Trenell Murphy Gov't Reponse to Suppression Motion

IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MARYLANDUNITED STATES OF AMERICA***V.*Crim. No. L 09-0098**TRENELL D. MURPHY ******o0o*****

GOVERNMENT'S RESPONSE TO DEFENDANTS’ PRETRIAL MOTIONS

Now comes the United States of America by its attorneys, Rod J. Rosenstein, UnitedStates Attorney, and Philip S. Jackson, Assistant United States Attorney, and in response to thedefendants’ various pretrial motions submits as follows.

I. Facts and Circumstances

During the autumn of 2007, detectives of the Baltimore (Maryland) Police Departmentreceived information from a confidential informant that an individual he/she knew as “Chuck”was distributing large amounts of cocaine city-wide. The informant further indicated that“Chuck’s” base of operations was the west-side of Baltimore, and that “Chuck” resided with hismother in that area. The residence of “Chuck’s” mother was identified by the informant as 3041Presstman Street. The detectives subsequently identified “Chuck” as Trenell D. Murphy(Murphy). During the course of their investigation, the detectives actually saw Murphy going toand from that residence.The above-cited confidential informant had a long track record (in excess of one year) of supplying accurate information to law enforcement. Information imparted by this confidentialinformant had been independently corroborated by other informants and by other investigativetechniques. For that reason, this confidential informant was considered by the detectives to be

-2-reliable.After receiving this information, the detectives were transferred to the east-side of Baltimore, and at that time took no further investigative measures with respect to Murphy. Whenin early 2009, the detectives were transferred back to the west-side of Baltimore, they renewedtheir attention toward Murphy.In that vein, in the evening hours of February 19, 2009, detectives set up surveillance inthe vicinity of 3041 Presstman Street. Those detectives observed parked alongside 3041Presstman Street a black Chevy truck bearing MD registration 88V422. According to Motor Vehicle Administration records, that truck was listed to Trenell David Murphy. During thecourse of their surveillance, the detectives observed Murphy exit from the front door of 3041Presstman Street and go to the driver’s side door of a blue Honda Odyssey minivan which was parked in front of the house. Murphy then re-entered the dwelling through the front door.According to MVA records, that Honda minivan is also registered to Murphy.Later that evening, the detectives observed a dark blue colored Honda Accord stationwagon park directly in front of 3041 Presstman Street. An unidentified African-American malethen exited the car. After knocking on the front door, the unidentified male was allowed to enter the dwelling. Approximately one hour later, the same unidentified male and a second male (later identified as Murphy) exited from the front door of 3041 Presstman Street. Each male wascarrying a white plastic bag; each of which were tied off at the top and appeared to be full to itscapacity. The first male put the bag he was carrying into the dark blue Honda station wagon andMurphy put the other bag into the bed of the black Chevy truck. Both then separately drove thevehicles from the area.

-3-The black Chevy was followed by detectives to the 1400 block of Ellamont Street whereMurphy pulled to the curb, retrieved the white plastic bag from the bed of the truck, anddiscarded that bag into the gutter. Murphy then re-entered the truck and drove from the area at ahigh rate of speed. Detectives almost immediately recovered the discarded bag and found it tocontain one (1) razor blade with white residue, suspected cocaine, one (1) Bicycle playing cardwith white residue, suspected cocaine, and numerous pages of newspaper, dated February 4,

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2009, with white powder residue, suspected cocaine. The investigating detectives recognized thewhite powder residue described above as cocaine through its texture and by the unique aromagiven off by cocaine.The dark blue Honda Accord station wagon was also followed out of the area bydetectives. As the vehicle traveled through the 800 block of Ellicott Drive the driver discardedthe white plastic bag onto the street, and suddenly accelerated at a high rate of speed. Thedetectives also recovered that discarded bag, and found it to contain numerous pages of newspaper, dated February 4, 2009, with white residue, suspected cocaine, one (1) large silver

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foil bag with residue, suspected cocaine, and numerous rectangular shaped saran wrap packagesand rubber bladders with white residue, suspected cocaine. The detectives recognized theseitems to be consistent with the manner in which kilogram quantities of cocaine are packaged for transportation. Furthermore, the detectives recognized that individuals involved in the wholesaledistribution of narcotics commonly discard the remnants of their activities at a location remotefrom the locus of their illegal activity in an attempt to avoid creating a nexus between their activities and the location where they handle their product.

Category:	Government Docs
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Upload Date:	07/08/2009
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Tags:	crime drugs cocaine baltimore rosemont crime drugs cocaine baltimore rosemont (fewer)

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