Case: Doc #1 1 Filed: 06/06/19 Page(Rev. I 1ft 1) Crimillai Complaint UNITED STATES DISTRICT COURT for the Southern District ot?Ohio United States of America v. MICHAEL SAVARD Def?ndanf?s?) CRIMENAL COMPLAINT E, the complainant in this case, state that the foliowing is true to the best of my knowledge and belief. . On or about the date(s) of May 20 through?June 6, 2019 in the county of in the Distn'ct of 9 WP ,the defendant(s) violated: Code Section Q??nse Description 18 U-S-C- 655 Theft or bribery concerning programs receiving Federal funds This criminal complaint is based on these facts: See Attached Affidavit Continued on the attached sheet. Compfahmm ?3 Signature SA CHAD ADOLPH. name and ri?e Sworn to before me and signed in my presence. City and state: Judge '3 signature Cincinnati, OH HON. KAREN L. LETKOVETZ Printed name and {Eric Case: Doc ti: 1 Filed: 06/06/19 Page: 2 of 7 PAGEID it: 2 AFFIDAVIT IN SUPPORT OF COMPLAINT 1, Chad A. Adolph, a Special Agent with the United States Treasury Department Internal Revenue Service, Criminal Investigation hereinafter referred to as the af?ant, being duly sworn, depose and state as follows: I. INTRODUCTION 1. I am and have been a Special Agent (SA) with the United States Treasury Department, Internal Revenue Service, Criminal Investigation, for over fifteen years. I received training in accounting, financial, and money laundering investigative techniques at the Federal Law Enforcement Training Center, I have also attended multiple seminars on money laundering and other financial schemes. My duties as a special agent include investigating potential criminal violations of Title 26 (Internal Revenue Code), Title 18- (money laundering and related speci?ed unlawful activities such as narcotics traf?cking, wire fraud, and public corruption) and Title 31 (Bank Secrecy Act) of the United States Code. I am currently assigned to Organized Crime Drug Enforcement Task Force investigations. As a Special Agent, 1 have many search and seizure warrant affidavits and conducted numerous criminal ?nancial investigations as well as public corruption investigations along with agents from other agencies and Task. Force Officers (TFOs) from other departments. 2. This af?davit is made in support of a criminal complaint. for MICHAEL SAVARD (SAVARD) for violation of 18 U.S.C. 666. Your af?ant is aware that whoever being an agent of a local government or government agency corruptly solicits or demands for the bene?t of any person, or accepts or agrees to accept, anything of value from any person, intending to be in?uenced or rewarded in connection with any business, transaction, or Case: DOC 1 Filed: 06/06/19 Page: 3 0f 7 PAGEID 3 series of transactions of such government or government agency involving anything of value or more, where that government has received, in the twelve month period preceding or following the offense conduct, benefits in excess of $10,000 under a Federal program involving a grant, contract, subsidy, loan, guarantee, insurance or other form of Federal assistance, has violated 18 U.S.C. 666 3. Because of my personal observations and participation in this investigation and information provided to me by other of?cers and TFOs, I am familiar with facts and circumstances of this investigation. This af?davit is intended to show only that. there is sufficient probable cause for the requested criminal complaint and does not set forth all of my knowledge of this matter. 11. Probable Cause BACKGROUND OF INVESTIGATION 4. Together with the Cincinnati Police Department (CPD), the United States Treasury Department IRSCI has been investigating SAVARD for various criminal offenses related to ?nancial bene?ts received by SAVARD as a result ot?his employment with CPD, Savard has been with the Cincinnati Police Department for twenty-five (25) years. Savard has been a Captain with CPD for approximately two (2) years overseeing the Special Services Section. Savard was a Lieutenant with CPD for approximately fourteen (14) years. As a lieutenant, Savard was assigned to multiple districts over the span of those fourteen years. 5. On May 29, 2019, your affiant and CPD TFO Colin Vaughn interviewed 3 CPD Sergeant During the course of the interview, explained that had learned that SAVARD had been placed on administrative duties at CPD and that there was an ongoing federal investigation. explained that on May 17, 2019, received a Case: Doc 1 Filed: 06/06/19 Page: 4 of 7 PAGEID it: 4 text message from a telephone number which did not recognize. The message read, ?When does the Us list expire?" CPDI responded via a text reading, ?July received a second text that read, "How about Sgt?? responded with a text that read, ?June CPDI received a third test message that read, ?Okay stop up and see me at Records Monday alter responded with a text message that read, ?I?m so not. sure who this received a text message in response that read, ?Mike Savard.? On May 20, 2019, received a text message which read, ?Hey, can you make it at 1100 at Records,? to which responded via text which read, ?Yes be there at i :00 Your affiant has seen all ofthe above texts. 6. On May 20, 2019, met SAVARD at the Records department located at 801 Linn Street, Cincinnati, Ohio. During the meeting, SAVARD told that SAVARD was going to work out a deal to plead guilty to federal charges and that SAVARD was thinking of retiring in July. SAVARD told that SAVARD would be willing to retire earlier in June ifCPDi. paid SAVARD $5,000. SAVARD told if paid the money to SAVARD and SAVARD took action to retire it would guarantee would be promoted to Lieutenant. 7. Your af?ant has learned that of?cers within. CPD are promoted using procedures developed by the City of Cincinnati Civil Service Commission. Officers Wishing to be considered for positions and be promoted must submit to a written examination and promotions are based at least in part upon their score on that civil service promotional exam. The exam is administered when a position vacancy occurs within CPD. Those who take the examination are ranked based upon numerical score and then placed on a Promotional Eligible List (PEL). Promotion to the next rank is awarded in order of the Case: Doc #2 1 Filed: 06/06/19 Page: 5 of 7 PAGEID 5 ranking that is generated on the PEL. Once an of?cer is promoted to the next rank, the list from which that officer was promoted from is used for promotions to that rank for a limited period of time, which your af?ant has learned is one year from the date of the ?rst promotion from the list. After the [one year] time period from the first promotion from the list occurs, the list expires and thereafter, any of?ceits) wishing to be promoted to that next rank must take the examination for the desired position, and a new PEL is then generated, which could cause officers on a previous PEL to drop in rank of eligibility. 8. Your ai??ant has reviewed the Police Lieutenant PEL, which was approved June 7, 2018. Your af?ant has learned that the ?rst Sergeant promoted to Lieutenant from this PEL was promoted July i, 2018, and based upon that promotion the expiration date of the PEL was set at July 1, 2019. Your af?ant has learned that since July l, 2018, several Sergeants have been promoted to the rank of Lieutenant, with the result that is the next Sergeant eligible for promotion to the rank of Lieutenant. 9. On May 30, 20'! 9, met SAVARD at 80l Linn Street, Cincinnati, Ohio. The meeting was audio-recorded and your af?ant has listened to the recording. told SAVARD that $5,000 is a lot of money and SAVARD responded that would make it. up in six months. During the meeting, SAVARD told that may never have another chance (to get promoted). SAVARD told CPDI that CPD-1 would make the money up in a heartbeat and wouldset up for Captain. CPDI told SAVARD that if did pay, wanted to be sure SAVARD would indeed retire, and SAVARD assured that, ?if we work this out,? SAVARD would leave June 215?. SAVARD told that if CPDI paid SAVARD he would retire and would he Lieutenant. SAVARD indicated that he had intended to retire ?at the end ol?July,? which is after the period during Case: DOC 1 Filed: 06/06/19 Page: 6 01?7 PAGEID 6 which CPDI would be eligible fora promotion to Lieutenant. asked if he could pay with money order, but SAVARD stated he wanted cash. reiterated that $5,000 was a lot of money and SAVARD responded that needed to look at the sixteen percent more in pay which would receive for however long remained at PD, which could result in receiving $150,000 to $200,000 more over the course of eight years. asked SAVARD fora few days to get the $5,000 together. SAVARD then told that. they don?t talk about it anymore, that they don"t discuss it, ifs a done deal and that [as far as everyone else would be aware] never did anything, SAVARD never did anything, would get promoted to Lieutenant and SAVARD would get $5,000. 10. On June 6, 2019, was provided $5,000 in U.S. Currency, the serial numbers of which were documented. met SAVARD at 801 Linn Street, Cincinnati, Ohio._ The meeting was audio?recorded. During the meeting, provided SAVARD $5,000 cash. After CPDI provided SAVARD the $5,000, SAVARD was arrested and the cash bearing the serial numbers provided to was recovered from SAVARD. ll. Your af?ant is aware that the City of Cincinnati government, by whom SAVARD is employed as a swom police Captain, has received, in the twelve month period preceding the offense conduct outlined herein, in excess of $10,000 in bene?ts under a Federal program involving a grant, contract, subsidy, loan, guarantee, insurance or other form of Federal assistance. Based upon your af?ant?s participation in this investigation, your af?ant respect?tlly submits the aforementioned facts provide probable cause to ?nd that SAVARD is in violation of 18 U.S.C. 666. I hereby declare that the foregoing is true and correct to the best of my knowledge and belief, pursuant to the investigation conducted on this case. Cage: Doc 1 Filed: 06/06/19 Page: 7 of 7 PAGEID 7 WW Chad A. Adolph Special Agent United States Treasury, Subscribed and sworn before me this 6th day of June, 2019 in Cincinnati, Ohio. we? Honorable Karen L. Likovitz 'Cj United States Magistrate Judge Southern District of Ohio