BGF 2010 Warrant

appearance and habits of drug dealers and users.
Through my
training, education and experience, I have become familiar with the
manner in which illegal drugs are transported, stored, and
distributed; the methods of payment for such drugs; the possession
and use of firearms in connection with the trafficking of such
drugs; and the manner in which narcotics traffickers store and
conceal the proceeds of their illegal activities.
2. This affidavit is being submitted in support of an
application for search warrants for the premises set forth below:
THE PREMISES KNOWN AND DESCRIBED AS 1120 HOMEWOOD AVENUE,

BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT
PREMISES #1"). SUBJECT PREMISES #1 is a residence of
Kimberly McIntosh;
THE PREMISES KNOWN AND DESCRIBED AS 4007 FORDLEIGH ROAD,

APARTMENT C, BALTIMORE, MARYLAND AND ITEMS CONTAINED
THEREIN ("SUBJECT PREMISES #2"). SUBJECT PREMISES #2 is
a residence of Todd Duncan, a/k/a “Donnie;”
THE PREMISES KNOWN AND DESCRIBED AS 237 EAST LAFAYETTE

STREET, 2ND FLOOR, BALTIMORE, MARYLAND AND ITEMS CONTAINED
THEREIN ("SUBJECT PREMISES #3"). SUBJECT PREMISES #3 is
a residence of Duconze Chambers, a/k/a “Ducon;”
THE PREMISES KNOWN AND DESCRIBED AS 1502 AISQUITH STREET,

Lamont Crooks;
THE PREMISES KNOWN AND DESCRIBED AS 2004 BALTIMORE

STREET, BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN
("SUBJECT PREMISES #5"). SUBJECT PREMISES #5 is a
residence of Davon McFadden, a/k/a “Ben;”
THE PREMISES KNOWN AND DESCRIBED AS 1204 WILCOX STREET,

PREMISES #6"). SUBJECT PREMISES #6 is a residence of Jon
Brice, a/k/a “Tiger;”
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THE PREMISES KNOWN AND DESCRIBED AS 1619 RIVERWOOD ROAD,
James Harried, a/k/a “Smiley;”
THE PREMISES KNOWN AND DESCRIBED AS 5305B VALIQUET ROAD,

PREMISES #8"). SUBJECT PREMISES #8 the residence of
James Bullock and potential stash location for Duncan;
THE PREMISES KNOWN AND DESCRIBED AS THE DESK OF KIMBERLY

McINTOSH LOCATED INSIDE TOTAL HEALTH CARE, 1501 DIVISION
STREET, BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN
("SUBJECT PREMISES #9"). SUBJECT PREMISES #9 is the work
station of Kimberly McIntosh;
THE PREMISES KNOWN AND DESCRIBED AS 304 EAST 21ST STREET,

Eric Ushry, a/k/a “E;”
THE PREMISES KNOWN AND DESCRIBED AS 1701 HARFORD AVENUE,

PREMISES #11"). SUBJECT PREMISES #11 is the residence of
Sherice Foster;
3. Based on the facts set forth in this affidavit, I
respectfully submit that there is probable cause to believe that BGF
is engaged in an ongoing and continued pattern of violations of
federal law and that there is presently concealed in the premises
set forth above (collectively “the SUBJECT PREMISES”) the items set
forth in the respective attachments hereto, all of which constitute
evidence, fruits, and instrumentalities of, inter alia, violations
of 18 U.S.C. § 1962, which prohibits participation in a racketeering
conspiracy; 21 U.S.C. §§ 841 and 846, which prohibits the
distribution and possession with intent to distribute controlled
substances, and conspiracy to commit those offenses; 21 U.S.C. §
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843, which prohibits the use of a communication facility in
furtherance of drug-trafficking; and 18 U.S.C. § 1959, which
prohibits violent crimes in aid of racketeering.
4. Because this Affidavit is being submitted for the
limited purpose of establishing probable cause for warrants to
search the premises set forth above, I have not included every
detail of every aspect of the investigation. Rather, I have set
forth only those facts that I believe are necessary to establish
probable cause. I have not, however, excluded any information known
to me that would defeat a determination of probable cause. The
information contained in this Affidavit is based upon my personal
knowledge, my review of documents and other evidence, and my
conversations with other law enforcement officers and other
individuals. All conversations and statements described in this
Affidavit are related in substance and in part unless otherwise
indicated.
I. Background
5. Since September 2008, DEA’s Special Investigations
Group (DEA SIG) has been conducting an investigation of the “Black
Guerilla Family” (BGF), a violent gang that operates in prison
facilities and major cities throughout the United States, including
in Baltimore, Maryland. The investigation has involved, among other
things:
a. physical surveillance in multiple locations,
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including the locations of the SUBJECT PREMISES;
b. debriefings of multiple confidential informants
(“CSs”);1
c. seizures of narcotics and narcotics proceeds and
other contraband;
d. review of monitored telephone calls over prison
telephones; and
e. electronic surveillance of cellphones used by BGF
members and leaders and their associates.
6. As more fully described below, the evidence obtained
through these and other means has established that BGF is a violent
gang that is engaged in drug-trafficking, extortion, and acts of
violence in Baltimore City and elsewhere.
7. The initial phase of this investigation was conducted
in February through April of 2009. During this period, DEA SIG
utilized wire intercepts of several cellular phones, including
contraband cellphones utilized by incarcerated members of BGF, which
demonstrated a pattern of racketeering activity and BGF’s control
of various prison facility.
8. On April 8, 2009, a Federal Grand Jury sitting in the
District of Maryland returned separate Indictments charging a total
of 25 BGF members and associates with drug-trafficking and other
offenses (“the 2009 Indictments”). Specifically, one Indictment
1
The reliability of each of the CSs is discussed below.
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(the “Brown Indictment”) charged Eric Brown and thirteen others,
including Deitra Davenport, Rainbow Williams, Marlow Bates, and
current or former corrections employees Terry Robe, Asia Burrus,
Musheerah Habeebullah, and Takevia Smith, with participating in a
conspiracy to distribute and possess with intent to distribute
controlled substances, in violation of 21 U.S.C. § 846. The same
indictment also charged Randolph Edison, Roosevelt Drummond, and
Zachary Norman with involvement in the drug conspiracy as well as
participation in a Hobbs Act robbery conspiracy, in violation of 18
U.S.C. § 1951. A second Indictment (the “Glasscho Indictment”)
charged Kevin Glasscho and 10 others, including Cassandra Adams,
Tyrone Dow, Calvin Robinson, Avon Freeman, James Huntley, Darnell
Holmes, a/k/a “Moe,” Darryl Taylor, Joe Taylor-Bey, a/k/a “Joe
Taylor,” Darien Scipio, a/k/a “Reds,” and Lakia Hatchett, with
participating in a conspiracy to distribute and possess with intent
to distribute one kilogram or more of heroin, in violation of 21
U.S.C. § 846. All of the offenses charged in these Indictments were
committed in furtherance of, or were committed by members of, the
BGF racketeering enterprise. In conjunction with the arrest
warrants for the 2009 Indictments, law enforcement executed 13
search warrants on various locations in and around Baltimore City,
as well as searches of 16 separate jail cells of alleged BGF members
located in various prison facilities throughout the State of
Maryland. As a result of these search warrants, law enforcement
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recovered approximately 500 grams of heroin, firearms, drug
paraphernalia and packaging material, BGF literature and hundreds
of documents and photographs linking the various members of the 2009
Indictments to each other and to BGF. Several of these individuals
have already pled guilty for their part in the conspiracy to
distribute and possess with the intent to distribute heroin,
including Robe, Habeebullah, Burrus, Smith, Robinson, Freeman,
Taylor, Taylor-bey and Hatchett.
9. Information developed during the initial
investigation, as well as from various cooperating witnesses,
demonstrated that the BGF was attempting to utilize the same
paramilitary structure successfully used by the enterprise in
prison, to control the heroin trade in Baltimore City.
Electronic Surveillance of BGF
10. On February 5, 2010, the Honorable J. Frederick Motz,
United States District Judge, signed an Order pursuant to Title 18,
United States Code, Section 2518, authorizing the Government to
intercept wire communications occurring over the cellular telephone
assigned call number (443)378-1737 and bearing international mobile
subscriber identity (“IMSI”) #316010166475527 (the "CHAMBERS
CELLPHONE” OR TARGET CELLPHONE #1), used by DUCONZE CHAMBERS, a/k/a,
“Duconze, a/k/a “Ducon,” with service provided by Sprint/Nextel,
including through the use of Sprint/Nextel’s Direct Connect/Dispatch
Services. Interception pursuant to this Order began on February 8,
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2010 and was terminated on April 7, 2010.
11. On March 1, 2010, the Honorable J. Frederick Motz,
subscriber identity (“IMSI”) #310410290776119 (the "DUNCAN
CELLPHONE” OR TARGET CELLPHONE #2), used by TODD DUNCAN, a/k/a,
“Donnie,” with service provided by T-Mobile. Interception pursuant
to this Order began on March 1, 2010 and was terminated on March 15,
2010.
subscriber identity (“IMSI”) #310260460554293 (the “Crooks
CELLPHONE” or "TARGET CELLPHONE #3"), subscribed to Lamont Crooks,
200 Patterson Park Avenue, Baltimore, Maryland and utilized by
LAMONT Crooks, with service provided by T-Mobile; and wire
communication occurring over the cellular telephones assigned call
number (410)599-5750 and bearing international mobile subscriber
identity (“IMSI”) #310410261755076 (the “COIL CELLPHONE” or "TARGET
CELLPHONE #4"), subscribed to COIL, 1200 West Baltimore Street,
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Baltimore, Maryland and utilized by TODD DUNCAN, with service
provided by T-Mobile. Interception pursuant to this Order began on
March 16, 2010 and is ongoing for the Crooks Cellphone, but
interception of the Coil Cellphone was terminated on April 7, 2010.
subscriber identity (“IMSI”) #310260254237302 ("TARGET CELLPHONE
#5"), subscribed to Aja M. Trice, 5307 Tramore Road, Baltimore,
Maryland 21214, used by TODD DUNCAN, a/k/a, “Donnie,” with service
provided by T-Mobile. Interception pursuant to this Order began on
March 25, 2010 and was terminated on April 7, 2010.
14. On April 6, 2010, the Honorable J. Frederick Motz,
assigned call number (410)913-6234 and bearing electronic serial
number (“ESN”) #03510747825/23A3FFB1 ("TARGET CELLPHONE #6"), with
an unknown subscriber, used by KIMBERLY McINTOSH, a/k/a, “Sister
Kim,” with service provided by Verizon Wireless. Interception
pursuant to this Order began on April 6, 2010 and is ongoing.
15. Pursuant to these wiretaps, other law enforcement
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agents and I intercepted hundreds of calls in which BGF members made
arrangements for narcotics transactions and discussed acts of
violence in furtherance of their racketeering enterprise.2
III. The Indictments
16. On April 7, 2010, a Federal Grand Jury sitting in the
District of Maryland returned an Indictment charging a total of 12
BGF members and associates with drug-trafficking (the 2010
Indictment”). Specifically, the 2010 Indictment charges Todd
Duncan, a/k/a “Donnie,” Kimberly McIntosh, a/k/a “Sister Kim, “ and
ten others, including Lamont Crooks, Duconze Chambers, a/k/a
“Ducon,” Jermain Davis, a/k/a “Dirty Rice,” Jon Brice, a/k/a
“Tiger,” Davon McFadden, a/k/a “Ben,” Ronald Scott, a/k/a “Piper,”
Earl Moore, James Harried, a/k/a “ Smiley,” Eric Ushery, a/k/a “E,”
and Sherice Foster with participating in a conspiracy to distribute
and possess with intent to distribute heroin, in violation of 21
U.S.C. § 846. The offense charged in this Indictment was committed
in furtherance of, or were committed by members of, the BGF
racketeering enterprise.
2
Based on my training and experience, I know that
narcotics traffickers often use codes when speaking on the
telephone about their illegal activities, and, specifically,
often speak in code about narcotics, quantities of narcotics,
payments for narcotics, and the proceeds of narcotics-related
transactions. Where I have described those conversations in this
affidavit, I have done so only in substance and in part. Based
on my training and experience and other investigation in this
case, including other intercepted calls, I have included my
interpretation of these calls in brackets and at the end of the
summary of each call.
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IV. The BGF Criminal Enterprise
A. Overview
17. As more fully described below, BGF is attempting to
take over the illegal drug trade at multiple locations in Baltimore,
Maryland and is committing drug-related acts of violence as part of
its continued efforts to expand its influence from inside the prison
walls to the streets of Baltimore. The evidence obtained to date
has established that BGF is active in numerous prison facilities in
Maryland, including, among others, North Branch Correctional
Institution (NBCI), Western Correctional Institution (WCI), Eastern
Correctional Institution (ECI), Roxbury Correctional Institution
(RCI), Maryland Correctional Institution – Jessup (MCIJ), Maryland
Correctional Institution – Hagerstown (MCIH), Baltimore City
Correctional Center (BCCC), Metropolitan Transition Center (MTC),
the Maryland Correctional Adjustment Center (MCAC), and the
Baltimore City Detention Center (BCDC). The evidence further
indicates that individual members, who have been released from
prison, have established regimes throughout Baltimore City. Each
section of the City functions as a regime, much like an individual
prison facilities. Each area, like each prison, has a commander and
a host of other positions or ranks, who report directly to a central
authority. The entire BGF organization is then controlled by this
central command structure, who are responsible for authorizing BGF
activities, including the collection of dues, the distribution of
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drugs, and the authority to engage in acts of violence.
18. Some of the leaders and members of BGF on the streets
of Baltimore, Maryland include, among others, the following:
a. KIM McINTOSH, a/k/a “Bonita Kim,” a/k/a “Sister
Kim,” (hereinafter “McIntosh”) who is responsible for coordinating
and overseeing BGF finance, overseeing the punishment of non
compliant BGF members and rival drug traffickers, and acts as a
processing and distribution manager for heroin trafficking in
Baltimore, Maryland. An inquiry into McIntosh’s criminal history has
revealed no arrests;
b. TODD Duncan, a/k/a “Donnie,” a/k/a “Donnie
Duncan,” (hereinafter “Duncan” or “Donnie”) has been identified as
the overall commander for BGF operations throughout the entire
Baltimore metropolitan area. Duncan oversees and coordinates the
criminal activity attributed to BGF in the Baltimore metropolitan
area. Duncan is the overall decision maker regarding BGF
activities. An inquiry into Duncan’s criminal history has revealed
convictions for 1st degree murder and attempted murder;
c. Lamont Crooks (hereinafter “Crooks”) has been
identified as a BGF affiliate, who is one of the heroin sources of
supply for BGF and others in the Baltimore metropolitan area. An
inquiry into Crooks criminal history has revealed convictions for
assault with intent to murder and felon in possession of a handgun.
Lamont Crooks is currently on federal supervised release after
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serving a 46 months sentence for being a felon in possession of a
firearm;
d. ERIK SEANTAE USHRY, a/k/a "E," (hereinafter
“Ushery”) has been identified as a BGF affiliate who purchases large
quantities of heroin from Crooks and utilizes McIntosh to mix and
package the heroin. An inquiry into Ushry’s criminal history
revealed convictions for possession with the intent to distribute
drugs;
e. DUCONZE CHAMBERS, a/k/a “Duconze,” a/k/a “Ducon,”
(hereinafter “Chambers”) has been identified as a high ranking BGF
member who distributes heroin for Todd Duncan in the eastern portion
of Baltimore City. An inquiry into Chambers criminal history
revealed convictions for assault with intent to murder and a handgun
violation;
f. RONALD SCOTT a/k/a "PIPER," (hereinafter “Scott”
or “Piper”) has been identified as a member of BGF who assists
Duncan with the distribution of heroin in Baltimore City. An
inquiry into Scott's criminal history has revealed no convictions;
g. DAVON McFADDEN a/k/a "BEN," (hereinafter
“McFadden” or “Ben,”) has been identified as a high ranking BGF
member who assists in the distribution of heroin for BGF. An
inquiry into McFadden's criminal history has revealed convictions
for possession with the intent to distribute drugs and possession
of a firearm;
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h. JAMES HARRIED a/k/a "Smiley," (hereinafter
“Harried” or “Smiley”) has been identified as a high ranking BGF
member who is responsible for investigating violations of BGF
protocol. An inquiry into Harried's criminal history has revealed
three convictions for possession with the intent to distribute
drugs;
i. JON DEVALLON BRICE a/k/a "Tiger Brice,” a/k/a
"Tiger," (hereinafter “Brice” or “Tiger”) has been identified as a
drug trafficker in the Baltimore area. An inquiry into Brice's
criminal history has revealed convictions for attempted manufacture
of a controlled substance and possession with the intent to
distribute drugs and two counts of drug possession;
j. DEVON LAMONT CRAWFORD, a/k/a “Taterman,” has been
identified as a hit-man for BGF who takes his orders from Duncan.
An inquiry into Crawford’s criminal history revealed a conviction
for second degree assault; and
k. JERMAIN DAVIS a/k/a “Dirty Rice, a/k/a “Man”
(hereinafter “Davis”) has been identified as a BGF member who
assists Duncan and McFadden in the sale of heroin in Baltimore.
Davis was arrested during the execution of a search warrant at his
home, where a quantity of heroin was recovered, on March 22, 2010.
An inquiry into DAVIS’s criminal history has revealed two previous
convictions for possession with the intent to distribute controlled
substances, a conviction for second degree assault, and a separate
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convictions for battery.
B. INFORMATION PROVIDED BY CONFIDENTIAL SOURCES
1. Confidential Source #1
19. During a series of debriefings between late November
2008 and January 2010, a reliable confidential informant CS1)3,who
is presently incarcerated and is a high-ranking member of BGF,
advised me and other investigators that BGF is a nationwide prison
gang with a presence in every correctional institution in the
country. CS1 related that he/she has been in various prisons
throughout the country and at each institution there has been a
faction of BGF. CS1 related that BGF is violent both inside and
outside prison, but that historically BGF has not been well-
organized outside of prison. CS1 stated that currently, BGF is
attempting to change this within Baltimore, Maryland by becoming
more organized and effective on the streets.
a. BGF Leadership
20. CS1 explained that within the prisons, BGF has a
group of individuals who are in leadership roles/positions of
authority and that this leadership group is known as the “Supreme
Bush.” All members, who are not in the Supreme Bush, are considered
part of the regime. The only place Bush members hold rank is within
3
The information provided by CS1 has consistently proven
reliable and has been corroborated by independent investigation,
and led, in part, to the identification and indictment of 23 BGF
members and associates. CS1 continues to provide information in
expectation of assistance with upcoming parole hearings.
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the correctional system; once a Bush member is no longer
incarcerated, he or she is considered a regular BGF member.
However, BGF members on the streets have taken on a new vision on
how things should be handled. CS1 explained that within months of
the unsealing of the 2009 Indictments, the structure and
organization of BGF began to change on the streets on Baltimore.
21. CS1 stated that Duncan has assumed the role as the
overall “city wide commander” of BGF on the streets of Baltimore.
Assisting Duncan in this role is McIntosh, who is the “Field
Marshall,” overseer of finance and one of the main “shot callers”
throughout the Baltimore metropolitan area - additional members,
including Chambers, “Commander of east Baltimore,” Thomas Burrell,
“Commander of South Baltimore,” Gerimo, China Man, Greyling Chase,
Tank Top, Bentley Dixon, a/k/a Benji, a/k/a Uncle Benji, and Matthew
Talley, a/k/a Gene.
22. CS1 reported that Duncan works as a youth counselor
for a non-profit organization, which he uses to conceal his
involvement with BGF. As BGF members are released from prison,
Duncan assists them in obtaining jobs which enables them to conceal
their illegal activities associated with BGF from law enforcement.
CS1 obtained Duncan’s office number, (410)752-8500, from other
members of BGF. Duncan uses this number for BGF members to reach
him when he is not available by cellphone.
b. Drug-Trafficking
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23. CS1 stated that drug trafficking both inside and
outside of prison is BGF’s primary means of making money, and is a
significant part of BGF’s activities on the streets of Baltimore.
CS1 stated that all violent crime, including murders, associated
with BGF, is related to its drug-trafficking activities. CS1
explained that BGF will sell any drugs, but primarily traffics in
cocaine and heroin.
c. Acts of Violence/Extortion
24. CS1 stated that BGF is extremely violent, both inside
and outside prison facilities, and is responsible for numerous
crimes of violence and related crimes, including robbery, extortion,
and murder for hire.
25. BGF leadership employs “Death Angels” or hitmen to
carry out murders on its behalf. CS1 related that only certain
people know the identity of each “Death Angel.” CS1 advised that
BGF will employ others to act as hitmen who may or may not be “Death
Angels.” According to CS1, there are enough violent members of BGF
to carry out murders.
26. CS1 advised that BGF members are required to learn
and abide by a code of conduct for the gang, and that BGF members
are periodically tested on their knowledge of the gang’s history and
rules. Members who fail to demonstrate adequate familiarity with
the gang’s history and rules are “sanctioned,” or beaten. During
the executions of the previous search warrants after the 2009
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Indictments, law enforcement recovered graded “tests,” from both
jail cells and at least one location searched as part of the initial
phase of the investigation.
27. CS1 reported that Eric Brown, indicted in the 2009
Indictments, published a book, "The Black Book – Empowering Black
Families and Communities" (hereinafter the "Black Book"). According
to CS1, Brown is purportedly distributing the book in order to
disseminate BGF doctrine, but that the Black Book is a ploy by Brown
to make BGF in Maryland appear to be a legitimate organization and
not involved in criminal activity. CS1 advised that Brown remains
a drug trafficker and that BGF funds its operations primarily by
selling drugs. During the executions of the previous search
warrants, law enforcement recovered copies of the “Black Book.”
28. During a series of debriefings, a confidential
informant (CS2)4, who is a high-ranking BGF member has provided
information regarding current BGF activities. During these
debriefings, CS2 provided the following names and associated
telephone numbers: William Rhodes, a/k/a “Jim Dog” (410)500-3790,
165*496*11477; Robert Jones, a/k/a “Seattle” (443)563-6196,
(443)909-5711; Nugget 165*493*56; Thomas Burrell, a/k/a “Cochise”
(410)690-2679; Bentley Dixon, a/k/a “Benji” (410)469-0682; Bird
4
CS2 is providing information in exchange for leniency
with criminal charges. CS2's information has been corroborated
to the extent possible and has proven accurate and reliable.
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165*492*652; Devon Butler, a/k/a “Body Target” (410)297-3793;
Stanley Brunson, a/k/a “Crackaz” 164*1008*1537; Dave (410)961-7979,
(443)623-6620, Dom (443)455-0904; Face (443)839-1556; Fase
183*935*41; Flatline (410)361-0386; Goat 164*1007*2346; (443)717-
9406; Hood 164*1014*4961; Jerry (443)623-1662; Jon Jon (410);710-
4692; Jr 165*497*1564; Kevin Moore (443)455-0322; Lil Ox
164*1014*5696; Lor Head (443) 790-4163; Mann (443)521-8210, Monkey
164*1007*13378; Pat 165*152156*1; Pimp (443)469-4433; Plak 164*1009-
2709; Rob 165*496*13846; Roe Roe 165*499*14119; Shaheed
165*493*11925, (202)731-5686; Shorts 164*1010*13322, 165*500*221;
Stevo 165*495*11003; Stizell 165*497*10563; Tank (443)500-2636; Tank
Top 165*498*10290 (443)224-6253; Will (443)992-1992; Wise
165*498*11514; Harris (443)790-7657. CS2 explained that BGF is
attempting to take control of the heroin sales in the McHenry and
Calhoun Street area in Baltimore City. CS2 advised that William
Rhodes, a/k/a Jim Dog, is a high ranking BGF member from South
Baltimore, who is trafficking heroin along McHenry Street and
Pennsylvania Avenue in Baltimore. CS2 stated that Rhodes had
recently been utilizing cellular telephone numbers (410)500-3790 and
(443)869-7458 along with push to talk numbers 165*496*11477 and
164*1012*7032 to conduct his drug trafficking activities. CS2
stated that the heroin is currently being sold under the name “Def
Jam.” According to CS2, a non BGF drug trafficker, identified only
as “Stizzel,” is Rhodes’s heroin trafficking competition in the
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McHenry Street area. CS2 explained that on November 16, 2009,
Rhodes advised that he wanted “Stizzel” either shot or a home
invasion conducted at his stash location.
29. On November 13, 2009, CS2 was debriefed regarding BGF
members operating in the southern portion of Baltimore City. CS2
stated that Thomas Burrell, a/k/a Gansta, a/k/a Cochise was
currently involved in heroin distribution and violence associated
with his drug distribution. According to CS2, one of Burrell’s BGF
associates is Rhodes. CS2 advised that Burrell was currently
utilizing cellular telephone number (410)690-2679 to conduct his day
to day BGF activities. CS2 also advised that McIntosh was
controlling BGF finance throughout Baltimore.
30. On November 23, 2009, CS2 was debriefed by law
enforcement officials regarding the BGF. CS2 advised that on
November 20, 2009, he/she was summoned to attend a BGF meeting in
Baltimore. Prior to the interview regarding the meeting, CS2
directed law enforcement to the location of the meeting, 1120
Homewood Avenue (SUBJECT PREMISE #1), the residence of McIntosh. CS2
was then debriefed on recent BGF activities.
31. CS2 advised that on Friday, November 20, 2009,
Bentley Dixon, a/k/a Benji was released from jail on a state drug
charge. Shortly after being released, Dixon telephoned CS2 and
requested a meeting in the Westport area of Baltimore City. Upon
arrival, CS2 advised that Dixon was speaking with Thomas Burrell.
20
CS2 advised that Dixon informed CS2 that Burrell and other BGF
members had accused CS2 of stealing money from BGF finance. Dixon
explained to CS2 that Burrell had been contacted by McIntosh
regarding the missing funds.
32. According to CS2, McIntosh was approached by a BGF
member, identified as “D,” who requested $500.00 from finance for
the purchase of a handgun. McIntosh informed “D,” that there was
not enough money available for his purchase. According to CS2, “D”
became upset because he (“D”) and other unidentified BGF members,
had been providing membership dues to CS2, which CS2 was suppose to
give to central finance for these purposes.
33. CS2 advised that McIntosh and “D” attempted to
contact CS2 regarding the missing funds, but were unsuccessful. In
response to the unanswered call, CS2 explained that McIntosh, Kareem
Randall, a/k/a Kareem, “D” and another BGF member, “J,” from
Brooklyn, Maryland met with Antonio Davis, a/k/a Tank Top, regarding
the missing funds.
34. According to CS2, a short time later, CS2 received a
telephone call from Antonio Davis. Upon answering the call, Randall,
using Davis’s phone, began yelling at CS2 about the missing funds.
During the same call, CS2 stated that McIntosh retrieved the phone
from Randall, identified herself and advised CS2 that there are some
issues that needed to be discussed regarding finance. McIntosh told
CS2 to speak with Duncan, and that Duncan would be waiting at E.
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Preston Street and Greenmount Avenue in east Baltimore
35. CS2 said that he/she attempted to explain to Dixon
that he/she was not responsible for any misappropriation of BGF
funds, but was advised that CS2 needed to explain things to Duncan.
36. CS2 stated that CS2 and Dixon responded to the area
of E. Preston Street and Greenmount Avenue. Upon their arrival, CS2
stated that he/she received an incoming call from BGF member “Twan”
from telephone number (410)558-7338. CS2 advised that “Twan” is a
heroin trafficker, who sells heroin in the area of N. Monroe and
Ramsey Streets. CS2 realized, however, that Duncan was using the
phone. Duncan instructed CS2 to respond to Homewood Avenue and
Biddle Street. Upon entering the block, CS2 observed BGF member
“Smiley” standing in front of 1120 Homewood Avenue, Subject Premise
#1.
37. CS2 advised that Dixon, Smiley, and CS2 then entered
1120 Homewood Avenue, Subject Premise #1. Upon entering the
residence, CS2 observed approximately 30 BGF members both known and
unknown to CS2, including Duncan, Smiley, McIntosh, Cutty, Kevin
Moore, Kareem Randall, Gerimo, and Antonio Davis, seated and
surrounding a central chair in the living room area of 1120 Homewood
Avenue, Subject Premise #1. In the center chair was Duncan.
38. As the meeting commenced, CS2 advised that it was
clear that CS2 and Dixon were being put on trial for
misappropriation of BGF funds. CS2 said that Duncan asked if CS2
22
was operating a “renegade wolf pack” by refusing to follow BGF
protocol. McIntosh then demanded to know whether CS2 had collected
money bound for finance, and whether or not CS2 told “D” that
Burrell had sanctioned a “hit” on an individual known as Gutter.
At that time, Duncan interjected and stopped the questioning. CS2
advised that Duncan, then pointed at Dixon and CS2 and asked if they
knew of Duncan’s position in BGF. McIntosh then advised that Duncan
had been voted, by high ranking BGF members, the new leader of BGF
outside of the prison system. CS2 stated that Duncan then advised
CS2 that he/she had been charged with stealing money from BGF
finance, and Dixon had been charged with knowing of the theft and
not correcting the problem. CS2 then said Kevin Moore, Gerimo,
Smiley, and an unknown BGF member walked into the kitchen and began
deliberating over the charges against CS2 and Dixon. CS2 said that
after several minutes the “four jurors” returned and whispered to
Duncan. Immediately after speaking with the “jurors,” Duncan
advised CS2 that he/she had been found guilty of stealing money from
BGF finance and was ordered to receive a two minute body beating
from various BGF members. Duncan advised Dixon that he also had
been found guilty and was ordered to receive a twenty second body
beating and was to be suspended from the BGF Bush for a period of
six months. CS2 advised that both CS2 and DIXON received their
beatings.
39. After the punishment, the BGF meeting continued. CS2
23
advised, that among other things, McIntosh spoke about the need to
have an individual identified as “Johnny Five” murdered for the
killing of a BGF comrade. CS2 advised that Duncan inquired about
the status of Johnny Five’s murder at which time he was told by
McIntosh that it was going to be taken care of by Burrell. McIntosh
also spoke about the need to obtain additional guns to keep in stock
for use by BGF members.
40. According to CS2, Duncan spoke of many BGF matters,
including the fact that he (Duncan) had implemented a “Defense
Team,” led by Kareem Randall. Duncan advised that the “Defense
Team” is always to be on stand by in case they are needed for
retaliation against anyone, who may interfere with BGF matters.
Additionally, Duncan stated that he is in the process of meeting
with Burrell to establish a second “Defense team.” CS2 stated that
toward the conclusion of the meeting, Duncan advised that all
members in attendance needed to be aware that he (Duncan) has a
source in the FBI that provides him with information. Duncan said
that if anyone learned of their meeting he would be able to
determine who was leaking BGF information and would handle things
accordingly.
41. During the latter part of the meeting, CS2 was
provided by members in attendance with the telephone number (443)
712-3603, which is being utilized by McIntosh. Shortly thereafter,
CS2 advised that Dixon and CS2 were allowed to leave the meeting.
24
42. At the conclusion of the interview, law enforcement
instructed CS2 to place a controlled telephone call to Thomas
Burrell at telephone number (410)690-2679 to discuss the recent BGF
meeting. During the conversation, Burrell and CS2 discussed the
meeting, including CS2's sanction.
43. Law enforcement then instructed CS2 to place a
controlled telephone call to “D” at (410)710-0299 to discuss the
recent BGF meeting and the accusations by “D” regarding the theft
of BGF funds by CS2. During the conversation, “D” acknowledged the
meeting and the accusations.
44. On December 4, 2009, CS2 was debriefed regarding
recent BGF activities. CS2 advised that on December 3, 2009, CS2
received a telephone call from BGF member, Brian Rainey, a/k/a
Shahid, who advised that he was currently being held on a $5,000
cash bail stemming from a felony drug arrest, which occurred on
November 19, 2009. During the conversation, Rainey requested that
CS2 place a telephone call to McIntosh at telephone number (443)712-
3603, and ask her for assistance in posting his bail. Ultimately,
CS2 agreed to make the call. A short time later, CS2 placed a non-
controlled telephone call to (443)712-3603, utilized by McIntosh.
During the conversation, CS2 notified McIntosh of Rainey’s
situation. McIntosh then advised CS2 that she would look into
Rainey’s bail situation.
25
45. During the month of December 2009, CS35 was debriefed
regarding his/her knowledge of the BGF. CS3 had notified law
enforcement that he/she is a well known and respected BGF member.
Among other things, CS3 stated that BGF is the most violent drug
gang operating in the state of Maryland. CS3 provided the following
names and telephone numbers of active BGF members in Maryland,
William Rhodes, a/k/a “Jim Dog” 165*496*11477, (443)869-7458,
164*1012*7032; Thomas Burrell, a/k/a “Cochise” (410)690-2783;
Gorilla Black (443)740-1838, Germo a/k/a “Jerimo” (443)858-0345;
Gene, a/k/a Matthew Talley (443)277-7449; Corey (410)585-5405;
Rodney Reaves, a/k/a “Hot Rod” (443)455-9544; Kareem, a/k/a Kareem
Randall 165*500*4416, (410)485-1823; Mack (443)602-1710, Anthony
Banks, a/k/a “Nugget” 165*493*56, (443)891-4044; Ralf (410)0858-
1039; Rambo 164*1011*8878; Stink 165*503*381; Stizill 165*497*10563;
165*495*11003, 165*1007*15265; Antonio Davis, a/k/a “Tank Top”
(443)398-1790, (410)209-0669; Kimberly McIntosh, a/k/a “Sister Kim”
(443)712-3603; Abron Scott, a/k/a “Tink” (443)398-1790, (410)209-
0669; Robert Loney, a/k/a “Looney” (410)500-7260; Mike Beatty, a/k/a
“Mike B” (443)220-7625; Reds (443)320-6641; and Skebo (443)540-3263.
46. On December 15, 2009, law enforcement officials
debriefed CS3 regarding current BGF activities. During the
debriefing CS3 advised, among other things that he/she could meet
5
CS3 is providing information in exchange for leniency
with criminal charges. CS3's information has been corroborated
to the extent possible and has proven accurate and reliable.
26
in person with McIntosh regarding BGF protocol and the gangs drug
trafficking activities. CS3 advised that McIntosh is the highest
ranking female BGF member in Maryland. CS3 advised that McIntosh
utilized cellular telephone number (443)712-3603, to conduct her
drug trafficking business.
47. On December 15, 2009, at approximately 12:06 p.m.,
law enforcement officials transported CS3 to Total Health Care
located at 1501 Division Street, McIntosh’s place of employment.
CS3 was equipped with a recording device to capture the conversation
with McIntosh. During the meeting, law enforcement observed CS3
meet with McIntosh near the front of the building. At the
conclusion of the meeting, CS3 met with law enforcement officials
and advised that McIntosh agreed to obtain three (3) grams of heroin
for CS3 later that evening. At approximately 4:10 p.m.,
investigators again met with CS3 and searched his/her person and
vehicle for the impending drug transaction. Both CS3’s person and
vehicle were found to be free of any contraband. At approximately
4:50 p.m., CS3 placed a controlled and recorded telephone call to
McIntosh at telephone number (443)712-3603. During the brief
conversation, CS3 agreed to drive McIntosh home from work. Shortly
thereafter, law enforcement followed CS3 to a community market
located on Pennsylvania Avenue, a short distance from Total Health
Care. Agents and officers then followed CS3 and McIntosh to her
residence, 1120 Homewood Avenue, Subject Premise #1, where both were
27
observed to enter the location.
48. Upon entering the residence, McIntosh began a
conversation that lasted over one (1) hour. During this time, CS3
was equipped with a recording device and transmitter. The
conversation involved, among other things, drug trafficking
including McIntosh’s willingness and ability to mix/process heroin
for BGF members and affiliates, shootings and violent acts
associated with drug trafficking, including the threat of violence
toward law enforcement cooperators. As the conversation commenced,
McIntosh asked CS3, “Are you ready for your grams now?” CS3
responded, “Fuck yeah, I’m ready whenever.” A more casual
conversation then ensued. CS3 asked, “Hey you know what I forgot
to ask you.” McIntosh answered, “What?” CS3 continued, “You already
got the mix?” McIntosh answered, “Um, hum. I don’t know how many
caps I got left. I think I bought a new thing but I, you know, I
be doing this for somebody else and he always get me. You know I
do his thing for him and he don’t never have the things. I’ll check
upstairs, I should have some though. At least I can put it and you
can just tomorrow.” McIntosh then placed an outgoing telephone call,
which is overheard on CS3's recording device. As the call is
answered, McIntosh said, “Hey, how you?” An individual, later
identified as Lamont Crooks responded, “What’s happening?” McIntosh
responded, “I’m trying to see you.” Crooks continued, “Oh yeah.”
McIntosh asked, “You in the hood?” Crooks answered, “Yeah, yeah I’m
28
in the hood.” McIntosh asked, “Alright, could you see me about six
o’clock?” Crooks answered, “Yeah.” McIntosh asked, “You remember
the six o’clock thing?” Crooks answered, “Yeah, yeah.”
49. A subsequent review of the pen register on (443)712-
3603, McIntosh’s Cellphone, revealed a call during the date and time
of this portion of the conversation to (443)703-6325, the Crooks
Cellphone.
50. McIntosh and CS3 then continued their conversation
regarding BGF activities and drug trafficking. CS3 asked whether
McIntosh was supplementing her income with drug proceeds. McIntosh
advised, “Yeah I been doing something, a little something.”
McIntosh explained that a BGF member “Hot Rod,” a/k/a Rodney Reaves,
had recently been arrested and that their has been some in fighting
between certain BGF members that should not have occurred. McIntosh
explained that some of the fighting had resulted in murder, to
include “Ant.” McIntosh explained that some BGF members thought
that Ant was a “rat” but she did not believe it. McIntosh
explained, “And then in the next sentence you see how EB and UNC and
RAINBOW6 and all them just came home. And then on that indictment
shit you see how EB was fucking Vernon girl (a reference to Tomeka
Harris, who was charged and has pled guilty in the 2009 Indictments)
6
These individuals, EB (Eric Brown); UNC (Uncle Ray, Ray
Olivis); and Rainbow (Rainbow Williams) were indicted in the 2009
Indictments involving the BGF and its smuggling of drugs into and
control of the Maryland prison system.
29
and Vernon and Ant was best friends. Something seem real, real
shakey with that. Something seem real, real shakey with that. Like
maybe, Ant was saying some shit that he didn’t like and maybe was
going back to Vernon telling him. Or it was a, he might have been
a threat now cause he witnessing shit that really ain’t right and
they got rid of him. I don’t even know.” CS3 asked, “The thing is
who made that call?” McIntosh answered, “I don’t know. Like I said
when Rainbow came home, see now I don’t got no more gel caps, damn,
when Rainbow came home “Donnie”(a reference to Duncan) kind of
allowed him to kind of…” CS3 continued, “Take over.” McIntosh
continued, “Something like that, something like that.” CS3 advised,
“Yeah, but the thing is, you know we have to see it in black and
white.” McIntosh responded, “Yep.” CS3 continued, “You can’t go
off of what somebody says, you can’t.” McIntosh advised, “Yeah, we
should be good. You just gonna have to cap it up (a reference to
packaging heroin). Yeah I ain’t like that. Cause like I said, one
minute he here and he in extremely good standing and the next minute
he was out of there and, and right before they killed him he
disciplined somebody and the person deserved to get disciplined.
The boy said fuck J7. That’s that west situation and they beat the
7
Based upon my investigation into BGF, J is a reference
to Jamaa. Jamaa is a Swahili term for family and is used
primarily by BGF members interchangeably with other monikers to
describe BGF. For example, in conversation BGF members will say
that “he is ‘J’,” meaning the individual is a member of the
“family.” The family is the Black Guerilla Family (BGF). So the
individual is a member of their criminal enterprise.
30
shit out of him. Dre had a fit because that’s his cousin’s baby’s
father. I don’t give a fuck. So he gets to say fuck J (BGF), gets
to sit in the car right it’s two weeks later, say fuck J (BGF) one
time, get beat for it. Two weeks later sit in the car let his
homeboy kill a comrade, shoot a comrade five times in the back.
You strapped (armed) and don’t do shit about it. Then come to a
meeting a week after that and say do we really have to harm a
civilian, cause that’s my homeboy. They is all sitting at these
meetings. I swear if I was at that meeting I’d a probably tried to
fuck him up right then and there and Dre still talking about oh
that’s my, he’s a good brother. That’s my cuz. I don’t give a
shit. He the one that went back to Uncle Ray telling people,
telling him I’m beating people for no reason. No that wasn’t for
no reason.” CS3 responded, “Yeah, I heard, I remember when he was
down the pen because, I’m trying to think, me and another comrade
was talking about you and Ray Ray8, Ray Ray asked me about you. I
said that’s, man that’s the best comrade I ever met with me in my
life.” McIntosh responded, “I know he was probably disappointed
that you said that.” CS3 continued, “Right, so he was like what she
be doing. I said Sis (a reference to Sister Kim, a/k/a McIntosh)
is laid back you know. Unless you jump out there, jump out there,
Sis is laid back. I didn’t know that’s why he was asking me.”
8
Ray Ray, is a reference to Uncle Ray, or Ray Olivis,
see note 6.
31
McIntosh responded, “That’s why he was asking. He said I, I beat
people for no reason. I’m abusing my authority and I’m on that.
I stole forty seven thousand dollars from finance. I’m in hiding,
can’t go nowhere. Can’t no brothers find me. Cutty had his little
part in spreading the rumor to. When he came home they brought him
to me. Donnie (Duncan) done brought him to me and he said, at first
he said he ain’t never said none of that. I’m like ok Cutty, so if
I get ten brothers that was on the tier with you, that all came home
and looked at me like I was crazy cause I was walking down the
Avenue embracing brothers, you gonna call them a liar. Well no I
ain’t saying that I didn’t say it. What I’m saying is if I said it
I was just passing along something that somebody said to me. Since
when do we do that without verification? But ok, figuring out all
the other brothers who had this idea and came home and found out it
wasn’t true. When I asked them where they got it from they said
they got it from you. So if you didn’t originate it then where did
you get it from? Oh I don’t remember. And Donnie (Duncan) and them
just let it go like that. I don’t remember. Ok, ok well I didn’t
steal no, no money. I’m, I’m, I’m still here. I’m not in hiding
yeah, yeah. I think they did that, they suspended me. They
suspended me right and I think they real goal was, cause at first
when they suspended me they didn’t have a reason. Since when do we
suspend people without a reason? Oh, no they still can’t give me
a reason. Cause they’ve invested every, investigated every avenue.
32
Turned over every rock, every stone, every decision I’ve ever made
was brought into question and I passed every single one of them.
So like a few weeks later they was like ok you can go ahead and
resume your position. Well before I do that can you just let me
know what I was suspended for? Oh I’m going to get back to you on
that.” CS3 responded, “That’s supposed, that’s supposed to come
first.” McIntosh continued, “You not gonna take your position, your
not gonna take your position back? Yeah, I’m gonna take it as soon
as you all give me my charge papers so I can show people that I was
actually you know, cleared. Well Rainbow asked Uncle Ray what you
want us to tell her? Tell her it was administrative.” CS3 asked,
“So what’s that supposed to mean?” McIntosh answered, “That means
he got to do what the fuck he want to do cause he brought it here
from Cali9. That’s why I found out that Doc is alive. That’s why
I found out that Doc is alive, that they lied. And Doc10 loves me.
You hear me Doc loves me. Like he, he knows my mind from the little
bit that he done read and I ain’t even feed him a whole lot yet.
I ain’t, I still ain’t even tell him I’m J (BGF). I think he know
9
Through my investigation, I have learned that Ray
Olivis, a/k/a UNC, a/k/a UNCLE RAY, a/k/a RAY RAY was authorized
to open BGF in the State of Maryland prison system in the mid
1990's by the California factions of BGF after Olivis served a
prison sentence in California.
10
Doc is a reference to Doc Holiday, a/k/a James Herold
Holiday, who is currently incarcerated in Florence, Colorado.
Holiday was one of the founding member of BGF in California in
the 1960's.
33
now though. Cause in the last letter he wrote Kim and he put past
sister. So I think he know and then like I said he said I risen
from the grave before and then it said watch out for the ones from
on this side or from your side.” McIntosh then received an incoming
telephone call. McIntosh answered the call and said, “Hello. Hey
E. I been, I don’t know, hiding. No I’m home. Yep, I got a ride.
Was you, you know what I just called yo too. Oh he’s gonna, ok, no
problem. Ok, alright.” McIntosh completed the call and returned
to her conversation with CS3. McIntosh advised, “That’s so funny,
yo would have been coming to my house anyway. The dude would have
been coming to my house anyway. That, the other dude that I whip
up (process heroin) for he um must have just called him himself.
Gonna meet him here. Ain’t that funny?” CS3 responded, “Yo, yo be
taking it down huh?” McIntosh answered, “Yeah he…” CS3 continued,
“It must be good...,” McIntosh continued, “…Yeah it’s decent. It’s
decent. It’s better than what most of the people out here got. You
know people ain’t having nothing that you can put higher than a
three (a ratio of cutting agent to heroin). It really has been
real, people putting their shit on a two, two and a half (a ratio
of cutting agent to heroin) and just getting a medium reading.”
McIntosh explained that drug traffickers other than herself have
been mixing their heroin with “codeine with the oxy codeine” which
doesn’t turn out to be of good quality. The conversation continued
between McIntosh and CS3 regarding different types of cutting agents
34
used by heroin traffickers.
51. A subsequent review of the pen register on (443)712-
3603, McIntosh’s Cellphone, revealed a call during the time and date
of this portion of the conversation incoming from (443)378-0318
subscribed to Erik Ushry at Irvine, California, 200 N Patterson Park
Avenue, Baltimore, Maryland. The call was listed as incoming at
5:55:20 p.m., and lasted 41 seconds. At the completion of the call,
McIntosh identified the caller to CS3 as “E,” one of the individuals
that she mixes and cuts heroin.
52. On December 15, 2009, at approximately 5:58 p.m., TFO
Benson and other surveillance officers observed a dark colored Buick
bearing Maryland registration 2FM V79 park in front of 1120 Homewood
Avenue, Subject Premise #1. TFO Benson observed a heavy set black
male, approximately 6’ 4” in height exit the Buick and entered 1120
Homewood Avenue. A query of the Maryland Motor Vehicle
Administration (MVA) revealed the vehicle to be registered to Erick
Seantae Ushry, B/M, 6’ 4”, 300 lbs, with a date of birth (DOB) of
04/22/1984, and an address of 1207 Greenmount Avenue, Baltimore,
Maryland. TFO Benson and other surveillance officers were later
shown a photograph of Erik Ushry and positively identified the
driver of the Buick as Ushry. After Ushry’s arrival at McIntosh’s
residence, McIntosh, Ushry and CS3 engaged in drug related
conversation. McIntosh initially advised that they needed to go to
a separate location in the house because “Lamont” was going to be
35
coming. At approximately 6:18 p.m., TFO Benson observed a white
Dodge Charger bearing Alabama registration 47L78L8 park in front of
1120 Homewood Avenue, Subject Premise #1. A few minutes later, the
passenger exited the vehicle and entered 1120 Homewood Avenue.
During the same time frame, McIntosh received an incoming call. A
review of the pen register over (443)712-3603 revealed the incoming
call at 6:18:56 from (443)703-6325, the Crooks Cellphone. During
the telephone conversation McIntosh said, “Hello. Oh come on in.”
Crooks then enters the residence and greets McIntosh, Ushry and CS3,
who was still wearing the recording device. Crooks tells McIntosh,
“I’m gonna need a, a bag to put the grams in.” McIntosh asked, “You
need a scale too?” Crooks responds, “No, I got a scale.” As the
conversation continues Crooks advises the group, “…Something mean
supposed to be coming. Yeah man they uh, uh the only thing I’m
waiting. Cause I told you I took a loss (unintelligible) with the
last thing. But they supposed to straighten half of it. Cause we
took like a hundred ninety thousand dollar loss and they supposed
to straighten it. So I don’t know how long (unintelligible) half
but if I get like seventeen and my money back and they supposed to
send something with it. You know what I’m saying? They said it
supposed to have been. It’s coming out of Chicago and that shit
pure.” As the conversation continues, Ushry advised that the
heroin he has been getting from Crooks has been of good quality.
At approximately 6:25 p.m., TFO Benson observed Ushry exit Subject
36
Premise #1, enter the Buick and depart the area. Shortly
thereafter, TFO Benson observed Crooks exit 1120 Homewood Avenue,
enter the white Dodge Charger and depart the area. At approximately
7:16 p.m., surveillance officers observed CS3 exit 1120 Homewood
Avenue, Subject Premise 1, and depart the area with surveillance
officers following. CS3 was followed to a neutral location and
relinquished the quantity of heroin purchased from McIntosh and
Crooks. Both CS3’s vehicle and person were again searched and found
to free from any contraband.
53. During a subsequent debriefing, CS3 identified the
source who delivered the heroin for McIntosh as Lamont. CS3 was
shown several photographs and identified Lamont Crooks as the heroin
source of supply. CS3 also stated that the five grams of heroin
were purchased at a price of four hundred dollars which had been
provided by law enforcement. CS3 advised that once Crooks arrived
he provided one gram of heroin to McIntosh, and twenty grams to
Ushry. The CS advised that Crooks had stated that he obtained his
heroin source of supply when he (Crooks) and the source were
incarcerated together in a federal correctional institution.
According to Crooks, the heroin source was from Boston,
Massachusetts. CS3 also advised that Crooks had lost one hundred
and nine thousand dollars during a recent heroin purchase, but that
he and his source of supply were going to split the loss.
54. On December 16, 2009, at approximately 1:10 p.m., law
37
enforcement investigators again met with CS3 to place a controlled
call to McIntosh over (443)712-3603. The call was placed in the
presence of law enforcement and was recorded. During the
conversation, CS3 asked McIntosh for a contact number for Crooks.
McIntosh told CS3 that she needed to obtain the number from her
phone and would call right back. At approximately 1:12 p.m., CS3
received an incoming call from McIntosh over (443)712-3603. During
the brief conversation, McIntosh provided CS3 with telephone number
(443)703-6325, the Crooks Cellphone, but advised that Crooks may
want CS3 to conduct any drug transactions through her.
55. On December 21, 2009, investigators again met with
CS3 to purchase heroin from McIntosh. At approximately 4:29 p.m.,
CS3 called (443)712-3603, and left a message for McIntosh. A few
moments later, CS3 spoke with McIntosh over the push to talk feature
of (443)712-3603. During the brief conversation, CS3 advised, “Hey
um, I need to see you.” McIntosh responded, “Ok, um give me a
little while I’m gonna hit you back.” CS3 asked, “Alright, is um
my man ready?” McIntosh answered, “Um, I don’t know. I can check
on that now.” CS3 asked, “Alright how long you, you talking? Cause
I got to go back and pick my mom up.” McIntosh answered, “Um, I
don’t know. Let me make a call.” CS3 responded, “Alright hit me
right back.” McIntosh continued, “Ok, what was you talking anyway?”
CS3 answered, “Uh ten” (a reference to grams of heroin). McIntosh
responded, “Ok.” At approximately 4:34 p.m., McIntosh called CS3
38
and advised that everything was ready to go.
56. A subsequent review of the pen register over the
(443)712-3603 revealed an outgoing call to the Crooks Cellphone at
4:33:36 p.m., seconds prior to the return call to CS3 from McIntosh.
57. On December 21, 2009, law enforcement investigators
searched CS3 and the CS’s vehicle and found them free of any
contraband. CS3 was then provided with a recording device and eight
hundred dollars in government funds for the purpose of a controlled
purchase of ten grams of heroin from McIntosh. Investigators
followed CS3 to 1120 Homewood Avenue, Subject Premise #1, the home
of McIntosh. CS3 was observed to arrive at the residence at
approximately 4:58 p.m. Within minutes of CS3's arrival, McIntosh
placed an outgoing call over (443)712-3603. McIntosh asked, “Hey
can you come through? You know how long that’s gonna be? Ok what
time is it now? Ok, ok I’ll let him know.” McIntosh then told CS3,
“He said he gotta wait until the girl get off. It’s gonna be six.”
CS3 advised that he/she would return to McIntosh’s residence after
six o’clock. As the conversation continued, McIntosh asked, “Did
you just want to leave your um thing, in case he come through?” CS3
advised that he/she would hold the money in case CS3 did not return
that evening. A short time later, CS3 exited 1120 Homewood Avenue,
and was followed to a secure location. CS3 returned the official
funds and stated that McIntosh was waiting for Crooks to arrive with
the heroin after 6:00 p.m.
39
58. A review of the pen register over (443)712-3603
revealed an outgoing call to the Crooks Cellphone at 5:00:30 p.m.,
which lasted 42 seconds.
59. On December 21, 2009, at approximately 6:24 p.m.,
surveillance officers observed a four door Acura bearing Maryland
registration 7EX Y82 park near 1120 Homewood Avenue, Subject Premise
#1. Shortly thereafter, two unidentified males exited the vehicle
and entered the residence. At approximately 6:30 p.m., surveillance
officers observed the two unidentified males exit the dwelling and
engage in a conversation with McIntosh, who was standing in the
doorway. A few minutes later both males entered the Acura and
departed the area. A query of Maryland MVA revealed registration
7EX Y82 registered to a 2002 four door Acura registered to Davon
Jerome McFadden, DOB: 01/07/1986 at 2004 E. Baltimore Street,
Baltimore, Maryland 21231, SUBJECT PREMISE #5. At approximately
7:47 p.m., law enforcement officials again met with CS3 for the
purpose of a heroin purchase from McIntosh. CS3 and the CS vehicle
were again searched and found free of any contraband. CS3 was
provided with eight hundred dollars in government funds and was
equipped with a recording device. Investigators then followed CS3
to 1120 Homewood Avenue, Subject Premise #1, arriving at
approximately 7:55 p.m. Minutes after CS3's arrival, McIntosh
asked, “You wanted ten right?” McIntosh explained that she was
running out of minutes on (443)712-3603, but would replenish them
40
later in the evening. As the conversation continued, McIntosh
explained that she needed to obtain a new supply of “cut” and would
not be able to mix the heroin for CS3. CS3 asked where he/she could
obtain cutting agent and McIntosh stated, “They say Old Town Mall.
I know that’s where I get my, my vials from sometimes. It, down
there the vials are thirty, you get seven hundred for thirty. But
downtown you get five hundred for twenty and the cut, like I, they
said today that they got it down there. I can get it tomorrow but
that’s a hundred dollars, you know.” At approximately 8:17 p.m.,
surveillance officers observed CS3 exit the residence and proceed
out of the area. Investigators followed CS3 to a secure location
where CS3 relinquished a quantity of heroin purchased from McIntosh.
CS3’s person and vehicle were again searched and found to be free
from contraband.
60. A subsequent review of the pen register over
(443)712-3603 revealed two outgoing calls and one incoming call to
the Crooks Cellphone minutes after CS3 left McIntosh’s residence.
61. On January 11, 2010, law enforcement investigators
debriefed CS3 regarding the current activities of McIntosh and the
BGF. CS3 advised that currently he/she could not reach McIntosh
over the telephone but could speak with her at her place of
employment. Law enforcement officials then transported CS3 to
McIntosh’s place of employment at Total Health Care. CS3 was
equipped with a recording device and instructed to meet with
41
McIntosh. The following is a portion of the conversation between
McIntosh and CS3: McIntosh asked, “Did JIM (a reference to Rhodes)
ever get you a tone [firearm]?” CS3 responded, “Fuck no. He gave
me the runaround, kept sending me down south fucking Baltimore.”
McIntosh continued, “And I ain’t like that. You know why I didn’t
like that? Because Five (a reference to James Harris a/k/a Johnny
Five, a rival of BGF) is down there and you know him and Five be in
cahoots from time to time.” And you know he sent you, that’s why
I said, where did he send you? McIntosh explained that if “Five”
knows that a “comrade11” is in his drug trafficking area then he
would assume that the BGF member is there looking to cause him harm.
McIntosh explained that Harris would immediately inflict harm on
anyone he believes may cause him harm. McIntosh explained that
Rhodes has continued to have dealings with Harris even though,
“There’s been a green light out on yo since the beginning” (a
reference to an ordered murder of Harris by BGF). According to
McIntosh, Harris is responsible for the murder of a BGF member
causing BGF to order his death. McIntosh explained that it was
wrong for Rhodes to not advise CS3 of the ongoing problems with
Harris. McIntosh said, “You need to go holler at Donnie (Duncan),
Cause see Jim (Rhodes) just put himself on the fucking block (a
reference to being sanctioned for not following BGF protocol).
11
Comrade is a term used by BGF members to describe other
members or address each other, for example, “he’s a good comrade”
[he’s a respected member of BGF].
42
Cause if he did something, he robbed somebody who he shouldn’t have
robbed and it was really a misunderstanding. You know as where if
he would have came to the table it could have just got clarified.
He, he could have said oh I did get um, clearance [from the BGF
hierarchy]. I did try to find out if yo was that [a member of BGF]
and he said he wasn’t and they would have dealt with it in a whole
other way. Yo ain’t even showing up (a reference to attending BGF
meetings). He on the run from Donnie (Duncan) and them. He won’t
show up. He won’t come. He won’t call. Donnie and them want to
know where he live. McIntosh continued that she knows that the
mother of Rhodes lives near Washington Boulevard, but she was unsure
of where Rhodes is staying. McIntosh explained that Rhodes is
keeping a low profile and not being loyal to “J” (BGF).
62. As the conversation, continued CS3 asked, “You got
a new number?” McIntosh responded, “I got to get a new number.
They just made me back secretary (a rank within the BGF hierarchy,
specifically overseer of the organization’s finance).” CS3 asked,
“You got my number right?” McIntosh responded, “Yeah, yep. They
just made me back secretary too. So I’m gonna be getting me a J
(BGF) phone and I’m gonna get back all my little contacts and they
gave me the, a few other little areas (a reference to areas
controlled by BGF) that I, I get to deal with now.” The
conversation continued regarding activities being conducted by BGF
members. McIntosh advised that CS3 needed to go in person and
43
explain to Duncan the problem CS3 has been having with Rhodes.
63. On January 12, 2010, CS3 met with law enforcement
officials regarding the BGF. During the debriefing, at
approximately 2:39 p.m., CS3 placed a controlled call to McIntosh
at Total Health Care. Upon reaching McIntosh, CS3 was told to
immediately respond to her job because she needed to show CS3
something. Shortly thereafter, CS3 was equipped with a recording
device and followed to Total Health Care located at 1501 Division
Street. At approximately 3:01 p.m., CS3 arrived at McIntosh’s place
of employment and entered the building. During this time, law
enforcement investigators learned that there had been a shooting
near Total Health Care. A further inquiry revealed, Marc Antonio
Jackson had been arrested and charged with the attempted 1st degree
murder of Brandon Walker early on January 12, 2010. The location
of the shooting was listed as 500 Sanford Place, a short distance
from Total Health Care. At approximately 3:13 p.m., surveillance
officers observed McIntosh and CS3 exit the building and engage in
a conversation. During the conversation, McIntosh explained that
the shooting of Walker was BGF related. McIntosh explained that
within the last month the victim, Walker, had a verbal altercation
with Jackson, the shooting suspect, identified by McIntosh as
“Mark.” McIntosh explained that Mark had said to her that the next
time he sees the victim he is going to “burn him up” (a reference
to shooting the victim). As the conversation continued, CS3 and
44
McIntosh switched back and forth between the shooting and CS3’s
ongoing problem with Rhodes. McIntosh ultimately agreed that CS3
needed to address the problem with Duncan and Chambers. At
approximately 3:16 p.m., surveillance officers observed Kareem
Randall exit a white van, which had stopped near Total Health Care,
and approach CS3 and McIntosh. The three then engaged in a brief
conversation. During the conversation, Randall advised that the
“feds” were parked near the corner. Shortly thereafter, Randall
walked toward a gold Toyota 2 door bearing Maryland registration
6BZV83, which was parked at the corner of Pennsylvania Avenue and
Mosher Street, while McIntosh and CS3 continued their conversation.
At approximately 3:21 p.m., McIntosh returned to the building as CS3
walked toward the gold Toyota. At approximately 3:23 p.m., officers
observed Randall exit the passenger’s side of the Toyota and engage
in a conversation with CS3. During the conversation, CS3 told
Randall that he/she needed to obtain a handgun. Randall advised,
“We just lost mother fucking seven [because of the shooting that had
just occurred].” CS3 acknowledged the shooting as Randall
continued, “Yeah we had seven guns up there yo.” Randall then
explained that he needed to advise “Jim Dog” (a reference to Rhodes)
about the loss of the guns. Randall ultimately advised CS3 that
because of their loss he (Randall) could not provide CS3 with a
handgun. At approximately 3:26 p.m., the meeting between Randall
and CS3 concluded. A few minutes later, CS3 entered the CS vehicle
45
and was followed by law enforcement back to the DEA office. At
approximately 3:52 p.m., shortly after arriving at the DEA office,
CS3 received an incoming push to talk call from Randall. Due to the
unexpected activation by Randall, law enforcement was unable to
record the conversation. The conversation was, however, transmitted
over the speaker portion of CS3’S phone, which enabled agents to
hear the conversation. During the brief conversation, Randall
asked, in a heated manner, CS3’s current location. CS3 countered
and asked Randall’s current location. Investigators then heard an
unidentified male in the background whisper to Randall, “No, you ask
where he’s at?” Randall then asked CS3 if he/she was at a building
near a hotel. CS3 advised that he/she was currently downtown near
the Downtown Locker Room. Randall then abruptly advised that he
would call CS3 later. Based on the nature of the questioning and
the location of the DEA building adjacent to a hotel, law
enforcement believed that a BGF associate of Randall’s observed CS3
enter the DEA building. At approximately 4:23 p.m., law enforcement
unsuccessfully had CS3 call McIntosh to clarify the questioning by
Randall.
64. A few days after the conversation with Randall, CS3
met McIntosh at Total Health Care. During the brief conversation
with McIntosh, McIntosh avoided conversation related to BGF and/or
criminal activity, and instructed CS3 to enter rehab and get his/her
life together.
46
65. After the 2009 Indictment, and at various times
including August 5, 2009, law enforcement debriefed a confidential
source (CS4).12 CS4 is a high-ranking member of the BGF, and a
contributor to the Black Book.
66. CS4 described BGF’s efforts to appear to be a
legitimate organization. According to CS4, the Black Book, which
was the brain child of Eric Brown was to “make [BGF] look like a
legitimate organization.” Brown and other high-ranking members of
BGF hoped that by using BGF’s control over the prison system, the
BGF could control violence in the institution and continue to enrich
themselves through the prison economy (smuggling contraband). CS4
indicated that Brown was able to convince several community leaders
including former Federal Bureau of Investigation agent Dr. Tyrone
Powers, Dr. Andre Bundley, a former mayoral candidate, and Bridget
Alston-Smith, who operated a non-profit organization called Partners
in Progress, of the message contained in the Black Book. These
individuals began assisting Eric Brown in teaching in prison the BGF
and other prison gangs, the message of the Black Book. According
to CS4, Brown and other members hoped that, much in the same way BGF
controlled prison violence through subtle coercion, control of the
12
CS4 is providing information in exchange for protection
by law enforcement from the BGF, who believe he/she is/was a
confidential source. CS4's information has proved accurate and
has been corroborated to the extent possible.
47
prison economy, extortion, and retaliation, members on the street
could control the violence in Baltimore City. According to CS4,
this would have the effect of legitimizing BGF, allow the enterprise
to continue to earn money through drug trafficking, and taxing of
others trafficking in drugs, as well as providing legitimate high-
paying jobs to high-ranking members of BGF funded by various
government grants.
5. Source of Information #1
67. On December 28, 2009, DEA investigators interviewed
source of information #1, hereafter referred to as SOI #113.
According to SOI #1, he/she has had close interaction with many high
level drug traffickers and BGF members in Baltimore to include
McIntosh, Duncan, Chambers, Henry Giles, Piper, Taterman, a/k/a
Devon Crawford, and Gerimo. SOI #1 said that all of these
individuals are involved in drug trafficking and violent activities
attributed to BGF. Regarding violence, SOI #1 identified Taterman
as a “hit man” for Duncan. SOI #1 also identified Kool Aid as
partner with Taterman and involved in acts of violence.
Additionally, SOI #1 provided the following telephone numbers for
active BGF members in Baltimore, Todd Duncan, a/k/a, “Donnie”
cellular (410)559-5750, office (410)752-8500 and 8501; Bunchy
13
SOI #1 is providing information because the violence
associated with BGF has gotten out of control, and SOI #1 feels
that he/she is in a position to assist law enforcement. SOI #1's
information has been corroborated to the extent possible and has
proven accurate and reliable.
48
(443)676-5412; Stacey Smith (443)927-4360; Lamont (410)599-8150; Mia
Wilson (410)350-4118; Duconze Chambers (443)378-1737; Piper
(410)599-8350; Nathan Barksdale, a/k/a “Bodie” (443)766-2380 and
(443)467-7222; Dirty Rice, a/k/a “Man” (410)783-1853, (410)539-1618,
(410)736-9634; a female correctional officer (443)630-7672; Kool Aid
(443)453-1394; Taterman (443)850-1780, and Marty (443)865-7335.
68. According to SOI #1, Duncan and Kimberly Mayfield
Jones, known to law enforcement as McIntosh are the leaders of BGF
on the streets of Baltimore. SOI #1 advised that both Duncan and
McIntosh report to Uncle Ray, a/k/a Ray Olivis, who is currently
housed in the Maryland Correctional and Adjustment Center (MCAC) on
federal charges (the 2009 Indictments). According to SOI #1, Duncan
currently works as a youth counselor in Baltimore for a non-profit
organization called COIL. However, SOI #1 advised that Duncan makes
his money by selling heroin in the area of Greenmount Avenue and E.
Preston Street. Persons who assist Duncan in his heroin business
were identified by SOI #1 as Chambers, Piper and Henry Giles. SOI
#1 explained that as recently as the middle of December 2009, Duncan
and Chambers were supplied 300 grams of heroin from Terry Johnson.
According to SOI #1, Duncan and Chambers began receiving the heroin
after Duncan’s cousin D-Nice, a/k/a Darnell Gray, was murdered by
associates of Johnson. SOI #1 said that Johnson is not charging
Duncan for the heroin because he believes that as long as Duncan
receives the heroin, Duncan and or his associates will not retaliate
49
against Johnson for the murder of Duncan’s cousin. SOI #1 stated
that Duncan and his associates are extremely violent and will
ultimately murder Johnson. A query of law enforcement databases
revealed that Darnell Gray, a/k/a “D-Nice,” was murdered on December
16, 2009.
69. During the course of the interview, SOI #1 advised
that he/she could place telephone calls to members of the BGF.
Specifically, SOI #1 advised that telephone calls could be made to
Chambers, Piper, Nathan Barksdale, a/k/a “Bodie,” and Dirty Rice,
a/k/a “Man.”
70. On December 28, 2009. at approximately 6:03 p.m., SOI
#1 placed an outgoing consensually monitored telephone call to
Chambers over the Chambers Cellphone. SOI #1 placed the cellular
telephone on speaker mode for investigators to monitor. During the
conversation, Chambers advised that he has been selling “shit” (a
reference to heroin) for Donnie (Duncan). Chambers stated he was,
“helping him out so they could make something (a reference to
money).” SOI #1 advised that Chambers should not trust Donnie,
“because he is doing some cruddy shit.” Chambers responded that,
“Donnie is alright.” SOI #1 then brought up the recent murder of
D-Nice, stating that, “Donnie may have been given the 300 (a
reference to 300 grams of heroin), but he’s going to steal what they
have and kill them boys anyway.” SOI #1 stated that Chambers goes
along with it because he is scared of Donnie. Chambers stated, he
50
is not scared of Donnie, “they are tight, they fight like brothers
sometimes, but they are tight.”
71. On December 28, 2009, at approximately 6:25 p.m., SOI
#1 placed an outgoing consensually monitored telephone call to Piper
at (410)599-8350. SOI #1 placed the cellular telephone on speaker
mode for the investigators to monitor. During the conversation, SOI
#1 asked Piper where they were. Piper responded, “Over west.” SOI
#1 then said, “I hear Donnie (Duncan) in the background you ain’t
over west.” SOI #1 then instructed Piper not to give Donnie SOI
#1’s number. Piper advised, “No problem…,” because he doesn’t want
Donnie mad at him. SOI #1 said, “Don’t tell him you are on the
phone with me.”
72. On December 28, 2009, at approximately 7:10 p.m., SOI
#1 placed an outgoing call to Jermain Davis, a/k/a, Dirty Rice at
(410)539-1618. SOI #1 placed the telephone on speaker mode for the
investigators to hear. During the conversation, SOI #1 mentioned
the murder of D-Nice. SOI #1 stated, “That if he is kin, you know
Donnie is going to kill them boys eventually, no matter how much
shit (a reference to heroin) they give him.” Davis agreed, saying,
“It is only a matter of time.” SOI #1 advised Davis to stay away
from Duncan. Davis explained that he is not worried about Donnie
(Duncan), he don’t trust him and goes out strapped (armed) to meet
him, but he is not worried about him.
73. On December 29, 2009, law enforcement investigators
51
met with SOI #1 regarding the BGF. During the meeting, SOI #1
provided the address of 2004 East Baltimore Street, Baltimore,
Maryland (the residence of McFadden, Subject Premise #5) as a
residence used by BGF to store handguns. SOI #1 stated that
approximately one month ago SOI #1 was parked outside of 2004 East
Baltimore Street, when a BGF member identified only as Capo exited
the residence and placed four 9 MM handguns into SOI #1’s vehicle.
The handguns were then transported to a residence frequented by
Taterman.
74. On January 5, 2010, SOI #1 contacted law enforcement
investigators regarding the BGF. SOI #1 advised that he/she had
recently been at a bar in southeast Baltimore frequented by BGF
members. While in the bar, SOI #1 overheard a conversation between
several men regarding a recent abduction and murder. SOI #1
reported that an individual named “Marquel” had been kidnapped two
days ago and was subsequently murdered. The victim’s body was later
located in the Park Heights area of Baltimore and the vehicle used
in the crime was found by law enforcement on Pennsylvania Avenue in
Baltimore. According to SOI #1, he/she overheard that the
individuals responsible for the abduction and murder are Jim Dog
(Rhodes) and several other BGF members. During the abduction, a
ransom was paid for the return of the victim. The person who picked
up the ransom money was Sister Kim, (McIntosh). Upon receiving the
information, investigators contacted the Baltimore Homicide Unit and
52
learned that on January 3, 2010, Marcal Antwan Walton was abducted
and later found murdered in the 2300 block of Ocala Avenue in the
Park Heights community. Homicide Detectives have identified Jim
Dog, a/k/a William Rhodes, as a possible suspect in the homicide.
75. On January 7, 2010, SOI #1 contacted law enforcement
regarding recent activities related to BGF. SOI #1 stated that on
January 6, 2010, shortly after 8:00 p.m., Duncan and Taterman were
involved in a verbal argument in the area of Homewood Avenue and
East Preston Street. During the argument, Duncan scolded Crawford
for not following the proper protocol when it came to committing
violent acts against the community. According to SOI #1, Duncan
explained that all of the shootings and murders Crawford had been
committing needed to be cleared through him, and that he (Crawford)
should not be handling things with out prior approval. SOI #1
stated that Crawford produced a large handgun and advised that he
will do what ever he wants and no one can stop him. As the argument
continued, SOI #1 stated that Sister Kim (McIntosh) was observed
walking from her home (Subject Premise #1) carrying a large
revolver. McIntosh also became involved in the argument, ultimately
telling Crawford that he needed to follow proper protocol.
76. Later on January 7, 2010, SOI #1 again contacted law
enforcement and advised that Duncan had been arrested in the evening
hours of January 6, 2010 for unknown reasons. A query of law
enforcement databases revealed that Duncan was arrested in the 1100
53
block of Homewood Avenue (the same block as Subject Premise #1, and
the location of the altercation with Taterman) at approximately 8:40
p.m., on January 6, 2010 for providing a false statement to a police
officer.
77. On January 21, 2010, law enforcement debriefed SOI
#1 regarding the current drug activity of Chambers and Duncan. SOI
#1 advised that Chambers is still controlling a street distribution
location for heroin in Baltimore. SOI #1 explained that the shop,
while controlled by Chambers is actually operated by an individual
known as Tiger (later identified as Jon Brice). SOI #1 provided
Tiger’s phone number as (410)940-4668. SOI #1 also explained that
Duncan is the source of heroin at the shop and that Duncan recently
provided the heroin directly to Tiger for distribution, while
relying on Chambers to collect the proceeds.
C. Communities Organized to Improve Life, Inc. (COIL)
78. As noted above, members of BGF have attempted to
legitimize the BGF by publicly calling for an end to inner city
violence. In strikingly similar fashion to Eric Brown’s efforts
with the Black Book, Duncan has been employed as a youth counselor
at Communities Organized to Improve Life, Inc. (COIL), a non-profit
organization committed to the reduction of violent crime. COIL is
funded by a grant announced on August 9, 2007 by then Mayor Shelia
Dixon and the Baltimore City Health Department for $382,600. The
funds were provided to COIL to implement Operation Safe Streets in
54
Southwest Baltimore. Operation Safe Streets is a community based
violence prevention program focused on reducing shootings and
homicides in Baltimore City. COIL is the second location for
Operation Safe Streets, the first location was in the McElderry
Park and Madison East neighborhoods. Funding for the Operation Safe
Streets initiative run by COIL is provided by a grant from the
United States Department of Justice.
79. CS4 previously provided information related to Duncan
and COIL. According to CS4, Duncan works at COIL as a way of
legitimizing himself in the eyes of law enforcement and the public.
Duncan gives the appearance of working with at risk youth, while
maintaining his role as leader of the BGF. Additionally, Duncan has
assisted other BGF members like Ronald Scott, a/k/a “Piper,” to
obtain jobs as youth counselors at COIL. CS4 related that the
Operation Safe Streets located in the McElderry Park and Madison
East neighborhoods is controlled by the BGF, specifically Anthony
Brown, a/k/a “Gerimo.” According to CS4, BGF members released from
prison can obtain employment from Operation Safe Streets.
80. On January 24, 2010, Duncan appeared on a local
Sunday morning television show, Grace and Glory. The brief segment
showed Duncan being interviewed by the show’s host highlighting the
“great” work COIL was doing. During the segment, Duncan identifies
himself as a “former” gang member.
81. On March 27, 2010, at approximately 3:28 p.m., Duncan
55
received an incoming call from (443)717-8417, utilized by Killa.
During the conversation Duncan advised, "I need you down here.
Cause I'm down here with the brothers, Meech and all them." Killa
asked, "Where at?" Duncan answered, "Down by my job (a reference
to COIL)." Killa asked, "What time?" Duncan answered, "Right now
if you can get here. But ev, everybody here." Killa responded,
Alright, alright um that's Cal, down there where we used to come at,
Baltimore and Calhoun right?" Duncan answered, "Carrollton." Killa
responded, "Carrollton, alright I'm gonna try to get a ride now."
Based on their training and experience and other information
developed during this investigation, law enforcement agents believe
that Duncan was holding a BGF meeting at COIL, the corner of W.
Baltimore Street and S. Carrollton Avenue.
D. Intercepted Communication
82. Throughout this investigation, law enforcement has
intercepted calls corroborating the information provided by the
sources listed above. These intercepted calls identify not only
BGF’s illegal activity, including drug trafficking, but BGF’s
organization, structure and hierarchy as a racketeering enterprise.
1. Gang Activity
83. On February 14, 2010, at approximately 11:58 a.m.,
Chambers received an incoming call from Duncan using the Duncan
Cellphone. During the conversation, Duncan asked, “What happened
last night? They talking about running you through.” Chambers
56
responded, “Who gonna run me through?” Duncan continued, “They said
they got to fighting and you ain’t assist them.” Chambers
continued, “Cause I wasn’t, I wasn’t over there. Me and Lamont was
right there. When I got there I made a sure them mother fucking
niggers…When we got over there we just (inaudible). I’m like man
what the fuck? Who the fuck, that’s Dill. So man Dill come to me
said yo go over your table man. So I go over there to your table
and I said what the fuck going on? So he said the niggers is going
out. Man, well tell them to run me through. Cause Lamont, all of
them over there. Tell them, tell them, tell them run me through.”
Duncan responded, “But Lamont and them don’t got nothing to do with
nothing.” Chambers continued, “But we (inaudible), how the fuck you
gonna attack, how I’m gonna assist you when we don’t know what the
fuck going on. When we, when me and Lamont really got over there
he, we seen Dill. Cause Dill told me he said yo that’s Taterman,
grab Taterman. So I go over to Taterman and said what the fuck
going on? He said the nigger, we didn’t even know who the niggers
they was fighting. So really I thought like… I’m like what the fuck
going on? So Dill try to actually tell me like, the nigger threw
some water. I said the nigger threw some water. So when me and
Lamont got over there, I said that’s Dill fighting. So when Dill
come over he say yo grab Taterman. I said what the fuck going on.
So I grab, so I go over to Taterman, Taterman already zapped out.
I said what’s going on? Taterman saying, man I knocked these
57
niggers out. I said you knocked them out? He said yeah, I said the
nigger threw some water. Me, me and your cousin (inaudible). So
I didn’t leave nowhere. Me and Lamont ain’t leave nowhere after we
found out what’s going on. So I like man, he said, so Taterman said
look yo they getting the dude just like gave me a whatya call’m.
So Kool Aid said I’m going out by myself. I’m the last one going,
and then I didn’t go to sleep until everybody was clear. I called
Dill and everything. So I’m like, he said, I said meet us down the
whatya call’m. So Lamont was like, Lamont, me and Lamont get on the
truck we had the man, he said come on yo let’s get them, niggers
getting ready to come out. So (inaudible), so we ain’t, I still
don’t go nowhere until Dill like, you all good. Don’t, you all good.
Kool Aid got it (a gun) on him now. Now you all can come out. So
we come out, I said man the dude was already pointing the gu, one
of ours was on, our little homey was already on point. To go and
do what they get, do, do what they get. So I said ok. I still
don’t leave till Gutter, I call Taterman and hundred times yo. I
said you still right there we turning back to get you now. He said
we good yo, we gone, we gone. I said man we coming to get you right
now. He said we good, we gone. I said alright. I still don’t
leave until I knew all of them was safe.” Duncan responded, “Well,
Black said they in there fighting, Black said they in there
fighting, Black the one that running you through.” Chambers
continued, “Well tell him run me through...cause I wasn’t over
58
there, cause I know how… He wasn’t fighting. I ain’t see him
fighting. When I go over he was standing, when we got over, when,
when me and Lamont got over, we, when we got over there and find out
who it was, Black was right there. He’s like man you know this and
that. I said man who the fuck you said, who the fuck was fighting?
So when they turn I just seen Dill. But we didn’t even know
Taterman or none of the comrades cause we thought it was little
homeboys. Me and Lamont thought it was little homeboys fighting.
We didn’t know Taterman, Kool Aid and them was fighting. Cause we
wasn’t over there when the shit got off. So when I asked Dill, I
was like yo what the fuck happened? He said nigger threw the water
and Taterman knocked him out. I want him to run me through. Yeah
this time I want him to run me through. Cause this time Lamont and
them, they got to come and play. I want them to come. I want them
to run me through. Cause he sitting there running his fucking
face.” Based on their training and experience and other information
that Duncan was notifying Chambers that he is being brought up on
BGF charges (a reference to being “run through”) by BGF member
Black. According to Duncan, Black said that Chambers did not help
“comrades,” Taterman and Kool Aid, when they were involved in a
fight at a club.
84. On March 8, 2010, at approximately 11:40 a.m., Duncan
placed an outgoing call to (410)913-6234 utilized by McIntosh.
59
During the conversation McIntosh advised, "I got about three things
for you. What you doing today?" Duncan answered, "A rack of shit.
Why what's up?" McIntosh answered, "Um the first thing is I got a
call this morning from um Chanell. Rem baby mother. He at it on
her again." Duncan advised, "I don't want to hear nothing more with
that. Go ahead." McIntosh continued, "Ok second thing, who do, who
should I direct that to?" Duncan answered, "I don't even, I don't
even care nothing about that. Go ahead." McIntosh continued, "Ok
second thing is um, Twan is reaching out again." Duncan asked,
"Which one?" McIntosh answered, "The one, south Baltimore one. I
just told him to right up his complaints and pass it in." Duncan
responded, "Alright." McIntosh continued, "And that, that's how I,
you feel what I'm saying? And then Rem gonna lean on him telling
him he shouldn't have gone over east. They dealing with the shit
on this side. Something, something, something." Duncan asked,
"What he mean (unintelligible)." McIntosh continued, "So you feel
what I'm saying? I'm not, I'm, I don't want deal with it cause he
gonna think it's a personal." Duncan advised, "Don't worry about
it I'll send somebody over there." McIntosh responded, "Ok good
enough." As the conversation continued Duncan advised, "I'm
trying, I'm trying to make, make something happen but um, I'm a, I'm
a try to do it." McIntosh responded, "Ok and remember um, remember
um, what was it, the day before yesterday." Duncan answered,
"Yeah." McIntosh continued, "I think you can go four." Duncan
60
responded, "Huh, oh yeah!" McIntosh continued, "I think you, yep,
yep." Duncan asked, "Oh wit, wit, wit, wit, with the old peoples?"
McIntosh answered, "With the new peoples. With the old, old. You
know the, the new joint." Duncan responded, "Wit a, wit, with the
huh?" McIntosh continued, "Limpy boy." Duncan responded, "Yeah
that's what I'm saying, yeah." McIntosh responded, "Yep." Duncan
responded, "Alright that's what's up." McIntosh advised, "I heard
all, like you know one to ten. Like past ten. They couldn't even
say ten. It was like twelve or thirteen." Duncan asked, "For real?
And what you put yourn'?" McIntosh answered, "Um now that's the
key, that's the key. I uh, under three. Barely under three."
Duncan responded, "So mines, mines should be good then. Cause I,
I done a three and a half." McIntosh responded, "Yep, you should
be, you should be fine." Duncan responded, "Alright that's what's
up." McIntosh continued, "Yep you should be fine. I had got a call
late, late last night they was oh yeah, oh yeah. Ok." Duncan
responded, "Alright that's, that's what's up." Based on their
training and experience and other information developed during this
investigation, law enforcement agents believe that in the beginning
of the conversation McIntosh was advising Duncan, who is the overall
city wide commander of BGF, about BGF matters related to "Reem" (a
reference to Kareem Randall); and complaints by BGF member "Twan."
Regarding Randall, Duncan advised, "Don't worry about it I'll send
somebody over there." Regarding Twan, McIntosh advised, "I just
61
told him to right up his complaints and pass it in (a reference to
having high ranking BGF members review the complaints).” As the
conversation continued Duncan and McIntosh discussed a recent supply
of heroin, how many times the heroin could be cut, and the overall
quality. McIntosh advised, "I heard all, like you know one to ten.
Like past ten. They couldn't even say ten. It was like twelve or
thirteen" (a reference to Duncan having heroin with a high purity.)
McIntosh and Duncan then discuss how they processed and mixed their
heroin. McIntosh said, "I uh, under three. Barely under three,"
and Duncan responded, "So mines, mines should be good then. Cause
I, I done a three and a half." McIntosh responded, "Yep, you should
be, you should be fine."
received an incoming call from McIntosh. During the conversation
McIntosh advised, "Remember the little one I told you, that little
uh number one from south?" Duncan responded, "Yeah." McIntosh
continued, "He, he over that jail." Duncan responded, "Again?"
McIntosh continued, "Yeah I told you it was a warrant out." Duncan
asked, "For what?" McIntosh advised, "They reopened, that they re,
they, there was a warrant out um and they reopened up one of his
cases." Duncan responded, "Oh damn." McIntosh continued, "Yep one
that was put on the stet that got him out." Duncan responded,
"Yeah." McIntosh continued, "They reopened, they reopened it. I
don't know why. I ain't never seen no shit like that in the
62
computer. They reopened it." Duncan asked, "The feds got him?"
McIntosh answered, "Um no I doubt it. No he over the jail." Duncan
advised, "They might. Yeah but I'm saying, that, they would reopen
his case. The thing is you see it got put on the stet before. He
ain't never set on the stet." McIntosh continued, "Um yeah he be
getting, he escapes all the time. I don't even (unintelligible)."
Duncan advised, "No but you know they, you know they can reopen your
shit if it's on a stet." McIntosh responded, "Oh well yeah that,
that's what happened. But I ain't see no (unintelligible) cards.
Or I'll go in there tomorrow though." Duncan responded, "Oh, yeah
that, that was right too." McIntosh responded, "Yeah?" Duncan
continued, "Yeah." McIntosh continued, "Ok. We gonna have to work
something out here though. You know that right?" Duncan responded,
"(Unintelligible) yes." McIntosh responded, "Huh?" Duncan advised,
"I'm listening." McIntosh continued, "Ok I think, we'll think,
we'll come up with something fair." Duncan advised, "Here you go
with your shit. You (unintelligible). You paying seventy five
dollars already for it." McIntosh advised, "Well that's cool too,
that's cool." Duncan continued, "Yeah." McIntosh continued,
"That's cool." Duncan advised, "You feel what I'm saying? I'm not,
I'm, I'm not doing it for nobody else just you." McIntosh
responded, "That's fine." Duncan continued, "You know what I'm
saying? You and Ben (McFadden) the only two. You feel what I'm
saying?" McIntosh responded, "Yeah." Duncan continued, "Ain't
63
nobody, I ain't doing it for nobody else." McIntosh responded, "Ok,
ok, ok. Oh I (unintelligible)." Duncan responded, "Huh?" McIntosh
continued, "Like (unintelligible)." Duncan advised, "Yeah I'm about
to get a new number too. So um…" McIntosh responded, "Me to, me
to." Duncan continued, "Um I'm a call you from a new number."
McIntosh advised, "No don't call me on this phone." Duncan advised,
"Alright soon as these, these minutes run out." McIntosh advised,
"Wait, wait for me to um get a new phone and then you call me on my
new phone." Duncan responded, "Alright." McIntosh continued,
"Cause you calling me on this phone is the same. Like you know what
I'm saying?" Duncan responded, "Right yeah." McIntosh continued,
"So like I'm a, I'm a try to get a new phone." Duncan responded,
"Yeah." McIntosh continued, "And you call me on that phone and then
that will be the new. You feel what I'm saying?" Duncan responded,
"Right." McIntosh continued, "Yeah I think, yeah I'll do that
tomorrow. Or maybe not tomorrow." Duncan and McIntosh then
discussed new homes for McIntosh and Duncan's mother. McIntosh then
said, "Alright well um, was there something else, no I guess that's
it. That was the main thing. You already know that was the main
thing." Duncan responded, "Right." McIntosh continued, "Yeah I
don't know and I, there's a few people over there you know." Duncan
responded, "Right so, but um the right people there so they already
know. So you know." McIntosh responded, "I know, I know let's
hope." Duncan advised, "If a mother fucker over there…" McIntosh
64
advised, "You know Rudy over there." Duncan continued, "Right so
if a mother fucker make a, make a call out here I'm gonna be very
disappointed." McIntosh responded, "Yeah I know." Duncan
continued, "You feel, you feel what I'm saying?" Based on their
investigation, law enforcement agents believe that during the
initial portion of the conversation McIntosh was advising Duncan
that "that little uh number one from south,” (a reference James
Harris, a/k/a Johnny Five) was arrested on a warrant and is
currently being house at the Baltimore City Detention Center. The
conversation then shifted to Duncan, McIntosh and McFadden's drug
trafficking activities. McIntosh advised that she and Duncan needed
to talk about the profits being made from the sale of their drugs.
Duncan explained, "You paying seventy five dollars already for it
(a reference to seventy five dollars per gram of heroin).” McIntosh
advised, "Well that's cool too, that's cool." Duncan continued,
"Yeah." McIntosh continued, "That's cool." Duncan advised, "You
feel what I'm saying? I'm not, I'm, I'm not doing it for nobody
else just you." McIntosh responded, "That's fine." Duncan
continued, "You know what I'm saying? You and Ben the only two."
(Duncan was referring to selling heroin to McIntosh and McFadden for
seventy five dollars per gram of heroin which is at a lower cost
than any of Duncan's other drug purchasers.) The conversation then
returned to the arrest of Harris. McIntosh advised, "there's a few
65
people over there you know" to which Duncan responded, "Right so,
but um the right people there so they already know. So you know."
McIntosh responded, "I know, I know let's hope." Duncan advised,
"If a mother fucker over there…" McIntosh advised, "You know Rudy
over there." Duncan continued, "Right so if a mother fucker make
a, make a call out here I'm gonna be very disappointed." During
this part of the conversation McIntosh and Duncan were discussing
how there were BGF members at the detention center with Harris that
are expected to inflict bodily harm on Harris. Duncan explained
that no one should have to contact him from inside the detention
center to verify whether or not Harris should be harmed, they should
already know what should happen to Harris. During the
investigation, law enforcement has learned from confidential sources
that Harris is being held responsible for murdering a BGF member.
The murder Harris committed was not sanctioned by Duncan, therefore,
Harris is to be harmed on sight
86. On March 21, 2010, at approximately 4:42 p.m.,
Chambers received an incoming call over the Chambers Cellphone from
Loc. During the conversation Chambers told Loc to advise Nut that
he was getting ready to walk up. As Chambers is speaking with Loc,
McIntosh was heard in the background stating, "If you register them
without their money right. (Unintelligible). And, and they don't
got the (unintelligible). In thirty days we should have three
thousand dollars from every comrade and every comrade should
66
(unintelligible). Then from that point when the thirty days on
(unintelligible) for my registration. But I know that
(unintelligible) is not going to stop until the thirteenth. That
gives people a chance to really try to get it together." Based on
their training and experience and other information developed during
this investigation, law enforcement agents believe that McIntosh was
advising the high ranking BGF members attending the meeting that she
had devised a plan for registering new members that would net the
gang a large profit. According to McIntosh, each area commander
would be expected to pay to finance in thirty days three thousand
dollars from their immediate underlings. This influx of cash would
enable the gang to boost the amount of money they currently have in
BGF finance.
McFadden. During the conversation McFadden advised, "Hey Dookie,
I need you to uh, get a count of everybody that's gonna register yo.
And get that twenty five dollars from em' and I'll come holler at
you." Chambers responded, "Right." McFadden continued, "And call,
call me as soon as you get everything together." Chambers
responded, "Alright, I, I'm, I'm waiting for um, I gotta…" McFadden
advised, "I need it by Monday." Chambers responded, "Ok I'm, I'm
already on top of all that." McFadden responded, "Alright." Based
on their training and experience and other information developed
67
during this investigation, law enforcement agents believe that
McFadden was instructing Chambers to collect twenty five dollars
from each BGF member under his command which he, McFadden would
collect and place into BGF finance.
received an incoming call from Smiley. During the conversation
Harried, a/k/a Smiley, said, "Yo, hey I wanted to ask you a question
right." Duncan responded, "Yeah." Harried continued, "I'm down
here with uh, with uh, uh Ben and you know Sean right." Duncan
responded, "Yeah." Harried continued, "And Sis (McIntosh), uh you
(unintelligible) counted their little, their little money. But Sis
wants uh, them to uh write down the names and stuff. Can you please
get it from her later on today?" Duncan responded, "Alright, just
text me and tell me how much it's supposed to be." Harried
responded, "Uh nah, nah, nah. Uh, uh Ben got the money." Duncan
responded, "Alright so Ben gonna text me again." Harried asked,
"You hear me?" Duncan responded, "Say it again." Harried
responded, "Ben got the money but she got the names." Duncan
responded, "Right, so you all, you all want the papers. You all,
so you all want the names from her?" Harried responded, "I mean
that's what you, that, I mean that's what you were saying." Duncan
responded, "I ain't, I don't understand Smiley." Harried continued,
"I mean, you know she got, she got you know their, their names and
phone numbers and stuff like that." Duncan responded, "Right, yeah
68
but I…" Harried continued, "If you want her to keep it she can."
Duncan responded, "Yeah she, she, that, that's her job." Harried
responded, "Ok I'll just hand them to her." Duncan responded,
"Yeah, alright." Based on their training and experience and other
information developed during this investigation, law enforcement
agents believe that Harried, McIntosh and McFadden were together
counting the money that had been collected from BGF members and were
completing a detailed list of the BGF members who had provided money
toward BGF finance. Harried advised Duncan that McFadden had the
money from the BGF membership. However, Harried was unclear whether
the list of BGF contributors should be delivered to Duncan. Duncan
advised that the list should be left with McIntosh. Harried
explained, "I mean, you know she got, she got you know their, their
names and phone numbers and stuff like that." Duncan responded,
"Right, yeah but I…" Harried continued, "If you want her to keep
it she can." Duncan responded, "Yeah she, she, that, that's her
job."
89. On March 29, 2010, at approximately 10:42 a.m.,
Duncan placed an outgoing call to McIntosh. During the conversation
Duncan advised, "I definitely got to get up with you today for
real." McIntosh responded, "Oh yeah." Duncan continued, "Yeah."
McIntosh responded, "Ok, ok. Well I'm at work. I know you don't
got to work today." Duncan responded, "Right." McIntosh continued,
"And it's a rainy day too." Duncan responded, "I know. I talked to
69
um Bow (a reference to Rainbow William, who was indicted in the 2009
Indictments)." McIntosh asked, "Uh the old man?" Duncan answered,
"Uh he ain't old. Bow." McIntosh responded, "Oh Moe." Duncan
yelled, "Bow." MCINTSOH responded, "My, oh, oh, yeah." Duncan
advised, "Yeah and um your name, my name came up." McIntosh asked,
"What we do now?" Duncan yelled, "Just listen. You know where he
at [federal detention awaiting trial]." McIntosh answered, "Yeah,
oh for real!" Duncan answered, "Yeah." McIntosh responded, "Ok."
Duncan continued, "And, and, and the crazy thing is right, you hear
me?" McIntosh answered, "Yeah." Duncan continued, "Like it wasn't
nothing bad. You feel what I'm saying?" McIntosh responded,
"Yeah." Duncan continued, "They asked you know, uh they were
telling him or whatever right." McIntosh responded, "Yeah." Duncan
continued, "But you, um, the dude R (Ray Olivis) and the dude E
(Eric Brown) right." McIntosh responded, "Yeah." Duncan continued,
"But they, they, it was like ya'll, ya'll was the main ones at
first." McIntosh asked, "For real?" Duncan answered, "Yeah that's
how they got started." McIntosh responded, "Oh shit. But that's
crazy though cause at that time, you got to think about that time.
I was quiet for a whole like eight months. I didn't talk to them
at all. You feel what I'm saying? At all, at all. Nobody over
there." Duncan responded, "Right." McIntosh continued, "So I don't
know how, you see what I'm saying." Duncan responded, "Yeah."
McIntosh continued, "Oh my. Yeah you gonna definitely have to sit
70
down and fill me in on all the little details on that." Duncan
responded, "Yeah cause he really didn't get in to it but um, I'm
gonna have somebody go see him though, visit him for real."
McIntosh responded, "Alright." Based on their training and
experience and other information developed during this
investigation, law enforcement agents believe that Duncan was
advising McIntosh that he received word from "Bow" (a reference to
Rainbow Williams) regarding McIntosh. Duncan explained that law
enforcement began their initial investigation of BGF centered on
McIntosh, Ray Olivis, a/k/a Uncle Ray, and Eric Brown, a/k/a EB.
Duncan advised, "But you, um, the dude R and the dude E right."
McIntosh responded, "Yeah." Duncan continued, "But they, they, it
was like ya'll, ya'll was the main ones at first." McIntosh asked,
"For real?" Duncan answered, "Yeah that's how they got started."
McIntosh responded, "Oh shit. But that's crazy though cause at that
time, you got to think about that time. I was quiet for a whole
like eight months. I didn't talk to them at all." During the
initial investigation McIntosh, Olivis, Williams, and Brown were
identified by law enforcement as high ranking BGF members. Ray
Olivis, Rainbow Williams, and Eric Brown are currently in federal
custody pending trial for conspiracy to distribute heroin. McIntosh
was not charged during the initial BGF investigation.
placed an outgoing call to Barry. During the conversation Duncan
71
asked, "Hey now what was going on? Barry answered, "Alright like
I said that same incident that happened over there right. What it
was they got a little com, you know comrade out here right." Duncan
responded, "Right." Barry continued, "He made accusations that he
gonna start putting his hands on other brothers right. So um…"
Duncan responded, Right." Barry continued, "You know they giving,
a matter a fact he was down with C. You know so uh they getting a
little, a little thing about that right. So early that morning I
comes out here. He gets to beefing with some old men. He bumps the
old man car and the old man get out. They get to arguing. He beat
the old man with a shovel and then bust the old man windows. They
get, you know, telling about that, no you was wrong about that. So
he tell the comrade alright, you nah mean I'm, I'm a see. He rolls
out, comes back with a gun. The (unintelligible) dude was foxin'.
Oh no you can't do this. He (unintelligible). So he shoots him,
shoots the man. So the dude took the gun back so he shoot him
back." Duncan asked, "For real?" Barry responded, "Yeah so he on,
he, he, he, he on the run now. But the thing is you, he goes down
there with a gun to do harm to another brother." Duncan responded,
"Right." Barry continued, "And just happy he ain't hit another
dude." Barry and Duncan continued to discuss the shooting
situation. Barry then advised, "Moe and them made a suggestion
right. I just got to talking to him. Well I know the suggestion
to give to you right. He…" Duncan responded, "Yeah." Barry
72
continued, "But it's more so dealing with the Sister (McIntosh)
right. He was, he feels that you know, she should no longer receive
any type of paperwork. Saying that her name supposedly keep coming
up." Duncan responded, "Oh yeah." Barry continued, "You know, a
that's a suggestion he said (unintelligible) we should give to you.
For me to give to you." Duncan responded, "Ok." Barry continued,
"Shouldn't receive no more. You know. I said yo since her name you
know cause that puts safeguards definitely on you. It's about
(unintelligible)." Duncan responded, "Right." Barry continued,
"Man if anything that she'd have, she should you know give it up.
Because if not you know if so man you know, sh, sh, she might be the
one that they go through just to bring us down. Cause I'm saying
they know there's some ones out there that escaped you know that
they really want. And you know uh…" Duncan responded, "Right."
Barry continued, "And my main man you know he one of em'. You nah
mean?" Duncan responded, "Yeah." Barry continued, "Yeah brother
you got to know, you, you got to think that. You know what I mean?
And, and, and, and, and then when we talking on this thing (a phone)
like this man we got to go back to our Swahili roots man." Duncan
responded, "Alright that's what's up." Based on their training and
investigation, law enforcement agents believe that Barry was
explaining that he had a problem with a BGF member who had violated
protocol by attacking an older gentleman and then later shooting a
73
BGF comrade, both of which are in violation of BGF protocol. Later
in the conversation Barry advised that he and others believe that
law enforcement has not concluded their investigation into BGF.
Barry and others believe that McIntosh may be the downfall of BGF.
Barry advised, "she should no longer receive any type of paperwork.
Saying that her name supposedly keep coming up." Barry continued,
"Man if anything that she'd have, she should you know give it up.
Because if not you know if so man you know, sh, sh, she might be the
one that they go through just to bring us down. Cause I'm saying
they know there's some ones out there that escaped."
2. Drug-Trafficking/Drug Smuggling
91. On February 10, 2010, at approximately 12:53 p.m.,
Chambers received an incoming call from (410)327-0407, utilized by
Shelly. During the conversation Shelly asked, "Did it fall
through?" Chambers answered, "No that mother fucking weather14 been
stopping me yo." Chambers then asked to speak with "Fat Ass."
Shelly then put Toot, a/k/a Fat Ass, on the telephone. Chambers
asked, "What's up fat boy?" Toot responded, "Oh man just
maintaining waiting on the boat come through. So we can get this
shit started." Chambers advised that because of the snow he has
been confined. Toot advised, "Well if you ever need another spot
you need to let me know. I'm on a, I'm trying to get up here on a
14
This telephone call coincides with the two major
snowstorms in the Baltimore area in early 2010.
74
Biddle and a Patterson Park. I want something new (a new drug
distribution location). I ain't going back around there. There
ain't nothing around there." Chambers responded, "Right, but a
bunch of bull shit ass niggers that want to beef (fight over drug
territory)." Toot continued, "Yep but like, but like up on Milton
with some shit like that." Chambers advised, "Like, like that shit
right, that's why I really got mad. You know what I mean? That's
why I came around there. You know what I'm saying? Because that
some bull shit yo was on." Toot continued, "Yeah man cause I ain't
even do nothing to that nigger. I got locked up that nigger even
called that nigger and told that nigger. That nigger and I told him
I used the money. He said ok. When I came home he was like, I said
man I know you ain't gonna cut me off. I know you gonna give me a
chance to get the money back. He like nah I ain't gonna cut you off
(halt the supply of drugs). I ain't gonna cut you off. Like three
months went past. You know I mean? I supposed to keep asking him.
So then soon as I finally got my hand on something, the same day I
finally got my hand on something he gonna send the boy James
Finchman, the boy James up there. You know what I mean? Then James
go back down there and tell him yeah Toot up there. So then him,
that shit is crazy." Chambers responded, "Yeah I ain't like that
either yo." Toot advised that after that time he had problems
obtaining a new supply of drugs. Toot said, "He stagnated me."
75
that the recent snowstorm has caused problems with their ability to
sell drugs, and past problems with money and obtaining consistent
supplies of drugs.
Chambers placed an outgoing call from the Chambers Cellphone to
Duncan on the Duncan Cellphone. During the conversation Chambers
advised, "Yo I', I said I'm right here with Dre he want to holler
at you." Duncan responded, "Wait, he gotta, you gotta wait. I'll
call ya'll back." Chambers responded, "Alright, well you want me
to give him the number?" Duncan responded in a heated tone, "I'm
waiting on a call. I'll call you back." At approximately 3:43
p.m., Duncan returned the call to Chambers using the same phones.
Upon answering the call Chambers advised, "Hey here go Dre he want
to holler at you." Duncan asked, "What Dre is this?" Chambers
answered, "Tall Dre, right here." Duncan asked, "Which one? Yeah,
who kept my mother fucking money!" Dre then used the Chambers
Cellphone to speak with Duncan. Dre said, "Yo." Duncan asked, "Hey
what's with my money man?" Dre answered, "Huh?" Duncan yelled, "My
money." Dre responded, "Yo, I told you soon when I get it I got
you." Duncan responded, "Man I'd a been locked up on some bull
shit." Dre continued, "Right I been looking uh, uh, uh, uh, uh I
been looking for you. I been, I been looking for you. I been
sending messages to you." Duncan advised, "Well I didn't get none
76
of your messages." Dre responded, "You didn't get none of my
messages. Killer ain't tell you my message?" Duncan continued,
"None of them, none of them." Dre advised, "You is, you is kidding
me." Duncan advised, "No, I didn't get none of your messages." Dre
responded, "That's crazy. Every time I come over I see yo and I
tell him, yo tell Donnie (Duncan) I been in contact." Duncan
advised, "No, nobody gave me no message." Dre advised, "Man I
really, really, really need to holler at you though." Duncan
advised, "Well I'm on my way to Delaware right now to the guy that
be frontin'." DRE asked, "When, when, when, when a good time?"
Duncan advised, "I, I'm leaving for Delaware now. Tomorrow…" Dre
continued, "I say… Tomorrow? Around what time?" Duncan continued,
"Yeah." Dre asked, "And where at?" Duncan advised, "It don't make
a difference tomorrow. Just hit my, just get this number from um,
Ducon (Chambers)." Dre responded, "Alright, alright, alright."
that Dre owed Duncan for a past drug transaction and Duncan wanted
the money prior to any additional drug sales to Dre. Duncan stated
he was going to Delaware, "to the guy that be frontin'" (a reference
to being supplied drugs on consignment) and that if Dre wanted to
purchase additional drugs from Duncan he would be available the
following day.
77
Chips. During the conversation Chips asked, "You know somebody that
work down Brockbridge?" Chambers answered, "Yeah." Chips
continued, "Oh alright you know my other cousin, you know his
brother down there." Chambers responded, "Bug." Chips advised,
"Yeah we trying to handle something." Based on their training and
investigation, law enforcement agents believe that Chips was
inquiring whether Chambers knew of a corrections officer at the
Brockbridge Correctional Facility who may help them smuggle
contraband into the facility for his cousin Bug. Chips advised,
"Yeah, we trying to handle something," and Chambers acknowledged
that he had an individual that would help them.
placed an outgoing call to Jermain Davis. During the conversation
Davis commented on how Duncan hurt his (Davis’s) feelings when
Duncan questioned him about his (Davis's) drug trafficking
activities. Davis said, "Nigger that's how the fuck I was doing
what I was doing when we was rollin'. You feel me? Hello, huh."
Duncan responded, "Yeah I'm here. (Unintelligible)." Davis
continued, "Yeah I said, I said that's how I was doing what I was
doing when we was rollin'." Duncan responded, "You just take so
fucking long." Davis asked, "What time you get out the, huh?"
Duncan continued, "You just be taking so fucking long. I understand
78
what your doing but god damn." Davis responded, "Yo, yo for real
yo, no for real yo it be the police yo." Duncan responded, "I, I
already know that." Davis continued, "Soon as a nigger came out yo,
the knockers (police) came. I said what the fuck!" Duncan
continued, "Yeah I already know. Look I had left some things with
her but how anybody gonna get it?" Davis responded, "And you left
them." Duncan continued, "Sitting here I thought about
(unintelligible). I said fuck that shit." Davis continued, "Yeah
and she looked. I had like seven of them under my balls right."
Duncan responded, "Yeah." Davis continued, "So when I seen them I
ate them. I said man what the fuck. So Emo was like yo, I need you
yo. So I was like yeah I get me, I can get some of these mother
fuckers in right now. You know what I'm saying?" Duncan responded,
"Right." Davis continued, "So when you was calling me." Duncan
responded, "Yeah." Davis continued, "I was running to get the
what's a names." Duncan responded, "Oh." Davis continued, "You
know what I'm saying? The one's I had left." Duncan responded,
"Right." Davis continued, "But Emo's like why the fuck is you
breathing? I said man look I was running." Based on their training
and experience and other information developed during this
investigation, law enforcement agents believe that Davis was
explaining to Duncan that the reason Duncan could not reach Davis
by phone was because Davis was busy on the streets of Baltimore
selling drugs for Duncan and trying to avoid being arrested by the
79
"knockers" (a reference to narcotics officers).
placed an outgoing call to Davis. During the conversation Davis
said, "Come holler at me man. Yo you still right?" Duncan
answered, "Not yet I'm waiting for the call now." Davis responded,
"Alright so you know what yo when, when I get it right." Duncan
responded, "Um hum." Davis continued, "And I see them that's what
it be best for me to do is mix it. You know what I'm saying?"
Duncan responded, "Alright." Davis continued, "So I can just go
with the flow." Duncan responded, "Right." Davis continued, "You
know what I'm saying? Then I be, you know doing it faster." Duncan
responded, "Right." Davis asked, "You understand what I'm saying?"
Duncan responded, "Alright that's what's up." Davis continued,
"That's fine, see I meant yo…" Duncan answered, "Yeah." Davis
continued, "And you see how shit been you know turning and it ain't
been that, it ain't been slow like that." Duncan responded,
"Right." Davis advised, "I had that since early today though. I
got yourin' out of the way first." Duncan advised, "Alright, I'll
be there." Based on their training and experience and other
agents believe that Davis had been mixing and selling drugs for
Duncan throughout the day however the quality of the drugs was not
that good. Davis asked if Duncan was obtaining a new quantity of
drugs to which Duncan said he was. Davis then advised that he would
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mix the new drugs with the bad quality drugs, which would allow the
drugs to be easier to sell. Davis asked, "Yo you still right?"
Duncan answered, "Not yet I'm waiting for the call now." Davis
responded, "Alright so you know what yo when, when I get it right."
Duncan responded, "Um hum." Davis continued, "And I see them that's
what it be best for me to do is mix it."
placed an outgoing call to Davis using (410)736-9634. During the
conversation Davis asked, "Yo why you ain't answer your phone
chief?" Duncan answered, "No cause I, I swear to god I didn't even
know the mother fucker was ringing." Davis advised, "I could have
been robbed yo. Somebody could have ended up killing me yo."
Duncan responded, "I didn't know, I didn't know that it was
ringing." Davis asked, "Oh, yo where my fifty dollars yo?" Duncan
advised, "I got you. I'm ready to um…" Davis asked, "Where you
at?" Duncan responded, "I'm on my way back down there so I can give
you…" Davis continued, "I'm leaving out she talking
(unintelligible) from Sis (McIntosh)." Duncan responded, "Alright
why you um, go get the um what's a name." Davis asked, "What?"
Duncan responded, "There's a single bag with four and I put the
other one in there." Davis responded, "Alright where it at?"
Duncan advised, "It's, tell her get it out the spot
(unintelligible)." Davis responded, "Alright I'll tell her." Davis
and Duncan then briefly discussed food and money Davis owes to a
81
male named Sid, and then Davis calls, "Sis." McIntosh in the
background responded, "Yes." Davis continued, "He said give me the,
the four seams in the bag." McIntosh responded, "Of what?" Davis
continued, "There's four, there's four of them in a bag." Based on
this investigation, law enforcement agents believe that Duncan was
telling Davis to obtain the drugs he had left at McIntosh's
residence so he (Davis) could deliver them to Duncan. During the
call Duncan indicates that McIntosh has a hidden location in her
residence, Subject Premise #1, where she conceals the drugs.
Chambers placed an outgoing call to Davis using (410)539-1618.
During the conversation Davis advised, "Angie had leaned on Donnie
(Duncan) because I be helping this nigger eat yo. You feel me?"
Chambers answered, "Right." Davis continued, "And shit before the
police grabbed me I was doing like three, four hundred joints a day.
You hear me Ducon." Chambers answered, "I know." Davis continued,
"And then when I have to fall back and take it long, yo what are you
doing. Yo hold up. Who the fuck you think you talking to! You
hear me?" Chambers answered, "Right." Davis continued, "I'm like
yo, who the fuck is you think you talking to yo. Nigger I'm helping
you eat. And then he know what the fuck I be doing. I, I be
fucking with Emo and them right." Chambers responded, "Right."
Davis continued, "To slide shit in. You know I'm saying? So I can
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slide his shit in...and I told him nigger you be giving me bull
shit...where as though I got to get, you know I got to get with them
to mix the shit up. Dump, dump all of it out and mix it up...so I
won't fuck my name up. So nigger, cause he called me one day, got
a whole bunch of people on the squares." Davis continued, "So we
in Sis (McIntosh) house. So he called me like, yo what the fuck is
you doing yo? You playing games? I said man don't call my mother
fucking phone while I'm doing what I'm doing and I got. So he
called back like oh yeah yo it's like that. What the fuck's wrong
with you? So I hung up right. So after I got finished doing what
I was doing....so I called, so I called, he called me from Sis phone
right Ducon (Chambers)." Chambers responded, "Yeah." Davis
continued, "So he wouldn't get on the phone so I, I called Angie and
got Angie to call her, call him right. He's like yo what's going
on this and that. So uh, so Angie asked me. So I told her right.
I said man yo that nigger got to be crazy. When you helping this
nigger eat don't nobody do nothing for him but you." Chambers
responded, "Right." Davis continued, "So when I see him face to
face yo, I'm like yo what the fuck. You gonna act like you don't
know what the fuck I be doing. Oh yo my bad yo I'm sorry yo. I
wasn't even thinking because we was talking about something. I said
yeah you don't never think nigger. What the fuck is wrong with you?
You know the fuck I be swindling nigger miss, mixing and matching
nigger. Fuck is wrong with you? You know what the fuck I been
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doing for you. The whole time fucking with them and you know what
I'm saying? Not letting them niggers know. You know, you know
sliding shit in. When the fuck a, a, a, a jimmy mack is only
fifteen joints and you know what I'm saying? I got to dump that out
and bam, bam. Oh yeah I'm a give them their money first so you know
what I'm saying, their hundred, hundred dollars first. You know
what I'm saying? To get them out the way so I can slide ours in."
Chambers responded, "Right." Davis continued, "Dumb ass nigger
don't be asking me no questions. He like yo my bad this, yeah
alright yo. I said yo you be on some bull shit yo." Chambers
responded, "Don't he!" Davis continued, "No yo I'm sorry this and
that. Uh then he keeping asking me about fifty dollars. I said
Donnie (Duncan) I'm not giving you no fifty dollars man, fuck you.
I'm not giving you no fifty dollars." Chambers advised, "That man
is crazy." Davis continued, "I said I'm not giving you no fifty
dollars man. You got to be crazy. Then what fucked me up right,
this what fucked me up right. You know I had to go see Sis
(McIntosh) for him right." Chambers responded, "Right." Davis
continued, "So she gonna slide me her shit. You feel me?" Chambers
responded, "Right. She a sneaky mother fucker too." Davis
continued, "Listen, so he ain't answering his phone. You know he
don't, when it come down to his money yo haul ass. You feel me?"
Chambers responded, "Right." Davis continued, "So I put two and two
together, what the fuck. So I asked her. I like oh that was yours?
84
She was like yeah. I said hold yo. I said Sis why you do that?
When you could have called me and asked me to take care of something
for you. You feel me?" Chambers responded, "Yeah." Davis
continued, "You ain't got to use slim and I told Donnie, yo don't
you never do that again yo. Cause the way me and you do business
you let me do it at my pace. You know what I'm saying? Cause she
calling me, calling me, calling me like you know what I'm saying,
like hurry up. What the fuck! You feel me?" Based on their
investigation, law enforcement agents believe that Davis was
advising Chambers that he was selling three hundred to four hundred
units of heroin for Duncan on a daily basis. Davis advised that in
addition to selling drugs for Duncan he (Davis) also was selling
drugs for an individual identified as "Nemo." Davis explained that
Duncan was receiving poor quality heroin and he (Davis) was mixing
Duncan's drugs with Nemo's drugs to get Duncan’s to sell. Davis
explained that Duncan recently had Davis sell drugs for "Sis" (a
reference to McIntosh) without asking him (Davis). Davis explained
that Duncan did not have to conceal the fact that he (Davis was
selling McIntosh's drugs because he would have sold them for her
anyway.
3. Acts of Violence
Chambers received an incoming call from (443)630-2120 utilized by
85
Little Mike. At the initiation of the conversation Chambers
advised, "What's up Little Mike. The nigger can't find the dude
man." Little Mike asked, "You said you can't find him?" Chambers
continued, "No, then I heard brothers on him and everything. We
gonna keep on trying to flush his ass out boy but I ain't seen him."
Little Mike responded, "Yeah, yeah, yeah he goin, he gonna come
around. You know what I mean? Got to, he ain't got no where to
go." Chambers acknowledged, "Right." Little Mike continued, "You
know what I'm saying? Hey yo, man I need your help G man. Trying
to bounce back of that bullshit yo. That shit fucked us up." As
the conversation continued, Little Mike asked, "Yeah just grab, yeah
yo how much of that shit can you grab us yo?" Chambers asked, "What
you trying, what you trying to go?" Little Mike, "Man listen we
already got, we already, we just coped up on a QP of that shit
right. Man we just doing, just throw, just throw a little
something, put, put with that shit (inaudible)." Chambers
responded, "I can do that, I can do that for tomorrow." Little Mike
and Chambers then continue to discuss the distribution of different
drugs and making money from drug trafficking. Eventually, Little
Mike explains, "Yeah straight, you know what I mean? Soon as we
track that shit out. Yo a day or two yo. Straight send that shit
right back to you yo. I'd grab the white, grab the white
(inaudible). Whatever you can for real yo. Yeah the nigger we
gonna send through there he the one that gonna bring it straight to
86
us. You see what I'm saying?" Chambers advised, "Right. You all
ain't selling nothing out here? I don't deal with that shit but I,
my man get it and I know, I know he a do, he do right by us."
Little Mike responded, "That's all we, we already spent almost all
our cake. That nigger fucked us up. Uh, uh, uh Ducon (Chambers)
yo, that nigger fucked us up yo. You hear me? Yeah that nigger
fucked us up yo. You hear what I'm saying? We, we took the little
cake we did have and straight coped up on some, straight coped up
on some ready (crack) real quick. You know what I'm saying? But
that shit ain't enough for us to do what we trying to do though.
You know what I'm saying? Because the nigger we was sending
through, you know we got bills to pay too. You see what I'm saying?
And we trying to make that shit right back yo. You know what I'm
saying?" Chambers acknowledged, "Right." Little Mike continued,
"Yeah we trying to call on some favors man. We need to get shit
back right boy. We need some help G. You know what I mean?
Straight like that. You feel me?" Chambers advised, "Yeah, I'm
trying to tell you. I'm, I'm man, my peoples, I ain't even be doing
shit. But I'm just saying you got some money I can go at that
nigger for you then." Little Mike advised, "Nah, we already spent
what we had. That's what I'm trying to tell you." Chambers
advised, "Well then, I can't do nothing if I ain't got no money
cause I'm, you know what I mean? I'm (inaudible) man. I'm waiting
on my shit. Again, the conversation continues regarding drug
87
trafficking and Little Mike says, "Yeah man we spent that shit with
yo and he won't do shit for us. So now we got what we got. So now
we on a tip where as though man we just trying to grab one extra,
extra OZ or two real quick yo. You know what I'm saying? You can
(inaudible). That's why we ain't, ain't looking for nothing crazy.
We just trying to get an ounce or two man." Based on their training
investigation, law enforcement agents believe that Little Mike is
distributing marijuana and cocaine and is asking Chambers to supply
him with a new quantity of cocaine. However, at the current time
Little Mike has little money because a drug associate absconded with
some of his proceeds. Chambers acknowledged the loss and advised
that he (Chambers) and his close associates have been looking for
the unidentified thief. Chambers advised, "The nigger can't find
the dude man,” Chambers continued, "No, then I heard brothers on him
and everything. We gonna keep on trying to flush his ass out boy
but I ain't seen him." Little Mike responded, "Yeah, yeah, yeah he
goin, he gonna come around. You know what I mean? Got to, he ain't
got no where to go." It is the belief of law enforcement that due
to the violent nature of the BGF that once the thief is located he
will be physically harmed and possibly murdered. As the
conversation continued, the content shifted to the sale and purchase
of quantities of different drugs. Little Mike advised that he
recently purchased a "QP" (a reference to a quarter pound of
88
marijuana). Eventually, Chambers advised that he would contact one
of his drug associates and ascertain whether they had a supply of
cocaine.
placed an outgoing call to (410)913-2466 utilized by McIntosh.
During the conversation Duncan asked, “They told you Jim (a refernce
to Jim Dog, a/k/a William Rhodes) was locked up?” McIntosh
answered, “Yep, I, oh I knew. I wanted to tell you. I told Ben
(McFadden) today.” Duncan advised, “Yeah I, Ben told me.” McIntosh
responded, “Yeah I told him today. I got the paperwork and
everything. It’s not a pretty situation either.” Duncan responded,
“Yeah I heard.” McIntosh continued, “And that was last, last April,
April twenty fourth oh nine.” Duncan responded, “That’s crazy ain’t
it?” McIntosh continued, “Yep shit comes back to haunt your ass.
I heard they got DNA, somebody must have got cut and they got DNA
and all type of shit. They gonna axe me if D, if yo blood mixed
with somebody else blood can they still it’s yo blood. Yeah I
believe so.” Duncan responded, “Yeah they know what two different
blood type is mixed.” McIntosh continued, “Yeah see technology
nowadays is a bitch.” Duncan asked, “Yeah they don’t, they don’t
watch what’s a name?” McIntosh laughed and said, “I guess it’s just
the CSI.” Duncan continued, “Yeah.” McIntosh continued, “Yeah, yes
sir. So yeah, but I’m gonna tell you the whole little crazy story.
You know yo came, the, the other one came and hollered at me. Told
89
the baby mother to call me.” Duncan responded, “Oh I bet she did
now.” McIntosh continued, “I, oh yeah came through like this, you
know he got to mix me up in their whole little, you see what I’m
saying. (Unintelligible).” Duncan advised, “Yeah I, I already know
what he up to now. (Unintelligible).” McIntosh continued, “Yep, yep
they was like, yep I called. I, I told her I was like tell him call
me. So she told him to call me. He needed to see me face to face.
So I tell her tell him give me five minutes. I’m in the middle of
something. Mind you I’m at work. You see what I’m saying? Give me
five minutes I’ll be out there. She call me back cracking up
laughing. She said it can’t wait five minutes it might, he might
not have enough time.” Duncan responded, “Yeah.” McIntosh
continued, “And you just passed me earlier and ain’t say shit.”
Duncan asked, “He say he don’t want…” McIntosh continued, “Your
boy, and your boy just passed me on Friday. I called him out. Like
damn Jim that’s how you do now, as he walked past me.
(Unintelligible) And the funny, funny thing is I specifically
remember, cause I heard this shit in the streets. You heard me?”
Duncan responded, “Right.” McIntosh continued, “I specifically
remember inquiring. I didn’t know who, what, when, why or where.
I just knew that, that had happened. And I had just…” Duncan
advised, “Oh here’s who I need for you to get in contact with me.
Get in contact with Stephon for me.” McIntosh responded, “Oh, uh,
hum, yep ok I will.” Duncan responded, “Yeah.” McIntosh then made
90
several unintelligible sounds. McIntosh continued, “Yep I, I asked
about that. I, that was so funny. Don’t tell Sis, don’t tell her.
Yeah don’t tell me. That’s right. Thank you very much.” Duncan
then advised that he would call her back after nine. McIntosh
responded, “Ok, ok that’s cool.” Duncan asked, “Why what’s up? Who
you want to (unintelligible).” McIntosh advised, “Uh your boy came
through.” Duncan asked, “Who?” McIntosh continued, “Your boy, your
boy was was supposed to come here yesterday at what six o’clock,
when we talked to him. Call me at twelve thirty last night asking
if it was too late, it really was. So I told him call, catch up to
me in the morning. And he calls me in a panic…” Duncan asked,
“Which one?” McIntosh answered, “Kev! Calls me in a panic this
morning talking about he only got forty five minutes. This, this,
that. Now I already left and went to work right. But when I
explained to him what, what it was he was like it’s not, ain’t no
money in there? No.” Duncan responded, “Right.” McIntosh
continued, “So I, I me being the being the dumb sister, oh no I
meant me being the good sister.” (Laughing) Duncan responded,
“Right.” McIntosh continued, “Told him flat out I have a hundred
dollar’s in my pocket. I need it back by the end of the day. In
front of Styles I will yo for real to minute on this one, like for
real. Cause I don’t have it. You see what I’m saying?” Duncan
responded, “Yeah.” McIntosh continued, “But I understand the
situation so, I, but I’m telling you it’s going to go to the line.
91
that McIntosh was reporting to Duncan, the city wide commander of
BGF, current BGF matters. McIntosh advised that “Jim” (a reference
to William Rhodes, a/k/a Jim Dog) had been arrested for a violent
crime that he had committed on April 24, 2009. McIntosh said that
she had in her possession the “paperwork” (a reference to Rhodes’s
charging paperwork) which revealed that Rhodes was linked to the
violent crime through his DNA. On March 2, 2010 investigators
learned that Rhodes had been arrested for an abduction and murder
which occurred in April 2009. During the latter portion of the
conversation McIntosh that “Kev” had come to her asking for money.
McIntosh advised that there was no money in the house (a reference
1120 Homewood Avenue, Subject Premise #1). In accordance with BGF
rules, the person in charge of finance (McIntosh) would have in her
possession money gained from BGF dues, any taxes paid to the BGF and
any proceeds obtained by criminal means. It is believed that “Kev”
was asking for money from BGF finance to help him get on his feet.
McIntosh told Duncan that because there was no money available that
she gave “Kev” some of her personal money, but expected the money
to be returned within a day. McIntosh told Duncan, “I’m telling you
it’s going to go to the line (a reference to having Kev sanctioned
for not repaying the money she lent him.)” Law enforcement has
learned that being sanctioned by BGF results in the paying of fines,
92
physical assault, or possible death.
placed an outgoing call to (443)806-6730, utilized by Davon. During
the conversation Duncan asked, "God damn where my cut at yo?" Davon
asked, "On what?" Duncan continued, "You all sell the truck yet?"
Davon responded, "Man you ain't, they ain't tell you what happened?"
Duncan answered, "No them niggers didn't ain't tell me what
happened." Davon continued, "Man those dummies go to uh get the
joint and the mother fucker been towed." Duncan asked, "Oh the
nigger told!" Davon responded, "Yeah I don't know what the fuck.
Wherever the fuck they park at that bitch got towed. So they really
ain't even got no truck." Duncan asked, "It got towed or the nigger
told?" Davon answered, "Say it again." Duncan continued, "What the
nigger, it, I thought you said the nigger told. But the car got,
the truck got towed." Davon responded, "Yeah it got towed like a
tow truck got that bitch." Duncan asked, "So when the fuck, why
didn't they go get it?" Davon answered, "I don't even know. I'd
rather, you know I ain't even ask them that. He told me like yo,
you ain't gonna believe this, yeah the shit got towed. I'm like
that's crazy. I hung up like I got to tell (unintelligible) this."
Duncan asked, "Right it ain't, it ain't reported stolen or nothing
is it?" Davon answered, "I don't know that's what I'm thinking like
why would it got towed. You feel me? Cause it ain't, the what they,
where they parked it that wasn't no tow away zone, it ain't no snow
93
route or nothing. They parked on a little side street up Whitelock.
So I'm thinking like why would it have just got towed. It might
have been reported. You know what I mean?" Duncan responded,
"Right so a nigger get something, how much you all get from the
store though?" Davon answered, "I ain't, I ain't (unintelligible).
I told you I got a little ass uh, twenty inch flat screen. They
keep trying to give me fifty dollars for it at the pawn shop. I
ain't, I'm about to put that bitch on Craig's List." Duncan asked,
"So what they get for the ear rings?" Davon answered, "All that
shit was fake." Duncan responded, "Oh my god!" Davon continued,
"That's what I'm saying (unintelligible). Duncan asked, "You still
believe them?" Davon continued, "And, and dummy keep saying like
yo, I'm telling you the shit was still in there, the shit was still
in there. I'm like shorty, they don't got nothing and then he tell
me he want a fake jewelry (unintelligible)." Duncan responded,
"Yeah he always do that." Davon continued, "Right you know he keep
talking, I'm telling you like yo niggers don't know. I'm like
shorty you can't tell me shit. Like if a nigger holding he not
gonna be wearing no fake jewelry." Duncan then asked, "The only
that was real was the bag then right?" Davon asked, "The what?"
Duncan responded, "The bag." Davon continued, "Bag, the bag what,
oh yeah, yeah, yeah, yeah, yeah the Jimmy Choo bag." Duncan then
asked an unidentified female in the background how much money a
Jimmy Choo bag was worth. Davon advised that an unidentified female
94
associate returned the bag to Nordstrom's and received a "couple
hundred dollars." Based on their training and experience and other
agents believe that Davon and other unidentified BGF members
committed a commercial robbery along with an auto theft and were
selling the items on the streets of Baltimore. Some of these items
were taken to a pawn shop and at least one Jimmy Choo bag was
returned to Nordstrom's Department Store for profit. Duncan was
expecting to obtain a portion of the profits made from the
commercial robbery and the theft of the truck. Duncan asked, "God
damn where my cut at yo?" Davon asked, "On what?"… After learning
the truck was towed prior to being sold for profit, Duncan asked,
"How much you all get from the store though?"
101. On March 7, 2010, at approximately 10:04 a.m.,
Duncan placed an outgoing call to McIntosh. During the conversation
McIntosh asked, "You come out yet?" Duncan answered, "Not yet."
McIntosh advised, "Boss you need to make this the first stop when
you come out." Duncan asked, "Why what happened?" McIntosh
responded, "Um oh your boy Stephon." Duncan asked, "Which Stephon,
which one?" McIntosh responded, "Uh, the crazy one." Duncan asked,
"Alright what happened?" McIntosh answered, "Oh I guess he was
look, missing something last night. Something very minor and minute
and whipped out on all the people. In front of little kids and all
that, brothers and all that." Duncan responded, "Alright." Based
95
McIntosh was notifying Duncan, the overall city wide commander of
BGF, who she referred to as "Boss," that BGF member "Stephon" lost
an item last evening and in response "whipped out" (a reference to
displaying a handgun.) Based on Stephon's behavior McIntosh was
notifying Duncan so he could handle things with Stephon
appropriately.
Duncan received an incoming call from (443)807-0715, utilized by B.
During the conversation, Duncan advised that he was in the company
of Mike Grey. Duncan told B, "I'm gonna let you talk to him and
what you, what you was telling me." B responded, "Yeah." Duncan
continued, "Just tell him everything you had told me." B responded,
"Alright." Duncan then put Mike Grey on the telephone." Grey
asked, "What's up nigger you talking about me?" B responded, "What
it do?" Grey asked, "What's up?" B responded, "Ain't nothing. Nah,
bas, basically, basically you nah mean." Grey asked, "What, what
about the Noodle, about the Noodles part?" B answered, Yeah. Just,
just basically um little kid, little kid was like, he talked to some
kid, he talked to some kids. Um some dudes from over east Baltimore
and they was like, somebody said don't look up to it. But you know
there's some peoples over there saying that your name had came up
in, in, involved in it, whatever." Grey responded, "Yeah." B
96
continued, "So I was like I, I don't know nothing about that. You
see what I'm saying? I said that they are just summin' but I don't
think it was, it, it (unintelligible) to that. You know what I
mean?" Grey responded, "Yeah." B continued, "So I don't know what,
I what happened but, but the little kid axed to meet um some dudes
over there and they was, they told him like yo don't even ax nothing
else about that. Leave that alone. As far as yo…" Grey responded,
Yeah." B continued, "You know what I'm saying? Then I was like oh
really. So it bet, basically I left, I ain't say nothing else to
him about it. I ain't even ax, yo who told you this who told you
that because he told…" Grey responded, "Yeah." B continued, "He
said that they said leave it alone. I left the shit, I, I left it
alone. But I talked to Sister Kim (McIntosh) and Donnie (Duncan)
um, about Donnie about it." Grey responded, "Yeah." B continued,
"It's just like your name came up and Gene name. So I was like well
Gene, I said how Gene name come up. I said some of these niggers
are chit chattin' on the phone. I said I talked to Gene on, on yo
phone." Grey responded, Yeah." B continued, "So I was like yeah,
I was like I don't know, I don't know nothing about that. You know
what I mean?" Grey advised, "Yeah but I'm on GPS. I ain't, I ain't
do nothing to him. I ain't like him but I ain't do nothing to him
though." B responded, "Right. See I knew you all didn't get along
but I, I just figured it, it wasn't like that." Grey responded,
"Yeah. Yeah but he did that. You know what I mean? He stole from
97
us and shit. So I, I was always on the shit that if I can't
(unintelligible)." Grey and B then talk over each other. B
continued, "But yeah, what, what they said was but he called
somebody else. He called, alright he called, one day I was with
him, he called the dude, I think his name Randy. And…" Grey
responded, "Yeah." B continued, "Randy said that they, I mean they
was saying that you was saying that you had shot Noodles or
something." Grey responded, "Um hum." B continued, "They said that
you said that you had shot Noodles and you supposed to been doing
something to um, damn this a Oakie. You and, and you supposed to
been trying to shot Oakie too or something. But (unintelligible)
got." Grey responded, "Man no." B continued, "They said you had
shot Noodles right. So Noodles went and got, Noodles went and got
all this hospital paper stuff and, and showed me um the hospital
thing, the police had shot him and so forth and so forth. You see
what I'm saying?" Grey responded, "Yeah me, me and Oakie was
together." B responded, "Huh?" Grey continued, "Me and Oakie was
together. Me and Oakie was partners when Noodles and them stole
from Oakie." B responded, "Oh yeah." Grey continued, "Yeah that's
why we was going to get him." B responded, "Oh shit, I don't know…"
Grey continued, "Yeah." B continued, "…nothing about that." Grey
responded, "Yeah." B continued, "Then we heard about
(unintelligible). I just know that, that him, he called some dude
named Rand, Randy and Randy said that you, you said you had shot
98
Noodles or something. And Noodles was like yo ain't shot me yo.
The police shot me or whatever. You feel what I'm saying?" Grey
responded, "Um hum." B continued, "So I was like alright. You know
I ain't never, I never heard nothing bout you, you supposed to shot
(unintelligible)." Grey responded, "Yeah." B continued,
"(unintelligible. I didn't know you all was beefin'." Grey
responded, "No we was on him cause he stole, he (unintelligible).
You know how mother fucker him and Major been going out robbing
every morning. So we had it set up so that they can come up there
and get, get stuff from the little kid's before they go out." B
responded, "Right." Grey continued, "Come and get his jumper." B
responded, "Right." Grey continued, "And then one morning Major
pulled a gun on the little kid's." B responded, "Oh yeah." Grey
continued, "Yeah and that's how…" B asked, "Oh Major, Major robbed
you." Grey continued, "Yeah, yeah that's how Major got shot in his
head." B responded, "Oh yeah, yeah, yeah, yeah." Grey continued,
"Yeah, yeah Noodles right there with him though." B asked, "Oh
Noodles, Noodles was with him?" Grey responded, "Yeah. They was
partners." B advised, "Cause they say Greg was with me, um Major
when yo got shot." Grey responded, "Yeah but Noodles, Noodles,
Noodles might have been the driver that day. (Unintelligible)."
B advised, "Yeah he must have been drunk. He know, he must have
been drivin' but, but yo, yo um, Greg was with him when he got shot
that day. Cause Greg,…" Grey responded, "Yeah." B continued,
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"…Greg called me yeah, Greg called me about that." Based on their
investigation, law enforcement agents believe that Mike Grey had
been accused by an unidentified person in Baltimore of the recent
murder of BGF member Asia Carter, a/k/a Noodles, which occurred in
March of 2010. Grey, who had been speaking with Duncan, utilized
Duncan's phone to clear his name from the murder. Grey explained
that he did not like Carter because he had assisted in robbing
Grey’s and Oakie's (a/k/a David Rich) drug operation, but he (Grey)
was not responsible for the murder.
V. SUBJECT PREMISES
103. Based on the information set forth elsewhere in this
affidavit, my training, experience, and participation in narcotics
investigations, and my conversations with other law enforcement
officers, there is probable cause to believe that the Subject
Premises are locations being used for the storage and distribution
of narcotics, narcotics proceeds, and the facilitation of narcotics
offenses. Additionally, there is probable cause to believe that the
BGF is an association-in-fact racketeering enterprise, and the
Subject Premises are used by the enterprise to further the
enterprise’s illegal activities.
70. Based upon my training and experience and my
participation in this and other narcotics investigations, as well
as my conversations with other agents, I know the following:
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a. Narcotics traffickers often maintain on hand
large amounts of both narcotics and currency in order to maintain
and finance their on-going narcotics business, as well as
paraphernalia used in the manufacture, packaging, preparation, and
weighing of illegal narcotics in preparation for trafficking, and
narcotics traffickers maintain these items where they have ready
access to it.
b. Narcotics traffickers often maintain financial
records and financial instruments related to their narcotics
transactions and the profits derived from those transactions
including, but not limited to, currency, bank checks, cashiers
checks, Western Union receipts, money orders, stocks, bonds,
precious metals, and real estate records;
c. Narcotics traffickers frequently maintain records
of their narcotics transactions including, but not limited to,
books, ledgers, records and other documents relating to the
manufacture, transportation, possession, and distribution of
controlled substances. Such documents are frequently maintained
where the traffickers have ready access to them, including in their
homes;
d. Narcotics traffickers commonly maintain books,
records and other documents that identify and contain the names,
addresses and/or telephone or pager numbers of associates in their
narcotics-trafficking or money-laundering activities, including, but
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not limited to: address books, telephone books, rolodexes,
telephones, pagers, or personal digital assistants with stored
telephone information, notes reflecting telephone and pager numbers,
photographs (to include still photos, negatives, movies, slides,
video tapes, and undeveloped film), and audiotape recordings of
conversations, including those made over telephone answering
machines;
e. Narcotics traffickers commonly maintain
identification and travel documents, including, but not limited to,
tickets, transportation schedules, passports, notes and receipts
related to travel, and motel/hotel receipts;
f. Indicia of occupancy, residency and/or ownership
of the premises to be searched are often present in such premises;
g. Narcotics traffickers commonly maintain many of
the foregoing items in computer files; and
h. Narcotics traffickers commonly maintain the
foregoing items inside combination or key-lock safes or strong
boxes, suitcases, locked cabinets and other types of locked or
closed containers, or hidden compartments, which are secreted in
locations such as the SUBJECT PREMISES, where they may maintain
these items securely.
104. I am further aware based upon my training and
experience and my participation in this and other investigations,
as well as my conversations with other agents that:
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a. Gang members will often maintain and/or possess
a roll call where they list the gang name and then list the members’
names below. Roll call lists often include dollar amounts that
signify and track dues payments made by gang members at meetings.
They may also list the names of allies and rival gangs. Dues are
used to help certain gang members who are incarcerated for acts of
violence and/or drug trafficking post bail or obtain an attorney.
They are also used to purchase weapons or as a “tithe” to higher-
ranking gang members.
b. Gangs use graffiti to mark their territory and
graffiti can be used to disrespect or make threats against rival
gangs, by crossing out the rival gang’s graffiti, or “tag,” and
placing their own “tag.” “Tagging” is an activity where the
participants and/or gang adopt a unique written nickname known as
a “tag.” Gang members “tag” on public or private property and will
often include the gang name in order to show the gang’s area of
control and their personal affiliation with the gang. The writing
of the “tags” results in the crime of destruction of property.
“Taggers” often write their friends’/fellow gang members’ names in
tagging scrapbooks. They also record their “tags” in these books
and will cut out newspaper articles on graffiti and put them in
their scrapbooks. They often will write their unique “tag,”
nickname, and/or gang name on their personal property to identify
their property or to practice their tag. This personal property
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often includes papers, sketchbooks, bedroom walls, backpacks, and
other personal items. They will sometimes try variations of their
“tag” to see how it looks when done differently. Gang members often
possess many items such as spray-paint and wide tip marking pens for
this purpose.
c. Gang members will often maintain photographs,
video recordings, clothing, drawings, letters, notes, cards, or
other correspondence which show their association and/or membership
with the gang as well as their relationship to other members and
associates of the gang. These videotapes and/or photographs
sometimes depict the gang members committing criminal acts,
admitting to the crimes, and making threats against rival gangs.
The correspondence often contains directives from more senior
incarcerated gang members instructing persons on the street to carry
out various criminal acts and must be maintained by persons on the
street as their proof that they have the authority to commit certain
criminal acts. The correspondence also often includes discussions
about criminal acts committed on behalf of BGF. This correspondence
constitutes evidence of criminal acts committed in furtherance of
the underlying criminal enterprise but also documents the gang
member’s association with that enterprise. Your affiant also knows
that gang members in this investigation have referred to and used
the Internet to contact other members. Your affiant knows that
there are websites that gang members use to establish profiles and
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to identify and locate other gang members.
d. Gang members keep in close contact with members
of their gang as well as members of allied gangs. They often
maintain phone and address lists of their associates. These lists
will typically include the person’s nickname or “street name” as
well as their real name. Gang members have been known to use
beepers, cell phones, and two-way digital radios to keep in contact
with each other and to plan and advise about gang meetings. Gang
members often communicate with each other through letters,
particularly when they are incarcerated. Their letters sometimes
detail criminal acts they have done as well as referring to other
gang members and disclosing their identities and crimes they have
committed.
e. Gangs, including BGF, have books or other
documents that set forth the rules and/or code of conduct for
members of the gang. These books are distributed to and maintained
by gang members. BGF members are required to study, and are tested
on their knowledge of, these materials.
f. BGF members use prepaid credit cards as a means
of financing the gang’s illegal activities, and often maintain such
cards and documents relating to such cards.
g. Based on participation in this investigation as
well as discussions with other law enforcement officers, I know that
the type of documents and records described above are typically
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found at the residences of gang members and that such evidence
assists in proving the allegiance of a particular individual to the
gang. I am aware from search warrants conducted in connection with
this and other gang investigations that document(s) that refer or
relate to the individual’s membership in the gang are often located
among the individual gang member’s personal belongings.
A. SUBJECT PREMISES #1 - 1120 Homewood Avenue, Baltimore,

Maryland
105. Based on evidence developed during this
investigation, including information provided by confidential
sources and calls intercepted during wiretaps, I have learned that
Kimberly McIntosh, a/k/a “Sister Kim,” is the highest ranking female
member of BGF in Baltimore. As more fully described above, calls
intercepted over the wiretaps in this investigation indicate that
McIntosh is responsible for the finance of the BGF on the streets
of Baltimore. Additionally, she utilized Subject Premise #1 for the
cutting, packaging, the sale of heroin, and other controlled
substances, as well as near daily meetings of other high ranking
members of BGF. During these meeting, various racketeering
activities of the BGF are discussed and debated among the ranking
structure of BGF, to include, the sale of drugs, acts of violence,
and the disciplining of non-compliant BGF members. In addition to
the calls summarized above, throughout the investigation law
enforcement has intercepted conversations between McIntosh and
others discussing the use of Subject Premise #1. For example:
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a. On March 7, 2010, at approximately 11:09 a.m.,
Duncan placed an outgoing call to Jermain Davis a/k/a Dirty Rice.
During the conversation Duncan asked, "You got some empty caps?"
Davis answered, "Yeah." Duncan responded, "I need them yo. I'm
over Sis house (a reference to Sister Kim’s house, Subject Premise
#1)." Davis responded, "Alright." Based on their training and
advising Davis that he needed some "empty caps" (a reference to
gelatin capsules used for packaging heroin). Davis advised that he
had what Duncan needed at which time Duncan told Davis to bring the
item to "Sis house" (McIntosh's residence, Subject Premise #1.).
b. On March 8, 2010, at approximately 6:21 p.m.,
Duncan received an incoming call from Davis. During the
conversation Davis asked, "Where you at yo?" Duncan answered, "I
had to dip off." Davis asked, "Oh you coming back?" Duncan
responded, "Yeah go to the house and get it." Davis responded,
"Alright." Duncan continued, "Alright I'll be back though but go
to the house and get it." Based on their training and experience
and other information developed during this investigation, law
enforcement agents believe that Duncan was advising Davis to go to
McIntosh's, 1120 Homewood Avenue, Subject Premise #1, and obtain the
heroin which Davis was to sell. On March 7, 2010, SOI #1 notified
law enforcement that Duncan had called he/she on (410)599-5750, the
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Coil Cellphone, and instructed SOI #1 to have Davis come to
McIntosh's residence because he (Duncan) needed Davis to sell heroin
for McIntosh. A short time after law enforcement received the
information from SOI #1, surveillance officers observed Duncan meet
with Davis near the McIntosh residence.
c. On March 21, 2010, at approximately 2:39 p.m.,
Duncan placed an outgoing call to (443)540-5082 utilized by an
unidentified male (UM). During the conversation Duncan asked,
"Where you exactly at?" The UM responded, "Um I'm coming from
church brother. Now is not a good time. Hello." Duncan responded,
"I'm listening." The UM advised, "Yeah now is not a good time
brother. I'm coming from church." Duncan spoke to McIntosh in the
background, "He say he ain't gonna be able to make your all meeting
he coming from church." McIntosh responded, "Ok what time he get
out a church?" Duncan advised, "He coming from church now." The
UM asked, "Where the brother, where the brother at?" Duncan
responded, "No it's (unintelligible). No I ain't talking about that
situation. I'm talking about you need to get with these, with your
other brothers. (Unintelligible) obligation. Your obligation, if
you can't fulfill it then let me know now." The UM yelled, "Stop
the bull crap alright yo." Duncan responded, "It's a meeting. So
could you make it or not?" The UM yelled, "I told you I'm coming
from church. What can I do yo? (Unintelligible) loud on me when
you in front of them niggers, Donnie (Duncan). What you doing man?
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What you gonna do yo?" Duncan responded, "That's what I'm asking.
You can't make it let me know." The UM responded, "Alright I can't
do it yo."
d. On March 21, 2010, at approximately 2:44 p.m.,
Duncan received an incoming call from the same UM as the preceding
call. During the conversation the UM advised, "You cannot be upset
with these little, little spur of the moment meetings." Duncan
responded, "I don't got nothing to do with the committee they, they
call the meetings brother. You see what I'm saying? And…" McIntosh
was then heard in the background, "It's like, and it's an
emergency." Duncan continued, "It's an emergency, it's an emergency
meeting and if you can't make then you can't make it." Duncan then
spoke to an unknown person on another phone. Duncan then returned
to the UM and said, "There ain't nobody here yet. But everybody is
on their way here (a reference to McIntosh’s residence, Subject
Premise #1)." Duncan explained that he and "Smiley" were the only
individuals at McIntosh's residence. The UM advised that he was on
his way. Based on their training and experience and other
agents believe that during the preceding two calls Duncan, McIntosh
and other high ranking BGF members were having an unscheduled
"emergency" BGF meeting and wanted every high ranking BGF member to
be in attendance. During these calls, law enforcement was
monitoring a camera positioned to view the 1100 block of Homewood
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Avenue, the location of Subject Premise #1. Law enforcement was
able to observe Duncan, Harried, a/k/a Smiley, and Erik Ushry near
the entrance to Subject Premise #1.
106. 1120 Homewood Road, Baltimore, Maryland, identified
herein as Subject Premise #1, is a three story painted red brick row
home with a white entry door with a white mailbox to the left of the
entry door. I have learned from records maintained by Baltimore Gas
and Electric (“BGE”) that the utilities for Subject Premise #1 are
in the name of Danisha M. McIntosh.
107. Beginning on or about March 5, 2010, law enforcement
installed a pole camera. The camera maintained a view of the 1100
block of Homewood Avenue, on the same side of the street as Subject
Premise #1. Because of the location of the camera, law enforcement
could not view the front door of Subject Premise; however, it was
possible to view individuals approaching the location. At various
times during this investigation, law enforcement was able to observe
Duncan, McIntosh, Harried, and others going to and from Subject
Premise #1. As recently as April 5, 2010, law enforcement has
surveilled McIntosh entering and exiting this location.
108. Based upon the foregoing and on my training,
experience, and participation in narcotics and gang investigations,
I respectfully submit that there is probable cause to believe that
there will be found in Subject Premise #1 the items set forth in
Attachment A, which constitute evidence, fruits and/or
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instrumentalities of violations of, inter alia, 18 U.S.C. § 1962,
which prohibits participation in a racketeering conspiracy; 21
U.S.C. §§ 841 and 846, which prohibits the distribution and
possession with intent to distribute controlled substances, and
conspiracy to commit those offenses; 21 U.S.C. § 843, which
prohibits the use of a communication facility in furtherance of
drug-trafficking; 18 U.S.C. § 1959, which prohibits violent crimes
in aid of racketeering, and 18 U.S.C. § 1956(d), which prohibits
conspiracy to launder money.
B. SUBJECT PREMISES #2 - 4007 Fordleigh Road, Apt C.,

Baltimore, Maryland
Todd Duncan, a/k/a “Donnie,” is the citywide commander of BGF. As
more fully described above, calls intercepted over the wiretaps in
this investigation indicate that Duncan participates in the daily
operation of the BGF enterprise and supervises all facets of BGF’s
illegal activities to include: the sale of drugs, acts of violence,
and the disciplining of non-compliant BGF members.
110. The residence at 4007 Fordleigh Road, Apartment C,
Baltimore, Maryland, identified herein as Subject Premise #2, is the
residence of Todd Duncan, a/k/a “Donnie.” The main entrance to
Subject Premise #2 is glass door with a blue awning with the numbers
4007 in white on the awning. The apartment is a green door on the
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second floor to the left of the entry with the letter C affixed in
the center of the door.
111. On February 16, 2010, law enforcement agents
established surveillance in the area of Subject Premise #2. At
approximately 9:00 a.m., Duncan was observed exiting the apartment
building, 4007 Fordleigh Road, with a small child. Duncan placed
the child in a gray 2001 Chevy Tahoe with Maryland registration
42124M2. After Duncan was observed exiting the apartment building,
law enforcement requested the utilities for all apartment units in
4007 Fordleigh Road. Based on these requests, law enforcement
learned that Apartment C has utilities in the name of Chamera
Wilson. According to SOI #1, whom SOI #1 described as Mia Wilson,
Wilson is the girlfriend of Duncan. SOI #1's description of the
location of Duncan’s residence matched the location for Subject
Premise #2. Further, on March 31, 2010, law enforcement established
surveillance at Subject Premise #2, at approximately 7:55 a.m., law
enforcement observed Duncan exit the apartment building, 4007
Fordleigh Road, on his way to court for his January 6, 2010 arrest
for making a false statement to an officer (discussed above).
Finally, electronic surveillance authorized by the orders to
intercept Duncan’s phone places Duncan in the vicinity of 4007
Fordleigh Road most overnights.
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Attachment B, which constitute evidence, fruits and/or
in aid of racketeering and 18 U.S.C. § 1956(d), which prohibits
C. SUBJECT PREMISES #3 - 237 East Lafayette Avenue, 2nd

floor, Baltimore, Maryland
Duconze Chambers, a/k/a “Ducon” is a high ranking member of BGF and
controls a street level drug shop. In addition to the calls
summarized above, throughout the investigation law enforcement has
intercepted conversations between Chambers and others discussing the
the sale of drugs from a Chambers’s residences. For example:
a. On February 22, 2010, at approximately 4:27
p.m., Chambers placed an outgoing call to (443)804-8962, subscribed
to Crystal Owens at 22 Stockmill Road, Apartment K, Baltimore,
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Maryland, and utilized by Chips. During the conversation Chips
asked, "What's up Dookie?" CHAMBER responded, "What's up yo?"
Chips asked, "What's up?" Chambers responded, "You man." Chips
continued, "Shit what's up? You good?" Chambers answered, "What
time, I told you I'm trying to make that move with you. I'm trying
to holler at you." Chips advised, "Oh alright, I'm gonna come down
there." Chambers asked, "When?" Chips answered, "I got, listen I
just dropped my girl off all the way out this motherfucker. I'm out
Essex. So soon as I leave Essex." In the background, "Well I gotta
turn up here somewhere." Chambers advised, "Come straight to me."
Chips responded, "Huh?" Chambers advised, "Come straight to me."
Chips asked, "Straight to you?" Chambers answered, "Yeah." Chips
responded, "Alright, where you at down the house?" Chambers
answered, "Yeah." Chips ended, "Alright that's what it be." Based
Chambers was conducting a drug transaction with Chips at Chambers
residence, located at 1017 E Preston Street, Baltimore, Maryland,
Chambers former residence.
b. On February 22, 2010, at approximately 4:46 p.m.,
Chambers received an incoming direct connect call from
316010168595225 with an unknown subscriber, utilized by an
unidentified male (UM). During the conversation Chambers advised,
"Yo what's up? Hey I told you I, I'm not gonna call you until I
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really got it, you know right. You said you wanted to check it out.
Main man, me and yo down here now and shit." The UM responded,
"Alright you gotta give me a couple days yo cause I'm, I'm on flat
zero right now. I need at least three days. I'll be straight
probably like Wednesday." Chambers asked, "What you say?" The UM
answered, "Probably like Wednesday. I'm on flat zeros right now.
So probably like Wednesday." Chambers responded, "Alright that's
what it is." Based on their training and experience and other
agents believe that Chambers was in the process of conducting a drug
transaction with Chips. During the anticipated drug transaction
Chambers spoke with an unknown drug associate to determine whether
the UM wanted to examine, and purchase a quantity of drugs from
Chips. The UM advised he currently had no money, but would on
Wednesday.
c. On February 22, 2010, at approximately 4:52 p.m.,
Chambers received an incoming call from (443)804-8962, subscribed
to Crystal Owens at 22 Stockmill Road, Apartment K, Baltimore,
Maryland, and utilized by Chips. During the conversation Chambers
advised, "Come downstairs you here up now yo." Chips responded, "No
boy I got Janece with me. Come on man." Chambers responded,
"Alright." Based on their training and experience and other
agents believe that Chambers was conducting a drug transaction with
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Chips at Chambers residence, located at 1017 E Preston Street,
Baltimore, Maryland. At approximately the same time as the call,
4:52 p.m., surveillance officers observed a silver 2000 Saturn
bearing Maryland registration 8ADH25 park near Chambers's residence.
A few moments later, the male driver of the 2000 Saturn entered 1017
E. Preston Street. A query of the MVA revealed the vehicle is
registered to Crystal Lorraine Owens, 2650 Lauretta Avenue,
Baltimore, Maryland, the same name as the subscriber of the cell
phone utilized by Chips.
Chambers received an incoming call from (443)762-5482, utilized by
Mark Johnson. During the conversation Johnson asked, "You at work?"
Chambers answered, "No at my house." Johnson responded, "Up your
house." Chambers continued, "Yeah on Lafayette and Guilford."
Johnson advised, "Alright I gotta try to get that. I'm a, I'm a,
I'm in east Baltimore already. Um I'm a ready to come that way."
Chambers responded, "Alright how long you gonna be? I'm gonna be
here though." Johnson advised, "Oh alright I ain't gonna be no more
than bout a half an hour." Chambers responded, "Huh?" Johnson
advised, "I said I ain't gonna be no more than bout a half an hour."
Chambers responded, "Alright." Based on their training and
investigation, law enforcement agents believe that Johnson was going
to meet Chambers at his residence to pick up a drug related item.
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Johnson advised, "Alright I gotta try to get that" (a reference to
a drug related item). Chambers advised that his residence was
located near the corner of Lafayette Avenue and Guilford Avenue.
It is believed by law enforcement, based on this call and others
indicating that Chambers was moving, that Chambers is currently
living with his girlfriend at her residence located at 237 E.
Lafayette Avenue 2nd floor, Baltimore, Maryland. On April 2, 2010
at approximately 10:19 a.m., law enforcement was conducting
surveillance at Subject Premise #3, and observed Chambers exit the
front door of 237 East Lafayette Avenue.
115. 237 E. Lafayette Avenue 2nd floor, Baltimore,
Maryland, identified herein as Subject Premise #3, is the residence
of Chambers, and his girlfriend, who has been previously identified
as Renata Harlaque. I have learned that the utilities for Subject
Premise #3 are in the name of Renata Clark Harlaque, and a
subscriber to a cellphone that contacts Chambers over his cellphone
is subscribed to at Subject Premise #3. Subject Premise #3 is a
three story light gray apartment with a green door. The numbers 2
3 7 are above the door on a brown placard in gold.
there will be found in SUBJECT PREMISES #3 the items set forth in
Attachment C, which constitute evidence, fruits and/or
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drug-trafficking; and 18 U.S.C. § 1959, which prohibits violent
crimes in aid of racketeering.
D. SUBJECT PREMISES #4 - 1502 North Aisquith Street,

Baltimore, Maryland
Lamont Crooks is an associate of the BGF, and a source of supply of
drugs for the organization and others. In addition to the calls
summarized above, throughout the investigation law enforcement has
intercepted conversations between Crooks and others discussing the
sale of drugs from locations utilized by Crooks, including Subject
Premise #4. For example:
a. On March 21, 2010, at approximately 7:46 p.m.,
Crooks received an incoming call from (443)600-0645, utilized by
Earle Moore, a/k/a Harold Moore. During the conversation Moore
asked, "What's up Big Homie?" Crooks responded, "Ain't nothing
what's happening with you?" Moore responded, "Hey I got that for
you." Crooks responded, "Alright, alright. I'm a um, what you, you
118
still around the way?" Moore responded, "Huh?" Crooks asked, "You
still around, around the way or you at your house?" Moore answered,
"Nah I', I'm home." Crooks responded, "Oh alright, alright. I'm
a try to shoot through there." Moore responded, "Alright." Based
during this investigation, law enforcement agents believe that Moore
had drug proceeds that he owed to Crooks from a past drug
transaction. Moore advised, "Hey I got that for you" (a reference
to drug proceeds.)
Crooks received an incoming call from Moore. During the
conversation Crooks advised, "Hey yo I been waiting on this still,
on a mother fucking ride man. Mother fucking taking kind of long.
So I might just have to get with you like early in the morning or
something." Moore responded, "Alright cause I get up, I, I'll be up
like early in the morning like seven, eight." Crooks responded,
"Alright so that'll work. Yeah so I, you know. I'll be straight
to you. Oh, I mean you in though right." Moore responded, "Yeah."
Crooks continued, "What time, what time you going out tonight?"
Moore advised, "Oh I ain't even going back out tonight. I'm, I'm…"
Crooks responded, "No I'm talking about what time you going to
sleep?" Moore answered, "Oh I'm up for a second. Just hit me."
Crooks responded, "Alright yeah so if, you know if this nigger, if
he ever come through. Then, you know what I'm saying? Crooks
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explained that he does not have a vehicle to drive at the current
time. Crooks advised, "So you know I'll hit you back tonight or you
know, or tomorrow morning." Moore responded, "Ok." Based on their
investigation, law enforcement agents believe that Crooks and Moore
had planned a drug related meeting; however, currently Crooks did
not have a ride to meet with Moore. Crooks advised that they may
have to conduct their drug related meeting the following morning.
c. On March 22, 2010, at approximately 8:58 a.m.,
conversation Moore asked, "Yo what's up Big Homie?" Crooks
responded, "Ain't nothing man. I'm waitin', I'm waitin' on the uh,
the Homie to come swoop me now." Moore responded, "Alright."
Crooks asked, "Alright so what you, you still at the house or you
gonna be down the way?" Moore answered, "Uh, I'm a probably, I'm
gonna be at one of em'. Cause I'm, I'm getting ready to see what
my uncle want. Cause if you need me to I can bring it to you if you
need me to." Crooks responded, "Oh alright um, what's, are you
mobile?" Moore responded, "I, when my uncle come he a bring me
wherever I needed to go at." Crooks responded, "Oh alright." Moore
continued, "That's why I (unintelligible) hand it to you. Cause
mother fucker's keep calling me worrying me and I'm like shit I just
got up. Like damn." Crooks responded, "Yeah. Alright…" Moore
advised, "(Unintelligible). I, I can call you and find out what you
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want me do." Crooks responded, "Alright so um that, that, the other
thing we'll just, you, you want that?" Moore responded, "Well yeah,
I'd grab and go ahead, go ahead and do that." Crooks responded,
"Alright, alright so um, that way I'll know cause I'm a have to run,
you know. Well I mean, just let, let me know when he, hit me when
he get there. Then that way I know what I have to um do." Moore
responded, "Alright yeah but I'll go ahead and grab that, alright."
Crooks responded, "Alright." Based on their training and experience
enforcement agents believe that Crooks and Moore had planned a drug
related meeting during which Moore was to give Crooks drug proceeds
and in turn Crooks was going to supply Moore with a new quantity of
drugs. Moore advised, "Alright yeah but I'll go ahead and grab
that, alright (a reference to obtaining drugs.)” Crooks responded,
"Alright" (an agreement to supply Moore with a new quantity of
drugs.)
d. On March 22, 2010, at approximately 9:09 a.m.,
conversation Moore advised that he had a ride to come and meet with
Crooks. Crooks asked, "You know where the Rite Aid at on Harford
Road?" Moore answered, "Yeah." Crooks continued, "Harford in
between like Federal and Oliver?" Moore responded, "Yeah." Crooks
advised, "Yeah meet me right there." Moore responded, "Alright."
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that Crooks and Moore had planned to meet at the Rite Aid located
at 1521 Harford Road to conduct a drug transaction.
e. On March 22, 2010, at approximately 10:03 a.m.,
conversation Moore advised, "I'm here." Crooks responded, "Alright,
alright I'll be right there." During this conversation law
enforcement established surveillance at the Rite Aid located at 1521
Harford Road, approximately three blocks from Crooks’s residence.
A few minutes after this conversation, Crooks walked onto the
parking lot and met with Moore and George Cunningham, the driver of
the vehicle. Moments later, Crooks, Moore, and Cunningham entered
Cunningham’s vehicle and left the lot. Law enforcement followed the
vehicle to the 1500 block of Aisquith Street. Crooks then exited
the vehicle and walked to the front door of his residence located
at 1502 Aisquith Street, Subject Premise #4. Moore and Cunningham
then drove out of the area. Based on the calls between Crooks and
Moore, as well as the surveillance of the drug related meeting, a
car stop was conducted on the vehicle occupied by Moore and
Cunningham. Upon approaching the vehicle, law enforcement observed
a clear bag containing numerous gelatin capsules containing
suspected heroin inside of the vehicle. Both Moore and Cunningham
were arrested. Based on their training and experience and other
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agents believe that Crooks had supplied the heroin seized from Moore
and Cunningham during their meeting at the Rite Aid located at 1521
Harford Road. It is believed by law enforcement that Crooks
obtained the heroin from his residence located at 1502 Aisquith
Street and returned to the residence, Subject Premise #4, with the
money discussed with Moore in the preceding calls.
118. The residence at 1502 North Aisquith Street,
Baltimore, Maryland, identified herein as Subject Premise #4, the
residence of Lamont Crooks, is a two story brick row home with a red
front entry door with the numbers 1502 displayed on the right side
of the building near the entry door. On March 18, 2010, law
enforcement established surveillance at Subject Premise #4. At
approximately 10:32 a.m., Crooks was observed smoking a cigarette
in backyard of the that location. Later that same day, at
approximately 11:35 a.m., law enforcement observed Crooks exit
Subject Premise #4 via the front door.
Attachment D, which constitute evidence, fruits and/or
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E. SUBJECT PREMISE #5 - 2004 East Baltimore Street,

Baltimore, Maryland
Davon McFadden, a/k/a Ben, is a BGF member. McFadden and Duncan
sometime pool their money to purchase larger quantities of drugs.
On several occasions during this investigation law enforcement has
intercept conversations demonstrating McFadden’s involvement in the
BGF criminal enterprise. For example:
Duncan placed an outgoing call to (443)759-2466, utilized by
McFadden. During the conversation Duncan advised, "Yo I had to go
back to work right but yo good though." McFadden asked, "He's
straight?" Duncan answered, "Yeah." McFadden responded, "Alright
tell him, alright I'm about, I'm, I'm, I'm probably gonna have to
wait. I'm gonna see what's up though. See if yo give me something
else. You can take that for yourself." Duncan responded,
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agents believe that Duncan was advising McFadden that "yo", (a
reference to a UM, whom Duncan was observed by law enforcement
having a drug related meeting with at 8:00 p.m., the same day) had
the money to purchase a quantity of drugs from Duncan. Duncan
advised McFadden of this to ascertain whether McFadden wanted to
participate in the drug transaction with the UM. McFadden advised,
"I'm probably gonna have to wait. I'm gonna see what's up though.
See if yo give me something else. You can take that for yourself."
It is believed by law enforcement that Duncan and McFadden on
occasion work together selling drugs when a large purchase is
requested. This type of working relationship is common within the
hierarchy of BGF. High ranking members of BGF not only want
themselves to be successful in their criminal endeavors but also
want gang members to be able to live a comfortable life.
b. On March 5, 2010, at approximately 11:24 a.m.,
Duncan received an incoming call from McFadden. During the
conversation Duncan said, "Yeah I just calling you letting you know
the knockers (police) was around there." McFadden asked, "What?"
Duncan asked, "You heard me?" McFadden asked, "What?" Duncan
advised, "I was calling to let you know them knockers was around
there. On Biddle and Greenmount." McFadden responded, "You said
what?" Duncan responded, "The police yo, the police." Based on
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this investigation, law enforcement agents believe that Duncan was
warning McFadden that the police were in the area of Biddle Street
and Greenmount Avenue, an area where McFadden sells drugs. During
this time frame law enforcement was notified that a Baltimore City
Narcotics squad was making drug arrests in the area of Greenmount
Avenue and Biddle Street.
Duncan placed an outgoing call to McFadden. During the conversation
Duncan advised, "Hey you know Trap locked up to yo." McFadden
responded, "Yeah I know Lope told me. He said he got locked up
right after he came and seen me. (Unintelligible) I said I had got
a little something from Ensor Street and shit. That's when he got
locked up by them. (Unintelligible)." Duncan responded, "Oh
alright then that's all I wanted to know." Based on their training
inquiring of McFadden the circumstances of "Trap’s" arrest. McFadden
advised, "He said he got locked up right after he came and seen me"
(a reference to Trap being arrested after obtaining drugs from
McFadden). The arrest of "Trap" matches the drug arrest conducted
by the Baltimore Police Department earlier in the day.
Duncan placed an outgoing call to McFadden. During the conversation
Duncan advised, "Yo they just raided what's a name and them house
126
yo." McFadden asked, "Who?" Duncan continued, "Where Dirty Rice,
(a/k/a Jermain Davis), at." McFadden asked, "For real?" Duncan
responded, "Yeah." McFadden responded, "Oh my god man." Duncan
asked, "You gave him something?" McFadden answered, "Yeah." Duncan
responded, "Man." McFadden continued, "God damn yo. This nigger
got no luck yo. Um, um, um. Who went in there?" Duncan answered,
"Um probably the knockers (police) and the blue and whites."
McFadden asked, "Where you at?" Duncan answered, "Around there
trying to see what the fucks going on." McFadden asked, "Who out,
who around the way?" Duncan responded, "Huh?" McFadden asked, "Who
around the way?" Duncan answered, "Nobody." McFadden asked, "What
made them do that?" Duncan answered, "Man they raided more, they,
they, his house ain't the only house raided, they going up in. They
going in all them houses around there. They going in like two
people houses in that court." Based on their training and
advising McFadden that Jermain Davis, a/k/a Dirty Rice, a member of
their drug organization had been arrested at his house during a drug
raid. McFadden was concerned because McFadden had recently given
Davis heroin. Duncan asked, "You gave him something?" (a reference
to providing Davis drugs.) McFadden answered, "Yeah." It was later
learned by law enforcement that Baltimore City narcotics
investigators arrested Jermain Davis, a/k/a Dirty Rice at his
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residence, 847 Abbott Court, during the execution of a search
warrant. Seized during the arrest was a quantity of heroin.
121. On March 10, 2010 at approximately 10:45 a.m., law
enforcement established surveillance at 2004 East Baltimore Street,
Subject Premise #5. At approximately, 1:14 p.m., law enforcement
observed McFadden exit Subject Premise #5 and enter a gold colored
mini-van with a North Carolina registration. On a previous
occasion, December 21, 2009 (discussed above), law enforcement
observed McFadden operating a 2002 four door Acura registered in
McFadden’s name at Subject Premise #5. On March 31, 2010, law
enforcement again observed McFadden exit Subject Premise #5 and
enter the gold mini-van; however the van had different plates and
was registered to McFadden at Subject Premise #5.
122. The residence at 2004 East Baltimore Street,
Baltimore, Maryland, identified herein as Subject Premise #5, is a
three story brick row home with two windows with green trim to the
left of the entry door. A white placard with the numbers 2004 in
black is on the left side of the entry door, and black railing
leading to the door. The property is listed to the Housing
Authority for Baltimore City
there will be found in SUBJECT PREMISES #5 the items set forth in
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Attachment E, which constitute evidence, fruits and/or
in aid of racketeering and and 18 U.S.C. § 1956(d), which prohibits
F. SUBJECT PREMISES #6 - 1204 Wilcox Street, Baltimore,

Maryland
investigation, including calls intercepted during wiretaps, I have
learned that Jon Brice, a/k/a “Tiger,” is a member of BGF and works
along with other members in the distribution of heroin in east
Baltimore. Several calls were intercepted during this investigation
in which Brice, a/k/a “Tiger,” discussed the distribution of heroin.
Duncan placed an outgoing call to (410)940-4668, subscribed to Tiger
Brice, PO BOX 54988, Irvine, California, utilized by Jon Brice.
During the conversation Duncan advised, "I need you to come around
here and do something real quick." Brice responded, "Alright." At
approximately 1:24 p.m., Duncan placed an outgoing call to Brice.
During the conversation Duncan asked, "Tell me something." Brice
129
responded, "We good shorty." Duncan responded, "Alright." Brice
advised, "On a scale I'd give it an eight." Duncan responded,
"Alright that's what's up." Based on their training and experience
enforcement agents believe that Duncan obtained a sample of his
heroin from McIntosh's house, and transported it to Brice’s house,
1204 Wilcox Street, Subject Premise #6, and then had Brice test the
quality of the heroin. According to Brice, on a scale from one to
ten he give's the quality an "eight." During the course of the
these calls surveillance observed Duncan at McIntosh’s residence and
the Brice residence.
Duncan placed an outgoing call to (443)467-7687, utilized by Brice.
During the conversation Duncan advised, "Meet me around there."
Brice responded, "Alright." Duncan continued, "I'll call you when,
yeah meet me around there. I'm on my way around there now,
alright." Brice responded, "Alright, alright." Duncan advised,
"I'm gonna be about ten minutes." Brice responded, "Alright."
Duncan said, "They set around, go around and sit down there on the
steps." Brice responded, "Alright." Based on their training and
instructing Brice to meet him (Duncan) at McIntosh's home, so Brice
could handle a drug related matter for Duncan. Shortly after the
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call law enforcement observed Brice approach the McIntosh residence
on a bike. A short time later, Duncan arrived and approached the
front of McIntosh's residence. Moments later, Duncan and Brice were
observed leaving the front of the residence. Brice then rode on the
bike toward his residence located at 1204 Wilcox Street. A few
minute's later agents and officers observed Brice enter his
residence. Based on their training and experience and other
agents believe that Duncan was having Brice handle a drug related
matter for him. During the course of the investigation Brice has
been identified as a tester or quality control advisor for heroin
that is sold by Duncan. On at least one occasion, Duncan has been
observed leaving McIntosh's residence, 1120 Homewood Avenue, Subject
Premise #1, and shortly thereafter entering the residence of Brice.
After staying only a short period of time, Duncan then left Brice’s
residence and departed the area. Shortly after leaving Brice's
residence Duncan spoke with Brice over the telephone and was
informed by Brice of the quality of some heroin.
Duncan placed an outgoing call to Brice. During the conversation
Duncan asked, "You in the house Tiger?" Brice responded, "Nah I'm
around here on Ensor Street." Duncan advised, "So I need, I need
to get in your house for a minute." Brice asked, "You need to get
in the house?" Duncan answered, "Yeah." Brice responded,
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agents believe that Duncan needed access to Brice's home, 1204
Wilcox Street, Subject Premise #6, to conduct drug related business,
specifically the mixing and packaging of heroin. Brice allow Duncan
to use his home for his drug business.
Chambers received an incoming call from Duncan. During the
conversation Chambers asked, “Who’s this?” Duncan answered,
“Donnie.” Chambers responded, “What’s up, ain’t shit.” Duncan
responded, “Yeah, hey do me a favor.” Chambers responded, “Yeah.”
Duncan continued, “Call Tiger (Brice) and just see, see if he’s in
the house (Subject Premise #6) and then call me right back.”
Chambers responded, “I don’t know. I don’t think he in there.
Cause they just bust his windows out.” Duncan asked, “Who bust his
windows out?” Chambers answered, “Little Darry and them.” Duncan
asked, “Why?” Chambers answered, “Man I think, I think he owes
them, he said, he said that shorty money got stolen.” Duncan
responded, “Got stolen?” Chambers continued, “Yeah like you know
Darian was staying there and like four hundred and something
dollars.” Duncan responded, “Damn.” Chambers continued, “Yeah you
know Terry got that white boy in there too.” Duncan responded,
“Right. Well the windows don’t look that bad. I just rode past
there.” Chambers explained that he would call Brice. Based on
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this investigation, law enforcement agents believe that Duncan
wanted Chambers to contact Brice so he (Duncan) could meet with
Brice to discuss drug related business. Chambers advised that Brice
was unlikely to be home because he is being held responsible for the
theft of four hundred dollars of drug money belonging to Darry a/k/a
Darian.
125. The residence at 1204 Wilcox Street, Baltimore,
Maryland, identified herein as Subject Premise #6, is the residence
of Jon Brice, a/k/a “Tiger.” Subject Premise #6 is a two story
brick row house with a black screen/metal door, and green front
entry door, with the numbers 1204 in black affixed to the entry
door.
Attachment F, which constitute evidence, fruits and/or
133
G. SUBJECT PREMISE #7 - 1619 Riverwood Road, Essex, Maryland
learned that James Harried, a/k/a “Smiley,” is a member of BGF.
Harried’s presence has been requested on several occasions by BGF
members to participate in the investigations of BGF member, who are
accused of violating BGF rules.
a. On February 14, 2010, at approximately 1:06 p.m.,
Chambers placed an outgoing call to Harried. As the call was being
placed Chambers, is heard in the background saying, "Where the fuck
Taterman at? He said the security guard, nah he said Taterman just
knocked a nigger out. I said what the fuck going on? He said the
nigger threw some water. So Lamont like yo everybody, I said man
I don't know who up…" Harried then answered the call. Chambers
said, "Hello Smiley." Harried responded, "Yeah." Chambers
continued, "This Ducon (Chambers) man." Harried said, "What's up?"
Chambers continued, I'm, I'm, I'm telling this, I'm, I'm calling you
man because they, I need to see you man cause…" Harried asked, "Why
what's up?" Chambers answered, "Alright, why because um, you know
Donnie (Duncan) say um, um Black running me through and, and, and,
and he running me through for something that I don't have, I really
134
didn't have knowledge of. You know what I'm saying?" Harried
asked, "What?" Chambers continued, "I didn't have knowledge of."
Harried asked, "Who the hell is Black?" Chambers answered, "Rome,
that's his name Black, Rome." Harried responded, "Alright, um, you,
you need to see me now or, or…" Chambers answered, "Well you close
by?" Harried answered, "No I'm out in the county." Chambers asked,
"Alright so you good to come down tomorrow then?" Harried
responded, "Yeah." Chambers responded, "Alright." Harried asked,
"This your number right?" Chambers answered, "Yeah." Harried
advised, "Alright I'm gonna call you as soon as I get in town."
Chambers responded, "Alright." Based on their training and
investigation, law enforcement agents believe that Chambers wants
to meet with Harried, a/k/a Smiley, a high ranking BGF member, to
explain his version of the events surrounding the fight and Black's
request to have Chambers "run through" for not assisting fellow BGF
members in the fight. CS2 had previously identified “Smiley” as one
of the BGF members who took part in having CS2 sanctioned
(physically beaten) for the misappropriation of BGF funds.
b. On February 15, 2010, at approximately 5:04 p.m.,
Chambers placed an outgoing call to (443)909-5173, utilized by
Roddy. Upon answering the call, which was on speaker mode, Chambers
advised, "I said we got Unc here now. But I'm saying, I was telling
them about the situation and shit. I was letting them know that you
135
was there too." Roddy responded, "Right." Harried, a/k/a Smiley,
a/k/a Unc asked, "Like ok, can you tell me what happened?" Roddy
explained, "Alright as far as um, I mean I would say far as anybody
being aware of the situation, I would say that's impossible because
it's like, you know we was all there but like the brother didn't put
us on point basically. So like when it happened it was just, far
as it, you know just being spontaneous and then you know just a
whole shit just broke out. Cause like, you know what I mean? Once
the shit went down everybody just went everywhere. So you know it's
dark and you can't tell who's who and…" Harried responded, "Yeah."
Roddy continued to explain his version of the events regarding the
fight. Chambers then chimed in and began explaining his version of
the events. Based on their training and experience and other
agents believe that Chambers, Harried, and other unknown males were
together and speaking with Roddy on speaker phone regarding the
fight and the events that led to the investigation of Chambers.
Ultimately, Harried was in charge of conducting the investigation
for BGF.
c. On February 20, 2010, at approximately 4:27 p.m.,
Chambers received an incoming call from Harried. The call went
unanswered and went to voicemail. As the call was being connected,
Harried was heard in the background stating, "Nah matter a fact, uh,
matter a fact sell him a hundred." An unidentified male, again in
136
the background, responds, but was unintelligible. Harried then
continued, "That or that, either one." The unidentified male asked,
"Yeah but can, can he handle it?" Based on their training and
investigation, law enforcement agents believe that Harried was
advising one of his drug associates to sell an unidentified person
a quantity of drugs, "sell him a hundred."
Chambers received an incoming call from (443)600-5191, subscribed
to Lawanne Jackson, 1619 Riverwood Road (Subject Premise #7), Essex,
Maryland, utilized by Harried. During the conversation Chambers
advised, "Soon as Rudy bring the whatya call’m to me I'm, I'm a
shoot that, the hundred down there probably to you or Sister Kim
(McIntosh)." Harried responded, "Yeah give it, give it to a, give
it to Sis (McIntosh) cause um we out, we out right now." Chambers
responded, "Alright where you at?" Harried answered, "Uh going to
take care of something." Chambers responded, "Oh ok. I thought you
all was, oh he, oh did you go down there?" Harried responded,
"Huh?" Chambers advised, "You know, you know double R was down
Sister Kim house." Harried responded, "Yeah, yeah, yeah I got it."
Chambers advised, "You already, you, I was just down there."
Harried responded, "Oh so you already know about it." Harried
responded, "Yeah we get ready to go take, straighten the shit out
now." Chambers responded, "Oh ok, alright." Harried advised, "So
137
I'll, I'll, I'll tell you when we get down there." Based on their
investigation, law enforcement agents believe that there was a BGF
meeting that was to occur at McIntosh's residence. During the
meeting each member was to pay their BGF dues. Additionally, prior
to the meeting, Duncan and Harried were handling an unidentified
problem with a BGF member. Harried advised, "Yeah we get ready to
go take, straighten the shit out now."
e. On March 19, 2010, at approximately 9:02 a.m.,
Duncan received an incoming call from Harried. During the
conversation Duncan asked, "Kevin locked up?" Harried answered,
"Yeah he, he um need four hundred more dollars to get out. He said,
she said, he said if I got it, trying to get out. He said he got
like six thousand dollars (unintelligible). I guess she got the
rest, she got some of the money but she needs four hundred more."
Duncan advised, "I'm gonna call Ben (McFadden) and them." Harried
asked, "Alright you uh, you want this number so you can call the
girl back?" Duncan responded, "I don't want to talk to her."
Harried asked, "Oh you gonna give it Ben (McFadden) and them?"
Duncan responded, "I'm, I'm a call Ben and them and tell Ben to call
you. But I'm gonna tell him what, what to do though. But when I
get the money, once they get the money then they just call her and
give her the money to get, bail yo out." Harried responded,
"Alright that's what's up." Duncan asked, "Yeah what's up with you
138
though?" Harried answered, "Nothing I'm like she's like, she's like
can I speak to ‘brother Smiley.’ I'm like who the fuck is this?"
Duncan responded, "Yeah." Smiley continued, "You know he wrong for
doing that shit like that. He supposed to (unintelligible)."
Duncan responded, "Yeah, right and my thing is I gave him a hundred
dollars, he owes Sis (McIntosh) three hundred dollars, he say he was
getting put out and all this shit. I give him a hundred dollars so
he can go get his car fixed." Harried responded, "Yeah." Duncan
continued, "He got to much shit going on with him." Harried asked,
"Alright you want to let him sit for a while we can let him sit for
a while, if you want to let him sit." Duncan responded, "Yeah he
wants, I'm, I'm a make sure they don't raise his bail. You feel
what I'm saying?" Harried responded, "Yeah." Duncan continued, "Or
whatever but um man nobody keep going through all that shit."
Harried responded, "Alright let him sit for a while. Shit you know
how I feel." Duncan then instructed Harried to call and find out
the reason for Kevin’s incarceration. Based on their training and
investigation, law enforcement agents believe that Harried was
advising Duncan that BGF member Kevin needed additional bail money.
Duncan explained that he would advise McFadden and have him
(McFadden) call Harried. Ultimately, Duncan and Harried agree to
let Kevin sit in jail for a while to show him that he can't keep
breaking the law, getting caught and expecting BGF to come to his
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rescue.
f. On March 19, 2010, at approximately 11:04 a.m.,
Duncan received an incoming call from Harried. During the
conversation, Harried advised he spoke with a female regarding
Kevin. Harried asked, "You want to let him sit? Cause if you want
to let him sit I, I, I won't call her back." Duncan answered, "No,
no we gonna get him. But my, my, my thing is as soon as Ben
(McFadden) put some minutes on his phone I'm gonna tell him to go
around and collect some dues from everybody and get his ass out.
But man that shit crazy." Harried advised, "Yeah but he still gonna
have to pay when he get out though." Duncan responded, "Yeah he
gonna pay that shit when he get out." Based on their training and
investigation, law enforcement agents believe that Duncan was going
to have BGF member McFadden collect dues from BGF members in the
community to post Kevin’s bail.
128. 1619 Riverwood Road, Baltimore, Maryland, identified
herein as Subject Premise #7, is the residence of James Harried,
a/k/a “Smiley.” Subject Premise #7 is a two story red brick row
house with a white entry door and the numbers 1619 in black on a
white placard to the left of the door. The entrance is covered by
a roof with a black railing leading to the entry. According to
records maintained by BGE, the utilities for Subject Premise #7 are
in the name of Lawanne S. Jackson. Lawanne S. Jackson is also the
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subscriber for cellular telephone (443)600-5191, the cellphone
utilized by Harried. Further the phone is subscribed to at the
address of Subject Premise #7. Finally, on March 24, 2010, law
enforcement were conducting surveillance at Subject Premise #7. At
approximately 6:05 a.m., Harried was observed exiting Subject
Premise #7.
Attachment G, which constitute evidence, fruits and/or
H. SUBJECT PREMISE #8 - 5305B Valiquet Avenue, Baltimore,

Maryland
130. Based on a series of telephone conversations and
contemporaneous surveillance conducted by law enforcement on March
19, 2010, SUBJECT PREMISE #8 has been identified as a possible stash
141
location for Duncan and the BGF enterprise. The series of calls and
surveillance is described below:
Duncan received an incoming call from (443)540-5082, utilized by an
unidentified male (UM). During the conversation the UM explained,
"The little nigger from over west Baltimore he ain't getting back
or nothing." Duncan responded, "Oh yeah." The UM responded, "Yeah.
This shit crazy yo. What's going on with you?" Duncan answered,
"I, I want to, I, I want to um you know take care of what needs to
be tooken care of. You see what I'm saying?" The UM answered,
"Yeah." Duncan continued, "But we definitely need that from little,
from shorty." The UM advised, "Sh, he ain't answering. I just told
Cali in the beginning yo." Duncan responded, "I know what you
saying. You, you know what I'm saying?" The UM responded, "Yeah."
Duncan advised, "I'm, I'm a, I'm a you know just fuck with Tay."
The UM asked, "Say it again." Duncan responded, "Just fuck with
Tay." The UM responded, "Oh yeah." Duncan continued, "That, that,
that, that's the only legit thing." The UM asked, "Oh he came
through?" Duncan answered, "Yeah." The UM responded, "Wow."
Duncan continued, "You feel what I'm saying?" The UM asked, "You,
you hit him again?" Duncan answered, "No I'm, you know, you already
know like what we got to do." The UM responded, "Man let's do that
shit asap yo." Duncan responded, "I know yo." The UM continued,
"God damn Donnie. Man come get me, come get me yo. I'll do it."
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Duncan responded, "I got my son, I, I, I'm going to but my son
gettin' his hair done right now." The UM responded, "Alright what
time you think you be done." Duncan advised, "Waiting, waiting on
him now. It ain't gonna take long. So just answer your phone.
Where you at?" The UM responded, "I'm at my mother house." Duncan
continued, "Alright that's what's up." Duncan and the UM then spoke
about Duncan's son. The UM then said, "Yeah yo hit, hit, hit me yo.
I'll do that shit. I'll even do it at Calvin's just have them all
in three hundreds or whatever yo. Give that nigger everything."
Duncan responded, "Right." The UM continued, "Give him everything
yo." Duncan advised, "Yeah I, that's, that's the only way it'll
work out any old way." The UM responded, "Yeah." Duncan continued,
"You see what I'm saying? Cause I'll (unintelligible). When I
called yo I want to like you know, the shit will be today for real."
The UM responded, "Yeah." Duncan asked, "You feel me?" The UM
responded, "Yeah that was (unintelligible)." Duncan continued, "He,
he, yeah he wasn't trippin or nothing." The UM responded, "Yeah hey
I just want to start from scratch yo." Duncan responded, "I know."
that Duncan and the UM are pooling their money to purchase a new
shipment of heroin from Tay because they had a problem with their
alternate drug source. The problem with the alternate drug source
is believed to be the quality of the drugs making it difficult to
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profit from the sale. Duncan advised, "I'm, I'm a, I'm a you know
just fuck with Tay." The UM asked, "Say it again." Duncan
responded, "Just fuck with Tay." The UM responded, "Oh yeah."
Duncan continued, "That, that, that, that's the only legit thing"
(a reference to drugs being of good quality). The UM asked, "Oh he
came through?" Duncan answered, "Yeah." As the conversation
continued the UM advised, "Give him everything yo" (a reference to
drug money). Duncan advised, "Yeah I, that's, that's the only way
it'll work out any old way" (a reference to the two of them making
money selling drugs.) The UM explained, "Yeah hey I just want to
start from scratch yo." Duncan responded, "I know" (a reference to
getting back to making a lot of money from the sale of drugs.)
b. On March 19, 2010, law enforcement established
surveillance at 102 South Bouldin Street, the home of Angie Wilson,
a paramour of Duncan. At approximately 10:12 a.m., law enforcement
observed Duncan exit the address with a small child and enter his
2001 Chevy SUV. Duncan was then followed to several locations,
including 127 Collington, the home of his mother, where he dropped
off his child. At approximately 10:38 a.m., Duncan was observed to
return to the area of South Bouldin Street and enter 102 South
Bouldin. At approximately 11:19 a.m, law enforcement observed
Ronald Scott, a/k/a “Piper,” arrive in the 100 block of South
Bouldin Street. Scott was driving a 2004 Infiniti and was
accompanied by another black male. Scott and the unknown male stood
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outside of 102 South Bouldin, and at approximately, 11:21 a.m.,
Duncan was observed to exit 102 South Bouldin and speak with Scott
and the unknown individual. The meeting lasted approximately 4
minutes after which, Duncan approached his vehicle and Scott and the
unknown male approached theirs and both drove from the area.
c. On March 19, 2010, at approximately 11:26 a.m.,
Duncan received an incoming call from (443)449-1474, subscribed to
Henry Giles, 1210 Wilcox Street, Baltimore, Maryland, utilized by
Henry. During the conversation Duncan asked Henry if Potter was in
school. Duncan advised, "If Potter in school get the key and call
Piper and give it to Piper." Henry responded, "Alright." At
approximately 11:33 a.m., Duncan received an incoming call from
Henry. During the conversation Henry advised, "I don't got Piper
phone number in my phone. Tell him to call me. I got the key
though." Duncan responded, "Alright, alright." Based on their
telling Henry to obtain a key for McIntosh's home, Subject Premise
#1, from Potter and give the key to Piper.
Duncan received an incoming call from (410)504-2763, utilized by an
unidentified male (UM). During the conversation the UM advised,
"Alright yo we got the key. Now what's up?" Duncan answered,
"Alright go to the house." The UM responded, "Um to uh… Hello."
145
Duncan responded, "Go to Tiger's (Brice’s), alright." The UM
responded, "Huh?" Duncan responded, "Go to Tiger's." Duncan
explained to the UM to go to Tiger's until he (Duncan) gets there.
that Duncan wanted one of his drug associates to meet him at
Tiger's, a/k/a Brice’s home so he could help Duncan with some drug
related business.
e. At approximately 11:42 a.m., Duncan was observed
to pull into the driveway of 5305B Valiquet Road, Subject Premise
#8. Duncan exited his vehicle and entered the location. Duncan
stayed inside the location for approximately ten minutes and then
was observed exiting the location carrying an object he placed under
the driver’s seat of his 2001 Chevy Tahoe. Duncan then briefly
returned to side of Subject Premise #8 then reentered his vehicle
and left the area.
f. On March 19, 2010, at approximately 12:21 p.m.,
Duncan received an incoming call from the same unidentified male
(UM). During the conversation the UM advised, "Yo saying he don't
know where to at in, in, in Sister Kim's." Duncan responded, "Um
that's the whole thing is ya'll got to look upstairs somewhere. It
should be in one of them bags yo." The UM responded, "So you want
us to go upstairs and look inside one of the bags?" Duncan
responded, "Yeah." The UM advised, "Only thing, only thing we gonna
146
need is the um…" Duncan advised, "It should be in, in the white bag
I had. Cause I'm around Tiger's (Brice’s) house (1204 Wilcox,
Subject Premise #6) now." The UM advised, "This mother fucker don't
want to go in there." In the background Scott, a/k/a Piper, then
said, "I'm going in there." The UM advised, "So I'm, alright,
alright no he going." Duncan responded, "Man, it's not time for you
all playing games man." Scott then used the UM's phone to speak
with Duncan. Duncan asked, "You don't know where to look at?"
Scott answered, "No I know about the drawer but nah I don't
(unintelligible)." Duncan responded, "No I ain't talking about the
drawer. Nah look, look in the closet." Scott responded, "Uh huh."
Duncan advised, "Look in the closet. It should be a white bag and
the um, the jelly beans should be in the white bag." Scott
responded, "Alright." At approximately 12:26 p.m., Duncan received
an incoming call from (443)504-2763, utilized during the call by
Scott. During the conversation Scott advised, "Alright I'm, I'm at
the closet so…" Duncan asked, "You couldn't, ain't, ain't no bag
right there?" Scott answered, "Nah I see like tampon bags and shit
like that." Duncan asked, "You look on the side?" Scott continued,
"A white, a white plastic bag or a Victoria Secret bag?" Duncan
asked, "How the white bag look?" Scott answered, "This white
Victoria Secret bag got a teddy bear and shit in it. A bunch of
liquor. (Unintelligible)." Duncan responded, "It's white, it's not
that bag." Scott continued, "White plastic bag got a box of
147
tampons." Duncan advised, "Look, look, look, look, look on the side
of the closet then." Scott responded, "Alright." Duncan responded,
"Yeah." Scott was then heard moving items around in the background.
Duncan advised, "It should be a H&M bag, the bag that we had."
Scott asked, "A H&M?" Duncan answered, "Yeah." Scott was again
heard moving items around in the background. Duncan asked, "You
don't see no H&M bag in there nowhere in there?" Scott answered,
"No." Duncan continued, "On the side of, on the side of the
closet?" Scott responded, "Nah at the top or bottom. I'm looking
at the top and bottom." Duncan responded, "No, no on the, don't
know how, not when you go in the closet. Like (unintelligible) at
the door is open. It should be a bag on the side of the closet."
Scott responded, "Ok, oh alright you want this whole bag?" Duncan
advised, "Look in there and see if every, if everything that we,
that we need." Scott responded, "Um the strainers the, the, yeah
everything is in here." Duncan responded, "Alright come on. I'm,
I'm around here already." Scott responded, Alright." During the
conversation law enforcement observed Scott arrive at McIntosh's
residence, 1120 Homewood Avenue, Subject Premise #1, and depart
moments after the conclusion of the call. Scott was observed
leaving the McIntosh’s residence with a weighted white plastic bag.
Moments later, law enforcement observed Scott arrive in the 1200
block of Wilcox Street, near 1204 Wilcox Street, Subject Premise #6,
the home of Brice. Based on their training and experience and other
148
agents believe that Duncan had instructed Scott to retrieve the drug
paraphernalia, including strainers needed to mix and package heroin
from the McIntosh’s residence.
g. At approximately 11:54 a.m., Duncan was observed
getting gas at a Shell station on Frankford Road and Cedonia Avenue.
At approximately 12:10 p.m., Duncan was observed briefly entering
127 Collington Avenue. At approximately 12:22 p.m., Duncan was
observed to park his vehicle in front of 1204 Wilcox Street,
“Tiger’s house,” Subject Premise #6. Shortly thereafter, Scott was
observed parking his vehicle on the side of Wilcox Street.
131. Based upon this series of calls and surveillance,
I believe that Duncan obtained a quantity of heroin from 5305B
Valiquet, Subject Premise #8, then contacted Scott to obtain the
cutting agents and various packaging paraphernalia from 1120
Homewood, Subject Premise #1, and then transported those items to
Subject Premise #6, 1204 Wilcox, for preparation for street level
distribution.
132. 5305B Valiquet, Baltimore, Maryland, identified
herein as Subject Premise #8, is a possible stash location for BGF.
Subject Premise #8 is a two story light brown duplex with the
numbers 5305 over the front door. There are wooden stairs leading
to the white side door and the letter B is affixed to the side door.
The utilities for 5305B Valiquet are in the name of James Bullock.
149
Bullock has a significant criminal history, including two prior drug
distribution felonies. Further, Bullock was arrested on August 28,
2007 along with McFadden and others for participating in a craps
game in the 700 block of east Preston Street.
Attachment H, which constitute evidence, fruits and/or
I. Subject Premise #9 - desk of Kimberly McIntosh located at

Total Health Care 1501 Division Street, Baltimore,
Maryland
Kimberly McIntosh, a/k/a “Sister Kim,” is the highest ranking female
150
member of BGF in Baltimore. As more fully described above, calls
intercepted over the wiretaps in this investigation indicate that
McIntosh is responsible for the finance of the BGF on the streets
of Baltimore. Additionally, she utilized Subject Premise #1 for the
cutting, packaging, the sale of heroin, and other controlled
substances, as well as near daily meetings of other high ranking
members of BGF. During these meeting, various racketeering
activities of the BGF are discussed and debated among the ranking
structure of BGF, to include, the sale of drugs, acts of violence,
and the disciplining of non-compliant BGF members.
135. On occasion, McIntosh has met with a confidential
source at her place of employment, Total Health Care, located at
1501 Division Street, Baltimore, Maryland. On at least one
occasion, the source entered 1501 Division Street and spoke with
McIntosh. During this encounter, McIntosh agreed to provide the
source (CS3), with a quantity of heroin after she finished work.
136. Additionally, several intercepted conversations
indicate that McIntosh routinely discusses BGF activity while she
is at work. For example:
a. During a series of calls on March 9, 2010, from
approximately 9:48 a.m. to 10:17 a.m., Duncan contacts McIntosh, who
is again at work. Duncan then requests McIntosh’s key to her home,
Subject Premise #1. After this call, electronic surveillance,
authorized by the Court’s order to intercepts Duncan’s cellular
151
phones, indicated that Duncan traveled to the area of Total Health
Care, and then from there to the area of Subject Premise #1.
b. On March 29, 2010, at approximately 10:42 a.m.,
Duncan speaks to McIntosh, who indicates that she is at work.
Duncan then proceeds to inform McIntosh of the information that he
(Duncan) received from “Bow (a reference to Rainbow Williams).”
This call was summarized above.
137. Subject Premise #9 is a business, Total Health Care,
located at 1501 Division Street, Baltimore, Maryland, and McIntosh’s
place of employment. McIntosh has been surveilled at the location
on several occasion, and as late as April 1, 2010. Further, her own
conversations place her at that location on a near daily basis.
138. The precise location of McIntosh’s work space is
unknown to law enforcement because it is impossible for law
enforcement to conduct surveillance inside the business. Because
McIntosh routinely meets and/or discusses BGF activity while working
at Total Health Care, law enforcement believes that McIntosh may
maintain books, ledgers, contact lists, talley sheet and other items
of evidentiary value at her desk. The search of Subject Premise #9
will, therefore, be confined to the immediate desk and/or work space
of Kimberly McIntosh.
J. SUBJECT PREMISE #10 - 304 East 21st Street, Baltimore,

Maryland
152
learned that Erik Ushry, a/k/a “E,” is a wholesale customer of
heroin of Crooks. Additionally, recorded conversations between
McIntosh and CS3 on December 15, 2009 indicate that McIntosh
processes heroin for Ushry (see above). Duncan has also been
observed on at least one occasion, March 21, 2010, in and around
1120 Homewood Avenue, Subject Premise #1, during the “emergency” BGF
meeting, (see above).
140. On March 30, 2010, law enforcement was conducting
surveillance at 304 East 21st Street. At approximately 5:42 p.m.,
Ushry was observed to exit that location.
141. Further, on March 31, 2010, Duncan asks Ushry to
meet him near his (Ushry’s) mother place prior to going to court.
Duncan and Ushry are then observed together at the District Court
of Maryland for Duncan’s trial for giving a false statement to
officer. While awaiting trial, Duncan was arrested for violation
of his parole (a parole retake warrant) and taken into custody in
the courtroom. Law enforcement officers were present in the
courtroom and observed Duncan hand his personal effects to
individuals in the courtroom. Ultimately, law enforcement observed
Ushry take possession of the cellular telephones that are the
subject of the court orders to intercept Duncan’s communications.
Law enforcement continued to surveil Ushry and observed him leave
the courthouse and begin to travel toward Subject Premise #10
142. 304 E. 21st Street, Baltimore, Maryland, identified
153
herein as Subject Premise #10, is the residence of Ushry. Public
record databases confirm that Ushry uses Subject Premise #10 as his
place of residence. Subject Premise #10 is a three story row home.
The first floor is painted white and the upper two floors are black.
There is a white front entry door with the numbers 304 in black
above the door.
Attachment J, which constitute evidence, fruits and/or
I. SUBJECT PREMISE #11 - 1701 Harford Avenue, Baltimore,

Maryland
learned that Lamont Crooks is a source of supply of heroin for the
BGF. Crooks has been observed on at least one occasion conducting
154
a drug transaction with Earle Moore after using the Crooks Cellphone
to arrange for the transaction. Intercepted calls further indicate
that Crooks utilized Sherice Foster to process and mix the heroin
at her home, Subject Premise #11. During a series of intercepted
phone calls over the Crooks Cellphone, Crooks discusses with Foster
the processing of heroin. For example:
Crooks placed an outgoing call to (410)261-6110, assigned to the
Charles Village Safeway, utilized by Sherice Danielle Foster.
During the conversation Crooks asked, "What time you get off?"
Foster answered, "Um six o'clock." Crooks responded, "You get off
at six." Foster responded, "Right and then I'm going to a tattoo
party." Crooks responded, "Huh?" Foster asked, "Why what's up?"
Crooks responded, "Yeah, yeah um and then what?" Foster responded,
"I'm going to a tattoo party oh but I be home. I'm gonna go home
first." Crooks responded, "Say she going home then she going to a
tattoo party." Foster then spoke of getting a new tattoo. Crooks
advised, "No we had some uh, something for you to uh, here I wanted
to drop something off." Foster asked, "When you, when they, when
you, when you all need them done by?" Crooks answered, "Um like
tomorrow." Foster advised, "Oh I work eight to four thirty. Just,
I'll do them tonight. I'm do em' tonight when I finish doing what
I was doing." Crooks responded, "Alright." Foster advised,
"Alright just drop it off." Crooks responded, "Ok." Based on their
155
investigation, law enforcement agents believe that Crooks was taking
a large quantity of drugs to Foster so she could package the drugs
for street sale. Crooks advised, "No we had some uh, something for
you to uh, here I wanted to drop something off." Foster asked,
"When you, when they, when you, when you all need them done by?"
Crooks answered, "Um like tomorrow." Foster advised, "I'm do em'
tonight when I finish doing what I was doing."
Crooks placed an outgoing call to (410)261-6110, assigned to the
Charles Village Safeway, utilized by Foster. During the
conversation Crooks asked, "What time you get off?" Foster
answered, "Four thirty." Crooks said in the background, "She said
four thirty homie." Crooks then asked Foster, "Um how many of them
demonstrations you get through?" Foster answered, "All of em'."
Crooks then spoke to a unidentified male in the background. Crooks
said, "Alright shoot back." The UM responded, "Alright." Crooks
then advised Foster, "Yeah he said he gonna uh, uh, the homie said
he gonna come get you." Foster asked, "From work?" Crooks
answered, "Yeah not unless you got a ride." Foster advised, "No he
can come get me. Alright you coming with him?" Crooks responded,
"Oh, oh no. They um, is they, it's, it's in the house?" Foster
answered, "Yeah in that same bag." Crooks responded, "Oh alright
but, yeah who in there?" Foster answered, "I don't know. But he
156
gonna come get me right?" Crooks advised, "Alright I'm a, uh, uh
nah I probably shoot and get it. Yep that's what I was thinking
about. I'll probably shoot. Cause you know I'm fucked up. But I'm
a shoot and get it." Based on their training and experience and
other information developed during this investigation, law
enforcement agents believe that Crooks was asking Foster how much
of the drugs he (Crooks) provided to her were packaged. Crooks
asked, "Um how many of them demonstrations you get through (a
reference to units of drugs)” and Foster answered, "All of em'."
Crooks asked, "They um, is they, it's, it's in the house, Subject
Premise #11?" Foster answered, "Yeah in that same bag (a reference
to having the drugs stored in the Foster residence.)”
c. On April 2, 2010, at approximately 12:31 p.m.,
Crooks received an incoming call from (443)278-3855, subscribed to
Danielle Foster, 1701 Hartford Road, Baltimore, Maryland, utilized
by Foster. During the conversation Crooks asked, "You at work?"
Foster answered, "Um." Crooks responded, "Oh shit. What time you
get off?" Foster answered, "Two forty five. I'm a do them when I
come home. I ain't got (unintelligible.)" Crooks advised, "No you
good." Based on their training and experience and other information
that Crooks was inquiring whether Foster had finished packaging the
quantity of drugs he had recently given her to package for sale.
As a result of the conversation surveillance was established at the
157
Charles Village Safeway, 2401 N. Charles Street, Baltimore,
Maryland. At approximately 3:06 p.m., law enforcement observed
Foster exit the Safeway and enter a vehicle. Law enforcement then
followed Foster to 1701 Harford Avenue, Baltimore, Maryland, Subject
Premise #11. At approximately 3:13 p.m., Foster exited the vehicle
and entered the front door to her residence located at 1701 Harford
Avenue, Baltimore, Maryland, Subject Premise #11. A query of public
record databases revealed the current residence for Sherice Danielle
Foster as 1701 Harford Avenue, Baltimore, Maryland.
145. 1701 Harford Road, Baltimore, Maryland, identified
herein as Subject Premise #11, is the residence of Sherice Foster.
Public record databases confirm that Foster uses Subject Premise #11
as her residence, and the utilities are in her name. Additionally,
the cellular phone used by Foster is subscribed to in her name at
Subject Premise #11. Subject Premise #11 is a red brick building
with the address 1701 Harford Avenue on a white sign affixed to the
building to the right of the white entry door.
Attachment I, which constitute evidence, fruits and/or
158
VI. Computers
learned the BGF is highly sophisticated criminal enterprise and use
various forms of media to communicate. For example:
a. On March 27, 2010, Duncan and Harried speak with
each other regarding the collection of BGF dues and the registration
of members. During the conversation, Duncan tells Harried “text
me...how much it suppose to be.”
b. Further on February 11, 2010, at approximately
2:28 p.m., Chambers received an incoming call from Crooks. During
the conversation Crooks advised, “Hey yo I just got your text uh
about Keko. Where, where he was at?” Chambers answered, “Oh I
don’t know where Keko and them but that, oh shit you know I don’t
know how to respond on that shit but Keko up his house.” Crooks
responded, “Oh alright. Well if, if, if, if he calls you back tell
him, tell him um, tell him call me. Give him my number.” Chambers
continued, “Alright he don’t got no phone. I be hitting him on
159
Facebook.” Crooks responded, “Oh alright. Then I got to get him
on my page then.” Chambers advised, “Yeah just go to my page and
you’ll see that he my friend and hit it and, and send him a friend
request. He probably still on there.” Crooks responded, “Alright,
alright that’s what I’ll do then.” Based on their training and
investigation, law enforcement agents believe that Keko is
attempting to purchase a quantity of drugs from Crooks through
Chambers. The content of the drug purchase was sent to Crooks from
Chambers through a text message. When Crooks requested that
Chambers to have Keko call him directly, Chambers advised that he
communicates with Keko only through the use of the website Facebook.
Chambers instructed Crooks to view Chambers Facebook page, locate
Keko under his friends section and ask Keko to become one of his
friends. By “friending” Keko, Crooks can communicate with Keko
regarding drug trafficking directly via the website Facebook. A
review of Chamber Facebook page by law enforcement revealed several
photographs of Chambers friends. One such friend, identified as
Regulator Keko is in several photographs surrounded by other males
displaying hand gestures identified as being used by gangs.
148. Based on the above conversation, it is clear that
at least some members of BGF communicate through computers. As a
result, law enforcement requests permission to seize computers, if
they are located at the Subject Premises, with the exception of
160
SUBJECT PREMISE #9, and if necessary separate search warrants will
be prepared for the computers.
VII. Night-Time Execution
149. These warrants are being executed for offense
related to Title 21 of the United States Code, involving narcotics
trafficking. On an almost daily basis the indicted individuals
engaged in a city-wide conspiracy to distribute heroin. Along with
continuous drug trafficking, law enforcement has intercepted calls
demonstrating the highly organized and violent nature of this
organization. Based on those reasons, and the multitude of
conversations listed above, I request permission, pursuant to 21
U.S.C. § 879, to execute the warrants at anytime to protect the
integrity of the investigation, prevent the destruction of evidence
and to ensure the safety of the agents executing the warrants.
VIII. Authorization for No Knock Entry
Crooks placed an outgoing call to (443) 271-9198, subscribed to
James Bondd, PO Box 54966, Irvine, California, utilized by Fella.
During the conversation Crooks asked, "Yo you ever get mobile yet?"
Fella answered, "No not yet I'm waitin' on my car. I'm in the house
yo." Crooks responded, "Oh alright." Fella asked, "You alright?"
Crooks answered, "Yeah, yeah when you um, when you um, you slide
through, yeah, yeah definitely holler at me though. You still is
straight?" Fella responded, "Nope I, I, I, I'm, I got a dude. He
161
just got straight or whatever. Told me when I get mobile to come
holler at him. He got…" Crooks responded, "Oh ok." Fella
continued, "Hey yo there's another dude right. That I'm gonna
holler at right." Crooks responded, "Yeah." Fella continued,
"Their Q's, with, with, with Q's there shit is outstanding." Crooks
responded, "Oh ok." Fella continued, "Man I'm talking about really
it's outstanding." Crooks responded, "Yeah." Fella continued, "So
that's what you were trying to do?" Crooks answered, "Yeah um plus
I probably, I probably gonna need that um, that forty (a firearm).
You still needed it?" Fella answered, "That what?" Crooks
continued, "That forty dollars you were talking about. You still
needed it?" Fella answered, "Yeah, hell yeah." Fella advised that
he would be able to meet Crooks in about an hour. Based on their
investigation, law enforcement agents believe that Crooks was asking
to purchase a quantity of drugs from an unidentified source of
supply known to Fella. However, Fella advised that his regular
source did not have the drugs Crooks wanted but, Fella had another
drug source who had just received a new shipment. Crooks advised,
"Yeah, yeah when you um, when you um, you slide through, yeah, yeah
definitely holler at me though. You still is straight?" Fella
responded, "Nope I, I, I, I'm, I got a dude. He just got straight
or whatever." As the conversation continued Crooks asked, "I
probably gonna need that um, that forty. You still needed it?" (a
162
reference to a forty caliber handgun.) Fella advised that at this
time he still needed to obtain the weapon from Crooks. Ultimately,
Fella agreed to meet with Crooks later in the evening to discuss the
purchase of drugs by Crooks.
151. I personally have participated in a previous arrest
of Crooks. At the time of this arrest on November 30, 2004, Crooks
was observed to exit 1502 Aisquith Street, Subject Premise #4, en
route to conduct a home invasion robbery. At the time of his
arrest, Crooks and his two conspirators were in possession of three
firearm, including an 9mm semi-automatic Uzi and a magazine with 32
rounds. On Crooks’s person was a loaded Taurus 9mm handgun. Crooks
ultimately pled guilty to being a felon in possession of a firearm.
He was sentenced to 46 months in federal prison and is still on
supervised release.
152. I am aware that firearms are “tools of the trade”
in drug trafficking. Crooks’s personal history and the nature of
the telephone call described above, which, based upon my training
and experience, is discussing a firearm, I believe that any attempt
to “knock and announce” prior to making entry at Subject Premise #4,
creates an unacceptable risk to the officers executing the warrant
at this particular location. Accordingly, I request that the agents
and officers executing the search warrant at 1502 Aisquith Avenue,
Subject Premise #4, be permitted to execute that warrant without
first knocking and their presence.
163

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appearance and habits of drug dealers and users.

training, education and experience, I have become familiar with the

manner in which illegal drugs are transported, stored, and

distributed; the methods of payment for such drugs; the possession

and use of firearms in connection with the trafficking of such

drugs; and the manner in which narcotics traffickers store and

conceal the proceeds of their illegal activities.

2. This affidavit is being submitted in support of an

THE PREMISES KNOWN AND DESCRIBED AS 1120 HOMEWOOD AVENUE,

THE PREMISES KNOWN AND DESCRIBED AS 4007 FORDLEIGH ROAD,

THE PREMISES KNOWN AND DESCRIBED AS 237 EAST LAFAYETTE

THE PREMISES KNOWN AND DESCRIBED AS 1502 AISQUITH STREET,

THE PREMISES KNOWN AND DESCRIBED AS 2004 BALTIMORE

THE PREMISES KNOWN AND DESCRIBED AS 1204 WILCOX STREET,

THE PREMISES KNOWN AND DESCRIBED AS 5305B VALIQUET ROAD,

THE PREMISES KNOWN AND DESCRIBED AS THE DESK OF KIMBERLY

THE PREMISES KNOWN AND DESCRIBED AS 304 EAST 21ST STREET,

THE PREMISES KNOWN AND DESCRIBED AS 1701 HARFORD AVENUE,

3. Based on the facts set forth in this affidavit, I

respectfully submit that there is probable cause to believe that BGF

is engaged in an ongoing and continued pattern of violations of

federal law and that there is presently concealed in the premises

forth in the respective attachments hereto, all of which constitute

evidence, fruits, and instrumentalities of, inter alia, violations

of 18 U.S.C. § 1962, which prohibits participation in a racketeering

conspiracy; 21 U.S.C. §§ 841 and 846, which prohibits the

distribution and possession with intent to distribute controlled

substances, and conspiracy to commit those offenses; 21 U.S.C. §

furtherance of drug-trafficking; and 18 U.S.C. § 1959, which

prohibits violent crimes in aid of racketeering.

4. Because this Affidavit is being submitted for the

limited purpose of establishing probable cause for warrants to

detail of every aspect of the investigation. Rather, I have set

forth only those facts that I believe are necessary to establish

probable cause. I have not, however, excluded any information known

to me that would defeat a determination of probable cause. The

information contained in this Affidavit is based upon my personal

knowledge, my review of documents and other evidence, and my

conversations with other law enforcement officers and other

individuals. All conversations and statements described in this

Affidavit are related in substance and in part unless otherwise

5. Since September 2008, DEA’s Special Investigations

Group (DEA SIG) has been conducting an investigation of the “Black

Guerilla Family” (BGF), a violent gang that operates in prison

facilities and major cities throughout the United States, including

in Baltimore, Maryland. The investigation has involved, among other

a. physical surveillance in multiple locations,

b. debriefings of multiple confidential informants

c. seizures of narcotics and narcotics proceeds and

d. review of monitored telephone calls over prison

e. electronic surveillance of cellphones used by BGF

members and leaders and their associates.

6. As more fully described below, the evidence obtained

gang that is engaged in drug-trafficking, extortion, and acts of

violence in Baltimore City and elsewhere.

7. The initial phase of this investigation was conducted

in February through April of 2009. During this period, DEA SIG

utilized wire intercepts of several cellular phones, including

contraband cellphones utilized by incarcerated members of BGF, which

demonstrated a pattern of racketeering activity and BGF’s control

of various prison facility.

8. On April 8, 2009, a Federal Grand Jury sitting in the

District of Maryland returned separate Indictments charging a total