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UNITED STATES DISTRICT COURTRRK OF T JRT

SOUTHERN DISTRICT OF OfflQ .

EASTERN DIVISION ZIJI8MAY 17 PM 3: II4

UNITED STATES OF AMERICA,

Plaintiff,

vs.

DION ROOSVELT MCCLENDON

Defendant.

THE GRAND JURY CHARGES:

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CASE Nd40y[oiMi^7

INDICTMENT

18 U.S.C. § 1344(2)

18 U.S.C. § 1708

18 U.S.C. § 115(a)(1)(B) and (b)(4)

FORFEITURE ALLEGATION

COUNT 1

Attempted Bank Fraud

On or about December 18, 2017, in the Southern District of Ohio, Eastern Division,

defendant DION ROOSVELT MCCLENDON, did execute, and attempt to execute, a scheme

and artifice to defraud and to obtain money by means of false and fraudulent pretenses,

representations, and promises, from J.P. Morgan Chase Bank,a financial institutiondoingbusiness

in the State of Ohio insured by the Federal Deposit Insurance Corporation, in that defendant

presented a check in an amount of $2,100, forged with "Dion McClendon" as the payee, and

attempted to cash the check at Checksmart, 91 S. Hamilton Road, Whitehall, Ohio, 43213.

In violation of 18 U.S.C. § 1344(2).
COUNT 2

Possession of Stolen Mail

On or about February 28, 2018, in the Southern District of Ohio, Eastern Division,

defendant DION ROOSVELT MCCLENDON unlawfully received, concealed, and possessed

mail, to wit: approximately three checks, each of which defendant knew was stolen from an

authorized depository for mail matter.

In violation of 18 U.S.C. §§ U.S.C. 1708 and 2.

COUNT 3

Threats Against a Federal Law Enforcement Officer

On or about April 27, 2018, in the Southern District ofOhio, Eastern Division, defendant

DION ROOSVELT MCCLENDON did threaten to assault Timothy McCall, a federal law

enforcement officer, with the United States Postal Inspection Service, with the intent to impede,

intimidate, and interfere with him while he was engaged in and on account ofthe performance of

official duties, and with the intent to retaliate against Timothy McCall in retaliation for the

performance ofhis official duties.

In violation of 18 U.S.C. §§ 115(a)(1)(B) and (b)(4).

FORFEITURE ALLEGATION

1. The allegations contained in this Indictment are hereby realleged and incorporated

by reference for the purpose of alleging forfeitures to the United States.

2. Upon conviction ofthe offense alleged in Count 2 ofthis Indictment in violation of

18 U.S.C. § 1708, or a conspiracy to commit such offense, the defendant, DION ROOSVELT

MCCLENDON, shall forfeit to the United States of America, pursuant to 18 U.S.C.
§ 981(a)(1)(C) and 28 U.S.C. § 2461(c), any property, real or personal, constituting or derived

from proceeds obtained as a result ofsuch violation.

3. If any ofthe forfeitable property described above, as a result of any act or omission

ofthe defendant:

caiuiot be located upon the exercise ofdue diligence;

has been transferred or sold to, or deposited with, a third party;

has been placed beyond the jurisdiction ofthe court;

has been substantially diminished in value; or

a.

b.

c.

d.

e. has been commingled with other property which cannot be divided without

difliculty.

the United States of America, pursuant to 21 U.S.C. § 8S3(p) as incorporated by 28 U.S.C.

§ 2461(c), is entitled to seek forfeit any other property ofthe defendant up to the value ofthe above

forfeitable property.

Forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C), along with 28 U.S.C. § 2461(c), and

Rule 32.2 of the Federal Rules ofCriminal Procedure.

A TRUE BILL

s/FOREPERSON

BENJAMIN C. CLASSMAN

UNITED STATES ATTORNEY

J C.

JONATHAN J.C. GREY, (6292918-IL)

Assistant United States Attorney

FOREPERSON