Case 1:10-mj-01339-SKG Document 1 Filed 04/12/10 Page 1 of 4

FILED
U.S. DlSTRICr COi{Fn
UNi¥EJj< ~TA:TES"DISfifilcT COURT
ltt~IPUCf3O~ ~~OLAND
UNITED STATES OF AMERICA ~~E~K'SprFJ,~E
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v. 8'1' __ , .. CRIMIWAL COMPLAINT

JAMES BULLOCK CASE NUMBER: /0 --12;01 5K-C--

5305B Valiquet Avenue
Baltrimore,'Marylalnd

I, the undersigned complainant, being duly sworn state the following is true and correct to
the best of my knowledge and belief. On or about April 12, 2010, defendant, (Track Statutory Language Offense)

James Bullock, d~d knowingly, intentionally and unlawfully possess with the intent to distribute a
mixture or substance substance containing a detectible amount of heroin, a Schedule I controlled
substance,

in violation of Title -.2.L United States Code, Section(s) 841

I further state that I am a Task Force Officer of the Drug Enforcement Administration, and that this
complaint is based on the following facts: Official Title

SEE ATTACHED AFFIDAVIT

Continued on the att~ched sheet and made a part hereof: 0 Yes 0 No

William Nic es, Task Force Officer

Drug Enfor ent Administration

Baltimore, Maryland

Susan K. ai.rv~y:j
United States Migistrate Judge
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 Case 1:10-mj-01339-SKG Document 1 Filed 04/12/10 Page 2 of 4

AFFIDAVIT

This affidavit is submitted in support of an application for a criminal complaint charging James

Bullock ("the defendant") with violating 21 U.S.C. S841 to wit: possession with the intent to distribute

heroin, a Schedule I controlled substance.

I, William Nickoles, am a Detective with the Baltimore Police Department and have been

so employed since 1992. I have been deputized as a Task Force Officer with the DEA for

approximately nine (9) years. I am currently assigned to the DEA's Special Investigations Group

(DEA SIG), which investigates large-scale narcotics trafficking organizations in the Baltimore area.

During my time as a law enforcement officer, I have participated in numerous investigations of

unlawful drug distribution and investigations of violent gangs, including the use of confidential
I

informants and cooperating witnesses, undercover transactions, physical and electronic surveillance,

telephone toll analysis, investigative interviews, the execution of search warrants, and the recovery

of substantial quantities of narcotics, narcotics proceeds, and narcotics paraphernalia. I have

reviewed taped conversations, as well as documents and other records relating to narcotics

trafficking and gang activity. I have interviewed drug dealers, users and confidential informants and

have discussed with them the lifestyles, 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.

On April 8, 2010 law enforcement obtained search warrants, as part of an on- going

investigation conducted by DEA SIG into narcotics trafficking associated with the Black Guerilla

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 Case 1:10-mj-01339-SKG Document 1 Filed 04/12/10 Page 3 of 4

Family (BGF). These warrants, signed by the Honorable 1. Frederick Motz, United States District

Court Judge, were for 11 locations in and around Baltimore City, including 5305B Valiquet Avenue

in Baltimore, Maryland ("the Valiquet address"). On April 12, 2010 at approximately 6:00 a.m., law

enforcement executed the search warrant at the Valiquet address. Upon entering the location, law

enforcement encountered the defendant inside the residence. After being secured by law enforcement,

the defendant, who is a prohibited person, told the officer that he had a gun under his mattress. The

defendant was then read his rights and informed the officers of the locations of the drugs in the

residence.. An orderly search was then conducted. During the search, agents/officers recovered

approximately 100 gelatin capsules of suspected heroin in a pot on the kitchen counter; inside a ,child's

cup on a shelf in the kitchen was approximately 24 grams of suspected heroin; inside another child's

cup in the dishwasher was another 4 gr~ms of suspected heroin; in an ashtray in the living room were

4 baggies containing a total of23 gelatin capsules of suspected heroin; in the kitchen in a cooler were

two bottles of quinine; used to process heroin; in the laundry room was four Cap M' Quick units, a

large bag with empty gelatine capsules, and a large bag with suspected cutting agents. In the bedroom

under the mattress, where a child was sleeping, was a 9mm Glock 26, in the locked-back position, next

to the firearm were two loaded magazines. Also in the bedroom was a ballistic vest. A sampling of

the gelatin~ capsules tested positive for the presence of heroin.

I know, based on his training and experience, that the evidence seized from the Valiquet

address is consistent with the preparation, pack~ging and distribution of heroin. On the foregoing, it

is therefore my belief that James Bullock is in violation 21 U.S.C. 9841, to wit: possession with the

intent to distribute heroin.

koles, Task Force Officer

cement Administration

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 Case 1:10-mj-01339-SKG Document 1 Filed 04/12/10 Page 4 of 4

Signed, sworn and subscribed to before me this (Z-day of April, 2010.

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