UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA
v.
MATTHEW TORRES
Hon. Steven C. Mannion
Mag. No. 18-6258 (SCM)
CRIMINAL COMPLAINT
I, Kelly Blanchfield, being duly sworn, state the following is true and
correct to the best of my knowledge and belief:
SEE ATTACHMENT A
I further state that I am a Special Agent with the Federal Bureau of
Investigation ("FBI"), and that this complaint is based on the following facts:
SEE ATTACHMENT B
continued on the attached pages and made a part hereof.
Special Agent
Federal Bureau of Investigation
Sworn to before me, and subscribed in my presence
on the 18th day of December, 2018
at Newark, New Jersey
HONORABLE STEVEN C. MANNION
UNITED STATES MAGISTRATE JUDGE Signature of Judicial Officer
ATTACHMENT A
On or about December 7, 2017, in Passaic County, in the District of New
Jersey, and elsewhere, defendant
MATIHEW TORRES
did knowingly and willfully conspire and agree with others to injure, oppress,
threaten, and intimidate Victim 1 and others in the free exercise and enjoyment
of the rights secured to them by the Constitution and laws of the United States,
namely, their right to be secure in their vehicles and their persons against
unreasonable searches and seizures.
In violation of Title 18, United States Code, Section 241.
ATTACHMENT B
I, Kelly Blanchfield, am a Special Agent with the Federal Bureau of
Investigation. I am aware of the facts contained herein based upon interviews
and briefings with other law enforcement officers and interviews of witnesses. I
also have reviewed or been briefed regarding other evidence, including Internal
Affairs complaints and text message communications. Because this complaint
is being submitted for the limited purpose of establishing probable cause, I
have not set forth herein each and every fact that I know or that has been told
to me concerning this investigation. Unless specifically indicated, any
statements herein attributed to individuals are set forth in substance and in
part. Where I assert that an event took place on a particular date, I am
asserting that it took place on or about the date alleged.
1. At times relevant to this complaint:
a. Defendant MATTHEW TORRES ("TORRES") was a police
officer employed by the Paterson Police Department ("PPD) in
Paterson, New Jersey.
b. Eudy Ramos was a police officer employed by the PPD.
Ramos has been charged in a separate criminal complaint.
c. CW-1 was a police officer employed by the PPD. CW-1 has
cooperated with law enforcement in the hopes of obtaining a
more favorable outcome with respect to pending federal
charges.
2. According CW-1, TORRES and other PPD officers, including Ramos
and CW-1: (a) stopped and searched vehicles and the drivers and passengers of
those vehicles, without legal basis; and (b) stole money from the drivers and
passengers of those vehicles.
3. For example, on or about December 7, 2017, TORRES and Ramos
conducted a vehicle stop of Victim 1 in Paterson. According to Victim 1, Victim
1 was a passenger in the passenger seat of a vehicle driven by Victim l's
brother. TORRES and Ramos, assigned to two different police cars that day,
conducted the vehicle stop and removed Victim 1 and his brother from the
vehicle. TORRES and Ramos then searched the vehicle, Victim 1, and Victim
1 's brother. Victim 1 advised Ramos and Torres that Victim 1 had two bags of
marijuana in his pocket. Ramos told Victim 1 that "honesty goes a long way."
Victim 1 also had $3,100 in his pocket. Ramos took the $3,100 and placed it
on the backseat of the vehicle. Ramos then told Victim 1 that Ramos "doesn't
worry about the weed." Ramos also told Victim 1 that Victim 1 had a potential
outstanding warrant. TORRES and Ramos placed Victim 1 in one of the police
cars and Victim 1 's brother in the other. They told Victim 1 that Victim 1 could
be charged with distribution of marijuana and that they could not let Victim 1
go "because the camera saw it," likely referring to a City of Paterson camera
located in the area.
4. According to Victim 1, Ramos then told Victim 1 that, instead of
arresting Victim 1, they could take $500, have Victim 1 sign a piece of paper,
and give the paper to the narcotics division. Ramos told Victim 1 that they
would confiscate $500 and that Ramos had to call a superior officer to verify
that $500 was acceptable. Ramos asked Victim 1 for Victim 1 's date of birth
and social security number, placed a call, and then hung up the telephone and
told Victim 1 that his superior had said "they could do it, but it'll be $800."
Ramos then took a piece of white paper that had a PPD logo on it, turned it
over, wrote something on it, and told Victim 1 to sign it. Victim 1 signed it.
Victim 1 does not know what was written on the paper.
5. TORRES and Ramos then released Victim 1 and Victim 1 's brother
without filing any charges. According to Victim 1, there was $1,000 missing
from his original $3,100. TORRES and Ramos did not report the cash seizure
to the PPD.
6. According to PPD records, there were no outstanding warrants for
Victim 1.
7. According to CW-1, Ramos frequently used fake paperwork, of the
sort he used with Victim 1, to trick individuals into believing that the incident
was a legitimate law enforcement encounter.
8. In or about December 2018, TORRES was interviewed by the FBI.
TORRES admitted that he and Ramos illegally seized cash from Victim 1 and
that they shared the cash proceeds afterwards. TORRES also admitted that he
and Ramos had engaged in similar criminal conduct on other occasions.