G s~: 1:1.9-cr-X3 10 -i~R~ ~c~c #~: 1 Filed: t~ / 11 Pct : 2 c~~ 2 P,~~~ID ; 4 UNITED STATES BISTRICT CC3URT St~UT~-iER3~1 DISTTtICT OF t)HIO WESTERN DIVISIC?N UNITET~ STATES +OF AMERICA, :u~ ;~ ~ >. CASE NL). Plaintiff, ~T[TI}GE vs. ~. . r ?~° < .t.. IlV'Ft)RMATICIN MICI-iAEL SAV.~RI), 18 TJ.S.C. § 666(a}(1)(I3) 26 U.S.C. § 7206(1.) Defendant. TEIF iJNITT,~ STAT~~S ATT(3~2.N~Y CHARGES: 1. At times relevant to this Indictment, the City of Cincinnati was a local government located in the Southern District ~f Qhio. 2. At #imes relevant to this Indictment, tl~e Cincinnati Police Department ("CI'L~") was a law e~~farcement agency of'the Gity of Cincinnati. 3. At times z~elevant to this Iz~dicbment, the defendant, MICIIAEI. SAVAI22D, was an agent of'the City crf C'incitulatr, that zs, he was employed as a Captain for t}Ze City of Cincinnati Police I?e~~arttn~nt. 4. The City of Giucinnati and the Cincinnati Police Department received federal benefits in excess of $14,000 during the periad fi•am on ax about July 20I 8 fo an or about Ju;ie 20 ] 9, C~IJNT ONE (Brikrery Caucer~zing Programs Receiving ~ ec~eral ~+unds) 5. Paz~agraplas I Through 4 of fihc Inforsnatian are incorporated hire, 6. From pn nr about May 20, 2019 to on ar about June 6, 2019, in tlae Southern Dzstrict of C)hio, tl~e defei~dat~t, MICHAEL SAVARL), bei~~g an agent of a ]acal govenlmcnt that received federal be~~;efits in excess of $14,000 in the twelve-month period ~i~om June 2018 try .Tiny 201. ~}, corruptly solicited and demanded for his own benefit, and accepted and ~as~. x;19-~r-QO~.Q6-MRE3 Dcac #~: 1 filed: (~~/23/1 Page: 2 of 2 F'A E(D #~: 44 agreed tca accept a thin, of value frc~nl a p~:rson, intending. to be influenced anc~ rewarded in connection with a business, transaction, and series of transactions of such ]Qcal government involvi~~g a thing a~' value of $5,000 and mare, to wit, the cicfendant, MIC~~AEL SAVAIZD, solicited, accepted, and agreed tc~ accept $S,{}QO in cash f'resm CF'D Offcer t, an individual known to the grand jury, while intending to be influenced and rev~rarded in ca~lnectio~l wi#h tl~e promotion of CPD Officer 1 from Sergeant iv Liec.~tenant. in violation of 18 U.S.C. § 66fi(a}(1){Bj. CC)UNT `TWC) (I+'iling a I+alse Tax Return) 7. On or about October 17, 2016, in the Southern L?istrict cif Ohia, tl~e defEnda~~t, MTCI~AEL SAVARD, a resident of Hamilton County, Ohio, did willfully make and subscribe a U,S. Individual Income Tax Return (}~e~rn~ l E}4(?) fc~r tax year 201 S, which. was verified by a. written decla~~atian that it was made under the penalties of perjury end which he did not believe to be true and correct as to ev~7•y materiat natter. Specifically, the Farm 1040, w~uch was prc~arecl and signed in the Southern Distx-ict 4f 011io and was filed with the InternaP Revenue Service, was false as to a material matter, an that. it underreported the defendant's total income by not including income earned by the defendant for wc>rking o1'Fduty details at businesses. In violation of 26 U.S.C:. § ~2U6(l). BEN~AI'V1 + C. GLASSMAN UNIfiED TA'~"ES ATTORI~IEI' ~t ~ R~I;°~!,.~lE~'~~ t~N TTTIMAT HEW C. Assistan# United States Attorneys NG +. z