Case 3:20-mj-00230 Document 1 Filed 09/03/20 Page 1 of 6 AO 91 (Rev. 11/11) Criminal Complaint UNITED STATES DISTRICT COURT for the District of Oregon __________ District of __________ United States of America v. ) ) ) ) ) ) ) Pedro Aldo Ramos, Jr. Case No. 3:20-mj-00230 Defendant(s) CRIMINAL COMPLAINT %< 7(/(3+21( 25 27+(5 5(/,$%/( (/(&7521,& 0($16 I, the complainant in this case, state that the following is true to the best of my knowledge and belief. August 24, 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 M. Dennard ✔ Continued on the attached sheet. u /s/ Brendan M. Dennard Complainant’s signature FBI Special Agent Brendan M. Dennard Printed name and title $WWHVWHG WR E\ WKH DSSOLFDQW LQ DFFRUGDQFH ZLWK WKH UHTXLUHPHQWV RI )HG 5 &ULP 3 E\ WHOHSKRQH DW BBBBBBBB D P S P 4:47 Date: September 3, 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-00230 DISTRICT OF OREGON, ss: Document 1 Filed 09/03/20 Page 2 of 6 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). During my employment, I have been involved in the investigation and arrest of individuals charged with the aforementioned crimes and have assisted in the execution of search warrants and court orders based on those statutes. Case 3:20-mj-00230 3. Document 1 Filed 09/03/20 Page 3 of 6 I submit this affidavit in support of a criminal complaint and arrest warrant for PEDRO ALDO RAMOS JR., 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 RAMOS assaulted a police officer for the intended purpose of obstructing, impeding, or interfering in a violent manner with such law enforcement officer; that RAMOS intentionally participated in blocking traffic on a public street; that RAMOS did so knowingly and willfully, and that RAMOS 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. The information stated herein is based on my own personal involvement in this investigation, as well as my discussions with other law enforcement officers involved in this investigation, and information I have read that is contained in written reports pertaining to this investigation. This affidavit does not include all facts known to me regarding this investigation Page 2 – Affidavit of BRENDAN M. DENNARD Case 3:20-mj-00230 Document 1 Filed 09/03/20 Page 4 of 6 but contains only those facts which I believe are sufficient to establish the requisite probable cause. 6. On May 25, 2020, George Floyd died during his arrest by law enforcement officers in Minneapolis, Minnesota, sparking nationwide protests that extended to Portland, Oregon. The protests have, at times, included violence, civil disorder, arson, and looting. 7. On August 23, 2020, a group estimated at more than 200 people, gathered around the Portland Police Bureau (PPB) North Precinct located at 449 NE Emerson Street, Portland, Oregon. This precinct sits on the southeast corner of NE Martin Luther King Jr (MLK) Boulevard and NE Killingsworth Street. At this location, MLK Blvd has four lanes of travel while Killingsworth St has two; MLK is a major road in this area that runs north and south. Protestors were present in the streets, effectively blocking traffic in both directions. 8. Around 10:29 p.m., the gathering was declared an unlawful assembly due to individuals throwing chunks of ceramic, rocks, and glass bottles at officers. Participants were ordered to leave the area. Around 11:08 p.m., the event was deemed a riot due to the ongoing criminal behavior. Officers were struck by bottles, paint bombs, rocks, and heavy metal screws that were deliberately thrown at them. Participants were once again ordered to disperse. 9. Around 12:45 a.m. on August 24, 2020, PPB officers assigned to the Mobile Field Force were working the ongoing riot. An officer, hereafter Victim 1 (V1), was taking a female subject into custody who refused to follow the dispersal orders and subsequently, assaulted the officer. While V1 was arresting the subject, RAMOS ran up to the arresting officer, grabbed ahold of V1’s vest, and attempted to pull V1 off the arrestee. RAMOS then punched V1 on the side of her face. The assault was observed by a fellow officer, hereafter, Witness 1 (W1). Page 3 – Affidavit of BRENDAN M. DENNARD Case 3:20-mj-00230 Document 1 Filed 09/03/20 Page 5 of 6 RAMOS was subsequently arrested by police for Assault on a Public Safety Officer, among other charges. Conclusion 10. Based on the foregoing, I have probable cause to believe, and I do believe, that RAMOS intentionally obstructed, impeded, and interfered with law enforcement officers who were engaged in the lawful performance of their duties when RAMOS assaulted a police officer while participating in the blocking of traffic on a public street. RAMOS’s 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 RAMOS. 11. 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) Pamela Paaso, AUSA Paaso advised me that in her 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 12. 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 Page 4 – Affidavit of BRENDAN M. DENNARD Case 3:20-mj-00230 Document 1 Filed 09/03/20 Page 6 of 6 this time may cause flight from prosecution, or otherwise seriously jeopardize an investigation, including the planned arrest of the defendant. /s/Brendan M. Dennard __________________ Brendan M. Dennard Special Agent, Federal Bureau of Investigation Sworn in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone at 4:47pm 3 2020. __________ on September _____, ________________________________ THE HONORABLE JOLIE A. RUSSO United States Magistrate Judge Page 5 – Affidavit of BRENDAN M. DENNARD