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Case: 5:23-cr-00089-DCR-EBA Doc #: 1 Filed: 08/17/23 Page: 1 of 15 - Page ID#: 1

UNITED STATES DISTRICT COURT ~Distrlciofi<entooky


EASTERN DISTRICT OF KENTUCKY ALEO
CENTRAL DIVISION AUG 17 2023
LEXINGTON

UNITED STATES OF AMERICA

V.

RONNIE L. GOLDY

* * * * *
THE GRAND JURY CHARGES:

BACKGROUND

1. At all relevant times, RONNIE GOLDY was the Commonwealth Attorney

for the 21st Judicial Circuit in the Commonwealth of Kentucky. As Commonwealth

Attorney, GOLDY was an agent of the Commonwealth of Kentucky and was responsible

for the just administration of the Commonwealth's criminal laws. GOLD Y's

responsibilities included prosecutions for criminal offenses within the 21st Judicial

Circuit; that is, Bath, Menifee, Montgomery, and Rowan counties.

2. At all relevant times, Individual 1, whose identity is known to the grand

jury, was a resident of various locations within the Commonwealth of Kentucky,

including locations within the 21st Judicial Circuit.

3. At various relevant times, Individual 1 was charged with criminal offenses

within the 21st Judicial Circuit and other locations within the Commonwealth of

Kentucky, including the following:


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a. On or about June 24, 2015, Individual 1 was charged in Rowan Circuit

Court with a violation ofK.R.S. 514.110(3)(b) (receiving stolen

property valued between $1,000 and $10,000), a Class D felony offense

with a maximum penalty of up to five years of imprisonment and a

$10,000 fine (hereinafter, "Case A"). Individual 1 agreed to plead

guilty in Case A, and on or about January 15, 2016, the Rowan Circuit

Court entered a judgment finding Individual 1 guilty of a lesser included

violation ofK.R.S. 514.110(3) (receiving stolen property valued under

$500). Thereafter, Individual 1 remained subject to the jurisdiction of

the Rowan Circuit Court, including the requirements that Individual 1

abide by certain release conditions and make appearances in court as

ordered, and subject to potential additional incarceration for violations

of the Circuit Court's conditions and orders.

b. On or about November 30, 2015, Individual 1 was charged in

Montgomery Circuit Court with a violation ofK.R.S. 514.040 (theft by

deception; value under $500), a Class B misdemeanor offense with a

maximum penalty of up to ninety days of imprisonment and. a $250 fine

(hereinafter, "Case B"). Individual 1 agreed to plead guilty in Case B,

and on or about April 14, 2016, the Montgomery Circuit Court entered a

judgment finding Individual I guilty of violating this statute.

Thereafter, Individual 1 remained subject to the jurisdiction of the

Montgomery Circuit Court, including the requirements that Individual 1


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abide by certain release conditions and make appearances in court as

ordered, and subject to potential additional incarceration for violations

of the Circuit Court's conditions and orders.

c. On or about February 22, 2016, Individual 1 was charged in Rowan

Circuit Court with a violation ofK.R.S. 508.020 (assault, second

degree), a Class C felony offense with a maximum penalty ofup to ten

years of imprisonment and a $10,000 fine (hereinafter, "Case C").

GOLDY appeared in Case C as the Commonwealth's Attorney

prosecuting the criminal charges against Individual 1. Individual 1

agreed to plead guilty in Case C, and on or about August 23, 2016, the

Rowan Circuit Court entered a judgment finding Individual 1 guilty of a

lesser included violation ofK.R.S. 508.030 (assault, fourth degree).

Thereafter, Individual I remained subject to the jurisdiction of the

Rowan Circuit Court, including the requirements that Individual 1 abide

by certain release conditions and make appearances in court as ordered,

and subject to potential additional incarceration for violations of the

Circuit Court's conditions and orders.

d. On or about August 17, 2018, Individual I was charged in Clark Circuit

Court with multiple criminal offenses, including a violation ofK.R.S.

514.160 (identity theft), a Class D felony offense with a maximum

penalty ofup to five years of imprisonment and a $10,000 fine

(hereinafter, "Case D"). Individual 1 agreed to plead guilty in Case D,


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and on or about May 8, 2019, the Clark Circuit Court entered a

judgment finding Individual 1 guilty of an attempted violation of this

statute and other offenses. Thereafter, Individual 1 remained subject to

the jurisdiction of the Clark Circuit Court, including the requirements

that Individual 1 abide by certain release conditions and make

appearances in court as ordered, and subject to potential additional

incarceration for violations of the Circuit Court's conditions and orders.

e. On or about August 15, 2019, Individual 1 was charged in Bath Circuit

Court with multiple criminal offenses, including a violation ofK.R.S.

218A.1412(1)(d) (trafficking in a controlled substance, first degree), a

Class C felony offense under the circumstances, with a maximum

penalty ofup to ten years of imprisonment and a $10,000 fine

(hereinafter, "Case E"). Bath County law enforcement authorities

impounded Individual l's vehicle and cellular phone at the time of

Individual 1's arrest. Although this case was charged in the 21st

Judicial Circuit, a Special Prosecutor was appointed to prosecute the

criminal charges against Individual 1, based on GOLDY's expression

of a conflict of interest based on a purported familial relationship with

Individual 1. Individual 1 agreed to plead guilty in Case E, and on or

about February 6, 2020, the Bath Circuit Court entered a judgment

finding Individual 1 guilty of a lesser included violation ofK.R.S.

21 SA.1415 (possession of a controlled substance, first degree) and other


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offenses. On or about March 5, 2020, the Bath Circuit Court entered an

order directing the return of the aforesaid vehicle and cellular phone to

Individual 1. Thereafter, Individual 1 remained subject to the

jurisdiction of the Bath Circuit Court, including the requirements that

Individual 1 abide by certain release conditions and make appearances

in court as ordered, and subject to potential additional incarceration for

violations of the Circuit Court's conditions and orders.

4. At all relevant times, GOLDY owed the Commonwealth of Kentucky and

its citizens a duty to perform his responsibilities free from fraud, deceit, and self-

enrichment.

5. At all relevant times, GOLDY maintained a personal relationship with

Individual 1, which included at various points, engaging in sexual acts with Individual 1

and soliciting and accepting sexually explicit photographs and videos from Individual 1.

6. On multiple occasions during the relevant period, GOLDY used his

position as Commonwealth Attorney to perform official actions and to exert pressure and

influence on other public officials to perform official actions benefitting Individual 1.

At all relevant times, GOLDY and Individual 1 understood that the sexually explicit

images and periodic sexual encounters were provided in exchange for and because of

GOLDY's willingness to perform and procure official actions benefitting Individual 1 as

requested and as opportunities arose.


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COUNTS 1-6
18 u.s.c. § 1343
18 u.s.c. § 1346
18 u.s.c. § 2

7. Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated

by reference as if set forth fully herein.

8. From a date in or about November 2017, and continuing through a date in

or about November 2020, in Bath County, in the Eastern District of Kentucky, and

elsewhere,

RONNIE GOLDY,

with intent to defraud, devised and intended to devise a scheme and artifice to defraud

and to deprive the Commonwealth of Kentucky and its citizens of their right to the honest

and faithful services of a public official, namely, the honest services of GOLDY, through

bribery.

MANNER AND MEANS

The manner and means used to accomplish the objectives of the conspiracy

included, among others, the following:

9. GOLDY used his position as Commonwealth Attorney to perform official

actions to seek and secure Individual l's release from incarceration for Individual 1 's

criminal offenses and violations of release conditions. For example:

a. In or about November 2017, Individual 1 was arrested and held in custody

pending probation revocation proceedings in Cases A, B, and C. On or

about November 21, 2017, GOLDY notified the Judge presiding over
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Cases A and C that Individual 1 was being detained in Montgomery County

Jail and asked, "Can we let her out[?]"

, b. In or about August 2018, Individual 1 was arrested and held in custody

pending the criminal charges filed in Case D. On or about August 19,

2018, GOLDY notified the Judge presiding over Cases A and C that

Individual 1 was being detained in Clark County Jail. GOLDY expressed

his belief that Individual 1 had been arrested because of warrants previously

issued in Cases A and C. GOLDY claimed that Individual I was

"working for law enforcement" and urged "we need [Individual 1] out if

possible."

10. GOLDY used his position as Commonwealth Attorney to exert pressure on

other public officials to perform official actions that benefited Individual 1. For

example, and in addition to the communications listed in Paragraphs 9.a and 9.b above:

a. On or about November 6, 2019, GOLDY contacted the Special Prosecutor

assigned to Case E about the charges against Individual 1. GOLDY

claimed that Individual 1 was his "cousin" and suggested that the drug

trafficking charge against Individual 1 should be characterized as drug

possess10n.

b. In or about March 2020, GOLDY worked to secure an agreed court order ·

directing the release of the property that had been impounded during

Individual I's arrest in Case E. GOLDY contacted the Special Prosecutor

and others about the proposed agreed order. On or about March 4, 2020,
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GOLDY urged the Special Prosecutor to sign the proposed agreed order

and present it to the Judge in Case E.

11. GOLDY assigned and ascribed monetary value to sexually explicit images

depicting Individual 1. For example:

a. On or about May 3, 2018, Individual 1 asked GOLDY for money,

purportedly to help Individual 1 buy fuel for Individual l's vehicle.

GOLDY responded by sending $25.00 to Individual 1 through an internet

platform, and following that money transmission with successive messages

stating, "Now your turn. Loi."; "Don't leave me hanging"; and "You're

killing me." After additional messages back and f01ih, Individual 1

responded by sending GOLDY eight photographs depicting Individual 1 in

nude and sexually suggestive poses.

b. On or about April 19, 2020, Individual 1 offered to send additional sexually

explicit photographs and videos to GOLDY in exchange for approximately

$100. GOLDY responded, "Ok. I'll have to set up my card on my phone

... [to] Send$$".

12. GOLDY solicited sexually explicit images of and sexual encounters with

Individual 1 in exchange for using his position as Commonwealth Attorney to perform

official actions and exeti pressure on other public officials to perform official actions that

benefited Individual 1. For example:

a. On or about June 15, 2018, several days after Individual I sought

GOLDY's assistance in resolving a wa1Tant for Individual l's an-est,


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GOLDY sent a message to Individual 1 asking, "When do I get to see a

video". After Individual 1 responded, "When am I not gonna have a

warrant hahaha", GOLDY responded, "Lal. Good point", and "Incentives

never hurt.", explained his efforts to resolve Individual l's warrant, and

stated, "I'll try and speed it up."

b. On or about June 27, 2018, GOLDY sent a message to Individual 1 stating

"You owe me big time.'' After Individual I asked why, GOLDY

responded, "Judge is about to withdraw some warrants." After additional

messages back and forth, Individual 1 responded, "I'll send you that as

soon as I get home and make it." After approximately four weeks,

GOLDY asked Individual I, "Don't you owe me a video? Lol". After

Individual 1 responded,"& you could be right.. that is right, you did come

through on your end, didn't ya?", GOLDY replied, "Yes I am right. U

owe me a very good video or two."

c. On or about August 20, 2018, after making requests to facilitate Individual

l's release from incarceration, GOLDY sent a message to Individual 1

stating, "You are killing me. Lol", and "Though I do expect some videos

(more than I) this time." Individual 1 responded, "i suppose I may be able

to do that for you" and continued by suggesting that GOLDY "meet up"

with Individual I. GOLDY responded, "We can meet anytime you want."

Individual 1 responded with a statement about the difficulty of creating a

new video during the daytime and continued, "You DID get a bond taken
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care of on a Sunday, I suppose." After additional messages between the

two, on or about August 21, 2018, GOLDY stated, "Don't get off topic.

You still owe me videos. Can't tease and then not deliver."

d. In or about September 2018, Individual 1 asked GOLDY to help Individual

1 postpone a court hearing scheduled in Case D. GOLDY sent a response

to Individual 1 stating, "U notice you keep asking but not giving. Lol".

After Individual 1's answer, GOLDY responded with a message stating,

"I'm still waiting on those videos remember. Loi". GOLDY then sent

additional responses stating, "I can see what I can do." and "Clark county

can be difficult at times but I will do my best."

EXECUTION OF THE SCHEME

13. On or about the dates listed below, in the Eastern District of Kentucky and

elsewhere,

RONNIE GOLDY

for the purpose of executing the scheme described above, and in order to effect the

objects thereof, transmitted and caused to be transmitted by means of wire

communication in interstate commerce the following writings, signs, signals, pictures,

and sounds:

Count Date Descri12tion


Apple iMessage communication from GOLDY to the Case
1 August 19, 2018 A and Case C Judge, claiming "[Individual l] is working for
law enforcement and we need her out if possible.''
Facebook Messenger communication from GOLDY to
2 August 20, 2018 Individual 1, stating "You are killing me. Lol Though I do
expect some videos (more than 1) this time."
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Count Date DescriQtion


Facebook Messenger communication from GOLDY to
3 August 20, 2018
Individual 1, stating "We can meet anytime you want."
Facebook Messenger communication from GOLDY to
September 23,
4 Individual 1, stating "I'm still waiting on those videos
2018
remember. Lol"
Apple iMessage communication from GOLDY to the Case
November 6,
5 E Special Prosecutor, identifying Case E as "My cousin['s]
2019
trafficking case that's probably a possession."
Apple iMessage communications from GOLDY to the Case
E Special Prosecutor, asking about the status of an agreed
6 March 4, 2020 order for the release of Individual 1's property and claiming
"[Individual l's] family is trying to get [the] car. Tow guy
I wants like $2000. Crazy."

Each in violation of 18 U.S.C. §§ 1343, 1346, and 2.

COUNTS 7-12
18 U.S.C. § 1952(a)(3)
18 u.s.c. § 2

14. Paragraphs 1 through 12 of this Indictment are re-alleged and incorporated-

by reference as if set forth fully herein.

15. On or about the dates listed below, in the Eastern District of Kentucky and

elsewhere,

RONNIE GOLDY

knowingly and intentionally used and caused to be used a facility in interstate and foreign

commerce, namely a telephone and a wire and electronic communication as set forth

below, with the intent to promote, manage, establish, carry on, and facilitate the

promotion, management, establishment, and carrying on of an unlawful activity, that is

bribery, contrary to 18 U.S.C. §§ 1343 and 1346 and K.R.S. § 5 I 8.030(1 )(a), and
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thereafter performed and attempted to perform an act to promote, manage, establish, and

carry on, and to facilitate the promotion, management, establishment and carrying on of

the above unlawful activity:

Count Date Descri£tion


Apple iMessage communication from GOLDY to the Case
7 August 19, 2018 A and Case C Judge, claiming "[Individual 1] is working for
law enforcement and we need her out if possible."
Facebook Messenger communication from GOLDY to
8 August 20, 2018 Individual 1, stating "You are killing me. Lol Though I do
expect some videos (more than 1) this time."
Facebook Messenger communication from GOLDY to
9 August 20, 2018
Individual 1, stating "We can meet anytime you want."
Facebook Messenger communication from GOLDY to
September 23,
10 Individual 1, stating "I'm still waiting on those videos
2018
remember. Lol"
Apple iMessage communication from GOLDY to the Case
November 6,
11 E Special Prosecutor, identifying Case E as "My cousin['s]
2019
trafficking case that's probably a possession."
Apple iMessage communications from GOLDY to the Case
E Special Prosecutor, asking about the status of an agreed
12 March 4, 2020 order for the release of Individual l's property and claiming
"[Individual l's] family is trying to get [the] car. Tow guy
wants like $2000. Crazv."

Each in violation of 18 U.S.C. §§ 1952(a)(3) and 2.

COUNT 13
18 U.S.C. § 666(a)(l)(B)

16. Paragraphs 1 through 12 of this Indictment are re-alleged and incorporated

by reference as if set forth fully herein.

17. In the one-year period from on or about January I, 2018 through on or

about December 31, 2018, the Commonwealth of Kentucky received benefits in excess of
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$10,000 from the United States government under federal programs involving grants,

contracts, subsidies, loans, guarantees, insurance, and other forms of Federal assistance.

18. On or about August 20, 2018, in the Eastern District of Kentucky, and

elsewhere,

RONNIE GOLDY

corruptly solicited and demanded for his own benefit and accepted and agreed to accept

things of value from Individual 1, intending to be influenced and rewarded in connection

with business, a transaction, and a series of transactions of the Commonwealth of

Kentucky, specifically including Rowan and Clark Counties, valued at $5,000 and more;

that is, the criminal matters of Individual 1 identified above as Cases A, C, and D.

All in violation of 18 U.S.C. § 666(a)(l)(B).

COUNT 14
18 U.S.C. § 666(a)(l)(B)

19. Paragraphs I through 12 and 17 of this Indictment are re-alleged and

incorporated by reference as if set forth fully herein.

20. On or about September 23, 2018, in the Eastern District of Kentucky, and

elsewhere,

RONNIE GOLDY

corruptly solicited and demanded for his own benefit and accepted and agreed to accept

things of value from Individual I, intending to be influenced and rewarded in connection

with business, a transaction, and a series of transactions of the Commonwealth of


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Kentucky, specifically including Clark County, valued at $5,000 and more; that is, the

criminal matter of Individual 1 identified above as Case D.

All in violation of 18 U.S.C. § 666(a)(l)(B).

A TRUE BILL

CARLTON S. SHIER,IV
UNITED STATES ATTORNEY
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PENALTIES

COUNTS 1-6: Not more than 20 years imprisonment, $250,000 fine, and 3
years of supervised release.

COUNTS 7-12: Not more than 5 years imprisonment, $250,000 fine, and 3
years supervised release.

COUNTS 13-14: Not more than 10 years imprisonment, $250,000 fine, and 3
years supervised release.

PLUS: Mandatory special assessment of $100 per count.

PLUS: Restitution, if applicable.

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