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Case 1:09-mj-04182-BPG Document 3 Filed 11/25/09 Page 1 of 5

AFFIDAVIT 09-4182 BPG


This Affidavit is submitted in support of search warrants targeting:

1. Self-storage container AI019, located at the business know as Public


Storage at 820 Kent Avenue, Baltimore, Maryland 21228, marked "A 1019" in
black numerals on its exterior, and leased to Paul Sessomes, and

2. Self-storage container E0009, located at the business known as


Public Storage at 1701 Whitehead Road, Baltimore, Maryland 21207, marked
"E0009" in black numerals on its exterior, and leased to Paul Sessomes,

in which there is probable cause to believe evidence of the type outlined in Attachment
A, which is evidence of violations of21 U.S.C. 9846 (conspiracy to distribute controlled
substances) will be found.

Your Affiant

Your affiant, Task Force Officer (TFO) David L. Phillips, is an investigative or


law enforcement officer ofthe United States within the meaning of 18 U.S.c. 92510(7),
that is, an officer of the United States who is empowered by law to conduct investigations
of, and to make arrests for, offenses enumerated in 18 U.S.C,'S2516. Your affiant
Phillips is currently assigned as a Task Force Officer of the Drug Enforcement
Administration (DEA) HIDT A Group 51.

Your affiant has been a member of the Baltimore County Police Department since
October, 1995 . Your affiant received 40 hours of training in the investigation of
controlled dangerous substances while attending the Baltimore County Police Academy.
Since 1997, your Affiant has attended annual in-service training classes that have focused
on the investigation of narcotics violations.

During your affiant's tenure with the Baltimore County Police Department, he has
participated in the execution of over fifty (50) search and seizure warrants that have
targeted violations and violators of the criminal controlled substance laws, where
quantities of controlled dangerous substances, diluents, assorted packaging materials,
paraphernalia related to the narcotics trade, ledger sheets, customer lists, currency,
weapons and other items listed in Attachment A which are commonly used in the
furtherance of and are evidence of illegal narcotics trafficking.
While assigned to the Narcotics Section of the Baltimore County Police
Department, your affiant while acting in an undercover capacity has made at least three
(3) purchases of controlled dangerous substances from narcotics traffickers.
Your affiant has participated in prior investigations that have utilized court-
ordered interception of wire communications as an investigative tool, and is thereby
familiar with the jargon used by those involved in illegal narcotics trafficking.

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As a result of his law enforcement experience, your affiant has debriefed


numerous defendants, cooperating witnesses and others who have experience in the
distribution, packaging, and distribution of controlled dangerous substances.
Consequently, your affiant has become familiar with the phraseology and practices of '
those that abuse and illegally distribute controlled dangerous substances.

Facts and Circumstances

Unless otherwise noted, the below recited facts and circumstances are known to
your affiant through his review of the reports of agents assigned to this investigation, and
through his discussions with agents assigned to this investigation, and not upon your
affiant's first-hand observations. This affidavit does not include all facts and
circumstances know by your affiant about the described investigation, but only those
sufficient for purposes of this affidavit.

Since early 2008, agents of the Drug Enforcement Administration (DEA) New

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York Field Division (NYFD) and Bogota (COLOMBIA) Country Office (BCO) have
targeted the suspected heroin trafficking and money laundering activities of Jorge
Humberto ESPITIA-Arciniegas, Carlos Andres ESPITIA-Garcia, Gloria Patricia
RIVERA, and Henry HERRERA-Rodriguez, among others. Based on information
obtained through various court-ordered wiretap interception conducted by agents
assigned to the NYFD and BCO, those agents intercepted multiple narcotics-related
conversations between the above targets and a then unidentified Baltimore-based male
where the call participants discussed the collection of large amounts of drug proceeds.
Furthermore, based on these calls, it was determined that the actual delivery of drug
proceeds of the targeted narcotics organization were occuring in the Baltimore area, and
were being coordinated by this unidentified male who was using cellular telephone
(410)940-1134. According to service provider records, that cellphone was subscribed to
Nicole Barnes, DOB: 06/17/79,4216 Parkside Drive, Baltimore, MD, 21206.

Based on that information, agents assigned to a Baltimore-based DEA Group


initiated an investigation endeavoring to discern the narcotics-related activities of the
unidentified male who was then utilizing cellular telephone (410)940-1134. In that vein,
investigating agents sought and obtained a court order issued by a State of Maryland
judge, that authorized the tracking of that phone via a device that discerned that
cellphone's location through the use of cell sites the cellphone was using to receive and
make calls. In that manner, and through a Maryland Motor Vehicle Administration
photograph, the agents were able to identify Paul Sessomes (MV A Soundex #S-252-676-
237-820), an African-American male (d.o.b., 10/24/53) Baltimore resident as the user of
the cellphone that had been in contact with the investigation's targets concerning the
delivery of drug proceeds. In fact, during September, 2008, Paul Sessomes was observed
by the agents meeting with Diego Neira and Maria Espitia-Garcia, known money
launders for the Bogota, Columbia based Espitia heroin organization under investigation,
in Baltimore.

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Further, during October, 2008, Paul Sessomes was observed by investigating


. agents meeting with Thomas Corey Crosby who in November, 2009, pled guilty to a
federal narcotics felony in the District of Maryland, for which he is awaiting sentencing.

According to NCIC records, Sessomes has been twice arrested for narcotics
felonies, but in both cases the criminal charges were dismissed.

Public Storage operates a.chain of self-storage facilities nationwide. According


to current records of Public Storage, Paul Sessomes rents a) self-storage unit Al 0 19
located at 820 Kent Avenue, Baltimore, Maryland 21228, and b) self-storage unit E0009
located at 1701 Whitehead Road, Baltimore, Maryland 21207. In leasing these self-
storage units, Paul Sessomes identified himself to Public Storage employees by his
Maryland Driver's License, which bore soundex number S-252-676-237-820 .

. Your affiant knows through his training and experience that distributors of
controlled dangerous substances sometimes use self-storage containers to hide controlled
dangerous substances, drug proceeds and evidence of their illegal trafficking activities as
outlined in Attachment A.

On November 17,2009, TFO David Phillips, TFO George Vigue and his canine
trained in the olfactory detection of certain controlled substances went to the Public
Storage facility located at 820 Kent Avenue, Baltimore, Maryland 21228 in order to
conduct an exterior scan in the vicinity of unit Al 0 19. Once there, the canine was
deployed in the interior corridor containing the target unit Al 019. The canine scanned
several units' doors before alerting to the odor of a controlled dangerous substance in
self-storage unit Al 019.

Later that same day, TFO Phillips, TFO George Vigue and the same canine then
went to the Public Storage facility located at 1701 Whitehead Road, Baltimore, Maryland
21207 in order to conduct an exterior scan in the vicinity unit E0009. Once there, the
canine was deployed at the middle of the row containing target unit E0009. The canine
scanned several units' doors before alerting to the odor of a controlled dangerous
substance in self-storage unit E0009.

TFO Vigue has completed a fourteen (14) week training program with his drug
detection dog, "Zoe". "Zoe" has been trained and certified in the detection of drug odors,
to include marijuana, cocaine, methylenedioxymethamphetamine (MDMA-Ecstasy),
phencyclidine (PCP) and heroin. TFO Vigue has been trained to care for, maintain,
deploy, and recognize behavioral changes in the working dog that are consistent with a
positive detection of drug odors. "Zoe" is trained to react at the source of the odor if one
is detected. "Zoe" will sit when an odor is detected, though she has also scratched,
barked or attempted to bite the source on previous occasion where contraband was
subsequently recovered. This behavior is referred to as an "alert". Since deployment,
TFO Vigue and "Zoe" have successfully attended bi-weekly training and monthly
certification. TFO Vigue and "Zoe" are currently certified as a narcotics detection team

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4182 SPG
by the National Law Enforcement Canine Organization.

TFO Vigue and "Zoe" have successfully recovered large amounts of controlled
dangerous substances that have resulted in successful prosecutions in state and federal
courts. TFO Vigue and "Zoe" have also located and recovered large amounts of currency
that have been contaminated with drug odors which have been seized at the state and
federal levels.

Wherefore your affiant avers that there is probable cause to believe that located
m:

1. Self-storage container AI019, located at the business know as Public


Storage at 820 Kent Avenue, Baltimore, Maryland 21228, marked
"A 1019" in black numerals on its exterior, and leased to Paul
SESSOMES, and

2. Self-storage container E0009, located at the business known as Public


Storage at 1701 Whitehead Road, Baltimore, Maryland 21207, marked
"E0009" in black numerals on its exterior, and leased to Paul
SESSOMES,

is evidence of the type detailed in Attachment A of the narcotics trafficking


activities of Paul Sessomes.

Your affiant affirms under penalty of perjury that the facts and circumstances
outlined above are true and accurate to the best of his knowledge and belief.

Date'
It 1:J.!i /0 '}

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ATTACHMENT A
1. Controlled Dangerous Substances to include but not confined to heroin, a Schedule
I controlled substance;
2. Related packaging material including small glass vials, and small zip-lock baggies;
3. United States currency, money orders, or other recognizable assets that are
proceeds of narcotics trafficking;
4. Books, records, receipts, notes, ledgers, airline tickets, money orders and other
papers relating to the transportation, purchase, packaging, sale and distribution of controlled
substances;
5. Documents, papers, or electronic storage devices which reflect the names,
addresses and/or telephone/beeper numbers of their suppliers, couriers, customers and other
associates in the illegal drug trade;
6. Proceeds of illegal activities to include monetary instruments, precious metals,
jewelry, rare coins, works of art and other items of value, as well as books and records regarding the
acquisition, use and disposition of such items of value;
7. Receipts pertaining to financial/monetary transactions conducted'through domestic
banks, foreign banks, and other financial institutions in their efforts conceal or legitimize their illegal
proceeds;
8. Photographs of themselves, their co-conspirators, and their associates;
9. Indicia of occupancy, including documents, mail, receipts, bills;
10. Paraphernalia relating to the packaging, distribution and/or abuse of controlled
substances, including but not limited to scales and baggies;

all of which are based on the training and experience of your affiant to be evidence, fruits and/or
instrumentalities of violations of Title 21 of the United States Code as described in the attached
affidavit of Task Force Officer David Phillips.