UNITED STATES DISTRICT COURT

DISTRiCT OF MARYLAND
UNITED STATES OF AMERICA
v.
SANTIAGO VARGAS-PONCE,
Defendant.
CRIMINAL COMPLAINT
CASE NUMBER: | · · í í ¹ SJ((;-
;
I, the undersigned complainant, being duly sworn, state the following is true and correct to
the best of my knowledge and belief: On February 16, 2010, in the District of Maryland,
SANTIAGO VARGAS-PONCE, the defendant, did knowingly and intentionally distribute and
possess with intent to distribute five kilograms or more of a mixture or substance containing a
detectable amount of cocaine, a Schedule II controlled substance, in violation of Title 21, United
States Code, Section 841(a)(l).
I further state that I am a Special Agent with the Drug Enforcement Administration and that
this complaint is based upon the following facts:
See Attached Affidavit
Continued on the attached sheet and made a part thereof: 0 Yes 0No
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TODD C. EDWARDS ~
SPECIAL AGENT
DRUG ENFORCEMENT ADMINISTRATION
Sworn to before me and subscribed in my presence,
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Date and Time'Issued
at Baltimore, Maryland
SUSA K. GAU y~. ~ ~
UNITED STATES MABIS:rRATE JUDGE S
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DISTRICT OF MAR Y~~Nmi'... - ~
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Case 1:10-mj-00493-SKG Document 1 Filed 02/17/10 Page 1 of 4
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AFFIDAVIT IN SUPPORT CRIMINAL COMPLAINT
I,Todd C. Edwards, being duly sworn, depose and state:
1. I am a Special Agent of the Drug Enforcement Administration ("DEA"). Your affiant
has been a duly sworn member of the DEA for approximately 13 years. Your affiant successfully
completed the DEA Training Academy, where your affiant received formal training in the fields of
narcotics investigation, drug identification, methods of concealment, and distribution of controlled
substances. Since becoming a DEA agent, your affiant has participated in numerous investigations
of unlawful drug trafficking. Your affiant has participated in the arrests of over 100 individuals for
violations of the narcotics laws of the State of Maryland and the United States of America. Your
affiant has also participated innumerous debriefings of those involved in the abuse and distribution.
of controlled substances. Your affiant has recovered or participated in the recovery of substantial
.quantities of cocaine, cocaine base, heroin, marijuana, and various paraphernalia for the distribution,
packaging, and manufacturing of controlled substances. Your affiant has made over 50 affidavits
in support of search and seizure warrants which have targeted violations and violators of criminal
narcotics laws, and has participated in the execution of over 150 search and seizure warrants where
evidence of such violations were recovered. Your affi~nt has participated in at least five
investigations that have used court-ordered wiretaps as an investigative tool, and is thereby familiar
with the manner of communication and expression used by narcotics traffickers in communicating
to others involved in narcotics trafficking, including the use of coded/guarded language to obliquely
(rather than directly) refer to the narcotics that are the true subject of their conversations.
2. This affidavit is in support ofa Complaint against SANTIAGO VARGAS-PONCE.
This affidavit is based upon proactive law enforcement operations, my conversations with other law
enforcement officers and other individuals and my review of relevant documents. Because this
affidavit is being submitted for the limited purpose of establishing probable cause, it does not include
all of the facts that I have learned during the course of this investigation. Where the contents of
documents, and the actions and statements of others are reported herein, they are reported in
substance and in part, except where otherwise indicated.
3. Based on proactive law enforcement operations, my conversations with other law
enforcement officers and other individuals and my review of relevant documents, I have learned the
following:
(a) In January 2010, a reliable Confidential Source (CS)' related
information to federal law enforcement agents that a Mexican drug-trafficker was in
negotiations with the CS to deliver a large quantity of cocaine to Baltimore. During
the week of February 8-12, 2010, the CS related to federal law enforcement that the
Mexican drug-trafficker had contacted the CS and indicated that SANTIAGO
VARGAS-PONCE would be traveling to Baltimore to deliver approximately ten (l0)
1 The CS is cooperating with law enforcement officials in the hopes of receiving a reduced
sentence. Information provided by the CS has proven to be reliable and has heen corroborated by
independent investigation.
Case 1:10-mj-00493-SKG Document 1 Filed 02/17/10 Page 2 of 4
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kilograms of cocaine during the week of February 15, 2010.
(b) On February 15, 2010, SANTIAGO VARGAS-PONCE contacted the
CS and indicated that he would be in Baltimore, Maryland later that day with a large
quantity of cocaine. Later on February 15,2010, SANTIAGO VARGAS-PONCE
contacted the CS and indicated that he had arrived in Baltimore, Maryland.
(c) During the evening of February 15, 2010, the CS met with
SANTIAGO VARGAS-PONCE to discuss the pending drug transaction. During the
meeting, SANTIAGO VARGAS-PONCE indicated to the CS that he had
approximately six (6) kilograms of cocaine hidden in his car. The CS and
SANTIAGO VARGAS-PONCE discussed where the drug transaction would take
place. They agreed that the transaction would take place in a secure garage located
in Owings Mills, Maryland. It was also agreed between the CS and SANTIAGO
VARGAS-PONCE that the CS would keep the vehicle in the garage overnight and
the transaction would take place on February 16,2010.
(d) On February 16, 2010, the CS picked-up SANTIAGO VARGAS-
PONCE from a hotel, gathered tools to extract the cocaine from the vehicle, and
drove to the garage in Owings Mills, Maryland where the car was parked and under
surveillance by federal law enforcement agents. The CS dropped-off SANTIAGO
VARGAS-PONCE at the. garage in Owings Mills. The CS told SANTIAGO
VARGAS-PONCE that he needed to go get money and left the area. After
SANTIAGO VARGAS-PONCE entered the garage, federal law enforcement agents,
via a hidden camera, observed SANTIAGO VARGAS-PONCE disassemble the
vehicle. Federal law enforcement agents obtained consent from the lessee of the
premises to enter the garage. After federal law enforcement agents observed
SANTIAGO VARGAS-PONCE extract a large object from the engine compartment
of the vehicle, federal law enforcement agents opened the garage door and observed
SANTIAGO VARGAS-PONCE standing by the object extracted from the engine
compartment. Upon further inspection, the object extracted from the engine
compartment of the vehicle appeared to be approximately four (4) kilograms of
suspected cocaine. SANTIAGO VARGAS-PONCE was placed under arrest.
Federal law enforcement agents later extracted an additional two (2) kilograms of
suspected cocaine from the engine compartment ofthe vehicle. The suspected illegal
substance was later field-tested for cocaine with positive results.
4. Based on the foregoing, I respectfully submit that there is probable cause to believe
that on February 16,2010, in the District of Maryland, SANTIAGO VARGAS-PONCE, the
defendant, did knowingly and intentionally distribute and possess with intent to distribute a
controlled substance, to wit: approximately five kilograms or more of a mixture or substance
containing a detectable amount of cocaine, a Schedule II controlled substance, in violation of Title
21, United States Code, Sections 841(a)(l). ' . .
2
Case 1:10-mj-00493-SKG Document 1 Filed 02/17/10 Page 3 of 4
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!
Todd C. Edwards
Special Agent
Drug Enforcement Administration
Case 1:10-mj-00493-SKG Document 1 Filed 02/17/10 Page 4 of 4

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