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Filed 01/19/12 Page 1 of 3 PageID# 2
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA
JAN 1 9 2012
UNITED STATES OF AMERICA
) ) )
Case No. l:12-MJ-26
MICHAEL BABATUNDE AYODELE, Defendant.
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
I, Byron Braggs, being duly sworn, depose and state as follows:
I am a Special Agent of the United States Department of Homeland Security,
Homeland Security Investigations (HSI). I am assigned to the Washington Dulles International
Airport. My duties as a Special Agent with DHS include, but are not limited to, the investigation
of federal laws governing the importation and exportation of controlled substances. I have
received training in general law enforcement, including training in Title 21 of the United States
I have been a Special Agent since 1992 after graduating from the Federal Law
Enforcement Training Center at Glynco, Georgia.
2. I am an "investigative or law enforcement officer" of the United States within the
meaning of Title 18, United States Code, Section 2510(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 Title 18, United States Code, Section 2516(1).
This affidavit is submitted in support of a criminal complaint charging that on or
about January 16, 2012, in Loudoun County, Virginia, within the Eastern District of Virginia,
Case 1:12-mj-00026-JFA Document 2
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MICHAEL BABATUNDE AYODELE knowingly or intentionally imported or attempted to
import into the customs territory of the United States from any place outside thereof, or
attempted to import into the United States from any place outside thereof, 100 grams or more of
a mixture or substance containing a detectable amount of heroin, a Schedule I controlled
substance, in violation of 21 U.S.C. §§ 952 & 963.
The facts set forth in this affidavit are based on my personal knowledge and
review of records, documents, and other physical evidence obtained during this investigation, as
well as information conveyed to me by other law enforcement officials.
This affidavit does not include each and every fact observed by me or known to
the government. I have set forth only those facts necessary to support a finding of probable
On or about January 16, 2012, AYODELE arrived at Dulles International Airport,
in Loudoun County, Virginia, within the Eastern District of Virginia, on a flight from Zurich,
Officers with Customs and Border Protection (CBP) referred AYODELE to a
secondary inspection area. AYODELE told CBP officers that he was returning from Nigeria where he was visiting family. During the inspection process, AYODELE asked if he could use
CBP officers noted that while AYODELE was using the toilet, they heard a noise
likely caused by objects coming into contact with the stainless steel toilet. It was discovered that
the source of the noise was AYODELE passing of pellets from his body. AYODELE passed 55
Case 1:12-mj-00026-JFA Document 2
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pellets while in the secondary area. CBP officers observed AYODELE expel some of the pellets
from his rectum.
CBP officers field-tested the contents of one of the expelled pellets, which tested
positive for the presence of heroin. AYODELE was transported to the Reston Hospital for additional observation. While at the hospital, AYODELE expelled an additional 31 pellets. The
total gross weight of all of the pellets expelled by AYODELE was 1089.3 grams.
AYODELE acknowledged that he swallowed the pellets, which he understood
Based upon the above information and my training and experience, I submit that
there is probable cause to believe that on or about January 16, 2012, in Loudoun County,
Virginia, within the Eastern District of Virginia, MICHAEL BABATUNDE AYODELE
knowingly or intentionally imported or attempted to import into the customs territory of the
United States from any place outside thereof, or attempted to import into the United States from
any place outside thereof, 100 grams or more of a mixture or substance containing a detectable amount of heroin, a Schedule I controlled substance, in violation of 21 U.S.C. §§ 952 & 963.
Special Agent v__-U.S. Department of Homeland Security
Sworn to and subscribed before me this 19th day of January, 2012.
/s/Thomas Rawles Jones, Jr.
The Honorable T. Rawles Jones, Jr.
United States Magistrate Judge Alexandria, Virginia