IN THE SUPERIOR COURT OF PAULDING COUNTY STATE OF GEORGIA THE STATE OF GEORGIA INDICTMENT NOo?/- ¢.7 ~bba/33 "VERSUS DONALD RICHARD DONOVAN JANUARY TERM, 2021 CHRISTOPHER M. CARR, ATTORNEY GENERAL Count! Bribery, O.C.G.A. §16-10-2(a)(1) Count 2 Violation of Oath by Public Officer, 0.C.G.A. § 16-10-1 Counts 3-4 False Swearing, O.C.G.A. §16-10-71(a) WITNESS: Rocky Bigham, Assistant Special Agent in Charge Georgia Bureau of Investigation uF BILL NTary ‘son ‘This _17" day of. Faneusey _, 2021waives ent, list of witnesses, formal arraignment, and pleads: Deftadant ‘Defendants Atiomey Prosecuting Attorney This____day of 202_. ‘The Defendant _ copy of indictment, arraignment, and pleads: Defendant Defendant's Attomey Prosecuting Attomey This day of, 202.IN THE SUPERIOR COURT OF PAULDING COUNTY STATE OF GEORGIA THE GRAND JURORS selected, chosen, and sworn for the County of Paulding, to wit: 1, Jonathan Judson Ray - Foreperson 2. Lindsey Eugene Smith 14. Kenneth Richard Trezek 3. Natalie Michelle Louis 15. Valerie Nared Stone 4-—faytor Rashod-Brewer ‘}6—Rechebverie-Willeughby 5. Katherine Michelle Warren He-adeshe-Baitey Ettis~. 18. Lisa Ree Bruner 6 Dayanis Ruiz Chay Ke i 19. Rachel Elizabeth Altman 8. Corney McKenzie Gentry 30-Christie-K-Shepherd 9. Joy Lynn Young 21. Christina Marie Webb 10, Breanna Fox Roller 22. James Joseph Pitts IL. James Percy Young, Jr. 23. Andrea Chafin Morris 12. John Frederic Thomas, Jr, 2h~Bamalerkndree Alternate 13. Renee Heather Malinowski - Alternate Bo tore bee Hom Altprants 86. John Andrews Kirkwood in the name and behalf of the citizens of Georgia, charge and accuse DONALD RICHARD DONOVAN with the offense of BRIBERY, in violation of O.C.G.A. § 16-10-2(a)(1), for that the said accused, in the County of Paulding and the State of Georgia, on or about October 31, 2017, did give to Stefanie Burford, a person acting in her capacity as a prosecutor on behalf of the Municipal Court of the City of Cedartown, a political subdivision of the State of Georgia, a benefit to which she was not entitled, to wit: the submission of an order of nolle prosequi dismissing criminal charges then pending in Paulding County Superior Court against Alex Harrell, a client of the said Stefanie Burford acting in her capacity as a private attorney, with the purpose of influencing her in the performance of an act, to wit: her decision as Municipal Court Prosecutor regarding the disposition of criminal charges then pending against Jamie White, an employee of said accused’s office, said act being related to the funetion of the said Stefanie Burford’s office and employment as prosecuting attomey of the Municipal Court of the City of Cedartown , contrary to the laws of said State, the good order, peace, and dignity thereof:Count ro ‘The Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, further charge and accuse DONALD RICHARD DONOVAN with the offense of VIOLATION OF OATH BY PUBLIC OFFICER, in violation of 0.C.G.4. § 16-10-1, for that the said accused, in the County of Paulding and the State of Georgia, on or about October 31, 2017, while a public officer, did willfully and intentionally violate the terms of his oath as prescribed by law, to wit, O.C.G.A. § 15-18-2, contrary to the laws of said State, the good order, peave, and dignity thereof, as follows; Atal times relevant to this indictment, the accused was the District Attorney of the Paulding Judicial Circuit, a public officer. On or about December 18, 2014, said accused took the oath of Disttict: ‘Attomey. Said oath included, in part, the following language: “I, Donald Richard ‘Donovan, do swear (or affirm) that 1 will faithfully and impartially, and without fear, favor or affection, discharge my duties as DISTRICT ATTORNEY, and will take only my lawful compensation... So help me God,” On or about October 31, 2017, said accused violated the above. provision of his oath of District Attomey in that he committed the offense of bribery as set out in count one of this indictment and incorporated herein by reference. Count Three ‘The Grand Jurors aforesaid, in the name and behalf of the citizens of ‘Georgia, further charge and accuse DONALD RICHARD DONOVAN with the offense of FALSE SWEARING, in violation of O.C.G.A. § 16-10-71(a), for that the said accused, in the County of Paulding and the State of Georgia, on or about May 2, 2019, having been administered a lawful oath in the making of an affidavit, a matter other than a judicial proceeding, did knowingly and willfullymake a false statement, to wit, said accused denied ever having said that he wanted to have sex with Jamie White, contrary to the laws of said State, the good order, peace, and dignity thereof, Count Four ‘The Grand Jurors aforesaid, in the name and behalf of the citizens of Georgia, further charge and accuse DONALD RICHARD DONOVAN with the offense of FALSE SWEARING, in violation of O.C.G.A. § 16-10-71(a), for that the said accused, in the County of Paulding and the State of Georgia, on or about May 2, 2019, having been administered a lawful oath in the making of an affidavit, a matter other than a judicial proceeding, did knowingly and willfully make a false statement, to wit, said accused denied describing fantasies regarding his desire to be physical with Jamie White, contrary to the laws of said State, the good order, peace, and dignity thereof. CHRISTOPHER M. CARR ATTORNEY GENERALSPATE OF GEORGIA, COUNTY GE PAULDING SUPERIOR COURT CLERK'S OFFICE Tiexeby oxy atthe rego ata nd crest ‘opyol thecal evorted document(s) she sted sin sie = 5 ye Pat Cony, Get