Not sympathetic to a rival gangster? Ok lets find an innocent victim: not a rival criminal, but an innocent witness who our protag wants to intimidate. Gangster wants to intimidate the witness, but can't get at them, so cooks up a scheme to convince the witness that the police are in his pocket. Exactly as above, causing the police to investigate the witnesses phone.
Another one might be, a certain government wants to identify opposition groups using images associated with them . Apple is not keen to be associated with that, but the government can simply generate fake child-porn (remember, programmatically generated CP is just as illegal) for each image of interest.