UNITED STATES DISTRICT COURT

DISTRICT OF MARYLANDUNITED STATES OF AMERICA

v .

FrankAIDOO

CRIMINAL COMPLAINT

CASE NUMBER:

0 0 /

-I /~

K C -

I, Richard Federico, the undersigned complainant being duly sworn state the following is true andcorrect to the best of my knowledge and belief. On or about March 30, 2009 in the District of Maryland,defendant did,

(Track Statutory Language Offense)

Knowingly and intentionally import into the United States of America, from a place outsidethereof, 1.2 kilograms or more of a mixture or substance containing a detectable amount ofheroin, a Schedule Icontrolled substance, and did knowingly and intentionally possess withtheintent said quantity of heroin,

in violation of Title

.lL

United States Code, Section(s) 952(a), 960 (a) and 841.I further state that I am a Special Agent of the U.S. Immigration and Customs Enforcement, and that thiscomplaint is based on the following facts:

Official Title

SEE ATTACHED AFFIDAVITCdJhtinuedon the attached sheet and made ~ part hereof: ~ NoSworn to before me and subscribed in my presence,March 30, 2009

Date

United States Magistrate Judgeat

Case 1:09-mj-01168-SKG Document 1 Filed 03/30/2009 Page 1 of 4

AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINTI. Purpose of the Affidavit1. This affidavit is submitted in support of a criminal complaint chargingFrank AIDOO with conspiracy to import 1.2 kilograms or more of a quantity of amixture or substance containing heroin, a Schedule I controlled substance, intothe United States from a place outside the United States, to wit, Ghana andelsewhere, in violation of21 U.S.C. sections 952(a) and 960(a).II. Your Affiant2. Your affiant, Richard Federico, is a Special Agent of the United StatesDepartment of Homeland Security, Immigration and Customs Enforcement (ICE),in Baltimore, Maryland. As such, your affiant is a law enforcement officer of theUnited States within the meaning of Section 2510(7) of Title 18 of the UnitedStates Code, that is, an officer empowered by law to conduct investigations of,and make arrests for, offenses enumerated in Section2516 of Title 18.3. Your affiant is a Special Agent with United States Immigration andCustoms Enforcement (ICE), under the Department of Homeland Security and ispresently assigned to the Smuggling/Narcotics Group, at the BaltimoreWashington International (BWI) Airport. During his tenure as a Federal CriminalInvestigator, your affiant has participated in numerous investigations involvingsmuggling, narcotics, and other unlawful activities. These investigations haveincluded the use of surveillance techniques and the execution of search, seizure,and arrest warrants. Your affiant has attended the Criminal Investigator Training

Case 1:09-mj-01168-SKG Document 1 Filed 03/30/2009 Page 2 of 4

( ) r - / (

) e e ; ,

Program and Customs Basic Law Enforcement Academy at the Federal LawEnforcement Training Center. Your affiant is familiar with the facts andcircumstances of the investigation that is the subject of this search warrantapplication. Your affiant has been employed with

u.s

Customs Service /ICEsince January 1998.III. Probable Cause4. On Friday, March 27, 2009, at approximately 1801 hours, Frank AIDOO,Citizen of Netherlands (Ghana born) (DOB 12-02-54) arrived at BaltimoreWashington International Airport, Baltimore, Maryland aboard a British AirwaysFlight Number 229 from London Heathrow International Airport, London, GreatBritain England. Customs and Border Protection (CBP) Officer obtainedinformation regarding AIDOO's airfare and prior activities. AIDOO's ticket waspurchased (cash) three days prior to flight. Intelligence obtained alleged thatAIDOOhad been involved in heroin smugglingactivities. AIDOOhad traveled toan address in New York utilized by Nigerian heroin smugglers, who wereapprehended at John F. Kennedy Airport and in Boston. Upon questioning byCBP Officers, AIDOO became very nervous and did not know where he wasstaying. AIDOO indicated that his purpose for travel was that he was visiting hisnephew for a couple of weeks. CBP Officers contacted the alleged nephew, andthe stories told by AIDOO and alleged nephew were different. Upon furtherquestioning, AIDOO informed the CBP inspectors that he had ingested pellets of heroin. AIDOO was taken to BaltimoreWashington Medical where he passed 100

_~~'Jf. __ ~ •.•••

Case 1:09-mj-01168-SKG Document 1 Filed 03/30/2009 Page 3 of 4