Probable Cause Affidavits Against HPD Officers

THE STATE OI.- TEXAS 03014651 D.A.
LOG NUMBER:2653 tO
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STEVEN O. BRYANT SPN: 03014651 BY: EH DA NO: 2425968 3(J <\J
I2OO TRAVIS DOB: B M t2ll8ll973 AGENCY:DAO
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HOUSTON, TX77OO2 DATE PREPARED: 7 ll 12020 O/R NO: S1907
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ARREST DATE: TO BE Pq'r.f --J

NCIC CODE:480232 RELATED CASES:
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FELONY CHARGE: TAMPERING GOVERNMENTAL RECORD
CAUSE NO: COURl'ORDERED BAIL: TO BE SET

HARRIS COUNTY DISTRICT COURT NO: 16808E1 MAGISTRATION
FIRST SETTING DATE: PRIOR CAUSE NO:
228
CHN RGE SEQNUM: I
IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS:
Before me, the undersigned Assistant District Aftorney of Harris County,'l'exas, this day appeared the undersigned affiant, who underoath says
that he has good reason to believe and does believe that in Harris County, Texas, STEVEN O. BRYANT, hereafter styled thc Defendant,
heretofore on or about April 23,2018, did then and there unlawfully, knowingly make a false entry in a governmental record, namely, a
Houston Police Depar-tmentNarcotics Division C.l. Activity Sheet/Receipt for Funds [rorm, with the intent to defi'aud and harm another.
PROBABLE CAUSE
Affiant, Lieutenant Billy Milan, is a cefiified peace officer employed by the Han'is County District Attomey's Office (HCDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to believe and does believe that f,orrner Houston Police Department (HPD)
Officer Steven Bryant, hereinafter defendant, did cornmit the state jail lelony oflense of tampering with a govcrnmental record on or about
April 23,2018, in Houston, []arris County, Texas. Affiant bases this belief on the follorving:
On January 15,2020, former HPD Narcotics Officers Gerald Goines (Goines) and the delendant werc indicted for 1'ampering with a
'T'hese charges ccnter on lalse staternents sworn
Governmental Record, see Harris County Cause Nos. 1660164 and 164i521, rcspectivcly.
to by Coines in obtaining a narcotics scarch warrant for a residence located at 7815 Ilarding Street arrd false statements made in thc
corresponding offense reporl by the defendant. Execution of that search warratrt lcd to the death of both ltonteowners, injury to foLrr FIPD
officers, and thereafler an FIPD invcstigation into Coines' use of confidcntial inlormants (C.l.s) to obtain scarch warrants.
case#158088u CRT#228
Affiant reviewed the FIPD offense reporl (OR) documenting that investigation, t{PD OR No. 133932-19, authored by Sergeant Rick Bass, a
licensed peace officer currently employed by HPD, and learned the following: All C.l.s registered to Coines rvere intervicwed and each
denied having completed a controlled buy at l-larding Street, despite the probable cause affidavit for the search warrant for that location
statingthataC.l.hadcompletedacontrolledbuythedaypriortothedateoltheaffidavit. OneoltheC.l.swhowasinterviewed
(hereinafterrefenedtoasC.l.#l)reporledtohaveattirnesbeenpaidbyGoincsforworknotprelonned. C.l.#lgaveavideointerview
during which C.l. #l was asked about several locations where, according to olficial HPD records (specifically C.l. Forms discussed more
fully below), C.l. #l had conducted controlled buys. C,l. #l denied having conducted several olthose buys, each of which led to a narcotics
search warrant.
Affiant is aware of and has reviewed HPD General Order 600-16 (GO) which governs C.l.s and paynterlts to C.l.s. The GO hotds that,,all
meetings between a C.l. and an olficer shall be attended by two officers." This regulation requires that that at least two officers be present
when a controlled buy is conducted. It further mandates that "officers shall not pay a confidential inforrnant without the appropriate witness
present." The GO goes on to dictate how payments to C.l.s will be documented, stating that all payments to C.l.s "shall be fully
documented on a division's'Confidential lnformant Receipt for Funds forrn"'(C.1. Fonn) with ''control information" to include the
signature of the C.l. as an agreement that the payment was received, the signature of the investigator rnaking the payment, the signature of at
least one other officer witnessing the payment, and the date of the payment. 'l-hese forrns, as dictatcd by the GO, require that at least three
people -the C.1., the investigator, and a witness - be together in one place in order for a payrnent to occur. Alfrant has revierved numerous
HPD C.l. Forms and has noted that these lorms also include the time of the payment and the associatcd OR nurnber for thc OR wherein the
controlled buy is docurnented.
Affiant has also reviewed the Special lnvestigation Comrnand, Narcotics Division, Standard Operating Procedures (SOP). SOp 100/2.05
covers "Confidential Inlormant Funds/Expense Letters, Limits of Authorization and Use of Flash Money" and includes a section on "CI
Payments & Receipt for Funds Fortn." That section rcpeats the requirements of GO 600-16 and also specifically states, "The CI Receipt
for Funds form will be completed at the time of the payment to the CI" (emphasis in original). Alfiant has reviewed the specific C,l. Irorm
used by the HPD Narcotics Division, titled "C.l. Activity Sheet / Receipt for Funds Form." The form has six sections. The first section
includes C.l. name, date, time, location, OR nurnber, and blanks for up to two drug types and the corresponding weight. The second section
is for an afflount paid to the C.l. for information and assistance and includes blanks for the amount paid and the C.l.'s signature. The third
section is for an amount provided to the C.l. to purchase narcotics and includes blanks for the amount paid and the C.l.'s initials. The fourlh
section provides a space for details. The fifth section starts with the word "Witness" followed by a blank for a printed name and a blank for
a signature. The sixth section goes on to provide blanks forthe signatures of the revierving sergeant and the reviewing lieutenant.
Affiant reviewed documents provided by HPD pursuant to this investigation, inclLrding C.l. F-orms, cxpense reports, offense repofts,
oveftime request forms, and expense authorization forrns, and specifically all docurnentation relating to HPD OR number 05 149 l4-18.
Affiant observed that in the C.l. Activity Sheet/Receipt lor Funds Forrn associated r,vith this reporl nunrber, the defendant signed that he
witnessed Goines make a payment to C.l. # I on April 23,2018 at l8:00 hours lor a buy allegedly made at 6807 Goforth in Houston, Harris
County, Texas. C.l. #l denied making any buys at this location.
Affiantpreviouslyobtainedsearchwarrantslorcell sitedataforthepersonal cell phonesofthedefendant,Goincs,andC,l,#1. Affiantwas

provided a copy of the cell site data returned as a result of those warrants. The data for the defendant came fi'om Sprint and ranged from
January 8,2018 through February 1,2019. 'l-he data lor Goines carrre lrorn 1'-Mobile and ranged from March 29,2018 through February l,
20l9.ThedataforC.l.#lcamefromAT&TandrangedfromMarch25,20lTthroughDecenrberSl,20lS.l'hisdatawasprovidedto
Nathan Gates (Gates), a Lieutenant lnvestigator and Digital Forensic Exarniner currently crnployed within the FICDAO Digital Forensic
Unit. During the time period for which data was returned, Gates rnapped the coordinatcs of the cell phone data for the defendant, Goines,
and for C.l. #l for the dates and times of each payment documented.
ln reviewing the defendant's cellsite mapping for this date and time, Affiant obscrved that the defendant's cetl phone was in use and
travelling from approximately l6:38 hours to l6:5 I hours, approximately along U.S. 59 between the 610 Loop and State Highway 288,
Affiant observed that there is no call data showing his location to be any closer to 6807 Golorth at or near the tinre of the alleged buy. In
reviewing the cell site mapping for Goines, Affiant observed that his cell phone was in use at 18.25 hours in the Cypress area, a location
Affiant knows to be approximately thirty (30) miles away from 6807 Golorth. In reviewing the ccll site mapping for C.l. ill forthis date and
time, Affiant observed that C.l. #l's cell phone was in use from approximately l6:40 hours to l9:29 hours in the area of SH-288 and I-45, a
location that Affiant found to be approximately five (5) rniles away 6807 Goforlh.
Based on the above information, Affiant has reason to believe that neither thc alleged buy nor the allcgcd payment for said buy took place as
documented by Goines and the defendant, and thus Affiant has reason to believe that the defendant did not witness any allcged payment to
C.l. #1 at l8:00 hours on April23,20l8, as documented by the dclcndant in thc C.l Activity Shcet / Rcceipt for Funds Fonn. Texas Penal
Code Section 37.10, Tampering with a Covernmental Record, provides that, arnongst other rneans, "a person comrnits an ollense if he
knowingly makes a false entry in, or false alteration of, a governmental record." 'lexas Pcnal Code Scction 31 .01(2) providos that a
case#158088u CRT#228
"Governtnental Record" includes "anything belonging to, received by, or kept by governrncnt ior information, including a court record."
The C.l. Forms described above are required by a General Order to be completed for all C.l. payrnents. 1'hey are kept by HPD to document
C.l. activity and involvement in narcotics investigations. Affiant is aware that I-ICDAO has requested and received frorn FIPD C.l. Fonns
dating back more than 20 years. HPD is a subdivision of the City olHouston, a rnunicipality.
Affiant therefore believes that the defendant did commit the offense of tarnpering witha governmental record on or about April 23,20 18, in
Houston, Harris County, Texas by knowingly making a false entry in a governmental rccord, narnely a Houston Police Department
Narcotics Division C.l. Activity SheetiReceipt for Funds Form, and that this olfense was cornmittcd with the intent to delraud the Houston
Police Department,
ACAINST THE PEACE AND DICNITY OF THE STATE.
Signed and sworn by me on

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AFFIANT ASSISI-ANT DIS'f RICT ATTORNITY

OF I]ARRIS COUNTY,'|EXN S
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Witness (Peace Officer)
Witness Printed natne & Badge or Payroll nutnber
COMPLAINT
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JUDGE KI.LI.I JOI]NSON
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REPORT: DIM6o1 JUSTICE ]NFORMATION MANAGEMENT SYSTEM TIME: 4:79
DATE 07 / 0r/20 D.A. TNTAKE MANAGEMENT SYSTEM
DEFENDANT DESCRTPTORS
# : 2653103
TRANSACTION D.A. LOG # 2553103
IN CUSTODY....: N CARINDICATOR ID BY PRINTS
DATE OF ARREST: TIME OF ARREST
sPN #. ......: 03014551
AFIS NUMBER...:
DEFENDANT NAME: BRYANT, STEVEN O
ALIAS NAME.... :
ALTAS SPN..... :
US ClTIZEN INS# :
ALLIEN STATUS i TLLEGAL CODE

PLACE OF BIRTH: CTTY OF BIRTH:
RACE..........: B SEX: M DOB: 1,2/r8/L973
MARITAL STATUS: BUILD: HEV HEIGHT: 607 WEIGHT: 275
HATD SKIN:
qr-1De
LGT EYES: BRO
STREET ADDRESS 12OO TRAVIS

CITY.. HOUSTON, TX ZIP:
PHONE () AETT.
EMAIL:
CELL OPT.]N: EMAIL OPT_IN
PRIOR ARREST?: Y FBI#: STATE rD #' TXlO8l4222
AGENCY ID#..: DAO SSN: so# : 2769433
ALIAS SPN(S) ,:
DL#......,..: 76187220 DL ST: TX
co-DEFENDANTS? 6-
DOES TI{E DEFENDANT IIAVE A SPN? Y N
PRINTED | 07 /0t/2020 O4:19 (CASS JAMES M) DIM5O1

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THE STATE OF TEXAS D.A. LOG NLJMBER: 2653127
03014651 \
VS.
STEVEN O. BRYANT
TRAVIS
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HOUSTON, TX77002
SPN:03014651
DOB: B M l2l18/1973
DATE PREPARED: 1 ll 12020
CJIS TRACKING NO
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AGENCY:DAO
OrR NO: S1907
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FELONY CI-IAITGE: AGC THEFT PUB SERV E
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CAUSE NO: COURT ORDI]RED BAIL: TO BE SET
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HARRIS COUNTY DISTzuCT COURT NO: MAGISTRATION o
PRIOR CAUSI] NO:
i:
FIRST SETTING DATE:
CHARGE SEQ NUM: I
Before me, the undersigned Assistant District Attorney of Harris County, Texas, this day appeared the undersigned affiant, who under oath says
that he has good reason to believe and does believe that in Flarris County, Texas, STEVEN O. BRYAN'[, hereafter styled the Defendant,
heretofore on or about March 21,2018 continuing through January 22,2019, did then and thcre unlarvlully, while a public servant, namely,
a Texas Peace Officer, and pursuant to one scheme and continuing course of conduct, appropriate, by acquiring or otherwise exercising
control over propefty, namely, money and compensatory tirne, owned by the llouston Police Departlncnt and the City of llouston,
hereinafter styled the Complainant, of the value of at least two thousand flve hundred dollars but less than thirty thousand dollars, with the
intent to deprive the Complainant of that property, and said properry canre into the Delendant's custody, possession and control by virtue of
the Defendant's status as a public servant.
Probable Cause:
Affiant, Investigator Jonathan Prykyl, is a certified peace olficer employed by the Harris County District Attomey's Officc (HCDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to believe and does believe that forrncr Houston Police Deparlment (IJPD)
Oflrcer Steven Bryant, hereinafter the defendant, did commit the third degree fetony olfense of theft by a public servallt, in an amount more
than twenty-five h undred dollars but less than th irty thousand do llars, on or about March 2 I , 20 I 8, and continu ing through January 22,
2019, in Houston, Harris County, Texas. Affiant bases this belief on the following:
Affiant is aware of and has reviewed HPD General Order (G.O.) #300-07, subject "Ove ftime Compensation." It outlines oveftime (OT)
compensation for all classified employees of HPD lvho hold the rank of police officer, senior police officer, or sergeant, or other employees
withapaygradeequivalentofsergeantorbelow. Pertinentexcerptsarequotcdbelow:
Except as otherwise noted in this Ceneral Order, all overlime earned shall be compensated at the rate of time and a half.
Officers shall have the option of overlime pay or cotnpensatory time for ovefiime workcd, unless the compensatory tirne bank limit would
be exceeded.
At the time of an officer's separation 1lorn the deparlrnent as a classified ernployee, all banked compensatory tirne (depending on how it was
accrued) shall be administered in accordance with the applicable larv or the applicable Mect and Conler Agreernent.
Officer requesting overtime compensation shall subrnit the appropriate overtinle reqttest lbrrn.
Affiant reviewcd overtime forms requested lrom HPD by IICDAO pertaining to the dclcndaut lor 2011 and 20 18. Affiant observed that the
,.Houston Police Deparlment Overlirne Request Forrn" (Ove(irne Forrn). Affiant lurthcr obscrved thc forms to contain four
forms are titled
sections. The first section contains the narne and employee nurnber olthe crnployee requcsting cotnpensation, the date and hours worked,
whetherpayorcompensatorytirneisbeingrequcsted,the total nurnberofhourscotnpetrsationrequested,andthelocation. Thesccond
related incident nutnber.
section coniains,,overlirne 6odes," the Squad number of thc requesting officer, dctails olrvork pcrforttted and the
signature of the
The third section has a certification that the request is "correct and in accordance',vith GO 300-07," follorved by the
officer. 'l'he fourlh scction provides space for
requesting officer, as well as a listing of thc regular duty hours and days ol-f oithe rcquesting
rcqrrcst followcd by space for posting inforrnation.
a rlviewing supervisor and reviewing rnember of,comrnand stalf to approvc or deny the
for Overlirne Cotnpensation Can Result in Adrninistration
J'he bottorn of the form contains a notation reading, "Falsifying a Request
Discipline and Crirninal Prosecution."
case#l6808821 CRT#228
ln addition to the deflendant's Overtime Forms, Affiant reviewed the offense reports (OR) for the incident numbers listed on each form
reviewed. Affiant conducted research through law enforcement databases in order to determine the delendant's home address.
Affiantreviewedapreviouslyobtainedasearchwarrantfor20 l8cell sitedataforthepersonal cellphoneofthedefendant. Thedata
retumed was provided to Nathan Gates (Gates), a Lieutenant Investigator and Digital Irorensics Exarniner cur-rently employed within the
HCDAO Digital Forensics Unit. For the periods for which data was obtained, Gates mapped the coordinates of the cell site data for the
defendant's cell phone during the times for which defendant requested OT cornpensation.
Affiant observed an Oveftime Fonn signed by the defendant requesting pay compensation I'or 8 hours of Ol' worked llom 1800 hours on
March2l ,2018, to 0200 hours on March22,20l8, and detailing two narcotics search warrant executiorrs. Incident Nos. 0358101-18,
0357661-18,and0358013-l8arelisted. AffiantrevicwcdtheORforlncidentNo.0358l0l-l8andobservedthereporltodocumenta
narcotics search warrant execution conducted on March 2l ,2018,at67 19 New York, at 1123 hours. Affiant reviewed the OR for Incident
No. 03 5766 I - I 8 and observed the reporl to document a narcotics search warant execution cond uctcd on March 2l , 20 18, at 3 0 I I N agle, at
l740hours. AffiantreviewedtheORforlncidentNo.03580l3-l8andobservedthereporltodocurnentanarcoticssearchwarrant
execution condLrcted on March 21 ,2018, at 5907 Beldart, at 1900 hours.
ln reviewing the defendant's cell site mapping lor I 800 hours on March 2l , 20 I 8, to 0200 hours on March 22,20 18, Affiant observed that
the defendant's phone connects to towers in the area of30l I Nagle between 1807 and 1830 hours. 'fhe defendant's phone connects to a
tower in the area of 67 19 New York at approximately 18.1 I hours. The defendant's phone coltnccts to towers in the area of the Southeast
Station, 8300 Mykawa between 184 I and 2057 hours. l'he defendant's phone connects to a towcr along South Beltway 8 for a phone call
beginningat2222hours. Attheterminationofthatphonecall thedefendant'sphoneisconnectedtoatowerintheareaofGreatwood
(approximately at the intersection of South Grand Parkway and US 59), which includes thc area olthe defendant's residence.
Based on the above information, Affiant has reason to believe that the defendant worked no nrore than five of the eight hours documented in
his March 2l ,2018 Overtime Form, and thus any form of payment received from HPD for the additional three hours alleged constitutes a
theft.
Affiant observed an Overtime Form signed by the delendant requesting pay compensation lor 8 hours of OT worked fiom 1800 hours on
April 4,20l8,to0200hoursonApril 5,20lS,anddetailing"streetpop"investigations. IncidentNos.0423569-18,and0423110-l8are
listed. AffiantreviewedtheORforlncidentNo.0423569-l8andobservedthereporltodocurnenta"buybust"operationconductedon
April 4, 20 I 8, at l2 100 Fondren, at 1822 hours. The delendant is not mentioned in this repon. Affiant reviewed the OR for Incident No.
042377 0-l8 and observed the report to document a narcotics search warrant execution cond ucted on Apri I 4, 2018, at 12lr28 Fondren, at
-l'he
1900 hours. The defendant is mentioned in this report as perlorrning surveillance. report indicates the final arrest time as 1933 hours.
Inreviewingthedefendant'scell sitemappingforl800hoursonApril 4,2018,to0200hoursonApril 5,20 l8,Affiantobservedthatthe

defendant'sphoneconnectstotowersintheareaoll2l00Fondren andl222l Fondrenbctween l8l5and l948hours. Thedefendant's
phone is connected to a tower in the area ofthe defendant's rcsidence, between 203 I and 2248 hours.
Based on the above information, Affiant has reason to believe that the defendant workcd no more than three of the eight hours docurnented
in his April 4,2018 Overtime Fornr, andthus any form of payment received from IIPD forthe additional five hours alleged constitutes a
theft.
Affiant observed an Oveftime Form signed by the defendant requesting pay compensation lor 6 hours of OT rvorked liorn 1800 to 0000
hours on April 23,2018, and detailing narcotics investigation. lncident No. 05 14914-18 is listed. Alfiant revierved the OR for Incident No.
0514914-18 and observed the report to docutnent a controlled buy conducted on April 23,2018, at 6807 Goforth, at 2100 hours. Affiant
reviewed HPD documentation indicating that the confidential informant (CI) utilized for the controlled buy was registered to former HPD
Officer Gerald Goines. Affiant has reviewed a recorded interview with the CI utilized for this controlled buy and noted that the Cl stated
that they never performed any controlled buys at 6807 Goforth.
lnreviewingthedefendant'scell sitemappingfor l800to0000hoursonApril 23,20 lS,Afflantobscrvedthatthedeflendant'sphone
connects to a tower the area the defendant's residence, between 2042 and 2 I 20 hoLrrs.
Based on the above information, Affiant has reason to believe and does believe that the def'endant worked none of the six hours docurnented
in his April 23,2018 Oveftime Form, and thus any forrn of payment received flom HPD lor those six hours alleged constitutes atheft.
Affiant observed an Overlime Form signed by the defcndant requesting pay cornpensation lor 8 hours olOT worked from 1800 hours on
April 25,20 l8to0200hoursonApril 26,20l8,anddetailingtheexecutionoftwonarcoticssearclrwarrants. IncidentNos.05l9738-18
and05 19974-lSarelisted. AffiantreviewedtheORlorlncidentNo.05 19738-l8andobservcdthcreporltodocumentasearchwarrant
execution on April 25,2018, at 8335 Parnell, at 1700 hours. Affiant reviewed the OI{ lor Incident No.05 19974-18 and observed the report
todocumentasearchwarrantexecutiononApril 25,2018,at6807Goflor-th,atl820hours. Affiantnotcdthatthedefendantisnotthecasc
agent lor either investigation.
case#16808821 CRT#228
In reviewing the defendant's cell site mapping for I 800 hours on April 25, 20 I 8 to 0200 hours on April 26, 2Ol8, Affiant observed that the
defendant's phone does not connect to towers in the area of 8335 Parnell or 6807 Golorrh. 'l'he defendant's phone connects to towers along
SouthBeltway8duringaphonecallbeginningat2009hours. Thedefendant'sphoneconnectstoato\verintheareaofthedcfendant's
residence, at2159 and 2221 hours.
Based on the above information, Affiant has reason to believe that the defcndant worked no lnore than two of the eight hours documented in
his April 25,2018 Overtime Form, and thus any forrn of payrnent received from HPD for the additional six hours alleged constitutes a theft.
Affiant observed an Overtime Form signed by the defendant requesting pay compensation for 6 hours of OT worked from 1800 to 0000
hours on May 17,2018, and detailingthe execution of two narcotics search warrants. IncidcntNos.0624688-18 and 0625013-18 are listed.
Affiantreviewed the OR for lncidentNo.0624688-18 and observed the reporlto doculnent a search warrant execution on May ll ,2018,at
5033 Doolittle, at 1609 hours. Affiant reviewed the OR for Incident No. 0625073-18 and observed the report to document a search warrant
execution on May 17,2018, at 860 I Amadwe, at 1700 hours. Affiant noted that the defendant is not the case agent for either investigation.
ln reviewing the defendant's cell site mapping for I 800 to 0000 hours on May 17, 201 8, Affiant observed that the defendant's phone does
notconnecttotowersintheareaof5033Doolittleor860 IArnadwe, l'hedefendant'sphoneconnectstotowersintheareaofdowntown
nearHPDHeadquafters, locatedat l200Travis,betwecn l8l I and 1832 hours. Duringaphonecallbeginningat 1855 hoursthe
defendant'sphoneconnectstotowersalongUS5g. ThephoneconncctstoatowerinthcalcaofGrandParkwayandUS5gatlg03hours.
Between 1923 and 2 | I I hours the defendant's phone connects to tou'ers in the area ofthe area ofthe defendant's residence.
Based on the above information, Affiant has reason to believe that the defendant rvorked no more than one of the six hours documented in
his May 17,2018 Overlime Form, and thus any form of payment received lrom HPD fbr the additional five hours alleged constitutes a theft.
Affiant observed an Overtime Form signed by the defendant requesting compensatory tirne compensation lor 8 hours of Ol'worked from
l600to0000hoursonMay23,2018,anddetailingtheexecutionoftwonarcoticssearchwarrants. IncidentNos.0655473-18and0653465-
l8 are listed. Affiant reviewed the OR for lncident No. 0655473-18 and observed the reporl to document a search warrant execution on
May23,2018,at28 l9Berry#5,atl700hours. AffiantreviewedtheORlorlncidentNo.0653465-l8andobservedthereporttodocument
asearchwarrantexecutiononMay23,20lS,at28l9Berry#8,at l700hours. Affiantnotedthatthedefendantisnotthecaseagentfor
either investigation.
In reviewing the defendant's cell site mapping for 1600 to 0000 hours on May 23,201 8, Affiant observed that the defendant's phone does
connect to towers in the area of 28 I 9 Berry at I 823 and I 824 hours. At I 920 hours the defendant's phone connects to a tower in the area of
the defendant's residence.
Based on the above information, Afflant has reason to believe that the defendant worked no more than four of the eight hours documented in
his May 23,2018 Overtime Form, and thus any form of payment received frorn IIPD for the additional four hours alleged constitutes a theft.
Affiant observed an Overtime Form signed by the delendant requesting pay compensation for 4 hours of Ol- rvorked llom 1800 ro2200
hoursonOctober9,20lS,anddetailinganarcoticssearchrvarrantexecution. IncidentNo. 1282333-lSislisted. AffiantreviewedtheOR
forlncidentNo. 1282333-l8andobservedthereporttodocumentasearchwarrantexecutiononOctober9,20 18, at3409 Mcllhenny,at
1640 hours. Affiant noted that the delendant is not the case agent for this investigal.iou.
I n review ing the defendant's cel I site nrapp ing for I 800 to 2200 hours on October 9, 2 0 I 8, A ffi ant observed that the defendant's phone
neverconnectstotowersintheareaof3409Mcllhenny. Duringaphonecallbeginningat lS04hoursthedefendant'sphoneconnectsto

towers along I- 10 west of downtown and then to a tower in the approxirnate area of FM 529 and West Grand Parkway. The phone connects
to another tower in that approximate area at 2028 hours.
Based on the above information, Affiant has reason to believe that the dclendant worked nonc olthe fbLrr hours documented in his October
9,2018 Overlirne Form, and thus any forrr.r of payrnent received frorn HPD lor those four hours allcged constitutes
a theft.
Affiant observed an Overtime Fonn signed by the delendant reqLresting pay conrpcnsation lor 8 hours of OT worked lront 1800 hours on
Novemberl,20lSto0200hoursonNovernberS,20 l8,anddetailingundercovcrnarcoticsinvcstigations. IncidcntNos. l4l28ll-18,
1413062-18,and1413305-l8arelisted. AffiantreviewedtheORlorlncidentNo. 14128 ll-lSandobservedtherepofitodocurnentabuy
bust operation on November7,2018, at21 00 Hamilton. '[he repoft docurnents the offense tirne and thc amcst tirne to be 1625 hoLrrs.
AffiantnotedthatthedefendantisnotmentionedintheOR. AffiantreviewedtheORforlncidentNo. 1413062-18andobscrvedthereporl
to document a buy bust operation on Novernberl,2018, at 1000 Elgin. 1'he repoft docurrcnts the oflense tirnc and the arrest tinre to be
lTl6hours. AffiantreviewedtheORforlncidentNo. 1413305-l8andobservcdthercporttodocumentabuybustoperationonNovember
1,2018, at 1000 Elgin. The repoft documents the offense time and the arrest tirne to bc lU04 hours. Afllant noted that the defcndant is not
the case agent for any ofthe investigations.
Case#15808821 CRT#228
Inreviewingthedefendant'scellsitemappingfor l800hoursonNovemberl,2018 to0200hoursonNovember8,20lS,Affiantobserved

thatthedefendant'sphoneconnectstotowersintheapproximateareaof2l00Harniltonandl000E,lginbetweenl8l3andl856hours. The
defendant'sphoneconnectstoatowerintheareaofthedelendant'sresidence,attheconclusionolaphonecall beginningat l935hours
and then again at 2056 hours.
Based on the above information, Affiant has reason to bclieve that the defendant worked no more than two olthc cight hours documented in
his November7,2018 Overlime Form, and thus any lorrn of payment received frorr HPD for the additional six hours alleged constitutes a
theft.
Affiant observed an Overlime Form signed by the defendant requesting pay compensation for 8 hours olO-l'worked from 1800 hours on
December12,2018to0200hoursonDecemberl3,20 l8,anddetailingundercovernarcoticsinvestigations. lncidentNos. l564446-l8and
1564692-18arelisted. AffiantreviewedthcORforlncidentNo. 1564446-l8andobservedthereporttodocumentabuybustoperationon
December 12,2018, at2l ll Fannin, at 1635 hours. The reporl documents two arrests at 1630 hours. Alfiant noted that the defendant is not
mentionedintheOR. AffiantrevicwedtheORforlncidentNo. 1564692-l8andobservedthereporttodocumentabuybustoperationon
December 12,2018, at 1000 Hadley, al 1742 hours. The reporl documents two arrests at 1745 hours. Alfiant noted that the defendant is not
mentioned in the OR.
In reviewingthe defendant's cell site mapping ior 1800 hours on December 12,2018 to 0200 hours on December 13,2018 Affiant observed
thatthedefendant'sphonedoesnotconnecttotowersintheareaof2lll Fanninorl000 lladley, l'hedefendant'sphoneconnectstoa
tower in the area of Greater Third Ward at 1803 hours. During a phone call beginningal2020 hours, the defendant's phone connects to a
tower in the area of Brookside Village and then to a tower in the area of the defendant's residence.
Based on the above information, Affiant has reason to believe that the defendant worked no lnore than three of the eight hours documented
in his December 12,2018 Overtime Form, and thus any forrn of payment received frorn llPD forthe additional five hours alleged
constitutes a theft.
Affiant observed an Overlime Form signed by the defendant requesting pay compensation for 5 hours of OTworked frorn 1800 to 2300
hours on January 22,2019, and detailing a controlled buy and indicating that after the buy officers tagged the evidence at 1200 Travis, HPD
Headquarters. IncidentNo.0095844-l9islisted. AffiantreviewedtheORlorlncidentNo.0095844-l9andobservedthereporlto
documentacontrolledbuyonJanuary22,2019,at443l KnoxvilleatlS00hours. Thereporlindicatesthattheevidencewasnotsubmitted
until January 23,2019 at 1504 hours.
In reviewing the defendant's cell site mapping for I 800 to 23 00 hours on January 22, 2019, A fflant observed that the defendant's phone
neverconnectstotowersintheareaof443l Knoxvilleorl200Travis. Thedefendant'sphoneconnectstoatowerintheareaofl-l0and
WestGrandParkwayduringthistirne. Thedeflendant'sphoneconnectstotowersinthearcaofthedefendant'sresidencebetween l826and
2024 hours.
Based on the above information, Affiant has reason to believe that the defendant rvorked none of the five hours documented in his January
22,2019 Overlime Form, and thus any form of payment received from tlPD for those alleged fivc hours constitutes a theft.
Each of the Overtime Forms discussed herein indicates by a check rnark and a signature that they were approved by a supervisor and a
rnember of the command staff for payment and further lists a "date posted." Thus affiant has probable cause to believe the defendant was
paid for the OT requested.
Affiant reviewed business records received from the City of Houston, Administration and Regulatory Affairs Dcpaftment. The records
include the oveftime "calculated rate of pay" for the defendant for2018. Affiant observed the defendant's overlime calculated rate of pay to
be $62.34 on January I , 20 I 8, through pay date J uly 20, 20 I 8. Beginning pay date August 3, 20 I 8, and continuing through pay date
November 21 ,2018, the defendant's oveftime calculated rate of pay is $64.19. Beginning pay date December 1,2018 and continuing
through the end of January 2019, the defendant's overlirne calculated rate of pay is $64.23.
Based on the hours and rate ofpay discussed above, Affiant has reason to believe and does bclieve the lollowing reflects the value ofpay
and compensatory time acquired by the defendant without the effective consent of HPD and the City of Houston:
case#16808821 CRT#228
OTCI.AIMEI' ACruALOT COFFECT PAYI'ENT

PAYMENT HOURS AMOUHT OVEBPAYME}IT
3/2Ni2018 s62 34 o s498 72 ) $311 70 $187.02
4J4,'2018 $.62.34 I $4S8 72 1
ils7.42 $311-70
4123/2018 $62.34 6 $374.04 0 s0.00 $374.04
4/25,',2018 $62.34 M98.72 2 $124-68 $374.04
5/17120 1 8 s62.34 6 w4.04 1 $62 34 $311.70
5t23i2018 $62.34 I w9472 4 $249.38 $249.36
1 0i 9/201 I s64.19 4 s256.76 s0 00 $256 76
1117t2019 864-1 I I $513.52 $1 28 38 $385 1 4
12J12,2018 $6,4 23 s $513.84 3 $192.6S $321.15
1t22J2019 $84_23 t s321.r 5 0 s0 0s $321,1 5
Based on the above information, Affiant has reason to believe that the defendant did not actually work all of the hours for which he
submitted an Overtime Form, and for which he was compensated, and thus that the defendant unlawfully appropriated compensation from
HPD. Texas Penal Code Section 31.03, Theft, provides that, "a person commits an olfense if he unlarvlully appropriates propefty with intent
to deprive the owner of propefty," and that "appropriation is unlawful if it is without the olvner's el-fective consent." This Section also
provides that if the value of the properly stolen is $2,500 or more but less than $30,000, the offense is a State Jail Felony. l'his Section
furlher provides that the offense is increased to the next higher category ofoffense ifit is shown on the trial ofthe offense that "the actor
was a public servant at time of the offense and the properly appropriated came into the actor's custody, possession or control by vinue of his
statusasapublicservant." TexasPenal Code l.0Tprovidesthatapublicservantincludesapersonemployedasanofficerofgovernment.
The City of Houston is a government entity located within Harris County, Texas. HPD is a subdivision of the City of Houston.
Affiant has reviewed Texas Penal Code Section 31.09 and knows that when amounts are obtained in violation olChapter 3l (Theft)
pursuant to one scheme or continuing course ofconduct, whether from the same or several sources, the conduct may be considered as one
offense and the amounts aggregated in determining the grade of offense.
Affiant therefore has reason to believe and does believe that on about March 2l ,2018, though January 22,2019, while a pubtic servant,
namely a Texas Peace Officer, and pursuant to one scheme and continuing course of conduct, Steven Bryant did then and there unlawfully
appropriate, by acquiring or otherwise exercising control over propefiy, namely, money and compensatory time, owned by the Houston
Police Department and the City of Houston, hereinafter styled the Complainant, of the value of at least two thousand five hundred dollars
but less than thirty thousand dollars, with the intent to deprive the Complainant of that propefiy, and said properry came into the
Defendant's custody, possession and control by virtue ofthe Defendant's status as a public servant.
AGAINST THE PEACE AND DICNITY OF THE STATE
Signed and sworn by me on l- Duly attested by ,aon o 0t /" ob0
AFFIANT ASSIS ANT DIS RICT ATTORNEY

OF I]ARRIS COUNTY, TEXAS
I Qq nt o,
Bar No.
l>\s>q()L
Witness Printed name & Badge or Payroll number
COMPLAINT
a
.JULY'i 2O20
o
ot)
"''tQhoin=,.,riin NSON
":n
-{0
, t':.'u :,..) li;r: i;1.-:t t\i. ;,:.,r.:

REPORT: DIM501 JUSTICE INFORMATION MANAGEMENT SYSTEM TIME: 4:42
DATE | 0't / 0t /20 D.A. INTAKE MANAGEMENT SYSTEM
DEFENDANT DESCRIPTORS
TRANSACTION # : 265372't D.A. LOG #: 2553L27

IN CUSTODY... . : N CARINDICATOR ID BY PRINTS:
DATE OF ARREST: TIME OF ARREST:
sPN #.. ... ..: 03014551
AFIS NUMBER.. . :
DEFENDANT NAME: BRYANT, STEVEN O

ALIAS NA]VIE....:
ALIAS SPN.....:
US CITIZEN :Y INS#
ALLIEN STATUS : ILLEGAL CODE
PLACE OF BIRTH: US CITY OF BIRTH:
DAl,atr SEX:
B M DOB : 12 / tg /t9'13
MARITAL STATUS: MA BUILD: HEV HEIGHT: 607 WEIGHT: 275
HATR.. .... ..: xxx SKIN: LGT EYES: BRO
calDc
STREET ADDRESS | 1200 TRAVIS

CITY.. ..: HOUSTON, TX ZIP: '77002
PHONE....... : ( ) CELL: EMAIL:
CE]:L OPT- IN: EMAIL OPT-IN
PRIOR ARREST? Y FBI# STATE fD #: TXI0874222
AGENCY ID#. . : DAO SSN so# : 2169433
ALIAS SPN(S) .
DLt+. , , 767 8L220 DL ST: TX
EMPLOYER...... : RETIRED
OCCUPATION..,. : RETIRED
MENTAL ILLNESS .... .: N
CO-DEFENDANTS ?
DOES THE DEFENDANT HAVE

G
A SPN? € N
PRTNTED | 07 /Ar/2020 o4:42 (CASSlDy, JAMES M) DrM6O1

THE STATE OF TEXAS
03014649
*& t"C
D.A. LOG NUMBER: 26531l6
VS.
CERALD MICHAEL GOINES
I2OO TRAVIS
SPN:03014649
DOB: B Nl l0l2lt964
CJIS TRACKINC NO.:
BY: EH DA NO: 2425968
AGI]NCY:DAO
t
HOUSTON, TX77004 DATE PREPARED: 7 ll 12020 O/R NO: SI907 i
tr
ARREST DATE: TO BE
NCIC CODE:4802 33 RELATED CASES:
CAUSE NO: COURT ORDERED BAIL: TO BE SET A E.

HARRIS COUNTY DISTRICT COURT NO MAGISTRATION
16808EJ
228
CHARGE SEQ NUM: I
Before me, the undersigned Assistant District Attorney olHarris County,'[exas, this day appeared the undersigned affiant, who under oath says
that he has good reason to believe and does believe that in Hanis County, 'l'exas, GERALD MTCHAEL GOINES, hereafter styted the
Defendant, heretofore on or about October 15, 2017, did then and there unlawfully, knowingly rnake a false entry in a governmental record,
namely, a search warrant issued by a magistrate.
It is further presented that on or about October 15,2017, in Harris County, Texas, the Defendant did then and there possess a govemmental
record, namely, a search warrant issued by a magistrate, with the intent that it be used unlawfully.
It is further presented that on or about October 15,2017, in Harris County,'fexas, the Defendant did then and there make, present, and use a
governmental record, namely a search warrant issued by a rnagistrate, with knorvledge of its falsity.
PROBABLE CAUSE:
Affiant, Lieutenant Billy Milan, is a cerlified peace officer employed by the llarris County District Attorney's Office (IICDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to believe and does believe that forrner ilouston Police Dcpartrnent (HpD)
Olficer Gerald Goines, hereinafter defendant, did cornmit the third degree fclony offense of tanrpering with a governmental recorcl on or
about October 15,2017, in Houston, I-larris County, I'exas. Affiant bases this belief on the following:
On January 15,2020, the defendant and forrner HPD Narcotics Officer Steven Bryant (Bryant) were indicted for Tampering with a
Governmental Record, see Harris County Cause Nos. 1660164 and 1643521 , respectively. These charges center on false statements sworn
to by the defendant in obtaining a narcotics search warrant for a residcncc located at 7815 I{arding Street and false staternents rnade in the
conesponding off,ense reporl by Bryant. Execution of that search wan'aut lcd to the death of both homeowncrs, injury to four IIPD officers,
and thereafter an IIPD investigation into the defendant's use of confidcntial inlormants (C.l.s) to obtain search warrants.
Affiant reviewed the HPD offense report (OR) docurnenting that invcstigation, l{PD OR No. 133932-19, authored by Sergcant Rick Bass, a
licensed peace officer currently employed by IJPD, and learned the following: All C.l.s registcred to the defendant were interviewed and
each denied having completed a controlled buy at Harding Street, despite the probable causc affidavit for the s€arch warrant lor that location
statingthataC.l.hadcompletedacontrollcdbuythedaypriortothedateolthealfidavit. OneoftheC.l.srvhowasinterviewed
(hereinafterrefenedtoasC.l.#l)repo(edtohaveattirncsbeenpaidbythedefendantforworknotpreforrncd. C.l.#tgaveavideo
Case#1680883/ CRT#228
interview during which C.l. #l was asked about several locations where, according to official HPD records (specificatly C.l. Forms
discussed more fully below), C.l. #l had conducted controlled buys. C.l. #l denied having conducted sevcral olthose buys, each of which
led to a narcotics search warrant.
AffiantisawareofandhasreviewedHPDCeneral Order600-16(GO)whichgovernsC.l.sandpaymcntstoC.l.s. TheGOholdsthat,,all

meetings between a C.l. and an officer shall be attended by two officers." This regulation requires that that at least two oftlcers be present
when a controlled buy is conducted. lt fufther mandates that "officers shall not pay a confidential informant without the appropriate witness
present." The GO goes on to dictate how payrnents to C.l.s will be documented, stating that altpayments to C.l.s "shall be firlly
documented on a division's'Confidential tnformant Receipt for Funds lonn"'(C.1. Form) with "control information" to include the
signature of the C.l. as an agreement that the payrnent was received, the signature of the investigator rnaking the payment, the signature of at
least one other officer witnessing the payment, and the date of the payrnent. These forms, as dictated by the GO, require that at least three
people-theC.l.,theinvestigator,andawitness-betogetherinoneplaceinorderforapaymenttooccur. Affianthasreviewednumerous
HPD C.l. Forms and has noted that these forms also include the time of the payrnent and the associated OR number for the OR wherein the
controlled buy is documented.
Affiant has also reviewed the Special Investigation Command, Narcotics Division, Standard Operating Procedures (SOP). SOp 100/2.05
covers "Confidential Informant Funds/Expense Letters, Limits of Authorization and Use of Flash Money" and includes a section on "CI
Payments & Receipt for Funds Form." That section repeats the requirernents of GO 600-16 and also specifically states, "The CI Receipt
for Funds form will be completed at the time of the payrnent to the CI" (emphasis in original). Affiant has reviewed the specific C.l. Form
used by the HPD Narcotics Division, titled "C.1. Activity Shect / Receipt for Funds F-orrn." The forrn has six sections. The first section
includes C.l. name, date, time, location, OR nutnber, and blanks for up to two drug types and the corresponding weight. The second section
is for an amount paid to the C.l. for information and assistance and includes blanks lor the anrount paid and the C.l.'s signature. The third
section is for an amount provided to the C.l. to purchase narcotics and includes blanks for the arnount paid and the C.l.'s initials. The fourth
section provides a space for details. The fifth section stans rvith the rvord "Witness" lollorved by a blank lor a printed name and a blank f,or
a signature. The sixth section goes on to provide blanks for the signatures of the rcviewing sergeant and the reviewing lieutenant.
Affiant reviewed documents provided by HPD pursuant to this investigation, including C.l. Forms, expense reports, offense reports,
overlime request forms, and expense authorization forms, and specifically all documentation for I-lPD OR nurnber 130597 l-17. Affiant
observed that the defendant subrnitted a C.l. Activity Sheet/Receipt for Funds Form associated with this reporl number, wherein he stated
that he made payments to.C.l. #l on October 14,2017 at l5:00 hours for a buy allegedly made at 4855 Fuqua #2301 in Houston, Harris
County, Texas. The defendant further states in this document that the C.l. purchased rnarijuana at this location on that date. The defendant's
supervisor former FIPD Sergeant Clemente Reyna (Reyna) signed this form as a rvitness to these alleged payments. C.l. #l denied making
any buys at this location.
Affiantpreviouslyobtainedsearchwarrantsforcell sitedataforthepersonal cellphonesofbothReynaandC.l.#1. Affiantwasprovideda

copyofthecell sitedatareturnedasaresultofthosewarrants. l'hedataforReynacamefromAT&TandrangedfromFebruary2l ,2011
through December 17,2018. The data for C.l. #1 came ffom AT&T and ranged from March 25,2017 through December 31,2018. This data
was provided to Nathan Gates (Gates), a Lieutenant Investigator and Digital Forensic Exarniner currently employed within the HCDAO
Digital Forensic Unit. During the time period for which data was returned, Cates nrappcd the coordinates of the cell phone data for Reyna
and for C.l. #l for the dates and times of the documented payrnent,
In reviewing Reyna's cell site mapping for this date and time, Affiant observed that Reyna's cell phone was in use and travelling from
approximately 14:30 hours to l5:51 hours in the area between approximately the Highway 6 and Westpark Tollway intersection and
approximately the Highway 6 and U.S. 290 intersection, locations that Affiant found to be approxinrately twenty-five (25) rniles and forty
(40) miles away from 4855 Fuqua, respectively. In reviewing the cell site rnapping for C.l. # t for this date and time, Affiant observed that
C.l. #l's cell phone was in use from approximately l4:00 hours to l5:37 hours in the area olSH-288 and I-45, a location that Affiant found
to be approximately eleven ( I I ) miles away Ilom 4855 Fuqua.
Affiant reviewed a "no-knock" search warrant obtained by the defcndant on October 15, 2017 for 4855 [.uqua #2301 in which the defendant
states that he met with a C.l. and provided funds to that C.l. to make a buy at this location on October 14,2017. The defendant fu(her states
in this warrant that the C.l. purchased a substance known to the delendant to bc marijuana. Based on the above information, Affiant has
reason to believe that neither the alleged buy nor the alleged payrnent for said buy took place as docurncnted by the defendant in the C.l
Activity Sheet/ Receipt for Funds Form or the corresponding search warrant. The dclcndant presented this wanant to Harris County
Criminal Law Hearing Officer Ronald Nichols, who signed and issucd said rvarrant, on October 15,20 17.'fhe detendant executed this
warrant on October 17,2011 resulting in the arrest of one of the occupants of the residence.
Texas Penal Code Section 37.10; Tampering with a Governtneul.al l(ccord, provides that, arnongst other means, "a person cornrnits an
offense if he knowingly rnakes a false entry in, or false alteration ol, a governrnental rccord." Texas l)enal Code Scction 37.01(2) provides
that a "Covernmental Record" includes "anything belonging to, received by, or kept by governrnent lor information, including a courl
record." Texas Penal Code Section 37.01(l) provides that a "Court ltecord" includes a warrant.
case#1680883/ CRT#228
Affiantthereforebelievesthatthedefendantdidcommittheoffenseoltamperingwithagovernrnental recordonoraboutOctober
in Houston, Harris County, Texas by knowingly making a false entry in a governmental record, namely
l5,2oll
a search warrant.
AGAINST THE PEACE AND DIGNITY OF THE STATE.
Signed and sworn by me on Duty artested by r]1e on AZfl -,)O )C)
AFFIANT ASSISTANT DI S'|RICI' A1''TORNEY

OI.'I]ARRIS C , TEXAS
I
I tu \)i rsc.,."-
Bar No.
lS)7ctc,
Witness Printed name & Badge or Payroll nurnber
COMPLAIN'I'
:--'14.':' -i)l riii' Srnii liiDD liiiiiiil (lrirrl: ;iiAi nL.,a,;a3 'ii)..'..-i ).'.t lt 1l1ii! ;,,iil:tr, .l;.1ir!,
?ilE AD !,fe Ni{,100
L!,tlr-ri;, jr-Lai'1:[-i:.i, s-'-'tii: Tll:i L]tr-it;int a.i. :t ,)-, ;..':,")i ..,t,'.:'.'...i ,):i:;:"i, iiir_ DFiiii5i ,.-a TAI_,IPER ocl,/?
t"irit
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"
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ilrj.ltill il.I?l t:aO::t ;$!. : i-ji l:i11.1:,i. ,r::;-'):'iI ltjSl.ji,t 'il,; l\?i,.i_ _.,;,;r- i:r :l:ri :rL.::
l>t,i:"1, \tt,'.;1:::.i:l:::'i::.i il:rii. ti i:i1: i) a.iiiitr:1i_i i.:1.),ia
1 .i . ", i"i'. r':, .!') '.;i..:L t'.a,.11 L;.\i.ii .i:,,.) ii:,,.:tt rr . i,..;, j .:l; JULY 1 2020
hD
DGE KELLI JOHNOSN
REPORT: DIM501 JUSTICE INFORMATION MANAGEMENT SYSTEM
DArE: TIME: 4:58
07 / 0t/ 2o D.A. ]NTAKE MANAGEMENT SYSTEM
TRANSACTION # : 2653t76 D.A. LOG #: 2653lt1

IN CUSTODY....: N CARINDICATOR ID BY PRINTS:
DATE OF ARREST:
TIME OF ARREST:
sPN #..... ...: 03014549
AFIS NUMBER...:
DEFENDANT NAIV1E: GOINES, GERALD MIC}IAEL
AL]AS NAIVIE....:
ALIAS SPN... ,.:
US CTTIZEN.. ..: INS# :

PLACE OF BIRTH: CITY OF BIRTH:
RACE. , : B SEX: M DOB: t0/02/t964
MARITAL STATUS: BUILD: HEV HEIGHT:501 WEIGHT:260
HAIR.. ..... .: xxx SKIN: DBR EYES: BRO
calpc

CITY. , HOUSTON, TX ZIP:
PHONE. () CELL: EMAIL:
CELL OPT-IN: EMAIL oPT-IN:
PRIOR ARREST?: Y FBI# V1MWNPJWS STATE rD #: TX10545645
AGENCY rD#..: DAO SSN SO#: 2159434
ALIAS SPN (S) . :
DL#... .. .. : 12928572 DL ST: TX

, '
\
CO-DEFENDANTS? TNOI
DOES THE DEFENDANT IIAVE A SPN? Y N
PRINTED | 0't / 0t / 2020 04:58 (CASSIDY, JAMES M) DIM6O1

;)
.fHE
,#
STATE OF TEXAS 03014t649 D.A. t,OG NUMBER: 2653111
VS. CJIS'|RACKING NO.:
GERALD GOINES SPN:030146.19 BY: EH DA NO: 2125968 1a 6
I2OO TRAVIS DOB: B M 101211961 AGENCY:DAO H O a
DATE PREPARED: 7 ll 12020 O'll. NO: 51907 o

HOUSTON, TX77OO4
- 8t
ffi{-
C\J
ARRES'I I)ATE:TO BE i'i: O
<\J :\
-v [It ))
NCIC CODE: 4802 33 RELATED CASES: -I
I*-d r ..)
1
;J
FELONY CHARGE: TAMPERING GOVERNMENTAL RECOI{l) b4 fi'c)
?; f
I
x
CAUSE NO: COU RI' ORDERED SN I UhdRE SET A

HARRIS COUNTY DISTRICT COURT NO l6t08E4 MACISTRATION 0)
228 F
CHARGE SEQ NUM: I crl
Before me, the undersigned Assistant District Attorney of Flanis Counfy, Texas, this day appeared thc undersigned alfiant, who under oath says
that he has good reason to believe and does believe that in Harris County, l-exas, CERALD GOINES, hereafter styled the Defendant,
heretofore on or about April 24, 2018, did then and there unlawfully, knowingly rnake a false entry in a governrnental record, namely, a
search warrant issued by a magistrate.
It is lurlher presented that on or about April24,20l8, in Harris County, Texas, the Defendant did then and there unlawfully possess a
governlnental record, namely, a search warrant issued by a magistrate, with the intent that it be used unlawfully.
It is furlher presented that on or about April 24, 20 18, in Hanis County, Texas, the Delendant drd then and there make, present, and use a
govemmental record, narnely a search wamant issued by a magistrate, with knowledge of its lalsity.
PROBABLE CAUSE
Affiant, Lieutenant Billy Milan, is a cerlified peace olllcer ernployed by the tlarris County I)istrict nttorney's Office (llCDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to belicve and does belicvc that lbrmcr Floustorr Police Deparlmcnt (llPD)
Officer Gerald Goines, hereinafler defendant, did cornrnit the third degrcc lclony offense of tantpcring rvith a govcrnlne ntal record on or
aboLrt April 24,2018, in l{ouston, Ilarris County, l-exas Affiant bases this bclicf on tlte lollou'ing:
casefl15808S4l CRT#228
On January 15,2020, the defendant and former HPD Narcotics Officer Steven Bryant (Bryant) rvere indicted
lor Tampering rvith a
Governmental Record, see Hanis County Cause Nos. 1660164 and 1643521 respectively. tt.r. charges center
, on false statements sworn
to by Goines in obtaining a narcotics search warrant for a residence located at 7815 lJarding Street and false
statements made in the
corresponding offense report by the defendant. Execution ofthat search warrant led to the death ofboth horneowners,
injury to four HpD
officers, and thereafter an HPD investigation into Goines' use of confidential informants (C.l.s)
to obtain search wan.ants.
Affiant reviewed the HPD offense reporl (OR) documenting that investigation, HPD OR No. 131932- 19, authored
by Sergeanr Rick Bass, a
licensed peace officer currently employed by HPD, and learned the following: AII C.l.s registered to
the delendant rvere interviewed and
each denied having completed a controlled buy at tlarding Street, despite the probable cauie alfidavit for
the search warrant f,or that location
stating that a C.l. had completed a controlled buy the day prior to the date of the affidavit. One of the
C.l.s who was interviewed
(hereinafterrefelredtoasC.l.#l)reportedtohaveattimesbeenpaidbythedefendantlorworknotpreformed.
C.l.#lgaveavideo
interview during which C.l. #l was asked about several locations where, according to olficial HPD records (specifically
C.l. Forms
discussed more fully below), C.l. #l had conducted controlled buys. C.l. #l denied having conducted several'of
those buys, each of which
Affiant is aware of and has reviewed FIPD General Order 600-16 (CO) which governs C.l.s and payments to C.l.s. The GO holds
that,,all
meetings between a C.l. and an officer shall be attended by two officers." 1'hii regulation requires that that
at least two officers be present
when a controlled buy is conducted. It further mandates that "officers shall not pay a confidential informant without the
appropriate witness
present." The GO goes on to dictate how payments to C.l.s will be documented, stating that all payments to C.l.s,,shall
be fuliy
documented on a division's'Confidential Informant Receipt for Funds form"'(C.1. Form) with "control information',
to include the
signature of the C.l. as an agreement that the payment was received, the signature olthe investigator making
the payment, the signature of at
least one other officer witnessing the payment, and the date of the payment. These forrns, as dictated by the
GO, require that at least three
people - the C.1., the investigator, and a witness be together in one place in order for a payment to occur.
- Affiant has reviewcd numerous
HPD C'1. Forms and has noted that these forms also include the tirne of the payment and the associated OR number for the
OR wherein the
Affiant has also reviewed the Special Investigation Cotnmand, Narcotics Division, Standard Operating Procedures (SOp).
SOp I00/2.05
covers "Confidential Informant Funds/Expense Letters, Lirrits of Authorization and Use olFlash H.,toney" and includes a
section on ,,CI
Payments & Receipt for Funds Form." That section repeats the requirements of GO 600-16 and also sjecifically states,,.The
CI Receipt
for Funds form will be completed at the time of the payment to the Cl" (ernphasis in original). Affianr has rcviewed the specific
C.l. Form
used by the HPD Narcotics Division, titled "C.l. Activity Sheet / Receipt for Funds Form." 'fhe lorm has six sections.
l'he first section
includes C.l' name, date, time, location, OR number, and blanks for up to two drug types and the corresponding weight. The
second section
is for an amount paid to the C.l. for information and assistance and includes blanks for the amount paid and ttre C f .t signature.
The third
section is for an amount provided to the C.l. to purchase narcotics and includes blanks lor thc amount pard and the C.l.'s initials.
The fourrh
section provides a space for details. The fif,th section starls with the word "Witness" lollowed by a blank for a printed narne
and a blank for
a signature, The sixth section goes on to provide blanks for the signatures of the revierving sergeant and thc reviewing lieutenant.
Affiant reviewed documents provided by HPD pursuanl. to this investigation, including C.i. p'onns, expcnse reports, off.nr. reports,
oveftime request forms, and expense authorization forms, and specifically all documentation relating to IIPD OR number 05 149 l4-lg.
Affiant observed that the defendant submitted a C.l. Activity Sheet/Receipt for Funds Forrn associaGa *itt, this report number, wherein he
stated that he made payments to C.l. #l on April 23,2018 at l8:00 hours for a buy allegedly made at 6807 Goforth in Houston,
Harris
County, Texas. The defendant furlher states in this document that the C.l. purchased crack at this location on that date. Bryant signed this
form as a witness to these alleged payments. C.l. #l denied rnaking any buys at this location.
Affiantpreviouslyobtainedsearchwarrantsforcell sitedataforthepersonal cell phonesofthedeflendant,Bryant,andC.l.#1. Affiantwas

provided a copy of the cell site data returned as a result of those warrants. The data for the defendant came fforn T-Mobile and ranged llom
March29,20l8 through February 1,2019. The data for Bryant came liorn Sprint and ranged l}om January 8,2018 through Februaiy l,
2019. The data for C.l. #l came fi'om AT&T and ranged from March 25,2017 through December 31,2018. This data was provided to
Nathan Gates (Gates), a Lieutenant Investigator and Digital Forensic Examincr currently employed within the I-ICDAO Oigital Forensic
Unit. During the time period for which data was returned, Gates mappcd the coordinates of the cell phone data for the defendant, Bryant,
and for C.l. #l for the dates and times of each paylnent documented.
In reviewing the cell site mapping for the defendant, Affiant observed that his cell phonc was in use at. l8:25 hours in the Cyprcss area, a
location Affiant knows to be approximately thirly (30) miles away frorn 6807 Coforth. ln reviewing Bryant's cell site mapping for this date
and time, Affiant observed that Bryant's cell phone was in use and travcllirrg fi'orn approxirnately I6:38 hours to l6:51 hours,ipproxirnately
along U.S. 59 between the 610 Loop and State Highway 288. Affiant observed that there is no call data showing his location to'be any
closerto680TGoforthatornearthetimeoftheallegedbuy. lnrevieu'ingtheccll siternappinglorC.l.#llorthisdateandtirnc,Afdant
observedthatC.l.#l'scellphonewasinusefiomapproximatelyl6:40hoLrrsto l9;2ghoursinthcareaolsll-288andl-45,alocationthat
Affiant found to be approxirnately five (5) rniles away 6807 Goforlh.
Case#15808841 CRT#228
Affiant reviewed a "no-knock" search lvarant obtained by the defendant on April 24,2018 lor 6807 Coforth in which thc defendant states
that he met with a C.l. and provided funds to that C.l. to rnake a buy at this location on April 23,2018. l'he defendant further states in this
warrant that the C,l. purchased a substance known to the delendant to be crack cocaine. Based on the above information, Affiant has reason
to believe that neither the alleged buy nor the alleged payment for said buy took place as docurnented by the de fendant in the C.l Activity
Sheet / Receipt for Funds Form or the corresponding search warrant. The defendant presented this warrant to Harris County Criminal Law
Hearing Officer Connie Spence, who signed and issued said warrant, on April 24,2018. l'he delendant executed this warrant on April25,
2018, resulting in the arrest ofone ofthe occupants ofthe residence,
Texas Penal Code Section 37.10, Tampering with a Governmental Record, provides that, amongst other means, "a person comrnits an
offense if he knowingly makes a false entry in, or false alteration of, a governrnental record." Texas Penal Code Section 37.Ol(2) provides
that a "Governmental Record" includes "anything belonging to, received by, or kept by government for information, including a court
record." Texas Penal Code Section 37.01(l) provides that a "Court Rccord" includes a rvarrant.
Affiantthereforebelievesthatthedefendantdidcommittheoffenseoftamperingwithagovernmental recordonorabout April 24,2018,in
Houston, Harris County, Texas by knowingly making a false entry in a governmental record, namely a search lvarrant issued by a
magistrate.
Signed and sworn by me on Duly attcstcd by rne on -O/ - Iolu
AFFIANT ASSI STANl' DISTRIC'1- ATTORN EY

OF IIARRIS COUNTY.
'|EXAS
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i JULY 1 2020 5:
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JUDGE KELLI JOHNSON $o

Rt": r',::
?irtGE liO
Intatgd Et Dept.
rif*natrt Division
REPORT: DIM501 .]USIICE. ]NFORMATION MANAGEMENT SYSTEM TIME: 4:52
DATE: 07 / 0t/ 20 D.A. INTAKE MANAGEMENT SYSTEM
# : 2553tt'l
TRANSACTION
D.A. LOG #: 2653tt1
IN CUSTODY....: N CARINDICATOR: ID BY PRINTS:
sPN #.........: 03014549
AFIS NUMBER,. . :
DEFENDANT NAME: GOINES, GERALD

ALIAS NAME....:
ALIAS SPN. .,. . :
US CITIZEN INS#
ALLIEN STATUS : ILLEGAL CODE:
PLACE OF BIRTH: C]TY OF BIRTH:
RACE..........: B SEX: M DOB: ta/02/L964
MARITAL STATUS: BUTLD: HEV HEIGHT: 601 WEIGHT: 260
]JATD SKIN: EYES :
scARs..... ..:
CITY. . HOUSTON, TX ZIP :
PHONE. () CELL: EMAIL:
CELL OPT- IN EMAIL OPT.IN:
PRIOR ARREST?: Y FBI # VlMWNPJW5 STATE ]D #: TX10545545
AGENCY TD#. . : DAO ssN so#: 2759434
ALIAS SPN(S).:
DL#...... . .: ]-2928572 DL ST: TX
CO-DEFENDANTS? 6.
DOES THE oppprrrtral,rr HAVE A SPN? N
PRINTED I O'7 /OI/2020 O4:52 (CASSIDY, JAMES M) DIM5O1

THE STATE OF TEXAS 03014649 D ER:2653114
VS. C NO.:
GERALD GOINES SPN: 03014649 B 242se68 Qo o
A
I2OO TRAVIS
HOUSTON, TX77004
DOB: B M 101211964
DATE PREPARED: 7 ll 12020 o qP.3 s
.-3*
c\r s ,5
o
A TOBE . 'd:
@l ^() Fl f
o
NCIC CODE: 4802 33 RELATED CASES: :^L
@Eia -J
-
FELONY CHARGE: TAMPERING GOVERNMENTAL RECORD c\,i

-)
@e
CAUSE NO: COURT ORDERED BAIL: TO BE SET
HARRIS COUNTY DISTRICT COURT NO MAGISTRATION o
FIRST SETTING DATE: PRIOR CAUSE NO: ta- rl,
CHARGE SEQ NUM: I
IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS
Before me, the undersigned Assistant District Attorney of Hanis County, Texas, this day appeared the undersigned affiant, who under oath says
that he has good reason to believe and does believe that in Harris County, Texas, G ERALD GOINES, hereafter styled the Defendant,
heretofore on or about November 28,2018, did then and there unlawfully, knowingly make a false entry in a governmental record, namely, a
search warrant issued by a magistrate.
It is further presented that on or about November 28,2018, in Harris County,'l'exas, the Defendant did then and there possess a
govemmental record, namely, a search warrant issued by a magistrate, with the intent that it be used unlawfully.
It is further presented that on or about November 28,2018, in Harris County, Texas did then and there make, present, and use a
govemmental record, namely a search warrant issued by a rnagistrate, with knowledge of its falsity.
PROBABLE CAUSE:
Affiant, Lieutenant Billy Milan, is a cerlified peace officer ernployed by the Harris County District Attomey's Office (HCDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to believe and does believe that forrner Houston Police Deparlment (HPD)
Officer Gerald Goines, hereinafter defendant, did comrnit the third degree lelony offense of tampering with a governmental record on or
about November 28, 2018, in Houston, Harris County, Texas. Affiant bases this belief on the following:
On January 15,2020, the defendant and former HPD Narcotics Officer Steven Bryant (Bryant) were indicted for Tampering with a
Governmental Record, see Harris County Cause Nos. 1660764 and 164352 [, respectively. These charges center on false statements sworn
to by Goines in obtaining a narcotics search warrant for a residence located at 7815 Flarding Street and false staternents rnade in the
corresponding offense repoft by the defendant. Execution of that search waffant led to the death of both homeowners, injury to four FIPD
officers, and thereafter an HPD investigation into Goines' use of confidential inforrnants (C.l.s) to obtain search warrants.
Affiant reviewed the HPD offense report (OR) documenting that investigation, HPD OR No. 133932-19, authored by Sergeant I{ick Bass, a
licensed peace officer currently employed by HPD, and learned the following: All C.l.s registered to the delcndant were interviewed and
each denied having completed a controlled buy at Ilarding Street, despite the probable cause altldavit for the search warrant for that location
stating that a C.l. had completed a controlled buy the day prior to the date of the affidavit. One of the C.l.s who was interviewed
(hereinafter refered to as C.l. #1) reporled to have at tirnes been paid by the delendant for work uot preforrned. C.l. #l gave a video
interview during which C.l. #l was asked about several locations where, according to official HPD rccords (specifically C.l. Irorrns
case#1580885/ CRT#228
discussed more fully below), C.l. #l had conducted controlled buys C.l. # I dcnied having conducted several olthose buvs, each ofwhich
Affiant is aware of and has reviewed HPD General Order 600-16 (CO) which governs C.l.s and payments to C.l.s. The GO holds that "all
Ineetings between a C.l. and an officer shall be attended by two officers." This regulation requires that that at least two officers be present
when a controlled buy is conducted. It further mandates that "officers shall not pay a confidential informant without the appropriate witness
present." The GO goes on to dictate how payments to C.l.s rvill be docurnented, stating that all payments to C.l.s "shall be fully
documented on a division's'Confidential Inlormant Receipt lor Funds fonn"'(C.1. Form) with "control inforrnation" to include the
signature of the C.l. as an agreement that the payment was received, the signature of the investigator making the payrnent, the signature of at
least one other officer witnessing the payment, and the date of the payment. J'hese fornts, as dictated by the GO, require that at Gast three
people - the C.1., the investigator, and a witness - be together in one place in order for a payment to occur. Affiant has reviewed numerous
HPD C.l. Forms and has noted that these forms also include the time of the payment and the associated OR number for the OR wherein the
Affiant has also reviewed the Special Investigation Command, Narcotics Division, Standard Operating Procedures (SOP). SOp 100/2.05
covers "Confidential Informant Funds/Expense Letters, Limits of Authorization and Use olFlash Money" and includes a section on "CI
Payments & Receipt for Funds Form." That section repeats the requirements of CO 600-16 and also specifically states, "The CI Receipt
for Funds form rvill be completed at the time olthe payment to the Cl" (emphasis in original). Affiant has reviewed the speciflc C.l. Form
used by the HPD Narcotics Division, titled "C.l. Activity,sheet / Receipt for [.unds [.'orm." The lornt has six sections. 'fhe first section
includes C.l. nalne, date, time, location, OR number, and blanks for up to two drug types and the corresponding weight. 'lhe second section
isforanamountpaidtotheC,l,forinformationandassistanceandincludesblanksfortheatrountpaidandtheC.l.'ssignature. Thethird
section is for an amount provided to the C.l. to purchase narcotics and includes blanks lor the amount paid and the C.l.'s initials. The fourth
section provides a space for details. The fifth section starts with the u'ord "Witness" follorved by a blank lor a printed name and a blank for
a signature. The sixth section goes on to provide blanks for the signatures of the reviewing sergcant and the reviewing lieutenant.
Aflfiant reviewed documents provided by HPD pursuant to this investigation, including C.[. Forrns, expense repofts, offense reports,
oveftime request forms, and expense authorization forms, and specifically all docurnentation for llPD OR nurnbers l4g798l -18 and
1507139-18. Affiant observed that the defendant submitted a C.l. Activity Sheet/Receipt for Funds Forrrs associated with these report
numbers,whereinthedefendantstatedthathemadepaymentstoC.l.#lonDecember3,20 l8atl3:00hoursforabuyallegedlymadeat
3600 Tuam #2 in Houston, Harris County, Texas, and the results ofa search warrant executed at that address, The defendant furlher states in
this document that the C.l. purchased rnarijuana and hydrocodone at this location on that date. 'fhe de fendant's sLrpervisor formcr HpD
Sergeant Clemente Reyna (Reyna) signed these forms as a witness to these alleged payments.
Affiant add itionally observed in offense report 149798 I - I 8, the defendant states that it rvas on Novernber 27 , 20 18 at I 7:00 hours, and not
on December 3,2018 at l3:00 hours, that he and Bryant (not Reyna) met with a C.l. at 3600'l'uam #2, who purchased marijuana and
hydrocodone at that location. C.l. # I denied making any buys at this location.
Affiantpreviouslyobtainedsearchwarrantsforcell sitedataforthepersonal cell phonesolthedefcndant,Reyna,andC.l.#1. Affiantwas

providedacopyofthecell sitedatareturnedasaresultofthosewarrants. ThedataforthedefendantcamefromT-Mobileandrangedllom
March29,20l8 through February 1,2019. The data for Reyna came from AT&T and ranged frorn February2l ,2017 through December 17,
20l8.The data forC.l. #l came frotn AT&T and ranged fi'onr March 25,2011 through Decernber3l,20 18. This datarvas providedto
Nathan Gates (Gates), a Lieutenant lnvestigator and Digital Forensic Examiner currently ernployed within the LICDAO Digital Forensic
Unit. During the time period for which data was returned, Gates mapped the coordinates of the cell phone data for the defendant, Goines,
and for C.l. #l forthe dates and times of each payment docurnented.
In reviewing the defendant's cell s ite mapping lor Novernbe r 27 , 201 8, at I 7:00 hours, Affi ant observed that h is cell phone was in use on
that date between l6:00 hours and l6:34 hours in the area of 610 Loop and I-45 South, a location Alfiant found to be approxirnately five (5)
miles away from 3600 Tuam. Affiant observed the defendant's cell phone to be in use again at approxirrately 17:33 hours in the area of
Hobby Airporl, a location Affiant found to be approximately eight (8) nriles away lrom 3600 l-uarn, indicating to Affiant that the defendant
was moving away fi'om the alleged buy location at the time olsaid buy. ln revierving Reyna's cell site rnapping for this date and time,
Affiant observed that his cell phone was in use between l6:05 hours and ll:34 hours in the Cyprcss area,a location Affiant fbund to be
approxitnatelythirty(30)milesawayfrom3600Tuam.Finally,inrcviewingthe cell sitemappingforC.l.ill lorthisdateandtirne,Affiant
observed that C.l. #l's cell phone was in use frorn approximately l6:05 hours to l7:53 hours irr thc area of SII-288 and l-45, a location that
Affiant found to be approximately five (5) miles away from 3600 'l'uam.
Inreviewingthecell sitemappingforthedefendantforDecenrber3,20l8,at l3:00hours,Alllantobservedhiscell phonewasinuseat

approximately 12:37 hours in the area of U.S. 290 and the 610 Loop, a location Alfrant lourrd to be approxirnatcly twelve (12) miles away
fiom 3600 Tuam. Affiant observed the defendant's cell phone was in use again at approxilxalely 12:45 hoLrrs in the Jersey Village area,a
location found to be approximately twenty (20) rniles away fronr 3600'l'uam. In rcvicwing Rcyna's ccll site rnapping for Decernber 3,2018,
at l3:00 hours, Affiant observed that Reyna's cell phone rvas in use and travclling lrom approxirnate ly l2:32 hours to l3:28 hours beginning
case#1580885/ CRT#228
approximately at the HPD station located at 8300 Mykawa and travelling northbound along Beltrvay 8 to the Greenspoint area of Houston,
locations that Affiant found to be approximately seven (7) miles and twenty (20) rniles away fi'orn 3600 Tuarn, respectively. Finally, in
reviewingthecell sitemappingforC.l.#l forthisdateandtime,AffiantobservedthatC.l.#l'scell phonewasinuseandtravellingfrom
approximately 12:33 hours to l3:28 hours between the area of SH-288 and I-45, and the Bellaire alea, locations that Affiant found to be
approximately five (5) miles and ten (10) miles away frorn 3600'l'uam, respectively.
Affiant reviewed a "no-knock" search wan'ant obtained by the dclendant on Novernber 28, 20 l8 lor 3600 Tuarn #2, in which the defendant
states that he met with a C.l. and provided funds to that C.l, to make a bLry at this location on Novernber'27,2018. The defendant lufther
states in this warrant that the C.l. purchased a substance knorvn to the delendant to be ntarijuana. Bascd on the above information, Affiant
has reason to believe that neither the alleged buy nor the alleged payment lor said buy took placc as documented by the defendant in the C.t
Activity Sheet / Receipt for Funds Forms, the corresponding offense report, or the corresponding search warrant. The defendant presented
this wanant to Harris County Criminal Law Hearing Officer Lionel Castro, who signed and issucd said warrant, on November 28,20 18.
The defendant executed this warrant on Novernber 29,2018, rcsulting in the arrest of one olthe occupants of the residence.
Texas Penal Code Section 37.10, Tampering with a Governmental Record, providcs that, amongst other rneans, "a person comrnits an
offense if he knowingly makes a false entry in, or false alteration of,, a governmental record." Texas Penal Code Section 31 .01(2) provides
that a "Governmental Record" includes "anything belonging to, received by, or kept by govcrnment for information, including a court
record." TexasPenal CodeSection3T.0l(l)providesthata"CourlRecord"includesawarrant.
Affiant therefore believes that the defendant did commit the offense of tarnpering with a governrnental record on or about November 28,
2018, in Houston, Harris County, Texas by knowingly making a false entry in a governmental record, namely a search warrant issued by a
magistrate.
AGAINST THE PEACE AND DIGNITY OF TI-IE STATE
Signed and sworn by me on Duly attested by rne on
lzt'tz
AFFIANT ASSISTAN'f DI S1'RIC]' ATTORNEY
OF IIARRIS C
I ,i,J P: r','v
Bar No.
77'i'f') ?oc
Witness (Peace Officer) "J
Witness Printed name & Badge or Payloll nurnber
COMPLAINT
;"liDii[ii,]i,t tj,: ;?i;. 1._ rtlAilD:)i-' i,"\ 3LI'i:t; ii;1jir,1t it,l i:tr r.ri j;'rlilrt, l i';.:
Ei:ii.N;a:iiliC ttlio:iFl -1ilii i:Ci):? lih].llai a7o1il T-, .r\irSiie,r. T:il i,.:.^t,i. i.,:);.la'i. :-ati:"1i,:i ljj:! irF.: h€,
ilt)il iT H."r:1 a.<i,-f'";:iD. Il"riIL IS Sii .-.,ii iitl;r,]ir-i) lJ;,',,t
JIJLY 1 2O2O
I li,\'.ri: lt5',ii:l:ri$i S.s,it CCir?i.{.1iT.4ti) CI','Lil t,li
,'r/
UDGE KELLI JOHNSON ;f0
DArE : 0'7 / 0l /20 , D.A. INTAKE MANAGEMENT SYSTEM
TRANSACTION # 2653Lt4 D.A. LOG #: 2653114

IN CUSTODY,. ,. N CAR]NDICATOR: ID BY PRINTS:
DATE OF ARREST TIME OF ARREST:
SPN # 03014549
AFIS NUI\4BER. . .
DEFENDANT NAME GO]NES, GERALD

ALIAS NAME....
ALIAS SPN.. ...
US C]TlZEN INS#:
ALLIEN STATUS ILLEGAL CODE
PLACE OF BIRTH CITY OF BIRTH:
RACE.. B SEX: M DOB: 7A/02/1964
MARITAL STATUS BUILD: HEV HEIGHT: 601 WEIGHT: 250
HAIR.. SKIN: DBR EYES: BRO
SCARS

PHONE () CELL: EMAIL:
CELL OPT-IN: EMAIL OPT_IN
PRIOR ARREST?: Y FBI# VI-MWNPJWS STATE ID #: TX10545645
AGENCY ]D#. . : DAO ssN SO#: 2),69434
ALIAS SPN(S) .:
uD+, .... .. : 28512 DL ST: TX
CO - DEFENDANTS ?
DOES THE DEFENDANT FIAVE A SPN? Y N
PRINTED | 07 /0L/2020 04:55 (CAS DY, JAIVIES M) DIM6O1

A-
THE STATE OF TEXAS 03059894 D A I,OG NUMBER 2653

G
VS. CJIS'I-RACKINC NO.:
CLEMENTE REYNA SPN: BY: EH DA NO: 2425968
I2OO TRAVIS DOB: WMll/6/1968 AGENCY:DAO
f
HOUSTON, TX77004 DATII PREPARED: 7 I I 12020 O/R NO: S1907 o
g
ARII.EST DA-l'll:TO BE '-
o
J

HARRIS COUNTY DISTRICT COUR'f NO: MACISTRATION
16808Eq
228
CHARCE SEQ NUM: I
Before me, the undersigned Assistant District Attorney of llarris County, Texas, this day appcared the undersigned affiant, rvho under oath says
that he has good reason [o believe and does believe that in l]anis County, Tcxas, CLEMENTE IIEYNA, hereafter sfyled the Delendant,
heretofore on or about December 3,20I8, did then and there unlar.r'fully, knowingly rnake a false entry in a governmental record, namely, a
llouston Police Deparlment Narcotics Division C.l. Activity Sheet/Receipt for Funds F-ornt, with the intent to defraud or harm another.
PROBABLE CAUSE
Affiant, Lieutenant Billy Milan, is a certified peace oflicer employed by the Han'is County District Attorney's Oifice (HCDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to believe and docs believe that lormer Houston Police Department (HPD)
Sergeant Clemente Reyna, hereinafter defendant, did cornmit the state jail felony offense of tampering with a governmental record on or
about December 3,2018, in Houston, Harris County, Texas. Alfiant bases this belief on the following:
On January 15,2020, former HPD Narcotics Officers Gerald Goines (Goines) and Stevcn [lryant (Bryant) wcre indicted for Tanpering with
a Governmental Record, see Haris County Cause Nos. 1660764 and 1643521 , respectivcly. 'l'hcse charges center on false stal.ements sworn
to by Goines in obtaining a narcotics search warrant for a residence locatcd at 7815 Harding Street and false stateluents made in the
corresponding offense reporl by Bryant. lrxecution of that search warrant lcd to the dcath of both honreowncrs, injury to four I IPD officers,
and thereafter an IIPD investigation into Goines' use olconfidential inlornrants (C.l.s) to obtain search warrants.
Case#1680886/ CRT#228
Affiant reviewed the HPD offense report (OR) docurnenting that investigation, HPD OR No. 133932- 19, authored by Sergeant Rick Bass, a
licensed peace officer currently employed by HPD, and learned the following: AllC.l.s registered to Goines were interviewed and each
denied having completed a controlled buy at Harding Street, despite the probable cause affidavit for the search warrapt for that location
stating that a C.l. had completed a controlled buy the day prior to the date of the alfidavit. One of the C.t.s who was interviewed
(hereinafterreferredtoasC.l.#l)reportedtohaveattinresbeenpaidbyCoinesfbrworknotprefonned. C.l.#l gaveavideointerview
during which C.l. #1 was asked about several locations where, according to official HPD records (specifically C.l. Forms discussed more
fully below), C.l. #l had conducted controlled buys. C.l. #l denied having conducted several olthose buys, each olwhich led to a narcotics
search rvarant.
AffiantisawareofandhasreviewedHPDGeneral Order600-16(CO)whichgovernsC.t.sandpaymentstoC.l.s. T'heGOholdsthat,,all

meetings between a C.l. and an officer shall be attended by two officers." This regulation requires that that at least two officers be present
when a controlled buy is conducted. It further mandates that "officers shall not pay a confidential informant without the appropriate witness
present." The GO goes on to dictate how payments to C.l.s will be documented, stating that all payments to C.l.s "shall be fully
documented on a division's'Confidential Informant Receipt for Funds form"'(C.1, Irorrn) with "control information" to include the
signature of the C,l. as an agreement that the payment was receivcd, the signature olthe investigator making the payment, the signature of at
least one other officer witnessing the payment, and the date of the payment. 'l'hese forrns, as dictated by the GO, require that at least three
people -the C.1., the investigator, and a witness - be together in one place in order lor a payment to occur. Affiant has reviewed numerous
HPD C.l. Forms and has noted that these forms also include the time of the payrnent and the associated OR nurnber for the OR rvherein the
Affiant has also reviewed the Special Investigation Cornmand, Narcotics Division, Standard Operating Procedures (SOp). SOp 100/2.05
covers "Confidential Informant Funds/Expense Letters, Limits of Authorization and Usc olFlash Money" and includcs a section on,,Cl
Payments & Receipt for Funds Form," That section repeats thc requirements olGO 600-16 and also specifically states, "The Cl Receipt
for Funds form will be completed at the time of the payment to the CI" (emphasis in original). Alfiant has reviewed the specific C.l. Form
used by the HPD Narcotics Division, titled "C.l. Activity Shcet / Receipt for Funds Forrn." l'he form has six sections. l'he first section
includes C.l. name, date, time, location, OR number, and blanks for up to two drug types and the corresponding weight. 'fhe second section
is for an amount paid to the C.l. for information and assistance and includes blanks lor the amount paid and the C.l.'s signature. The third
section is for an amount provided to the C.l. to purchase narcotics and includes blanks for the amount paid and the C.l.'s initials. The fourlh
section provides a space for details. The fifth section starts with the word "Witness" follorved by a blank for a printed name and a blank for
a signature. I'he sixth section goes on to provide blanks for the signatures ofthe revierving sergeant and the reviewing lieutenant.
Affiant reviewed documents provided by FIPD pursuant to this investigation, including C.l. Forms, expense repofts, offense repofts,
oveftimerequestforms,andexpenseauthorizationforrns,andspecificallyall docurnentationforHPDORnurnbers l491g}l-l8and
1507 139-18. Affiant observed that in the C.l. Activity Sheet/Receipt for Funds Forrns associated with these reporl numbcrs, the defendant
signed that he witnessed Goines make payrnents to C.l. # l on December 3, 20 l 8 at l3:00 hours for a buy allegedly madc at 3 600 Tuam #2
inHouston,HarrisCounty,Texas,andfortheresultsofthesearchwarrantpredicatedonthatbuy.C.l.#l deniedmakinganybuysatthis
location.
Affiantpreviouslyobtainedsearchwarrantsforcell sitedataforthepersonal cell phonesofthedefendant,Goines,andC.l.#1. Affiantwas

provided a copy of the cell site data returned as a result of those warrants. The data for thc dclendant came from AT&T and ranged from
February 2l ,2017 through December 11,2018. The data for Goines came lrom-f-Mobilc and ranged from March 29,2018 through
February 1,2019. The data for C.l. #l carne from AT&T and ranged lrom March 25,2017 through December 31, 2018. This data was
provided to Nathan Gates (Gates), a Lieutenant lnvestigator and Digital Forensic Exanriner currently employed within the HCDAO Digital
Forensic Unit. During the time period for which data was returned, Gates rnapped the coordinates of the cell phone data for the defendant,
Goines, and for C.l. #l for the dates and times of each payment documented.
In reviewing the defendant's cell site mapping for this date and time, Affiant observed that the defendant's cell phone was in use and
travelling from approximately l2:32 hours to l3:28 hours beginning approximately at the IIPD station located at 8300 Mykawa and
travelling northbound along Beltway 8 to the Greenspoint area of Ilouston, locations that Affiant found to be approxirnately seven (7) miles
and twenty (20) miles away from 3600 Tuam, respcctively. [n reviewing the cellsite rnapping lor Goines, Affiant observed his cell phone
was in use at approximately 12:37 hours in the area of U.S. 290 and the 610 Loop, a location Affiant found to be approximately twelve (12)
miles away from 3600 Tuam. Affiant observed Goines'cell phone was in use again at approxirnately 12:45 hours in the Jersey Village area,
a location found to be approximately twenty (20) miles away from 3600 l'uarn. In reviewing the ccll site mapping for C.l. # I for this date
and time, Affiant observed that C.l. #l's cell phone was in use and travelling fi'om approxirnately l2:33 hours to l3:28 hours between the
area of SII-288 andl-45, and the Bellaire area, locations that Affiant lound to be approximately five (5) rniles and ten (10) miles away from
3600 Tuarn, respectively.
Based on the above information, Alfiant has reason to be licve that neithcr the alleged buy nor the allcged payments lor said buy took placc
as documented by Goines and the defendant, and thus Alfiant has reason to believe that thc delcndant did not witness any alleged payment
to C.l. #l at 13:00 hours on Decernber 3,2018, as documented by the defendant in thc in thc C.l Activity Sheet / Reccipt for Funds F-orms.
Case#1580886/ CRT#228
Texas Penal Code Section 37.10, Tampering with a Governrnental Record, provides that, arnongst othcr means, "a pcrson cornmits an
offense if he knowingly makes a false entry in, or false alteration oi, a governmental record." -l'exas Penal Code Section 3i.Ol(2) provides
that a "Governmental Record" includes "anything belonging to, received by, or kept by government for inlormation, including a court
record." The C.l. Forms described above arc required by a General Orderto be corlpleted for all C.l. paytnents. They are kelt by HpD to
document C.l. activity and involvement in narcotics investigations. Affiant is arvare that IICDAO has requcsted and rlceived lrorn IIpD C.l
Forms dating back more than 20 years. HPD is a subdivision of the City of Houston, a rnunicipality.
Affiant therefore believes that the defendant did commit the offense of tampering with a governmental record on or about December 3,
20 18, in Houston, Harris County, Texas by knowingly making a false entry in a governrnental rccord, namely a Houston Police Department
Narcotics Division C.l. Activity Sheet/Receipt for Funds Form, and that this olfense rvas cornrnitted with the intent to defraud the Houston
Police Deparlment.
Signed and swonr by me on Dury attested by nre on qL' /^, JL)
AFFIANT ASSI STANI' DI S'I'RICl' AI"|OITN EY

OF HARRIS COUN'IY,TEXN
BarNo la/.F)?ad
S
/ ,J P t rso*l
COMPLAINT
rili' : , : j. ,lr.S, 'l'iif,] Lp,?V€. lltrll5D
'1|lii i ,iii C?FgtlSE L.tF,i,.\it-p!tirltic
JtJtY 1 2a20
ct)
,ll'
n'.
JUDGE KELLI JOHNSdT}
'' iir
REPORT: DIM6O1 I
..]US T CE INFORMATION MANAGEMENT SYSTEM
DArE:07/0:I/20 D.A
TIME: 4:29
INTAKE MANAGEMENT SYSTEM
DEFENDANT DBSCRTPTORS
TRANSACTION # 2553120
IN CUSTODY... N D.A. LOG #: 2653120
. CARINDICATOR ID BY PRINTS:
DATE OF ARREST
TIME OF ARREST:
SPN #.
AFIS MIMBER. . .
DEFENDANT NAME REYNA, CLEMENTE

ALIAS NAME....
ALIAS SPN,....
US CITIZEN
INS #
ALL]EN STATUS : TLLEGAL CODE
PLACE OF BTRTH:
CITY OF BIRTH:
RACE....... ..: W SEX: M DOB:7t/06/L968
MARITAL STATUS: BUILD: MED HEIGHT: 500 WEIGHT: 220
HAIR... . . ..: BRO SKIN: LBR EYES:
scARs.. ..... :
BRO
STREET ADDRESS I I2AO TRAVIS

CITY.. . .: HOUSTON, TX ZIP:
PHONE........ : ( ) CELL: EMAIL:
CELL OPT-IN: EMAIL OPT- IN
PRIOR ARREST?: N FBr#:
AGENCY ID#..: DAO
STATE ID #:
SSN: eA+.
ALIAS SPN (S) . :
uvf.
DL#........ .: 1-L94A2i7 DL ST: TX

CO-DEFENDANTS?
@
A SPN? Y N
PRINTEDT 07/0L/2020 04:29 (CASSIDy, J M) DIM5O1

a
THE STATE OF TEXAS
03059894
ogsclYct/
D.A. LOG NUMBIIR: 2653131
VS, CJIS'I-ITACKING NO.:
CLEMENTE REYNA SPN: llY; EH DA NO:2425 o
6
x
I2OO TRAVIS DOB;WMll/6/1968 AGENCY:DAO o o
lhv F
HOUSTON, TX17004 DATE PREPARED: 1 ll 12020 O/R NO: S1907
(l)T ({
O
O
ARRIISI'DA'I'E:TO BE Ei o)o
=O
c! l
o
):
NCIC CODE: 4802 32 RELATIID CASES: FJ -,J>; .f
FELONY CHARGE: TAMPERING GOVERNMENTAL RECORD I

idL-
.-E =
'--)
CAUSE NO: COURl'ORDERED BAI LFryb BE SET
HARRIS COUNTY DISTzuCT COURT NO MAGISTRATION 6)
E
FIRST SETTING DATE: PRIOR CAUSI] NO: o
CIIARGE SEQ NUM: I
that he has good reason to believe and does believe that in l{arris County, Texas, CLEMENTE II,EYNA, hereafter sfyled the Def'endant,
heretofore on or about April 25,2018, did then and there unlawfully, knowingly make a false entry in a governmental record, namely, a
Houston Police Deparlment Narcotics Division C.l. Activity Sheet/Receipt for F'unds Form, with the intent to defraud or harm another.
PROBAI]I,E CAUSE:
Affiant, Lieutenant Billy Milan, is a certified peace olficer ernployed by the Ilarris County District Attorney's Office (HCDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to believe and does believe that lonner Ilouston Police Deparlnrent (HI']D)
Sergeant Clemente Reyna, hereinafter defendant, did corrrnit the state jail felony offense of tarxpcring with a governmental record on or
aboutApril 25,2018, in Houston, Harris County, Texas. Affiant bases this belief on thc lollowing:
On January 15,2020, fonner HPD Narcotics Officers Gcrald Goines (Goines) and Stevcn Bryant (llryant) wcre indicted for'fampering with
-l'hcse
a Governmental Record, see Llarris County Cause Nos. 1660764 and 1643521 , respectivcly. charges centcr on false statements sworn
to by Goines in obtaining a narcotics search warrant for a residence located at 7815 tlarding Street and false statements made in the
corresponding offense report by Bryant. Execution ofthat search warrant led to the death of both homcowners, injury to four IIPD officers,
and thereafter an HPD investigation into Goines' usc of confidential informants (C.l.s) to obtain scarch warants.
AffiantreviewedthetlPDoffensereport(OR)docurnentingthatinvestigation, I{PDORNo. 133932-l9,authoredbySergeantRickBass,a

licensed peace officer currently employed by HPD, and learned the following: All C.l.s registered to Goines were interviewed and each
denied having cornpleted a controlled buy at llarding Street, despitc thc probable cause affidavit forthe search wan'ant forthat location
stating that a C.l. had completed a controlled buy thc day prior to the date of the affidavit. One of the C.l.s who was interviewed
case#15808871 CRT#228
(hereinafter referred to as C.l. #1) reporled to have at tirnes been paid by Goines lor work not prelorrned. C.l, #l gave a video interview
during which C.l' #l was asked about several locations where, according to olficial I-ll,D recoids (specilically C.l. F'orms discussed more
fullybelow),C.1'#l hadconductedcontrollcdbuys. C.l.#ldeniedhavingconductedsevcral olthosebuys,eachofwhichledtoanarcotics
search warrant.
AffiantisawareofandhasreviewedHPDGeneral Order600-16(GO)whichgovernsC.l.sandpayrnentstoC.l.s. TheGOholdsthat,,all

rneetings between a C.l. and an officer shall be attended by two officers." This regulation requircs that that at least two officers be present
when a controlled buy is conducted. It furlher mandates that "officers shall not pay a confidential informant without the appropriate witness
present." The GO goes on to dictate how payments to C.l.s will be documentcd, stating that all paytnents to C.l.s "shall be fuliy
documented on a division's 'Confidential Informant Receipt for Funds form"' (C.1. Form) with "control information" to include the
signature of the C.l. as an agreement that the payment was received, the signature of the investigator making the payment, the signature of at
least one other officer witnessing the payment, and the date of thc paylnent. These forms, as dictatcd by the CO, require that at least three
people - the C.1., the investigator, and a witness - be together in one place in order for a payment to occur. Affiant has reviewed numerous
HPD C.l. Forms and has noted that these forms also include the time of the payrnent and the associated OR number for the OR wherein the
Affiant has also reviewed the Special Investigation Corntnand, Narcotics Division, Standard Operating Procedures (SOP). SOP 100/2.05
covers "Confidential Informant Funds/Expense Letters, Limits of Authorization and Use otFlash Money" and includes a section on ,.CI
Payments & Receipt for Funds Forn'I." That section repeats the requirernents olGO 600-16 and also specifically states, "The CI Receipt
for Funds form will be completed at the tirne of the payment to the CI" (emphasis in original). Affiant has reviewed the specific C.l. Form
used by the HPD Narcotics Division, titled "C.1. Activity Sheet / Iteceipt for Funds Forrn." The form has six sections. The first section
includes C.[. name, date, time, location, OR number, and blanks for up to two drug types and the corresponding weight. The second section
is for an amount paid to the C.l. for information and assistance and includes blanks lor the amount paid and the C.l.'i signature. The third
section is for an amount provided to the C.l. to purchase narcotics and includes blanks lor the amount paid and the C.l.'s initials. The fourth
section provides a space for details. The fifth section starts with the rvord "Witness" lollowed by a blank for a printed name and a blank for
asignature. Thesixthsectiongoesontoprovideblanksforthesignaturesofthcreviewingsergeantandthereviewinglieutenant.
Affiant reviewed docutnents provided by HPD pursuant to this investigation, including C.l. Forms, expense reports, offense reports,
oveftime request forms, and expense authorization forms, and specifically all documentation relating to HPD OR nurnber 05 19974-18.
Affiant observed that in the C.l. Activity Sheet/Receipt fbr Funds Fonn associated with this reporl nurnber, the defendant signed that he
witnessed Goines make a payment to C.I. # I on April 25, 2018 at 2 I :00 hours in relation to the resu lts of a scarch warrant executed at 6807
Coforth in Houston, Harris County, Texas. C.l. #l denied making any buys at this location.
Affiantpreviouslyobtainedsearchwarrantsforcell sitedataforthepersonal cell phonesolthedefcndant,Goines,andC.l.#1. Affiantwas
provided a copy of the cell site data returned as a result of those warrants. The data for the defendant calne from AT&T and ranged liom
February 2l ,2017 through December 11 ,2018. The data for Goines came from T-Mobile and ranged from March 29,2018 through
February 1,2019. The data for C.l. #l came from AT&T and ranged from March 25,2017 through Dcccmber 31,2018. This data was
provided to Nathan Gates (Gates), a Lieutenant Investigator and Digital Forensic Examiner currently ernployed within the HCDAO Digital
Forensic Unit. During the time period for which data was returned, Gates mapped the coordinates of the cell phone data for the defendant,
Goines, and for C.l. # I for the dates and times of each payment documented.
In reviewing the defendant's cell site mapping for this date and time, Affiant observed that the defendant's cell phone was in use and
travelling liom approximately 20:04 hours to 20:55 hours, beginning approximately at the I{PD station located at 8300 Mykawa and
travelling norlhbound along Beltway 8 to the Cypress area. In reviewing the ccll site mapping for Goines, Affiant observed that his cell
phone was in use and was travelling from approximately 20:05 hours to 2l:50 hours, also beginning approxirnately at the HPD station
located at 8300 Mykawa and travelling nonhbound along Beltrvay 8 to the Cypress area. In reviewing the cell site nrapping for C.l. #l for
this date and time, Affiant observed that C.l. #l's cellphone was in use fiom approxirnately 20:03 hours to 2l:43 hours in the area of Sll-
288 and l-45, a location that Affiant found to be approxirnately ten (10) rniles away ftom 8300 Mykawa and approximately thifty (30) miles
away ftom the Cypress area.
Based on the above information, Affiant has reason to belicve that neither the alleged buy nor the allcged payrnent took placc as
documented by Goines and the defendant, and thus Affiant has reason to believe that the defcndant did not witness any allcged payrnentto
C.l.#l at2l:00hoursonApril25,20l8,asdocurnentedbythedefendantintheC.lActivitySheet/ReceiptlorFundsF'orrn.TexasPenal
Code Section 37.10, Tarnpering with a Govcrnmcntal Record, provides that, arnongst other rneans, "a person cornmits an offense if he
knowingly makes a false entry in, or false alteration of, a governmental record." Texas Pcnal Codc Section 31 .01(2) providcs that a
"Governmental Record" includes "anything belonging to, received by, or kept by govcrnrncnt for inlonnation, including a couft record."
'lhe C.l. Forms described above are requircd by a Gencral Order to bc cornplctcd lor all C.l. payments. They arc kept by IIPD to document
C.l, activity and involvernent in narcotics investigations Affiant is aware that IICDAO has requestcd and receivcd frorn HPD C.l. Forms
dating back more than 20 years. HPD is a subdivision olthe City o[]louston, a rnLrnicipality.
Affiantthcreforebelievesthatthedefendantdidcomrnittheoffenseoftarnpcringwithagovenrrncntal recordonorabout April 25,2018,in

Case#16808871 CRT#228
Houston, Flarris County, Texas by knowingly making a false entry in a governmental record, namcly a Houston Police Deparlment
Narcotics Division C.l. Activity Sheet/Receipt for Funds Forrn, and that this oflense was committed with the intent to defraud the Houston
Police Department.
Signed and srvorn by me on Dull' attested by ,rra on o) ot

[*
\o
./\
AFI]IANl' ASSI STANT DI S'I'RICT ATTORN EY

OF I{ARRIS COUNTY, TEXAS
I N ?r n. r,.,
Bar No
I >,F\? tt c'
Witness Printed name & Badge or Payroll nutnbcr
COMI'LAINl'
'; , li' i . 1i.1.!.1), ?hi. n!],tV[ tiiJ,tE0
,t! . |
.: I: " i : l,!a i:'?titi1? 0: tAMpEil.il.;c
'rA-
*,3.i:ia.) til"1 iilE 3t'J3.T i.ij,trr-l; !.?,.).,'a ,:tt irti.,iEir :!; t 1-,,.i_ j .1, .;. Bsl$',i
1,.in ii,j,,: '13!",3.a
t:.'..:Eal;i.. li.;rtIi_:)- aFi n: Il;:):1:r,.: ii i,L,t!,,if '. s'
: irr'.ie. FEI:I..-L? i;4,; :.::,'1li\:::,.- .ll:i a..;VEli
JUIY 1 2024 :c^
tt
a
JUDGE KELLI JOHNSON

:;o
'?.i:1'l.r':' I
i,:,i..t: it)': :a:.1.:: .-i: J.11, t: : ;,1.?.7i c...).i,:.: I .

t;r' 1: i i.t .a:-.i'i li.la tlt.,l p )i: rj t a,1.
u:a r; t,'
REPORT: DIM501 ,fUSTICE INFORMATION MANAGEMENT SYSTEM TIME: 4:35
DArE: 07/0t/20 D.A. INTAKE MANAGEMENT SYSTEM
DEFENDANT DE$CRIPTORS
# : 2653131
TRANSACTION D.A. LOG #: 2553131
sPN #. . .... :
AFIS NUMBER...:
DEFENDANT NAME: REYNA, CLEMENTE
ALIAS NAME..,.:
ALIAS SPN.....:
US CITIZEN INS#:
RACE. .........: W SEX: M DOB: tt/06/L968
MARITAL STATUS: BUILD: HEIGHT: WEIGHT:
HArR, ..... . .. .: SKIN: EYES:
qalDe
STREET ADDRESS ].200 TRAVIS

CITY. . HOUSTON, TX ZIP:
CELL OPT-IN: EMAIL OPT-IN
PRIOR ARREST?: N FBI# STATE ID #
AGENCY ID#. . : DAO SSN so#
ALIAS SPN(S) .:
DL#..........: ]-L948277 DL ST: TX
CO-DEFENDAN rcZ AO
\'
DOES THE DEFENDANT IIAVE
I
A SPN?
O4:35
Y
6
(CASSIDY, JAMES M) DIM5O1
PRINTED O7 /07/2020
THE STAI'E OF TEXAS
030s9894
AJCSCL\qV
D.A. LOG NUMBUR; 2653119
VS.
CJIS I'RACKING N
CLEMENTE ROBLES REYNA SPN:
I2OO TRAVIS
BY: EH DA NO:24
DOB: WMll/6/1968 AGENCY:DAO
HOUSTON, TX77OO2 DATE PREPARED: 7 ll t2020 s
O/R NO: SI907
ARREST DATE: TO
NCIC CODE:2399 G8 RELATED CASES:
q
I.-ELONY CHARGE; AGC THEFT PUB SERV
CAUSE NO;
HARRIS COUNTY DISTRICT COURT NO: COURI'ORDERED BAIL: TO BE SET
FIRST SETTING DATE: MAGISTRATION
PRIOR CAUSE NO;
CHARGE S EQ NUM: I
IN THE NAME AND BY AUTHORITY OF THE STATE
OF TEXAS:
Probable Cause
Affiant' Investigator Jonathan Prykryl, is a certified peace

officer employed by the Ilarris County Atto,ey,s olice (l-lCDAo) and
assigned to the civil Rights Division' Arfiunt has probable
^District
cause to believe und do., belicve that lorrner
Sergeant clemente I{eyna, hcreinafter the defcndant, Houston'police Departrnent (HpD)
did comrnit the third dcgree r.l"rf orr.rre of thefl
by a public servant, in an arnount
,nu. thirtv thousana aoita,s, on o, abouio.tou., z, 2017,
I,:TJ[:,:-;:ffi]:,*'J'J#'#]:X:J:,' ind.ontinJng through Scptember
Affiant bases this belief on the following:
Affiant is aware of and has reviewed HPD Gcneral ordcr (G.o.)

H300-ol ,subject "ovcrtirne Cornpe nsation.,' It
compensation for all classified employees of tJPD our.lines oveftime (or)
who hold the rank olpolice offic.., .enior
with a pay gradc equivalent of sergeant or below. Pertincnt folicc ofliccr, or sergcant, or other ernployees
excerpts are quotcd below;
case#1680888/ CRT#228
Except as otherwise noted in this General

order, all overtime earned shall be conrpensated
at the rate of time a'd a half.
officers shall have the option of overtime pay
or compensatory time for oveftinre worked,
be exceeded. unress the compensatory time bank limit
wourd
At the time of an officer's separation fi'om

the department as a classified employee,
accrued) shall be administered in accordance all banked cor.npensatory tirne (depending on
with the uppri.utr. iu* or the appiicatt. rr,1..luna how it was
confer Agreement.
officer requesting overtime compensation shall
submit the appropriate overtime request flonn.
for 20ll and 20 I g. Affiant observed

thar the
ant furlher observed the forms to contain
four
requesting officer, as well as a listing

ofthe
areviewing supervisor and reviewirig mernb
The bottom of the form contains a notation
r
Discipline and Criminal prosecution.,,
Affiant is aware of and has reviewed

G'o' #300-04, subject"llxtra Emproyrnent." It
outlines conditions and restrictions on extra
and specificalli .r;i;', ";;p;vees wi,
::X'r[ffi:[']fl,?ffi;;,Tplovees' not work anylxtra emproyrnenr ror compensarion or
as a
In addition to the defendant's overlime

Forms, Af,fiant reviewed the offense
reports (ol{) for the incident numbers listed on each form
ffii.x."*liffil;:.1-fl""1::,tTJ::#A:miu:zu;lf;]i:;,,,r,:i."i"r',',IIJ'lri!', Arnant conducteJ research rhrough raw
for periods throughout
Til;,:.,XTTfirdinates
Overlime Form siened bv

and detailing tr,".]..u,il 6 hours of oT worked l}om 1800 to
000 hours
wed the ORior f nciaeni N nr Nos. ,,1249479_47,, and 1250240_17
are
er 2,2017 , at 3826 Rosemr ent a narcotics search warranf execution
repoft to document a narcotics search warran, Incident No. I 250240 -17 and observed
the
Montridge, at I830 hours.
In reviewing the defendant,s cell site mappin
not connect to cell towers in the area ofjfjZO Lntobserved that the defendant's phone
does
towers in the area of 85 18 Montridge cell phone was in use and connected to
",
il;;-
traveling to the Cypress area. The defendant's connccts to towers along West Beltway
cell
8,
hours until after midnight. ar the delendant's residence, frorn
2004
Based on the above infornration' Affiant

has reason to believe that the deflendant
in his october2,2017 the overlime Form, worked no more than trvo of the six or.hours
andlhus any fo.rnof ;;;;;, documented
constitutes a theft. received rrom III)D ror rhe additionar four
hours areged
Affiant observed an overtime Form signed br tl"

requesting pay conrpcnsation for g hours
December 4' 2017 to 0200 hours on D-ecember.S, !:f"ldant
2011, andaeiliring
-ro-r. or worked from Ig00 hours on
of
'
17'1523003-17'and 1523430-lTarelisted' ".,r..t pof; inrl.iigotionr. Incident Nos. I 522705 -r7, r522g5g_
Affiantreviewedth.'oFforrncidentNo.r52270\-rTandobservedthereporltodocurnenta
street pop investigation conducted on Decernber
4,20ll,at 8000 Jutland, at l6i3 hours. Affiant reviewed thc oR for Inciclent
1522858-11 and curnenta street pop investigation conductcd on No.
n...,ru., 4,2oll ,a1 g900 cullen, at 1706 hours.
Affiant reviewed 1523003-17 ani ots.ruca it.,. r.port to crocurnen[
December4'201 1733hours' Affiantreviewedtheol{forlncidentNo.
a strect pop invesr.igatiorr conducted
on
docutnent a stree Isz:+:o-tzaiaobservedthereporlto
ctecl on Dccember 4,2017, at 7401cullcn,
at lg l0 hoLrrs.
case#1680888/ CRT#228
In reviewing the defendant's cell site mapping for 1800 hours on Dccember 4,2oll, to 0200 hours on Decembcr 5,2Ol7,Affiant observed
that the delendant's phone does not connect to cell towers in the arca of 8000 Jutland, 8900 Cullen, 5050 Sunflow er, or 74Ol Cullen. l'he
defendant's phone is connected to a tower in the Cypress area, near the defendant's residence, betrvecn I 80 I hours on December 4,20 .1
and 0146 hours on Decernber 5,2017.
Based on the above information, Affiant has reason to believe that the defendant did not work any olthe eight OT hours documented in his
December4,2017 OvertimeForrn,andthusanyformofpaymentreceivedlromHPDforthoseallegedeighthoursconstitutesatheft.
AffiantobservedanOvertimeFormsignedbythedefendantrequestingpaycolnpensationfor8hoursofOTworkedfrom l800hourson
December l,20ll , to 0200 hours on December 8,2017, and detailing two narcotics search warrant executions. Incident Nos. 1535305-17
and0153588-lTarelisted. AffiantreviewedtheORlorlncidentNo. 1535305-lTandobservcdthereporttodocumentanarcoticssearch
warrant execution conducted on December 7,2017,at3413 Liberty, at 1600 hours. Affiant reviewed the OR for Incident No. 1535305-17
and observed the reporl to document a narcotics search wanant execution conducted on Decem ber 1 , 2Ol7 , at 3 56 I Corder at I 825 hours.
In reviewing the defendant's cell site mapping for I 800 hours on December 1 ,2017, to 0200 hours on December 8,2olj, Affiant observed
that the defendant's phone does not connect to cell towers in the area of 34 I 3 Liberty or 356 I Corder. Between I 940 and 2004 hours, the
defendant's phone connects to towers in the approximate area of the Southeast Station, located at 8300 Mykawa. The defendant's phone
then connects to towers along West Beltway 8, traveling to the Cypress area. The defendant's phone is connected to a tower in the Cypress
area, near the defendant's residence, between 204 I hours on December 7,2011 and 0 I 4 I hours on Decenrber 8,2017 .
Based on the above information, it is Affiant's belief that the defendant worked no more than three of thc eight hours documented in his
December 1,2017 the Overtime Form, and thus any forrn of payment received from HPD for the additional five hours alleged constitutes a
theft.
Affiant observed an Oveftime Form signed by the defendant requesting pay compensation lor 8 hours of OT worked frorn 1800 hours on
December 11,2017, to 0200 hours on December 12,2017, and detailing two narcotics search warrant executions. lncident Nos. 1552737-17
and 1552903-17 are listed. Affiant reviewed the OR for Incident No. 1552737-17 and observed the reporl to document a narcotics search
warrantexecutionconductedonDecembcr 11,20 l7,at5017 ReedRoad, at1634 hours. AffiantreviewedtheORforlncidentNo.
1552903-17 and observed the reportto document a narcotics search warrant execution condLrcted on December 11,2011,at4929
Southwind, at l7l3 hours.
lnreviewingthedefendant'scell sitemappingfor l800hoursonDecetnber tl,20l7,to0200hoursonDecember 12,2017,Affiant

observed that the defendant's phone connects to towers in the approxirnate area of 5017 Reed Road and 4929 Southwind between I 853 and
20 I 5 hours. The defendant's phone then connects to towers along West Be ltrvay 8, trave ling to the Cypress area. The defendant's phone is
connected to a tower in the Cypress area, nearthe defendant's residence, between 2046 hours on Deccmber I 1,2017 and 0153 hours on
December 12,2017 .
Based on the above information, Affiant has reason to believe that thc defendant worked no more than three of the eight hours documented
in his December I l, 2017 the Oveftime Form, and thus any form of payment rcceived lrorn HPD for the additional five hours alleged
AffiantobservedanOvertimeFormsignedbythedefendantrequesting8hoursofpaycornpensationforOTworkedfiorn l800hourson
April 25, 2018, to 0200 hours on April 26,2018, and detailing trvo narcotics search rvarrant cxecutions. Incident Nos. 05 19738-18 and
05 19974-18 are listed. Affiant reviewed the OR for Incident No. 05 19738-18 and observed the reporl to document a narcotics search
warrantexecutionconductedonApril 25,2018,at8335Parnell,atl7l0hours. AffiantreviewedtheORforlncidentNo.05 19974-l8and
observed the report to document a narcotics searclr warrant execution conducted on April 25,2018, at 6807 Colorth at 1820 hours.
ln reviewing the defendant's cell site rnapping for 1800 hours on April 25, 2018, to 0200 hours on April 26,2018, Affiant observcd that the
defendant's phone connects to towers in the approximate area of 6807 Goforlh and 8i35 Parnell bctwcen 1805 and 1932 hours. The
defendant's phone then connects to towers along West Beltway 8, traveling to the Cyprcss area. l'he delendant's phone is connected to a
towerintheCypressarea,nearthedefendant'sresidence,between2l00hoursonApril 25,2018and0l3lhoursonApril 26,2018.
Based on the above inforrnation, Affiant has reason to belicve that thc defendant rvorked no rnore than three of the cight hours docurnented
in his April 25,2018 the Oveftime Forrn, and thus any form of payrnent reccived fi-orn FIPD for the additional five hours alleged constitutes
a theft.
AffiantobservedanOvertimeFonnsignedbythedefendantrcquestingpaycompensationfor4hoursofO'f workedfrom l800to2200

hours on May 2,20 18, and detailing two narcotics search wamant executions. Affiant also obscrved an Oveftimc Form signed by the
defendant requesting compensatory tirne cornpensation for 4 hours olOT worked lrorn 2200 hours on May 2,2018, to 0200 hours on May
Case#1680888/ CRT#228
3' 2018, with the same detail description as the 1800 to 2200 hours form. lncident Nos. 0553289-18 and 0553332-lg are listed
on both
forms' Affiant reviewed the OR for Incident No. 0553289-18 and observcd the report to document a narcotics search warrant execution
conducted on May 2,2018, at3502 Mainer aL 1740 hours. Affiant reviewed the OR for Incident No. 0553332-18 and
observed the repoft to
document a narcotics search warrant execution conducted on May 2, 20 I 8, at 5827 pcrshing, at I 824 hours.
In reviewing the defendant's cell site mapping for 1800 hours on May 2,20 18, to 0200 hours on May 3,2018, Afflant observed
that the
defendant's phone connects to towers in the approximate area of 3502 Mainer and 5827 Pershing beiween 1802 and 2050
hours. The
defendant's phone then connects to a tower in the Cypress area, near the defendant's residence, between 2 I 2 I hours on May
2,201g, and
0150 hours on May 3,2018.
Based on the above information, Affiant has reason to believe that the defendant rvorked no more than four of
the eight hours documented in
his two May 2,20 | 8 Overlime Forms, and thus any lorm of payment received frorn HPD for the additional four houis alleged
constitutes a
theft.
Affiant observed an Overtime Form signed by the defendant requesting colnpensatory tirne cornpcnsation for 6 hours of OT worked
flom
0800tol400hoursonSeptember30,20l8,anddetarlingthereviewofninecasefilcs. ThelocationprovidedisfbrthesoutheastStation,
8300 Mykawa.
In reviewing the defendant's cell site mapping for 0800 to 1400 hours on Septembcr 30, 2018, Affiant observed that the defendant's
phone
does not connectto celltowers in the area of 8300 Mykawa. l'he deflendant;s phone is connected to a tower in
the area of 12100 Hiram
Clark Road frorn 0800 to 1348 hours. Affiant also reviewed business records obtaincd from FrizellGroup lnternational, LLC (Frizell).
The
records contain documentation of the defendant's employment with Frizell including the date worked, start time, end time,
and location.
The records include an entry stating that Clernente Reyna (the deflendr nt) worked on September 30, 2018, rvith a start time
of 0700 hours
and an end time of 1500 hours.
Based on the above inforrnation, Aflfiant has reason to believe that the def'endant worked none of the six hours
documented in his September
30,2018 the Overtime Form, and thus any forrn of payment receivecl from HPD for those alleged six hours constitutes a theft,
Each of the Overtime Forms discussed herein indicates that they were approved by a supervisor and a member of the
cornmand staff for
compensation and further list a "date posted." Thus, affiant has probable cause to believe the delendant was paid for the
Ol'requested.
Affiant reviewed business records received from the City of Houston, Administration and Regulatory Affairs Deparlment. 'fhe records
include the ovetlime "calculated rate of pay" for the defendant throughout20lT and20 18, as well as the Biweekiy pay Schedule
for 20 l7
and20l8. AffiantobservedthatbeginningwithpaydateOctober 13,2Ol7(representingthepayperiodbeginningSeptember23,20lTand
ending October 6,2017), and continuing through pay date July 20,20 18, the defendant'i overlime calculated rate of pay was
$69.23.
Affiant observed that beginning with paydate August 3, 20 18, and continuing through pay date F-ebruary 15, 2019, the defendant,s overtime
calculated rate of pay was $71.34.
Based on the hours and rate ofpay discussed above, Affiant has reason to believe the follorving reflects the value ofpay
and compensatory
time acquired by the defendant without the effective consen[ of IIPD and the City of Ilouston:
OT CLAiITiED ACTUAL OT CORRECT PAYMET{T

PAYMEI{T HOURS AIVTOUT{T O\rE RPAYIVE llT
10Er2U7 69.23 b 54't 5.38 2 5138 4E s276.92
1?J4t2017 8923 s553 84 0 s0 00 CCED O'
1zfi120'17 69.23 o s553 84 a
s207 63 s 346.1 5
12t11t2017 rc t1 s553 84 ?
s207 69 s 346.1 5
Al25l201E 6S.23 o cEEt or
3 s207 09 s34A.15
5t2t2018 69 23 eEca ol
t276 92 s276 S2
stSaDuE 71,34 D s128 0{ 0 s.0 00 s428 04
TOTAL THE FT AIVIOU I{T 14.17
Based on the above information, Affiant has t'eason to believc that the dclcndant did not actually wolk all of the hours for which he
submitted an Overtime Fortn, and for which he was compcnsated, and thus that the dclcndant unlarvfully appropriated cornpensation from
HPD and the City of Houston. Texas Penal Code Section 31.03,'Iheft, provides that, "a person cornrnits an oft-ense if he Lrnlawfully
appropriates properly with intent to deprive the owtrer of property," and that "appropriation is untawlul if it is without the owner's elfective
consent." This Section also provides that if the value of the properly stolcn is $2,500 or rnore but less than $30,000, the ollense is a State
J ail Felony. Th is Sect ion further provides that the olfense is increased to thc next h ighcr category o f offense if it is
shown on the trial of the
Case#16808881 CRT#228
offense that "the actor was a public servant at time ofthe offense and the property appropriated
came into the actor,s custody, possession or
control by virtue of his status as a public servant." Texas Penal Code 1.07 provides'tirat a public servant
includes a person employed as an
officerofgovernment' ThecityofHoustonisagovernrnentcntitylocatedwithinllaniscounty,,Texas. llpDisasubdivisionofthecity
of Houston.
Affiant has reviewed 'fexas Penal Code Section 31.09 and knows that when amounts are obtained in violation
pursuant to one schetne or continuing course of conduct, whether fronr the same
of Chapter 3l ('fheft)
offense and the amounts aggregated in deterrnining the grade of offense.
or several sources, the conduct,-,1uy f. considered as one
Affiant therefore has reason to believe and does believe that on about Octobe r 2,2017, though September
30, 201g, while a public servant,
namely a Texas Peace Officer, and pursuant to one scheme and continuing course olconduci, Clernente
Reyna did then and there
unlawfully appropriate, by a exercising control over property, namely, lnoney and compensatory time, owned by the
Houston Police Department on, hereinalterstyled the Complainant,;f the value of at leasttwo thousand flve hundred
dollars but less than thirty th he intent to deprive the complainant of that propefly, and said property came into the
Defendant's custody, posses ftue ofthe Deiendant,s status as a public servant.
Signed and sworn by me on ?V Duly attested by me on 0 oi /a obo

(-
AFFIANT ASSISTANl' DIS'f RICl' ATTO Y
OIT IIAI{IiIS COUNI'Y, I'T]XAS
I
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Bar No.
t>tA)?Od
Witness Printed name & Badge or Payroll nuntber
COMPLAINT
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JUDGE KELLI JOHN

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REPORT: DIM601 JUSTICE INFORMATION MANAGEMENT SYSTEM
DArE: TIME: 4:37
07 /0t/20 D.A INTAKE MANAGEMENT SYSTEM
IN D.A. LOG #: 2553119
CUSTODY... . N CARINDICATOR: ID BY PRINTS:
DATE OF ARREST
TIME OF ARREST:
sPN #.
AFIS NUMBER. ,.
DEFENDANT NAME REYNA, CLEMENTE ROBLES
ALIAS NAME....
ALIAS SPN.,.. .
US CITIZEN.. . .: Y INS #
ALLIEN STATUS : TLLEGAL CODE
RACB...... ...i W SEX: M DOB: tL/06/7968
MARITAL STATUS: MA BUILD: MED HEIGHT: 5OO
}.IITD WEIGHT: 220
BLK SKIN: LGT EYES: BRO
scARs.. ..... :

CITY.. HOUSTON, TX ZIP: 77002
PHONE, () .87 T .
EMAIL:
CELL OPT-IN EMAIL OPT_IN
PRIOR ARREST?: N FBI#:
AGENCY ID#. . : DAO
STATE ID #:
SSN: so# :
ALIAS SPN(S).:
DL#..........: 779 4827 7 DL ST: TX
EMPLOYER RETIRED
OCCUPATION.,.. RETIRED
MENTAL ILLNESS ,,,: N
co-DEFENDANTS?
d6
PRINTED I O7 /01./2020
A SPN?
O4:37 (CASSIDY, JAMES
Y
6 M) DIM6 O 1
THE STA'|E OF TEXAS D.A. LOG NUMBER:2653
0305989s
VS. CJIS'IRACKING NO.: q
THOMAS WOOD SPN: BY: EH DA NO: 2425968
I2OO TRAVIS DOB: W M 312011968 ACENCY:DAO
HOUSTON, TX77004 DATE PREPARED: 7 lll2020 O/R NO: SI907
ARREST DATE: TO BE
o

HARRIS COUNTY DISTRICT COURT NO: MAGISTRATION
CHARGE SEQ NUM: I
Before me, the undersigned Assistant District Attorney olHarris Counly', Texas, this day appcared the undersigned alfiant, who under oath says
that he has good reason to believe and does believe that in Hanis County, Texas, THOMAS WOOD, hereafter styled rhe Deflendant,
heretolore on or about October 31,2017, did then and there unlawlully, knowingly make a false entry in a govemrnental record, namely, a
Houston Police Department Narcotics Division C.l. Activity Sheet/Receipt fol Funds Forrn, with thc intent to defraud and hann another.
PROBABLE CAUSE
Affiant, Lieutenant Billy Milan, is a certified peace officer ernployed by the Llan'is County District Attorrrey's Olfice (tICDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to believe and does believe that forrner Flouston Police Deparlrnent (HPD)
Sergeant Thomas Wood, hereinafter defendant, did cornrnit the state jail felony olfense oltanrpering with a governmental record on or about
October 31,2017, in Houston, Ilarris County, Texas. Afllant bases this belief on the lollowing:
On January 15,2020, former HPD Narcotics Officers Gerald Goines (Goines) and Steven Bryant (Bryant) were indicted lor Tarnpering with
a Governmental Record, see Harris County Cause Nos. 1660164 and 1643521, respectively. These charges center on lalse staternents sworn
to by thc defendant in obtaining a narcotics search rvarrant for a residence located at 7815 Harding Street and false staternents made in the
corresponding offense report by Bryant. Execution of that search \\'arrant led to the death of both horneou,ners, injury to four HPD oflficers,
and thereafter an HPD investigation into the defendant's use of confidcntial inlormants (C.l.s) to obtain search warants.
Affiant reviewed the IIPD offense report (OR) documenting that invcstigation, I IPD OI{ No. 133932-19, ar"rthored by Sergeant Rick Bass, a
licensed peace officer currently ernployed by HPD, and learned the following: All C.l.s rcgistcred to Goines were intcrviewed and each
case#1680890/ CRT#228
denied having completed a controlled buy at Ilarding Strcet, despite the probable cause aftldavit lor thc search warrant for
that location
stating that a C.l' had completed a controlled buy the day prior to the date olthe affidavit. One of the C.l.s who was interviewed
(hereinafterreferredtoasC.l.#l)reportedtohaveattimesbeenpaidby'Goincsforrvorknotprelormcd. C.l.#lgaveavideointerview
during which C.l. #l was asked about several locations where, according to olficial IIPD records (specitically C.l]Forrns discussed
more
fully below), C.l. #l had conducted controlled buys. C.l. #l denicd having conducted scvcral of thosc buys, lach of which led to a narcotics
search warrant.
Affiant is aware of and has reviewed IIPD General Ordcr 600-16 (CO) which governs C.l.s and payments to C.t.s. The
GO holds that..all
meetings between a C.l. and an officer shall be attendcd by two olflcers." This regulation requires that that at lcast two officers
be present
when a controlled buy is conducted. It further mandates that "officers shall not pay a confidential informant without the appropriate
witness
present." The GO goes on to dictate how payntents to C.l.s will be documented, stating that all payments to C.l.s,,shall be fully
documented on a division's 'Confidential Infortnant Receipt for Funds form"'(C.1. Foim) with "control infolnation,,to include
the
signature of the C.l. as an agreement that the payment was received, the signature of the invcstigator nraking the payment,
the signature of at
least one other officer witnessing the payment, and the date of the payment. Thcse forms, as diitated Uy tne CO,'require that
at least three
people - the C.I., the investigator, and a witness be together in one place in order for a pay'ment to occur. Affiant
- has reviewed numerous
HPD C.l. Forms and has noted that these forms also include the time of the payment andih; associated OR number for the OR
wherein the
Affiant has also reviewed the Special Investigation Command, Narcotics Division, Standard Operating Procedures (SOp). SOp 100/2.05
covers "Confidential Informant Funds/Expense Letters, Limits of Authorization and Use of Flash Money" and includes a section
on,,CI
Payments & Receipt for Funds Form." That section repeats the requirements olGO 600-16 and also sjccifically states,,,The
CI Receipt
for Funds form will be completed at the time of the payrnent to the CI" (emphasis in original). Affianthas rcvierved the spccific
C.l. Form
used by the HPD Narcotics Division, titled "C.l. Activity Sheet / Receipt for Funds Form." The form has six sections. The
first section
includes C.l. name, date, time, location, OR number, and blanks for up to two drugtypes and the con'esponding weight. The
second section
is for an amount paid to the C.l. for information and assistance and includes blanks for the amount paid and ttre C.f .i signature.
The third
section is for an amount provided to the C.l. to purchase narcotics and includes blanks lor the atnount paid and the C.l.,s initials.
The fourlh
section provides a space for details. The fifth section starls with the word "Witness" follorved by a blank for a printed name
and a blank for
a signature. The sixth section goes on to provide blanks lorthe signatures of the reviewing sergeant and the reviewing lieutenant.
Affiant reviewed documents provided by HPD pursuant to this investigation, including C.l. F'orms, expense repofts, offense reports,
oveftime request forms, and expense authorization forrns, and specifically all documentation lor IIPD oR numbcr 1312420-17.
Affiant
observed that Goines submitted a C.l. Activity Sheet/Receipt for Funds Form associated with this report number, wherein
he stated that he
madeapaymenttoC.l.#l onOctober3l,20l7at09:00hoursfor theresultsofasearchwaffantpredicatedonabuymadebyC.l.#l at
4855 Fuqua #2301 in Houston, Harris County, Texas. The defendant signed this form as a witness to this alleged puy*.nt on
this date and
time. C.l. #l denied making any buys at this location.
Affiantpreviouslyobtainedsearchwarrantsforcell sitedataforthepersonal cell phonesolboththedefendantandC.l.#1. Affiantwas

providedacopyofthecell sitedatareturnedasaresultofthosewarrants.'l'hcdataforthedefendantcarneliornAT&Tandrangedffom
April6,20lTthroughMarchg,20lS.ThedataforC.l.#lcarnefrornAT&Tandrangedfi'omMarch25,2OlTthroughDecember3l,20lg.
This data was provided to Nathan Cates (Cates), a Lieutenant Investigator and Digital Forensic Exanriner cur.rently e"mployed
within the
HCDAO Digital Forensic Unit. During the time period for which data was returned, Gates rnapped thc coordinates of ihe cell phone
data
forthedefendantandforc.l.#l forthedatesandtimesofthedocumentedpayment.
In reviewing the defendant's cell site mapping for this datc and time, Affiant observed that the defendant's cell phone was in
use and
travelling at 08:52 hours in the arca north of the 610 Loop between thc Indepcndence Heights and Acres Hornes neighborhoods. The
defendant's cell phone was in use in the same area again at09:52 hours, with no indication of any cell phone use outside of that locatio,
during the time in between. In reviewing the cetl site mapping for C.l. #l fol this date and time, Affiant observed that C.l. #l,s cell phone
was in use frorn approximately 08:04 hours to 09:54 hours in the area olSH-288 and I-45, a location that Affiant found to be approximately
fifteen (15) miles away from the defendant's location in northwest Ilouston during the sanre tinre.
Based on the above inflorrnation, Affiant has reason to bclieve that neither the alleged buy nor the allcgcd payment discussed Screin took
place as docurnented by Goines and the defendant, and thus Affiant has reason to believc that the delendant did not witness any alleged
payment to C.l. #l at 09:00 hours on October 31,2017, as docurnented by the dcfendant in thc C.l Activity Sheet / Receipt for Fundi
Form.
l'exas Penal Code Section 37. 10, 1'arnpering with a Governmental Record, providcs that, arrrongst othcl rneans, "a persol corrrrnits an
offense if he knowingly makes a false entry in, or falsc altcration ol, a govenrncntal record." l'exas l)cnal Codc Section 3i.Ol(2)provides
that a "Governmental Record" includes "anything bclonging to, reccived by, or l<cpt by'govcnrrnent lbr inforrnation, including u iou,f
record."TheC.l.FormsdescribedabovearerequiredbyaGeneral Ordertobecolnpletcdlorall C.l.payrrcnts.'l'heyarckeplbyHpDto
documcnt C.l. activity and involvement in narcotics invcstigations. Alfiant is arvare that tICDAO has requested and ieceivcd lrorn HpD C.l.
Forrns dating back tnore than20 years. HPD is a subdivision of the City of IIouston, a rnunicipality.
Case#l680890/ CRT#228
Affiant therefore believes that the defendant did commit the olf,ense oltampering with a governmental record on or about October 31,2017
in Houston, Hanis County, Texas by knowingly making a false entry in a govemrnental record, namely a llouston Police Depaftment
Narcotics Division C.l Activity Sheet / Receipt for Funds Forrn, and that this offense was committed with the intent to defraud the Houston
Police Department.
ACAINST THE PEACE AND DIGNITY OF TtIE STATE.
Signed and swom by me on

?/ Dury attested by rne on Ufu/* u'
AFFIANT ASSISTAN'I' DISI'RICT A-I-TORNEY

OF IIARRIS COUNTY. flrXAS
\
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Witness Printed name & Badge or Payroll nurnber
COMPLAINT
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II
KELLI JOHNSON
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REPORT: DIM501 .]USTICE INFORMTTTION
DArE:
MANAGEMENT SYSTEM TIME: 4:47
0'7 / 0t /20 D.A.'INTAKE MANAGEMENT SYSTEM
IN D.A. LOG #: 2653140
CUSTODY..,. N CARINDICATOR ]D BY PRINTS:
DATE OF ARREST
TTME OF ARREST:
SPN #
AFIS NL]MBER. . .
DEFENDANT NAME WOOD , THOMAS

ALIAS NAME....
ALIAS SPN.... .
US CITIZEN INS#:
ALL]EN STATUS : ILLEGAL CODE:
PLACE OF B]RTH: CITY OF BIRTH:
Platr W SEX: M DOBt 03/20/1968
MARITAL STATUS: BUILD: LGT HEIGHT: 509 WEIGHT: 185
HAIR.. ....... . : xxx SKIN: LGT EYES: BLU
scARs... .....:
STREET ADDRESS: 12OO TRAVIS
f-TTv . .: . uA
nwUSTON, TX ZIP:
PHONE. .......: ( .FI T .
)
EMAIL:
CELL OPT-IN: EMATL OPT-IN:
PR]OR ARREST?: N FBI#: STATE ID #
AGENCY ID#..: DAO SSN: so#
AL]AS SPN(S) .:
DL#........ .: t25tgt44 DL ST: TX
CO-DEFENDANTS?
G
A SPN? Y
DOES THE DEFENDANT IIAVE
PRINTED: 07 /OT/2020 04:4'7 (CASSIDY,

6,
.]AMES M) DIM5O1
THE STATE OF TEXAS 03059896 D.A. t.OG NUMBER: 2653097 'a
VS.
HODGIE ARMSTRONG SPN:
CJIS TRACKIN
BY: EH DA N
q
o
o
I2OO TRAVIS DOB: B M 812911965 AGENCY:DAO s
\J
x
o
HOUSTON, TX77004 DATE PRIIPARIID: 7 I I 12020 O/R NO: S1907 a
CW
ARRESl'DATE
c J
NCIC CODE:480232 REI.ATED CASES:
trl-.,, .,
., . S i,
FELONY CHARGE: TAMPERING GOVERNMENTAL RECORD - J

--)
l: -_
-.i "r_
CAUSE NO: COURT ORDERED BAIL: TO BE SE AT
HARRIS COUNTY DISTRICT COURT NO: MAGISTRATION i
FIRST SETTING DATE: PRIOR CAUSE NO: .' CJ
CHAII.CE SEQ NUM: I
Before me, the undersigned Assistant District Attorney of l-larris County, Tcxas, this day appeared thc undersigned affiant, who r,rnder oath says
that he has good reason to believe and does believe that in Hanis County, l-cxas, HOI)GIE AIfMSTIiONC, hercafter stylcd the Defendant,
heretofore on or about January 22,2019, did then and there unlawfully, did then and therc knowingly make a talse entry in a governmental
record, narnely, Houston Police Deparlrnent offense report number 0095844-19, lvith the intent to dcfraud or hartn anothcr.
PROBABt,E CAUSE
Affiant, Lieutenant Billy Milan, is a certified peace officer employed by the Harris County District Attorney's Olfice (HCDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to believe and does believe that fonner Houston Police Department (HPD)
Officer Hodgie Armstrong, hereinafter defendant, did cornmit the state jail felony offense of tampcring with a governmental record on or
about January 22,2019, in Houston, Harris County, Texas. Affiant bases this belief on the lollorving:
On January 15,2020, former HPD Narcotics Officers Gerald Goines (Goines) and Stevcn Bryant (Bryant) were indicted for Tampering with
a Governmental Record, see Harris County Cause Nos. 1660764 and 1643521, respectively. l'hcse charges center on false statements sworn
to by Goines in obtaining a narcotics search warrant for a residence located at 7815 Harding Strect and false staternents made in the
corresponding offense report by the defendant. Execution olthat search warrant lcd to the death of both homeowners, injury to four HPD
officers, and thereafter an HPD investigation into Coines' and Bryant's use olconfidential inforrnants (C.l.s) to obtain search warrants.
AffiantisawareofandhasreviewedHPDGeneral Order600-16(GO)whichgovernsC.t.sandpaynlcntstoC.l.s. TheGOholdsthat"all

meetings between a C.l. and an officer shall be attended by two officers." 'l'his regulation requires that that at least two officers be present
when a controlled buy is conducted. It fufther mandates that "officers shall not pay a confidential inlormant without the appropriate witncss
present." The GO goes on to dictate how payments to C.l.s will be docunrented, stating that all paytnents to C.l.s "shall be fully
documented on a division's 'Confidential Informant Receipt lor Funds form"' (C.1. Irornr) rvith "controI inforrnation" to include the
signature of the C.l. as an agreement that the payment was received, the signature olthe investigator making the paymcnt, the signaturc olat
'fhese fbrrns, as dictated by the GO, require that at least three
least one other officer witnessing the payment, and the date olthc payrncnt.
people the C.1., the investigator, and a witness be togethcr in one place in order lor a payrnent to occur. Afflant has reviewed numerous
I-IPD C,l. Fonns and has noted that these forms also include the tirne of the payment and the associated OR number for the OR wherein the
Affiant has also reviewed the Special lnvestigation Comrnand, Narcotics Division, Standard Operating Procedures (SOP). SOP 100/2.05
covers "Confidential Informant Funds/Expense Letters, Limits of Authorization and Use of Flash Money" and includes a section on "Cl
Payrnents & Receipt for Funds Fonn." That section repeats the requirerncnts of GO 600-16 and also specifically states, "'[.he Cl Receipt
for Funds forrr will be completed at the time of the payment to the Cl" (emphasis in original). Alfiant has reviewed the specific C.l. Form
used by the HpD Narcotics Division, titled "C.1. Activity Sheet / Receipt for Funds Forur." Thc forrn has six sections. l'he first section
includes C.l. name, date, time, location, OR nurnbcr, and blanks for up to two drug types and thc corrcsponding weight. The second section
is for an amount paid to the C.l. for inforrnation and assistance and includes blanks for the arnount paid and thc C.l.'s signature. The third
section is for an amount provided to the C.l. to purchase narcotics and includes blanks lbr the anrount paid and the C.l.'s initials. l'he fourlh
section provides a space for details. The fifth section stafts with the rvord "Witness" lollorved by a blank for a printed name and a blank for
a signature. The siith section goes on to provide blanks for thc signatLrres olthe revicwing sergcant and the reviewing lieutcnant.
Affiant reviewed docLrrnents provided by tlPD pLlrsuant to this investigation, including C.l. Forrns, cxpensc reports, offense reporls, and
overlime request forms for IIpD OR nurnber 0095844-19. Alfiant observcd that thc dcl'cndant subrnitted a C,l. Activity Sheet/Receipt lor
I.unds Form associated with this rcport nurnbcr, whcrein thc cle fendant statcd that lre tradc pavtrents to a C.l. on January 22,2019 lor a buy
Case#15808911 CRT#228
allegedly made at 4437 Knoxville in Houston, Harris County,'fexas. Thc fornr indicates that this money was "paid and/or provided" on
January 22,2019. The original time documented appears to have been 20:00 hours (8;00prn), horvever a parenthetical reading "l9:30"
(7:30pm) is written in red ink above "20:00." Bryant's signature appears on the forrn in the blank provided for witness. Affiant additionally
observed that Armstrong stated in HPD OR No. 0095844-l9lhat he and Bryant rnet with the C.l. and conducted the above-described
controlled buy at4437 Knoxville on January 22,2019, at 6:00pm (18:00 hours).
Affiant previously obtained search warrants for cell site data for Bryant's personal cell phonc. Affiant was provided a copy of the cell site
data returned as a result of that warrant. Bryant's data came lrorn Sprint and ranged from January 8, 20 I 8 through February I , 2019. This
data was provided to Nathan Gates (Gates), a Lieutenant Investigator and Digital Forensic Examiner currently employed within the
HCDAO Digital Forensic Unit. During the time period for which data was returned, Gates mapped the coordinates of the cell phone data
for Bryant for the dates and times of each payment docurnented.
ln reviewing Bryant's cell site mapping forJanuary 22,2019, at l8:00 hours (as docurnented by the defendant in the offense reporl), Affiant
observed Bryant's cell phone was in use at approximatcly l8:06 hours in the area of I-10 and West 99, tnore than thirly (30) miles from
4437 Knoxville. In reviewing Bryant's cell site mapping forJanuary 22,2019 at l9:30 hours and 20:00 hours (as documented bythe
defendant in the C.l. Activity Sheet / Receipt for Funds Forrn), Affiant observed Bryant's cell phone,,vas in use and travelling at
approximately 18:24 hours, l8:39 hours, l9:21 hours, and20'.24 hours, all in the Richmond, Texas area, a location Affiant found to be more
than twenty-five (25) miles fi'om 4437 Knoxville.
Based on the above information, Affiant has reason to be lieve that neither the alleged buy nol the alleged payment for said buy took place as
documented by Bryant and the defendant, and thus Affiant has reason to bclieve that the dcfendant knorvingly made a false statement in
documentingthatBryantwaspresentforanyallegedcontrolledbuyorpaymenttoaC.l,at l8:00hours, l9:30hours,or20:00hourson
January 22,2019,aI 4431 Knoxville, as stated by the delendant in HPD ollense reporl number 0095844-19 and in the corresponding C.l
Activity Sheet / Receipt for Funds Form.
Texas Penal Code Section 37.10, Tampering with a Governrnental Record, provides that, anrongst other means, "a person commits an
offense if he knowingly makes a false entry in, or false alteration of, a governrnental record." l-exas Penal Code Section 37.01(2) provides
that a "Governmental Record" includes "anything belonging to, received by, or kept by governrrent for inforrnation, including a court
record." Based on his experience and training, Affiant knorvs offense repons to be made and kept by t-lPD narcotics officers to document
the activity and involvement of officers and witnesses in narcotics investigations. HPD is a subdivision of the City of Houston, a
municipality. Affiant is additionally aware that Texas appellate courts have held offense reports to be governmental records under Texas
Penal Code Section 37.01.
Affiant therefore believes that the defendant did cornrnit the offense of tarnpering rvith
a governmental record on or about January 22,2019,
in Houston, Harris County, Texas by knowingly making a false entry in a governrnental record, narnely a Ilouston Police Dcparlment
offense report number 0095844-19, and that this offense was committed with the intent to dellaud the Houston Police Department.
AGAINST THE PEACE AND DICNITY OF THE STATE.
Signed and sworn by me on 4o Duly attcsted by me on
AFFIANT ASSISTANI' DI S]'RIC'f ATTORNEY

OF HARRIS COUNTY, TEXAS

.t
I
Bar No
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COMPLAINT
THE STATE OF TEXAS 03059897 D.A. LOG NIJMBER: 2653143
VS. CJIS TI{ACKING NO.: A
ROBERT GONZALES SPN: BY: EH DA NO:ZlZSgeff 3 - o
I2OO TRAVIS DOB: W M 711311960 AGENCY:DAo **l f,;] 8I a\Ja o
HOUSTON, TX17004 DATE PREPARED: 1 I I /2020 O R No: 51907 l'o-. cv

ARRESI' DA'I-E: To BEh+ .{''; :l
:-.-..- S t-)
NCIC CODE:2699 78 RELATED CASES lev i-:.:: t: a

-J
FELONY CHARGE: MISAPPLICATION -.fC -)
@*
CAUSE NO: COURT ORDERED BAll,: TO IIE SEt T
HARRIS COUNTY DISTRICT COURT NO: 168089,4 MAGISTRATION ,S
F
228 CI{ARGIj SEQ NUM: I
Before me, the undersigned Assistant District Attorney ol[{arris County, Texas, this day appeared the undersigned affiant, who undcr oath says
that he has good reason to believe and does believe that in Harlis County, l'cxas, ROBERT GONZALES, hereafter styled the Defendant,
heretofore on or about December 12,2016 continuing through March 19,2018, did then and there unlawfi.rlly, while a fiduciary, namely,
while an administrator, and while aperson acting in a fiduciary capacity, and while an officer, nlanager, employee, and agent caryingon
fiduciary functions on behalf of a fiduciary, knowingly, intentionally, and recklessly nrisapply property, namely money,olthe value of at
least two thousand five hundred dollars but less than thirty thousand dollars by dealing with said propcrty contrary to an agreement under
which the Defendant held the property and in a rrranner that involved substantial risk olloss to the IIoLrston Police Deparlrnent, the owner of
said properly and the person for whose benefit the property rvas held, to wit: by repeatedly failing to veri! and authorize the payment of
Houston Police Department funds to confidential informants prior to Houston Police Departrnent Nalcotics officers releasing said funds to
said confidential informants in violation of the General Orders and accornpanying Standard Operating Procedltt'cs of the [{ouston Police
Department.
Probable Cause:
peace officer employed by the lJarris County' District Attorney's Office (ItCDAO) and
Affiant, Lieutenant Billy Milan, is a certified
has probable caLrse to belicvc and does bclieve that former Houston Police Deparlment (l-lPD)
assigned to the Civil Rights Division. Affiant
Lieutenant Robert Gonzales, hereinafter defendant, did comrnit the state jail t-elony oflf'cnse of aggregatc rnisapplication of liduciary propefty
on or about December 12,2016 through March I 9, 20 I 8 in Houston, Harris County, Texas.
On January 15,2020, forrner HPD Narcotics Officers Cerald Goines (Coincs) and Stcvcn Bryant (Bryant) were indicted for'Iarnpering with
a Govemmental Record, see Harris County Cause Nos. 1660164 and 164352[, respectively. These charges center on false statements sworn
to by Goines in obtaining a narcotics search warrant for a residence located at 7815 I{arding Street and false statements nrade in the
correspondingoffensereportbyBryant, Executionofthatsearchwarrantlcdtothedcathofbothhomeowners,injurytolourHPDofficers,
and thereafteran HPD investigation into Coines'use of confidential informants (C.l.s) to obtain scarch warrants.
Affiant is aware of and has reviewed HPD General Order (G.O.) # 100-07 covering "standard Operating Procedures" (SOPs). C.O. # 100-07
mandates that "standard Operating Procedures (SOPs) shall be followed by all comrrrands, divisions, offices and units performing like tasks
and functions in order to ensure uniformity of police services." lt furlher states that "all erlployees are responsible for knowing,
understanding, and following the SOPs applicable to their assignment" and that G.O. #100-07 "applies to all employees." G.O. #100-07
additionally mandates that "each ernployee shall read the current SOPs applicable to thc ernployee's assigntnent," that "Ii]f after reading the
applicable SOPs an employee has any issues, concerns, or qucstions, the ernployee shall rneet with his supervisor to address these matters,"
and that "[e]ach employee shall sign an Acknowledgment of Receipt and l{eview of Standard Opcrating Proccdures forrn." Affiant has
reviewed HpD personnel records for the defendant and obscrved that thc defendant signcd an Acknowledgement of Receipt olGeneral
OrdersforG.O.#100-0TonbothJanr.rary 13,2Ol2andMay 13,2019,andforC.O.#600-l6onbothDecernber7,2010 andMarch30,
20t5.
Affiant is additionally aware of and has reviewcd tlPD General Order (G.O.) #600-16 covcring "Confidential Irrlorrnants and Other Sources
of Information," which holds that "a supervisor''s authorization is neccssary lor thc disburscrrent olarry CI ltrnds" and shall bc documented.
The order furlher states that a sergeant lnay approve up to and including S250. A [-ieutcnant lnay approve up to $2500. G.O. #600-16 ftrrlher
case#15808941 CRT#228
requires that a "Confidential lnformant Receipt for Funds" forrn be completed, including the amount of the payment, the date on which the
payment was made, and a signature of the "first-line supervisor witnessing the payrnent if the payrnent exceeds $50." C.O. #600-16
additionally requires that "each division using confidential inlorrnants shall develop and adhere to standard operating procedures (SOPs)
specific to that division's use of confidential informant lunds."
Affiant has reviewed the Special Investigation Cornmand, Narcotics Division, Standard Opcrating Procedures (SOP), specifically SOP
100/1.03, titled "Narcotics Division lnvestigative Lieutenant." Pursuant to this SOP, the Narcotics Division lnvestigative Lieutenant is
responsible for a number of duties, including to "supervise daily operations of the squad ensuring conformance with departmental policies
and procedures" and "to approve the expenditure of funds." Affiant has reviewed IIPD personnel rccords for the defendant and observed
thatheservedasaNarcoticsDivisionlnvestigative[,ieutenantduringtheyearsol20 l4through20l8. AffianthasalsoreviewedSpecial
Investigation Command, Narcotics Division, SOP 100/2.05, which covers "Confidential Inlormant Funds/Expense Letters, Limits of
Authorization and Use of Flash Money," and includes a section on "CI Payments & Receipt lor Funds Form." That section repeats the
requirements of GO 600-16 and also specifically states, "The CI Receipt lor Funds forrn will be cornpleted at the tirne of the payment to the
CI"(emphasisinoriginal).Regardingauthorizationforexpendituresoveracerlainanrount,SOP 100/2.05tnandatesthatpurchases
requiring amounts over $125.00 up to $250.00 rnust have prior approval by a Squad Supcrvisor,'uvhereas a Narcotics Division Lieutenant
may authorize an expenditure of over $250.00 up to 52,500.00.
Affiant has reviewed the specific C.l. Forrn used by'the HPD Narcotics Division, titled "C.1. Activity' Sheet / Receipt for Funds Form" and
has found that, consistent with SOP 100/2.05, the form has six sections, 'Ihe first section includes C.l. name, date, timc, location, OR
number, and blanks for up to two drug types and the corresponding weight. l'he second scction is lor an amount paid to the C.l. for
information and assistance and includes blanks for the arnount paid and the C.l.'s signature. The third section is for an amount provided to
the C.l. to purchase narcotics and includes blanks for the amount paid and the C.l.'s initials. The lourth section provides a space for details.
The fifth section starls with the word "Witness" followed by a blank for a printed name and a blank for a signature. The sixth section goes
on to provide blanks for the signatures of the reviewing sergeant and thc revierving lieutenarrt.
Affiant has reviewed the specific form used by the LIPD Narcotics division to document the required authorization, entitled "Request for
C.l. Payment/Expense Authorization" form. The form has four sections. l'he flrst section includes the requesting officer's narne, payroll
number and squad number, and the date of thc incident and incident nutnber. The second section has a heading reading, "C.1. Payment
Request," with space forthe "amountrequested" and forthe signature and date of the required supervisors, includingthe lieutenant. Affiant
has additionally reviewed Special Investigation Cornmand, Narcotics Division, SOP 200,'1.22, rvhich covers "Handling of Confidential
Informants: Recruited or Contract," and includes a section for "Paymcnt of Criminal Informants and Use of Confidential lnforrnant Activity
Sheet/Receipt for Funds forrn." Consistent with SOP 100/2.05 (described above), this section requires that:
"All Narcotics Division personnel will properly document all funds provided to or paid to a Confidential lnforrnant by completing a
'l'he Confidential Informant Activity Sheet/l{eceipt lor FLrnds Form will be
Confidential Informant Activity Sheet/Receipt for Funds Forrn.
completed and signed at the time funds are dispersed to the Confidential Informant. (Ex. Both payments to inf,orrrants and funds provided
to the informant for narcotics purchases are included in this dircctive.)" (emphasis in original)
SOp 200/l .22 further mandates that "AllConfidential luformant Payrnents over $50.00 nrLrst be rvitnessed by a supervisor and a Request for
Confidential Informant Payment form cornpleted." lt further states:
"All payments to a Confidential Informant will be approved throLrgh the oflficer's chain ol-cornmand. Signattrres of approval will be placed
on both the Request for Payrnent and the Confidential Informant Activity Sheet/Receipt for Funds fbrnr. The levels of authorization
-l'he
necessary for approval are outlined in Section l2 oiS.O.P. 200 1.22. requcst lor payrlent r+'ill bc put in synopsis form detailing the
Confidential Informant's involvernent, degree of risk, the amount of narcotics and rnoney seized, thc number of suspects arrested and
charged, as well as the amount the officer wishes to pay the Confidential lnfortnant. No Confidential lnformant payment over $1,000.00
will be rnade unless laboratory analysis has been conducted and the quantity (weight) olthe seized contraband has been determined. Any
false/positive field test determined by laboratory analysis will be brought to the Case Agent's Lieutenant's attcntion for furlher review. A
supplement of the laboratory analysis must be included in the olfense rcporl and attached to the Confidential lnforrnant payment request
foim. No payment will be made without the Narcotics Division Comrnandcr's approval ilthe contraband is deterrnined to be sirnulated
substance. After approval is granted and payment is made, the Request lor Payrncnt Form and thc Confidential Informant Activity
Sheet/Receipt for Funds form will be attached to the officer's expcnse lctter and lorwardcd through his/her chain of Cornmand." (ernphasis
in original)
SOp 200/l .22 goes on to give the example that a "Licutenant must approve and sign payntcnts frour S251.00 to $2500.00." (ernphasis in
original) This is furlher st;red in Section l2 oISOP 2OOll.22 (referenced above), titled "Confidential Informant Fund Expenditures-Lirnits
of Authorization,,,which in relevant parl mandates that "[p]urchases rcqLriring amounts larger than $125.00 nlust have prior squad
supervisor approval," that "[a] squad supervisor may authorizc a maxin.ruur ol$250.00 for ttndcrcover br,rys and a maximum of $250.00 lor
payment of bonfidential Inftrmants," and that "[a] Narcotics Division [-icutenant rnay authorize art expenditure of ttp to $2500.00."
Affiant has reviewed HpD offense reports, Confidcntial lnfonnant Activity Shcct/Reccipt lor FLrnds lorrns, l(cquest for Paymcnt forttts, and
Case#16808941 CRT#228
accornpanying documentation for multiple tlPD Narcotics Division transactions from 20 l4 to 20 I8. Afflant has learned through this review
that the defendant acted contrary to the G.O.s and SOPs described above on multiple occasions, rcsulting in thousands of dollars of llPD
funds being disbursed without proper authorization or verification,
Specifically, Affiant reviewed the above-described docurnentation for IIPD incident number 029514918. Alfiant found the case agent for
this incident to be Bryant. Affiant reviewed the Request lor Payrnent Fonr for this incident, in which Bryant stated that he made a buy and
executed a subsequent search warrant at the location, and that he was requesting to pay the C.l. for this incident $ 1,300 for their assistance.
AffiantobservedthedefendantsignedthisrequestonMarch 19,20l8.AffiantreviewedthecorrespondingC.l.ActivitySheet/Receiptfor
Funds form and observed that Bryant documented paying this C.l. $ 1,300 lor "inforrnation or assistance" on March 21, 20 18, for target
location 8633 West Airport Boulevard. Affiant additionally reviewed the Houston Forensic Science Center laboratory analysis report for
this incident. This lab report is dated March 27,2018.
Pursuant to the above-described G.O.s and SOPs, no payment over $1,000 is to be made untilthe laboratory analysis has been completed,
and the lab repoft showing the results of said analysis is to be attached to the Request for Payrnent fortn. Because the lab report for this
incident was not issued until eight (8) days after the defendant authorized this pay'ment, no lab report could have been attached to the
Request for Payment form, as required by SOP 200 1.22. Because no lab reporl was issued until six (6) days after Bryant disbursed S1,300
to the C.l. for this incident, the defendant failed to veriI the type and quantity of the substances allegedly recovered beFore HPD funds were
spent for this transaction, in violation of SOP 2001 | .22. W ithout said vcrification, any d isburscment of H PD funds posed a substantial risk
ofsaid funds, in this instance $1,300, being spent on the recovery ofsimulated, rather than illegal, substances, contrary to the policies and
orders of HPD. Additionally, because the defendant failed to revieu'the lab results prior to the funds being spent, the defendant risked the
over-expenditure of HPD funds where the quantity of the alleged substance recovered might be less than the atnount alleged by the
requesting case agent, contrary to the policies and orders of HPD.
Affiant additionally reviewed the above-described documentation for HPD incident nutnber 55888917. Affiant lound the case agent for this
incidentto be HPD Narcotics Officer Felipe Gallegos (Gallegos). Alfiant reviewed the Request for Payrnent l]orm forthis incident, in which
Gallegos stated that he made a buy and executed asubsequent search warrant at 5523 Elm Larvn, and that he was requesting to pay the C.l.
$1,100 for this incident. Affiant observed that the defendant signed this request on June 8, 2017. Affiant reviewed the conesponding C.l.
Activity Sheet/Receipt for Funds form and observed that Gallegos documented paying this C.l. Sl,l00 for "inlormation or assistance" on
May 18,2017. Affiant additionally reviewed the Houston Forensic Sciencc Center laboratory analysis reporl lor this incident.'fhis lab
report is dated June 12,2011.
Pursuant to the above-described G.O.s and SOPs, "Ip]urchases requit'ing arnounts Iarger than $125.00 must have prior squad supervisor
approval," and any expenditure over $250 up to $2500 required the prior authorization of thc Narcotics Division Lieutenant, in this case, the
defendant. Because the defendant signed the Request for Payrnent approximate ly twenty (20) days after the payrnent of $1,100 was made to
the C.1., the defendant failed to authorize the disbursement of those funds in accordance rvith the G.O.s and SOPs. Additionally, because the
lab reporl for this incident was not issued until four (4) days after the defendant authorizcd this payment, no lab report could have been
attached to the Request for Payment form, as required by SOP 20011.22. Because no lab repoft was issued untilnearly a month after
Gallegos disbursed $1,100 to the C.l. forthis incident, the defendant failed to verify the type and quantity of the substances allcgedly
recovered before HPD funds were spent for this transaction, in violation of SOP 200 1.22. Without said verification, and without proper
authorization, any disbursement ofHPD funds posed a substantial risk ofsaid funds, in this instance Sl,l00, being spent on the recovery of
simulated, rather than illegal, substances, contrary to the policies and orders of HPD. Additionalty, because the defendant failed to review
the lab results prior to the funds being spent, the def,endant risked the over-expenditure of IIPD funds where the quantity of the alleged
substance recovered might be less than the amount alleged by the requesting case agent, contrary to the policies and orders of HPD.
Affiant additionally reviewed the above-described documentation for HPD incident nutnbcr 09113|r1 11 . Atfiant found the case agent for
this incident to be Goines. Affiant reviewed the Request for Payment Fornr for this incident, in which Goines stated that he executed a
search warrantat65l4 Depriest, and that he was requesting to pay the C.l. S1,500 lor this incident Affiant noted that Goines stated in his
Request for payment Form that the "confidential inlorrnant was paid thc anrount of $1,500 on 08/03/20l7." Alfiant observed that the
defendant signed this request on September 14,2017. Affiant reviewed thc con'esponding C.l. Activity Shcct/l{eceipt for Furrds form and
observedthatGoines documentedpayingthisC.l.$l,500for"inlormationorassistancc"onAugust3,20lT.Alfiantadditionallyt'eviewed
the Houston Forensic Science Center laboratory analysis report for this irrcident. This lab rcport is dated Scpternber 6,2017.
Because the defendant signed the Request for Payment over one month alter the payrnent ol$1,500 was tnade to the C.I., thc delendant
failed to properly authoriie the disbursement of those funds in accordancc with the G.O.s and SOPs. Additionally, because thc lab report for
this incidint was issued over a month after Goines disbursed $ 1,500 to the C.l. for this inciderrt, no lab report could have been attached to
the Request for payment form, and thus the defendant failed to verily thc typc and quantity ofthe substances allegedly recovered before
HpD funds were spent forthis transaction, in violation of SOP 2OOll.22. Without said verification, and without proper authorization, any
disbursement of HpD funds posed a substantial risk oIsaid funds, in this instance S1,500, bcing spent on the recovery of simulated,
rather
delendant lailed to review thc lab results prior
than illegal, substances, contrary to the policies and orders of I'lPD. Additionally, becausc the
to the funds being spent, the deiendant iiskea the over-cxpenditure oillPD funds rvherc thc cluantity olthc allcged substance recovered
Case#15808941 CRT#228
ntight be less than the arnount alleged by the requcsting case agcnt, contrary to thc policies and ordcrs olllPD.
Affiant additionally reviewed the above-describcd documentation fbr IIPD incident nurnbcr 151924416. Affiant found the case agent for
this incident to be Bryant. Alfiant reviewed the Request for Payrnent Fornr lor this incident, in lvhich Bryant statcd that he executed a search
warrant for the location, and that he was requesting to pay the C.l. $2,400 lor this incideut. Affiant observed that the de lendant signed this
request on December 12,2016. Affiant reviewed the corresponding C.l. Activity Sheet/Rcceipt fbr Funds lorrn and observed that Bryant
documented paying this C.l. 52,400 for "inForrnation or assistancc" on Dcccmbcr 14,20 16, lor targct location 5201 Market Street. Affiant
additionally reviewed the Houston F'orensic Science Center laboratory'analysis reporl fbrthis incidcnt.'l'his lab repoft is dated January 5,
2017.
Because the lab report for this incident was issued over twenty (20) days alter the defendant authorized this payrnent, no lab report could
have been attached to the Request for Payment form, as required by SOP 20011.22. Because no lab repoft was issued until approximately
twenty (20) days after Bryant disbursed 52,400 to the C.l. lor this incident, the defendant failed to verify thc type and quantity of the
substances allegedly recovered before HPD funds were spent forthis transaction, in violation oISOP 20011.22. Without said verification,
any disbursement of HPD funds posed a substantial risk of said funds, in this instance $2,400, being spent on the recovery of simulated,
rather than illegal, substances, contrary to the policies and orders of HPD. Additionally, because the defendant failed to review the lab
results prior to the funds being spent, the defendant risked the over-expenditure offlPD funds where the quantity ofthe alleged substance
recovered might be less than the amount alleged by the requesting case agent, contrary to the policies and orders of HPD.
Affiant has reviewed Texas Penal Code Section 32.45, "Misapplication of Fiduciary Properly," under which a person commits an offense if
he intentionally, knowingly, or recklessly misapplies property he holds as a fiduciary in a manner that involves substantial risk of loss to the
owner of the properly or to a person for whose benefit the property is held. Under this section, "Fiduciary" includes an administrator, any
person acting in a fiduciary capacity, and any officer, manager, employee, or agent canying on fiduciary functions on behalf of a fiduciary.
Under this section, "Misapply" means "deal with property contrary to an agreement under which the fiduciary holds the property." An
offense committed under this section is a state jail felony if the value olthe property misapplied is $2,500 or more but less than $30,000.
Affiant has reviewed Texas Penal Code Section 32.03 and knows that when amounts are obtained in violation of Chapter 32 (Fraud)
pursuant to one scheme or continuing course ofconduct, whether from the same or several sources, the conduct may be considered as one
For all of the reasons listed above, Affiant has reason to believe and does believe that the defendant, former HPD Lieutenant Robert
Gonzales, committed the state jail felony offense of aggregate misapplication of fiduciary property on or about December 12,2016 and
continuing through March I 9, 20 1 8, by know ingly, intentionally, and recklessly dealing w ith $6,3 00 (the total value o f, the amounts detailed
above), which was owned by HPD and being held by the defendant for the benefit of HPD, whilc he was employed as an administrator,
officer, manager, employee, and agent of HPD, in a manner that involved substantial risk of loss to HPD by repeatedly failing to verif, and
properly authorize the expenditure of HPD funds to confidential infonnants prior to HPD Narcotics officers releasing said funds to said
confidential informants, in violation of the General Orders and accornpanying Standard Operating Procedures of the FIPD.
Signed and sworn by me on z//zo Duly attested by rne on () C,I

/o ><)
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AFFIANT ASSISl' N1'DISTRIC'f ATTORNEY

OF IIARRIS COUNTY,'I'EXAS
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REPORT: DfM601 JUSTICE INFORIiIATION
DArE:
MANAGEMENT SYSTtrM TIME: 4:26
07 / At/ 20 D. A., I.NTAKE MANAGEMENT SYSTEM
TRANSACTION # 2653 09'7 D. A. LOG #: 2653097

IN CUSTODY, .,. N CARINDICATOR ID BY PRINTS:
sPN #.........:
AF]S NUMBER... :
DEFENDANT NAME: A1IMSTRONG, HODGIE

ALIAS NAME.,..:
ALIAS SPN.. ... :
US CITIZEN Y INS#
ALLTEN STATUS : ]LLEGAL CODE:
RACE..........: B SEX: M DOB: 0B/29/1965
MARITAL STATUS: BUILD: HEV HEIGHT: 511 WEIGHT: 259
HAIR.. ..: BLK SKIN: DRK EYES: BRO
qr-lD a

CELL OPT-IN: EMAIL OPT-IN:
PRIOR ARREST?: N FBI#: STATE ID #:
AGENCY ID#..: DAO SSN: so# :
ALIAS SPN(S) . :
DL#....... ..: 10725254 DL ST: TX
Co-DEFENDANTS? 6-
DOES THE DEFENDANT }IAVE
PRTNTED
A SPN? Y
| 07 / 0t / 2020 04 :25 ( CASS rDy, JAMES
6 M DIM5 O 1
)
THE STATE OF TEXAS 030s9897 D.A. LOG NUMBER: 26531,t3
VS. CJIS TRACKING NO
ROBERT GONZALES SPN: BY: EH DA NO: 242
TRAVIS
I2OO DOB: W M7lt3lt960 AGENCY:DAO a
\J
HOUSTON, TX 77004 DATE PREPARED: 1 ll12020 OiR NO: S1907 a
C\J
5
ARREST DATE TO c l
tJ a
S
NCIC CODE:2699 78 RIILATtlD CASES -J !l
FELONY CHARGE: MISAPPLICATION .-)
CAUSE NO: COURl'ORDERED IIAIL: TO BE S Et T

HARRIS COUNTY DISTRICT COURT NO 1680894 MAGISTRATION
228
CIiARGII SEQ NUM: I
that he has good reason to believe and does believe that in Harris Counfy, l'exas, ROBERT GONZALES, hereafter styled the Deflendant,
heretofore on or about Dccember 12,2016 continuing through March 19,2018, did then and there unlawfully, while a fiduciary, namely,
while an administrator, and while a person acting in a fiduciary capacity, and while an officer, manager, employee, and agent carrying on
fiduciary functions on behalf of a fiduciary, knowingly, intentionally, and recklessly misapply propefty, namely money,of the value of at
least two thousand five hundred dollars but less than thirty thousand dollars by dealing with said propefiy contrary to an agreement under
which the Defendant held the properly and in a manner that involved substantial risk of loss to the llouston Police Department, the owner of
said property and the person for whose benefit the properry was held, to wit: by repeatedly lailing to verifo and authorize the payment of
Houston Police Department funds to confidential informants priorto Houston Police Deparlrnent Narcotics officers releasing said funds to
said confidential informants in violation of the General Orders and accornpanying Standard Operating Procedures of the []ouston Police
Department.
Probable Cause
Af,fiant, Lieutenant Billy Milan, is a cerlified peace officer employed by thc ttarris County District Attorney's Oftlce (l-tCDAO) and
assigned to the Civil Itights Division. Affiant has probable cause to believe and docs believe that lormer Houston Police Deparlment (HPD)
Lieutenant Robert Gonzales, hereinafter defendant, did comrnit the state jail felony olfense of aggregate misapplication olfiduciary property
on or about December 12,2016 through March 19,2018 in llouston, Ilarris County, Texas.
Affiant bases this belief on the following
On January 15,2020, fonner HPD Narcotics Officers Gerald Goines (Goines) and Stevcn Bryant (Bryant) were indicted for Tampering with
a Governmental Record, see Harris County Cause Nos. 1660764 and 1643521, respcctively. These charges centcr on falsc statements sworn
to by Goines in obtaining a narcotics search warrant for a residcnce located at 78.l5 Halding Street and false statements made in the
corresponding offense report by Bryant. Execution of that scarch warant led to the death of both homeowners, injury to lour HPD officers,
and thereafter an HPD investigation into Goines' use of confidential inforrnants (C.l.s) to obtain search warrants.
Affiant is aware of and has reviewed HPD General Order (C O.) # 100-07 covering "Standard Operating Procedures" (SOPs). C.O. # 100-07
mandates that "standard Operating Procedures (SOPs) shall be lollowed by all commands, divisions, offices and units perforrning like tasks
and functions in order to ensure uniformity of police services." It further states that "all employees arc responsible for knowing,
understanding, and following the SOPs applicable to their assignment" and that G.O. #100-07 "applies to all ernployees." G.O, #100-07
additionally mandates that "each employee shall read the current SOPs applicable to the employee's assignntent," that "Ii]f after reading the
applicable SOPs an employee has any issues, concerns, or questions, thc employee shall meet with his supervisor to address these matters,"
and that "[e]ach employee shall sign an Acknowledgment olReceipt and Review olStandard Opcrating Procedures fonn." Affiant has
reviewed HPD personnel records for the defendant and observed that the defendant signcd an Acknowledgement ofReceipt ofGeneral
OrdersforG.O.#100-07onbothJanuary13,2012andMayl3,20l9,andforC.O.#600-l6onbothDecetnberl,20l0andMarch30,
201 5.
Affiant is additionally aware oland has revicwed IIPD Gencral Order (G.O.) #600-16 covering "Conlldential [nlorrnants and Other Sources
of Information," which holds that "a supervisor's authorization is nccessary for thc disburselnent of any CI lunds" and shall be docLrmented.
The order furlher states that a sergcant nray approve up to and including $250. A Lieutcnant rnay approve up to $2500. C.O. #600- l6 further
case#15808941 CRT#228
requires that a "Confidential Informant Receipt for Funds" lorrn be cornpleted, including the amount of the payrnent, the date on which tlre
paymentwasmade,andasignatureofthe"first-lincsupervisorwitnessingthe payrnentifthepayrnentexceeds$50." G.O.#600-16
additionally requires that "each division using confidential informants shall develop and adhere to standard operating procedures (SOPs)
specific to that division's use of confidential informant funds."
Affiant has reviewed the Special Investigation Cornmand, Narcotics Division, Standard Operating Procedures (SOP), spccifically SOP
100/1.03, titled "Narcotics Division lnvestigative Lieutenant." Pursuantto this SOP, the Narcotics Division Investigative Lieutenant is
responsible for a number of duties, including to "supervise daily operations of the squad ensuring conformance with departmental policies
and procedures" and "to approve the expenditure oflunds." Affiant has revierved HPD personnel records lorthe defendant and observed
thatheservedasaNarcoticsDivisionlnvestigativel,ieutenantduringtheyearsof20l4through20 18. AlfianthasalsoreviewedSpecial
Investigation Command, Narcotics Division, SOP 100/2.05, rvhich covers "Confidential Inforrnant Funds/Expense Letters, Limits of
Authorization and Use of Flash Money," and includes a section on "CI Payments & Receipt for Funds Form." That section repeats the
requirements of GO 600-16 and also specifically states, "The CI Receipt for Funds lorrn will be cornpleted atthe time of the payrnentto the
CI" (emphasis in original). Regarding authorization for expenditures over a ceftain arnoLrnt, SOP 100/2.05 tnandates that purchases
requiring amounts over $125.00 up to $250.00 rnust have prior approval by a Squad Supcrvisor, w'hereas a Narcotics Division Lieutenant
may authorize an expenditure of over $250.00 up to $2,500.00.
Affiant has reviewed the specific C.l. Form used by the HPD Narcotics Division, titled "C.1. Activity Sheet / Receipt for Funds Form" and
has found that, consistent with SOP 100/2.05, the form has six sections. 'fhe first section includcs C.l. name, date, time, location, OR
number, and blanks for up to two drug types and the corresponding weight. 'l'he sccond scction is for an arnount paid to the C.l. lor
information and assistance and includes blanks flor the arnount paid and the C.l.'s signaturc. The third section is for an amount provided to
-l-he
the C.l. to purchase narcotics and includes blanks forthe anrount paid and the C.l.'s initials. fourth scction provides a space lor details,
The fifth section starts with the word "Witness" followed by a blank lor a printed narne and a blank for a signature. The sixth section goes
on to provide blanks for the signatures of the reviewing sergeant and the reviewing lieutenant.
Affiant has reviewed the specific form used by the HPD Narcotics division to docLtment the reqLrired authorization, entitled "Request for
C.l. Payment/Expense Authorization" form. The lorm has four sections. l'hc fir'st section includcs the requesting officer's name, payroll
number and squad number, and the date of the incident and incident number. The second section has a heading reading, "C.1. Payment
Request," with space for the "amount requested" and for the signature and date of the required supervisors, including the lieutenant. Affiant
has additionally reviewed Special Investigation Cornmand, Narcotics Division, SOP 200/1.22, rvhich covers "Handling of Confidential
Informants: Recruited or Contract," and includes a section for "Paytnent of Crirninal Inlormants and Use of Confidential Informant Activity
Sheet/Receipt for Funds fonrr." Consistent with SOP 10012.05 (described above), this section requires that:
"All Narcotics Division personnel will properly document all funds provided to or paid to a Confidential Informant by completing a
Confidential lnformant Activity Sheet/Receipt for Funds Forrn. The Confidential lnlormant Activity Shect/Receipt for Funds Form will be
completed and signed at the time funds are dispersed to the Confidential Informant. (Ex. Both payments to inforrnants and funds provided
to the informant for narcotics purchases are included in this directive.)" (emphasis in original)
SOP 200/l .22 further mandates that "All Confidential Informant Payments over $50.00 nrust be rvitnessed by a supervisor and a Request for
Confidential lnformant Payment form completed." lt further states:
"Allpayments to a Confidential Inforrnant will be approved through the ofltlcer's chain of cotnntand. Signatures of approval will be placed
-l'he
on both the Request for Payment and the Confidential lnforrnant Activity Sheet/Receipl for FLrnds form. levels of authorization
pecessary for approval are outlined in Section l2 of S.O.P. 20011.22. The request for payrrent rvill be put in synopsis form detailing the
Confidential Informant's involvement, degree of risk, the arrount of narcotics and rnoney seized, thc number of suspects arrested and
charged, as well as the amount the officer wishes to pay the Confidential Inforrnant. No Confidential lnlormant payment over $1,000.00
will be made unless laboratory analysis has been conducted and the quantity (weight) olthe seizcd contraband has been determined. Any
false/positive field test determined by laboratory analysis will be brought to the Case Agent's Lierttenant's attention for further review. A
supplement of the laboratory analysis must be included in the offense reporl and attached to thc
(-'onfidcntial Infortnant payment request
form. No payment will be made without the Narcotics Division Cornmandcr's approval if the contraband is deterrnined to be sirnulated
substance. After approval is granted and paynrent is made, the Request for Paynrent Fornr and thc Confidcntial Informant Activity
Sheet/Receipt for Funds form will be altached to the officer's expense letter and forrvarded through his/hcr chain of Comtnand." (ernphasis
in original)
SOp 200/l .22 goes on to give the example that a "t,icutenant rnust approvc and sign paymcnts frorn S25 1.00 to $2500.00." (ernphasis in
original) This ii furlher stated in Section l2 of SOP 2OOll.22 (referenced above), titlcd "Confidential Inlormant Irund Expcnditures-Limits
of Authorization," which in relevant paft ntandates that "[p]urchases requiring amounts larger than $125.00 must have prior squad
supervisor approval," that "[a] squad supervisor rrray authorize a maxirnutn of 5250.00 lor undercover buys and a rnaximum of S250.00 for
payment of bonfidential Informants," and that "Ia] Narcotics Division Lieutenant rnay aLtthorize art expcnditure of up to $2500.00.'
Affiant has reviewed HpD offense repofts, Confidcntial Inlorrnant Activity Shectr'l(eccipt lor l"unds forrns, Reqr.rcst lor Payment forms, and
Case#16808941 CRT#228
accornpanying docunrentation for multiple HPD Narcotics Division transactions fi'orn 20 l4 to 2018. Alfiant has learned through this review
thatthe delendant acted contrary to the C.O.s and SOPs described above on multiple occasions, resLrlting in thousands of dollars of HPD
funds being disbursed without proper authorization or verification.
Specifically, Affiant reviewed the above-described documentation for I{PD incident nunrber 029514918. Atflant found the case agent for
this incident to be Bryant. Affiant reviewed the Request lor Payrnent Forrn for this incident, in rvhich Bryant stated that he made a buy and
executed a subsequent search warrant at the location, and that he was requesting to pay the C.l. for this incident $ 1,300 for their assistance.
Affiant observed the defendant signed this request on March 19,2018. Affiant leviewed the corresponding C.l. Activity Sheet/Receipt for
Funds form and observed that Bryant documented paying this C.l. $1,300 for "information or assistance" on March 21,20 18, fortarget
location 8633 WestAirport Boulevard. Affiantadditionally reviewed the Houston Forensic Science Center laboratory analysis report for
this incident. This lab report is dated March 27 ,2018.
Pursuant to the above-described G.O.s and SOPs, no payment over $ 1,000 is to be made until the laboratory analysis has been completed,
and the lab report showing the results of said analysis is to be attached to the Request for Payment forrn. Because the lab report for this
incident was not issued until eight (8) days after the defendant authorized this payment, no lab reporl could have been attached to the
Request for Payment form, as required by SOP 20011.22. Because no lab report was issued untilsix (6) days after Bryant disbursed S1,300
to the C.I. for this incident, the defendant failed to veri$, the type and quantity of the substances allegedly recovered before HPD funds were
spent for this transaction, in violation of SOP 20011.22. Without said verification, any disbursement of IIPD funds posed a substantial risk
of said funds, in this instance $ 1,300, being spent on the recovery of simulated, rather than illegal, substances, contrary to the policies and
orders of HPD. Additionally, because the defendant failed to review the lab results prior to the funds be ing spent, the defendant risked the
over-expenditr-rre of HPD funds where the quantity olthe alleged substance recovered rnight be less than the amount alleged by the
requesting case agent, contrary to the policies and orders of HPD.
Affiant additionally reviewed the above-described documentation for IIPD incident nurnber 55888917. Affiant found the case agent for this
incident to be HPD Narcotics Officer Felipe Gallegos (Gallegos). Affiant revierved the Request for Payrnent Forrn for this incident, in which
Gallegos stated that he made a buy and executed a subsequcnt search warrant at 5523 Elm [,awn, and that he was requesting to pay the C.l.
$1,100 forthis incident. Affiant observed that the defendant signed this request on June 8,20l.7. Alfiant revierved the corresponding C.l.
Activity Sheet/Receipt for Funds forrn and observed that Gallegos documented paying this C.l. $1,100 flor "information or assistance" on
-l-his
May 18,2017. Affiantadditionally reviewed the Houston Forensic Science Center laboratory analysis report forthis incident. lab
repoft is dated June 12,2011.
Pursuant to the above-described G.O.s and SOPs, "Ip]urchases requiring arnounts larger than S125.00 must have prior squad supervisor
approval," and any expenditure over $250 up to $2500 required the prior authorization of the Narcotics Division Lieutenant, in this case, the
defendant. Because the defendant signed the Request for Payment approximately twenty (20) days afler the payment ol$1,100 was made to
the C.1., the defendant failed to authorize the disbursement of those lunds in accordance with the G.O.s and SOPs. Additionally, because the
lab report for this incident was not issued until foLrr (4) days aftcr the defendant authorized this payment, no lab report could have been
attached to the Request for Payment form, as required by SOP 200 1.22. Because no lab report was issued until nearly a month after
Gallegos disbursed $1,100 to the C.l. forthis incident, the defendant failed to verify the type and quantity of the substances allegedly
recovered before HPD funds were spent for this transaction, in violation of SOP 20011.22. Without said verification, and without proper
authorization, any disbursement ofllPD funds posed a substantial risk ofsaid funds, in this instance $1,100, being spent on the recovery of
simulated, ratherthan illegal, substances, contrary to the policies and orders of IIPD. Additionally, because the defendant failed to review
the lab results priorto the funds being spent, the defendant risked the over-expenditure of HPD funds where the quantity of the alleged
substance recovered might be less than the amount alleged by the requesting case agent, contrary to the policies and orders of tlPD.
Affiant additionally reviewed the above-described docurnentation for HPD incident nurnber 0941311 l7 Affiant foLrnd the case agent for
this incident to be Goines. Affiant reviewed the Request for Payrnent Fornr for this incident, in which Coines stated that he executed a
search warrantat6514 Depriest, and that he was requesting to pay the C.l. $1,500 for this incident. Alfiant noted that Goines stated in his
Request for Payment Forrn that the "confidential informant was paid the anrou nt o I $ I ,5 00 on 0 8/03/20 I 7." A lfia nt observed that the
defendant signed this request on September 14,2017. Affiant reviewcd thc corresponding C.l. Activity Shcet/Receipt for Funds form and
observedthatGoines documentedpayingthisC.l.$l,500for"inforrnationorassistancc"onAugtrst3,20ll .Alfiantadditionallyreviewed
the Houston Forensic Science Center laboratory analysis repofl lorthis incident. This lab rcpot't is dated Scpternber6,20 17.
Because the defcndant signed l.he Request for Payment over one month aftcr the payment of S 1,500 r.vas tnade to the C.I., the defendant
failed to properly authorizc the disbursentent of those lunds in accordancc rvith the G.O.s and SOI'}s. Additionally, becausc the lab rcport for
thisincidentwasissuedoveramonthafterGoinesdisbursedSl,500totheC.l. lorthisincident,nolabreportcouldhavebeenattachedto
the Request for Payment form, and thus the defendant failed to verify thc typc and quantity olthe substances allegedly recovered before
IIPD funds were spent for this transaction, in violation of SOP 20011.22. Wilhout said vcrification, and rvilhout proper authorization, any
disbursement of HPD funds posed a substantial risk of said lunds, in this instance $1,500, bcing spcnt on the recovery of simulated, rather
than itlegal, substances, contrary to the policies and orders olI'lPD. Additionally, bccause thc delcndant failed to review the lab results prior
to the funds being spent, the defendant risked the over-cxpcnditure ofllPD funds rvherc the cluantity ofthe allcged substance rccovered
case#15808941 CRT#228
might be less than the amount alleged by the requesting case agent, contrary to the policies and orders of IIPD.
Affiant additionally reviewed the above-described documentation for IJPD incident number 154924416. Affiant found the case agent lor
this incident to be Bryant. Affiant reviewed the Request for Payrnent Form for this incident, in which Bryant stated that he executed a search
warrant for the location, and that he was requesting to pay the C.l. 52,400 for this incident. Affiant obscrved that the defendant signed this
request on December 12,2016. Affiant reviewed the corresponding C.l. Activity Sheet/Receipt lor F'unds lorrn and observed that Bryant
documented paying this C.l. $2,400 for "information or assistance" on Deccmber 14, 2016, for targct location 520 I Market Street. Affiant
additionally reviewed the Houston Forensic Science Center laboratory analysis repoft lor this incident. 'l'his lab rcport is dated January 5,
2017.
Because the lab report for this incident was issued over twenty (20) days after the defendant authoriz-ed this payment, no lab report could
have been attached to the Request for Payment form, as required by SOP 20011.22. Because no lab rcport was issued until approximatcly
twenty (20) days after Bryant disbursed $2,400 to the C.l. for this incident, thc defendant failed to verily the type and quantity of the
substances allegedly recovered before IIPD funds were spent for this transaction, in violation of SOP 20011.22. Without said verification,
any disbursement of HPD funds posed a substantial risk of said firnds, in this instance $2,400, bcing spcnt on the recovery of simulated,
rather than illegal, substances, contrary to the policies and orders of HPD. Additionally, becaLtse the defendant failed to review the lab
results prior to the funds being spent, the defendant risked the over-expenditure of HPD funds wherc the quantity ofthe alleged substance
recovered might be less than the amor.rnt alleged by the requesting casc agent, contrary to the policies and orders of IIPD.
Affiant has reviewed Texas Penal Code Section 32.45, "Misapplication of Fiduciary Property," under rvhich a person commits an offense if
he intentionally, knowingly, or recklessly misapplies propefty he holds as a fiduciary in a manner that involves substantial risk of loss to the
owner of the properry or to a person for whose benefit the propefty is held. Under this section, "Fiduciary" includes an administrator, any
person acting in a fiduciary capacity, and any officer, rnanager, etnployee, or agent carrying on fiduciary lunctions on behalfofa fiduciary.
Under this section, "Misapply" means "deal with properly contrary to an agreernent under which thc fiduciary holds the property." An
offense committed under this section is a state jail felony if the value of the properfy misapplied is $2,500 ol more but less than $30,000.
Affiant has reviewed Texas Penal Code Section 32.03 and knows that when amounts are obtaincd in violation of Chapter 32 (Fraud)
pursuant to one scheme or continuing course ofconduct, whether from the same or several sources, thc conduct may be considered as one
offense and the amounts aggregated in determining the grade of olfense.
For all of the reasons listed above, Affiant has reason to believe and does believe that the de fendant, lortner HPD Lieutenant Roberl
Gonzales, committed the state jail felony oflense of aggregate misapplication of fiduciary propeny on or about December 12,2016 and
continuingthrough March 19,20 18, by knowingly, intentionally, and recklcssly dealing with $6,300 (the total value of the anrounts detailed
above), *hi.h *ar owned by HPD and being held by the defendant for the benefit of HPD, whilc he r,vas enrployed as an administrator,
officer, manager, employee, and agent of HPD, in a manner that involved substantial risk of loss to HPD by repeatedly failing to verify and
properly authorize the expenditure of HPD lunds to confidential informants prior to HPD Narcotics olflcers releasing said funds to said
tonfidential informants, in violation of the General Orders and accotnpanying Standard Operating Procedures of the HPD.
AGAINST THE PEACE AND DIGNITY OF THE STATE
Signed and sworn by me on Duly attested by nre on CI' ol /n ><)

\
(.,
AFFIANT ASSISl' NI- D]S1'RIC'I A]'TORNEY

OF HARR IS COUN'I-Y.'I-EXAS
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JULY 1 2O2O ._?
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JUDGE KELLI JOH
',)!.1
! ai':.!-'l;ED
i l.iril lri': iiill I)l .;-r Li, ;l i
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CaPi tLs
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f:hcriti-s De,pt
War:'r't ,. L,l"istoill
DArE: 07 / 0t/20 D.A. .INTAKE MANAGEMENT SYSTEM
. , DEFENDANT DESCRIPTORS
TRANSACTION # : 2653143 D.A. LOG #: 2553143

IN CUSTODY.. ..: N CARINDICATOR: ID BY PRINTS:
SPN #.
AFIS NI'MBER. . .
DEFENDANT NAME GONZALES, ROBERT

ALIAS NAME....
ALIAS SPN... ..
US CITIZEN INS #
DA'tr SEX:
W M DOB: 0t/L3/1960
MARITAL STATUS: BU]LD: HEV HEIGHT: 511
HATD
WEIGHT:230
WHI SKIN: LGT EYES: BRO
scARs. . .....:
STREET ADDRESS: 1200 TRAVTS
crTY......... : HOUSTON, TX ZIP:
PHONE... ... .: () CELL: EMAIL:
PRIOR ARREST? :N FBI#: STATE ID#
AGENCY ]D#. . : DAO cclr,
so#
ALIAS SPN(S) .
DL#. . . : 03152467 DL ST: TX
CO-DEFENDANTS? 6
DOES THE DEFENJANT HAVE
PRINTED: 07/0t/2020
A
05:00
SPN? Y
e
(CASSIDY, JAMES M) DIM5O1
u
THE STATE OF TEXAS 03014651 D.A. LOG NUMBER:
VS. CJIS ]'RACKINC NO
STEVEN O. BRYANT SPN:03014651 llY: EH DA NO: 212
TRAVIS
I2OO DOB: B M l2ll8ll973 AGENCY:DAO
HOUSTON, TX77004 DATE PREPARED: 7 ll12020 O/R NO: S1907
ARRtiST DA'l'l::TO
NCIC CODE:480232 REI.ATED CASES:
FELONY CHARGE: TAMPERING GOVERNMENTAL RECORI)
CAUSE NO: COIJR'f ORDIIRED BAIt,: TO BE S E$ AT

HARRIS COUNTY DISI'RICT COURT NO MAGISTRATION
FIRST SETTING DATE:
168q!U'5 PRIOR CAUSE NO:
228 Cl{ARGE SEQ NUM: I
Before me, the undersigned Assistant District Attorney of Hanis County, Texas, this day'appeared the undcrsigned affiant, rvho under oath says
that he has good reason to believe and does believe that in Harris County, Texas, STEVEN O. BRYANT, hereafter sfyled the Defendant,
heretofore on or about January 22,2019, did then and there unlawfully, knowingly tnakc a lalse entry in a governmental record, namely, a
Houston Police Departrnent Narcotics Division C.l. Activity Shcet/Receipt for Funds Forrn, with the intent to defraud or hartn another.
PROBABLE CAUSE
Affiant, Lieutenant Billy Milan, is a cerlified peacc officer enrploycd by the Flaris County District Attorncy's Oifice (llCDAO) and
assigned to the Civil Rights Division. Affiant has probable caLlse to belicve and does bclicve that fortncr llouston Police Departrncnt (HPD)
OfFrcer Steven Bryant, hercinafter defendant, did comrnit the statc jail felony olfense of tarnpering rvith a govcrntrtental record ott or about
January 22,2019, in Houston, Harris County,'fexas. Afflant bascs this belielon thc follorving:
On January 15,2020, fornter HPD Narcotics Olficers Gerald Goincs (Goines) and thc dcf'cndant wcrc ilrdicted for Tampering with a
'l'hcse chalgcs cetltcr on f,alsc statements sworn
Governnrental Record, see parris County Cause Nos. it660164 and 1643521 , respcctivcly.
to by Goines in obtaining a narcotics search warrant for a residcncc located at 7815 Ilarding Street and lalse staterrlents rnadc in the
conispondingoffensereporrbythedefendant. llxecutionofthatscarchwan'antlcdtothcdeathofbothhotrcowncrs,injLrrytolourtlPD
officeis, and ihereafter an IIpD investigation into Goines' and Blyant's use of confidcntial infbrmants (C.l.s) to obtain search warrants.
Ca self 1 5808 95 | CRT #228
AffiantisawareofandhasreviewedHPDGeneral Order600-16(GO)whichgovernsC.l.sandpaynrentstoC.l.s.
TheGOholdsthat,,all
rneetings between a C'1. and an officer shall be attended by trvo officers." 'fhiiregulation requires
that that at least two officers be present
when a controlled buy is conducted. It further tnandates that "officers shall not paly a confidcntial inlormant
without the appropriate witness
present'" ]'he GO goes on to dictate how payrnents to C.l.s will be documented, stating that all payrnents
to C.l.s,,shall be fuliy
documented on a division's'Confidential Infonnant Receipt lor Irunds fonn"'(C.1. F-onn) witlr l'control
inlorrnation,'to include the
signature of the C.l' as an agreement that the payrnent r.vas received, the signature of the investigator
rnaking the payrnent, the signature of at
least one other officer witnessing the payment, and the date olthe payment. l-hese lbrrns, as diitated
by the Go, require that at least three
people - the C'1., the investigator, and a witness be together in one place in order lor a payrncnt
- to occur. Affiant has reviewed nurnerous
HPD C'l' Forms and has noted that these forms also include the time of the paynrent and'thc associated OR nurnber
for the OR wherein the
Affiant has also reviewed the Special Investigation Cornmand, Narcotics Division, Standard Operating procedures
(SOp). SOp 100/2.05
covers "Confidential Informant Funds/Expense Lefters, Limits olAuthorization and Use olplash tvtonel,"
and includes a scction on.,CI
Payments & Receipt for Funds Form." That section repeats the requirements of CO 600-16 and also
sjecifically states,.,The CI Receipt
for Funds form will be completed at the time of the payrnent to the CI" (emphasis in original). AiSanthas reviewed
the specific C.l. Form
used by the l-lPD Narcotics Division, titled "C.1. Activity Sheet / Receipt for [:unds Foni." The lorm
has six sections. Thc first section
includes C.l. name. date, time, location, OR number, and blanks for up to trvo drug types and the con-esponding
weight. 'l'he second section
is for an amount paid to the C.l. for inforrnation and assistance and includes blanki foi the arnount paid
and the C.l.'s signature. The third
section is for an amount provided to the C.l. to purchase narcotics and includes blanks for the amount paid
and the C.l.,s initials. The fourth
section provides a space for details. The fifth section starls lvith the rvord "Witncss" followed by a blank
for a pr-inted name and a blank for
a signature' The sixth section goes on to provide blanks for the signatures of the reviewing sergeant
and the reviewing lieutenant.
Affiant reviewed docutnents provided by HPD pursuant to this investigation, including C.t. Forms, expense repofts,
off'ense reports,
overtimerequestforms,andexpenseauthorizal.ionforms,andspecificillyall documeitationrelatingto HpDbRnumber0095g44-19.
Affiant observed that in the C.l. Activiry Sheet/Receipt for F'unds Forrn associated with this reporl nurnber, the defendant
signed that he
witnessed former HPD Officer Hodgie Armstrong make a payment to a C.l. on January 22,2019 for
a buy allegedly made a1 4437
Knoxville in Houston, Harris County, Texas. Specifically, Affiant observed that Arrnsirong docurnented in
this forrn that $g0 was provided
to a C'l' in order to purch the C.l. for their uriirtun.. in the investigation. Thc same form was
used to document the pro assistance. The lorrn indicates that this iron.y was "paid and/or
provided" on January 22, to have been 20:00 hours (8:00prn), however a parentiretical reading
"19:30" (7:30prn) is writt signature appears on the forrn in t-he blank provided lor witness.
Affiant additionally observed that Arrnstrong stated in IIPD oR No. 0095844-19 that he and the def-endant conducted
a controlled buy at
4437 Knoxville on January 22,2019, at 6:00prn ( l8:00 hours).
f
gh
of
yrnent ilocurnented.
t l8:00 hours (as documented in the offense reporl), Affiant observed
the defendant's cell phone was in use at approximately I 8:06 hours in the area ol I-10 and West 99, rnore than thirly (30) miles from 4437
Knoxville. Inreviewingthedefendant'scell siternappingforJanLrary22,20lgatlg:30hoursand20:00hours(asiocumentedintheC.l.
Activity Sheet / Receipt for Funds Fortn), Affiant observed the defendant's cell phone rvas in use and travelling at approximately lg:24
hours, l8:39 hours, I9:21 hours, and20:24 hours, all in the I{ichrnond, Texas arca,a location Af,fiant lound toLc rnoie than
twenty-five (25)
miles from 4437 Knoxville.
Based on the above information, Affiant has reason to believe that ne ither the allcgcd buy nor the alleged paytnent for said buy took place
as
documented by Armstrong and the defendant, and thus Affiant has reason to believe that thc defendani did not witness any,alleged payment
tothedocumentedC.l.atl8:00hours, l9:30hours,or20;00hoursonJanuary22,20lg,asdocurnentcdbythedelendantlntneC.l.ictivity
Sheet / Receipt for Funds Form. Texas Penal Code Section 37.10, Tampering with a Govcrnnrental Recori, provides that, amongst
other
means, "a person comtnits an offense if he knowingly rnakes a lalse entry in, or lalsc alteration ol, a goverpmental record." Texas penal
Co-de Section 37.01(2) provides that a "Governtnental Record" includes "anythirrg belonging to, receivcd by, or kept by government for
information, including a court record." The C.l. Fonns described above are rcqr,rired by a Ccneral Ordcr to bc com'pleted for all C.l.
payments. They are kept by HPD to docutnent C.l. activity and iuvolvcnlcnt in narcotics irrvestigations. Affiant is aware that IICDAO
has
requested and received from HPD C.l. Irorms dating back rnore than 20 years. III)l) is a subdivision ol'the City ol'llouston, a nrunicipality.
Affiant thereforc believes that the defendant did commit the ollense of'tampcring rvith a govcrnmental record on or about January 22,2019,
in I'louston, Harris County, Texas by knorvingly rnaking a lalse errtry irr a govcrnntcntal rccord, nanrcly a [[ouston Police f)cparlrnent
case#1580895/ CRT#228
Narcotics Division C.l. Activity Sheet/Receipt for Funds Form, and that this oflense was committed with the intent to defraud the Flouston
Police Department.
Signed and sworn by me on Duly attestcd by ,r-,a on 0 ) ot t, 0 >c./
AFFIANl' ASSISTAN-I DISI'RICI' ATTORNEY

OF I]ARRIS COUN-IY, ]'EXAS
narNo />lS)?0O
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Witness Printcd name & Badge or Payroll nutnber
COMPI,AINT
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i
JUDGE KELLI JOH
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Dep t
REPORT: DIM601 JUSTICE INFORMATION .}{ANAGEMENT SYSTEM TIME: 5:32
DArE: 07 / Ot/20 D.A. INTAKE MANAGEMENT SYSTEM
TRANSACTION # 2653255 D.A. LOG #: 2653255

IN CUSTODY.... N CARINDICATOR ID BY PRINTS:
sPN #. 03014551
AFIS NTIMBER, . .
DEFENDANT NAME BRYANT, STEVEN O

ALIAS NAME....
ALIAS SPN,...,
US CITIZEN :Y ]NS#:
ALLTEN STATUS ]LLEGAL CODE:
PLACE OF BIRTH C]TY OF BIRTH:
DA'Ei B SEX: M DoB : 1-2 / tg / L9't 3
MARITAL STATUS BUILD: HEV HEIGHT: 507 WEIGHT: 275
IJA TD : BLK SKIN: DRK EYES: BRO
SCARS .
STREET ADDRESS I 1200 TRAVIS

CITY.. ..: HOUSTON, TX ZIP:
PHONE...... ..: ( ) CELL: EMAIL:
CELL OPT-]N EMAIL OPT- IN
PRIOR ARREST?: Y FBI#: STATE ID #: TXl48]-4222
AGENCY 1D#..: DAO SSN: so# : 2169433
ALIAS SPN(S).:
DL#....... .: DL ST
CO-DEFENDANTS? NO
DOES THE DEFENDANT HAVE A SPN? Y N
PRINTED I O1 /OL/2020 O5:32 (CASSIDY, JAMES M) DIM5O1

t\
THE STATE OF TEXAS
.q
03014649 D.A. LOG NUMBER: 2653130
VS. CJIS TRACKING NO.:
GERALD MICHAEL GOINES SPN: 03014649 BY: EH I)A NO: 242596Pq
I2OO TRAVIS DOB: B M 101211964 ACENCY:DAO q
,E{ U,-
HOUSTON, TX77002 DATE PREPARED: 7 ll12020 O'R NO: 51907 (uI o
f=,-f (::}a ew
ARREST DAl E: TO BEF I f---, o
trU e\J
NCIC CODE: 2399 68 RELATED CASES
FELONY CHARGE: THEFT
CAUSE NO: COURl'ORDERED T

HARRIS COUNTY DISTRICT COURT NO MAGISTRATION
x6801,96
228
CHARGE SEQ NUM: I
Before me, the undersigned Assistant District Attorney of Harris County, Texas, ttis day appeared the undcrsigned affiant, who under oath says
that he has good reason to believe and does believe that in Harris County, Texas, GERALD MICHAEL GOINES , hereafter styled the
Defendant, heretofore on or about April 24, 2018 continuing through December 12,2018, did then and there unlawfully, while a public
servant, namely, aTexas Peace Officer, and pursuant to one scheme and continuing course of conduct, appropriate, by acquiring or
otherwise exercising control over property, namely, ntoney and compensatory time, owned by the tlouston Police Department and the City
of Houston, hereinafter styled the Complainant, of the value of at least two thousand five hundrcd dollars but less than thirly thousand
dollars, with the intent to deprive the Complainant of that properly, and said property carne into the Defendant's custody, possession and
control by virtue ofthe Defendant's status as a public servant.
PROBABLE CAUSE:
Affiant, Investigator Jonathan Prykryl, is a certified peace officer employed by the Ilarris County District Attorney's Office (gCDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to believe and does believe that forrner Houston Police Department (HPD)
Senior Police Officer Gerald Goines, hereinafter the defendant, did commit the third degree felony oflense of theft by a public servant, in an
amount more than twenty-five hundred dollars but less than thirty thousand dollars, on or about April 24,20 18, and continuing through
December 12,2018, in Houston, Harris County, Texas. Affiant bases this belief on thc following:
Affiant
is aware of and has reviewed HPD General Order (G.O.) #300-07, subject "Overtime Cornpensation." It outlines overlirne (OT)
compensation for allclassified employees of HPD who hold the rank of police officcr, senior police officer, or sergeant, or other ernployees
withapaygradeequivalentofsergeantorbelow. Peftinentexcerptsarequotedbelow:
Except as otherwise noted in this General Order, all overtime earned shallbe compensated at the rate of time and a half.
Officers shall have the option of oveftime pay or compensatory time lor overlimc worked, unless thc compensatory time barrk limit would
be exceeded.
At the time ofan officer's separation from the depaftment as a classificd ernployec, all banked compensatory tirne (depending on how it
connected to a tower accrued) shall be administered in accordance with the applicable law or the applicable Meet and Confer Agreetnent.
Officer requesting oveftime cornpensation shall submit the appropriate overlitne request fonn.
Affiant reviewed overtime fonns requested fiom IIPD by HCDAO perlaining to the dclendant lor 20 I8. Affiant observed that the forms are
titled "Houston Police Departrnent Oveftime Request ["orm" (Overlirne Fonn), Alfiant lurther observcd the lorrns to contain four sections.
l'he first section contains the name and employee number of the employee requcsting cornpensation, thc date and hoLn's worked, whether
payorcompensatorytimeisbeingrcquested,thetotal numberolhourscornpensationrequested,andtlrclocation. l'hesecondsection
contains "Oveftime Codes," the Squad nutnber of thc requesting officer, details of work perforrred and the related incident nulnber. Thc
third section has a certification that the request is "correct and in accordance with CO 300-07," lollowcd by the signature of the requesting
officer,aswell asalistingoftheregulardutyhoursanddaysoffoftherequestingofllcer. l'helourlhscctionprovidesspaceforareviewing
supcrvisor and reviewing metnber of cotnmand staflto approve or deny the requcst followed by spacc lor posting inforrnation. l'he bottorn
of the form contains a notation reading, "Falsifying a Request for Overlirne Cornpensation Can Rcsult in Adrninistration Discipline and
Criminal Prosecution."
case#1680896/ CRT#228
In addition to the defendant's Oveftime Forms, Affiant reviewed the offense repofts (OR) ior the incident numbers listed on each form
reviewed. Affiant conducted research through law enforcement databases in order to dctermine the defendant's home address.
Affiantreviewedapreviouslyobtainedsearchwarrantfor20l8cell sitedataforthepersonal cell phoneofthedefendant. Thedatareturned

was provided to Nathan Gates (Gates), a Lieutenant Investigator and Digital Forensics Exarniner currently employed within the HCDAO
Digital ForensicsUnit. Fortheperiodsforwhichdatawasobtained,Catesmappedthecoordinatesofthecell sitedataforthedefendant's
cell phone during the times for which defendant requested OT cornpensatron.
Affiant observed an Overtime Fonn signed by the defendant requesting pay colnpensation lor lour hours of OT worked from 0600 to 1000
hoursonApril24,20l8,anddetailinganarcoticssearchwarrantexecution. IncidentNo.05 13350-l8islisted. AffiantreviewedtheORfor
Incident No. 05 1 3350-1 8 and observed the reporl to document a narcotics search warraut exccution conducted on April 24,2018, at 10522
Beechnut, at 1030 hours.
In reviewing the defendant's cell site mapping for 0600 to 1000 hours on April 24,2018, Affiant obscrved that the defendant's phone does
not connecf to towers in the area of 10522 Beechnut. Between 0755 and 0842 hours, Affiant observed that the def,endant's phone does
connect to towers in the Cypress area, near the defendant's residence, and approxirnately trventy rniles fi'om 10522 Beechnut.
Based on the above infonnation, Affiant has reason to believe that the delendant worked no rnore than one olthe four hours documented in
his April 24,2018 Overtime Fonn, and thus any forrn of payrnent received from I{PD lor the additional three hours alleged constitutes a
theft.
Affiant observed an Overtime Form signed by thc defendant requesting pay compensation lor eight hours of OT worked from I 800 hours on
April25,20l8,to0200hoursonApril 26,20lS,anddetailingtwonarcoticsscarchwarrantexecutions. lncidentNo.05l9738-l8and
05 19974-lSarelisted. AffiantreviewedtheORforlncidentNo.05 19738-l8andobservedthe reporltodocumentanarcoticssearch
warrant execution conducted on April 25,2018, at 8335 Pamell, at 1700 hours. Affiant rcviewed the OR for Incident No.0519974-18 and
observed the reporl to document a narcotics search warrant execution conducted on April 25,2018, at 6807 Goforth, at 1820 hours.
In reviewing the defendant's cell site mapping for 1800 hours on April25,20l8, to 0200 hours on April 26,2018, Affiant observed that the
defendant's phone does not connect to towers in the area of 6807 Golorth or 8335 Parnell. At approximately 2005 hours, the defendant's
phone does connect to a tower in the area of 8300 Mykawa, the location of the HPD Southeast Station. Affiant knows from review of the
defendant's personnel records that he was assigned to Southeast at alltimes discussed herein. At approximately 2011,2015 and2017 hours,
his phone connects to towers approximately along South Beltway 8. At approximately 2038 hours, the phone connects to a tower in Jersey
Village, at approximately U.S. 290 and West Beltwal' 8. At approximately 2150 hours, his phone connccts to a tower in the area of
Cypress, where the defendant resides, and more than thirty rniles from 6807 Cotorth, 8335 Parnell, and 8300 Mykawa,
Based on the above information, Affiant has reason to believe that the defendant worked no more than thrce of the eight hours documented
in his April 25,2018 Overlime Form, and thus any lorrn of payment received lrorn HPD lor the additional five hours alleged constitutes a
theft.
Affiant observed an Overtime Forrn signed by the defendant requesting cornpensatory tirnc compensation for four hours of OT worked fi'om
0600tol000hoursonMay29,20lS,anddetailingtrvonarcoticssearchwarrantexecutions. IncidentNos.0679066-18and0679448-l8are
listed. Affiant reviewed the OR for Incident No. 0679066-l8 and observed the rcport to document a narcotics search rvarrant execution
conductedonMay29,2018,at1262lFondren,at09 l5hours. AffiantreviewedtheORlorlncidentNo.06T9448-l8andobservedthe
repoft to document a narcotics search warrant execution conducted on M ay 29 , 2018, at 3 63 I Su nbearn, at I 05 I hours.
lnreviewingthedefendant'scell sitemappingfor0600to l000hoursonMay29,20l8,Affiantobscrvedthatthedefendant'sphonedoes
notconnecttotowersintheareaof363 lSunbeamor1226l F'ondren. Betwcen0Tl4and0Sl3hours,hisphonedoesconnecttoatowerin
Cypress, in the area of the defendant's residence, more than thirty miles from the rvar-rant locations, At approximately 0858 and 090 I hours,
the defendant's phone connects to a tower in the area of West Beltway 8 and South Gessner, approxirnately two miles fron 12621 Fondren.
Based on the above information, Affiant has reason to believe that the defendant rvorked no rnore than one of the four hours docurnented in
his May 29,2018 Overtirne Form, and thus any forrn of paynrent received frorn HPD forthe additional three hours alleged constitutes a
theft.
Affiant observed an Oveftime Fonn signed by the defendant requesting pay compensation for four hours of OT worked fi'om 0600 to I 000
hours on August 6,2018, and detailing a narcotics search rvarrant execution. Incident No.0998257-18 is listed. Affiant reviewed the OR
for Incident No.0998257-18 and observed the repofi to document a narcotics search warrant execution conducted on August 6,2018,at
4524 Alvin. The reporl nar-rative notes that the warrant briefing was held at approxinrately 0847 hours.
ln reviewing the defendant's cell site rnapping for 0600 to 1000 hours on August 6,20lr8, Affiant obscrvcd that the delendant's phone does
not connect to towers in the area 4524 Alvin. 1'he phone does connect to towcrs in thc Cypress area, rvhere the defendant resides, at 0748,
0827 and 0828 hours. At approximately 0842 hours, thc phone connccts to a tower in the area oll-10 and West Grand Parkway. At
approximately 0846 hours, the phone connects to towers in the area oil-10 and Ilarker Cypress Road. Between approxinrately 0921 hours
case#1680896/ CRT#228
and 0933 hours, the defendant's phone connects to a tower in the area ofthe tlPD Southcast Station
Based on the above information, Affiant has reason to believe that the defendant worked no more than one olthe four hours documented in
his August 6,2018 Overlime Form, and thus any form of payment received frorn HPD for the additional three hours alleged constitutes a
theft.
Affiant observed an Overtime Form signed by the defendant requesting pay cornpensation lor four hours of OT worked from 0600 to 1000
hours on August 21,2018, and detailing a narcotics search warrant execution. Incident No. 1064348-18 is listed. Affiant reviewed the OR
forlncidentNo. 1064348-l8andobservedtherepofttodocumentanarcoticssearchwarrantexecutionconductedon'August2l,2Ol8,at
l2l I Bayou. The report narrative documents the warrant execution time to have been 1030 hours.
Inreviewingthedefendant'scell sitemappingfor0600to l000hoursonAugust2l ,2018,Affiantobservcdthatthedefendant'sphonedoes
notconnecttotowersintheareaof l2llBayou, locatedtothenortheastofdowntorvn. ThephonedoesconnecttotowersinCypress,
where the defendant resides, between 0647 hours and 0849 hours. At approximately 0912 hours, the defendant's phone connects to a tower
in the area of I-10 and Chimney Rock, approximately ten miles frorn l21l Bayou.
Based on the above information, Affiant has reason to believe that the defendant worked no more than one of the four hours documented in
his August 21 ,2018 Oveftime Form, and thus any form of payment received lrorn IIPD forthe additional three hours alleged constitutes a
theft.
Affiant observedan Overtime Form signed by the defendant requesting pay compensation for four hours of OT worked ftom 0600 to 1000
hours on September 6,2018, and detailing narcotics investigations. IncidentNos. 1134028-18 and 1133695-18 are listed. Affiantreviewed
theORforlncidentNo. 1134028-l8andobservcdtherepofltodocurnentanundercoverbuyconductedonSeptember6,20l8,at4500
Idaho,at0900hours. AffiantreviewedtheORforlncidentNo. 1133695-lSandobservcdthercporttodocurnentabuybustashavingbeen
conducted September J,2018, at 6800 New York, at 0907 hours.
In reviewing the defendant's cell site mapp ing for 0600 to I 000 hours on September 6, 20 I 8, A lfl ant observed that between 0626 and 0'7 02
hours, the defendant's phone connects to a towers in the Cypress area, rvhere the defendant resides. At approximately 0736 hours, the
defendant's phone connects to a tower in the area of I-10 and Westgreen. At approxirnately 0749 hours, the defendant's phonc connects to a
tower in the area of I-10 and Beltway 8, At approximately 0805 and 0813 hours, the defendant's phone connects to towers approximately
alongSouthBeltway8. Atapproximately0823hours,thedefendant'sphoneconnectstoatowerintheareaofMykawaandAirport,notfar
fromtheSoutheastStation. Betweenapproximately0849hoursand09 l5hours,thedefendant'sphoneconnectstotowersintheareaof
4500 Idaho and 6800 New York.
Based on the above information, Affiant has reason to believe that the defendant worked no more than two of the four hours documented in
his September 6,2018 Overtime Form, and thus that at any form of payment received lrom HPD for the additional two hours alleged
Affiant observed an Overtime Form signed by the defendant requesting pay compensation for four hours of OT worked from 0600 to 1000
hoursonOctober3,20l8,anddetailingnarcoticsinvestigations. IncidentNos. 1252656-18, 1254013-l8,and 1253344-18arelisted.
AffiantreviewedtheORforlncidentNo. 1252656-lSandobservedthereporttodocumentanundercoverbuyconductedonOctober3,
2018, at 7000 Cullen. Affiant noted that the reporl narrative indicates a time o10937 hours. Aftrant reviewed the OR for lncident No.
1254013-18 and observed the report to docurnent an undercover buy conducted on October 3, 201 8, al 4100 Larkspur, at 1045 hours.
AffiantreviewedtheORforlncidentNo. I253344-l8andobservedthereporltodocumentanundercoverbuyconductedonOctober3,
2018, at 8700 Cornal, at I 123 hours.
Inreviewingthedefendant'scell sitenrappingfor0600to l000hoursonOctober3,20lS,Affiantobservedthatthedefendant'scell phone
connects to a tower in the Cypress area, where thc defendant resides, between 0620 and 0734 hours. At 0824 hours his phone connects to a
tower approximately along South Beltway 8. Betrveen 0900 and 0948, the defendant's phone connccts towers in thc general vicinity ol
7000 Cullen, 4700 Larkspur and 8700 Comal.
Based on the above information, Affiant has reason to believe that the defendant u'orkcd no nrore than trvo of the four hours documented in
his 0600 to 1000, October 3,20 18 Overlime Form, and thus any forrn olpayment received fiom IIPD lor thc additional two hoLrrs alleged
Affiant observed an Overtime Form signed by the defendant requesting pay compensation for four hours of Ol'',vorked liom 1800 to 2200
hours on October 3,2018, and detailing a search warrant excct-ttion. Incident No. 1254607-18 is listed. Affiant reviewed the OR for
Incident No. 1254607-l 8 and observed the reporl to document a search warrant execution conducted on October 3, 20 I 8, ar2819 Beny, at
l547hours. Affiantnotedthatthereportindicatcsthatthescenewastuntedovcrtotheresidentsatl630hours. Affiantfufihernotedthat
the defendant was not the case agent.
In reviewing the defendant's cell site rnapping for 1800 to 2200 hours on Octobcr 3, 2018, Affiant observed that the defcndant's cell phone
does not connect to towers in the area of 2819 Berry, locatcd in Grcater Third Ward. AIfiant observed that thc defendarrt's phone connects
Case#l580896/ CRTf228
to towers along South Beltway 8 and the West Beltway 8 between l8:07 and l8:27 hours. Between l8:42 and 2l :46 hours the defendant's
phone connects to towers in the Cypress area, where the delendant resides, and more than twenty-five miles frorn 2819 Berry and the
Southeast Station.
Based on the above information, Affiant has reason to believe that the delendant worked none of the lour hours documented in his 1800 to
2200, October3,20 18 Overlime Form, and thus any form olpaynrent received from IIPD forthose lour hours alleged constitutes athefl.
Affiant observed an Overtime Form signed by the defendant requesting pay compensation for four hours of Ol'worked from 0600 to 1000
hours on October 15,2018, and detailing a street pop investigation. lncident No. 1307536-18 is listed. Affiant reviewed the OR for
Incident No. I 307536- I 8 and observed the report to document a buy bust conducted on October I 5, 20 I 8, at 6900 Cullen, at 0823 hours.
I n reviewing the defendant's cell site mapping for 0600 to I 000 hours on October I 5, 20 I 8, A lfiant observed that the de fendant's phone
connects to towers in the Cypress area, where the defendant resides, at 073 I and 0750 hours. At approxirnately 0802 hours, the defendant's
phone connects to a tower in the area of l-10 and Sll 6. At approximately 0838 hours, the defendant's phone connects to a tower in the area
of downtown Houston. Between approximately 0854 hours and 0924 hours, the defendant's phone connects to towers in the general vicinity
of6900 Cullen and the Southeast Station.
Based on the above information, Affiant has reason to believe that the defendant worked no rnore than two of the four hours documented in
his October 15,2018 Overlime Fonn, and thus any form of payment received lrorn HPD for the additional two hours alleged constitutes a
theft.
Affiant observed
an Oveftime Form signed by the defendant requesting pay compensation for four hours of OT worked from 0600 to 1000
hoursonNovember5,20 lS,anddetailingastreetpopinvestigation. IncidentNo. 1401664-18 islisted. AffiantreviewedtheORfor
IncidentNo. 1401664-lSandobservedthereporttodocumentanundercoverbuyconductedonNovenrber5,20 l8,at5l3l Mallow.
Affiant noted that the report narrative indicates that the investigation started at 0905 hours.
Inreviewingthedefendant'scell sitemappingfor0600to l000hoursonNovember5,20l8,Aifiantobservedthat,atapproximately0l16
hours,thedefendant'sphoneconnectedtoatowerintheCypressarea,rvherethedefendantresides. Atapproximately0756,0807and08l4
hours,thedefendant'sphoneconnectstotowersapproxirratelyalongWestBeltway8. Atapproximately090 I hours,thedefendant'sphone
connects to a tower in the area of 5100 Mallow. At approxirnalely 0924 hours, the defendant's phone connects to a tower in the area of 8300
Mykawa.
Based on the above information, Affiant has reason to believe that the defendant worked no rnorc than two of the lour hours documented in
his November 5,2018 Overlirne Form, and thus any forrn of payment received fi'orn IIPD for the additional two hours alleged constitutes a
theft.
Affiant observed an Overlime Form signed by the defendant requesting pay compensation for lour hours olO'l'worked from 0600 to 1000
hours on November 13,2018, and detailing a street pop investigation. lncident No. 1436408-18 is listed. AFfiant reviewed the OR for
lncident No. 1436408-l 8 and observed the reporl to docurnent an undercover buy bust conducted on November 13,201 8, at 3901 Old
Spanish Trail, at l01l hours.
Inreviewingthedefendant'scell sitemappingfor0600to l000hoursonNovembcr 13,20 l8,Affiantobservedthatthedelendant'sphone
does not connect with towers in the area of 390 I Old Spanish Trail. Affiant obsetved that between 0626 hours and 0805 hours, the
defendant's phone connects to a tower in the Cypress area, where the defendant resides, and approximately thirry miles fi'om 390 I Old
SpanishTrial. Betweenapproximately0908hoursand0923hours,thedelendant'sphoneconnectstoatowcrintheareaolBellfor-tand
Jutland, approximately two miles from the Southeast Station.
Affiant has reason to believe that the defendant worked no more than one of the four hours documented in
Based on the above information,
his November 13,2018 Overtime Form, and thus any form of payment received Ilom IIPD for thc additional three hours alleged constitutes
a theft.
Affiant observed an Overlime Form signed by the defendant requesting pay colnpensation for four hours of Ol'worked frorn 0600 to 1000
hours on December 4,2018, and detailing an undercover narcotics investigation. lncident No. 152702 l-18 is listed. Affiant reviewed the
OR for IncidentNo. 1527021-18 and observed it to docunrent a buy bust conducted on Decernber 4,2018,at1200 Cullen, at 0829 hours.
Affiant noted that the defendant is not tnentioned in the report.
In reviewing the defendant's cell site rnapping for 0600 to 1000 hours on Dccember 4,2018, Affianl observed that betwecn 0659 hours and
094 I hours, the defendant's phone connects to a tolver in thc Cypress area, rvhere thc dclendant rcsides, and approxirnately thirly rniles lrotn
7200 Cullen.
Based on the above information, Affiant has reason to bclieve that the de fendant worked none of thc lour hours documentcd in his
December4,20lSOvertirneForm,andthusanyformofpayrnentreceivedfi'ornHPDlorthosclourhoursallegcd constitutesatheft
case#1580896/ CRT#z28
Affiant observed an Overtime Form signed by the defendant requesting pay conrpcnsation lor lour hours of Ol'worked frorn 0600 to l0O0
hoursonDecemberll,20l8,anddetailingastreetpopinvestigation. IncidentNo. 1557403-l8islistcd. AffiantreviewedtheORlor
IncidentNo. 1557403-l8andobservedittodocumentabuybustconductedonDecernberll,20 l8,at6800Cullen,at0853hours.
ln reviewing the defendant's cell site mapping for 0600 to 1000 hours on Deccrnber 11,20 18, Affiant observed that, between 0635 hours
and 0141 hours, the defendant's phone connects to a tower in the Cypress area, where the defendant resides. At approxirlately 0828 hours,
the defendant's phone connects to a tower in the area of I- I 0 and Shepherd. Bctween approxirnately 0848 hours and 0907 hours, the
defendant's phone connects to a tower in the area ofthe Llouston Zoo. At approximately 0917 hours, thc defendant's phone connects to a
tower in the general vicinity of 6800 Cullen.
Based on the above information, Affiant has reason to believe that the defendant worked no rnore than one of thc four hours documented in
his December 11,2018 Overtime Form, and thus any form of paymcnt received from HPD for the additional three hours alleged constitutes
a theft.
Affiant observed an Overlime Form signed by the defendant requcsting pay compensation for eight hours of Ol'worked from 1800 hours on
December12,2018,to0200hoursonDecernberl3,20 l8,anddetailingnarcoticsinvestigations. IncidentNos. 1564446-18and1564692-
l8arelisted. AffiantreviewedtheORforlncidentNo. 1564446-l8andobservedittodocunrentabuybustconductedonDecemberl2,
20l8,at2lllFannin,atl635hours. AffiantreviewedtheORforlncidentNo. 1564692-l8andobservedittodocumentabuybust
conducted on December 12,2018, at 1000 Iladley, al 1742 hours. Affiant noted that thc dcfcndant is not mentioned in either report.
ln reviewing the defendant's cell site mapping for 1800 hours on Dccember 12,2018, to 0200 hours on Decembcr 13,2018, Affiant
observed that the defendant's phone does not con nect to towers in the area of 2 I I I Fann in or I 000 I lad ley, both located near downtown.
Between 1903 hours and22lt hours, the defendant's phone connects to a towcr in the area of Aldine Westfleld and Rankin, and
approximately eighteen miles from 2l I I Fannin and 1000 Hadley. Between 2304 hours and 2308 hours, the defendant's phone connects to a
tower in the Cypress area, where the defendant resides, and approxinrately trventy-five miles ltorn 2l ll Fannin and 1000 ltadley.
Based on the above information, Affiant has reason to believe that the defendant rvorked no Inore than lour of the eight hours docutnented in
his December 12,2018 Overlime Form, and thus any lorm of payrnent received lrom FIPD for the additional four hours alleged constitutes a
theft.
Each of the Overlime Forms discussed herein indicates by a check mark and a signature that they wcre approved by a supervisor and a
member of the command staff for payment and furlher lists a "date posted." Thus alfiant has probable cause to believe the defendant was
AffiantreviewedbusinessrecordsreceivedfromtheCityofHouston,AdministrationandRegulatoryAtfairsDeparlmcnt. Therecords
include the overlime "calculated rate of pay" for the delendant for 20 18. Affiant observed the de flendant's oveftinte calculated rate of pay to
be $59.84 for April 24,2018, through August 6, 201 8, and $61 .68 for August 21,2018, through Decetnber 12,2018.
Based on the hours and rate of pay discussed above, Affiant belicves the following reflects the value of pay and compensatory time acquired
by the defendant without the effective consent of HPD and the City of Houston:
DATE OT PAY RATE OT HOURS CLAIMED OT CI-AIMEO PAYMENT ACTUAL OT HOURS CORRECT P YMENT AMOUNT OVERPAYMENT
412412018 359.84 4 9239.36 1 i59.84 31 79.52
1t25t2018 $59.84 8 3478 72 3 31 79.52 s299.20
5129t2018 959 84 4 s239.36 'l $59.84 s179.52
8/6/2018 $59 E4 4 $23S.36 1 $59.84 $1 79 52
8121t2018 s51.68 4 s246.72 1 $61.68 sl 85.04
9t6t201 I $61.68 4 $246.72 2 81 23.36 3123 36
1U3r2018 36r.68 I t246.72 3123.36 31 23.36
s246 72 0 g0 00 9246 72
1 0/3/20't8 $61.68 4
10115t7018 36'1.68 4 $246.72 2 tr23.36 t1 23 36
't 1/5/201 8 $6t.68 4 1246.72 a 123 36 s1 23 36
11113t2018 $61 68 4 $246.72 1 $51.68 31 85.04

121412018 $61 68 I s216 72 0 90 00 s216 12
1A11t2010 36,l.68 4 s246.72 1 $61.68 sl 85 04
12t1U2018 s61 6E I s493 44 4 $246 72 3248.t2
NT
Based on the above information, Affiant has reason to believe and does belicve that thc defendant did not actually rvork all of the hours for
which he submitted an Overlime Form, and for which he was compensated, and thus that the delendant unlawfully appropriated
compensation fi.om FIpD and the City of Houston. J'exas Penal Codc Section 3 1.03, I'hcft, provides that, "a person comlnits an offense if he
unlawfully appropriates property with intent to deprive the owner of properly," and that "appropriation is unlawlul if it is without the
owner's effective consent." This Section also provides that if the value of thc propeny stolen is 52,500 ormore but less than 530,000, the
offense is a State Jail Felony. This Section lufther prov ides that the offense is increased to the next h igh er category of offense if it is shown
on the tria[ of the offense that "the actor connected to a tower apublic servarrt at timc of the offensc and thc propefty appropriated came into
case#1680896/ CRT#228
the actor's custody, possession orcontrol by virlue of his status as apublic servant." Texas Penal Code 1.07 providql
th:r1 a public servant
includes a person employed as an officer of government. The City of Houston is a govemnrent entity located
withili-llarris County, Texas.
HPD is a subdivision of the City of Houston.
AffianthasreviewedTexasPenal CodeSection3l.0gandknowsthatwhenamountsareobtainedinviolationofChapter3l(l'heft)
pursuant to one scheme or continuing course of conduct, whether frorn the sar-ne or several sources, the conduct
ruy i. considered as one
Affiant therefore has reason to believe and does believe that on about April 24,2018, though Decernber 12,2}lg, while a public
servant,
nalnely a Texas Peace Officer, and pursuant to one scheme and continuing course of condict, Gerald Goincs did rhen
and ihere unlawfuily
appropriate, by acquiring or otherwise exercising control over property, narnely, rnoney and compensatory tirne, owned
by the Houston
Police Department and the City of Houston, hereinafter styled the Complainani, of the value of at least two thousand five
hundred dollars
but less than thirty thousand dollars, with the intcnt to deprive the Complainant of that property, and said property came into
the
Defendant's custody, possession and control by virtue ofthe Delcndant's status as a public seivant.
Signed and sworn by me on v- /- Duly attested by rne on o-''r/u t

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AFF]ANT ASSISTA DIS-I-RICT ATI'ORNEY

OF- IIARRIS COUNI'Y, ]'I]XAS
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Witness (Peace Olficer)
COMPLAINT
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JUDGE I JOHNSON
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REPORT: DIM601 JUSTICE INFORMAJION M.ANAGEMENT SYSTEM TIME:
DArE: 07l 0L/ZO .D.A. 8 : 34
L INTAKE MANAGEMENT SYSTEM
TRANSACTION # i 2553130 D.A. LOG #: 2553130

IN CUSTODY.. ..: N CARINDICATOR ]D BY PRINTS:
SPN # 03014649
AFTS NUMBER...
DEFENDANT NAME GOINES, GERALD MICHAEL
ALIAS NAME....
ALIAS SPN.... .
US CITIZEN Y INS#:
PLACE OF BIRTH: US CTTY OF BIRTH:
DA'E SEX:
B M DOB: t0/02/t9G4
MARITAL STATUS: MA BUILD: MED HEIGHT: 601 WEIGHT: 260
HA TD xxx SKIN: BLK EYES: BRO
crfaDc

CITY.. HOUSTON, TX ZIP: 11OO2
PRIOR ARREST?: Y FBI#: VIMWNP,fWS STATE fD #: TX1O545645
AGENCY ID#. . : DAO SSN: SO#: 2759434
ALIAS SPN (S) . :
DL#..... ....: 12928512 DL ST: TX
EMPLOYER . ,. : RETIRED
OCCUPATION .. , .: RETIRED
MENTAL ILLNESS .NT
CO_DEFENDANTS? NO
DOES THE DEFENDANT HAVE A SPN? N
PRTNTEDt 07/0L/2020 O8:34 ( JOHN) DIM6O1

THE STATE OF TEXAS D.A. l.OC NUMBER: 2653126
03059894 o
VS. CJIS ]'RACKING NO.: c
o
CLEMENTE REYNA SPN: BY: EH DA NO: 2425968
I2OO TRAVIS DOB:W M l116/1968 AGENCY:DAO
HOUSTON, TX77002 DATE PREPARED: 7 ll 12020 O'R NO: S1907
ARRIISI'DA]'E: TO BE
NCIC CODE: 4802 32 RELATED CASES:
CAUSE NO: COURT ORDERED BAIL: TO BE SET AT

HARRIS COUNTY DISTRICT COURT NO MAGISTRATION tsO
FIRST SETTING DATE: PRIOI{ CAUSE NO:
CIln RGE SEQ NUM: I
Before rne, the undersigned Assistant District Attorney of Harris Counry, l'exas, this day appearcd the undersigned affiant, who under oath says
that he has good reason to believe and does believe that in Harris County, Texas, CLEM ENTE REYNA, hereafter styled the Defendant,
heretofore on or about October 74,2017, did then and there unlarvfully, knorvingly make a false entry in a governmental record, namely, a
Houston Police Deparlment Narcotics Division C.l. Activity Sheet/Receipt for Funds Forrn, rvith the intent to defraud and harm another.
Probable Cause
Affiant, Lieutenant Billy Milan, is a certified peace officer employed by the I larris County District Attomey's Olfice (HCDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to believe and does believe that former Houston Police Department (HPD)
Sergeant Clemente Reyna, hereinafter defendant, did comrnit the state jail lelony offense oltarnpering with a governmcntal record on or
about October 14,2017, in ilouston, Harris County,'l-exas. Affiant bascs this bclief on the lollowing:
On January 15,2020, former IIPD Narcotics Officers Gerald Goines (Goincs) and Steven Bryant (Bryant) were indicled for Tampering with
a Govelnrnental Record, see Har-ris County Cause Nos. 1660764 and 1643521, respectively. 'l'hcse charges center on false statements sworn
to by Coines in obtaining a narcotics search warrant for a residence located at 7815 Ilarding Strcct and false staterrcnts made in the
corresponding offense reporl by Bryant. Execution of that search warrant lcd to the death olboth horncowners, injury to l'our HPD olficers,
Case#16808971 CRT#228
and thereafter an HPD investigation into Goines' use of confidential inlormants (C.l.s) to obtain scarch warants.
Affiant reviewed the HPD offense reporl (OR) docunrenting that investigation, I-IPD OR No. 133932- 19, authored by Sergeant Rick Bass, a
licensed peace officer currently employed by IIPD, and learned the following: AllC.l.s registered to Coines werc inierviewed and each
denied having completed a controlled buy at Ilarding Street, despite the probable cause affidavit for the search rvarrant for that location
stating that a C.l. had completed a controlled buy the day prior to the date of the affidavit. One of the C.l.s who was interviewed
(hereinafterreferred to as C.l. #l) reported to have at times been paid by Coines for u'ork not prelormed. C.l. #l gave a video interview
during which C.l. #l was asked about several locations where, according to olficial HPD rccords (spccifically C.l. Forms discussed more
fullybelow),C.1.#l hadconductedcontrolledbuys. C.l.#ldeniedhavingconductedseveral ofthoscbuys,eachofwhichledtoanarcotics
search warrant.
Affiant is aware of and has revicwed HPD General Order 600-16 (GO) which governs C.l.s and paymcnts to C.l.s. Thc GO holds that "all
meetings between a C.l. and an officer shall be attended by two officers." This regulation requires that that at least two olflcers be present
when a controlled buy is conducted. It furlher mandates that "officers shallnot pay a confidential informant without the appropriate witness
present." The GO goes on to dictate how payments to C.l.s will be documented, stating that all payrnents to C.l.s "shall be firlly
documented on a division's 'Confidential Inforrnant Receipt for Funds forrn"'(C.1. Form) with "control inforrnation" to include the
signature of the C.l. as an agreement that the payment rvas received, the signaturc of the investigator making the payrnent, the signature of at
least one other officer witnessing the payrnent, and the date of the payment. These fonns, as dictatcd by the GO, rcquire that at least three
people - the C.1., the investigator, and a witncss - be together in one place in order tbr a payrnent to occur. Affiant has reviewed nLlrnerous
HPD C.l. F-orms and has noted that these forrns also include the tirne of,the payrnent and thc associated OR number for the OR wherein the
controlled buy is docurnented.
Affiant has also reviewed the Special lnvcstigation Cornmand, Narcotics Division, Standard Operating Procedures (SOP). SOP 100/2.05
covers "Confidential Infortnant FundsiE,xpense Letters, Limits of Authorization and Use olFlash Money" and includes a section on "CI
Payments & Receipt for Funds Form." l'hat section repeats the requirernents of CO 600-16 and also specifically states, "The CI Receipt
for Funds form will be completed at the time of the payment to the CI" (emphasis in originat). Affiant has reviewed the specific C.l. Form
used by the HPD Narcotics Division, titled "C.l. Activity Sheet i Receipt for Funds Form." Thc form has six sections. l'he first section
inbludes C.l. name, date, time, location, OR number, and blanks for up to two drug types and the corresponding weight. The second section
isforanarnountpaidtotheC.l.forinformationandassistanceandincludesblanksfortheamountpaidandtheC.l.'ssignature. Thethird
section is for an amount provided to the C.l, to purchase narcotics and includes blanks for the amount paid and the C.l.'s initials. The fourth
section provides a space for details. The fifth section starts with the rvord "Witness" followed by a blank lor a printed name and a blank for
a signature. The sixth section goes on to provide blanks lorthe signatures of the reviewing sergeant and the reviewing lieutenant.
Affiant reviewed documents provided by HPD pursuant to this investigation, including C.l. Forrns, expcnsc rcporls, offense reports,
overlime request forms, and expense authorization fornrs, and specifically all documentation for UPD OR nurnber 130597 l-17. Affiant
observed that in the C.l. Activity Sheet/Receipt for Funds Form associated with this report numbcr, the defendant signed that he witnessed
Goines make payments to C.l. #l on October 14,2017 at l5:00 hours lor a buy allegedll,nrade at 4855 Fuqua in l-louston, Harris County,
Texas. C.l. #l denied rnaking any buys at this location.
Affiantpreviouslyobtainedsearchwarrantsforcell sitedataforthe personal cell phonesofthedelendant,aswell asC.l.#1. Affiantwas

provided a copy of the cell site data returned as a result olthose warrants. The data for the defendant came lrom A1'&T and ranged fronr
February 2l ,2011 through December 11 ,2018. The data for C.l. #[ carne fronr AT&T and rangcd frorn March 25,2017 throLrgh December
31,2018. This data was provided to Nathan Cates (Gates), a Lieutenant Investigator and Digital llorensic Examiner currently cmployed
within the HCDAO Digital Forensic Unit. During the time period for which data rvas returned, Gates rnapped the coordinates of the cell
phonedataforthedefendantandforC.l.#lforthedatesandtirnesofeachpaymentdocnrncnted.
In reviewing the defendant's cell site mapping lor this date and time, Affiant observed that the defendant's cell phone was in usc and
travelling frorn approximately l4:30 hours to l5:51 hours in the arca between approxirrately the Highway 6 and Wcstpark T'ollway
intersection and approxirnately the Highway 6 and U.S.290 intersection, locations that Alfiant lound to be approximately twenty-five (25)
miles and fofty (40) miles away from 4855 lruqua, respectively. In reviewing the cell site rnapping for C.l. # I for this date and time, Afflant
observed that C.l. #l's cell phone was in use frorn approximately l4:00 hours to l5:37 hours in the area of SII-288 and I-45, a location that
Affiant found to be approximately eleven (l l) miles away frorn 4855 Fuqua.
Based on the above information, Affiant has reason to bclieve that neither the alleged bLry nor the alleged payrnent for said buy took place as
documented by Goines and the defendant, and thus Affiant has reason to believe that the defendant did not witness any alleged payment to
C.l. #l at l5:00 hours on October 14,2017, as documented by the defendant in the in the C.l Activity Sheet / Reccipt for I'-unds Irorrn. J'exas
Penal Code Section 37.10, Tampcring with a Governnrental Record, provides that, arnongst other rncans, "a pcrson cornmits an offcnsc if he
knowingly makes a false entry in, or false altcration o[, a governrnental record." Tcxas Penal Code Section 31 .01(2) provides that a
"Govemmental Record" includes "anything belonging to, received by, or kept by governrnent lor inlorrnation, including a court record."
The C.l. Forms described above are required by a General Order to be completed for all C.l. payrnents. 'l'ltey are kcpt by IIPD to document
case#15808971 CRT#228
C.l. activity and involvement in narcotics investigations. Alfiant is aware that HCDAO has requested and received frorn HpD C.t. Forms
dating back more than 20 years. HPD is a subdivision olthe City of Houston, a municipality.
Affiant therefore believes that the defendant did commit the offense of tampering with a governnrental record on or about October l4,2Ol7
in Houston, Hanis County, Texas by knowingly making a lalse entry in a governrnental record, narncly a Flouston police Depaftrnent
Narcotics Division C.l, Activity Sheet/Receipt for Funds Forrn, and that this offense rvas conrrnitted with the intent to dellaud the Houston
Police Deparlment.
Signed and sworn by me on tu Dury artcsred by me on tD

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AFFIANT ASSI S]'AN1' DISl'R.ICI' A'T1'ORNI]Y

OF I IARIIIS COUNTY, TEXAS
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Witness (Peace Olficer)
COMPLAIN'T
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Dqt
DArE: 07 / 0! / 2A D.A. INTAKE .MANAGEMENT SYSTEM
,i
TRANSACTION # 2553125 D.A. LOG #: 2653126

IN CUSTODY.. .. N CARINDICATOR ID BY PRINTS:
DATE OF ARREST TIME OP ARREST:
SPN #
AFIS NUMBER...
DEFENDANT NAME REYNA, CLEMENTE
ALIAS NAIV]E..,.
ALIAS SPN.,, ..
US CITlZEN lNS#:
ALLIEN STATUS ILLEGAL CODE:
PLACE OF BIRTH CITY OF BIRTH:
RACE, . :W SEX: M DOB : i/ 06 / 1968
MARITAL STATUS BU]LD: MED HEIGHT: 600 WEIGHT: 220
}IAIR. . : BRO SKIN: LBR EYES: BRO
SCARS
STREET ADDRESS: 12OO TRAVIS

crTY.. :.. ...
HOUSTON, TX LTY:
PHONE.... .... .: () EMAIL:
PRIOR ARREST?: N FBI#: STATE ID #
AGENCY ID#. . : DAO SSN: so#
ALIAS SPN(S) .:
DL#..........: Lt9482'71 DL ST: TX
co-DEFENDANTS? (t
DOES THE DEFENDANT }IAVE A SPN? Y
PRINTED I O] /O)-/2A20 O4:40 (CASSIDY, JAMES M) DIM5O1

THE STATE OF TEXAS
03059895
VS.
THOMAS ALAN WOOD SPN:
I2OO TRAVIS DOB: W M312011968
HOUSTON, TX77002 DATE PREPARED: 7 I I 12020
r: Qi 3 :.
NCIC CODE:2399 68 RELATED CASES -....-,,
FELONY CHARGE; AGG THEFT PUB SERV
CAUSE NO: COURT ORDERED BAIL: TO SB dET,{T

HARRIS COUNTY DISTRICT COURT NO: MAGISTRATION
FIRST SETTINC DATE: 1680tU! PRIOR CAUSE NO:
228 CHARGE SEQ NUM: I
Before me, the undersigned Assistant District Attorney of Ilanis County, Texas, this day appcared the undersigned affiant, who under oath says
that he has good reason to believe and does believc that in t{arris County, Texas, THOMAS ALAN WOOD, hcreafter styled the Defendant,
heretofore on or about April 29,2017 continuing through February 26,2018, did then and there unlawfully, while a public servant, namely,
a Texas Peace Officer, and pursuant to one scheme and continuing course of conduct, appropriatc, by acquiring or otherwise exercising
control over properfy, namely, money and compensatory time, owned by the I{ouston Police Deparlment and the City of Houston,
hereinafter sryled the Complainant, of the value of at least two thousand five hundred dollars but less than thiny thousand dollars, with the
intent to deprive the Cornplainant of that propeny, and said propefiy came into the Delendant's custody, possession and control by virtue of
the Defendant's status as a public servant.
Probable Cause
Affiant, Investigator Jonathan Prykryl, is a certified peace officer employed by the tlarris County District Attorney's Office (HCDAO) and
assigned to the Civil Rights Division. Affiant has probable cause to believe and does believe that former Ilouston Police Deparlment (HPD)
Sergeant Thomas Wood, hereinafter the defendant, did cornrnit the third degree felony offense oltheft by a public servant, in an amount
more than twenty-five hundred dollars but less than thirly thousand dollars, on or about April 29, 2017, and continuing through February 26,
2018, in Houston, llarris County, Texas.
Affiant is aware of and has reviewed HPD General Order (C O ) #300-07, subject "Overtirne Cornpensation." It outlines overlime (OT)
compensation for all classified employees of HPD who hold the rank of police officer, senior police oflficer, or sergeant, or other employees
with a pay grade equivalent of sergeant or below. Pertinent excerpts are quoted below:
Except as otherwise noted in this General Order, all overtime earned shall be cornpensatcd at the rate of time and a half.
Officers shall have the option of overlirne pay or compensatory tirne for oveftime worked, unless the compensatory tirne bank limit would
be exceeded.
At the tirne of an officer's separation fronr the department as a classified employee, all banked cornpensatory time (depending on how it was
accrued) shall be administered in accordance rvith the applicable lall,or the applicable Meet and Conler Agrecment.
Officer requesting oveftime cornpensation shall subrnit the appropriatc oveftirne request fonn.
Affiant revierved oveftime forms requested fiorn IIPD by I ICDAO pertaining to the dclendant lor 20ll and 20 18. Affiant obscrved that the
forms are titled "Houston Police Depaftment Ovcrlirne [{equest Form" (Overlirne Form). Affiant fufther obscrved thc lorms to contain four
sections. The first section contains the narne and emplol,ee nurnbcr ol'the errployee requesting cornpcnsation, the datc and hours workcd,
whetherpayorcompensatorytimeisbeingrequested,thetotal nr.rmbcrofhourscompcnsatiorrrcqucsted,andthelocation.'fhesecond
section contains "Overtime Codes," the Squad nutnber olthc requesting officer, details of work pcrlorrncd and the related incident nurnber.
The third section has a certification that thc rcqucst is "corrcct and in accordancc with GO 300-07," lollowed by thc signature olthe
requesting officer, as well as a listing ofthe regular duty hours and days offolthe requcsting olficcr. l'he lourth section provides space lor
Case#16808981 CRT#228
a reviewing sttpervisor and reviewing member of cotnmand staff to approve or deny the rcquest followcd by space for posting
inlormation.
The bottom of the forrn contains a notation reading, "Falsifying a Request for Overlime Coinpensation Can Result in Administration
Discipline and Criminal Prosecution."
ln addition to the defendant's Overtime Forms, Alfiant revierved the offense reports (OR) lor the incident numbers listed on each forrn
reviewed. AlfiantreviewedTexasDepartmentofPublicSafetyrecordstodeterrninethedelendant'shomeaddress.
Affiant reviewed a previously obtained search warrant for cell site data for the personal cell phone ofthe defendant for periods throughout
2017 and 2018. The data returned was provided to Nathan Cates (Gates), a Lieutenant lnveitigator and Digital Forensics Examiner
currently ernployed within the HCDAO Digital Forensics Unit. For the periods for which datiwas obtained, Gates rnapped the coordinates
of the cell site data for the defendant's cell phone during the times for which detendant requested 01'compensation.
Affiant observed an Oveftime Form signed by the defendant requesting compensatoly tirne compensation for 8 hours of OT worked flom
800 to 1600 hours on April 29,2017, and detailing thc review olten case files. 'lhe Location provided is IlpD Headquarters, 1200 Travis.
In reviewing the defendant's ce ll site mapping for 800 to I 600 hours on April 29, 20 I 7, A lfi an t observed that the dc lendant,s phone
never
connects to towers in the area of 1200 Travis, or anywhere inside of the 610 t,oop Affiant observed that bctween 0848 and lj58
hours, the
defendant's cell phone connects to multiple towers in the area norlh olNorth 610 and betwcen US 290 and I-45, including the
area of the
defendant's residence.
Based on the above information, Affiant has reason to bclieve that the defendant,,vorked none of thc eight OT hours documentcd
in his
April 29,2017 Overtime Fortn, and thus any forrn of paynrent received frorn HPD for those alleged eight hours constitutes a theft.
Affiant observed an Overlinre Form signed by the defendant requesting compensatory tinre compensation lor 8 hours of 01 worked fiom
800 to 1600 hours on April 30,2017, and detailing the review olten case files. The location provided is HpD Headquarters, 1200 Travis.
In reviewing the defendant's cell site rnapping for 800 to 1600 hours on April 30, 20 17, Alflant observcd that the defendant,s phone
never
connectstotowersintheareaof l200Travis. Affiantobservedthatbetween0825and l2l5hours,thedefendant'scell phoneconnectsto
multipletowersintheareanorthofl-l0andbetweenUS2g0andl-45,includingtheareaofthedefendant'sresidencc. Betweenl3l6and
1339 hours, the defendant's phone connects to towers along l-10, west oldowntown.
Based on the above information, Affiant has reason to believe that the defendant worked no more than two of the eight OT hours
documented in his April 30,2011 the Overtirne Form, and thus any form of payrnent received frorn IIPD for the additional six hours
alleged
Affiant observed an Overlime Form signed by the defendant requesting compensatory tirne compensation for 6 hours of OT worked from
1800 to 0000 hours on July 25,2017, and detailing a narcotics "buy/bust" operation. Affrant also observed an Ovefiime Form
signed bythe
defendant requesting pay compensation for2 hours of OT worked from 0000 to 0200 hours on July 26,2017, and listing the same detalls as
thel800to000hoursform. BothformslistlncidentNo.0g43664-17. AlfiantreviewedtheORforlncidentNo.0g43664-lTandobserved
the repoft to document a narcotics investigation conducted on July 25,2017, at 5820 West Sam Houston parl<way (Beltway g), at 1942
hours.
Inreviewingthedefendant'scell sitemappingfor l800to0000hoursonJuly25,2Ol7,and0000to0200hoursonJuly 26,2Ol7,Affiant

observed that the defendant's cell phone never connects to towers in the area of5820 West Beltway 8. l'he defendant,s phone connects
to
towerswestofdowntown,approximatelyalongKirbyDrivebetrveen 1836 and2202hoLrrs. Bctween2236hoursonJuly25,20l7and0l36
hours on July26,2017,the defendant's phone connects to towers in the area norlh of Noflh 610 and bctwcen US 290 uni I-+S, includingthe
area ofthe defendant's residence.
Based on the above information, Affiant has reason to believe that thc defendant r.r'orkcd none of the e ight hours documented in his July 25,
2017 and h\y26,20 l7 Overtime Forms, and thus any form of paymentreceived from tlPD lorthose alleged eight hours constiturcs atheft.
Affiant observed an Overtime Form s igned by thc defendant requesting pay cotnpensation lor 6 hours of OT worked frorn I 800 to 0000
hours on August 16,2017, and detailing a narcotics search warrant exccution. Incidcnt No. 1036372-17 is Iisted. Affiant reviewed the OR
forlncidentNo. 1036372-lTandobservedthereporttodocumentanarcoticssearchwarrantexecutionconductedonAugust 16,20ll ,at
3229 Truxillo, at 1716 hours.
In reviewing the defendant's cell site mapping for 1800 to 0000 hours on August 16,2017, Alfiant obscrved that the defendant's phone
neverconnectstotowersintheareaof 3226Truxillo. Thedefendant'sphoneconuectstotowersinthedowntolvnareabetween l803and
l810hours. Betweenl82 l and234'Thours,thedefendant'sphoncconnectstoto,,ycrsinthcareanofihofNofth6l0andbetweenUS2g0
and I-45, including the arca ofthe defendant's residence.
Based on the above information, Affiant has reason to believe that the defendant worked no ntore than onc of the six hours documented in
his August 16,2017 Oveftime Forrn, and thus any lorrn of payrnent received frorn IIPD for thc additional five hours alleged constitutes a
theft.
Case#1580898/ CRT#228
Affiant observed an Oveftime Form signed by the delendant requesting pay compensation for 8 hours olO-l lvorked
from 0700 to 1500
hours on August 20,2017, and detailingthe review olten case files. The location Iisted is llPD Fleadquarlers,
1200 Travis.
Inreviewingthedefendant'scell siternappingtor0T00to l500hoursonAugust20,2}ll

,Affiantobservedthatthedefendant,sphone
never connects to towers in the area of 1200 Travis. Between the hours of0730 and 1334 hours, the defendant's phone
connects to towers
in the approximate area norlh of Norlh 610 and between US 290 and l-45, including the area of the
defendant,s residence. The defendant,s
phone connects to a tower in the approximate area of Wash ington Aven ue and Soulh H e ights Bou levard
between I 404 and I 4 I 5 hours.
Based on the above information, Affiant has reason to believe that the delendant worked no rnore than
one of the eight hours docurrrented in
his August 20,2017 Overtime Fom, and thus any form of payment received fiom HPD for thc additional seven hours
alleged constitutes a
rheft.
Affiant observed an Overtime Form signed by the delendant requesting pay compensation for 6 hours of OT worked from lg00 to
0000
hoursonOctoberl8,20lT,anddetailingtwonarcoticssearchwarrantexecutions. lncidentNos. l3l7g23-l7andl3lg4 l0-lTarelisted.
AffiantreviewedtheoRforlncidentNo. 1317923-lTandobservedthereporltodocumentanarcoticssearchwarantexecutionconducted
onOctoberl8,20l7,at8800Hammerly,atl300hours. AlfiantreviewedtheORforlncidentNo. 13184 l0-lTandobservedthereportto
document a narcotics search warrant execution conducted on october t8,20l l,at6916 Avenuc o at 1530 hours.
In reviewing the defendant's cell site mapping for 1800 to 0000 hours on October 18, 2017, Affiant observed that the defendant,s
phone
neverconnectstotowersintheareasofs800tlamrnerlyor6gl6AvenueO. Thedefendant'sphoncconnectstotowersintheappioximate
area of north of North 610 and between US 290 and I-45, including the area olthe defcndant'sresidcnce, between
1807 and 2332 hours.
Based on the above information, Affiant has reason to bclieve that the delendant worked none of the six hours docurnented
in his October
18,20 l7 Overtime Form, and thus any form of payment received fi'om HPD forthose alleged six hours constitutes atheft.
Affiant observed an Overlime Form signed by the defendanl. rcquesting pay compensation lor 8 hours of OT worked frorn lg00 hours
on
February26,20lsto0200hoursonFebruary2T,2Ol8,anddetailingtwonarcoticssearchwarrantexccutions. IncidentNos.0250l46-lg
and0250903-l8arelisted. AffiantreviewedtheORforlncidentNo.0250l46-l8andobservedthereporttodocumentanarcoticssearch
warrantexecutionconductedonFebruary26,20ls,ar4020 LunrberLane,at l630hours. AffiantreviervedtheORforlncidentNo.
0250903-l 8 and observed the report to document a narcotics search warant execution conducted on F'ebruary 26,2018, at 823 I Leonora, at
I 82 I hours.
In reviewing the defendant's cell site mapping for I 800 hours on February 26,2018 to 0200 hours on Fcbruary 27,21lg,Affiant
observed
that the defendant's phone never connects to towers in the area o14020 Lurnber Lane. The defendant's phone does connect to
towers in thc
areaof823 lLeonorabetweenl333andl845hours. Thedefendant'sphonethenconnectstotowcrsiniheapproximateareaofnorthof
Norlh 610 and between US 290 and I-45, including the area olthe defendant's residence, betwcen 2026 hours on February 26,201g and
0 I 58 hours on February 21 ,2018.
Based on the above information, Affiant has reason to believe that the defendant u,orked no more than three of the eight hours
documented
in his February26,2018 Overlime Fortn, and thus any forrn of payment received frorn tlPD forthe additional five hours alleged constitutes
a theft.
Each of the Ovefiime Forms discussed herein indicates by a check mark and a signature that they n,ere approved by a supervisor
and a
member of the command staff for paylnent and funher lists a "date posted." l'hus, alfiant has probablc cause to beiieve the defendant
was
Affiant reviewed business records received front the City of Houston, Administlation and Regulatory Alfairs Deparlment. The records
include the oveftime "calculated rate of pay" for the dclendant throughout 2017 and 20 18. Affialt observed the defendant's overtime
calculated rate ofpay to be $66.62 for all ofthe dates and tinres detailed above.
Based on the hours and rate of pay discussed above, Alfiant lras reason to believe the following rcflects the value of the pay and
compensatory tirne acquired by the defendant withoLrt the eflbctive consent of t'lPD and thc City of Ilouston:
Case#1580898/ CRT#228
OT HOURS OT CLAIMED ACTUAL OT CORRECT PAYMENT

DATE CLAIMED PAYMENT HOURS AMOUNT OVERPAYMENT
412912017 $66.62 B $s32.96 0 $0 00 $s32 96
413012017 $66.62 I $532.96 2 $133.24 $399.72
7125,t2017 $66.62 6 $399.72 0 s0 00 $399.72
712612017 $66.62 2 $133.24 0 $0.00 $133.24
81',t612017 $66.62 b $s99.72 1 $66.62 $s33.1 0
812012017 $66.62 I $532.96 I $66 62 $466.34
1011N2017 $66.62 b $399.72 0 $0,00 $399.72
a26D01B s66.62 8 $532.96 3 $199.86 $s33.1 0
rOTAL THEFT AMOUNT
Based on the above information, Affiant has reason to believe that the defendant did not actually work all of the hours lor which he
submifted an Overtime Form, and for which he was compensated, and thus that the delendant unlawfully appropriated compensation from
HPD and the City of Houston. Texas Penal Code Section 31.03, Theft, provides that, "a person commits an offense if he unlawfully
appropriates property with intent to deprive the owner o[properly," and that "appropriation is unlarvful iIit is rvithout the owner's effective
consent." This Section also provides that if the value of the propcrly stolen is $2,500 or rrore but less than $30,000, the offense is a State
Jail Felony. This Section further prov ides that the offen se is increased to the next h igher category of offense if it is shown on the trial of the
offense that "the actor was a public servant at time ofthe offense and the properfy appropriated came into the actor's custody, possession or
control by virtue of his status as a public servant." Texas Penal Code 1.07 provides that a public servant includcs a person ernployed as an
officer of government. The City of Houston is a government entity located within Harris County, Texas. HPD is a subdivision of the City
of Houston.
Affiant has reviewed Texas Penal Code Section 31.09 and knows that rvhen amounts are obtained in violation of Chapter 3l (Theft)
pursuant to one scheme or continuing course ofconduct, whether from the samc or several sources, the conduct may be considered as one
offense and the amounts aggregated in determining the grade of oflense.
Affiant therefore has reason to believe and does believe that on about April 29,2017, though lrebruary 26,2018, while a public servant,
namely a Texas Peace officer, and pursuant to one scheme and continuing course olconduct, Thontas Wood did then and there unlawfully
appropriate, by acquiring or otherwise exercising control ovcr propefiy, namely, rnoney and/or cornpensatory tintc, owned by the Houston
Police Department and the City of IIouston, hereinafter styled the Complainant, olthc value of at least two thousand five hundred dollars
but less than thirty thousand dollars, with the intent to deprive the Cornplainant of that properly, and said propeny came into the
Defendant's custody, possession and control by virtue ofthe Dcfendant's status as a public servant.
Signed and sworn by me on I Duty auested uy *. o'9 ? -oI- )'o 'I CJ
zN
AFFIANT ASSISTNNI' I)IS1'RIC'f ATTORN EY
OF HN RRIS COUNI'Y.'|EXNS
BarNo lTtfiraC)
I A, 0r nto,
COMPLAINT
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J KELLI JOHNSON
: i')
l, /a,!rir;1
t;ii Dtf [ilrirlli itr] ll)

:^l ..,r:.r.,-
Dspt
REPORT: DIM501 JUSTICE INFORMATION MANAGEMENT, SYSTEM
DArE: 07/07/20 TIME: 4:45
D.A. INTAKE MANAGEMENT SYSTEM
TRANSACTION# : 2553115 D.A. LOG #: 2653115

DATE OF ARREST:
TIME OF ARREST:
sPN #.. ......:
AFIS NUMBER.,.:
DEFENDANT NAME: WOOD, THOMAS ALAN
ALIAS NAME....:
ALIAS SPN..,..:
US CITIZEN Y INS#:
ALLIEN STATUS : lLLEGAL CODE
RACE.... .. .: w SEX: M DoB: 03/20/1,968
MARITAL STATUS: MA BUILD: MED HEIGHT: 509 WEIGHT: 185
ltArR........ .i BRO SKIN: LGT EYES: BLU
scARs. .......:
\-l-1I.. HOUSTON, TX ZIP : 'l'7 A02
PHONE () .ET I .
EMAIL:
PRIOR ARREST?: N FBI# STATE ID #
AGENCY ID#. . : DAO SSN so#
ALIAS SPN(S) . :
uDl+, ..... . : l-2578744 DL ST: TX

EMPLOYER RET]RED
OCCUPATION RETIRED
MENTAL ILLNESS.n ...: N
CO-DEFENDANTS?
\
l|NO
DOES THE DEFENDANT IIAVE A SPN? Y N
PRINTED I O7 / 01./2020 O4:45 (CASSIDY, J M) DIM6O1

Probable Cause Affidavits Against HPD Officers

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THE STATE OI.- TEXAS 03014651 D.A.

ARREST DATE: TO BE Pq'r.f --J

CAUSE NO: COURl'ORDERED BAIL: TO BE SET

IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS:

Affiantpreviouslyobtainedsearchwarrantslorcell sitedataforthepersonal cell phonesofthedefendant,Goincs,andC,l,#1. Affiantwas

ACAINST THE PEACE AND DICNITY OF THE STATE.

Signed and sworn by me on

AFFIANT ASSISI-ANT DIS'f RICT ATTORNITY

Witness Printed natne & Badge or Payroll nutnber

ALLIEN STATUS i TLLEGAL CODE

STREET ADDRESS 12OO TRAVIS

PRINTED | 07 /0t/2020 O4:19 (CASS JAMES M) DIM5O1

IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS:

Inreviewingthedefendant'scell sitemappingforl800hoursonApril 4,2018,to0200hoursonApril 5,20 l8,Affiantobservedthatthe

neverconnectstotowersintheareaof3409Mcllhenny. Duringaphonecallbeginningat lS04hoursthedefendant'sphoneconnectsto

Inreviewingthedefendant'scellsitemappingfor l800hoursonNovemberl,2018 to0200hoursonNovember8,20lS,Affiantobserved

OTCI.AIMEI' ACruALOT COFFECT PAYI'ENT

AGAINST THE PEACE AND DICNITY OF THE STATE

Signed and sworn by me on l- Duly attested by ,aon o 0t /" ob0

AFFIANT ASSIS ANT DIS RICT ATTORNEY

Witness Printed name & Badge or Payroll number

, t':.'u :,..) li;r: i;1.-:t t\i. ;,:.,r.:

TRANSACTION # : 265372't D.A. LOG #: 2553L27

DEFENDANT NAME: BRYANT, STEVEN O

STREET ADDRESS | 1200 TRAVIS

DLt+. , , 767 8L220 DL ST: TX

DOES THE DEFENDANT HAVE

PRTNTED | 07 /Ar/2020 o4:42 (CASSlDy, JAMES M) DrM6O1

CAUSE NO: COURT ORDERED BAIL: TO BE SET A E.

IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS:

AffiantisawareofandhasreviewedHPDCeneral Order600-16(GO)whichgovernsC.l.sandpaymcntstoC.l.s. TheGOholdsthat,,all

Affiantpreviouslyobtainedsearchwarrantsforcell sitedataforthepersonal cellphonesofbothReynaandC.l.#1. Affiantwasprovideda

AGAINST THE PEACE AND DIGNITY OF THE STATE.

Signed and sworn by me on Duty artested by r]1e on AZfl -,)O )C)

AFFIANT ASSISTANT DI S'|RICI' A1''TORNEY

Witness Printed name & Badge or Payroll nurnber

TRANSACTION # : 2653t76 D.A. LOG #: 2653lt1

ALLIEN STATUS : ILLEGAL CODE

STREET ADDRESS 12OO TRAVIS

DL#... .. .. : 12928572 DL ST: TX

PRINTED | 0't / 0t / 2020 04:58 (CASSIDY, JAMES M) DIM6O1

DATE PREPARED: 7 ll 12020 O'll. NO: 51907 o

CAUSE NO: COU RI' ORDERED SN I UhdRE SET A

IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS:

Affiantpreviouslyobtainedsearchwarrantsforcell sitedataforthepersonal cell phonesofthedeflendant,Bryant,andC.l.#1. Affiantwas

AGAINST THE PEACE AND DIGNITY OF THE STATE.

Signed and sworn by me on Duly attcstcd by rne on -O/ - Iolu

AFFIANT ASSI STANl' DISTRIC'1- ATTORN EY

Witness Printed name & Badge or Payroll number

it.') ;-.?il. :,1411A:1):.J i:':D?;\',;: t.:.!::ai)t_1 t -:)1,:^, ii-,,t.::t:-.i..\.,: )..:i.

JUDGE KELLI JOHNSON $o

DEFENDANT NAME: GOINES, GERALD

PRINTED I O'7 /OI/2020 O4:52 (CASSIDY, JAMES M) DIM5O1

FELONY CHARGE: TAMPERING GOVERNMENTAL RECORD c\,i

IN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS

Affiantpreviouslyobtainedsearchwarrantsforcell sitedataforthepersonal cell phonesolthedefcndant,Reyna,andC.l.#1. Affiantwas

Inreviewingthecell sitemappingforthedefendantforDecenrber3,20l8,at l3:00hours,Alllantobservedhiscell phonewasinuseat

AGAINST THE PEACE AND DIGNITY OF TI-IE STATE

Signed and sworn by me on Duly attested by rne on

Witness Printed name & Badge or Payloll nurnber

TRANSACTION # 2653Lt4 D.A. LOG #: 2653114

DEFENDANT NAME GO]NES, GERALD

STREET ADDRESS 12OO TRAVIS