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Affidavit Of Drug Bust In Southeastern Mass.

Affidavit Of Drug Bust In Southeastern Mass.

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Published by WBUR
More than two dozen people have been arrested on federal and state drug charges in a series of raids conducted by state and federal law enforcement officers in the Brockton area.
More than two dozen people have been arrested on federal and state drug charges in a series of raids conducted by state and federal law enforcement officers in the Brockton area.

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Published by: WBUR on Nov 18, 2010
Copyright:Attribution Non-commercial


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Complaint Affidavit
I, Kevin C. Hersey, a Special Agent with the Drug Enforcement Administration beingduly sworn, state:1.As a result of being a
Special Agent, I am an investigative or law enforcement officer of theUnited States within the meaning of Section 2510(7) of Title 18 of the United States Code,in that I am empowered by law to conduct investigations of, and to make arrests for, offensesenumerated in Title 18, United States Code, Section 2516.2.I am a Special Agent with the United States Department of Justice, Drug EnforcementAdministration (DEA). I have served in this capacity for over 20 years and have beenassigned to the New England Field Division for the past 12 years. Prior to my currentassignment, I was assigned to the New York Field Division. My primary duties as a DEASpecial Agent include the investigation of organized narcotics traffickers. I have receivedtraining in the field of narcotics enforcement and investigations including, but not limitedto, training regarding the identification of common street drugs such as cocaine and heroin.During my tenure as a DEA Special Agent, I have worked on hundreds of druginvestigations. Many of these investigations involved the organized domestic andinternational importation and distribution of kilogram quantities of cocaine and heroin. Ihave participated in approximately 10 investigations that involved the use of court-orderedeavesdropping, including being the Affiant for a large scale investigation that occurred in2008. Through my training, education, and experience, I have also become familiar with themanner in which illegal drugs are transported, stored, and distributed, and with the methodsof payment for such drugs.1
3.I have written and/or participated in the execution of numerous search warrants resulting inthe seizures of large quantities of controlled substances; packing implements and otherparaphernalia involved in the manufacture and distribution of controlled substances; largeamounts of United States currency, ledger books, bank records, telephone books, receipts,drug customer lists and other documents relating to the manufacturing, transportation,ordering, purchasing and distribution of controlled substances. I have participated in thedebriefing of dozens of defendants, informants and witnesses who had personal knowledgeregarding large-scale narcotics trafficking organizations. I have participated in all aspectsof drug investigations including conducting surveillance, executing searches pursuant tocourt-ordered search warrants and executing arrests. As a result of my assignments, I havereceived extensive specialized training in the field of narcotics identification, investigationand enforcement.4.Based upon my training and experience, I am familiar with the methods of operationemployed by narcotics traffickers operating at the local, statewide, national and internationallevels, including those involving the distribution, storage and transportation of narcotics andthe collection of monies that constitute the proceeds of narcotics trafficking activities. I amaware that drug traffickers commonly use cellular telephones in furtherance of their drugtrafficking activities and frequently change cellular telephone numbers and cellulartelephones in an effort to thwart law enforcement’s use of electronic surveillance. I am alsoaware that narcotics traffickers speak in vague, guarded or coded language when discussingtheir illegal activities, and employ a variety of counter-surveillance techniques in order todetect if their vehicles are being followed by members of law enforcement.2
5.My extensive narcotics training has familiarized me with the general characteristics of cocaine and heroin distribution “cells.” A distribution cell consists of 2 or more individualswho work in concert for the sole purpose of the distribution of large amounts of narcotics.Distribution cells are highly organized and disciplined, with a clear chain of command andcontrol. Distribution cells consist of workers, supervisors, and managers. They areextremely surveillance conscious and have a good understanding of methods used by lawenforcement agencies to investigate their activities. It has been my experience thatdistribution cells are often also instructed in how to best thwart law enforcement efforts toobtain Title III interceptions by limiting the use of cell-phones to 2 to 3 months, usingpre-paid non-registered cell phones which they exchange or pool within the group, orcellular phones registered to an alias or business. Distribution cell groups also employaggressive counter surveillance tactics. Distribution cell groups are often supplied on aconsignment basis by larger importation groups, with a strict timetable for payment.Distribution cell groups often network with other distribution cells in order to maintain aconstant supply of the distributed drug. Distribution cell groups often maintain locationsother than their primary residences to be used as secure points of distribution or storage of money and/or drugs.6.I have personally participated in the investigation of the subjects named in this Affidavitsince December, 2009. I am familiar with the facts and circumstances of this investigationfrom oral and written reports made to me by other Agents of the DEA, other federal, stateand local law enforcement agencies and a review of summaries of wiretap interceptions andthe underlying recordings.3

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