Case 3:20-mj-00233

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AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT
for the

District
of Oregon
__________
District
of __________
United States of America
v.

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)
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)
)
)

Alexandra Eutin

Case No.
3:20-mj- 00233

Defendant(s)

CRIMINAL COMPLAINT 
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I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
July 16, 2020

On or about the date(s) of
District of

Oregon

Code Section

Multnomah

in the county of

in the

, the defendant(s) violated:
Offense Description

18 U.S.C. § 231(a)(3)

Civil Disorder - Intentionally Obstructing, Impeding, Interfering with Law
Enforcement Officers Engaged in Official Duties

This criminal complaint is based on these facts:
See attached affidavit of FBI Special Agent Brendan Dennard

✔ Continued on the attached sheet.
u
/s/ Brendan Dennard
Complainant’s signature

FBI Special Agent Brendan Dennard
Printed name and title

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7:48
Date:

September 4, 2020
Judge’s signature

City and state:

Portland, Oregon

Hon. Jolie A. Russo, U.S. Magistrate Judge
Printed name and title

 Case 3:20-mj-00233

DISTRICT OF OREGON, ss:

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AFFIDAVIT OF BRENDAN M. DENNARD

Affidavit in Support of a Criminal Complaint and Arrest Warrant
I, Brendan M. Dennard, being duly sworn, do hereby depose and state as follows:
Introduction and Agent Background
1.

I am a Special Agent (SA) with the FBI and have been so employed for nine

years. I am currently assigned to a squad that is responsible for investigating violent crime,
fugitive apprehensions, and crimes against children. In 2011, I successfully completed 21 weeks
of training at the FBI Academy located in Quantico, Virginia. During that time, I was taught the
use and practical application of various investigative techniques that Federal law enforcement
officers are allowed to employ.
2.

Prior to my current squad assignment, I was tasked with coordinating the FBI-led

Safe Streets Metro Gang Task Force (MGTF) and had done so for five plus years. Prior to that, I
was part of the Clackamas County Sheriff’s Office Inter-Agency Task Force and had been
assigned for approximately a year and a half. As a member of these task forces, as well as my
current assignment, I have been empowered under Title 18, United States Code, Sections 3052
and 3053, and Rule 4 of the Federal Rules of Criminal Procedure, to conduct investigations and
make arrests for federal criminal offenses, including violations of 18 U.S.C. § 231(a)(3) (civil
disorder – obstruction of law enforcement); 18 U.S.C. § 231(a)(1) (civil disorder - incendiary
device); 18 U.S.C. § 844(f)(1) (arson); 18 U.S.C. § 2101 (riot); and 18 U.S.C. § 371
(conspiracy).
3.

I submit this affidavit in support of a criminal complaint and arrest warrant for

ALEXANDRA EUTIN, for civil disorder in violation of 18 U.S.C. § 231(a)(3). As set forth
below, there is probable cause to believe, and I do believe, that EUTIN struck a Portland Police

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Bureau Officer's head and helmet with a piece of wood for the intended purpose of obstructing,
impeding, or interfering in a violent manner with such law enforcement officer; that she did so
knowingly and willfully; and that she did so during a civil disorder that adversely affected
interstate commerce.
Applicable Law
4.

Title 18 U.S.C. § 231(a)(3) provides that “whoever commits or attempts to

commit any act to obstruct, impede, or interfere with any fireman or law enforcement officer
lawfully engaged in the lawful performance of his official duties incident to an during the
commission of a civil disorder which in any way or degree obstructs, delays, or adversely affects
commerce or the movement of any article or commodity in commerce . . . shall be fined under
this title or imprisoned not more than five years or both.” The term “civil disorder” means “any
public disturbance involving acts of violence by assemblages of three or more persons, which
causes an immediate danger of or results in damage or injury to the property or person of any
other individual.”
Statement of Probable Cause
5.

During the evening of July 16, 2020, approximately a couple hundred people

gathered in the general vicinity of PPB's Southeast precinct, located on the 4700 block of East
Burnside Street in Portland, Oregon. Once the group arrived at Southeast Precinct, they gathered
on East Burnside Street blocking all lanes of traffic. For about an hour, the group shined
flashlights and lasers at officers standing outside the precinct. The group was asked by the PPB
sound truck to remain peaceful.

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DENNARD

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6.

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At approximately 9:52 p.m., the group began making statements about wanting to

enter Southeast Precinct and burn down the property. The group was admonished by the sound
truck and told not to enter the property or they would be subject to arrest or use of force. The
group continued to stand in the street and started a small fire on East Burnside Street. Other
members of the group disregarded the messages given by the sound truck and crossed onto
Southeast Precinct property.
7.

At 11:45 p.m., an unlawful assembly was declared due to several people in the

crowd committing criminal activity. The criminal activity consisted of throwing rocks, bottles,
and sticks, as well as pointing green lasers at officers.
8.

A PPB Officer (Officer #1) was part of a cadre of officers making arrests at that

time. He was wearing markings on his clothing that clearly identified him as a police officer.
While attempting to make an arrest, Officer #1 was on the ground only a few feet from where
EUTIN was standing. EUTIN witnessed Officer #1 attempting to make this arrest. EUTIN had
a makeshift sign/shield made out of wood and hoses in her hand that she raised up and struck
Officer #1 with on top of his head/helmet. Another PPB Officer (Officer #2) witnessed EUTIN's
assault on Officer #1, which was also an attempt to obstruct, impede, or interfere with the arrest
Officer #1 was attempting. Officer #2 arrested EUTIN.
Conclusion
9.

Based on the foregoing, I have probable cause to believe, and I do believe, that

ALEXANDRA EUTIN knowingly, willfully and intentionally obstructed, impeded, and
interfered with a law enforcement officer who was engaged in the lawful performance of his

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DENNARD

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duties when EUTIN struck a Portland Police Bureau Officer's head and helmet with a piece of
wood; these actions took place during a civil disorder that adversely affected interstate
commerce in violation of 18 U.S.C. § 231(a)(3). I therefore request that the Court issue a
criminal complaint and arrest warrant for EUTIN.
10.

Prior to being submitted to the Court, this affidavit, the accompanying complaint

and the arrest warrant were all reviewed by Assistant United States Attorney (AUSA) Thomas
Ratcliffe. AUSA Ratcliffe advised me that, in his opinion, the affidavit and complaint are legally
and factually sufficient to establish probable cause to support the issuance of the requested
criminal complaint and arrest warrant.
Request for Sealing
11.

I respectfully request that the Court issue an order sealing, until further order of

the Court, all papers submitted in support of the requested criminal complaint and arrest warrant.
I believe that sealing these documents is necessary because any disclosure of the information at
this time may endanger the life or physical safety of an individual, cause flight from prosecution,
or otherwise seriously jeopardize an investigation, including the planned arrest of the defendant.
/s/ Brendan Dennard
Brendan Dennard
Special Agent
Federal Bureau of Investigation
Sworn in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone
7:48pm on September ____,
4 2020.
at _______
________________________________
HONORABLE JOLIE A. RUSSO
United States Magistrate Judge
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DENNARD

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