Case 2:15-cr-00109-RAJ-RJK Document 37 Filed 10/14/15 Page 1 of 4 PageID# 77

FILED

IN OPEN COURT

OCT 1 4 2015

IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA
NORFOLK DIVISION

CLERK, U.S. DISTRICT COURT

NORFOLK. VA

UNITED STATES OF AMERICA

v.

Criminal No. 2:15crl 09

DONALD G. MCMANUS,
Defendant.
STATEMENT OF FACTS

By signing below, the parties and their respective counsel agree that if this case had gone
to trial, the government's evidence would have established the following facts beyond a
reasonable doubt:

1.

In or about February 2015, Donald G. McManus, the defendant, was an active duty

member of the United States Navy stationed on board the USS GEORGE H.W. BUSH (CVN 77)
(hereinafter, USS BUSH).
2.

The USS BUSH is a United States Naval warship owned by the United States of

America. At the times pertinent to the events below, the USS BUSH was located within the
Eastern District of Virginia and, specifically, at Naval Station Norfolk, Virginia.
3.

The defendant is at the time of this agreement, and was during the month of February

2015, married to Breanna L. McManus. From on or about February 18,2015, and continuing to
on or about February 23, 2015, the defendant entered into a conspiracy with his co-defendant and
wife, Breanna L. McManus, to possess with intent to distribute and to distribute a detectable
amount of heroin to another sailor on board the USS BUSH in exchange for U.S. currency.

4.

While on a restricted status, in February 2015, the defendant approached a shipmate and

offered to sell heroin to her. The shipmate accepted the defendant's offer. The defendant called

til

Case 2:15-cr-00109-RAJ-RJK Document 37 Filed 10/14/15 Page 2 of 4 PageID# 78

his co-defendant, Breanna McManus, who brought heroin on board the USS BUSH. The
defendants then led the female sailor to a secure space in the air wing on board the USS BUSH

where all three of them proceeded to inject heroin into their bodies. On a second occasion

during the conspiracy, the defendants led the female sailor to a secure space in the air wing on
board the USS BUSH and used heroin again. The female sailor paid approximately $150 to the
defendants in exchange for heroin.

4.

On February 23,2015, a few days after purchasing heroin from the defendants, the

female sailor went into a heroin overdose on board the USS BUSH. An uninvolved sailor

stationed on board the USS BUSH found the female sailor unresponsive on the floor close to her

sleeping quarters. The sailor called the USS BUSH's medical clinic and informed clinic
personnel of the situation. The ship's medical response team provided immediatecare until
civilian Emergency Medical Technicians arrived on scene. The female sailor was without a

pulse for approximately 14 minutes until she was revived.

5.

The acts taken by the defendant in furtherance of the offense charged in this case,

including the acts described above, were done willfully and knowingly with the specific intent to
violate the law. The defendant acknowledges that the foregoing statement of facts does not
describe all of the defendant's conduct relating to the offenses charged in this case, nor does it
identify all of the persons with whom the defendant may have engaged in illegal activities. The
defendant further acknowledges that he is obligated under his plea agreement to provide

additional information about this case beyond that which is described in this statement of facts.

cv
^

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Respectfully submitted,
Dana J. Boente

United States Attorney

John F. Butler
/Special Assistant United States Attorney
United States Attorney's Office
101 W. Main Street, Suite 8000
Norfolk, Virginia 23510
(757)441-6331

john.f.butler@usdoj.gov

Case 2:15-cr-00109-RAJ-RJK Document 37 Filed 10/14/15 Page 4 of 4 PageID# 80

After consulting with my attorney and pursuant to the plea agreement entered into this

day between the defendant, DONALD G. MCMANUS, and the United States, I hereby stipulate
that the above Statement of Facts is true and accurate, and that had the matter proceeded to trial,
the United States would have proved the same beyond a reasonable doubt.

Ddnal
nald G. McManus

I am DONALD MCMANUS' attorney. I have carefully reviewed the above Statement of

Facts with him. To my knowledge, his decision to stipulate to these facts is an informed and
voluntary one.

Kirsten R. Kmet, Esq.

Counsel for Defendant

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