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us ATTORtEV

UNITED STATES DISTRICT COURT

DISTRlCT OF MAR.YLAND

UNITED STATES OP AMERICA

Y.

DARRELL CORNELIUS FRANCIS

r. the undersigned complainant. being duly sworn stare the following is true and correct to the best of Y.1\owlcdge and belief. On or about May 1 t!)rough. September! J , 2006, in the Distcict of Maryland and "11!1"w1~~i'I"': the defendant, (T, .. ~ 3IJ"'0'7 L""'''R. O'(C/11C)

Aundre Sherrod Reese and Darrell Cornelius Francis. did knowiogly. intenncnally and unlawfully conspire to distribute a mixture or substance containing 5 kilograms or more of cocaine, a Schedule n controlled substance

10 violation of Tille -fL United States Code. Scction(Ii)~

The affiant further slates that he is..i..Jask Force Officer of the Drug Enforc~meot Administr.ati9D. and that this

compillint is based on (he following fact": O,Od., Ti~,

SEE A IT ACHED AFF(DA VIT

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Connnued on the attached sheet and made a part hereof: ~ Yes 0 No

Date and Time Issued

at ' Baltimore. Maryland

Mark Lunsford, Special Agent Drug Enforcement Administration

Sworn to before me and subscribed in my presence.

/i- -t -IH

;ieth P. Gesner United States Magistrate Judge

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AFFIDAVIT

This affidavit is submitted in support of applications for criminal complaints charging

Your A(flant

Aundre Sherrod Reese and Darrell Cornelius Francis with conspiracy to distribute controlled

substances, to wit: five (5) or more kilograms of cocaine in violation of21 U.S.C. §846.

Your affiant, Mark Lunsford, is a Task Force Officer with the DEA, and is a law

enforcement officer of the United States within the meaning of Section 2510(7) of Title 18

United Slates Code, that is, an officer empowered by law to conduct investigations of. andn' , "'1C""h"'-'

arrests for, offenses enumerated in Section 2516 of Title 18, United States Code.

Your affiant is currently a Baltimore City Police Department detective assigned to the

narcotics unit, and has been employed by that police force for over ten (10) years, Your affiant

111t.-~ .

~. d. rrt-t4as received formal training in the fields of identification, investigation, methods of

concealment, and distribution of controlled dangerous substances.

Your affiant has participated in at least thirty (30) investigations of unlawful drug

trafficking. Your affiant has made or participated in the arrest of over 100 individuals for

violations of the narcotics laws of the United States of America and the State of Maryland. Your

affiant has also participated in at least 50 debriefings of individuals involved in the abuse and/or

trafficking of controJled substances, where details of the respective individual's abuse and/or

trafficking of controlled substances were imparted. Your affiant has made at least ten (10) .

affidavits 10 support of search and seizure warrants related to violators and violations of crjminal,~':·· narcotics laws. and has participated in [he execution of over one-hundred (100) search and

seizure warrants that have targeted violations and violators of criminal narcotics laws, by which

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where large amounts of contraband narcotics and narcotics-related paraphernalia were seized.

" . ,~

Your affiant has participated in at least five (5) investigations that have employed court-ordered

wiretaps as an investigative tool, and thereby has listened to, transcribed and read transcripts of

telephone conversations of individuals involved in narcotics trafficking.

Through the above-described training and experience, your affiant is familiar with the manner in which illegal narcotics are transported, stored, and distributed, and with the methods

of payment for such drugs, including but not limited to street terminology used in connection with narcotics transactions, the prices for and quantities of drugs that are distributed .at the ,. ,.,.'.~"".'.

wholesale and street levels, the manner in which narcotics are packaged for distribution, the

means by which narcotics are imported both locally and nationally, the quality of drugs, and the

use of stash locations and vehicle traps, the use of counter-surveillance techniques, and the

organizational structure of drug enterprises.

Confidential Informant 1

The below-described facts and circumstances include incidents and information your

affiant received/observed first-hand, as well as information received by other agents/officers

associated with this investigation who then related it to your affiant. The following narrative

does not recite every fact or circumstance known to your affiant about the narcotics trafficking

activities of Lionel McCoy, Darnell Williams, et al.

During the period December, 2005 to the present, agents associated with this

investigation have been in contact with a confidential informant registered with the DEA. This

individual will hereinafter be referred to as CI-l. Information imparted by CI-I has led (0 the

identification of several multi-kilogram cocaine and heroin dealers in the Baltimore metropolitan

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In debriefing CI-l, he/she has related that a male known to him/her as "Man Man", who

area. Cl-l is not cooperating with Jaw enforcement in return for any possible leniency in a

pending criminal matter. In fact, to your affiant's knowledge there are no current criminal

charges pending against CI-l, and none are contemplated. CI-l has received DEA monies in

return for information he/she has imparted. As outlined below, while under police supervision

and surveillance. CI-l has within the past calendar year purchased cocaine from a target of the.. .

'.I""","f

instant investigation, To your affiant's knowledge, all information imparted by Cl-l has provedr"f!

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truthful and accurate, and on that basis, your affiant believes the 0-1 is a credible and

source of information.

resides in the Dundalk area of Baltimore County. Maryland. supplies multiple drug distributors

1:1 the Baltimore metropolitan area with both cocaine and marijuana. eI-1 described "Man Man"

as an African-American male in his thirties having bald/close shaven hair and G. goatee. Agents

Earlier this year, CI~ 1 related Thomas was then using a cellular telephone. According to", "'.' , ... ,

familiar with an individual named Larry Mitchell Thomas (Thomas) knew that he had the nick-

name ofuMan Man" and matched the physical description given by Cl-L A photograph of

Thomas was shown to CI-l, who indicated that it. depicted the individual he/she knew as "Man

Man", On that basis, hereinafter, the names Larry Thomas and "Man Man" will be used

interchangeably to reference the same individual.

CI-l, when/if he/she wanted to purchase cocaine from Thomas, he/she contacted Thomas on that",

cellular phone, and that they would then have a conversation by which arrangements were made

for Thomas to deliver an amount of cocaine 10 CT-1 for an agreed-upon price.

..'

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In regard to Thomas's narcotics trafficking activities, Cl-l indicated that he/she is aware

that Thomas supplies an unknown number of subjects with amounts of cocaine and marijuana.

In that regard, CI-l has identified an individual he/she knows only as "Lonnie," who he/she identified as a source of the cocaine Thomas distributes. According to CI-I, "Lonnie" is an

African-American male who resides in the Baltimore area, and runs a bar known as "Bre's".

located on Belair Road in Baltimore.

According to State of Maryland records, Lionel McCoy is a resident agent for "Bre's I' and Grill" on Belair Road in Baltimore. According to the NCIC criminal record database, Lionel'"

McCoy (McCoy) has a 1997 conviction for a criminal handgun violation and a 2000 conviction for controlled substance possession. Your affiant showed a Maryland MVA photo cf Lionel

McCoy to CI-l. who identified McCoy as the individual he/she knew as "Lonnie". Hereinafter,

In furtherance of'rhis investigation, during the third week of January, 2006, while in the '''i'

McCoy and "Lonnie" will be use interchangeably to identify the same individual.

According to Georgia law enforcement authorities, during August 2005, McCoy was arrested in suburban Atlanta on an outstanding warrant, and in the vehicle from which he was

arrested there was recovered a black bookbag in which approximately $26,000.00 U.S. currency

was found. Your affiant knows through his training and experience that Atlanta, Georgia has

recently been an increasingly prominent "source city" for the cocaine that is distributed in the,

Baltimore metropolitan area. On that basis, your affiant believes that McCoy's possession of a:, :",

~ ".: ' -,. ! .

large sum of currency in the Atlanta area. is consistent with narcotics-related activity.

presence and under the supervision of law enforcement agents, CI-I placed several telephone

calls to a individual who identified himself as and/or answered to the name "Man Man", These

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phone calls were overheard by supervising law enforcement agents, and recorded with the

consent of Cl-L In response to Cl-I 's request to purchase contraband, "Man Man" instructed

CI-] to meet him at a designated location to discuss the sale, During these calls, CI-l and

Thomas did not overtly or explicitly refer to the cocaine that was the subject of-their

conversation, employing instead coded or guarded language to reference that subject, but did' discuss the price of the cocaine. Your affiant knows through his training and experience that.» i because of the clandestine nature of their business, those involved in narcotics trafficking often"::' ....

employ such coded/guarded language to disguise the true nature of their communications.

In preparation for the scheduled meeting with "Man Man", CI-l and his/her vehicle were

. "i' .,

thoroughly scorched and found to be free from contraband and cash. CJ-l was then supplied

Based on the foregoing and other circumstances, during May, 2006, the Honorable John .

with an amount of DEA funds designated for undercover purchases of contraband. Cl-I was

kept under constant police surveillance as he/she drove to the scheduled meeting with Thomas.

CI-I was observed to meet Thomas at the appointed place, and then after a briefdiscussion with

Thomas, to leave that meeting and return directly [0 your affiant. At that point. CI-l was found

to be in possession of an amount of white powder, which was later analyzed by certified DEA

chemists and found to be cocaine. According to cr-}, he/she obtained this cocaine from

Thomas.

Glynn (Judge of the Circuit Court for Baltimore City. Maryland) authorized the wiretap

interception of narcotics-related conversation that took place over a cellphone Thomas was then

using. Once interception of those communications was authorized, the investigating agents

r"'"

Intercepted narcotics-related conversations between Thomas and Lionel McCoy, who as outlined

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above was a suspected source of contraband for Thomas. Based on those intercepted conversations, Judge Glynn issued orders on June 1 s" 28lh and 291b, 2006 authorizing the

interception of narcotics-related wire communications of Lionel McCoy, among others. Once

interception of those communications was authorized. the investigating agents intercepted

narcotics-related conversations between McCoy and an individual who identified himseIfu./..l".>1'!f~.

"Nellie" (phonetic). "Nellie" was later identified through this investigation as Darnell Wit

(Williams). Based on a review of calls between "Nellie" and McCoy, it was believed that

"Nellie" was a confederate of McCoy in the distribution of contraband in the Baltimore

metropolitan area. Accordingly, an application was made for a wiretap order authorizing the

interception ofnarcotics-relatcd communications over a cellphone that was being used by

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I'·,

Intercepted Communications

"Nellie" for that purpose. On June 28, 2006, Judge Glynn granted that authority via his wiretap

order authorizing interception of narcotics-related communications over that cell phone.

The following narrative recites the details of certain phone conversations intercepted by

law enforcement agents pursuant to the various wiretap orders issued by Judge Glynn in relation! ..

to this investigation.

On July 10,2006, at approximately 12: 18 a.m., an outgoing call was placed by McCoY.'~;;~~!IIH

phone number 718-539-7382. Law enforcement agents assigned to this investigation have

observed Francis use [his telephone at a time they knew him to be in communication with other

participants in the narcotics conspiracy here under investigation. In that way, Francis has been

identified as the actual user of this cellphone, During this communication, McCoy indicated to

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Francis that be was in the "An. According to cell-site information, McCoy was using his phone

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at the time in Atlanta, Georgia, and therefore your affiant believes that the allusion to "the A" is a reference to Atlanta. Francis replied, «Alright. WeU, shit, we going ah to check on everything tomorrow" McCoy replied that he would be "waiting for the call". Francis then told McC<;,)I" that, "the Mexicans been hitting me up like a mother-fucker". McCoy replied, "Ohshit,

everything good. I'm just waiting, just waiting for somebody tell me something."

Your affiant knows from his training and experience, that in fear of being detected by 1~\V' enforcement, those involved in narcotics trafficking commonly speak obliquely about the

This interpretation is corroborated by a call intercepted on July 14, 2006, where a male

narcotics that are the true subject matter of their communications, using coded/guarded language

for that purpose. In that light, your affiant believes that in the above conversation, McCoy and

Francis were discussing arrangements concerning an impending narcotics transaction. Of

particular significance is Francis's reference to the Mexicans' impatience with matters ("them

Mexicans been hitting me up like a mother fuckcr"). Your affiant knows through his training

and experience that Mexican sources of contraband represent an increasingly SIgnificant role as

sources for the contraband that is distributed in the Baltimore metropolitan area. In respons~,tOi<"'"

that comment, McCoy indicated that he was just waiting for certain circumstances to occur

before he could further the process along ("Pm just to waiting for somebody to tell me

something").

speaking in a Mexican-accented voice spoke to McCoy. During that conversation, the Mexican

male related to McCoy 7 "1 was trying to get in touch with you because, they say you're gonna go

713718:3307

tell [hem my brother give you the Jist thing. Remember he, he, he spoke to you, he gave you 25, 25,30, and 25 right?" McCoy replied, "The last time I was there, he had 30 for me but he didn't

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give it to me." In this conversation, your affiant believes the parties were discussing a prior history of narcotics transactions where McCoy had obtained 25 and 30 kilogram amounts of ... ,'.

contraband from the caller's brother.

. .

On July 20, 2006, McCoy received an incoming call from Aundre Sherrod Reese n,h"".;.'"

used cellphone number 718-539-7382 (the same cellphone previously used by Francis, as

outlined above) to place that call. During the course of this conversation, Aundre Sherrod Reese

(Reese) asked McCoy, "You got the check with you in the A?". McCoy answered that he was ." ..

"waiting for him [0 bring it to me now." According to service provider cell-site information, at

at the time of this conversation, McCoy was in Atlanta, and on that basis your affiant believes

Reese's allusion to "the AI> is a reference to Atlanta, Georgia. Further, in this conversation,

your affiant believes that Reese was asking McCoy whether he had with him money for a

narcotics transaction ("You got the check with you?"). McCoy's response indicates that he was

expecting the arrival of the money SOO1). Your affiant notes that over the course of days

surrounding this intercepted call, there were intercepted other calls where "Nellie" (Darnell

Williams) was overheard arranging for an individual to travel to Atlanta. In that light, it

to your affiant that "Nellie" was cornplicit in arranging for the transport of narcotics-related

monies to Atlanta for McCoy.

Pursuant to the wiretap orders issued in furtherance of this investigation, the investigating

agents/task force officers knew that on July 25, 2006, McCoy was in the At1anta, Georgia area

when at approximately 3:00 p.m. he made an outgoing call to a phone number assigned to a cell

phone subscribed to in Mexico. During the call. McCoy spoke to an unknown individual who spoke English with a Hispanic accent, and told him that he (McCoy) had something for him.

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During that call, the Hispanic individual instructed McCoy to meet him in an hour. At

approximately 4:30 p.m. that same day, McCoy was observed to depart an Atlanta-area

apartment that McCoy, Williams and others associated with their narcotics trafficking had

\ i' "1

heard to refer to as "the Clubhouse", and drive to an apartment complex located on Boggs

in Duluth, Georgia.

A little after 5:00 p.m. that same day, another outgoing call to the same cell

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made by McCoy and was intercepted. During the course of that call, an .,:. ·;)IJ"uu",·

t

,

McCoy that the entry code for the gate at the Boggs Road apartment complex I

.

inside that gated community, McCoy drove directly to a particular building.

location, McCoy was observed to meet four individuals, and give them a backpack, which one6f ,I

the individuals then took into apartment #727. McCoy then appeared to argue with the other

individuals, and then drive from the Boggs Road complex without receiving anything in return.

On July 27, 2006, agents assigned to this investigation observed an individual, later, '

I;l: .

identified as Victor Olvera emerge from apartment #727 of the Boggs Road apartment campi'

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i

carrying several shoeboxes and a black suitcase which he placed in a black Ford Expedition.' .,

,

Olvera was then observed to drive the vehicle to another apartment complex in Duluth,

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I d

where he remained for several hours. Olvera was later that same day stopped by-police

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driving the Expedition in the immediate area of the Boggs Road apartment, Olvera ~as fo .

be driving with an expired driver's license. Olvera consented to a search ~fthe'!J~h~J\~, ., ' .

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resulted in the discovery and ultimate seizure 0[$807,070.46 U.S. currency from' the shoeboxes>~'.:, .

Olvera had been earlier observed placing in that vehicle. When interviewed Olvera indicated

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t rat IS possession 0 t rat currency resu te IS wor In construction.

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Based on the foregoing, your affiant believes that the seized monies wereattri

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McCoy and Williams and that it had been transported down to the Atlanta! area i11"

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their narcotics activities. ! 1/, ~ :!l'1 '1

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During the week beginning August 21, 2006, there were intercepted ph~n~ <j

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communications indicating that McCoy and Williams were arranging the ~urchak~ of a large ;;,. '

amount of cocaine from Texas from Reese.

On August 21, 2006, Darnell Williams received two phone calls from 281-838-4590.

According to service provider records, that cellphone is subscribed to by Aundre Reese of

Houston, Texas. During the course of this investigation, agents have observed Reese in

,I

conversation with others while using this cellphone, and in that manner have been able to

II

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identify Reese as not only the listed subscriber of the phone, but also its user. During this

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conversation, Reese indicated that, "My man called me late last night. .. and we $l;l()UI,? be

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today." Williams replied, "Alright I fly down there Wednesday?" Williams coijFn.u~~ari~.:rt

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explained that he wanted to straighten out a few more things with Reese. lIn th~thidale of

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conversation, the connection between the phones was lost. A follow-up call ensued during ;

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1

which Williams told Reese that he would be coming to Texas on Wednesday. Based on your

affiant's training and expertise it is believed that these two calls concerned Reese supplying

Williams with an undetermined amount of cocaine. In your affiant's opinion, when Reese stated

I j 11

On August 22, 2006, Williams placed an outgoing call to Reese. During this ,I

that his "man" had called him and that "we should be ready today", he was indicating to

Williams that he expected to have cocaine available for distribution in the immediate (uture, 1\;

I

conversation Williams asked, "I gonna have to go to the A?". Reese replied, "No."

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then asked, "Oh, it's gonna be in my backyard?", and Reese replied, "Yeah."

believes that in this conversation, Williams was asking Reese if he had totravel'to A~

,

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gonna have to go to the A?"), to receive a shipment of cocaine in question, but Reesd'

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the cocaine would not be going to Atlanta, but would be delivered somewhere closetlto the-

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Baltimore metropolitan area (UOh it's gonna be in my back yard?"). ii' 'i

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On August 29, 2006, Williams made another outgoing call to Ree~e. Duri~g this

conversation Williams confirmed with Reese that the plan was now to bring the shipment to

Baltimore.

Based on other intercepted conversations, investigators believed that the shipment of .

contraband was being transported in a vehicle being driven by an individual identified as

. .

Floyd. Law enforcement officers were able locate Floyd as he drove a Ford van northbound m:,IJI,tru,ru

Richmond, Virginia. Floyd and his van were stopped in Maryland and foJnd to contain 25. ;

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kilograms of cocaine and a handgun. Floyd was then arrested and charged with a~arqotics'l!i·

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felony.

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After Floyd's arrest, numerous calls between Williams, Reese and pranc~~:\V~te

intercepted where they voiced their concern about the whereabouts of Floyd, who 'unbeknownk,'· •.

: • -: j.',' t t~ ':

to them had been arrested in relation to this investigation. In fact, on August 31,2006, agents

related to this investigation observed that Williams picked up Darrell Francis at BWI airport

after Francis had flown to Baltimore from Houston (Texas) via Atlanta (Georgia).

Based on the foregoing, your affiant believes Aundre Sherrod Reese and Darrell

Cornelius Francis did conspire with each other and with others to distribute controlled

substances, to wit: five (5) or more kilograms of cocaine in violation of 21 U.S.c. §846 .

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Your affiant, Task Force Officer Mark Lunsford, affirms under penalties of perjury that

the facts and circumstances recounted in the foregoing affidavit are true and accurate to the best

. ~"

of his knowledge and belief.

Date

Mark Lunsford, Task Force Officer Drug Enforcement Administration

Signed to and sworn before me this

7 11t day of November, 2006.

~/.~.

~ 7 . \

.t:Seth P. Gesner

United States Magistrate Judge for the District of Maryland

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