WARNING: THIS GRAND JURY INDICTMENT CONTAINS GRAPHIC CONTENT
COUNT 21 -RETALlATTON AGArNST A WITNESS OR VICTIM (F3) Between and includi ng January 1,20 16 and June 29, 2017, Noman Boroumand unlawfully and felo niously used a threat, act of harassment. or act of hai-m or il1jury upon a person or property, which_ action was directed to or committed upon a witness or a victi m to any crime, namely: as retaliation at rettibulion against tJ1e witness or v ictim; in violation of section J8-8-706, C.R.S. The facts forming the basis of the criminal act alleged in Count 2 1, if proven, constitute an act of domestic violence, as defined in C.R.S . ยง 18-6-800.3(1). The offense alleged in Count 21 was committed in the fo llowing mrumer; repor(ed to police that the Noman Boroumand assaulted her on February 17, 20 16. Boroumand invited l1er to his bomeon February 25, 2016 to retrieve her final paycheck and return his garage door opener. He told he would not be there. When arrived at the holLSe he was there and lold her to recant her statement and then assaulted her botb physically and sexually.
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COUNT 22-SEXUAL ASSAULT (F4) Between and including August 1, 2011 and August 31, 2015, Noman B0rouma11d unlawfolly, feloniously >and knowingly inflicted sexual intrusion or sexual penetration on causing subrnfasion of the victim by meahs of sufficient consequence reasonably calculated to cause submission against victim's will; in violation of section I 8-3-402(1)(a), C.R.S. (l~ares Alrashed incidents) The fa.c ts forming the basis oftbe crim inal act alleged in Count 22, if proven, constitute an act of domestic violence, as defined in C.R.S. ยง 18-6-800.3(1).
T he offense alleged in Count 22 was committed in the following manner: Noman B0row11and had repeatedly asked to engage in a ''threesom e" with Pares Alrashed. She consistently told him no. On one occasion, after repeatedly voiced her lack of consent to the "threesome'' with Fares Alrashed to Noman Boromnand, Noman Boroumand and Fares Alrashed arrived at her home unannounced. Noman Boroumand demanded that they engage in a " threesome." did not want to engage in this conduct and verbalized that to Noman Bor0tm1a.nd. Finally. gave in out of fear of violence, based on prior domestic violence by Noman Boroumand; she believed that lhere was no way around it. Noman Boroumand forced her to have sexual intercourse with Fares Alrashed. This same kind of conduct occtu"red three to five times. Each time verbalized her unwillingness to engage in this conduct. Each time, Noman Boroumand forced her to have sexual intercourse with him and Fares Alrashed. After each of these occasions Fares Alrashed gave money to Boroumand' s insistence.
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COUNT 23-STALKING {FS} Between and including Jm1e 30. 2014 arid June 29, 2017, Noman Boroumand unlawfully, feloniously, and knowingly, directly or indirectly tlu¡ough another person, repeatedly followed, approached, contacted, placed Lmde.r surveil.lance, or made any form of communication with in a manner that would cause a reasonable person to suffer serious emotional distress, and caused serious emotional distress; in violation of section 18-3-602(l)(c), C.R.S. The facts forming the basis of the criminal act alleged in Count 23, if proven, constitute a11 act of domestic violence, as defined in C.R.S. § 18-6-800.3(1). The offense all.eged in Count 23 was committed in the following maru1er:
During the course of their relationship, NomanBoroumand would follow repeatedly call or texl her, look through her bedroom window at nighttime, and hide and wait for her in ber home, and attack her when she entered.
ln mid-20 l5, left the relationship with NomanBoroumand and moved out of his rental property. Several months later she left her employment wit11 Noman Boroumand's business. She obtained a new residence and began a new relationship. Noman Boroumand continued to call and text At times, he caJJed and stated that he was standing outside of her bedroom window, told her that he was watching l1er, and that he knew who she was with. On one occasion, arrived back at ber condominium from being in Windsor and saw Noman B0romow1d nearby her condominium. drove around the City of Greeley for approximately one hour until she pulled into the Greeley Police Department, when Noman Boroumand finally discontinued his surveillance of her.
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COUNT 24-STALKING {FS) Between and including December 1, 2015 and Jw1e 29, 20 17, Noman Boroumand unlawfully, feloniously, and knowingly, directly or indirectly through another person, repeatedly followed, approached, contacted. placed under surveillance, or made any fo rm of communication with in a mam1er that would cause a reasonable person to suffer serious emotional distress, and caused serious emotional djstress; in violation of section 18-3-602(1 )(c), C .R.S. The facts forming the basis of the criminal act alleged in Count 24, if proven, constitute an act of domestic violence, as defined in C .R.S. § 18-6-800.3(1). The offense a ll eged in Count 24 was committed in the following manner: Noman Boroumand continually followed and surveilled dw¡ing their reported to police tliat relat ionship. Specifi ca lly, on January 1, 20 ) 7, Borouma,nd assaulted ber and he was arrested. Several days later, was in fear because Boroumand kept dJiving by her home. She called her friend to come to her house. observed Boroumand drive by s house numerous times and call her incessantly. She described as being in fear and shaking. has also made staten1ents in text messages to Noman Boroumand ind icati11g that he con tinually surveils her to check on her whereabouts.
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COUNT 25-STALKJN G (FS) Between and including December 1. 20 15 and June 29, 2017, Noman Boroumand LU1lawfully, foloniously, and knowingly. directly or indirectly through another person, repeatedly followed. approached, contacted, placed under surveillance, or made any fol'm of communication with , in a manner that would cause a reasonable person to suffer serious emotional distress, and caused serious emotional distress; in violation of section 18-3-602(l)(c), C. R.S. The facts forming the basis of the crim ina l act alleged in Count 25, if proven. constitute an act of domestic violence, as defined in C.R.S. § 18-6-800.3(1). The offense alleged in Count 25 was committed in the following manner: During tile relationship betwee11 Noman Boroumand and friend, , described being in constant fear of Boroumand harming her friend. Noman Boroumand continually followed and surveilled . After reported he assaulted her on January 1, 2017 she called to come to her house. observed Boroumand drive by house numerous tjmes and call incessantly. described as being in feat and shaking. Further, described that Noman Boroumand's stalking of has caused her, , serious emotional distress~ out of fear for what might happen to
COUNT 26-STALKING (F5) Between and including December l , 2015 and June 29, 2017, Noman Boroumand unJawfully, feloniously. and knowingly, directly or indirectly tl1rougb another person, made a credjb]e threat to and, in connection with the threat, repeatedly followed, approached, contacted, or placed under surveillance the victim and/or a member of that person's immediate fami ly and/or someone wit11 whom that person has or has had a continuing relationship, namely: ; in violation of section 18-3-602(l)(a), C.R.S. The offense alleged in Cmmt 26 was committed in the following manner: Noman Boroumand threatened to harm while in the Weld County Jail. The recorded threat was from a call between and Noman Boroumand. Because of the Uu¡eal, police and warned that Boroumand was going to hann her. observed Boroumand surveilling her on several occasions~ including at her residence and while driving in Gi-eefoy, and , estranged common law husband has also observed Noman Boroumand surveilling hirn.
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COUNT 27-RETALIATJON AGAINST A WITNESS OR VICTIM {F3)
Between and including December 1, 2015 and June 29, 2017, Noman Boroumand unlawfully ru1d feloniously used a threat, act of harassment, or act of hru¡m or injury Ltpon a person or property, which action was directed to or committed upon a witness or a victim to any crime, namely: , as retaliation or retribution against , the witness or victim; in violation of section 18-8-706, C.R.S. The offense alleged in Count 27 was committed in the following manner: witnessed and rep011ed crimes to law enforcement committed by Noman Boroumand against . Boroumand, in a recorded call from Weld County Jail lo , threatened to harm . COUNT 28-SEXUAL ASSAULT (F4)
Between and inclucti11g July 1, 2014 ru,d June 1,2015, Noman Botoumand unlawfully, felo niously, and knowingly inflicted sexual intrusion or sexual penetration on , causing submission of the victim by means of sufficient consequence reasonably calculated to cause submission against victim's wi 11; in violation of section 18-3-402(1)(a). C.R.S. (fares Alrashed penetration) The facts suppo1ting Count Twenty-Eight are set forth after Count Thirty-One, and are incorporated as if fully set forth herein. COUNT 29-SEXUAL ASSAULT (F4}
Between and includi,ng July 1. 2014 and Jw,e 1, 20 I 5, Fares Alrashed unlawfully~ feloniously, and knowingly inflicted sexual intrusfon or sexual penetration 011 , causing submission of the victim by means of sufficient consequence reasonably calculated to cause submission against victim's will; in violation of section 18-3-402{1)(a), C.R.S. The facts supporting Count Twenty-Nine are set forth after Count Thirty-One, and are incorporated as if fully set forth herein.
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COUNT 30-CRIMINAL ATTEMPT TO COMMIT HUMAN TRAFFICKING FOR SEXUAL SERVITUDE (F4) Between and including July 1, 2014 and June 1, 2015, by engaging in conduct constituting a substantial step toward the commission of human trafficking fo r sexual servit ude, Noman Boroumand unlawfully attempted to sell, recruit, harbor, transport, transfer, isolate, entice, provide, receive, or obtai n by any means another person, namely , for the purpose of coercing her to engage in commercial sexual activity; in violation of sections 18.-3-504 an<! 18-2-101, C.R.S. The facts supporting Count Thirty are set fo1ih after Count Thirty-One, and are incorporated as if fully set fo1t h herein.
COUNT 31-CRIMINAL ATTEMPT TO COMMIT HUMAN TRAFFICKING FOR SEXUAL SERVITUDE {F4) Between and including July I, 2014 and June I, 2015, by engaging in conduct constituting a substantial step toward the commission of huma11 trafficking for sexual servitude, Fares Alrashed unlawfull y attempted to sell, recruit, harbor. transpo1t, transfer, isolate, entice, prov ide, receive, or obtain by any means another person, namely , for the purpose of coercing her to engage in comme.rcial sexual activity; in violation of sections 18-3-504 and 18-2-101, C.R.S. The offenses alleged in Counts Twenty-Eight Twenty-Nine, Thitiy, a nd Thirty-One were committed in the fo llowing manner: began to reconnect with Noman Boroumand in 2014; they had been known one another a number of years earlier. was going through a difficult time in ber life at the time, as she had just ended an abusive relationship. Noman B0rotm1and loaned her m oney on occasion, and she believed that he was trying to help her. On the day of the offense, Noma11 Boroumand asked if she would inject him wjth steroids at her house. A short time later Noman Boroumand and Fares A lrashed arrived at 's residence. Noman Boroumand forced to have anal sex with Fares Alrashed and recorded the assault on his phone. did not want to participate, but was in fear of Noman Boroumand, and despite her objections, Noman Boroumand insisied to that she was going to do as he told her to do. After was sexually assaulted, Noman Borommmd told . was upset and crying and told Fares Alrashed to pay them to get out of her house, without taking any of the money.
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COUNT 32-POSSESSJON OF A CONTROLLED SUBSTANCE - SCHEDULE 111, IV, ORV {DMl) Between and including .January 29, 20 16 and June 29, 2017 , Noman B0rorn11and unlawfully and knowingly possessed a material, compound, mixture, or preparation that contained Anabolic Steroids, a schedule ITT, IV or V controlled substance; in violation of section 18-18-403.5(1),(2)(c), C.R.S. The facts supportihg Count Thirty-Two are set forth after Count Thirty-Three, and are incorporated as if fully set forth herein.
COUNT 33-TRANSFER OF CONTROLLED SUBSTANCE 'WITHOUT REMUNERATION (DMl) On or between January 29, 2016 to June 29, 2017, Noman Borournand unlawfully, and knowingly transferred Anabolic Steroids, a schedule III controlled substance, without remuneration, and the amount of tile conh¡olled substance was not more than 4 grams. .in violation of section 18-18-405(1 ),(2)(e)(Il), C.R.S. The offenses alleged in Counts Thirty-Two and Thirty-Three were committed in the foJlowing mam1er: Numerous witnesses describe Noman Boroumand possessing and injecting anabolic stero ids. Borbmnand told law enfotcement that he gave steroids to friends of his and law enforcement found packaging consistent with anabolic steroids jn Boroumand's trash. Further, needles consistent with using steroids intravenously were found at Boroumand's residence.
COUNT 34-ASSAULT IN THE THIRD DEGREE (J\111) On or about January l, 2017, Noman Boroumand unlawfully, and knowingly or recklessly, caused bodiJy injuiy to ; in violation of section 18-3-204(1 )(a), C.R.S. The facts forming the basis of the criminal act alleged in Count 34, if proven, constitute an act of domestic violence, as defined in C.R.S. § 18-6-800.3( 1). The facts supporting Count Thirty-Four are set forth after Count Thirty-Five, and are incorporated as if fully set forth herein.
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COUNT 35-CHfLO ABUSE (M2)
On or about January 1. 2017, Noman Borournru1d unlawfoUy, knowingly, or recklessly, permitted , a child, to be unreasonably placed in a situation which posed a threat of inju1y to the life or health of the chi Id; in violation of section 18-6401(1 ),(7)(b)([). C.R.S. T he offenses alleged in Counts Thirty- Four and Thi1ty-Five were committed in the
following manner: repo1ted to police that Noman Boroumand assaulted her 011 January 1. 20 l 7. She described that Boroumand searched her cell pl1one and became enraged, punching her in the face. While was at the doorway bolcLing herfour-yearold daughter , Boroumand shoved to the ground. Officers observed injuries consistent with 's account. When to ld i hat Noman B0rou1nand m ight be arrested, attempted to recant her statement because sh.e said that Noman Boroumand was her sole source of income.
COUNT 36- WITNESS TAM PERING (F4)
Between and including January l , 2016 and June 29, 2017, Noman Boroumand unlawfully, felon iously., and intenrionally attempted, without bribery or threats, lo induce a wi1ness. a victjm, or a person the defendant believed might be ca lled to testi fy as a witness or victim io any crime to testify falsely or unlawfully withhold any testimony in violation of section 18-8-707, C.R.S. The facts fonrun g th e basis of the criminal act alleged in Count 36, if proven, constitute an act of domestic vi.olence, as defi ned in C.R.S. ยง 18-6-800.3(1 ).
The offense alleged in Count Thirty-Six was comm itted in the fo llowing manner: went to Non1ai1 Boroumand's to retrieve her fi nal paycheck and return bjs garage door opener. When she arrived, Boroumand asked her to recant her statement to po lie~ that he assaulted her on February 17, 2016.
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