Complaint No. 1784578211 - 1369800946

Acting under color of state law, in his capacity of Assistant Chief Special Agent, issued a written threat of criminal prosecution on official letterhead while refusing repeated requests to disclose the underlying case file, to include but not limited to the sworn complaint. This refusal obstructed the ability to verify the factual basis of the representations made. To the extent that any factual assertion proves inaccurate or unsupported, such conduct raises material concerns regarding credibility, candor and fitness to exercise prosecutorial or enforcement authority, and constitutes potential impeachment material.