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AO 91 (Rev.

08/09) Criminal Complaint

United States of America
Walter J. White,
for the
District of Montana
APR 2 3 2013
Clerk, U.S. District Court
District Of Montana
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of October 2012 to March 14, 2013 in the county of Yellowstone in the
District of Montana , the defendant(s) violated:
Code Section
(Count I)
21 U.S.C. Section 841 (a)(1)
(Count II)
18 U.S.C. Section 924(c)
Offense Description
Possession with intent to distribute methamphetamine.
(Penalty: Mandatory minimum ten years to life imprisonment; $10,000,000
fine; and five years supervised release)
Possession of a firearm in furtherance of a drug crime.
(Penalty: Mandatory minimum five years to life imprisonment consecutive to
any other sentence; $250,000 fine; and five years supervised release)
This criminal complaint is based on these facts:
See attached affidavit, incorporated by reference herein.
0 Continued on the attached sheet.
__ _
Sworn to before me and signed in my presence.
Date' JQ/3,_
City and state' :11 l/T) fi1.T
Case 1:13-cr-00039-DWM Document 1 Filed 04/23/13 Page 1 of 1
I, Robert M. Grayson, submit this affidavit in support of a
complaint alleging that Walter J. White has committed the crimes of:
Count I- Possession with Intent to Distribute Methamphetamine, in
violation of 21 U.S. C. 841(a)(1); and Count II -Possession of a Firearm
in Furtherance of a Drug Crime, a violation of 18 U.S. C. 924(c).
1. I am currently employed as a Special Agent with the Drug
Enforcement Administration ("DEA"). I have been employed with the
DEA since January 2012, and I became a Special Agent with the DEA
in May 2012. I am currently assigned to the Eastern Montana High
Intensity Drug Trafficking Area Unit ("EMHIDTA'') based out of
Billings, Montana.
2. I have received Basic Agent Training at the DEA Academy in
Quantico, Virginia. I have also received Basic Clandestine Laboratory
Training at the DEA Academy. Additionally, I possess a Bachelor of
Science degree in History and Political Science from Rocky Mountain
College in Billings, Montana, and a Masters in Public Administration
from Drake University in Des Moines, Iowa.
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3. I have conducted numerous drug investigations as a Special
Agent. During these investigations, I have had exposure to the
identification and odors of dangerous drugs. I have participated in drug
investigations revealing the common types of packaging, storage, street
terminology and costs of dangerous drugs. I have also executed search
warrants revealing several types of drugs, packaging materials, and
evidence of distribution.
4. Based on my training, experience, and participation in the
investigation of the distribution, transportation, trafficking, and
possession of controlled substances, I am able to identify
5. On March 13, 2013, United States Magistrate Judge Carolyn S.
Ostby reviewed and signed a search warrant for the property located at
1270 Lockwood Road #8 in Billings, Montana. 1270 Lockwood Road #8
is the residence and place of business for Walter J. White.
6. On March 14, 2013, federal and state law enforcements agents
executed the search warrant. When agents executed the warrant,
Walter J. White was the only occupant in the residence. During the
execution of the search warrant, agents located and seized multiple
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items of evidence. The seizure included approximately four ounces of
methamphetamine, two firearms (a FIE .22 caliber revolver and a
Taurus .45 caliber pistol), and $15,291 in U.S. currency. The Taurus
.45 caliber pistol was found under a mattress in the bedroom, and the
FIE .22 caliber revolver was found in a safe in the bedroom.
7. I have inspected the suspected methamphetamine seized
pursuant to the search warrant. Based upon my training and
experience, I believe that the substance in question is, in fact,
8. Mter the execution of the warrant, agents interviewed White
regarding his involvement in the distribution of methamphetamine.
White admitted to distributing methamphetamine out of the subject
location. According to White, beginning in October or November of
2012, he received approximately one to two pounds of
methamphetamine on average one time per week from his source of
supply. He further described how he would then distribute the
methamphetamine to other individuals.
9. Additionally, White admitted to possessing the firearms in the
residence. He stated that he kept one firearm under his pillow for
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protection from other individuals involved in drug trafficking who may
intend to rob or shoot him. White also stated that he obtained the
firearm found under his bedroom mattress in exchange for
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