FBI SPECIAL AGENT Scott Bowman Indictment

7/25/2019 FBI SPECIAL AGENT Scott Bowman Indictment

1/21

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

F IL EO

?U\5

JU

N 3 PM :

43

..,

< < ) \

IP

T

C: D\,/ I I '

c . .

t .

l .

1

L - L. . .

' /

-

--

--

----

UNITED STATES

DISTRICT COURT

FOR THE CENTRAL DISTRICT

OF CALIFORNIA

September

UNITE

D STATES OF AMERICA,

P l a i n t i f f

v .

SCOTT

M.

BOWMAN

Defendant .

The

Grand

Jury

charges :

I N D I C T M E N T

[18 U. S.C. 654: Convers ion of

Proper ty by a

Federa

l

Off

i

cer or

Employee; 18 U.S . C. 1512(c) (2) :

Obst ruc t ion

of J

u s t

i ce; ~ U.S.C.

1957

:

Money Laundering;

18

u:s.c. 1

519: Des t ruc t ion

Alte ra t ion o r Fa l s i f i c a t i on of

Records; 18

U.

S.C. 1512

(b)

(3) :

W

tness

Tamper

i

ng;

18

U.S.C

.

981 (a) (1) (C), 28 U.S.C.

2461(c) , 21 U.S.C.

853(p):

Cr iminal Forfe

i

ture]

[UNDER S E L ]

GENERAL

ALLEGATIONS

1 . Beginning in

o r

around

March

2005

and

con t inu ing through in

o r

around March

2015, the defendan t Scot t M.

Bowman, was a Special

Agent

of the

Federa l Bureau of Inves t iga t ion ( FBI ) .

As

an FBI

Specia l Agent, the defendant was en t rus ted with

the

i

nves t iga t ion

of

federa

l

cr imina l

of fenses

was au thor ized to

ca r ry

a

f i rearm

and was


2/21

1

2

3

4

5

6

7

8

9

10

1 1

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

empowered

to

make

a r re s t s

and to conduct searches and se izures

in

fur therance

of

h i s

duty

to enforce f edera l cr imina l law.

2. Beginning

in

o r

around

2006, and

con t inu ing un t i l

in

o r

around October

2014,

the

defendant was

ass igned

to

the

Gang

Impact

Team

( GIT ), a

j o in t

fede ra l - s ta te

t a sk

fo rce

based in San

Bernardino ,

Cal i fo rn ia which i s

respons ib le

fo r inves t iga t ing

gang

r e l a t e d cr imina l offenses in

the

grea te r Los Angeles area . As a

member of the

GIT t a sk fo rce the defendant

was respons ib le for

the

execu t ion

of

f edera l and

s t a t e

search

warrants

in the Centra l

D i s t r i c t of Cal i fo rn ia as well

as

the se izu re documentat ion,

t ranspor t a t ion

and

preservat ion of

evidence

se ized

dur ing

the

execu t ion of

f edera l and

s t a t e search warrants .

3

In

o r

around May

and

June

2014,

the

defendant ,

along

with

o ther GIT t a sk fo rce of f i c e r s p a r t i c i p a t e d in

the

inves t iga t ion of

a

s ign i f i c a n t Los Angeles-area methamphetamine d i s t r i bu t ion

organizat ion .

During the course of t h i s i nves t iga t ion

on

or about

June

13,

2014,

in Azusa, Cal i fo rn ia a member

of

GIT obta ined United

Sta tes

cur rency

se i zed

from

the persons of two indiv iduals bel ieved

to

be

involved

in methamphetamine

d i s t r i b u t i o n

ac t i v i t y .

Addi t iona l ly

on o r about

June

14, 2014,

the

defendant and

other

GIT

t a sk force

of f i ce r s

pa r t i c ipa t e d in the execu t ion of a

s t a t e

search

warrant a t a ho te l room

in

Azusa,

Cal i fo rn ia which was

bel ieved to

conta in

evidence

of methamphetamine d i s t r i bu t i on ac t i v i t y .

During

2


3/21

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

the course

of

the

search of

the hote l room,

GIT

members se ized

a

br iefcase conta in ing a

quant i ty of United Sta tes

currency.

4.

n

or

about

June 14, 2014, a

member

of the GIT task force

gave the defendant 10,982 in United Sta tes currency tha t was seized

from the

two

individua ls on

or about June

13, 2014, and recovered

from

the

hote l room

on or about June

14, 2014.

The

defendant was

given custody of the seized

currency

in h is o f f i c i a l capaci ty as

a

federa l law

enforcement

of f i ce r for the purpose of furthering a

federa l criminal

invest iga t ion .

Ins tead of

enter ing th i s currency

i n to

an

FBI

evidence

s torage fac i l i ty or submit t ing the currency for

for fe i tu re to the United Sta tes the defendant misappropria ted the

currency

for his

personal

use .

5

n

or

about

June 25,

2014, members of the GIT task

force

i n i t i a t e d survei l lance

of an

apartment bui ld ing in Ontario,

17

Cal i forn ia

which

was

bel ieved

to

be

the

residence

of

ind iv iduals

18

19

20

21

22

23

associa ted with a methamphetamine dis t r ibu t ion organizat ion.

During

the

course

of th i s su rve i l l ance

a member of

GIT obta ined

approximately 4,600 in United Sta tes currency from the

person

of one

of the res idents of one of the apartments within the building,

fol lowing

a t r a f f i c ~ t o p of a

vehic le

in

which

tha t res ident was

24

t rave l ing.

Later

tha t

day,

the

defendant and other GIT

task

force

25 of f i ce r s

par t i c ipa ted

in the execut ion of a s t a t e

search

warrant

a t

26

27

28

the apartment in quest ion.

This sea rch

re su l ted in the seizure

of

addi t ional

United Sta tes

currency.

3


4/21

3

4

5

6

7

8

6. On

o r about June 25, 2014,

a GIT

task force

off icer

t ransfer red

to the

defendant

custody

of the

United Sta tes

currency

obta ined as a resu l t of the t r a f f i c s top and apartment

search

on

or

about

June

25, 2014.

The

defendant

was

given custody of the

se ized

currency

in

h is

o f f i c i a l capaci ty as

a

federa l law enforcement

off icer for

inves t iga t ion .

the purpose

Ins tead

of

of fur ther ing

enter ing t h i s

a

federa l

cr iminal

currency in to

an FBI

9

evidence

s torage fac i l i ty o r

submit t ing the

currency for

for fe i tu re

10 to the United

Sta tes the

defendant

misappropr ia ted the currency for

12

13

14

15

16

17

18

19

20

21

22

23

4

25

his personal use.

7 . n

or

about

August

19, 2014, a t

the request

of

federa l law

enforcement

agents in

Pit tsburgh,

Pennsylvania,

the defendant and

other

GIT

t ask

force

of f i ce

rs par t i c ipa ted

in the execut ion of

a

federa l search warrant

a t

a residence on Lakewood Drive

in San

Bernardino,

Cal i fo rn ia

which

was

bel ieved

to

be

associa ted

with

heroin

and

cocaine d i s t r i bu t i on ac t iv i ty .

This search resu l ted in

the se izure of a l a rge amount of

United

Sta tes currency. This se ized

currency was sea led in

evidence

bags a t

the scene

and

provided to

the

defendant ,

in

his

of f i c i a l

capacity

as a

federa l law enforcement

off icer

for

the

purpose

of

fur ther ing a

federa l

cr iminal

inves t iga t ion .

In

or

around

the

evening

of August 19, 2014, the

defendant

and

another FBI

Special

Agent

placed the

sea led

bags

26

conta in ing

the se ized currency in a safe a t the FBI s res ident agency

27

in

Riverside, Cali fornia for overnight s torage .

28

4


5/21

1

2

3

4

5

6

7

8

8.

On or

about August

20,

2014, the defendant , act ing alone,

re t r i eved the sea led bags containing the seized

currency from

the

safe

a t

the FBI'

s

res ident agency in Riverside , Cal i forn ia .

The

defendant

opened

the

sea led

bags

containing the seized

currency,

withdrew a

subs tan t ia l amount of the seized

currency

for his personal

use,

and repackaged

the

remaining

quant i ty

of currency

in

new

evidence bags. The defendant

then t ransported

the repackaged por t ion

9

of the se ized currency to

a

f ac i l i t y

in Ontario,

Cal i forn ia operated

10

by

Company A

The

Company A

f ac i l i t y performs

cash counting

serv ices

11

12

13

14

15

16

for law enforcement

agencies

in the Los Angeles

area, par t i cu la r ly

in

cases involving the se izure of l a rge amounts of cash.

The

defendant

arr ived a t and

departed

from the

Company A

f ac i l i t y by himself .

n

employee of

Company A counted

the repackaged por t ion of the seized

currency and determined tha t

the repackaged port ion

of

the

seized

17

currency

to ta led

366,800.

The

defendant s igned

a

rece ip t r e f lec t ing

18

t h i s

to ta l

count .

An

employee of

Company A

then

provided

the

19

20

21

22

23

24

5

defendant with

a

copy

of the

signed

rece ip t .

9.

The defendant immediately took s teps to conceal his act ions

by fa l s i fy ing of f i c i a l

FBI

reports concerning the Lakewood

Drive

se izu re .

On

o r

about

August

21,

2014,

the

defendant

draf ted

and

submit ted

an o f f i c i a l report known as an FBI form

FD-302,

regarding

the

execution

of the search warrant

a t

the Lakewood Drive residence.

26 In

t h i s report

the

defendant

fa l se ly s t a t ed tha t only

366, 800 in

27

cash was

seized a t the Lakewood

Drive

residence, although

the

28

5


6/21

defendant knew tha t the t rue amount of cash seized was subs tan t ia l ly

2

grea te r .

3

10.

n

o r about August 26, 2014,

the

defendant draf ted

and

4

submit ted

another

FD-302

regarding the

t r anspor ta t ion to

the

Company

5

A

f ac i l i t y of the currency se ized a t the Lakewood Drive residence.

6

7

In

th i s

repor t

the defendant

fa l se ly

suggested

tha t

only

366,800

in

8

cash was

se ized a t

the

Lakewood

Drive

residence,

although

the

9 defendant

knew

tha t

the t rue

amount

of

currency

seized was

10

subs tan t i a l ly

grea te r .

The

defendant also

fa l se ly s ta ted in

th i s

11

repor t tha t he was accompanied

by

Detect ive

A a

San

Bernardino

12

Police Department

Detect ive

and fe l low

GIT

member, during the

13

t r anspor ta t ion of the se ized

currency

to the

Company A

fac i l i ty on

or

14

about August 20, 2014. Final ly the defendant a l t e red

the

rece ipt he

15

16

rece ived from

Company A

by

forging

Detect ive A's signature

on the

17

rece ip t

next

to

his

own

s ignature

and

at tached

to

th i s

report

an

18 e lec t ronic

image

of the rece ip t with the forged s ignature .

19

20

21

22

23

24

25

26

27

28

11.

In or

around

August and September 2014, the

defendant

spent

much of the currency tha t he misappropria ted for h is personal

use

and

enjoyment.

a .

On

o r about

the

morning

of

August

20,

2014

-

a f te r he

re t r i eved the

se ized currency from the

FBI

res ident

agency but before he arr ived

a t

the

Company A

fac i l i ty

-

the

defendant

t raveled

to

an

automobile

\

par t s

dealersh ip where

he spent

approximately 2,353 in

cash

6


7/21

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

toward

new rims and

a

new suede headl iner for

a

personal

vehicle .

b.

n

o r about August 21, 2014, the

day

a f te r the defendant

t ransported

a

port ion

of

the

se ized

currency

to

the

Company A

fac i l i ty the defendant

purchased a

2013

Toyota

Scion FR S

coupe

vehic le a t a used

car dealersh ip

for

27,500

in cash.

c.

Also

on

o r

about

August

21,

2014, the defendant opened

a

new checking

account in to which

he made numerous

cash

deposi t s to ta l ing

approximately

10,665 over the course

of August and September 2014.

d.

n

or

about August

31, 2014,

the defendant purchased

a

2012 Dodge Challenger coupe vehicle a t

a

used car

dealership

for

43,850 in cash.

e .

In

or

around

l a t e

August and

ear ly

September

2014,

the

defendant spent approximately 9,

612

in cash for

new

speakers ,

r ims,

and t i r e s for

the

Toyota

Scion FR S and

approximately 17, 000 in cash for

a new

sound

system,

r ims,

t i r e s

and

muffler

for the

Dodge

Challenger.

f . In

or

around

ear ly

September

2014,

the defendant pa id

approximately

15, 000 in

cash for cosmetic surgery for

his spouse.

g.

n

or

aboilt September 12 through September 14,

2014, the

defendant t rave led

with

his g i r l f r i end to

Las

Vegas,

Nevada, where he paid for accommodations in

a

su i te a t

a

7


8/21

2

3

4

5

6

7

8

9

10

12

13

14

15

16

luxury

hote l ,

casino,

and

r e so r t using

funds

from

his

new checking account .

During t h i s t r ip , the defendant

used more than $1, 000 in cash to pay for

t i cke t s

to

a

boxing

event .

h.

In

or around l a t e September

2O14,

the

defendant gave

Detect ive

A

$2,000

in

cash.

12. In or around

l a t e

August

and

September 2014, the defendant

fabr ica ted

a cover

s tory to conceal

the source of

the funds

tha t he

used to

pay

for these

personal

expendi tures , claiming to severa l law

enforcement

colleagues tha t he had recen t ly received

an approximately

$97,000

advance on his inheri tance

from his s ick fa ther .

In fac t ,

the defendant s fa the r

never provided

the

defendant with a

g i f t of

t h i s

s ize

or with

an advance on

the defendan t s

inheri tance.

13. In o r around October 2014, upon l earn ing tha t other

law

7

enforcement

of f i ce r s

were

inquir ing

about

the

dispos i t ion

of

the

18 currency

se ized in

June

2014, the

defendant took s teps to conceal his

19

course

of conduct .

20

21

22

23

24

25

26

27

28

a . n

or

about

October

21 and 22, 2014, the

defendant

rece ived inqui r ie s

from ,an FBI

superv isor

about the

currency se ized in June

2014.

The defendant fa l se ly

to ld

the FBI superv isor tha t the defendant brought the

cash

se ized in

June

2014 to the

Company A f a c i l i t y

on or

about August

20, 2014,

where Company A

employees

commingled

the cash seized

in June 2014 with the cash

8


9/21

1

s e i zed from the Lakewood Drive

r e s id en ce

on o r about

2

August 19,

2014.

3

b . On o r about October 22,

2014,

the defendant con tac ted

4

D etec t iv e

A

and

asked

him

to

prov ide

f a l s e

in fo rmat ion

5

to anyone who asked,

namely t h a t D etec t iv e

A had been

6

7

p res en t wi th the defendant

a t

the Company

A f a c i l i t y

on

8

o r about August 20, 2014.

9

c .

The defendant

a l s o s en t an emai l to Detec t ive A on o r

10

about October

22, 2014,

in which

the

defendant

se t fo r th

11

a

f a l s e

cover

s to r y

fo r

D etec t iv e

A

to prov ide

to law

12

enforcement

o f f i c i a l s

i D etec t iv e A were asked about

13

the d e fen d an t ' s a c t i v i t i e s

wi th

r e s p ec t to the

currency

14

-

s e i zed in June

o r

August

2014.

In t h i s emai l , the

15

16

defendan t wrote :

17 You

accompanied

me

to [Company

]

on

18

augus t

20.

I

drove the t r a i l b l a z e r [ . )

We had

19

sea l ed

money

from the SB search warran t of f

20

Lakewood.

I

had

sea l ed

money from some

other

21

se i zure s

2 o r 3) kapaks .

I

brought it in ,

22

you s tayed

out s ide .

I had to b r ing

the

23

24

r ece ip t out fo r you to

s ign l a t e r .

We l e f t I

25

t o l d

you

I mighta fucked up cause they pu t a l l

26

the

money

t oge the r .

T h a t ' s a l l .

In case your

27

s i c ]

asked .

28

9


10/21

1

2

3

4

5

6

7

8

9

10

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

d. On or about October 27, 2014,

the

defendant sent

another

email

to Detect ive

A

to which he at tached an

elec t ronic

image

of the copy of

the Company A rece ip t

bear ing

Detec t ive

A s forged

s ignature , so

tha t Detect ive

A

could recognize th i s s ignature and

fa l se ly

claim t

as

his

own

i f

asked.

10


11/21

2

3

COUNT ONE

[18 u.s.c.

654]

14. The

a l lega t ions

contained

in paragraphs through 4

of t h i s

4

Ind ic tment

a re

hereby

repeated

rea l l eged

and

incorpora ted

by

5

re fe rence as

though

fu l l y s e t

fo r th

here in .

6

15.

On o r about

June

14, 2014, in

the

Cent ra l

Di s t r i c t

of

7 Cal i fo rn ia the defendant , SCOTT M.

BOWMAN

being an o f f i c e r and

8 employee of the United Sta tes and of any department

and

agency

9 the reof embezzled

and wrongful ly conver ted

to

h i s

own use the money

10

and

prope r ty of another which came i n to

h is

possess ion

and

under hi s

11 con t ro l in the execut ion

of

such o f f i c e

and employment, and

under

12

co lo r

and claim

of au th o r i t y as

such o f f i c e r

and employee, namely,

13 United

Sta tes currency

in an

amount

g re a t e r

than

1,000

se ized

in

14 Azusa, Cal i fo rn ia on o r about June

13

and 14, 2014.

15

16

17

18

19

20

21

22

23

24

25

26

27

28

All i n v i o l a t i o n of Ti t l e 18, United

S ta t e s

Code, Sect ion 654.

11


12/21

COUNT TWO

[18

u . s . c . 1512 c)

2)]

2

3

16.

The a l l ega t ions conta ined

in

paragraphs 1 through 4 of t h i s

4

Ind ic tment

are

hereby

repeated, rea l leged,

and

incorpora ted

by

5 reference

as though

fu l l y s e t fo r th here in .

6 17. On

o r

about June 14, 2014,

in

the Centra l Di s t r i c t of

7 Cal i fo rn ia , the

defendant ,

SCOTT

M.

BOWMAN

cor rup t ly

obst ruc ted ,

8

inf luenced,

and impeded an o f f i c i a l proceeding tha t

i s ,

a

9

proceeding be fore

a cour t of

the

United Sta tes ,

and

a

proceeding

10

before a

f edera l grand ju ry and

at tempted

to

do

so,

by

knowingly

11 tampering

with

evidence,

t ha t i s ,

United

Sta tes

currency

se ized

in

12 Azusa, Cal i fo rn ia , on o r about June

13

and 14,

2014.

13

All

in

v io l a t i on of Ti t l e 18,

United Sta tes

Code,

Sect ion

14 1512 c)

2) .

15

16

17

18

19

20

21

22

23

24

25

26

27

28

12


13/21

COUNT THREE

2

[18 u s c

654]

3

18.

The a l l ega t ions contained in paragraphs 1, 2, 5, and 6 of

4 t h i s Indictment are

hereby

repeated

rea l leged and incorpora ted by

5 reference

as though fu l ly se t

fo r th herein .

6

19.

On o r about

June

25,

2014,

in

the

Central

Di s t r i c t

of

7 Cal i fo rn ia

the

defendant , SCOTT M. BOWMAN being an

of f i ce r and

8 employee of

the

United

Sta tes and of any department and agency

9

the reof

embezzled

and wrongful ly converted to his own

use the

money

10 and prope r ty

of another which

came

i n to

his possess ion and

under his

11 con t ro l in

the

execu t ion of such

of f i c e and

employmentr and under

12

co lo r and claim of au thor i ty as such

of f i ce r

and employee/ namely,

13 United Sta tes currency in an amount grea te r than 1,000

se ized

in

14

Ontar io ,

Cal i fo rn ia

on or about June 25, 2014.

15

16

17

18

19

20

21

22

23

24

25

26

27

28

All

in v io l a t i on

of

Ti t l e 18, United

Sta tes

Code, Sect ion

654.

13


14/21

1 COUNT

FOUR

2

[18

u.s.c. 1512

c)

2)]

3 20. The a l l ega t ions contained in paragraphs 1, 2, 5, and 6 of

4 t h i s

Indictment

are

hereby

repeated

rea l leged and

incorpora ted

by

5

re fe rence

as

though fu l l y s e t

fo r th

herein.

6 21. On o r about

June

25, 2014,

in the Centra l Di s t r i c t

of

7 Cal i fo rn ia the defendant , SCOTT M.

BOWMAN cor rup t ly obst ruc ted

8

inf luenced and

impeded

an

o f f i c i a l

proceeding

tha t i s a

9 proceeding

before

a cour t of the United Sta tes and a

proceeding

10

before a f edera l grand ju ry

and

at tempted to do so, by knowingly

11 tampering with evidence, t ha t

i s

United

Sta tes

currency

seized

in

12

Ontario ,

Cal i forn ia

on o r about June 25, 2014.

13 All in

v io l a t i on

of Ti t l e

18, United Sta tes

Code, Sect ion

14

1512 c) 2).

15

16

17

18

19

20

21

22

23

24

25

26

27

28

14


15/21

COUNT FIVE

2 [18 u.s.c. 654]

3 22.

The

a l l ega t ions contained in paragraphs

1,

2, 7, 8, 9,

10,

4 11, and

12

of

t h i s

Indictment

are

hereby

repeated rea l leged

and

5 incorporated by reference as though fu l l y se t fo r th here in .

6

23.

On

or

about

August

20,

2014, in the

Central

Di s t r i c t

of

7

Cal i fo rn ia the

defendant ,

SCOTT M. BOWMAN

being

an of f i ce r and

8 employee of

the

United Sta tes

and

of any department

and agency

9 the reof embezzled and wrongfully converted to h is own use the money

10 and proper ty of another

which came

in to h is

possess ion

and under

his

11 con t ro l

in the

execut ion of

such of f ice and

employment, and

under

12

co lo r

and claim

of

au thor i ty

as

such o f f i c e r and

employee, namely,

13

United Sta tes currency in

an

amount

grea te r

than 1,000

se ized in

San

14 Bernardino, Cal i fo rn ia on o r about August 19, 2014.

15

16

17

18

19

20

21

22

23

24

25

26

27

28

All

in

v io l a t i on

of

Ti t l e

18,

United

Sta tes Code,

Sec t ion

654.

15


16/21

1 COUNT

SIX

2 [18 U.S.C. 1512 c) 2)]

3 24. The a l l ega t ions contained

in

paragraphs 1, 2,

7,

8, 9, 10,

4

11,

and

12

of

th i s

Indic tment

are

hereby

repeated,

rea l leged

and

5 i ncorpora t ed

by re fe rence

as

though fu l ly

se t fo r th herein .

6 25. On o r about

August

20,

2014,

in the Cent ra l

Dis t r i c t

of

7

Cal i fo rn ia the

defendant ,

SCOTT

M.

BOWMAN

cor rup t ly

obst ruc ted

8

inf luenced and impeded an

o f f i c i a l

proceeding tha t

i s a

9 proceeding

before

a cour t

of

the United

Sta tes and

a proceeding

10

before

a f edera l grand ju ry

and

at tempted to do so, by knowingly

11 tamper ing with evidence ,

tha t

i s United Sta tes currency

se ized

in

12

San Bernardino,

Cal i fo rn ia

on or about August

19,

2014.

13

All in v io l a t i on of

Ti t l e

18, United

Sta tes Code, Sect ion

14

1512

c)

2).

15

16

17

18

19

20

21

22

23

24

25

26

27

28

16


17/21

2

3

COUNTS SEVEN THROUGH EIGHT

[18

u.s.c.

1957]

26. The a l l ega t ions contained in

paragraphs

1, 2, 7, 8, 9, 10,

4 11, and 12 of t h i s

Indictment

are hereby repeated, rea l leged and

5 incorpora ted

by

re fe rence

as

though fu l l y s e t fo r th here in .

6 27.

On or about

the

fol lowing dates in

the Cent ra l Di s t r i c t

of

7 Cal i forn ia the

defendant , SCOTT M. BOWMAN

knowing

tha t

the funds

8 involved represented the

proceeds

of some

form of unlawful

a c t iv i t y

9

conducted

the fol lowing monetary t ransact ions

a f fec t ing

i n t e r s t a t e

10 commerce in

cr imina l ly derived

prope r ty

of a value grea te r than

11 10,000, which

proper ty in fac t

was

der ived

from

speci f ied

unlawful

12 ac t i v i t y namely,

conspiracy to

d i s t r i bu t e

and possess with i n t en t to

13

d i s t r i bu t e

a con t ro l l ed substance, in

v io l a t i on

of 21

U.S.C.

846.

14 COUNT

15 Five

16

17

Six

18

19

20

21

22

23

24

25

26

27

28

DATE

August

21,

2014

August

31,

2014

MONETARY TRANSACTION

Cash

purchase of 2013 Toyota Scion FR-S

coupe vehic le

fo r

27,500

Cash

purchase of

2012

Dodge

Challenger

coupe veh ic le fo r 43,850

All in v io l a t i on

of

Ti t l e 18, United Sta tes

Code,

Sect ion 1957.

17


18/21

1

2

3

COUNT NINE

[18 u.s.c. 1519]

28. The a l l ega t ions contained in paragraphs

1 2 7 8

9

10

4

11 and

12

of t h i s

Indic tment

are

hereby repea ted

rea l leged

and

5

incorpora ted

by

reference

as

though

fu l ly

se t

fo r th

here in .

6 29. On o r about

August

26 2014 in

the Centra l Dis t r i c t

of

7 Cal i fo rn ia the defendant SCOTT M.

BOWMAN

knowingly f a l s i f i ed and

8

made

a

fa l se en t ry

in a record and document namely an FBI form FD

9

302

with

the i n t en t

to

impede

obs t ruc t and

inf luence the

10 i nves t iga t ion

and proper

admin is t r a t ion

of

a

matter within

the

11

j u r i sd i c t i on of

a department and agency

of the United Sta tes

namely

12 the

United

Sta tes Department of

Jus t ice

and in

r e l a t i on

to and

13

contemplat ion

of any such mat te r .

14 All

in

v io l a t i on

of

Ti t l e 18

United Sta tes

Code Sect ion 1519.

15

16

17

18

19

20

21

22

23

24

25

26

27

28

18


19/21

1

2

3

COUNT

TEN

[18

u.s.c. 1512 b)

3)]

30. The

a l l ega t ions

contained

in paragraphs 1 through 13 of

4

t h i s

Ind ic tment are hereby repeated,

rea l leged ,

and incorpora ted by

5

reference

as though f u l l y se t for th

here in .

6

31. On o r

about

October

22,

2014, in the Central D is t r i c t of

7 Cal i forn i a , the defendant ,

SCOTT

M.

BOWMAN knowingly

cor rupt ly

8 persuaded another person, namely Detec t ive A

and

at tempted to do so,

9 with

i n t en t

to

hinder ,

delay, and prevent the communication to a law

10

enforcement

o f f i c e r of the United Sta t e s of informat ion r e l a t i ng to

11 the commission and poss ib l e

commission

of

a federa l

offense .

12 All in v io l a t i on

of

T i t l e

18, United Sta t e s

Code, Sect ion

13 1512 b) 3) .

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

19


20/21

1 FORFEITURE ALLEGATION

2

[18 U.S.C.

981 a) 1) C), 28

U.S.C.

2461, 21

U.S.C.

853 p)]

3

32.

Pursuant

to Federa l Rule of

Criminal

Procedure 32.2 a) ,

4

no t ice

i s hereby given tha t

upon

convic t ion of any of the offenses in

5 v io l a t i on

of

Ti t l e

18, United

Sta tes Code, Sect ions 1512 and 1957

se t

6

for th

in

Counts

Two, Four, Six,

Seven, Eight , and

Ten

of t h i s

7 Indictment , defendant SCOTT M.

BOWMAN

sha l l fo r f e i t to the United

8 Sta tes of America, pursuant to

Ti t l e

18, .United

Sta tes Code,

Sect ion

9 981 a)

1)

C) and Ti t l e 28,

United

Sta tes Code, Sec t ion 2461 c), the

10 fol lowing:

11 a .

Al l r igh t , t i t l e and i n t e re s t in

any

proper ty ,

rea l or

12

personal ,

which

cons t i tu t es or i s

der ived

from

proceeds

obtained,

13 d i r e c t l y o r ind i rec t ly , as a r e su l t of such v io la t ion ;

and/or

14 b. A sum of money equal to the t o t a l amount of proceeds

15

der ived

from

each such v io la t ion .

16 33. Pursuant

to

Ti t l e 21,

United

Sta tes Code, Sec t ion 853 p),

17

as

incorpora ted

by Ti t l e 28,

Sec t ion

2461 c),

defendant SCOTT

M.

18

BOWMAN, i f

so convicted,

sha l l fo r f e i t

s ubs t i t u t e proper ty , up to

the

19 t o t a l value of the proper ty

descr ibed

in paragraph 32

i f ,

by any act

20 o r omission of the defendant , the prope r ty

descr ibed

in paragraph 32

21

o r

any

por t ion the reof , a) cannot

be located upon the exerc ise

of

22 due d i l igence ; b) has

been

t r a n s fe r r e d or

sold

to , or

deposi ted

23

with,

a t h i rd party ; c) has been

placed

beyond the j u r i s d i c t i on

of

24 the

cour t ;

d) has been s ubs t a n t i a l l y

diminished

in

value;

or e)

s

26

27

28

20


21/21

has been commingled with o ther proper ty tha t

cannot

be divided

2 without

d i f f i cu l ty

3

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

R YMOND HULSER

Chief

Publ ic In t eg r i t y Sect ion

L UR

BELL

Tr ia l

Attorneys

Public

In t eg r i t y Sec t ion

Criminal Divis ion

U.S. Department of Jus t ice

A

TRUE

BILL

Foreperson

FBI SPECIAL AGENT Scott Bowman Indictment

Documents

Transcript of FBI SPECIAL AGENT Scott Bowman Indictment