to halp 311:: could provide in return. 43. For example, on October ll, 2019, sent CH3 3 text message at approximately 7:35 am; statingk in part just need your help $31,200 today." When CHE-3 did not immediately respond; DENNARD sent a followup text at approximately 11:57 3221? stating I really need. your help; Please respond..? A'few hours later,- DENNARD caminued: ?Hi! I?m. with yea. But a few competing interest [sic] have reached out. I at least want to know that you?re read my texts and give a damn.? 44? On 0r about November 2, 201.9, at approximately 4:96 pm, CHS executed a consensually recorded telephane call to During 1hr: telephone callr CHS told DENNARD that the next issue in regards to the building of the music venue an the. banks related {0 a zoning change. CHS siatcd the zoning issue was tying things up, and then stated, ?these other things, I guess, Tamaya, we?re just going to have to tackle them,? to which DENNARD ?yeah.? DENNARD stated, haven?t seen anything coma across: so I was, that?s what I. was wondaring, I knew there would be some things coming up? bu: wasn?t sure exactly what.? DENNARD then told CH8 to keep her ?in. the 109;) on everything,? Just minutes after the call ended, DENNARD sent the CBS 111:: following text: Great talking with you, I know you called me becausc yam are trying to get some things done; Otherwise, you?ve. been tapped out; or {Do busy. Just to make sure we are going to be okra-yr please send. a little help to Inc-today. Cash Ap is 0k 0: I can meet. you later? I. hate to he transactional but you?ve. kind of made it llke ihat. l4- Case: Doc #1 1 Filed: 02/24/20 Page: 16 of 17 PAGEID 40 45. Two days later, on or about November 2019, DENNARD texted CH8 and said, ?Good Momingl Are you around today? I could really use your help, It?s kind of urgent to get it {odayf? continued: ?Happy to help you, But need yours roof" 46. Similarly? on or about November 13, 2019, contacted CHS asking for more moocy, ?just about. $500,? and stated, ?As I said, I?m sure then: will be ways to help you. as well and I will? 47. An analysis of personal banking account records from June 39 2019 to November 21, 20l9 indicaic numerous cash deposits in an amount totaling $20,295.00. Tho source. of the cash deposits is unknown. CONCLUSION 48. Based on the. forgoing, I request that the Court issue the proposed criminal complaint, as there is probable cause to bellow: DENNARD has committed honest services wire fraud, in violation of 13 U.S.C. 1346 and bribery Concerning programs receiving federal funds, in violation, of 18 U.S.C. 666, attempted extortion under color of ?ght, in violation of 18 usc 195}. Case: Doc 1 Filed: 02/24/20 Page: 17 of 17 41 REQUEST FOR SEALINS 49. I further Leagues?- that the Court order that all papers in suppm of this application, including the. affidavit, be sealed uniil further order of the: Court. These documents discuss an ongoing criminal investigation that is neither public mm to all of the targets 0f the investigation. Accordingly. there is good cause to seal these documents because their premature disclosure may seriously jeopardize thal investigatien. Respectfully Nathan Holbrook Special Agent Federal Bureau of Investigation Subscribed and swan to bcfare me on (?522% 2020 KAREN L. LIKov?sz UNITED STATES MAGISTRATE JUDGE