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RULE 9 WARRANT
IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
STATE OF DELAWARE,
v. INDICTMENT BY THE GRAND JURY
BRANDON COOPER
LD. NO. 2203005872
‘The Grand Jury charges that:
Introduction and Background Relevant to All Charges
1. BRANDON COOPER (“DEF
NDANT”) was an officer with the Wilmington Police
Department (“WPD”). At all times relevant to this Indictment, he was serving in his
official capacity as a law enforcement officer and public servant.
2, DEFENDANT was 30 years of age as of August 2021
3. VICTIM ONE is 17 years of age and will not be 18 until April of 2022.
COUNT ONE. A FELONY
#N _
SEXUAL SOLICITATION OF A CHILD in violation of Title 11, Section 1112A(a)(2)
of the Delaware Code.
4, On or before March 2020, DEFENDANT initially met VICTIM ONE at Kingswood
Community Center while working on assignment as a WPD Officer. VICTIM ONE was
a minor. DEFENDANT and VICTIM ONE had begun text communications by
November of 2021.
5. DEFENDANT referred to VICTIM ONE as “Yougn [sic]” and listed VICTIM ONE as
such in his phone, due to her age. DEFENDANT also referred to VICTIM ONE as10,
“baby.” DEFENDANT texted VICTIM ONE that he “aint fuck wit no younngn in a
Jonnngg tiem [sic]”.
On or about December 2, 2021, DEFENDANT asked VICTIM ONE via text message if
“You gotta boyftiend” and if “U drive or not yet” — VICTIM ONE responded “no” to both.
questions.
On or about December 2, 2021, DEFENDANT sent VICTIM ONE a video text message.
In the
leo, DEFENDANT showed his face, stated “look” and aimed the video recorder
downward to film his exposed, erect penis.
DEFENDANT is depicted wearing a WPD uniform in the December 2, 2021 video sent
to VICTIM ONE.
On or about the 3rd day of December, 2021, Division of Family Services (DFS)
responded to VICTIM ONE’s residence in response to VICTIM ONE’s report of sexual
abuse. The location of the incident was outside the jurisdictional boundaries of the City
of Wilmington and did not involve DEFENDANT. DEFENDANT, however, was
dispatched and responded to VICTIM ONE’s residence to assist DFS. Upon
DEFENDANT’s arrival, VICTIM ONE advised that a sexual assault did not occur.
Thereafter, VICTIM ONE disclosed to her DFS Social Worker that she recanted her
statement about a sexual assault because the responding police officer, DEFENDANT,
had sent her a video of him exposing his penis to her. VICTIM ONE was a minor when
she received that video. VICTIM ONE provided the video and text messages with
DEFENDANT to the DFS Social Worker.11, On or about December 3, 2021, following the DFS contact, VICTIM ONE texted
DEFENDANT that she is 17 years of age. DEFENDANT acknowledged to VICTIM
ONE that he knew of VICTIM ONE’s age.
12. On or between the 2"! day of December, 2021 and the 1* day of January, 2022, in the
County of New Castle, State of Delaware, DEFENDANT engaged in a series of text
‘messages with VICTIM ONE that were sexual in nature. The text messages included
nude photos of VICTIM ONE, and DEFENDANT enticing and encouraging sexual acts
with VICTIM ONE,
13. On or about December 10, 2021, DEFENDANT and VICTIM ONE communicate about a
‘meeting for sexual act. DEFENDANT texted VICTIM ONE “if only u was serious
[sic],” to which she responds “I am.” DEFENDANT asks “Where Im coming to [sic].”
VICTIM ONE provides the street name and says “The foster home.” DEFENDANT
responded: “Ok.” The meeting did not occur. VICTIM ONE had informed
DEFENDANT “My curfew at 11pm.”
14, On or about December 25, 2021, VICTIM ONE asked DEFENDANT “can I see you
before I leave for college, im leaving January 6 20222 [sic]” and DEFENDANT
responded “absolutely.”
15. Paragraphs 1 through 14 are incorporated herein,
16, DEFENDANT, on or between the 2nd day of December, 2021 and the Ist day of January,
2022, in the County of New Castle, State of Delaware, being approximately 30 years of
age at the time of this offense, did intentionally or knowingly use a cellular telephone or
other electronic device to communicate with VICTIM ONE, a child, to solicit, request,
command, importune, entice, encourage or otherwise attempt to cause VICTIM ONE to17.
18,
19.
Code.
20.
21.
22.
engage in a prohibited sexual act, and on or about December 10, 2021, did attempt to
‘meet in person with VICTIM ONE with regard to a specific sexual act.
COUNT TWO. A MISDEMEANOR
aN,
LEWDNESS in violation of Title 11, Section 1341 of the Delaware Code.
Paragraphs 1 through 14 are incorporated herein.
In the text messages between DEFENDANT and VICTIM ONE, DEFENDANT
encouraged VICTIM ONE to keep their communications “secret” and that he did not
“like NOBODY in my business.”
DEFENDANT, on or between the 2nd day of December, 2021 and the 1* day of January,
2022, in the County of New Castle, State of Delaware, did commit a lewd act which
DEFENDANT knew was likely to be observed by others who would be affronted or
alarmed.
COUNT THREE. A MISDEMEANOR
#N
OFFICIAL MISCONDUCT in violation of Title 11, Section 1211(1) of the Delaware
DEFENDANT admitted that he was working in his official capacity as a WPD Officer
when taking the video of his exposed penis and sending it to VICTIM ONE.
Paragraphs | through 20 are incorporated herein,
DE
INDANT, On or between the 2nd day of December, 2021 and the 1* day of January,
2022, in the County of New Castle, State of Delaware, while being a public servant, andintending to obtain a benefit, did commit an act constituting an unauthorized exercise of
official functions, knowing that the act was unauthorized.
FOREPERSON
KATHLEEN JENNINGS
ATTORNEY
DEPUTY ATTORNEY GHNERAL
Dated: March 14, 2022
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