UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

EUGENE DIVISION 

UNITED STATES OF AMERICA, 

Plaintiff, 

Case No. 6:15-CR- (l )>-- h-'{C 

INDICTMENT 

v. 

Count 1: Conspiracy to File Retaliatory Liens 

18 U.S.C. § 1521 

RONALD D. JOLING, and 

DORTHEA J. JOLING, 

Defendants. 

Count 2: Retaliatory Liens 

18 u.s.c. § 1521 

THE GRAND JURY CHARGES: 

INTRODUCTION 

At all times relevant to this indictment: 

1. RONALD D. JOLING and DORTHEA J. JOLING (hereinafter referred to collectively as 

"the JOLINGS") were husband and wife. 

2. The JOLINGS resided in the District of Oregon. 

3. In or about October 2011, the Grand Jury indicted the JOLINGS in the District of Oregon 

on various charges related to the payment of taxes. 

4. In or about November 2012, the Court assigned the case against the JOLINGS to Chief 

United States District Judge Ann Aiken. Chief Judge Aiken then presided over the trial 

of United States v. Joling eta/., 6: 11-cr-60 131-AA, in or about October 2014. 

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5. United States Magistrate Judge Thomas M. Coffin was the Magistrate Judge assigned to 

the case. 

6. Mary L. Moran served as the Clerk of Court. 

7. The United States Attorney's Office for the District of Oregon prosecuted the case. 

8. S. Amanda Marshall served as the United States Attorney for the District of Oregon. 

9. Assistant United States Attorney Scott E. Bradford served as the lead prosecutor in the 

case. 

COUNT I 

(Conspiracy to File Retaliatory Liens) 

10. From on or about August 15, 2013 through on or about February 26, 2014, in the District 

of Oregon and elsewhere, the defendants, RONALD D. JOLING and DORTHEA J. 

JOLING, knowingly conspired with each other and with others, known and unknown to 

the Grand Jury, to file false liens and encumbrances in public records against the real and 

personal property of officers and employees of the United States (the "individual 

victims") on account of the officers' and employees' performance of official duties, 

knowing and having reason to know that such liens and encumbrances were false and 

contained materially false, fictitious, and fraudulent statements and representations. In 

order to effect the object of the conspiracy, the JOLINGS had the false liens and 

encumbrances and other documents related thereto, including a "Notice of Security 

Interest with Intent to Perfect," prepared and mailed to the individual victims in Oregon, 

or filed in the public record, including The Sentinel newspaper in Coquille, Oregon, or in 

a private record which is generally available to the public on the internet. 

In violation ofTitle 18, United States Code, Section 1521. 

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COUNT2 

(Retaliatory Liens) 

11. On or about February 25, 2014 through February 26, 2014, in the District of Oregon, the 

defendants, RONALD D. JOLING and DORTHEA J. JOLING, attempted to file and 

filed in the public records of the State of California, via the California Secretary of 

State's website, false liens and encumbrances against the real and personal property of 

each of the following individual victims, all of whom are officers or employees of the 

United States government: (1) ChiefUnited States District Judge Ann Aiken; (2) United 

States Magistrate Judge Thomas M. Coffin; (3) Clerk of Court Mary L. Moran; (4) 

United States AttorneyS. Amanda Marshall; and (5) Assistant United States Attorney 

Scott E. Bradford. Knowing and having reason to know that the liens and encumbrances 

were false and contained materially false, fictitious, and fraudulent statements and 

representations-including a false statement that the individual victims owed the 

JOLINGS $100,003,000.00-the JOLINGS filed the false liens and encumbrances 

against the individual victims on account of the performance of their official duties 

relating to the criminal case United States v. Joling et al., 6: 11-cr-60131-AA. 

In violation of Title 18, United States Code, Section 1521. 

u., u 

Dated this 1! day of rv~a rCJJ 2015. 

A TRUE BILL. 

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Presented by: 

S. AMANDA MARSHALL 

United States Attorney 

~OLSON Assistant United States Attorney 

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