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UNITED STATES OF AMERICA
Civil Action No.
$4,874 U.S. CURRENCY, and
ONE 2006 MERCURY MONTEGO PREMIER, VIN IMEHM43146G618889,
. . . ...
VERIFIED COMPLAINT FOR FORFEITURE
The United States of America, by and through its undersigned
attorneys, respectfully presents to the Court the following:
1. This Court has jurisdiction over this forfeiture action
pursuant to 28 U.S.C. §§1345 and 1355, and 21 U.S.C. §881(a) (6)
Venue is proper in this court pursuant to 28
§1395 (b) .
3. On or about May 27 r 2008, the defendant property was
seized from Jeffrey Todd Huffman, 7835 Charlesmont Road, Baltimore,
pursuant to the execution of a Search and Seizure Warrant in the State
and District of Maryland.
4. Since seizure, the defendant property has been and
presently is in the custody of the U.S. Marshal Service.
5. The defendant property was used and was intended to be
used to commit and to facilitate the commission of a violation of Title
21 U. S. C. §841, and constitutes proceeds traceable to the sale or
exchange of controlled substances in violation of 21 U.S.C. §841; and, thereforer should be forfeited to the United States of America pursuant
to 21 U.S.C. §881(a} (4) and (a) (6).
6, Such forfeiture is based upon, but not limited tOr the
evidence outlined in the attached Application and Affidavit for Search and Seizure Warrant of TFO Ernest Moore and Detective Christopher Toland, Baltimore County Police Department, TFO Mark Lunsford, Baltimore City Police Department, and Special Agent Paul Ne i.k i.r'k , Drug Enforcement Administrationr which is incorporated herein by reference,
WHEREFORE, the plaintiff prays as follows:
1. That any persons having an interest in the above~
described defendant property be cited to appear herein and answer the Complaint;
2. That a Warrant in rem issue to the united States Marshals
Service commanding the agency to arrest the defendant property;
3. That Judgment of Forfeiture be decreed against the
4, That upon Final Decree of Forfeiture, the united States
Marshals Service should dispose of the defendant property according to law; and
5. That the plaintiff have such other and further relief as
the caSe may require.
Rod J. Rosenstein United States Attorney
Charles J. Peters
Assistant United States Attorney 36 S. Charles Street
Baltimore, Maryland 21201 Telephone 410 209-4800
I, Charles J. Peters, declare under penalty of perjury as
provided by 28 U.S.C. § 1746, that the foregoing Complaint for Forfeiture
is based on reports and information furnished to me by the Baltimore City
Police Department, Baltimore County Police Department and the Drug
Enforcement Administration and that everything contained therein is true
and correct to the best of my knowledge and belief.
Charles J. Peters
Assistant United States Attorney
* IN THE
* CIRCUIT/DISTRICT COURT
• FOR SAL TIMORE
Jeffrey Todd HUFFMAN 7835 Char/esmont Road Baltlrnore, Maryland 21222
it * *. * * *. * * *
Having given due conslderatlcm to the foregoing Motion to Seal Search Warrant Affidavit on the persons of: Jeffrey Todd HUFFMAN, White Male, 0.0.8 0-1/11/1976
And on the premises known as; 7835 Charlesmont Road Baltimore Maryland 21222
And in the vehicle described as: 2006 Silver Mercury, Maryland RegIstration
3CPP71, VlN# 1MEHM43146G618889 IlL
IT IS HEREBY ~RDERED this l!J day of ~, 2008, that the attached Affidavit in Support of Search and Seizure Warranfls hereby sealed for a period of not more that thirty- (30) days. Upon the expiration of this Order, the Affidavit shall, be unsealed and delivered, wlthln fifteen (15) days, to the personts) from whom the property was taken. If that person is not present at the 'time of
'delivery, the person apparently in charge of the premises from which the property was taken shall be served.
This Order is issued upon finding Qood cause, pursuant to Criminal Procedures Ar.ticle,1·203 of the Annotated Code of M~ryland.
IT IS FURTHER ORDERED that a copy of this Order be left at the above _location in lieu of the AffidavIt in support of the Search arrant.
r~ L-i- ' J:"0;P)U'}-- __
'* IN THE
'* CIRCUIT/DISTRICT COURT '* FOR BALTIMORE '*COUN1Y
Jeffrey Todd HUFFMAN 7835 Charles mont Road Baltimore, Maryland 21222
'* '* '* '* '* '* '* '* '* '* '* '* '* '* . '* '* '* '* '* '* '*
MOTION TO SEAL SEARCH WARRANT AFFIDAVIT
. Now comes rFO Ernest Moore and Detective Christopher Toland of the Baltimore County Police Department. S/A Paul Neikirk of the Drug Enforcement Administration and TFO Mark Lunsford of the Baltimore Pol/ce Department and moves this Honorable Court to pass an Order Pursuantto Criminal procedures Article 1-203 of the Annotated Code of Maryland, which provides for the sealing of an affidavit in support of a search and seizure warrant upon finding of good cause, and state:
1. That the criminal investigation to which 'the attached affidavit is related is of an ongoing nature and likely to yield further Information which could be of use in prosecuting criminal activity;
2. That the failure to maintain the confidentiality of the investlgat~on would [eopardlze the use of the Information, as well as jeopardize the source of the information; .
3. That the criminal investigation to which the attached affidavit is related Is an inquiry Into alleged criminal activity in violation of Laws of Maryland, pertaining to Controlled Dangerous Substances, Criminal Law Article CR 5-303 (d) through CR 5-904. Of the Annotated Code of Maryland, beIng conducted by a law
enforcement agency. namely the Baltimore County Police Department.
WHEREFORE, your petitioner prays that the attached affidavit in support of search and seizure warrant be sealed.
TFO Ernest Moore #3318
S/A Paul Neikirk
Detective Christopher Toland #3932
DISTRICT COURT/ CIRCUIT COURT FOR
BALTIMORE COUNTY SEARCH AND SEIZURE WARRANT
. To: Any Pollee Officer of Baltimore County
Affidavit having been made before me by TFO Ernest Moore #3318 and Detective Christopher Toland #3932J members of the Baltimore County Police Department, . TFO Mark Lunsford of the Baltimore City Police Department and S/A Paul Neikirk of the Drug Enforcement Administration say that they have reason to believe:
That on the premises known as:
7835 Charlesmont Road Baltimore, Maryland 21222
All end of group red brick rowhouse with a glass front storm door, green front entry door and the numbers 7835 posted to the right of the front doors on a white placard
And on the person known as:
Jeff~y Todd HUFFMAN, White Male, D.O.B 01/11/1976
And In the vehicle (s) described as:
2006 SHver Mercury, Maryland Registration 3CPP71, VIN#
9. Any firearms located inside the residence.
1 O.lndication of occupancy, residency, andlor ownership of the premises described above, including, but not limited to utlllty and telephone bills, canceled envelopes, and keys; and
11. Electronic equipment including but not limited to computer hardware and peripherals/hard drives!floppy disks, prInters, modems, programs, and program software, cellular telephones, and to review said seized Item
12.Any and all other material evidence which are in violation of, or evidence of the violation of the laws of Maryland pertaining to Controlled Dangerous Substances,
. . .
Criminal Law Article CR .5-303 (d) through CR 5-904, arid that the facts tending to
establish grounds for issuance of the' Search Warrant are set forth in the application/affidavit.
And I am satisfied that there is probable cause to believe that the property so described is in or onthe persons and premises above described and that grounds for issuance of the search warrant exist, being those grounds as stated on the application and affidavit attached hereto and incorporated herein by reference.
You are, therefore, commanded, with the necessary and proper assistance, to enter and to search forthwith the persons, premises, and vehicles herein above ·described for the property herein above specified, executing this warrant and making the search; and if property be found there, to seize It; and if upon execution of this warrant, there are found persons then and there engaged in the commIssion of a crime, arrest those so participating; leaving a copy of this warrant and Application/Affidavit therefore With an inventory of the property seized and returning a copy of said warrant, Application/affidavit, and inventory, if any, to me within ten (10) days after execution of this warrant; or, if not served, to return this warrant and
application/affidavit to me within fifteen (15) days after lts expiration. as required by law.
Dated this 1:2
day of "/?~-r
2008 1: oJ a. »«.
DISTRICT COURT/ CIRCUIT COURT FOR
APPLICATION AND AFFIDAVIT FOR SEARCH AND SEIZURE WARRANT
. To the Honorable Judge t,tAI til 7Tt./r()It%~f the District court/CirCl:lit-Court of Maryland for Baltimore . County, you're Affiants, TFO Ernest Moore #3318 and Detective Christopher Toland #3932. members of the Baltimore County Police Department. TFO Mark Lunsford of the Baltimore City Police Department and S/A Paul Neikirk of the Drug Enforcement Administration depose and say that they have reason to believe:
That on the premises known as:
7835 Charlesmont Road Baltimore, MaryJand 21222
An end of group red brick rowhouse with a glass front storm ,door, green front entry door and the numbers 7835 posted to the right of the front doors on a white placard
And on the person known as:
Jeffrey Todd HUFFMAN, White Male, D.0.8 01'11/1976
And In the vehicle (5) described as:
2006 Sliver Mercury, Maryland Regfstratfo~ 3CPP71, VIN#
There are items subject to seizure and review, such as, but not limited to;
1. Cocaine, a Schedule II, controlled dangerous substance, and other controlled dangerous substances;
2. Books, records, receipts, notes, ledgers, and other papers relating to the transportation, ordering, purchasing and distribution of controlled substances; in particular, Cocaine, a Schedule II, controlled danqerous substance.
3. Papers, tickets, notes, schedules, receipts and other items relating to domestic and foreign travel;
4. Address and/or telephone books and papers reflecting names, addresses, a~d/or telephone numbers;
5. Books, records, receipts, bank statements and records, money drafts, letters of credit, money order and cashiers check. receipts, passbooks, bank checks, and other items evidencing ~he obtaining, secreting, transferrIng, concealment and/of expenditure of money, 'such as safe deposit box records, keys, etc.;
'6. United States currency, precious metals, jewelry and financial Instruments, including, but not limited to, stocks and bonds;
'7. Photographs, in particular. photographs of co-conspirators, of assets, and/or of controlled substances;
8. Paraphernalia relating to the packaging. distribution. and/or abuse of
. controlled substances, including but not llmlted to, weights, scales and baggles;
9. Any firearms located Inside the residence.
1 D.lndication of occupancy, residency, and/or ownership of the premises described above, including, but not limited to utility and telephone bills, canceled envelopes, and keys; and
11. Electronic" equipment including but not limited to computer hardware and peripherals/hard driveslfloppy disks, printers, modems, programs, and program software, cellular telephones, and to review said seized items.
12.Any and all other material evidence which are in violation of, or evidence of the violation of the laws of Maryland pertaining to Controlled Dangerous Substances, Criminal Law Article CR 5-303 (d) through CR 5-904, and that the facts tending to establish gro!Jnds for issuance of the Search Warr.ant are set forth and the basis for the probable cause Is as follows:
STATEMENT OF PROBABLE CAUSE
DUring the "last several months, your afflants, TFO Ernest Moore and Dstectlve Christopher Toland of the Baltimore County Police Department, TFO Mark Lunsford of the Drug" Enforcement Administrations HIDTA Task Force and S/A Paul N~ikirk of the Drug Enforcement Administration have been conducting an investigation into the cocaine" distribution scheme of Gilbert WATKINS and the co-conspirators within this drug" organization. During their investigation, your Affiants have received infonnation "from confidential informants, as well as" other "Investigative methods, that Gilbert WATKINS is responsible for dIstributing large amounts of cocaine in the communities of Baltimore County and Baltimore City Maryland.
On April 1, 2008, TFO Moore, Detective Toland, TFO Lunsford, TFOBearde and S/A Neikirk presented an Affidavit In support of Application for the Interception of Telephonic Wire Communications for Gilbert WATKINS cellular telephones! (410)
908~1871 and (443) 622-7242. Upon review of the Application, the Honorable Patrick Stringer, Judge of the Circuit Court for Baltimore County, authorized members of the Baltimore County Police Department to initiate interceptions for Gilbert WATKINS.
On April 18, 2008, the Honorable Judge Patrick Stringer authorized a 30-day extension for the Interception of Telephonic Wire Communications for Gilbert WATKIN'S cellular telephones, (410) 908~1871 and (443) 622-7242. Upon review of the Application, the Honorable Patrick Stringer, Judge of the Circuit Court for Baltimore County, authorized members of the Baltimore County Police Department to initiate interceptions for Gilbert WATKINS.
As a result of this Investigation, your affiants were able to show through intercepted .calls and surveillancethat GJlbert WATKINS is a narcotics source of supply for Jeffrey Todd HUFFMAN.
On April 4, 2008 at 1356 hours, call number '0-364 captured as an ~utgoing call from 410-908-1871" utilized by G'Ubert WATKINS, to.443-415-4775r subscribed to and utilized by Jeffrey HUFFMAN. During the conversation, Jeffrey HUFFMAN says hello, and Gilbert WATKINS tells Jeffrey HUFFMAN hold tight, thIngs are looking up I will ,give you a call In about an hour. Jeffrey HUFFMAN says all right.
Prior to making the above-described call to Jeffrey HUFFMAN, Gilbert 'WATKIN$ , received a call from his source of supply who advised that he would be bringing
WATKINS a supply of narcotlcs, Immediately after, G,i1bert WATKINS made the
call to Jeffrey HUFFMAN. (Call # D~364)
Your Afflants know throuph their training know/edge and experience that Gilbert WATKINS was advising Jeffrey HUFFMAN that he was getting ready to get a large amount of narcotics and Gilbert WATKINS is telling Jeffrey HUFFMAN to be patient. Gilbert WATKINS was advising Jeffrey HUFFMAN that he will call him
in an hour when WATKINS has the narcotics that Jeffrey HUFFMAN is looking to purchase.
Your affiants conducted a check with various databases as to Jeffrey Todd HUFFMAN. which revealed the following:
Jeffrey Todd HUFFMAN
. Mf\N. 01/11/1976, 5'5 130 LBS. 7835 Chai1esmont Road Baltimore Maryland, 21222
.2006 Mercury4Door Maryland Registration 3CPP71, VIN# 1MEHM~3146G618889
No Criminal Record
A check through BGE revealed the subscriber for 7835 Char/esmont Road Baltimore,Maryland 21222"ls Jeffrey Todd HUFFMAN, since 08/12/2002.
On April 6,2008 at 1414 hours,call# D-617 was captured as an incoming call from 443-415-4775 subsoribed to and utilized by Jeffrey Todd HUFFMAN to 410- 908-1871 utlllzed by Gilbert WATKINS. During this call HUFFMAN asks WATKINS what's going on? WATKINS replies I am still on the backburner like you. HUFFMAN says all right I was just checking in and WATKINS replies hold your horses I said it has been looking ,good, but you know somebody don't ever" give you a good thing on anything. I will call you soon. HUFFMAN says aI/ right.
Your Affiant's know through their training knowledge and experience in the area of narcotics that Jeffrey HUFFMAN was calling Gilbert WATKINS to see jf
WATKINS had any narcotics. When WATKINS responded that somebody didn't give him a good thing, Your Affiants believe that WATKINS was still waiting on his source of supply to provide him with narcotics.
On April 14, 2008 at 1958 hours call# D~1523 was captured as an outgoing call from 410~908w1871 utilized by Gilbert WATKINS to 443-415-4775 utilized by Jeffrey HUFFMAN. During this call WATKINS asks HUFFMAN what's up with you. HUFFMAN replies nothing. I am over at Brandy's waiting for you to call me. WATKINS then gives HUFFMAN directions to Kenyon Avenue located in Baltimore City Maryland, and WATKINS tells HUFFMAN that when you get to Kenyon Avenue you will see my white truck parked there. HUFFMAN then tells WATKINS eight thirty, and WATKINS says yeah I should be there at eight thirty.
Based on your Afflants training knowledge and experience in the area of narcotics your Affiants believe that WATKINS called HUFFMAN and gave him directions to his residence at 3207 Kenyon Avenue to arrange a narcotics transaction.
On April 14, 2008 at approximately 2022 hours, surveillance was established near the location known as 3207 "Kenyon Avenue, 21213 in reference to intercepted conversations between GHbert WATKINS and Jeffery Huffman.
At approximately 2040 hours, Detective Kriete observed a 2006 Mercury bearing Maryland registration 3CPP71 arrive in the 3200 block of Kenyon Avenue, " 21213. The vehicle parked across the street from Gilbert WATKINS residence of 3207 Kenyon Avenue, The vehicle remained running with the lights on:
At approximately 2046 hours, a 1995 Infinity bearing Maryland registration 4DY-
N19 also arrived and parks in front of 3207 Kenyon Avenue, The lights were turned off, but the vehIcle remained running,
At approximately 2048 hours, WATKINS exited hIs residence 3207 Kenyon Avenue Baltimore Maryland, carrying a doubled white plastic (Wal-Mart) size bag, .which appeared to be filled. and the handles of the bag were tied at the top. WATKINS then knocked on the driver's window of the Infinity automobile. The operator of the Infiniti automobile rolled down the window, at which time WATKINS stuffed the plastic bag in the window arid walked away. The operator then got out of the Infinity and engaged in conversation with WATKINS.
-At approximately 2049 hours, Watkins walked over and got into the 2006 Mercury automobile Maryland RegIstration 3CPP71 and entered the front passenger's side of the vehicle, and the vehicle drove away. '
At approximately 2115 hours, Cpl. Markwordt was conducting surveillance at the location known as 8007 Del Haven Road Dundalk M,aryland 21222, (which Is the residence of WATKINS' X-girlfriend), Cpl. Markwordt observed the 2006 Mercury automobile Maryland Registration 3CPP71 arrive at the location. WATKINS exited the passenger side of the vehicle and was observed enterinq a-007 Del Haven Road. Cpl. Markwordt then established mobile surveillance on the Mercury automobile, the Vehicle drove in a dIrect route to 7835 Charlesmont
Road Baltimore. Maryland 21222. The operator is described as a White Male, 5"~
, 5 in height and weighing approximately 120 pounds. The operator exited the vehicle and entered the residence of 7835 Charlesmont Road, with the use of a key. Surveillance was terminated.
Your affiants know through their training, knowledge and experience that the above described actions coupled with the above described calls are consistent with a narcotics transaction.
On April 16,2008 at 1322 hours cEiIl#D-1649 was intercepted as an outgoing call from 410-908-1871 utilized by Gilbert WATKINS to 443415-4775 subscribed to and utilized by Jeffrey HUFFMAN. During this call WATKINS tells HUFFMAN that
he is at Vicky's house putting a lawn mower together. HUFFMAN then tells WATKINS I will meet you over there.
Based on your Affiants training knowledge .expertence in the area of narcotics your Affiant's believe that based upon the cal/, WATKINS and HUFFMAN would be meeting at WATKINS X-girlfriend's house at 8007 Delhaven Road in Dundalk Maryland 21222 forthe purpose of conducting a narcotics transaction.
.On April 16, 2008 at 1342 hours, Detective Longo responded to 8007 Delhaven Road 21222 in reference to a meeting between G'i1bert WATKINS· and Jeffrey _ Todd HUFFMAN. Upon Detective Longo's arrival In the block, HUFFMAN'S 2006 Mercury automobile Maryland registration 3CPP71 was parked in front of the location. As Detective Longo drove past the address, Gilbert WATKINS along with a White male and a small child were on the porch of this location; WATKINS appeared to be working on a lawnmower. Surveillance was terminated at that time. Detective Longo subsequently Viewed a Maryland Motor Vehicle Administration Driver's image photo of Jeffrey Todd HUFFMAN and positively identifIed him as the same White male that Detective Longo observed on the porch with. Gilbert WATKINS.
Your affiants know through their tr,aining, knowledge and experIence that the above described actions coupled with the above described calls are consistent .wIth a narcotics transaction.
On 512108 at 1926 hours, Call # 0·3455 was captured between Jeffrey HUFFMAN and 410-908-1871, utilized by Gilbert WATKINS. During the call, HUFFMAN and WATKINS agreed to meet at Baltimore's Best Deli on German Hill Road in Dundalk.
On 5/2/08 at 1943 hours, Call # 0-3459 was captured as an incoming call from 443-415-4775, utilIzed by Jeffrey HUFFMAN to 410~908-1871, utilized by Gilbert
WATKINS. During the call, Jeffrey HUFFMAN confirms the meeting location of Baltimore's Best Deli with WATKINS and WATKINS says he's crossing German Hili Road now.
Your affiants would proffer that these two calls are drug pertinent in nature, in the fact that through this Investigation, Gilbert WATKINS has been identified as Jeffrey HUFFMAN'S ,sou~ce of supply for cocaine and your affiants believe that they are agreeing to meet for the purpose of conducting a narcotics transaction.
TFO Ernest Moore
Your afflant Detective Ernest Moore #3318 has been a member of the Baltimore "County Ponce Department since February 1988, at which time your affiant was asslqned to the Patrol Division at Essex Precinct.
In October 1994, your affiant was assigned as an undercover Detective with the Essex Community Drug and Violence Interdiction Team (CDVIT).
InJuly 19~7, your affiant returned to the Patrol Division at the Essex PrecInct until being re-assigned to the Essex Community Dr:ug and Violence Interdiction Team (CDVIT) in August 2002.
In June 2004, your affiant was' assigned as a Detective to.the Baltimore County
Police Narcotics Division, investigating mid to upper level narcotics organizations operatlnptn Baltimore County.
In January 2007, your affiant was assigned to the United States Drug 'Enforcement Agency as a Task Force Officer, iDvestigating major drug traffickers within the State of Maryland.
During his tenure with the Baltimore County Police Department, your affiant has participated in numerous investigations that have utilized court ordered interceptions of wire communications on State and Federal levels. Your affiant is familiar with the lawful use of electronic surveillance equipment in investigations, which Involve the distribution of controlled dangerous substances. During the court ordered interceptions, your affiant has had the opportunity to intercept and decipher numerous telephone calle, which related to the sale and distribution of controlled dangerous substances, From those interceptions your affiant has become familiar with the jargons and phraseologies used, relating to the sale and distribution of controlled dangerous substances, as well as the coded and guarded conversations used by drug traffickers in attempt to elude police during those Interceptions.
Your Affiant has participated as a co-affiant in at least five (4) previous Investigations that have employed court-ordered wiretaps as an investigative ,tool, and thereby has listened to, transcribed and read transcripts of telephone conversations of individuals Involved In narcotics trafficking. As a resultof the previous court' ordered wiretap investigations, multiple kilograms of cocaine were
. seized, over fifty arrests were made and In excess of $1,OOO,0~O.OO was recovered: Your affiant has listened to in excess of 1000 calls where,CDS trafficking was discussed.
Yourafflant has conducted many probable cause searches for narcotics, which 'have resulted In arrests and convictions ·of controlled dangerous substance violators. Your affiant has on numerous occasions seized quantities of controlled
. danqerous SUbstances. which were chemically analyzed and used as evidence in prosecutions. Your affiant has on numerous occasions made undercover purchases or been involved with undercover purchases of controlled dangerous substances which have resulted In the arrest and conviction of drug distributors.
Your affiant has been trained by the Baltimore County Police Department, as well as other State, Local and Federal agencies, In controlled dangerous substance recognition and Investigations. Your affiant has received training In the area of narcotics Investigations at the Baltimore County Police Academy and while attending yearly In-Service Training. Your affiant has attended the following training:
1. 1988-Entrance Level Narcotics Training.
2. 1991--Search and Seizure Seminar.
3. 1992-Basic Criminal Investigators Schoof.
4. 1994-Drug Enforcement Training.
5. 1994-C.O.D.E. School.
6. 1994-C.D.V.I.T. Training.
7. 1995 Narcotics Search Warrant Tactical Entries
8. 1996-4th Amendment Seminar.
9. 2004-Club Drug Seminar
10. 2005-Multi-Agency Undercover Seminar
11. 2006-Methamphetamine Drug and Lab Recognition ·School
Through the above-described training and experience, your affiant is familiar with the manner In which illegal narcotics are transported, stored, and dlstnbutsc, as well as the methods of payment for such drugs.
Through the above-described training and experience, your affiant has become familiar with the street terminology used in connection with narcoflcs transactions, the prices for and quantities of drugs that are distributed. the manner in which narcotics are packaged for distribution, the means by which narcotlcs are imported both locally and nationally, the quality of drugs, and the use of stash locations and vehicle traps, the use of counter-surveillance techniques, and the organizational structure of drug enterprises.
Detective C.M. Toland #3932
Your Affiant, Detective C.M. Toland #3932, has been a member of the Baltimore County Police Department since May of 1995. Your Affiant is currently assigned as a Detective to the Baltimore County Police Vice Narcotics Unit and has been since August of 2006.
Before assignment"to the Vice Narcotics Unit, your Affiant was assigned as a Detective in the Towson Precinct Community Drug and violence Interdiction Team and has been sJnce February of 1999. While assigned to the Towson Precinct Community Drug and Violence interdiction Team, your Affiant has completed hundreds of narcotics investigations regarding the distribution and possession of controlled dangerous substances.
Your Affiant has conducted numerous hours of undercover surveillance and because of that, has observed numerous controlled buys and hand to hand buys of controlled dangerous substances which have led to numerous arrests. Your
Affiant has written and. executed hundreds of narcotics related search and seizure warrants pertaining to the distribution and possession of controlled dangerous substances which have led to the recovery of controlled dangerous substances, controlled dangerous substance paraphernalia, monies which are the proceeds of narcotics distribution and vehicles which were·utillzed to facilitate and transport controlled dangerous substances. In addition. your Affiant has made hundreds of arrests and has obtained numerous arrest warrant/summonses concerning these crimes.
Before assignment to the Towson Precinct Community Drug and Violence Interdiction Team, your Affiant was assigned as a Detective to the Towson Precinct Investigative Services Team for a period of one year and three months. During that time, your Affiant investigated numerous types of crImes including, but not limited to Auto Theft, Robbery, Theft, Fraud, Burglary, Controlled Dangerous Substance Possession, Distribution of Controlled Dangerous
Substances and Forged Prescriptions. While assigned to the Investigative Services Unit, your Affiant wrote and executed numerous search and seizure warrants pertaining to the above mentioned crimes. These warrants have resulted in the successful recovery of stolen property as well as the seizure of contraband and controlled dangerous substances. Also, while assigned to the Towson PrecInct Investigative Services Unit, your Affiant assisted the Community Drug and Violence InterdictIon Team during investigations and search and seizure warrants regarding controlled dangerous substances.'
Before assignment to the Investigative Services Unit, your Affiant was assigned to Patrol in the Towson Precinct for nearly three years. During this time as a street Patrol Officer, your Affiant was also involved in numerous investigations Pertaining to Armed robberies, Auto Theft, Fraud, Burglary and crimes involving
the sale and lor distribution of controlled dangerous substances.
Your Affiant has successfully completed a twenty-six week entrance ieVel trainIng course in which laws of search and seizure were taught as well as basic investigation techniques, 'criminal law, traffic law and interview and interrogation.
Your Affiant has attended numerous schools and seminars dealing with the following subjects: Search and Belzure.Auto Theft, Criminallnvestlgations, Interview and Interrogation, Drug Interdiction, Investigation of the Letter Drugs,
. such as GHB (Gamma Hydroxybutyric Acid), PCP (Phencyclidine), LSD
(Lysergic Acid Diethylamide), E (Ecstasy) and K (Ketamlne), Undercover
. . .
Surveillance and Electronic Surveillance.
Your Affiant has received additional training in these fields by Baltimore County Police. Maryland State Pollee, John E Reid, PA bureau of Narcotics, DEA (Drug Enforcement Agency) and MAGLOCLEN (Middle Atlantic Great Lakes Organized CrIme Law Enforcement).
Special Agent Paul NefkJrk
Your Affiant is a Special Agent employed by the Drug Enforcement Administration, having been a sworn member since September 2002. Your affiant Neikirk has received 17 weeks of formalized training at the DEA Academy, which included instruction in packaging, pricing, importation, methods of concealment, and trafficking methods of CDS violators. He has also received training In informant handling and the debriefing of CDS violators, He
additionally, has received training in the area of surveillance and counter
Your Affiant has attended a Complex Conspiracy & Investigations School and an Asset Forfeiture Training Seminar, both sponsored by the Drug Enforcement Administration. Your Affiant has also attended a Narcotics Investigation Training Seminar sponsored by the Maryland State Police. Prior to his current assignment, your affiant served as a police 9ffice~ for the Harford County , Sheriffs Office, Harford County, Maryland, for four years and before that he served as a corrections officer for the State of Maryland.
Since becoming an Agent with the Drug Enforcement Administration, your Affiant has partlclpatsdln at least fifty (50) investigations of unlawful drug trafficking. ' Your Affiant has made and/or participated in the arrest of over 500 individuals for violations of the CDS laws of the United States of America and the State of Maryland. Your A~ant has also participated in at least fifty (50) debrleflngs of individuals involved in the abuse and/ortrafflcklnq of COS, where details of the respective individual's abuse and/or t,rafficklng of CDS were Imparted. Your Affiant has drafted at least twenty-frye (25) affidavits in support of search and seizure warrants related to violators and violations of CDS laws and has participated in the execution of over one-bundred (100) search and seizure warrants that have targeted violations and violators of CDS laws, which resulted in the seizure of large amounts of CDS and drug-related paraphernalia.
Your Affiant has participated in at least five (5) investigations that have employed court-ordered wiretaps as an investigatIve tool, and thereby has listened to, transcribed and read transcripts of telephone conversations of individuals involved in narcotics trafficking. Your affiant Special Agent Neikirk has been an affiant on several court ordered wretap investigations where multiple kilograms of cocaine and heroin were seized, over fifty arrests were made and in excess of $1,000,000.00 was recovered. Your affiant has listened to in excess of 1000 calls where CDS trafficking was discussed.
TFO Mark Lunsford
Your Affiant, Police Officer Mark Lunsford has been a duly sworn member of the' Baltimore Police Department-since 1993. Your Affiant is currently assigned to the Organized Crime Division, specifically DEA HIDTA Group 54. During your Affiant's thirteen years .as a law enforcement officer, your Affiant has effected or partlclpated in the arrest of over one thousand persons for narcotic violations. Your Affr,ant has partlclpated in over 500 search and selzurewarrants for
, controlied dangerous substance violations which resulted In the seizure of controlled dangerous substances including crack cocaine, powder cocaine, liquid cocaine, heroin, marijuana, PCP, MDMA, other controlled dangerous substances, CDS paraphernalia, documents, U.S. Currency, firearms, other weapons related to drug,trafficking. YourAfflant is also familiar with both packaging and distribution methods utilized by drug traffickers.
Your Affiant has attended and successfully completed over 150 hours of specialized training In the field of narcotic enforcement. The Baltimore Police Department, Maryland State Police, Drug Enforcement Administration and HIDTA conducted this training.
This training also included an in-depth and comprehensive study into the various
types of illicit drugs, as well as the packaging, and the distribution technlques utilized' by narcotic traffickers. The training included the methodology and prices used to distribute narcotics at street level and wholesale quantities, and methods used to Import CDS. Through this training-and experlence.your Affiant has become familiar with the techniques used In trafficking narcotics; specifically, the methods utii/zed by narcotic traffickers to avoid detection by law enforcement. These methods include among others, the use of counter surveillance techniques, pagers, cellular phones, caller Identification, codes, scanners, aliases, straw purchases, money laundering and the use of businesses as a front to thelr illegal activities. Further, 'your Affiant Is familiar with the use of weapons as a tool of the narcotics trade both on Individuals or use within and organization.
Therefore, based upon your affiants' training, knowledge, experience and participation in Control/ed Dangerous Substance investigations as well as in financial lnvestlqatlons involving quantities of Controlled Dangerous Substances, they know:
A) That drug traffickers very often place assets in names other than their own to avoid detection of those assets by law enforcement ag~ncies;
8) That drug traffickers very often place assets in corporate entities in order to avoid detection by law enforcement agencies;
C) That even though these assets are in other persons names, the drug dealers
continue to maintain these' assets and exercise dominion and control over them;
D) That drug dealers very often maintain large amountsof currency on hand in order to maintain and finance their ongoing drug dealings;
E) That drug dealers maintain books, records, receipts, notes, ledgers, airline tickets, money orders, and other papers relating to the transportation, ordering, sale
and distribution of" controlled dangerous substances. That drug dealers commonly 'front" (provide ~rugs on consignment) drugs to their customers. That the. aforementioned books, records, receipts, notes, ledgers, etc. are maintained where the drug dealer has ready access to them;
F) That it is common for drug dealers to secrete contraband, proceeds of drug sales, and records of drug transactions in secure locations within their residences for ready access and to conceal them from law enforcement authorities;
G) That persons involved in drug trafficking conceal in their residences cachets of drugs, large amounts of currency, financial instruments, precious metals, jewelry, automobile titles, and other items of value, or proceeds of drug transactions and evidence of financial transactions relating to obtalnlnq, transferring, secreting, or spending of large sums of money acquired from Illegal drug sales;
H) That when drug dealers amass large proceeds from the sale of drugs that the dealers will attempt to legitimize these profrts. That to accomplish these goals, drug dealers utilize, but are not limited to, domestic or foreign banks, and/or financial institutions, securities, cashiers checks, money orders, letters of credit, brokerage houses, real estate, shell corporations, or business fronts. If drug dealers chose
not to attempt to legitimize these profrts, they will often conceal them in safe deposit boxes in financial institutions;
I) That after purchasing drugs, the dealers will transport or. cause to be transported -to the areas where they wlll distribute their drugs. That these methods of transportation include, but are not limited to, commercial airlines, private aircraft, ocean going vessels or carriers, rental or private autos, and government or private carriers;
J) That drug dealers commonly maintain addresses and/or telephone numbers in books or on papers which reflect the names, addresses, and/or telephone numbers of associates in their drug dealing scheme;
K) That drug dealers often take or cause to be taken photographs of themselves, their associates, their property, and their products. ,That dealers usually maintain these photographs at their residences or place of business;
L) That drug dealers usually keep paraphernalia for packaging, cutting, weighing and distributing controlled dangerous SUbstances. That these paraphernalia include, but are not limited to, plastic baggles and scales etc.;
M) That the courts have recoqnlzed that unexplained wealth is probative evidence of crimes motivated by greed, In particular dealing in controlled dangerous substances;
N) That based upon your affiant's training, knowJedge and experience that they
know drug dealers' commonly have In their possession, on their persons, in their
cars, or in their residence, firearms, Including but not limited to, handguns, pistols, revolvers, rifles, shotguns, machine guns: and other weapons. Said
weapons are used to protect and secure the drug dealers property. Such
property may include, but not limited to, drugs, jewelry, currency, precious jewels, and other Items that the drug dealers deem valuable;
0) That qrug dealers often maintain "stash houses," Including, but not limited to, second residences, vacant or occupIed apartments, or commercial storage facllr~ ties.
Your affiants, therefore, pray tliat a search and seizure warrant be issued, authorizing them with necessary and proper assistance to enter and search the aforementioned and described location, vehicle and person, and seize aI/ contraband, evidence, fruits and instrumentation's of the crime which are subject
to seizure and are in violation of. or evidence of the violation of, the laws of Maryland, pertaining to Controlled Dangerous Substances. Criminal Law Article
CR 5-3 3 (d) through C -904.
TFO Ernest Moore #3318
Detective Christopher Toland #3932
S/A Paul Neikirk
TFO Mark Lunsford
SWORN to before me and subscribed to in my presence this /3 day of
~J< · 2008. 1; t;:;>. a. fr'.
October 7, 2008
U.S. Marshals Service
Naquita Ervin Paralegal Specialist
RE: U.S. v. $4,874 U.S. CURRENCY and ONE 2006 MERCURY MONTEGO PREMIER, VIN lMEHM43146G618889
Civil Action No.
CATS ID: 08-DEA-500804j08-DEA-501596 - GC-07-0183
The United States has filed a forfeiture action against $4,874 U.S. CURRENCY and ONE 2006 MERCURY MONTEGO PREMIER, VIN IMEHM43146G618889. A copy of the Complaint for Forfeiture is attached.
Notice of this seizure will be published at www.forfeiture.gov pursuant to Rule G of the Supplemental Rules for Admiralty or Maritime and Asset Forfeiture Claims.
U.S. Department of Justice United States Marshals Service
PROCESS RECEIPT AND RETURN
PLAINTIFF COURT CASE NUMBER
UNITED STATES OF AMERICA
DEFENDANT TYPE OF PROCESS
$4,874 U.S. Currency and One 2006 MERCURY MONTEGO Verified Complaint in Rem
PREMIER, VIN lMEHM43146G618889
SERVE NAME OF lNDlVlDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO SEIZE OR CONDEMN
• 08-DEA~500804, 501596 - GC-07~0183
ADDRESS (Street or RFD, Apartmvnt No., City; State, and ZIP Code)
SEND NOTICE OF SERVICE TO REQUESTER AT NAME AND ADDRESS BELOW: I Number of process to be served
----------""'-"'-'" ............. --.._------- ---------- I with this Fonn - 285
Naquita C. Ervin, Paralegal Specialist : Number of parties to be served
U.S. Attorney's Olllce in this case
36 S. Charles Street, 4th floor
Baltimore, Maryland 2120 I I Check for service on U.SA
---_ ......... _----------------------- SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE (Include Business and Alternate Address, All Telephone Numbers, and Estimated Times Available For Service)
Arrest property and insert date into Notice of Forfeiture Action that will be published. Fill ill the date of arrest in this process receipt and return our copy.
Signature of Attorney or other Originat r
o DEFENDANT 4 I 0-209-4800
SE OF U.S. MARSHAL ONLY ~ DO NOT WRITE BELOW THIS LINE
! acknowledge receipt.for the total Total Process District of Origin District to Serve Signature of Authorized USMS Deputy or Clerk Date
number of process indicated.
(.'>ign Dill)' first U[)M 285 if more than
one [fSM 285 is sttbmitted) No. - - No. No. I hereby certify and return that I D have personally served, D have legal evidence of service, 0 have executed as shown in "Remarks", the process described on the individual, company, corporation, etc, at the address shown above or on the individual, company, corporation, etc., shown at the address inserted below.
o [hereby certify and return that [ am unable to locate the individual, company, corporation, etc., named above (See remarks below},
Name and title of individual served (If no: shown above). D A person of suitable age and discretion then residing
in the defendant's usual place of abode,
Address (complete ollly ijdijJamtthall shown above) Date of Service Time am
Signature of'Ll.S. Marshal or Deputy
Service Fee Total Mileage Charges Forwarding Fee Total Charges Advance Deposits Amount Owed to US Marshal or Amount or Refund
(including endeavors) REMARKS:
PRIOR EDITIONS MAY BE USED
SEND ORIGINAL + 2 COPIES to USMS.
FOIli\llJSi\I 285 (ReY, 12/IS/80}
1. CLERK OF COlJRT 2. lJSi'IIS Record 3, Notice of Service 4, Billing Statement 5, Acknowledgment of Receipt
1S 44 (Ecw. 7/95)
CIVIL COVER SHEET
The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court, This [ann, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM).
L (a) PLAINTIFFS DEFENDANTS
UNITED STATES OF A~lEmCA
(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF (EXCEPT IN U.S. PLAINTIFF CASES)
(c) ATTORNEYS (Fl RM NAME, ADDRESS, AND TELEPHONE NUMBER) Rod J. Rosenstein, United States Attorney
Charles J. Peters, Assistant United Stales Attorney United States Attorney's Office
36 S. Charles Street, 4th floor
Baltimore, Maryland 21201
ATTORNEYS (If KNOWN)
$4,874 u.s. Currency and One 2006 MERCURY MONTEGO PREMIER, VIN IMEHM43146G618889
COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT
(IN U.S. PLAINTIFF CASES ONLy)
NOTE: INLA.''D cmmEMNATION CASES, USE THE 1J)CATION OF THE TRACT Of LAN 0 INVOLVED
II. BASIS OF JURISDICTION (PLACE "X' IN ONE BOX O:-lLY)
fOR PLAINTIFF AI\'O ONE BOX FOR DEFENDA.'IT)
I X I I u.s. Govermneut Plaintiff
II 2 u.s. Govenunent Defendant
II 3 Federal Question
(U.S. Government Not a Party)
II 4 Diversity;
(Indicate Citizenship of Parties in item lll)
III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACEAN"X'lNONEBOX
(FOR DIVERSITY CAS ES ONLY)
PTF DEF 1]1 Incorporated or Principal PI Ace 114 114 112 Incorporated and Principal Place of liS [IS
Business in Another State
113 Foreign Nation
Citizen of this Stale Citizen of Another State
PTF DEF I 112
Citizen or Subject of a Foreign Cntry 113
IV. CAUSE OF ACTION (CITE TIlE us. CI\1L STATUTE \Jl'>'UER WHICH YOU AItEf1U~GA.~D WRITE BRJEF STATEMENT OF CAUSE DONOTCITEIURISDICTIONAL STATlJ"TES UNLESS DIVERsm'.)
VERIFIED COMPLAINT FOR FORFEITURE
V. NATURE OF SUIT
(PLACE AN "X" IN ONE BOX ONLY)
. CONTRACT TORTS FORFEITUHEf BANKRUPTCY OTHER STATUES
If 11 0 lnsurancc PERSONAL INJURY PERSONAL INJURY 11 610 Agriculture 11422 Appeal 28 U S,C 11 400 Slale Reapportionment
I! 120 Manne JJ 310 Airplane II J 62 Personal Injury Mod I! 620 Other Food & Drug 158 I! 410 Antitrust
I! 130 Miller Act n 315 Airplane Product Malpractice lXI 625 Drug Related Seizure II 430 !lanks and Banking
I! 140 Negotiable Instrument Liability II 365 Personal Injury Product at Property 21 U.S.C. SSI I! 423 Withdrawal
I! 150 Recovery of Overpuyment 11 320 Assault, Libel & Liability II 630 Liquor Law, 28 U,S,C. 157 II 450 CommerceiICC
& Enfbrcemertt of Judgment Slander II J 68 Asbestos Personal 11 6-10 KK & Truck Rates/etc
I! 151 Medicare Act II 3311 federal Employers' Injury Prod. Liab . 11 650 Airline Regs PROPERTY
I! 152 Recovery of Defaulted Liability 11 660 Occupational RIGHTS 11 460 Deportation
Student Loans (E"L V<1<r",,<) 113-10 Marine PEHSONAL PROPERTI' S.fetylHe.!th
I! 153 Recovery of Overpayment 11345 Marine Product liability ll 370 Other fraud 11 690 Other [I 470 Racketee Influenced
at Veteran's Benefits: 11350 Motor Vehicle 11 371 Truth in Lending II 820 Copyright, Corrupt Organizations
I! 160 Stockholders" Suits 1I 355 Motor Vehicle Product II 380 Other Personal Property II 830 Patent
IJ 190 Other Contract Liability Damage 11840 Trademark 11 810 Selective Service
Jl ]95 Contract Product liability ll 360 Other Personal Injury 11 385 Property Damage Prod, II 850 Securities/
Product Liability Ccmmoditles/ Exchange
SECURITY II 875 Customer Challenge 12
UcScC JI40 ('
II 710 Fair Labor Standards ll 861 filA (f395fJ) II 89 I Agricultural Acts
ACI !l 862 Black L"n8(923) II 892 Economic Stabilization
II 863 DIWCIDI\\,W t\C:1
 720 Labor/Mgmt Relations (40j(g))
REAL PROPERTY CIVIL RIGHTS PRISONER PETITION II 86~ SSfD Tille XVI It 893 Environmental Matters
I! 730 Labor/Mgmt II 865 RSI (405(g)) II 89~ Enorgy Allocation ACI
Reporting & Dis-closure Act II 895 Freedom of
I! 210 Land Ccndemnatloa IJ 441 Voting II 510 MOlions 10 vacate I! 740 Railway Labor Act FEDERAL II 900 Appeal of Fee Dc-crm
I! 220 Foreclosure  442 Employment Sentence II 790 Other Labor Litigation TAX SUITS Under Equal A-ccess. to Justice
II 230 Rent Lease & Ejectment 11443 Housing/Arcommudations Habeas Corpus:
1I 240 Torts to Land 1l4HWelfar-e 11530 General IJ 950 Constitutionality of S10le
I! 535 I! 791 Empl. Ret Inc Statutes
II 290 All Other Real Property 11440 Othcr Cbf Rights De-ath. Penalty Security Act I! 870 T.,e5 (U.S
I! 540 Mandamus & Other Plaintiff or Defendant) 11 890 Other 51.luI01)' Actions
II 5S0 Other (including I! 871 IRS - Third Party
198J Actions) 26 U.S.c. 7609 VI. ORIGIN
IX J I Original Proceeding
 2 Removed from State Court
113 Remanded from Appellate Court
CHECK YES only if demanded in complaint:
Request for Jlfry Trial: IJ yes IXJ no
VII. REQUESTED IN
CHECK IF THIS IS A CLASS ACTION
VII. RELATED CASE(S) (See instructions):
II 4 Reinstated or Reopened
II 5 Transferred from another district (specify)
II 6 Multidistrict Litigation
I! 7 Appeal to District Judge from Magistrate
DATE October 7, 2U08
Charles J. Peters, Assistant United States Attorney SIGNATURE OF ATTORNEY OF RECORD
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