JEFFREY R.

BUHMAN #7041
Utah County Attorney
CRAIG JOHNSON #10151
Deputy Utah County Attorney
100 East Center, Suite 2100
Provo, Utah 84606
Email: dcourt@utahcounty.gov
Phone: (801) 851-8026
Fax: (801) 851-8051

IN THE FOURTH JUDICIAL DISTRICT COURT

UTAH COUNTY, STATE OF UTAH
STATE OF UTAH,

INFORMATION

Plaintiff,
vs.
NASIRU SEIDU
479 N. Orem Boulevard
Orem, UT 84057
DOB: 09/07/1976,

Case No.
Judge: Darold J. McDade
OTN:

EDWIN N. RANDOLPH
442 E. 1000 S.
Springville, UT 84663
DOB: 08/06/1969,
Co-Defendants.
The State of Utah, by and through Craig Johnson, Deputy Utah County Attorney,
charges the defendant with the commission of the following offense:
COUNT 1: RETALIATION AGAINST A WITNESS, VICTIM, OR INFORMANT, a
third degree felony, in violation of Utah Code Ann 76-8-508.3, in that on or about
September 29, 2015 through November 25, 2015, in Utah County, the defendants, Nasiru
Seidu and Edwin Randolph, did act or aid and abet one another, believing that an official
proceeding or investigation was pending, was about to be instituted, or had been
concluded, to:

(a) (i) make a threat of harm; or

(ii) cause harm; and
(b) directed the threat or action:
(i) against a witness or an informant regarding any official proceeding, a victim of any
crime, or any person closely associated with a witness, victim, or informant; and
(ii) as retaliation or retribution against the witness, victim, or informant.
PROBABLE CAUSE STATEMENT: Martin Webb of the Provo Police Department,
having probable cause to believe that the defendant committed the above-listed offense,
submitted the following evidence in support of the filing of this Information: On
09/29/2015, police arrested Nasiru Seidu for Rape, which was subsequently filed as a
first degree felony and is a currently pending case before Judge McDade. Subsequent to
the Seidu bailing out of jail on the Rape case, the victim of the Rape was contacted by the
BYU Honor Code and Title IX offices on or around 11/25/2015. The victim was told that
BYU had a copy of the police report from Provo City. Police authored a subpoena to
BYU and discovered that a copy of the report was delivered to BYU. Upon receipt,
police discovered via the information provided by the subpoena that Edwin Randolph,
and other friends of Nasiru, had made the report to BYU and provided them with a copy
of the police report. The copy of the police report was the copy that was provided to
Nasiru via discovery.
Police made contact with the individuals that provided the report. Those individuals
disclosed that Nasiru posted bail and was released from the Utah County Jail. Nasiru
provided a copy of the report of this case to Randolph, who then took the copy of the
police report to the BYU Honor Code. Randolph admitted the idea was his (and not the
other friends) and stated that he knew that the victim in the case could receive
disciplinary action based on the information contained within the report and that Nasiru
gave him the copy of the report. Randolph stated that the disciplinary action could
include suspension or expulsion from the University.
The Rape victim is from California and may not be available for court proceedings
following a suspension or expulsion from BYU. Due to the fact that arrestee Nasiru
Seidu provided a copy of the Provo Police report Randolph, who then took the report to
BYU, knowing that the report could cause the victim of the rape to face consequences at
the University including suspension and expulsion, and while a criminal proceeding is
still ongoing, the victim has suffered retaliatory "harm" under the "Retaliation Against a
Victim" statute, pursuant to 76-5-508.3.

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Based upon evidence received from Martin Webb of the Provo Police Department, I have
reason to believe the defendant committed the offense as charged herein.
Authorized for presentment and filing this 19th day of February, 2016.
UTAH COUNTY ATTORNEYS OFFICE
Sworn to by:
/s/ Craig Johnson
Deputy Utah County Attorney