Ramirez and Navarrete were selling "a ton of percs" and that Navarrete "has a gun and
isn't afraid to use it."
Based on this information, Mousseau requested permission to search Navarreteand Dennis-Ramirez's apartment for oxycodone, Percocet, drug paraphernalia and related
evidence. Mousseau sought judicial authorization to execute the warrant during
nighttime hours, and to dispense with the ordinary "knock-and-announce" requirement
when executing a search warrant at a residence. In justification of these requests, he
stated the following:
Based upon my training and experience, I know that a
firearm is a commodity that is held onto and kept readily
accessible for protection. I also know that drug dealers
commonly arm themselves to prevent robberies of their
product and proceeds from rival drug dealers or from
buyers. I also know that sometimes drug dealers, if
given the opportunity, will arm themselves against the
police who are executing search warrants.
[A] No Knock Search Warrant... would allow the
officers executing the search warrant the ability to makea safe, swift entry and prevent anyone inside the premise
[from having] the time to arm themselves and fire at the
Officers. This request would also prevent suspect(s),
should they so choose, from firing a weapon and
injuring a civilian in another part of the residence
and/or other residences nearby.
The cover of darkness maximizes the abilities of policeofficers to approach a premises without being detected.
This in turn means that when search warrants are
executed, the drug distributors are less likely to have an
opportunity to jeopardize police officer safety or...
destroy drugs kept for sale. I have viewed the target
location involved in this investigation and I have found
that it has windows which overlook entry doors,
walkways and roadways approaching the premises
which must be used by police officers to gain entry to
said premises. Because of this, the ability of the
occupants to detect police officers approach is made
more likely as is it more likely that they can prepare to
Although not known to officers prior to executing the search warrant, their investigation wouldlater reveal that on multiple occasions, neighbors had heard gunshots coming from withinNavarrete and Dennis-Ramirez's second-floor apartment.