Case 2:14-cr-00005-GZS Document 34 Filed 06/10/14 Page 1 of 4

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UNITED STATES DISTRICT COURT
DISTRICT OF MAINE
UNITED STATES OF AMERICA

)
)
)
)
)

v.
PAUL ROBINSON

No. 2:14-cr-05-GZS

PROSECUTION VERSION
If this matter were to proceed to trial, the United States would prove the following facts
beyond a reasonable doubt:
Counts One and Three
On April 11, 2013, Defendant distributed 26.7 grams of cocaine base from an apartment in
Lewiston, Maine, to Person A. As Person A departed the apartment building, she was stopped
by the police and the drugs were seized. Soon after the drug seizure, law enforcement officers
secured the apartment from which Defendant distributed the cocaine base and subsequently
obtained a search warrant. Nobody was inside of the apartment at the time officers made entry.
During execution of the warrant, law enforcement officers seized items including the following:
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Monitors attached to surveillance cameras facing the front of the building

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A working police scanner

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A Smith and Wesson .40 caliber handgun bearing serial number DVJ5218

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A Springfield .45 caliber handgun bearing serial number MG577782

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Paperwork belonging to Paul Robinson

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A digital scale

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Approximately $4500 in cash

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6.23 grams of cocaine base

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5 EBT cards belonging to people other than Paul Robinson (a common currency for
drugs)
Law enforcement officers did not seize any paraphernalia such as crack pipes, steel wool,

or other smoking or lighting devices that would be consistent with crack use within the
apartment.
The Smith and Wesson firearm described above was located in a desk drawer with a line
of sight to the front door of the apartment. A loaded magazine was right next to this firearm.
The police scanners, surveillance monitors, and packaging materials were found on the same
desk. The Springfield firearm described above was found in a box underneath the same desk. A
loaded magazine was found near this firearm as well. Business records reveal that both firearms
were sold to Defendant.
The two firearms described above were seized soon after Defendant distributed cocaine
base to Person A. Both firearms were in close proximity to the front door of the apartment and
in close proximity to the seized 6.23 grams of cocaine base (located in an adjacent kitchen) and
approximately $4500 in cash (located in a bedroom). A trained and experienced law
enforcement officer would testify that drug traffickers commonly maintain firearms in order to
protect themselves, their drugs, and their drug proceeds.
Count Two
Between early 2011 and June 2012, Defendant Paul Robinson conspired with others known
and unknown to obtain cocaine base in Massachusetts for distribution in Maine. Specifically,
Defendant and other conspirators in the drug trade made numerous trips to Massachusetts during
the time period referenced above to acquire multi-ounce quantities of cocaine base in furtherance
of this conspiracy. Defendant and other conspirators would obtain the cocaine base from the
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conspiracy’s supplier, transport the drugs to Lewiston, and distribute the drugs in exchange for
cash. In June 2012, law enforcement officers in Maine seized approximately $16,000 in cash
from a vehicle occupied by Defendant and Eric Mitchell. This money represented drug
proceeds.
This conspiracy was responsible for transporting and distributing more than 28 grams of
cocaine base. During the course of the conspiracy, Defendant personally handled in excess of 28
grams of cocaine base. Therefore, 28 grams or more of cocaine base was reasonably foreseeable
to him.
Date: June 10, 2014
Respectfully submitted,
Thomas E. Delahanty II
United States Attorney
/s/David B. Joyce
Assistant U.S. Attorney
United States Attorney’s Office
100 Middle Street
Portland, ME 04101
david.joyce@usdoj.gov

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UNITED STATES DISTRICT COURT
DISTRICT OF MAINE

CERTIFICATE OF SERVICE
I hereby certify that on June 10, 2014, I filed the foregoing Prosecution Version using the
Court’s CM/ECF system, which will cause a copy to be sent to the following attorney:
Jonathan Goodman, Esq.

/s/David B. Joyce
Assistant U.S. Attorney

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