Conspiracy, Deprivation of Rights, Destruction of Records Indictment
Conspiracy, Deprivation of Rights, Destruction of Records Indictment
Conspiracy, Deprivation of Rights, Destruction of Records Indictment
FOR THE
NORTHERN DISTRICT OF CALIFORNIA
Mark B. Busby
CLERK, U.S. DISTRICT COURT
UNITED STATES OF AMERICA, NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO
V.
MORTEZA AMIRI,
ERIC ALLEN ROMBOUGH, and
DEVON CHRISTOPHER WENGER
DEFENDANT(S).
INDICTMENT
A true bill.
_________________________________.
August
____________________________________________
Brittany Sims, Clerk
____________________________________________
__________________________Bail, $ _____________
NO BAIL
Hon. Magistrate Judge Lisa J. Cisneros
1 ISMAIL J. RAMSEY (CABN 189820)
2
United States Attorney FILED
3 Aug 16 2023
4 Mark B. Busby
5 CLERK, U.S. DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
6 SAN FRANCISCO
7
10 OAKLAND DIVISION
18 INDICTMENT
19 The Grand Jury charges:
20 Introductory Allegations
21 At all times relevant to this Indictment, except where otherwise stated:
22 1. The Antioch Police Department (“APD”) was the police department for the city of
23 Antioch, located in the Northern District of California. The APD and its officers were charged with the
24 duty of enforcing the Constitution and laws of the State of California in accordance with the
25 Constitution and laws of the United States. APD formed the Problem-Oriented Policing (POP) team in
27 2. Defendant Morteza AMIRI was employed as a police officer with APD beginning in
28 approximately November 2017. In 2018, AMIRI was partnered with police service dog (K9) “Purcy”
INDICTMENT
1 and assigned to APD’s Canine Unit. Between approximately March 2019 and November 2021, AMIRI
2 deployed K9 Purcy to bite at least 28 subjects in and around Antioch. In early 2022, APD temporarily
4 3. Defendant Eric Allen ROMBOUGH was employed as a police officer with APD
5 beginning in approximately February 2017. ROMBOUGH also held assignments on APD’s SWAT
6 team, Gang Unit, and Problem-Oriented Policing (POP) team. ROMBOUGH served as an operator of
7 the 40mm less lethal launcher in each of these assignments. In less than one year between November
8 2020 and August 2021, ROMBOUGH deployed the 40mm less lethal launcher to shoot at least eleven
9 subjects in and around Antioch. In early 2022, ROMBOUGH resigned from the Gang Unit and the
10 SWAT team.
11 4. Devon Christopher WENGER was employed as a police officer with APD beginning in
14 5. APD disseminated a Policy Manual for which all its employees, including APD officers,
15 were responsible for knowing and understanding the policies and procedures contained within. APD’s
16 Policy Manual contained policies on Use of Force (Policy 300), which identified in relevant part, among
17 other things:
18 a. Duty to intercede (300.2.1): “Any officer present and observing another law
19 enforcement officer or an employee using force that is clearly beyond that which is necessary, as
22 b. Duty to report excessive force (300.2.3): “Any officer who observes a law
23 enforcement officer or an employee use force that potentially exceeds what the officer
27 considering officer and public safety, employ de-escalation techniques to decrease the likelihood
28 of the need to use force during an incident and to increase the likelihood of voluntary compliance
INDICTMENT 2
1 and/or peaceful resolution”, effective no later than January 2021;
3 e. Reporting the use of force (300.5): “Any use of force by a member of this
6 6. APD’s Policy Manual also contained policies on specific applications of force, including
7 Canines (Policy 311), applicable to police canines, and Kinetic Energy Projectile Guidelines (Policy
11 a. Personally owned PCD (701.5): “Members may carry a personally owned PCD
12 while on-duty, subject to the following conditions and limitations: … (d) The device should not
13 be used for work-related purposes except in exigent circumstances (e.g., unavailability of radio
14 communications). … (e) The device shall not be utilized to record or disclose any business-
17 Department”.
18 8. AMIRI and other APD officers received K9 training while assigned to APD’s Canine
19 Unit. For example, AMIRI reported receiving over hundreds of hours of K9 basic and maintenance
20 training courses between 2018 and 2021. Such training covered APD policies and proper deployment,
21 i.e., when it is appropriate to deploy a police canine, and relevant legal standards.
22 9. AMIRI, ROMBOUGH, WENGER, and other APD officers received 40mm less lethal
23 training and qualification while employed at APD. This training covered relevant APD policies,
24 nomenclature and munitions, recommended target areas, announcements, documentation, and other
25 topics. Among other things, the training advised APD officers that certain areas of the body are
26 “potentially lethal” when targeted by the 40mm less lethal launcher, including the head, neck, portions
27 of the chest, groin area, and portions of the back and lower back.
28
INDICTMENT 3
1 The Scheme to Violate Civil Rights
3 (“Defendants”) conspired and agreed together and with each other, and with others known and unknown
4 to the Grand Jury, to injure, oppress, threaten, and intimidate residents of Antioch, California and the
5 Northern District of California in the free exercise and enjoyment of rights secured to them by the
6 Constitution or laws of the United States, that is, to be free from the use of unreasonable force by a law
7 enforcement officer.
10 11. As part of the scheme to violate civil rights, Defendants communicated with one another
11 and with others known and unknown to the Grand Jury about their actual and intended uses of force,
12 including about specific violent acts that constituted excessive uses of force by a police officer against
14 12. As a further part of the scheme, Defendants agreed with one another and with others
15 known and unknown to the Grand Jury to carry out such violent acts against individuals in and around
16 Antioch even where the force was excessive, knowing that certain of their actions were excessive uses
20 and with others known and unknown to the Grand Jury after specific deployments of excessive force and
21 touted their applications of force, including in the communications identified in this Indictment.
22 14. As a further part of the scheme, after each canine deployment of K9 Purcy, AMIRI
23 captured photographs and videos of each subject’s injuries from the corresponding dog bite. While APD
24 required official documentation of injuries from such uses of force, AMIRI captured additional
25 photographs and shared them on his personal cell phone with individuals and officers not involved with
26 the incident, contrary to APD policy. For example, following a deployment of K9 Purcy to bite a
27 subject on December 19, 2019, AMIRI stated: “I’m gonna take more gory pics. gory pics are for
INDICTMENT 4
1 15. After each bite, AMIRI also messaged multiple recipients from his personal cell phone,
2 including in some instances ROMBOUGH and WENGER, about the bite, often with a consecutive
3 number memorializing the number of dog bites he had accumulated up to that point (for instance, “bite
4 #1”, “#2”, “just got #3”, “#4 on fire rn.. lol”, “#5 this morning”, “Purcy #6”, etc., through “#28”) along
5 with photographs and/or videos of each subject’s injuries, contrary to APD policy.
6 16. As a further part of the scheme, after ROMBOUGH’s deployment of the 40mm less
7 lethal launcher, he likewise secured photographs of the subject’s injuries. While APD again required
8 official documentation of such injuries, ROMBOUGH shared photographs of the injuries on his
9 personal cell phone with officers who were not otherwise involved with the incident and other
11 17. ROMBOUGH also collected the spent 40mm munitions following each deployment and,
12 instead of disposing or processing them, kept them for himself. ROMBOUGH collected the spent
13 munitions to create a display; specifically, he told others at APD that he was collecting munitions for
14 “the mantle” and creating a trophy “flag,” that is, in which the munitions were used among the stars and
16 18. As a further part of the scheme, Defendants deployed uses of force as “punishment” to
17 subjects beyond any punishment appropriately imposed by the criminal justice system, and/or made
21 19. As a further part of the scheme, Defendants also concealed and hid, and caused to be
22 concealed and hidden, the acts done and the purpose of the acts done in furtherance of the scheme,
25 authored police reports containing false and misleading statements to suggest that the force they
26 used was necessary or justifiable. In truth and in fact, and as Defendants well knew, Defendants
27 willfully used excessive force in numerous incidents, including those identified in this
28 Indictment.
INDICTMENT 5
1 b. Upon learning of each other’s participation in incidents involving violent acts that
3 declined to intercede and/or report the incidents to APD superiors, including as required by APD
4 policies. Instead, Defendants encouraged one another to continue the scheme to deprive the
7 20. Beginning in or about 2019, Defendants discussed with one another their plans and
8 intentions to deploy force against, and inflict harm upon, individuals in and around Antioch, including
9 through excessive uses of force. Such communications include those set forth below and elsewhere in
10 this Indictment.
11 21. For instance, AMIRI and ROMBOUGH exchanged the following messages on February
12 12, 2019 about “fuck[ing] some people up” and “hopefully get[ing] [AMIRI] a bite”:
27
28 1
See Cal. Vehicle Code § 10851 (theft of a vehicle); 2800 (disobeying a peace officer).
INDICTMENT 6
1 23. As an additional example, AMIRI and ROMBOUGH exchanged the following
15 AMIRI: sorry for the delay bro. had a mess on sycamore i was
cleaning. copy just read it all
16
ROMBOUGH: Lol what did you get?
17 Gorillas
27
28 2
Police Code 11-83 refers to a traffic accident.
INDICTMENT 7
1 AMIRI: surprised you didn’t use force on the bank burglar!
25 //
26 //
27
28 3
California Penal Code 211 prohibits robbery.
INDICTMENT 8
1 i took an SUV since he can’t fit in my car and i don’t
have a door pop for this car so he opened my door and
2 sent purcy in for a bite
3 [IMG_6207] [IMG_6213]
5 d. At about 8:17 a.m., AMIRI sent Officer-3, a police officer from a neighboring
6 police department, “Purcy #6 …” and a photograph from the incident, and stated the following:
7 AMIRI: this one was different... i had a lateral ride along (my
roommate) and i was driving someone else’s car so my
8 door pop wasn’t matched up... sooo i had my ride along
open my door 😂😂
9
i did not mention that in the report
10
Officer-3: Wow lol
11
AMIRI: hey we made it work lo 😂😂
12
Officer-3: Nice good job
13 What cut the dogs face?
15 30. Shortly thereafter, at about 9:14 a.m., AMIRI exchanged the following messages with his
16 roommate, Officer-1, remarking that the incident was a “weak ass 69” and “stretch of a 69” in reference
17 to California Penal Code 69 (resisting an officer) and explaining how he would get out of “go[ing] to
27 31. Following this incident, AMIRI authored a police report that differed from the
28 description AMIRI privately provided to others in his text messages, including that the report made no
INDICTMENT 10
1 ROMBOUGH: Fuck I just want to punch the shit out of someone lol
2 AMIRI: do it bro
4 AMIRI: the guy i bit today was proned out. no fucks given. you
don’t take us on a high speed and rob people and gun
5 point and crash into cars during a footbail and just give
up... bite on
6
ROMBOUGH: Lol agreed
7
AMIRI: I hate not having you on the streets with me
8
ROMBOUGH: i know bro. not even the same
9
c. The next day, on December 20, 2019 at about 8:57 a.m., AMIRI exchanged text
10
messages with Officer-6, a police officer at a neighboring police department. AMIRI sent
11
photographs and a video, requesting he “don’t share the video lol” and referring to the bite as
12
“the real punishment compared to the soft DA” (District Attorney):
13
AMIRI: #10
14 armed robbery with a pursuit to a foot bail to a bite
15 Officer-6: Nice work! Damn Purcy likes going for the armpit,
looks so painful lol
16
AMIRI: haha yea idk what’s with the armpit bites lol
17 IMG_8597.MOV
don’t share the video.. lol
18
Officer-6: I don’t share anything lol not even the pics bro! It’s
19 good that even though the laws don’t keep them in jail
they still get fucked up by the dog
20
AMIRI: haha i know right. i feel like this is the real punishment
21 compared to the soft DA
22 34. Following this incident, AMIRI authored a police report that differed from the
24
26 35. On May 6, 2020, APD officers, including AMIRI and ROMBOUGH, planned an
27 operation to arrest wanted individuals in Antioch, including X.B. At about 8:35 a.m., AMIRI and
INDICTMENT 12
1 AMIRI: yea [X.B.] was trying to take it down last night
5 36. AMIRI and ROMBOUGH rode together during this operation, as they described in text
9 37. At about 11:20 a.m., AMIRI’s K9 Purcy bit X.B. and ROMBOUGH assisted with
10 X.B.’s arrest. After the arrest, AMIRI sent numerous individuals photographs, a video, and/or a
11 description of the bite. At about 1:38 pm AMIRI and WENGER exchanged the following text
12 messages:
23 39. On May 11, 2020, AMIRI sent a video excerpt showing K9 Purcy’s bite of X.B. to
25
27 40. On August 21, 2020 at about 11:23 p.m., AMIRI and WENGER assisted Agency-1 with
28 the pursuit of a subject. AMIRI deployed K9 Purcy to bite the subject. About an hour later, at about
INDICTMENT 13
1 12:35 a.m., AMIRI exchanged the following text messages with WENGER:
2 AMIRI: if [Agency-1] didn’t have all those body cams and that
was us… we would have fucked him up more. He
3 didn’t get what he deserved
4 WENGER: I agree
That’s why I don’t like body cams
5
AMIRI: Emphasized “That’s why I don’t like body cams”
6
41. WENGER later sent the following messages at about 6:25 p.m. on August 22, 2020:
7
WENGER: We need to get into something tonight bro!! Lets go 3
8 nights in a row dog bite!!!
13 vehicle stop of another subject in Antioch, in which the subject was pulled from the vehicle and taken to
14 the ground. At about 7:06 p.m., AMIRI sent the following text message to WENGER, followed by a
15 photograph of the subject with injuries several hours later: “hahaha. [the subject] style”.
16 43. The next day, on August 23, 2020, officers from a neighboring agency Agency-2 initiated
17 a traffic stop of a vehicle containing a subject, later identified as D.R., that led them on a chase to a
18 transient encampment. After D.R. entered the encampment, the officers formed a perimeter. At about
19 7:25 p.m., AMIRI was dispatched to assist with apprehending D.R., known to him as a “car thief.” K9
20 Purcy located D.R. in a tent and bit him in the back, injuring him.
21 44. After the incident, AMIRI sent numerous individuals photographs, a video, and/or a
23 a. At about 8:47 p.m. that day, AMIRI sent WENGER multiple images of D.R. and
25
26
27
28
INDICTMENT 14
1 AMIRI: Loved “Fuck the mother fucking yes”
3 AMIRI: hell yea bro. ill find some shit. ill write it. just come
over and crush some skulls alongside purcy. ill handle
4 the rest lol
5 c. The day following the arrest of D.R. at about 1:12 p.m., AMIRI sent images of
8 ROMBOUGH: Turd
15 Hahaha
16 45. Following this incident, AMIRI authored a police report that differed from the
18
19 October 8, 2020: AMIRI Assaults M.Z.
20 46. On October 8, 2020 at about 6:41 a.m., AMIRI messaged ROMBOUGH, “tell [Agency-
22 47. Later that day at about 8:06 p.m., AMIRI sent text messages on his personal cell phone
23 to on-duty APD officers about M.Z., a transient individual in Antioch. AMIRI wrote the following to
24 the on-duty officers in a group text, including WENGER, Officer-7, and Officer-8, accompanied with
25 photographs of M.Z.:
26 AMIRI: [M.Z.]
28 4
APD officers referred to “code” in this context as buying a fellow officer a beverage or meal.
INDICTMENT 16
1 mail and was trying to open accounts under my name.
2 48. Among responses in the group text, WENGER responded at about 8:12 p.m.:
19 AMIRI: few months ago. i tracked him down and dragged him
to the back of a car to “discuss” the matter
20
Officer-9: Yikes
21
“Officer [Officer-9] how long did you know Officer
22 Amiri and in the course of your friendship did you ever
know him to act under color of authority ”
23
AMIRI: lol putting a pistol in someone’s mouth and telling them
24 to stop stealing isn’t illegal... it’s an act of public
service to prevent further victims of crimes
25
26 //
27 //
28 //
INDICTMENT 17
1 ROMBOUGH’s Uses of Force, Including 40mm Deployments and Communications about Them
2 54. On October 10, 2020, ROMBOUGH described violating civil rights to other APD
3 officers in relation to his police work and use of the 40mm less lethal launcher, including Officer-1,
7 55. On November 11, 2020, ROMBOUGH again referenced the violation of civil rights in
8 messages to other APD officers, including Officer-1, Officer-10, Officer-12, and others:
11
12 February 9, 2021: ROMBOUGH Deploys 40mm Less Lethal Launcher at R.C. [21-1103]
13 56. On February 8, 2021, AMIRI and ROMBOUGH exchanged the following messages
23 57. The next day, on February 9, 2021 at about 6:30 a.m., APD officers executed a search
24 warrant at a residence in Antioch. While inside the residence, ROMBOUGH and Officer-4 identified
25 R.C. outside a sliding door. ROMBOUGH deployed the 40mm less lethal launcher at R.C., injuring
26 him in the lower back area. ROMBOUGH and other APD officers had previously received instruction
27 during annual training that this area was a “potentially lethal” area of the body to avoid deploying the
28 40mm.
INDICTMENT 18
1 58. After the incident at about 8:48 a.m., ROMBOUGH sent numerous individuals
2 photographs of the injury, including Officer-13, stating “And another one got 40d”. At about 8:54 a.m.,
6 59. One day later, on February 10, 2021 after conducting another operation in Antioch in
7 which APD officers did not deploy a canine or 40mm less lethal launcher, AMIRI and ROMBOUGH
18 60. The next month, ROMBOUGH had multiple conversations about making progress on a
19 trophy “flag”, that is, in which he collected spent 40mm munitions and would use them among the stars
20 and stripes of the flag to commemorate his 40mm deployments on individuals in and around Antioch.
21 For instance, on March 5, 2021, ROMBOUGH exchanged messages with Officer-13 about events the
22 prior day in which ROMBOUGH “had the forty” and someone “almost got plugged”, stating “It’s been
23 fun”:
26 61. Likewise, following his 40mm deployments on two subjects on the same day, March 31,
27 2021, ROMBOUGH exchanged messages with Officer-14, who served as law enforcement with
28 another agency, about “taking down a second [] suspect and he got 40d too”:
INDICTMENT 19
1 Officer-14: 🤣🤣
That 40 flag is coming along!! Murica!!
2
ROMBOUGH: Liked “That 40 flag is coming along!! Murica!!”
3
4 May 5, 2021: ROMBOUGH Deploys 40mm Less Lethal Launcher at L.R. [21-3574]
5 62. On April 14, 2021 at about 10:47 a.m., ROMBOUGH and AMIRI exchanged the
6 following messages:
8 AMIRI: lmao
typical rambo
9
ROMBOUGH: Maybe tomorrow lol
10 Or at least 40d
11 63. Several weeks later, on May 5, 2021 at about 10:22 a.m., APD officers—including
12 ROMBOUGH—responded to a report that transients were living inside a privately-owned unit. While
13 responding, ROMBOUGH and Officer-10 located L.R. and another female individual laying on a bed
14 inside a room. ROMBOUGH deployed the 40mm less lethal launcher at L.R., injuring L.R. in the chest
15 and knocking him off the bed. ROMBOUGH and other APD officers had previously received
16 instruction during annual training that this area was a “potentially lethal” area of the body to avoid
18 64. Following this incident, ROMBOUGH authored a police report that differed from the
19 accounts that other APD officers later provided. ROMBOUGH later stated that he deployed the 40mm
20 less lethal launcher because L.R. was refusing commands and pretending to be asleep while a liquor
22 65. At about 1:40 p.m. that day, AMIRI sent a video captured from Instagram captioned
23 “Officer damages private property while executing a search warrant” of an unknown uniformed police
24 officer looking around, then repeatedly slamming a door into the side of a car parked inside of a private
25 garage to ROMBOUGH, with the message “you 😂😂” at about 1:41 p.m.; ROMBOUGH responded
26 “Lmao”.
27
5
28 APD records indicate that ROMBOUGH completed five hours of training this day on “Arrest
and Control” and two hours on “Wellness Presentation”.
INDICTMENT 20
1 66. AMIRI also sent the same video to Officer-1, and their exchange followed:
7 Officer-1: No 😂😂
8 AMIRI: jesus lol
14 67. Despite AMIRI’s conversation with Officer-1 about L.R. not “deserving” getting shot by
15 ROMBOUGH with a 40mm less lethal launcher, the next day, on May 6, 2021 at about 1:56 p.m.,
16 AMIRI sent ROMBOUGH a screenshot of another conversation containing a photograph of the two
17 officers and AMIRI’s subsequent commentary about “true love”, excerpted as follows:
18
19
20
21
22
23
24
25
26
27
28 6
California Penal Code 602 prohibits trespassing, a misdemeanor offense.
INDICTMENT 21
1
68. Less than two weeks later, on May 14, 2021, in reference to the potential deployment of
2
the 40mm less lethal launcher at another individual, ROMBOUGH stated “Lmao add him to the
3
mantle”.
4
69. The next month, ROMBOUGH and AMIRI exchanged the following messages on June
5
13, 2021, referencing “dog bite and 40 deployment”:
6
ROMBOUGH: You working?
7
AMIRI: yea
8 40 mins until the weekend
14
15 August 24, 2021: ROMBOUGH Deploys 40mm Less Lethal Launcher at J.W. [21-6399]
16 70. On July 27, 2021, AMIRI sent ROMBOUGH a screenshot of an email from APD
17 leadership stating “the new BWC [body-worn camera] and MVAR policies are effective immediately,
18 and the use of these devices should start at the beginning of the next scheduled shift.” The next day,
19 ROMBOUGH stated “Yeah over it bro” and “Can’t wait to retire”. AMIRI responded, “over it lmao”.
20 71. On August 5, 2021, AMIRI and ROMBOUGH exchanged the following messages:
25 72. On August 24, 2021, at about 6:08 a.m., APD officers—including ROMBOUGH and
27 individuals exited the residence after officers made announcements. Officers then entered the residence,
28 locating J.W. inside a locked bedroom holding a video game controller while sitting on an air mattress,
INDICTMENT 22
1
9 77. On September 20, 2021, Officer-12, a Sergeant, wrote the following to ROMBOUGH
11 Officer-12: You write that he didn’t comply but he clearly had his
hands up at first. You need to describe way better what
12 happened. He was ordered to put his hands on his head.
He didn’t do this. What did he do instead? (Leaned to
13 his right. Arm appeared to be reaching behind bed once
[Officer-4] grabbed him)
14
15 78. Following this incident, ROMBOUGH authored a police report that differed from the
17
18 August 31, 2021: ROMBOUGH Deploys 40mm Less Lethal Launcher at S.S. [21-7391]
19 79. On August 31, 2021, at about 2:50 p.m., APD officers—including ROMBOUGH,
20 AMIRI, Officer-10, and Officer-15—conducted a traffic enforcement stop of S.S. in Antioch. During
21 the encounter, which was captured on body-worn camera, at least five APD officers surrounded S.S.’s
22 vehicle and AMIRI called out “If you do not comply, you will be 40’d or bit by the dog.” As officers
23 called out commands, S.S. exited his vehicle with his hands raised, turned around and backed toward the
24 officers, and placed his hands on his head. As Officer-10 took S.S.’s hands, Officer-10 brought S.S. to
25 the ground; ROMBOUGH immediately approached and deployed the 40mm less lethal launcher at S.S.,
26 injuring him.
27 80. ROMBOUGH later reported that this deployment of the 40mm, as captured on body-
INDICTMENT 24
1 AMIRI: you get 4 tubs yesterday, make some arrests then 40
someone today?? who the fuck are you?? i love this
2 wenger 😂😂
3 WENGER: #Newyearnewme
Hahah jk
4 Just trying to get on swat bro! [. . .]
9 88. The next month, AMIRI and ROMBOUGH exchanged the following messages on
17 89. Paragraphs 1 through 88 of this Indictment are re-alleged and incorporated herein.
18 90. Beginning on a date unknown, but no later than approximately February 2019 and
19 continuing through approximately March 2022, in the Northern District of California, the defendants,
20 MORTEZA AMIRI,
ERIC ALLEN ROMBOUGH, and
21 DEVON CHRISTOPHER WENGER,
22 did knowingly and willfully conspire and agree together and with each other, and with others known and
23 unknown to the Grand Jury, to injure, oppress, threaten, and intimidate residents of Antioch, California
24 and the Northern District of California in the free exercise and enjoyment of rights secured to them by
25 the Constitution or laws of the United States, to be free from the use of unreasonable force by a law
26 enforcement officer, all in violation of Title 18, United States Code, Section 241.
27 //
28 //
INDICTMENT 27
1 COUNT NINE: (18 U.S.C. § 1519 – Destruction, Alteration, and Falsification of Records in
Federal Investigations)
2
3 93. Paragraphs 1 through 31 of this Indictment are re-alleged and incorporated as if fully set
4 forth here.
5 94. On or about July 24, 2019, in the Northern District of California, the defendant,
6 MORTEZA AMIRI,
7 did knowingly alter, destroy, mutilate, conceal, cover up, falsify, and make a false entry in any record,
8 document, and tangible object, to wit, the Antioch Police Department incident report regarding the arrest
9 of A.A., with the intent to impede, obstruct, and influence the investigation and proper administration of
10 any matter within the jurisdiction of the Federal Bureau of Investigation, an agency of the United States,
11 and in relation to or contemplation of any such matter or case, in violation of Title 18, United States
13
15
16 /s/
FOREPERSON
17 San Francisco, California
18
ISMAIL J. RAMSEY
19 United States Attorney
20
/s/
21 ERIC CHENG
AJAY KRISHNAMURTHY
22 ALETHEA SARGENT
Assistant United States Attorneys
23
24
25
26
27
28
INDICTMENT 29