Case 2:16-cr-00005-RFB Document 1 Filed 01/12/16 Page 1 of 3

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DANIELG. BOGDEN
United States Attorney
NICHOLAS D. DICKINSON
PHILLIP N. SMITH, JR
Assistant United States Attorneys
333 Las Vegas Blvd. South, Suite 5000
Las Vegas, Nevada 89101
PHONE: (702) 388-6336
FAX: (702) 388-6418

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VANITA GUPTA
Principal Deputy Assistant Attorney General
Civil Rights Division
PATRICIA A. SUMNER
Trial Attorney
601 D Street NW, 5th Floor
Washington, D.C. 20530
PHONE: (202)-616-4719

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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UNITED STATES OF AMERICA,
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) CRIMINAL INDICTMENT

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Plaintiff,

~ 2:16-CR- <1c.J5

RICHARD SCAVONE,

~VIOLATIONS:
~ 18 U.S.C. § 242 -

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v.
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Deprivation of Rights
) Under Color of Law;
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Defendant.

) 18 U.S.C. § 1519 - Falsification of a
) Document

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THE GRAND JURY CHARGES THAT:
COUNT ONE
(Deprivation of Rights Under Color of Law)

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On or about January 6, 2015, in the State and Federal District of

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Nevada,
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 Case 2:16-cr-00005-RFB Document 1 Filed 01/12/16 Page 2 of 3

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RICHARD SCAVONE,

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while acting under color of law as a police officer of the Las Vegas Metropolitan

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Police Department, after placing A.O. in handcuffs, grabbed A.O. around the neck

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with his hand and threw her to the ground; struck A.O. in the forehead with an

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open palm; grabbed A.O. by the head and slammed her face onto the hood of his

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patrol vehicle; grabbed A.O. by the hair and slammed her face onto the hood of his

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patrol vehicle a second time; and slammed A.O. into the door of his patrol vehicle,
willfully depriving A.O. of the right, protected and secured by the United States
Constitution, to be free from unreasonable seizures, which includes the right to be

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free from the use of unreasonable force by one acting under color of law. This
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offense resulted in bodily injury to A.O.
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All in violation of Title 18, United States Code, Section 242.
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COUNT TWO
(Falsification of a Document)

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On or about January 6, 2015, in the State and Federal District of
Nevada,

RICHARD SCAVONE,
in relation to and in contemplation of a matter that is within the jurisdiction of
the Federal Bureau of Investigation, an agency of the United States, knowingly
falsified a document with the intent to impede, obstruct, and influence an

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 Case 2:16-cr-00005-RFB Document 1 Filed 01/12/16 Page 3 of 3

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investigation and proper administration of that matter.

That is, defendant

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SCAVONE falsified his use of force report about his encounter with A.O.

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All in violation of Title 18, United States Code, Section 1519.

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DATED: this 12th day of January, 2016
A TRUE BILL:

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IS/

FOREPERSON OF THE GRAND JURY

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NICHOLAS D. DICKINSON
PHILLIP N, SMITH, JR.
Assistant United States Attorneys
PATRICIA A. SUMNER
Trial Attorney

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