Quick viewing(Text Mode)

Richard Shaw Case Xo. L . ) Q /U ) 67

Richard Shaw Case Xo. L . ) Q /U ) 67

Case 1:14-mj-00087-PMS Document 3 Filed 04/14/14 Page 1 of 1 Pageid#: 3 ' AO 9 1 (R !'k):'L 3t'.E12î h- )*'$SI' A: :'f;-x: F 'è' f) r. .' tl'.zctkb,:' lflzhè'ltcl)r sax,s oFFlcE I.J .S. DIST. COURT : t -, . ev. 1 1/1 1 ) Criminal Complaint kr. ox. . .,u,. j...t . '. .,. ,.gi's . ,:-.; ji)j Aytk.-: ct- z !J.IZ - N, vjyj .,t 1 h' . à' ' '' .' ' . '. L. è

CRIM INAL CO M PLAINT

ls the complainant in this case, state that the following is true to the best of m y knowledge and belief. On or about the datets) of January 2009 to date in the county of in the Western District of Virginia , the defendantts) violated: Code Section Offense Description 21 U.S.C. j 846 Conspiracy to Possess with the Intent to Distribute Methamphetamine

This crim inal com plaint is based on these facts: See Attached.

D Continued on the attached sheet. / Complainant 's signature Jonathan Tabor, Special Agent, Bureau of ATF Printed name and title

Sworn to before m e and signed in m y presence.

Date: 04/14/2014 Judge 's signature city and state'. Abingdon, Virginia Pamela Meade Sargent, U.S. Magistrate Judge Printed name and title Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 1 of 106 Pageid#: 4

IN THE UN ITED STATES DISTRICT COURT FOR THE W ESTERN DISTRICT OF VIRGFNIA

Abingdon Division

IN THE M ATTER OF THE ARRESTS UNDER SEAL OF RICHARD SHAW ET AL Case N o.

AFFIDAVIT IN SUPPORT OF CRIM INAL COM PLAINTS. ARREST AN D SEARCH W ARRANTS

1, Jonathan A. Tabor, Special Agent, United States Departm ent of Justice, Bureau of Alcohol, Tobacco, Firearm s, and Explosives, being duly sworn, do depose and state as follow s:

INTRODUCTION

I am a Special Agent (SA) with the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) and have been employed for approximately four years. Prior to becom ing an ATF Agent l served as a State Trooper with the W est Virginia State Police from 2003-2009. l have received training at the W est Virginia State Police Academy, Federal Law Enforcement Training Center (FLETC), and the ATF National Academy. During m y training at FLETC and the ATF National Academ y I received specialized training in the Controlled Substances Act, Title 21, United States Code, including, but not limited to Sections 841 (a)(1) and 846 (Conspiracy and Controlled Substance Violations), crim inal organizations engaged in conspiracies to manufacture and/or possess with intent to distribute cocaine, methamphetamine, marijuana and other dangerous drugs prohibited by law, search and seizure law , and many other facets of drug law enforcement.

During my tenure in law enforcem ent, 1 have become familiar with the m ethods and techniques associated with the distribution of narcotics, the latmdering of drug proceeds and the organization of drug conspiracies. In the course of conducting these investigations, yotlr affiant has been involved in the use of the following investigative teclm iques: interviewing confidential sources and cooperating witnesses; conducting physical surveillance, controlled buys; consensual monitoring and recording of both telephonic and non-telephonic com munications', conducting court-authorized electronic surveillance. Further, I have participated in the preparation, presentation and execution of num erous search and arrest warrants which have resulted in the recovery of weapons, narcotics, m oney and docum entary evidence indicative of firearm and narcotic trafficking organizations. Additionally, l have assisted in investigations and arrests leading to convictions for violations of federal and state firearm and narcotics laws.

1 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 2 of 106 Pageid#: 5

Through instruction and pm icipation in investigations, your affant has becom e fam iliar with the m anner and m ethods by which narcotics traffickers conduct their illegal business and the language and tenus that are used to disguise conversations about their narcotics activities. From experience and training, your affiant has learned, among other things, that in conversations narcotics traffickers believe susceptible to interception, they virtually never expressly refer to methamphetam ine or other illegal drugs by name; instead to conceal the true nattzre of their illegal activities and to thwart detection by law enforcement, they refer to the drugs and drug quantities using seem ingly innocent term s. Further, based upon your aftiant's know ledge, training, experience and participation in firearm and narcotic trafficking investigations, yotzr afEant knows that: lndividuals who deal in illegal controlled substances m aintain books, records, receipts, notes, ledgers, bank records, m oney orders, electronic files/data, computers and papers relating to the importation, m anufacture, transportation, ordering, sale and distribution of illegal controlled substances. These books, records, receipts, notes, ledgers, bank records, m oney orders, electronic tiles, computers, etc., are maintained in locations to which the dealers in illegal controlled substances have ready access, such as within their residences and the sunounding curtilage; their vehicles', the residences of fam ily members, friends and associates', the places in which they conduct their drug distribution activities, such as stash houses or safe houses; in business locations with which the trafficker is associated', or in storage areas.

4 . lndividuals who deal in illegal controlled substances routinely conceal large quantities of currency, financial instruments, precious metals, jewelry, and other items of value, typically proceeds of illegal controlled substance transactions. lndeed, when drug traftickers am ass large proceeds from the sale of drugs, they often attem pt to legitim ize or ''launder'' these protks. To aceomplish this, drug traffickers m ay utilize domestic and foreign banks and/or financial institutions and their attendant services, such as sectuities, cashier's checks, m oney drafts, letters of credit and safe deposit boxes. A11 of these items are generally found within their residences and the surrounding curtilage; their vehicles; the residences of family m embers, friends and associates; the places in which they conduct their drug distribution activities, such as stash houses or safe houses; in business locations with which the trafscker is associated; or in storage areas.

lt is comm on for individuals who deal in the sale of illegal controlled substances, to secrete contraband related to the trafficking activity, such as scales, razors, packaging m aterials, eutling agents, cooking utensils, m icrowave ovens, hair dryers, blenders, pots, dishes and other containers for preparing metham phetamine and other controlled substances for distribution, within their residences and the surrounding curtilage; their vehicles; the residences of family mem bers, friends and associates; the places in which they conduct their drug distribution activities, such as stash houses or safe houses', in business locations with which the trafticker is associated', or in storage areas.

lndividuals who deal in the sale and distribution of controlled substances com m only m aintain telephone numbers and address books or papers which reflect nam es, addresses ancl/or telephone numbers for their associates. These individuals often utilize cellular telephones, pagers and telephone system s to maintain contact with their associates in their

2 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 3 of 106 Pageid#: 6

illegal businesses. These electronic devices, telephone records, bills and paper are often found within their residences and the surrounding curtilage; their vehicles; the residences of fam ily m em bers, friends and associates; the places in which they conduct their dnlg distribution activities, such as stash houses or safe houses; in business locations with which the trafficker is associated; or in storage areas.

Individuals who deal in illegal controlled substances often take photographs of them selves, their associates, their property and illegal contraband. These photographs are usually maintained within their residences and the surrounding curtilage; their vehicles', the residences of fam ily mem bers, friends and associates; the places in which they conduct their dnzg distribution activities, such as stash houses or safe houses; in business locations with which the trafficker is associated', or in storage areas.

8. Persons who traffic in controlled substances maintain documents, letters and records relating to their illegal activities for long periods of tim e. This docum entary evidence is usually secreted within their residences and the surrounding curtilage; their vehicles; the residences of fam ily members, friends and associates; the places in which they conduct their dnzg distribution activities, such as stash houses or safe houses; in business locations with which the trafficker is associated', or in storage areas.

lndividuals involved in narcotics trafficking often own, possess and/or use fireanns as a m eans of facilitating their illegal drug activities. Said firearm s are used to protect and secure a drug traftickers property and narcotics from law enforcem ent and from theft by other crim inals. Drug traffickers also possess firearm s as a means of enforcing drug transactions, i.e., as a m eans of ensuring paym ent for the drugs they are selling. Such weapons are m ost often secreted within their residences and the surrounding curtilage; their vehicles', the residences of family mem bers, friends and associates', the places in which they conduct their dnzg distribution activities', such as stash houses or safe houses; in business locations with which the trafticker is associated', or in storage areas. Persons who possess or collect tirearm s also keep other firearm related equipm ent, to include am munition, amm unition m agazines, holsters, bullet proof vests, pistol grips, pistol boxes, cleaning kits and paperwork relating to the acquisition and disposition of tireanns.

10. lndividuals who are m embers of active drug organizations stay in regular contact with one another. This contact does not terminate once an individual is incarcerated. lncarcerated mem bers of drug organizations routinely send letters to and receive letters from other m embers of the organization in which they discuss ongoing crim inal activities and request various form s of assistance, from financial help to help in engaging in witness intim idation or elimination. ln addition, incarcerated m embers often keep photographs of themselves and other m embers of their organization in order to obtain respect from other inm ates.

1 l . Based on my training and experience I have becom e fam iliar with methods used by traffickers to smuggle and safeguard narcotics, to distribute narcotics, and to collect and launder proceeds. The aftiant is aware of the sophisticated tactics they routinely use to attem pt to thwart detection by law enforcement which include the utilization of ntzm erous

3 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 4 of 106 Pageid#: 7

different cellular telephones, counter surveillance, false or fictitious identities, and coded com munications and conversations. The affiant know s that individuals involved in narcotics traftk king often use (çcode'' words when facilitating illegal drug transactions. Based on the affiant's knowledge and participation of this investigation tenus such as tttruck parts , ttcoffee'' , ttrtz gs '' , ûûfurniture'' , tdlug nuts'' or $$ go to the m arket'' were used when conducting methamphetamine transactions in order to avoid detection from 1aw enforcement.

12. The inform ation contained in this affidavit is based on my personal observations, observations of other law enforcem ent officers, observations of Contidential lnformants (CI's) and Cooperating Sources (CS) as related to me, my review of official police and governm ent reports, and consultation with other agents/offcer involved in the investigation and is provided for the lim ited purpose of establishing probable cause. The inform ation is not a complete statem ent of a1l the facts related to this case.

13. This aftidavit is submitted in support of a request that a complaint, arrest warrantts) and search warrantts) be issued for the following personts) and placetslfor violations of Title 21, United States Code, Section 846, Conspiracy to Possess with the lntent to Distribute M etham phetamine:

Persons

1. Richard Shaw 2. M elvin Campbell 3. Jim Grindstaff 4. Daniel Reece 5. Linda W alters 6. Russell Cassell 7. Kenneth Craig Buchanan 8. Stephanie Patrick 9. Roger Lawson 10. Toby M ock 1 l . Rachael Peake 12. Jason M ullinax 13. Roger Austin Jr. 14. Tim othy Gerace 15. Angela Surber 16. Patricia Lealm Hall l 7. M ichael Brady Lester 18. Joseph N athan Hall 19. W illinm Hunt, Jr. 20. Brandi M arie Dtmford 21 . Tim othy Nickolas Rabara 22. Albert Hague 23. Kim berly Ann Bradley Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 5 of 106 Pageid#: 8

Locations

8282 Old M ill Road, Glade Spring, Virginia 24340 13341 Country Living Lane, M eadow view, Virginia 24340

INITIAL SUM M ARY

Beginning in April 201 1 law enforcem ent began to obtain inform ation regarding the m anufacturing and distribution of quantities of metham phetamine in the comm unity of Saltville located in W ashington Colmty, Virginia. Through arrests, interviews, and the cultivation of contidential inform ants, 1aw enforcement was able to identify a network of individuals involved in the possession and distribution of crystal m ethamphetam ine comm only referred to as tçlce'' in Southwest Virginia and Northeast Tennessee. The investigation shows that com m encing on or about January 1, 2009 and continuing to date, that in the W estern District of Virginia and elsewhere, the defendants lm owingly and unlawfully com bined, conspired and agrted together and with each other, and with other persons, both known and unknown to distzibute and possess with intent to distribute m ethamphetam ine; to m anufacture, distribute and possess with intent to distribute methamphetamine: a1l in violation of Title 21, United States Code, Sections 841(a)(1), (b)(1)(A)(viii); maintaining drug involved premises in violation of Title 2 1, United States Code, Sedion 856 and Title 18, United States Code, Section 2. All in violation of Title 21, United States Code, Section 846.

From Jtme 2012 until the present, federal, state, and local law enforcement have conducted interviews and executed controlled purchases of m ethamphetamine from m embers engaged in both the m anufacturing and trafficking of m ethamphetam ine. Tim othy GERACE aka BUDDHA was identified as a distributor of m ethamphetam ine in M ountain City, TN . In February 2013 undercover recordings of Tim othy GERACE captured audio in which GERACE stated he was being supplied methamphetamine from a M exican Cartel. GERACE stated he had over seventy (70) tirearms and his methamphetamine rulmers were armed. Through interviews and phone records it is known to law enforcem ent that GERACE supplies m ethamphetamine to a network of individuals to include, Roger LAW SON , Angela SURBER, Jason M ULLINAX, Brady LESTER, Joseph CcN athan HALL, W illiam HUNT, Jr., Rusty CASSELL, Toby M OCK and others in the W estern District of Virginia and the Eastern District of Tennessee. During the past several years GERACE and Richard itRick'' SHAW , also of M ountain City, TN, have conspired to distribute quantities of m ethamphetam ine. Through interviews and phone records it is known to 1aw enforcem ent that SHAW supplies metham phetamine to GEM CE, Dalm y REECE, Roger LAW SON , Jim GRIND STAFF, M elvin CA M PBELL and others.

5 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 6 of 106 Pageid#: 9

Throughout the course of this investigation, num erous subpoenas and court orders w ere issued for GPS tracking devices, telephone subscriber information, telephone toll records, and text m essage content cm cellular telephones. Text m essages were obtained via court order on the cell phones of Tim GERACE, Brady LESTER, Jason M ULLINAX, N athan HALL, Rick SHAW , Danny REECE, Rusty CASSELL, Roger LAW SON , Linda W ALTERS, Toby M OCK, and others. Any cellular telephone subscriber information and all text m essages referred to within this aftidavit, unless otherwise stated, are a result of these subpoenas and court orders.

PROBABLE CAUSE

SUBJECTS

Richard Charles SH AW

On February 25, 2009, M ichael Todd Layton was interviewed in Ashe County, NC. Layton stated that in December 2008, he purchased approxim ately $2,000.00 worth of m ethamphetam ine from Rick SHAW in M ountain City, TN.

On July 14, 2009, Christy Adam s was interviewed pursuant to a proffer agreement with the United States Attorney's Office. Adam s stated that in 2008, she traveled with Riehard SHA W from M ountain City, 'IN to Georgia to m eet with Todd Layton. Adam s stated that SHAW was a methamphetamine distributor for the same source of supply as her (iûchip'' in Georgia). On Decem ber 22, 2009, a traffic stop was executed on a vehicle operated by Richard SHAW in Anderson County, South Carolina. Pursuant to a search of the vehicle, approximately one (1) pound of methamphetamine was seized. SHAW and his passenger, Melvin Glen Cam pbell, were arrested and charged with trafticking m ethamphetam ine, As a result of the investigation SHAW and CAM PBELL were convicted of Attempt and Conspiracy Provisions Drug Law and received a five year suspended sentence and tive years probation.

On January 30, 2013 CS-4 was interviewed in Bristol, Virginia. CS-4 stated he/she, GERACE, and SHAW would sit and do m eth at SHAW 'S residence. Through interviews and surveillance SHAW 'S residence was identified as 382 T-Greer Road M ountain City, TN. CS-4 stated in early to m id April 2012 until arotmd July 4, 2012, he/she and GERACE would go to SHA W 'S house approximately three tim es a week. W hile present with SHAW , SHAW would provide m eth to use. CS-4 advised SHAW called people to com e to his house to pick up m eth. CS-4 advised he/she and GERACE would go out and sell meth for SHAW . CS-4 stated there was usually two to three zip lock bags full of methamphetnmine (ice) at SHAW 'S house. CS-4 stated the meth had the appearance of shattered glass and was not packaged in individual baggies but was packaged a1l together in the bags. CS-4 stated the m ost he/she had seen at one tim e was three zip lock bags full with the least amount being one sm all bag. CS-4 stated SHAW laundered m oney through a fake business. CS-4 stated during personal conversations with SHAW , SHAW bragged about not having ajob and laundering money for ten years through his fake business ûtshaw Industries.'' CS-4 stated on one occasion he/she witnessed GERACE take $10,000.00 cash to SHAW and observed GERACE personally hand the cash to SHAW .

6 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 7 of 106 Pageid#: 10

Between February 4, 2013 and February 7, 2013, CS-4 met with GERACE. W ords to the effect of the following were stated:

CS-4 asked GERACE about SHAW laundering m oney and how he does it. GERACE explained: SHAW tinds people, you know you can't put that m oney in your bank account, you can only put so m uch away and save som e stuff. W hat you do is buy land, find som eone who has good collateral, they buy the land, you give them the money and pay it off a little at the tim e, nothing more than $4,800.00, more than that sends up a flag. Or you buy' a business w ith another person and put the money into the business and then get it back clean. GERACE says he knows a guy up north who has over 20 businesses and moves his coke and pot m oney through them. You can go out and buy vehicles, the older ones with no loans. Buy and sell, just not show it, that is how you get caught. When l work a realjob l make good money, $80,000- 100,000 a year. That way I can m ake extra money and hide it like that. I bought this and that and prove it when I have a real job. 1 had a lot of extra money in the box but being off the last l two years Ssfucked me''. lt was fun but 1 am going to have to go back to work. CS-4 asked what Rick SHAW is doing. GERACE says: SHAW is laying 1ow and a couple of his people have called him . Buddha says: he is leaving well enough alone right now, trying to watch him self right now, not taking on anyone new. Just take it slow and wait, see what happens. Don't get greedy because that's when you get sloppy. 1 don't need to be greedy. The CS-4 asked GERACE if he likes dealing with the other people (M exicans) better. GERACE says yes, when it is done there is no fucking around, no playing gnmes. Dealing with Rick (SHAW ) he made you feel like you owed him something. 1 always paid him cash on time and he started jerking me around. l called him on it and then 1 went and took what 1 thought was mine and then some (GERACE previously admitted to CS-4 he had broken into a residence owned by 1 SHAW near Watauga Lake). A search of real estate records through the Johnson County, Tennesssee assessor's office reveals property owned by SHAW located at 623 W haley Town Road, Butler, TN 37640. The property was purchased on 10/13/2009 by Richard C. SHAW and Gary M arcus SHA W 11 for $35,000.00 with a $17,500.00 mortgage through Farmers State Bank. On 10/19/2009 bnnk records show Richard and Gary SHAW 11 paid off the balance of the loan ($18,342.35) with each brother paying approximately half of the rem aining balance with cash, a11 in $20.00 bills. The I residence is located approximately .5 miles from Watauga Lake. According to the records of Verizon W ireless, telephone number (423) 302-9299 was subscribed to by Richard C. SHAW at 382 T Greer Rd., M ountain City, TN . As a result of this investigation, your affiant believes that the prim ary user of this phone num ber was Rick SHA W .

On April 10, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephone numbers, including that of Danny REECE. In response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in that account from M arch 20 to M arch 27, 2013. The following is an excerpt from the search warrant results. Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 8 of 106 Pageid#: 11

M arch 21, 2013

Danny REECE to Rick SHAW , iGlhis is Danny ncw no. Are you at homefor ajèw?'' SHAW to REECE, iih?o b back 4 or 5'' REECE to SHAW , *i10-4 throw me a text when on wJy thanka man'' REECE to SHAW , çnNeed l whole an 1 J?J//'' Roger LA W SON to REECE, ;t1't)?: gonna wor/c in D town today?'' REECE to LAW SON, çLYeah but it will be 5 or 6 before that guy gets home. Then 1'11 Com e (?/Z

REECE to Rusty CASSELL, LQHe aint home ye/'' CASSELL to REECE, çGlkhere 9 he at?'' REECE to CASSELL, iilie said he would call when he got in /7tpz// J or 6prob'' CASSELL to REECE, 6*Hell. Ok''

REECE to SHAW , $$?'' SHAW to REECE, iiI 'm home man', REECE to LAW SON, GQM anjus text me i1l hollor atya when in hand '' LAW SON to REECE, i*Ok''

REECE to LAW SON , inGot them truckparts but not com in thay wJy till morning. Come up fyoud Iike to. '' REECE to CASSELL, çLGot help but not comi yr wJy till morn.''

Based on my training and experience, and my knowledge of this investigation, 1 believe that Danny REECE utilized the text messaging service on his cellular telephone to obtain m etham phetamine from Rick SHAW for the purpose of distributing it to Roger LAW SON and Rusty CASSELL.

slarch 23,2013

Danny REECE to Rick SHAW , I

REECE to CASSELL, *QOk told them 1 would ask u no àlïg,gy brother'' REECE to CASSELL, LLETA Jj''7

Based on m y training and experience, and my knowledge of this investigation, l believe that Dnnny REECE utilized the text messaging service on his cellular telephone to attem pt to sell four (4) grams of methamphetnmine for $1 10.00 per gram (instead of the going rate of $120.00

8 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 9 of 106 Pageid#: 12

per gram of crystal methamphetamine).I believe that Rusty CASSELL advised REECE that he could not afford to let it go at that price.

On April 1 1, 2013 Angela SURBER was interviewed in Bristol, Virginia. SURBER stated around 2009-2010 she m oved in with Danny REECE. After living with REECE for two m onths REECE asked SURBER to take him to M ountain City to obtain meth from Rick SHAW . SURBER stated she and REECE went to SHAW 'S to plzrchase m eth approxim ately once a week for approximately eight weeks. SURBER stated REECE obtained a tsfistful'' size of m eth each tim e from SHAW . SURBER advised m ost of the deals with SHAW occurred at his house but one deal occurred at a property SHAW owned in Butler, TN.

On April 23, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephone numbers, including those of Danny REECE and Rick SHAW . In response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accounts from April 9 to April 23, 2013. The following is an excerpt from the search warrant results.

April 10, 2013

Roger LAW SON to Danny REECE, kilts Roger myph is screwfup. Did u try to text me? New no. 276 206 3398,, REECE to LAW SON , Q*No still haven 't heard nothin'' LAW SON to REECE, iivb'o ur not Iikely to be over too soon. Just let me kntpw'' REECE to LAW SON, içïkrell im over here but no parts'' LA W SON to REECE, *GOk thanks.''

Rick SHAW to REECE, %*1 'm home'' REECE to SHA W , 6110-4 leavin Dlnown ntpw'' REECE to ûtBubba'' BUCHANAN 7LiDidyou an Rodger want to come tonight/t'

Based on my training and experience, and m y knowledge of this investigation, 1 believe that Danny REECE utilized the text messaging service on his cellular telephone to arrange to meet with Rick SHAW for the purpose of obtaining m ethamphetam ine. 1 believe that REECE in turn sold the m ethamphetam ine to Roger LAW SON and Bubba BUCHANAN.

A pril 14 - 15, 2013

Bubba BUCHANAN to Danny REECE, i;U n D r M tn CjKenny N stef, REECE to BUCHAN AN , ççout haven 't seen him yet', BUCHANAN to REECE, Gilkx when u dopleez bhknny N stef' REECE to Rick SHAW , ç6I gotta haul thisparts truck to Stony Creek an I 'll be up fyr around/'' REECE to SHAW , i%on wJy atlw to yr house'' SHAW to REECE, çç1 'm in Boone back soon', REECE to SHAW , *i1'l1 have to go tm ''

9 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 10 of 106 Pageid#: 13

SHAW to REECE, inok c u later text when u get back''

REECE to BUCHANAN , 2*10-4 good to goo'' Roger LAW SON to REECE, ççls it ok to stop by. lm in c//y'' REECE to LAW SON , çi10-4''

Based on m y training and experience, and my knowledge of this investigation, 1 believe that Danny REECE utilized the text messaging service on his cellular telephone to obtain m ethamphetam ine from Rick SHAW and distribute it to Bubba BUCHANAN and Roger LAW SON .

April 17, 2013

Rick SHAW to Danny REECE, inbleaded home'' REECE to SHAW , **On wJy do u need nethingh'om /own?'' SHAW to REECE, Qnllrink't

Roger LA W SON to REECE, dûadre u n D Fow?7 tonight'' REECE to LAW SON , $iC/ry'' REECE to LAW SON , iiGotparts't

Based on m y training and experience, and my knowledge of this investigation, 1 believe that Danny REECE utilized the text messaging service on his cellular telephone to obtain metham phetam ine from Rick SHAW and distribute it to Roger LAW SON .

April 19, 2013

Dalmy REECE to Rick SHA W , G*Willyou be around tonight.?'' SHA W to REECE, iiàhïo sorry''

Bubba BUCHANAN to REECE, GiEver hear n e thing LKenny Nstef' REECE to BUCHANAN, **He went to the Rodrun nothinft BUCHANAN to REECE, dt.. .l0-4bNKenny Nstef'

April 20 - 21, 2013

REECE to SHAW , çiblave you got any ideal what time you will be home/'' (423) 707-5321 to REECE, nLlfandwhenpossible can you double my regparts order //2/C.V'' REECE to (423) 707-5321, iiDude is gone to Rodrun//'' (423) 707-5321 to REECE, içsheeeotl'' (423) 534-7673 to REECE, i;& t@'' REECE to (423) 534-7673, iiDude is gone to the Rod Run. Don 't know when he will be home''

10 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 11 of 106 Pageid#: 14

BUCHANAN to REECE, GiNow wvî//.v up WKenny N Stef' REECE to BUCHANAN , Gx othin he still aint home?'' BUCHANAN to REECE, ;'Fex me when WKenny N stef'

Roger LAW SON to REECE, Lizqre u gonna be in D Town today/'' REECE to LAW SON , 1iFw#.' Dude is gone to the Rod Run don 't no when he will be home/'' LAW SON to REECE, ççAll 1 need is a 50 lb. bag ofdogfool' REECE to SHAW , Giklave you got any ideal what time you will be /?t??ne?'' BUCHANAN to REECE, iilkhat 's the word W Kenny N Stef' REECE to BUCHANAN , iiNothin/', SHA W to REECE, Qo3oml.n'' REECE to SHAW , içlkeenfourrrr on wayfrom Dlbwn'' REECE to BUCHANAN , içllow m uch cash u got on hand/'t BUCHANAN to REECE, **160 WKenny Nstef' REECE to BUCHANAN , idf-fow quik can u get to river bridge/'' BUCHANAN to REECE, 6120 n route now W Kenny N stef' LAW SON to REECE, iiok fl come over ntlwy'' REECE to LAW SON, GnYeahfor a lil,, LAW SON to REECE, içok Im leavin Saltville n(?w.'' LAW SON to REECE, çiBe there in 20 mfns''' REECE to LAW SON, Qil0-4''

The affiant believes Rick SHAW utilized the aforem entioned text messages to distribute metham phetam ine to Danny REECE who in turn distributed methamphetamine to Roger LAW SON and Kenneth BUCHANAN.

On M ay 2, 2013, CS-IO w as interviewed in Charlotte, N C. CS-IO stated that Rick SHAW was a metham phetamine distributor in M ountain City, TN . CS-IO stated that SHAW lived on T Greer Rd. and was currently on federal probation.

On August 16, 20 13, a search warrant was executed at 190 12 Lake Rd., Abingdon, VA, the residence of Nathan HALL, Brandi DUN FORD, W illiam HUN T, Jr. and others. Seized from the apartment of HALL and DUNFORD was a m ethamphetam ine lab. Subsequent to the search warrant, HALL, DUNFORD and HUNT w ere interviewed separately. HALL stated that the liquids seized during the search wanunt did not contain methnm phetam ine, as they were left over from previous tccooks''. HALL stated that he obtained his m etham phetam ine primarily from CtBUDDHA'' aka Tim GERACE. HALL stated that Rick SHAW was a big m ethamphetam ine supplier from TN .

On October 31, 2013 CS-9 was interviewed in Abingdon, VA . CS-9 stated he/she m et Rick SHAW three to fotlr years ago through Angela SURBER and Danny REECE. CS-9 stated that he/she had witnessed SHAW distribute m ethamphetamine on num erous occasions. CS-9

11 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 12 of 106 Pageid#: 15

stated SHAW told him/her to never speak openly about m eth but to speak in code when talking/texting on the phone. CS-9 stated SHAW sold m ethamphetam ine out of his garage. ( On Novem ber 19, 2013, CS-7 was interviewed in Coeburn, VA . CS-7 stated that in September 20l 3, he/she was present at the residence of Rick SHAW in M ountain City, TN when the person he/she was with received methamphetamine from Rick SHAW .

On M arch 7, 2014 the affiant traveled to the Carter County, Tennessee Courthouse in an attempt to speak with a Haley Herd believed to the ex-girlfriend of Rick SHAW . W hile present in the courtroom the afsant observed Herd sitting behind M elvin CAM PBELL and Rick SHAW (CAM PBELL and SHAW were arrested in Carter Cotmty, Tennessee on December 7, 2013 after a domestic incident with the Herd). The affiant identified himself to Herd and asked to speak to her about her relationship with SHAW . Herd then provided her cell phone and agreed to speak with the aftiant on later date.

On M arch 12, 2014 CS-8 contacted the affiant after attem pting to order 1 .0 gram s of m ethamphetam ine from Jim GRINDSTAFF at the direction of 1aw enforcem ent. CS-8 stated Jim GRW DSTAFF had contacted hinfher about ptlrchasing m etham phetam ine. GRINDSTAFF stated a DEA agent had contacted SHAW 'S girlfriend at the Carter County Courthouse and was asking questions about SHAW . GRW DSTAFF stated SHAW had moved a11 of his drugs to his residence until things cooled down. GRIND STAFF stated SHAW m ay not m ake a rtm to pick up m ethamphetam ine this m onth so if CS-8 wanted metham phetamine he/she should come soon. GRINDSTAFF added that SHAW was making approximately $50,000.00 a month from illegal drug transactions.

On M arch 25, 2014 Carter Cotmty, Tennessee Sheriff s Deputy M yles Cook advised that he arrested SHA W and M elvin CAM PBELL on Decem ber 7, 2013 near the intersection of W haley Town Road in Butler, TN. During the arrest SHAW stated to COOK that the tw o story residence located at the intersection of Highway 159 and W haley Town Road was his residence. Cook stated that he had recently arrested Herd for tiling a false police report after she had recanted her prior statements m ade during SHAW 'S arrest on Decem ber 7, 2013. Cook advised during her arrest Herd stated that she and SHAW were arguing over m ethamphetnm ine dtlring the December 7, 2013 incident.

M elvin Glen CAM PBELL

On D ecem ber 22, 2009, a traftic stop was executed on a vehicle operated by Richard SHAW in Anderson County, SC. Pursuant to a search of the vehicle, approximately one (l) pound of metham phetam ine was seized. SHAW and his passenger, M elvin Glen Campbell, were arrested and charged with trafficking metham phetam ine. As a result of the investigation SHAW and CAM PBELL were convicted of Attempt and Conspiracy Provisions Dnzg Law and received a five year suspended sentence and five years probation.

According to the records of Verizon W ireless, telephone number (423) 557-2246 was subscribed to by Robin Ensor at 1 195 Dry Creek Rd., Elizabethton, 'FN. As a result of this

12 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 13 of 106 Pageid#: 16

investigation, your affiant believes that the primary user of the telephone w as M elvin Glen CAM PBELL.

(1n November 2013, 1aw enforcement executed a search warrant on the cellular telephone of a known methamphetam ine distributor in Abingdon, VA. Contained within the Contacts List of this cellular telephone was the name Glen CAM PBELL with telephone number (423) 557- 2246.) On April 23, 20l 3, a seazch warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephone num bers, including those of Danny REECE and Rick SHAW . ln response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accounts from April 9 to April 23, 2013. The following is an excep t from the search warrant results.

April 10, 2013

Danny REECE to Itick SHAW , GGlkxt me when u get upplease need to see ya andl'll bringyr culvertpipe /05' SHAW to REECE, Gi1 'm at Courtney'' REECE to SHAW , inïkhen be in.?'' SHAW to REECE, iil-onight'' REECE to SHAW , 1210-4 text me as soon as you... thanks r/tzn''

REECE to Glen CAM PBELL, Giliey man this is Danny can you text me Big Jims no I don 't àtwé' it in my new phone.'' CAM PBELL to SHAW , GQl-ley call me when ya get up n goin''

REECE to Jam es GRINDSTAFF, iGliey man this is Danny. Is this Big Jims no. ?'' GRIND STAFF to REECE, SIFEJ this is Big Jim't REECE to GRW D STAFF, iillog not home can you /lc/#?'' GRIND STAFF to REECE, LGyeah Iam goodlam getting out in about an hour or so u wtzn/ me to run by'' REECE to GRIND STAFF, ikf 'm up here on the ?7pw bypass wtu headed to Dtownpullin a trailor can u meet me at Doc Talors Vet Of/ic: Iv already turnd rtltfntf' GRW DSTAFF to REECE, LGok give me 10 min what do u ncptf' REECE to GRINDSTAFF, ççcouple'' GRINDSTAFF to REECE, çiok 1 will split the dfference with u it will be 220 be there in afew min t?/c''

CAM PBELL to SHA W , Gçïkrhat time ya thinkya be home/'' SHAW to CAM PBELL, *%5 or &'

Based on m y training and experience, and my knowledge of this investigation, l believe that Dnnny REECE utilized the text messaging service on his cellular telephone to ascertain the location of Rick SHAW in an effort to obtain methamphetam ine. l believe that SHAW advised REECE that he was at his sister Courtney's house, and REECE contacted Glen CAM PBELL to

13 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 14 of 106 Pageid#: 17

get in touch with Jnm es GRINDSTAFF to ptlrchase the m ethamphetam ine. 1 believe that CAM PBELL eontacted SHAW directly to ascertain a tim e for his return.

April 17, 2013 (423) 440-5203 to Rick SHAW , *Q1 know 1 ()w: u money 4 the tires and Im sorry, 1 will pay u soon as 1 can. 1ts not my intention that Glen wtpr/c it off.ok? Its not him who tpwps', only me. Sorry t?/c'' SHAW to (423) 440-5203, i*l'm cool dose he no u tlwc'' (423) 440-5203 to Rick SHAW , CIFCJ, cuz I went to his house that night straight J/cr 1 got the tires 2 share....ofcourse then 1 gotfuknhred n thats where my money cameh'om lol'' SHAW to (423) 440-5203, tûA''' Based on m y training and experience, and my knowledge of this investigation, I believe that the user of telephone number (423) 440-5203 (believed to be Heather Rae Ranck) utilized the text messaging service on her cellular telephone to discuss a drug debt owed to Rick SHAW . I believe that SHAW and Heather Ranck discussed Glen CAM PBELL'S knowledge of the debt and his use of the methamphetamine (tttires'').

April 19 - 20, 2013 Glen CAMPBELL to Rick SHAW, GiGona stop n holler at ya fok? Wont stay long. 1 know ya got companytt CAMPBELL to SHAW, içNever heardfrom ya. Iprob head back home'' CAM PBELL to SHAW , %Guqre ya home? I'fzrtz.ç gona tryya one more time b4 1 went to Eliz. M e n boys got busy schedule next 2 days'' CAM PBELL to SHAW , çiReally could use ya /7c#7. Holler f/'ytz get down this wly'' SHAW to CAM PBELL, %ilhis is Torainna Ricksphone kept going offljust ntpw Iooked

at it sorry ..but tzn-vwtzy.ç seen it wash'om u do ya need me to get Rick up or something', CAM PBELL to SHA W , i*No 1* holles later but thanks'' SHAW to CAM PBELL, i;K lol this is Glen right?''

Based on m y training and experience, and my knowledge of this investigation, l believe that Glen CAM PBELL utilized the text m essaging service on his cellular telephone in an attempt to contact lkick SHAW . 1 believe that CAM PBELL was attem pting to obtain m ethamphetam ine for him self and others with whom he worked. l believe that SHAW 'S girlfriend, Torraina A schenback, responded to CAM PBELL on SHAW 'S phone.

On M arch 25, 2014 Carter County, Tennessee Sheriff s Deputy M yles Cook advised that he arrested SHAW and M elvin CAM PBELL on December 7, 2013. During the arrest SHAW stated to Deputy Cook that the two story residence located at the intersection of Highway 32 1 and W haley Tow'n Road was his residence. Cook stated that he had recently arrested Herd for tiling a false police report after she had recanted her prior statem ents m ade during SHAW 'S arrest on Decem ber 7, 2013. Cook advised during her arrest Herd adm itted that she and SHAW were arguing over methamphetamine during the December 7, 2013 incident.

14 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 15 of 106 Pageid#: 18

Jam es Carl GRINDSTAFF

ln 2005 GRIND STAFF plead guilty to the offense of sim ple possession of schedule 11 substance aher being arrested for drunkenness, sim ple possession of a schedule 11 substance, and illegal possession of a weapon. GRINDSTAFF also have prior an-ests for driving under the

influence 1 St an d 2nd offense and aggravated dom estic assault.

According to the records of TracFone, telephone number (423) 431-8498 was subscribed to by Tim Grindstaff at 1022 Justus Dr., Johnson City, TN with a date of birth of 10/31/1976. According to the records of Thomas Reuters (credit database), James Carl GRINDSTAFF has utilized this address between 2002 and 2013. As a result of this investigation, your affiant believes that the prim ary user of this telephone was James GRINDSTAFF.

According to the records of TracFone, telephone number (423) 483-813 1 was subscribed to by Brenda Gaither at 1022 Justus Dr., Johnson City, TN with a date of birth of 10/31/1976. As a result of this investigation, your affiant believes that the prim ary user of this telephone was Jam es GRINDSTAFF.

(On December 5, 2013, CS-8 positively identified a photograph of James Carl GRINDSTAFF as his/her metham phetam ine source of supply known as iiBig Jim''. CS-8 stated that çtBig Jim 's'' cellular telephone number was (423) 483-8131.) On April 23, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accotmts of several cellular telephone numbers, including those of Danny REECE and Rick SHAW . ln response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accounts from April 9 to April 23, 2013. The following is an excerpt from the search warrant results.

April 10, 2013

Danny REECE to Rick SHAW , iilnext me when u get up please need to see ya and 111 bringyr culvert pipe to'' SHAW to REECE, Qil'm at Courtnef' REECE to SHAW , GGïkhen be in/'' SHAW to REECE, â*l-onightt, REECE to SHAW , 1610-4 text me as soon as you...thanks man''

REECE to Glen CAM PBELL, içbley man this is Danny can you text me Big Jims no 1 don 't have it in my new phone.'' CAM PBELL to REECE, G*liey call me when ya get up n gt?f?7''

REECE to Jam es GRINDSTAFF, iiHey man this is Danny. Is this Big Jims no. ?''

15 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 16 of 106 Pageid#: 19

GRW DSTAFF to REECE, (CJ'C,& this is Big Jim'' REECE to GRINDSTAFF, Gillog not home canyou Jle/#?'' GRINDSTAFF to REECE, G*kkah 1 am good I am getting out in about an hour or so u want me to run by'' REECE to GRINDSTAFF, çnl'm up here on the ncw bypass wtu headed to Dtownpullin a trailor can u meet me at Doc Talors Vet O//icc iv already turnd rtpt/ntf' GRINDSTAFF to REECE, çnokgive me 10 min what do u acctf' REECE to GRINDSTAFF, içcouplet' GRINDSTAFF to REECE, içok 1 will split the dp rence with u it will be 220 be there in afew min tp/c'' Based on m y training and experience, and m y knowledge of this investigation, I believe that Danny REECE utilized the text m essaging service on his cellular telephone to ascertain the location of Rick SHAW in an effort to obtain m etham phetam ine. l believe that SHAW advised REECE that he was at his sister Courtney's house, and REECE contacted James GRINDSTAFF to purchase the m ethamphetamine.

On October 31, 2013, CS-9 was interviewed in Abingdon, VA. CS-9 stated he/she met Rick SHA W tllree to four years ago. CS-9 stated that Jim GRIND STAFF aka Sûllig Jim '', Rusty CASSELL, Danny REECE, and his girlfriend Linda W ALTERS distributed m ethnmphetam ine for SHAW . CS-9 stated he/she had seen GRW DSTAFF with an 8 inch x 4 inch brick of m ethamphetam ine on two separate occasions in the past.

On Decem ber 5, 2013, CS-8 was interviewed in Abingdon, VA. CS-8 stated that he/she had purchased one (1) gram of methamphetamine from lkBig Jim'' on at least five (5) occasions in the last year. CS-8 stated that ûiBig Jim'' took him /her to his m etham phetam ine supplier's residence. CS-8 positively identified Rick SHAW 'S residence of 382 T-Greer Road, M ountain City, Tennessee as the location. CS-8 positively identified a photograph of Jam es GRINDSTAFF as SûBig Jim v'' CS-8 stated that CtBig Jim 's'' cellular telephone number was (423) 483-8131.

On January 17, 2014, CS-8 purchased one (1) gram of crystal methamphetamine from GRINDSTAFF from his residence located at 233 Pedro Shouns Lane M ountain City, TN located in Doe Valley Trailer Park. During the transaction CS-8 stated he/she had trouble finding the m eth so GRW DSTAFF entered the bedroom and pulled out a box containing between 25-50 individual clear baggies containing what appeared to be crystal m ethamphetam ine. CS-8 advised each bag looked just like the bag she purchased and provided to the affiant. CS-8 stated he/she observed two guns on the bed, one of which appeared to be an AK-47 style ritle. There were two gun safes in the bedroom, a tall one that contained rifles and shotguns and a sm aller one that contained handguns. According to CS-8 each safe contained approximately five long guns and five handguns. An assortment of am mo was also observed in the bedroom . CS-8 stated GRINDSTAFF also had a Beretta pistol visible in his back lef4 pocket during the transaction.

16 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 17 of 106 Pageid#: 20

On M arch 7, 2014 the affiant traveled to the Carter County, Termessee Courthouse in an attempt to speak with Haley Herd believed to the ex-girlfriend of Rick SHAW . W hile present in the courtroom the affiant observed Herd sitting behind M elvin CAM PBELL and Rick SHAW (CAM PBELL and SHAW were arrested in Carter County, Tennessee on December 7, 2013 after a domestic incident with Herd). The affiant identified himself to Herd and asked to speak to her about her relationship with SHAW . The fem ale then provided her cell phone and agreed to speak with the affiant on a later date.

On M arch 12, 2014 CS-8 contacted the affiant after attem pting to order l .0 gram s of m ethamphetam ine from GRW DSTAFF at the direction of law enforcem ent. CS-8 stated Jim GRINDSTAFF had contacted him/her about purchasing m etham phetam ine. GRINDSTAFF stated a DEA Agent had contacted SHAW 'S girlfriend at the Carter County Courthouse and was asking questions about SHAW . GRINDSTAFF stated SHAW had moved a11 of his drugs to GRINDSTAFF'S residence until things cooled down. GRINDSTAFF stated SHAW m ay not m ake a nm to pick up m ethamphetam ine this m onth so if CS-8 wanted m ethamphetam ine he/she should come soon. GRINDSTAFF added that SHAW was making approximately $50,000.00 a m onth from illegal drug transactions.

D aniel Shane REECE

Dnnny REECE has two prior felony convictions for possession of a controlled substance.

On September 24, 2007, Daniel Shane REECE was arrested in possession of over four (4) grams of methamphetam ine.

On January 13, 2008, Daniel REECE was arrested in possession of $2,552.00 U.S. Currency and methamphetamine residue.

On M arch 30, 2009, a search warrant was executed at the residence of Christy Denise Adams in M arion, VA. Seized pursuant to the search warrant was over one (1) ounce of m ethamphetam ine, packaged for distribution. Adam s was arrested for possession with the intent to distribute methamphetamine. Seized f'rom Adams' vehicle was over $ 12,000.00 U.S. Currency. The sole occupant of the vehicle at the tim e of seizure was Daniel Shane REECE.

According to the records of Verizon W ireless, telephone number (423) 297-5395 was subscribed to by Dwayne Pruitt at 31529 O1d Stage Rd., Glade Spring, VA. This phone was active from October, 2012 tmtil M arch 17, 2013. As a result of this investigation, your affiant believes that the prim ary user of this phone num ber was Danny REECE, a distributor of crystal m etham phetam ine for Rick SHAW in M ountain City, TN and Dnm ascus, VA. According to the records of Verizon W ireless, telephone number (423) 895-5732 was subscribed to by Dwayne Pruitt at 31529 Old Stage Rd., Glade Spring, VA. This phone was active from M arch 20, 2013 until at least July, 2013. As a result of this investigation, your affiant believes that the prim ary user of this phone number was Dnnny REECE. According to text m essages received via search warrants, a m ale nam ed isDanny'' was the user of both listed telephones. According to the text m essages, çsDnnny'' lived in M otmtain City,

17 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 18 of 106 Pageid#: 21

TN, but spent tim e on property also occupied by Rusty CA SSELL and dated a fem ale nam ed Sslvinda''. Agents w ere aware that Rusty CA SSELL lived on property owned by Danny REECE at 21504 Fisher Hollow Rd., Dam ascus, VA and that Danny REECE and Linda W ALTERS were involved in a romantic relationship.

On April 10, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephone num bers, including that of Roger LAW SON. ln response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in that account from April 1 to April 10, 2013. The following is an excep t from the search warrant results.

April 2, 2013

Toby M OCK to Roger LAW SON, iiDid u ever decide fu wcr: gona go to the mkt/jntoby (.W' LAW SON to M OCK, QiNot sure. J/'f do 111 call ?z.5'

LAW SON to Dnnny REECE, GQGonna be in D Ftpwa today/'' REECE to LAW SON , çGHere now'' LAW SON to REECE, iican I ask how long u will be there/t' REECE to LAW SON, i%4 or 5 hrs but I don 't katlw fthparts will last that long/'' LAW SON to REECE, içcan u hang on to at least 3. 111 be there shortly'' REECE to LAW SON , SsT'ry my best'' LAW SON to REECE, *LOk.''

LAW SON to M OCK, çnGetting ready to go to the market. Be ur wJy unless u can meet me in Glade.t'

LAW SON to REECE, iisave me at least 3.'%

Based on m y training and experience, and my knowledge of this investigation, I believe that Roger LAW SON utilized the text messaging service on his cellular telephone to obtain metham phetamine from Danny REECE for resale to Toby M OCK.

April 5, 2013

Toby M OCK to Roger LAW SON , iLïk-en u goin to the mkt? Eddie here and wanted to sendfor somepaintintobyO 't LAW SON to M OCK, Q%can go anytime but wait couple ofhrs. Callyal.'' M OCK to LAW SON , *i1 got somebody else bringing me sum $ over to I ned to send with yaàntobyk '

Danny REECE to LAW SON , GiETA/'' LAW SON to REECE, iils 11:30 to late/'' REECE to LAW SON, iiBe (7/c'' LAW SON to REECE, çilhanks''

18 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 19 of 106 Pageid#: 22

M OCK to LAW SON , çiWherya at/àntoby @ ' LAW SON to M OCK, iuust kiddin on our wtzy.'' MOCK to LAW SON, Giokey dokey...yal b carefuljntoby @' LA W SON to M OCK, ççft'''

M OCK to LA W SON, %iR yal close? qntoby f7' LAW SON to M OCK, CtF:.C at Bub '.ç''

M OCK to LAW SON, iiHave yal /c.# Bub 's yetjntoby tkp' LAW SON to M OCK, *iI 'm down at Kenny 's. Bub 's got t/r5'.''

Based on my training and experience, and m y knowledge of this investigation, I believe that Roger LAW SON utilized the text messaging service on his cellular telephone to obtain metham phetam ine from Danny REECE. l believe LAW SON in turn sold the m etham phetam ine to Toby M OCK after stopping at Bubba BUCHANAN 'S and Kenny Forrester's residences.

On April 1 1, 2013 M gela SURBER was interviewed in Bristol, Virginia. SURBER stated she smoked metham phetam ine with Roger LAW SON at his house when he lived in Glade Spring, Virginia. LAW SON also gave m ethamphetam ine to SURBER to deliver to his daughter. SURBER stated around 2009-2010 she m oved in with Danny REECE. SURBER advised after living with REECE for two m onths, REECE asked if SURBER would give him a ride to M ountain City, TN to obtain meth from Rick SHAW . SURBER stated she and REECE went to SHAW 'S to purchase meth approximately once a week for eight w eeks. SURBER stated REECE obtained a Sktistful'' size of m eth each tim e from SHAW . SURBER advised m ost of the deals with SHAW occurred at this house but one deal occurred at a property SHAW owned in Butler, TN .

On April 23, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accotmts of several cellular telephone num bers, including those of Danny REECE and Rick SHAW . In response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accounts from April 9 to April 23, 20 13. The following is an excerpt from the search warrant results.

April 10, 2013

Danny REECE to Rick SHA W , iilkxt me when u get upplease need to see ya andl 'll bringyr culvertpipe to'' SHAW to REECE, QL1 'm at Courtney', REECE to SHAW , çâïk-hen be in/'' SHAW to REECE, iiTonight'' REECE to SHAW , 1610-4 text me as soon as you... thanks ?A)la'' REECE to Christy Adams, çiWhtz upfeel like meetin me in Fisher Hollor in couple hrs. ?'' REECE to Johnny Osborne, incan u spare any cofpp?'' Osborne to REECE, iillon 't have lzl7b/lnzky''

19 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 20 of 106 Pageid#: 23

REECE to Osborne, iiliate to bother u again but do have elains no she gave it to me but L inda must have erased it or Big Jims no''

REECE to Glen CAM PBELL, iiHey man this is Danny can you text me Big Jims no 1 don 't have it in my ncw phone.t, CAM PBELL to REECE, GGl-ley call me when ya get up n gtpfn''

REECE to Jam es GRINDSTAFF, Q*l-ley man this is Danny. Is this Big Jims no. ?'' GRINDSTAFF to REECE, CtFCJ this is Big Jim'' REECE to GRIND STAFF, i%ltog not home can you help/t' GRINDSTAFF to REECE, iik-eah 1 am good 1 am getting out in about an hour or so u want me to run by'' REECE to GRW DSTAFF, i*1 'm up here on the ncw bypass wtzs' headed to Dtownpullin a trailor can u meet me at Doc Talors Vet O//cc iv already turnd rounl' GRINDSTAFF to REECE, ç*Ok give me 10 min what do u ncetf' REECE to GRIND STAFF, incouple'' GRINDSTAFF to REECE, ;(Ok 1 will split the dfference with u it will be 220 be there in afew min ta/c'' LAW SON to REECE, ç*vjre u gonna be in D lbwn today '' REECE to LAW SON, çilfl can get some tires I will be. 111 letyou no asap'' LAW SON to REECE, iiok //2J?7/o'''

REECE to Adam s, 6iI 'd sure like to try that Folgers :rJn#/'' Admns to REECE, içï'vhat.l'' Adams to REECE, Gil'm @ work'' REECE to Adam s, iGD amm till when/'' Admns to REECE, ç*probably wonf be offtill 12.30'% REECE to Adams, 1*10-4 1 'll hollor back f/7 canfnd aph charger its bout Jc1tf' Adams to REECE, $;0/6'7

LAW SON to REECE, GGlts Roger myph is screwfup. Did u try to text me? New no. 276 206 3398'' REECE to LAW SON, ioNo still haven 't heard nothin'' LAW SON to REECE, ççvb'o ur not Iikely to be over too soon. Just Iet me krtpw'' REECE to LAW SON, içWell im over here but no partf' LAW SON to REECE, Giok thanks.''

SHAW to REECE, **1 'm home'' REECE to SHAW , $*10-4 leavin Dlhwn atpw'' REECE to kdBubba'' BU CHAN AN, inD idyou an Rodger want to come tonight/''

Based on my training and experience, and m y knowledge of this investigation, 1 believe that Danny REECE utilized the text m essaging service on his cellular telephone to comm unicate with Rick SHAW , Christy Adam s, Jolmny Osborne, Glen CAM PBELL, and James GRINDSTAFF in an effort to obtain m ethamphetam ine. 1 believe that REECE communicated

20 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 21 of 106 Pageid#: 24

with Roger LA W SON who wanted to purchase m ethamphetam ine. 1 believe that REECE eventually purchased methamphetamine from SHAW and sold to LAW SON and Bubba BUCHANAN .

April 11, 2013

Roger LAW SON to Danny REECE, Lilhis is my new no. 276 206 6462 r u gonna in D Ftpwn today/'' REECE to LAW SON, nckkah in a couple hrs'' LA W SON to REECE, iGok thanks''

LAW SON to REECE, çQzqre u in Damascus? Atpgcr'' REECE to LAW SON, 1110-4 ETA.?'' LAW SON to REECE, çiHow long have 1 got to get there/t' REECE to LAW SON, içprob be late late before 1 leave't LAW SON to REECE, Qiok be there about /lr.'' REECE to LAW SON, *il0-4,'

April 11 - 12, 2013

Bubba BUCHANAN to REECE, iiliey r u up tex r call me Lcraig N stef' REECE to BUCHANAN, CiETAB'' BUCHANAN to REECE, Gi3o/Ncraig N stef' REECE to BUCHANAN , **10-4,'

BUCHAN AN to REECE, ènupstairejNcraig N & c./'' REECE to BUCHAN AN , i610/5,t REECE to Christy Adams, iiTalkin to Bub hejus got here 111 text whn he gone''

Based on m y training and experience, and my knowledge of this investigation, I believe that Dnnny REECE utilized the text messaging service on his cellular telephone to sell m ethamphetam ine to Roger LAW SON and Bubba BUCHANAN.

April 14 - 15, 2013

Bubba BUCHANAN to Danny REECE, ç*U n D r M tn CàKenny N stef, REECE to BUCHAN AN , iiout haven 't seen him yett' BUCHANAN to REECE, Lilkx when u do pleez bKenny Nstef' REECE to Rick SHAW , ç*1 gotta haul this parts truck to Stony Creek an 1 'll be up fyr around?''

REECE to SHAW , iion wtz-p nrlw to yr house'' SHAW to REECE, i$f 'm in Boone back soon'' REECE to SHAW , LiI 'lI have to go tpn'' SHAW to REECE, **Ok c u later text when u get #tzck''

REECE to BUCHANAN , iGl0-4 good to goo''

21 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 22 of 106 Pageid#: 25

Roger LAW SON to REECE, çnls it ok to stop by. Im in cïry'' REECE to LAW SON, GGl0-4''

Based on m y training and experience, and m y knowledge of this investigation, 1 believe that Danny REECE utilized the text m essaging service on his cellular telephone to obtain metham phetam ine from Rick SHAW . 1 believe that REECE sold the methamphetamine to Roger LAW SON and Bubba BUCHANAN.

April 16, 2013

Roger LAW SON to Danny REECE, ûi# u in D lnown today/'' REECE to LAW SON, GQWhile it lastl Yeah DTown'' LAW SON to REECE, iGuqre you still there fso I 'll b there in 20 mins'' REECE to LAW SON, iilreahb' LAW SON to REECE, iiok''

LAW SON to REECE, %iR u still there? I need 1 more tirefor my trailer'' Based on my training and experience, and my knowledge of this investigation, l believe that Roger LA W SON utilized the text m essaging service on his cellular telephone to purchase metham phetam ine from Danny REECE on two separate occasions on the snme date.

April 17, 2013

Rick SHA W to Danny REECE, inlieaded home'' REECE to SHAW , içon wJy do u need nethingfrom town/'' SHAW to REECE, QiDrink''

Roger LAW SON to REECE, çëvjre u n D Ftpwn tonight'' REECE to LAW SON, iûcj/y'' REECE to LAW SON, içGotparts''

Based on my training and experience, and m y knowledge of this investigation, 1 believe that Danny REECE utilized the text m essaging service on his cellular telephone to obtain m ethamphetam ine from Rick SHAW and sell it to Roger LAW SON .

April 19, 2013

Rick REECE to Danny SHAW , LGWillyou be around tonight/'t SHAW to REECE, CQNO sorry''

Bubba BUCHANAN to REECE, iiEver hear n e thing X enny N Stef' REECE to BUCHANAN , ççl'le went to the Rodrun nothing'' BUCHANAN to REECE, Ck. . .l0-4$NKenny N stef,

22 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 23 of 106 Pageid#: 26

April 20 - 21, 2013

REECE to SHAW , iGliave you got any ideal what time you will be /lo-e?'' (423) 707-5321 to REECE, inlfand whenpossible can you double my regparts order //7/c-&'' REECE to (423) 707-532 l , *iDude is gone to Rodrun?/'' (423) 707-5321 to REECE, iisheeeotl'' (423) 534-7673 to REECE, tûU'z@'' REECE to (423) 534-7673, GGltude is gone to the Rod Run.Don 't know when he will be home'' BUCHANAN to REECE, LiNow wvî//: up WKenny N Stef, REECE to BUCHANAN , GQNothin he still aint /lo?>le?'' BUCHANAN to REECE, inlkx me when NKenny N stef'

LA W SON to REECE, çGvlre u gonna be in D lhwn today.J'' REECE to LAW SON , içFwd. D ude is gone to the Rod Run don 't no when he will be home.J'' LAW SON to REECE, çiAll 1 need is a 50 lb. bag ofdogfool, REECE to SHAW , içl-lave you got any ideal what time you will be home/'' BUCHANAN to REECE, çiWhat 's the word WKenny N stef' REECE to BUCHANAN, iiNothin/'t

SHAW to BU CHANAN, i%30min,t REECE to SHAW, GiTeeenfourrrr on wayj'om Dl-own'' REECE to BUCHANAN , iiHow much cash u got on hand/'' BUCHANAN to REECE, *2160 XKenny Nstef, REECE to BUCHANAN, içblow quik can u get to river bridge/'' BUCHANAN to REECE, *120 n route ntpw XKenny N stef' LAWSON to REECE, %iOk fl come over nt?w?'' REECE to LAW SON, nnjmeahfor a lilt' LA W SON to REECE, Gnok Im Ieavin Saltville nöw.'' LAW SON to REECE, çiBe there in 20 mins'' REECE to LA W SON, ';7p-#''

Based on m y training and experience, and m y knowledge of this investigation, I believe that Danny REECE utilized the text m essaging service on his cellular telephone to obtain m ethamphetam ine from Rick SHAW and sell it to Roger LAW SON and Bubba BUCHANAN.

23 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 24 of 106 Pageid#: 27

On M ay 8, 20l 3, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephone numbers, including those of Danny REECE, Rick SHAW and Roger LAW SON . ln response to the execution of this search w arrant on Verizon W ireless, agents received text m essages stored in those accounts from April 26 to M ay 8, 2013. The following is an excerpt from the search warrant results.

M ay 1, 2013

Toby M OCK to Roger LAW SON, GiHave u heard anything?jntoby @ ' LA W SON to M OCK, GnNotyet'' M OCK to LAW SON , çx bntoby (.W'

LAW SON to Dalm y REECE, çGu gonna be in D F/wn today/'' REECE to LAW SON, içlétn c@ '' LAW SON to REECE, iiok thanks.t' LAW SON to REECE, iiok to stop by later/'' REECE to LAW SON, iç10-4,' LAW SON to REECE, çiOk''

Based on my training and experience, and m y knowledge of this investigation, I believe that Roger LAW SON utilized the text messaging service on his cellular telephone to obtain metham phetamine from Darmy REECE and sell it to Toby M OCK .

On August 21, 20l 3, the affiant, while conducting surveillance of the REECE residence, observed REECE exit his residence and walk towards a GM C Yukon bearing Tennessee Registration E70 31F. A Departm ent M otor Vehicles query reveals Term essee Registration E70 31F to be registered to Daniel S. REECE of 1025 W est M ain Street, M ountain City, TN on a 1996 GM C Yukon. On September 19, 2013 the affiant installed a GPS tracking device on the subject vehicle pttrsuant to a federal search warrant obtained through the Eastem District of Tennessee which authorized the installation of a GPS monitoring device on the subject vehicle for a period of 45 days.

Between Septem ber and Decem ber 2013, surveillance was conducted on the vehicle utilized by Danny REECE (white GM C Ytlkon, TN Registration E70 31F). REECE'S vehicle frequented the residence of Rick SHAW (382 T Greer Rd., Mountain City, TN) approximately every two (2) to three (3) days during this time period, thirty-one (31) times total in two months.

Linda Louise W A LTER S, aka L inda SLEM P

Linda W alters has prior arrests for assault, worthless checks, thet-t of property over $500.00, leaving the scene of an accident, and driving under the influence of alcohol.

24 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 25 of 106 Pageid#: 28

On April 1 1, 2013, Angela SURBER w as interviewed in Bristol, Virginia. SURBER stated that she had sold methamphetamine over the years for Danny REECE and others. SURBER stated that REECE'S current girlfriend was Linda LNU (last name unknown) in M ountain City, TN.

According to the records of Verizon W ireless, telephone number (423) 218-7469 was subscribed to by N ancy Slemp at 1444 Crossroads Dr., M ountain City, TN. According to the following text messages, a fem ale nam ed dslvinda'' was the user of this telephone. According to the records of Thomas Reuters (credit database), Linda W ALTERS also resided at 1444 Crossroads Dr., M otmtain City, TN , Apt. F-2. Based on the results of this investigation, agents believe that this phone was utilized by Linda W ALTERS, the girlfriend and partner of Danny REECE in the distribution of methamphetamine.

On M arch 22, 2013, a search wanunt was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephones, including that utilized by Roger LAW SON . ln response to the execution of this search wanunt on Verizon W ireless, agents received text m essages stored in those accounts from February 23 to M arch 22, 2013. The following is an excerpt from the search warrant results.

February 25, 2013 Toby MOCK to Roger LAW SON, Gilt-you go meet Rachael will u holla at me Eddie wnet somewhere an he may not make it bak n time to go meet herjnlhby'' LAW SON to M OCK, *i1 'vc not heardh'om her.'' M OCK to LAW SON, iiL indajus text me bak and she good ànToby'' M OCK to LAW SON, Cirzr: can holla at L inda (/'N want toànlhby'' MOCK to LAW SON, iiHow many ofthose rugs did u ned an I can text herbnToby'' LAW SON to M OCK, iibley is L inda gonna be there this evening/'' M OCK to LAW SON, içI 'm not sure I haven 't talkd to her anymore since earlier she probably will lrekonjnlbby' MOCK to LAW SON, *i1 think she is ready ntpw fu were wantin to yell at herjnToby'' LAW SON to Danny REECE, içWill it be ok to stop by @ 6 or 7.?,' REECE to LAW SON, *il0-4 that 'lI 1?:/nc'' LAW SON to REECE, Gion tha wtzy, that t?/c3'' REECE to LA W SON, L*l0-4''

M OCK to LAW SON, iicall L inda an she saidshe could tellya wher to come /t?lz7F(?:y.',)'' LAW SON to M OCK, Giliejust text me.'' M OCK to LAW SON, içokbnlhby .')''

M arch 1, 2013

25 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 26 of 106 Pageid#: 29

LAW SON to Linda W ALTERS, inDo u knt?w where Danny is? Jfnof, can u help me? WO#Cr'' W ALTERS to LAW SON , Gil'le 'w in th bedl believe. A1l 1 hav is one xtra'' W ALTERS to LAW SON , ç*No my apt r u n mc'' W ALTERS to LAW SON , iiK Food Lion'' LAW SON to W ALTERS, CSFeJ Foodlion ok be right fàcrc'' LAW SON to Danny REECE, ioBe there shortly''

Based on my training and experience, and m y knowledge of this investigation, 1 believe that Roger LA W SON utilized the text m essaging senice on his cellular telephone to comm unicate with Linda W ALTERS in an effort to obtain m ethamphetam ine. l believe that LAW SON and W ALTERS agreed to meet at the Food Lion to consumm ate the transaction, then LAW SON notified Dalmy REECE to 1et him know.

M arch 11 - 20, 2013 Danny REECE to Roger LAW SON, içTe1l her these are .5s. They gofor 2'' LAW SON to REECE, iGok. r'lrc 'll take care ofli'' LAW SON to Linda W ALTERS, iiliave u seen Danny/''

LAW SON to REECE, LGzlre u in D ftpwn.'' LAW SON to REECE, Gâlley man are u in D fown?'' LAW SON to REECE, Qivjre u at home? Need to c z/.''

LAW SON to W ALTERS, ççcan u call me/'t W ALTERS to LAW SON, Qçlfyou need tell me ntaw cause 1 am tlking to him right nt?w an 1 will getfor you too'' LAW SON to W ALTERS, iç1 need at least 1. Is it ok (/'f give TG urph. No. ?'' WALTERS to LAW SON, içK 1 canpick one upforyou. FcJ thtshne'' LA W SON to W ALTERS, içvjrc yal comin to D town or u already there.?'' W ALTERS to LAW SON, **No 1 am not but Dannyprobably will shortly do you want me to tell him so you canjst meet up with him ovr there/'' LAW SON to W ALTERS, içYespleaset' W ALTERS to LAW SON , Qil'le ne dwn there in bout 2 hours. A''' LAWSON to WALTERS, â*1 will need @ 3 I/'/le can bring them. L et me kntpw.'' W ALTERS to LAW SON, iil-l'e should b ther netime (fyt?z/ hurry an grab him b4 nebdy else gets ther lol''

Based on my training and experience, and m y knowledge of this investigation, l believe that Roger LAW SON utilized the text messaging service on his cellular telephone to com municate with Danny REECE about selling % grams of metham phetam ine for $100.00. I believe that REECE stopped using that particular cellular telephone, so LAW SON had to arrange a m etham phetam ine transadion thzough Linda W ALTERS. 1 believe that LAW SON ordered tlzree (3) grams of methamphetamine and arranged to pick it up from REECE in Dnmascus, VA (referred to as $iD Town'').

26 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 27 of 106 Pageid#: 30

On April 10, 2013, a search warrant was applied for and obtained in the W estern District

of Virginia for text messages stored in the accounts of several cellular telephone numbers, including those of Danny REECE and Linda W ALTERS. In response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accounts from M arch 18 to M arch 27, 2013. The following is an excerpt from the search warrant results.

M arch 20, 2013

Linda W A LTERS to Rick SHAW , GGliey is Danny still there/'' SHAW to W ALTERS, tûFc5''' W ALTERS to SHAW , iiWillyouplz hav him to call me b4 he heads back thisaway?t, SHAW to W ALTERS, Cil'c,ç 1 will how r u doing'b

Danny REECE to W ALTERS, 124238955732', REECE to WALTERS, ûkAèw no 1 love you come see me fu wln/. 1 'm bout out Ifyou could run by hollor l will call an get th t?#.?''

Based on my training and experience, and my know ledge of this investigation, I believe that Linda W ALTERS utilized the text m essaging service on her cellular telephone to comm unicate with Rick SHAW about the whereabouts of Danny REECE. l believe that REECE obtained a new phone number and shared it with W ALTERS. 1 believe that REECE ran out of methamphetamine and asked W ALTERS to go to Rick SHAW 'S residence (ishollor'') and pick up some m ore.

M arch 21, 2013 Linda WALTERS to Danny REECE, GGNeed l whole an l J?JI/'' REECE to W ALTERS, âLcome Jlcrc'' W ALTERS to REECE, iione an qtr all in one #Jg'' W ALTERS to REECE, ($.. .hav u tlked to #ïc/c'' W ALTERS to REECE, Lill'e saidhe would he% me out especially (J'f wJl sick an I i'zlt? Joe is lookinfor him ljst thot u might hav tlked to him a could maybe grab a couple b4'' REECE to W ALTERS, **No notyet't

REECE to Rick SHAW , :(?'' SHAW to REECE, Ckf im home ?zilp''

REECE to W ALTERS, içGota run up th road. Be rt /7/c''

Based on my training and experience, and m y knowledge of this investigation, I believe that Linda W ALTERS utilized the text messaging service on her cellular telephone to order one whole ounce and one % ounce of m ethamphetam ine for her custom ers. I believe that W ALTERS asked REECE to m ake contact with Rick SHAW to obtain additional methamphetam ine. l believe that REECE contacted SHAW then told W ALTERS that he was going to pick up.

2 7 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 28 of 106 Pageid#: 31

M arch 27, 2013

Linda W ALTERS to Dalmy REECE, iollid u work at Ricks today'' REECE to W ALTERS, iiI got a couple hrs fz7'' WALTERS to REECE, iiWht did u do th rest fth /f?nc'' REECE to W ALTERS, ççWait on him to go to the garage'' WALTERS to REECE, iivqn you didn 't hav enuffmoney to buy me somthin to eat today butyou had enuffto get grn?.!'' REECE to W ALTERS, Lntmuck this goddam shityou supplyh'om now t?n.'' W ALTERS to REECE, Qiuqndyou are rightfuck this dumb shitjust because you enjoy living /44 waiting on th r?x/ deal I don 't andl cannot handle lies an bullshitt' REECE to WALTERS, iGWhat gd lies im expecting a texth'om Rodger and I cant get a fuckin thg done while thph keeps. . .'' REECE to W ALTERS, *iI need that 60 before I go to wör/c in th am'' W ALTERS to REECE, *GHa1 Perfect example ... u said u gave him to 1:00', REECE to W ALTERS, **Well Buba askfor more time and fyr not callin me a lier then tell me qwil wbatyr sayin', W ALTERS to REECE, tW tpw its Buba''

Based on m y training and experience, and my knowledge of this investigation, l believe that Linda W ALTERS utilized the text messaging service on her cellular telephone to ascertain if Darmy REECE went to see Rick SHAW . I believe that REECE was fed up with W ALTERS and told her to be the metham phetam ine supplier to their customers from now on. I believe that REECE m entioned two of their custom ers, Roger LAW SON and Bubba BUCHANAN .

Russell W ayne CASSELL, aka ddRustyM CA SSELL

Rusty Cassell has a prior conviction for the m anufacture, sale, possession of a controlled substance.

On January 30, 2013 CS-4 was interviewed in Bristol, Virginia. CS-4 stated from 2004- 2006 Rusty CASSELL was selling methnmphetnmine at a garage in Glade Spring, Virginia. Through interview s and surveillance CASSELL'S personal residence was identified as 21504 Fisher Hollow Road, Dam ascus, Virginia.

CS-4 stated in the fall/winter of 201 1 he/she and Jason M ULLINAX were getting approximately four (4) ounces of meth per week from CASSELL. CS-4 stated this continued for approximately tive to six m onths. CS-4 stated he/she was at CASSELL'S every day for five months. CS-4 stated the m ost m eth he/she had ever seen at one tim e at CA SSELL'S residence was a one gallon zip lock baggy full of meth Ciice''. CS-4 added the m eth was not individually wrapped. CS-4 stated he/she saw hand to hand deals while present at CASSELL'S residence.

CS-4 stated he/she always paid CA SSELL in cash and had seen approxim ately $7,000.00 in his wallet on one occasion. CS-4 stated he/she paid CASSELL $200.00 for an eight ball (3.5

28 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 29 of 106 Pageid#: 32

gms) of meth. He/she stated most other people paid $350.00. CS-4 stated in February 2012

he/she was present at CA SSELL'S when GERACE brought m eth to CASSELL. CS-4 stated he j saw GERACE hand CASSELL a quantity of meth. According to CS-4, CASSELL was providing approximately one (l) ounce of meth per week to Bubba BUCHANAN for approxim ately five to six m onths.

Between February 4, 2013 and February 7, 2013 CS-4 m et with Timothy GERACE. W ords to the effect of the following were stated:

GERACE said he has not talked to Rusty (CASSELL) lately because he owes him over $1000 so CASSELL is dodging him. CASSELL is getting his meth from Devanna (BOARDW INE). GERACE said he thinks he can get away with not paying him. GERACE said he gave CA SSELL the chance to make the money back hundreds of tim es and he could not do that.

According to the records of Verizon W ireless, telephone number (276) 698-4109 was subscribed to by Cardinal Travel Center, Nick Lam bert, P.O. Box 340, Glade Spring, VA . According to text m essages obtained via search warrant, the user of this telephone was a male named idRusty'' who had property in comm on with Danny REECE. According to the W ashington County Sheriff s Office database, Russell ttRusty'' CASSELL resided in a second hom e located on the property of Danny REECE at 21504 Fisher Hollow Rd., Dam ascus, VA . A s a result of this investigation, your aftiant believes that the prim ary user of this phone number was Russell CdRusty'' CASSELL.

On Septem ber 19, 2013 SCSO lnvestigator Prater and W CSO Detective Hazelwood were present at the Petro Truck Stop in Glade Spring, Virginia when, at their direction, ATF SA Duke called CASSELL'S aforem entioned cell phone number. Inv. Prater and Det. Hazelwood observed CASSELL answer the phone call and then put the phone back in his pocket once SA Duke ended 1 the call. On April 10, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephone num bers, including those of Danny REECE and Linda W ALTERS. ln response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accotmts from M arch 18 to M arch 27, 2013. The following is an excerpt from the search warrant results.

M arch 21, 2013

Danny REECE to Rick SHAW , iilnhis is Danny rlew no. Are you at homefor Jx wp'' SHAW to REECE, *GNo b back 4 or J''

REECE to SHAW , **10-4 throw me a text w//E'a on wtz-r thanks man'' REECE to SHAW , çiNeed l whole an l /7fz#'' REECE to Rusty CASSELL, çil-le aint home yet'' CASSELL to REECE, çèWhere is he J/?''

29 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 30 of 106 Pageid#: 33

REECE to CASSELL, çilie said he would call when he got in bout J or 6probt' CA SSELL to REECE, %6He1l. Ok''

REECE to SHAW , t'?'' SHAW to REECE, iil'm home mant'

REECE to CASSELL, GnGot help but not ctpznï yr wly till morn.'t

M arch 23, 2013

REECE to SHAW , ktlbrf be home in bout an hour'' SHAW to REECE, inl'm home an 1 will b here... '' REECE to SHAW , ççl'm on my wayh'om D town zmw'' REECE to CASSELL, QLl-l'ey 1 can get rid of4 but theyjust got $110.00 apeace instead of 120.00 can ya do j/?'' CASSELL to REECE, iisorry man but im in th hole again cant do it'' REECE to CASSELL, Gnok told them 1 would ask u no Afgp/ brother'' REECE to CASSELL, LCETA J5''

Based on m y training and experience, and m y knowledge of this investigation, 1 believe that Dalm y REECE utilized the text m essaging service on his cellular telephone to comm unicate with Rick SHAW and Rusty CASSELL concerning the distribution of methnmphetamine. l believe that REECE asked CASSELL if he could afford to 1et the grams of metham phetam ine sell for $1 10.00 instead of $120.00 per gram (the current price for one gram of crystal methamphetamine).

On April 23, 2013, a search warrant was applied for and obtained in the W estern District of V irginia for text m essages stored in the accounts of several cellular telephone num bers, including those of Danny REECE, Rick SHAW and Rusty CASSELL. ln response to the execution of this search wan'ant on Verizon W ireless, agents received text m essages stored in those accounts from April 9 to April 23, 2013. The following is an excerpt from the search wanunt results.

April 14, 2013

Rusty CASSELL to Danny REECE, nuust making sure it wl.& u up there'' CASSELL to REECE, i*zqny help'' REECE to CA SSELL, iûa4 Iil I wtzs' gettin ready to leave do you wlnf me to come by/'' CA SSELL to REECE, inlhe ol man Tom needs some help wls' w:y I wJ: asking. l'bz/ can have my big screen f/'zf want it also.'' REECE to CA SSELL, GD on 't need it. Can you cover him cause 1 need to gtp.?'' CA SSELL to REECE, $*1 can 't brother. He b tp/c'' REECE to CASSELL, iiR u out/'' CASSELL to REECE, i*llellya. 1 b ok brother. TTYL '' REECE to CA SSELL, ç*Do you want me to com e down/''

30 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 31 of 106 Pageid#: 34

CASSELL to REECE, GGhrot fu need to go man. Unless ujust want to... tu(.P' IIEECE to CASSELL, **1 b there in 2 rzl//7''

Based on my training and experience, and my knowledge of this investigation, l believe that Rusty CASSELL utilized the text messaging service on his cellular telephone to comm unicate with Danny REECE. l believe that CASSELL asked REECE if he had any methamphetamine (1the1p'') because CASSELL had run out and was trying to provide it to Ciol m an Tom ''

April 15, 2013

Rusty CASSELL to Danny REECE, çiU coming over'' REECE to CASSELL, iilm am overl'' CASSELL to REECE, **U is here', REECE to CA SSELL, d$f is Jz'r'' CA SSELL to REECE, iils it break time'' REECE to CA SSELL, Gs ends on what u bring me to cJ/''

CASSELL to (772) 225-2484, çGliey olpal u still needing', CASSELL to (772) 225-2484, inl-lello'' CASSELL to (772) 225-2484, iiugoing to miss out olpaI...'' Based on m y training and experience, and m y knowledge of this investigation, 1 believe that Rusty CASSELL utilized the text messaging service on his cellular telephone to comm unicate with Danny REECE for the purpose of obtaining m ethamphetamine. 1 believe that after CASSELL obtained the methamphetamine from REECE, CASSELL attem pted to contact one of his drug custom ers.

April 17, 2013

Frankie M adrie to CASSELL, i%bley brother can u help me out tonightpossibly on break @ 9..302 111 make it well worth your while...lhankv manll'' CASSELL to M adrie, i*Not unless my buddie comes by brother. 1 been sick man. Guess that bug goin around...''

Based on m y training and experience, and m y knowledge of this investigation, 1 believe that Rusty CASSELL utilized the text m essaging service on his cellular telephone to comm unicate with Frankie M adrie. 1 believe that M adrie attempted to obtain m ethamphetam ine from CASSELL on his break from work. As a result of this investigation, agents have learned that Frankie M adrie was involved in the m anufacturing of metham phetamine with co-conspirator Brady LESTER.

April 19, 2013

Rusty CA SSELL to Danny REECE, içU up', REECE to CA SSELL, ii-lus wo/ce up''

31 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 32 of 106 Pageid#: 35

CASSELL to REECE, GiBub up there', CASSELL to REECE, Guust pulled z7'' CASSELL to REECE, **No whos comin in/', CASSELL to REECE, iGBubba went up hill't

Based on my training and expericnce, and m y knowledge of this investigation, I believe that Rusty CASSELL utilized the text messaging service on his cellular telephone to eomm unicate with Danny REECE regarding the arrival of Bubba BUCHANAN . 1 know that CA SSELL resides on a m ulti-home property owned by REECE in Dam ascus, VA, and believe that CA SSELL acts as a lookout for REECE when REECE is there.

April 21, 2013

Danny REECE to Rick SHAW , iil-lave you got any ideal what time you will be home/'' SHAW to REECE, çG3ominb' REECE to SHAW , Qilkeenfourrrr on wayj-om D/bwa'' REECE to Bubba BUCHANAN , iiHow much cash u got on J2Jn#?'' BUCHANAN to REECE, 21160 WKenny N Stef,

REECE to Rusty CASSELL, **He is home. U got any cash to go on/'' CASSELL to REECE, iildon 't brothert,

Based on m y training and experience, and m y knowledge of this investigation, 1 believe that Danny REECE utilized the text m essaging service on his cellular telephone to comm unicate with Bubba BUCHANAN and Rusty CASSELL regarding the purchase of m ethamphetam ine from Rick SHA W .

April 22, 2013

Frankie Madrie to Rusty CASSELL, Gâll'ey ole buddy hope u have gotten rid oftht bugya had last time i talked zujust thought id chek and c fi could come cu mayb bring u sum cash on break n bout 15min i dnt care Ifits afew days or so b4 u can get me tht v6for my old beater ,' can wait (/'z/ dnt mind 2/7:17 me out k thanks ?/kJn'' CASSELL to M adrie, CSFJ itprob b tomorrow b4 i couldget it. You can leave it n the ash tray ofmy suzuki f/'1/ want to. '' M adrie to CASSELL, $*K sounds good illput it out there shortly then. What would a 3.5 runfor my car?'' CA SSELL to M adrie, 1*420,'

Madrie to CASSELL, çilput 240 out there couldn'tjlnd ast tray so iput between seats n cupolder. Thanks van''

32 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 33 of 106 Pageid#: 36

CA SSELL to M adrie, CCA'''

Based on m y training and experience, and m y ltnowledge of this investigation, I believe that Rusty CASSELL utilized the text m essaging service on his cellular telephone to com municate with Frankie M adrie. 1 believe that M adrie utilized code to inquire about the price of an 1/8 ounce of methamphetamine (3.5 grams), to which CASSELL responded $420.00. 1 believe that M adrie could not afford the 3.5 gram s, so instead lef4 $240.00 for CASSELL to obtain 2 grams of methamphetamine. (Based on my involvement in this case and others, l know that the çtstreet value'' of one gram of crystal methamphetamine is $120.00).

On Septem ber 2, 2013 Stephanie PATRICK was arrested with Craig l'Bubba'' BUCHANAN in Johnson County, TN for drug related offense after being found in possession of approxim ately 1 1.4 grams of methamphetamine. Following her arrest PATRICK stated to Johnson County, TN Sheriff s Investigators that she picked the m ethamphetamine up from someone in Virginia earlier and had already sold an eight-ball (3.5 gms) earlier in the evening. PATRICK stated she and BUCHANAN were ttfronted'' the m etham phetam ine and were attem pting to sell it. PATRICK stated she and BUCHANAN went to Cçlkusty' s'Youse. Based on the affiant's participation in the investigation it's believed that çtlkusty'' is Russell CA SSELL. W hile at k'Rusty's'' FBUCHANAN and PATRICK weighed out an' eight-ball (3.5 gms) of meth and sold it to 'kRusty''. PATRICK stated Stlkusty'' paid her $ 154.00 for the meth.

Kenneth Craig BUCHANAN, aka ddBubba'' BUCHANAN

Craig Buchanan has a prior conviction for the m anufacture, sale, possession of a controlled substance.

On April 3, 2013, CS-4 was interviewed in Bristol, Virginia. CS-4 stated that in late winter 2009 until April 2010 he/she m ade and sold 3.5 grams of methamphetam ine per week to Bubba BUCHANN AN for $350.00.

CS-4 stated that from Septem ber to Novem ber 2012, he/she observed Tim othy GERACE meet with Bubba BUCHANNAN at his garage in Glade Springs, Virginia and get an 8-bal1 (3.5 grams) of methnmphetamine no less than seven times.

On April 1 1, 2013 Angela SURBER was interviewed in Bdstol, Virginia. SURBER stated that she had used m ethamphetam ine with Bubba BUCHANAN and Stephanie PATRICK. According to SURBER, she, PATRICK and BUCHANAN traded m etham phetam ine with each other when one another would run out.

According to the records of Verizon W ireless, telephone number (276) 206-0244 was resold to TracFone with no subscriber inform ation available. According to the following text m essages, the user of this phone was a m ale named iûBubba'' 5 tlKenny'' and dûcraig'' *As a result of this investigation, your affiant believes that the primary user of this phone number was Kenneth Craig GtBubba'' BUCHANAN. Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 34 of 106 Pageid#: 37

On April 23, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephone num bers, including those of Danny REECE and Rick SHAW . In response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accounts from April 9 to April 23, 2013. The following is an excerpt from the search warrant results.

April 10, 2013 Roger LAWSON to Danny REECE, inlts Roger myph is screwfup. Did u try to text me? New no. 276 206 3398'' REECE to LAW SON , *îNo still haven 't heard nothint' LAW SON to REECE, içvb'o ur not likely to be over too soon. Just let me kn/w'' REECE to LAW SON , i*WelI im over here but noparts'' LAW SON to REECE, içok f/cl?7/o,.''

Rick SHAW to REECE, ânl'm home'' REECE to SHAW , ii10-4 leavin D Town nöw''

REECE to Bubba BUCHANAN, GiDidyou an Rodger want to come tonight/''

April 11 - 12, 2013

BUCHANAN to REECE, çiliey r u up tex r call me Lcraig N & c./'' REECE to BUCHANAN , iCETA/'' BUCHANAN to REECE, iç3o/Ncraig N steft REECE to BUCHANAN, Qil0-4', BUCHANAN to REECE, GiupstairebNcraig N stef' REECE to BUCHANAN, *il0/5'' REECE to Christy Adams, iGlnalkin to Bub hejus got here 111 text whn he gtpêlc''

April 14 - 15, 2013 BUCHANAN to REECE, iiU n D r Mtn Cxenny Nstef' REECE to BUCHANAN , içout haven 't seen him yet'' BUCHANAN to REECE, içlnex when u dopleez âKenny N stef' REECE to SHAW , **I gotta haul thisparts truck to Stony Creek an I 'll be up fyr around/'' REECE to SHAW , ç*on wJy ntpw to yr house'' SHAW to REECE, iil'm in Boone back soont' REECE to SHAW , iç1'll have to go t?:7'5 SHAW to REECE, isok c u later text when u get Atzc/c''

REECE to BUCHANAN , *Q10-4 good to goo'' LAW SON to REECE, iGls it ok to stop by. lm in cï/y''

34 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 35 of 106 Pageid#: 38

REECE to LAW SON , ii10-4''

Based on my training and experience, and m y ltnowledge of this investigation, I believe that Danny REECE utilized the text m essaging service on his cellular telephone to obtain m ethamphetam ine from Rick SHAW and distribute it to Bubba BUCHAN AN and Roger LA W SON .

April 19, 2013

Danny REECE to Rick SHAW , LiWillyou be around tonight?', SHAW to REECE, iiNo sorry'' Bubba BUCHANAN to REECE, çiEver hear n e thing LKenny Nstef, REECE to BUCHANAN, Lil-le wcnf to the Rodrun nothing'' BUCHANAN to REECE, ;(. . .10-4W Kenny N stef'

April 20 - 21, 2013

BUCHANAN to REECE, ttAbw wvzf/: up Wlkknny N stef' REECE to BUCHANAN, iW othin he still aint home/t' BUCHANAN to REECE, iilkx me when WKenny N Steft REECE to SHAW , iâliave you got any ideal what time you will be home.?''

BUCHANAN to REECE, iLWhat 's the word W Kenny N stef' REECE to BU CHAN AN , GçNothin/''

SHAW to BUCHANAN , ii-îomin', REECE to SHAW , Gilkeenfourrrr on wayh'om DTown', REECE to BUCHANAN, Gillow much cash u got on /Jtz/7#?'' BUCHANAN to REECE, **160 WKenny Nstef' REECE to BU CHANAN , içblow quik can u get to river bridge/t' BUCHANAN to REECE, 6120 n route ntaw WKenny Nstef, Roger LAW SON to REECE, Giok fl come over ntlw?'' REECE to LAW SON, QiYeahfor a /ï/'' LAW SON to REECE, iGok lm leavin Saltville nt?w.'' LAW SON to REECE, ççBe there in 20 mins'' REECE to LAW SON , çi10-4't

On M ay 8, 2013, a search wanunt was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephone num bers, including those of Dalmy REECE, Rick SHAW , Roger LAW SON and Bubba BU CHANAN. In response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored

35 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 36 of 106 Pageid#: 39

in those accounts from April 26 to M ay 8, 2013. The following is an excerpt from the search warrant results.

April 30, 2013

Bubba BUCHANAN to Danny REECE, Guus wtlkc up have 2 go 2 dmv n the am b ok 2 come over then't REECE to BUCHANAN, içl0-4',

Toby M OCK to BUCHANAN , **R u gona come by A.A u go to work/jntoby .',)'' Lauren Allison to BUCHANAN, iiliey (/Z/ still got my 3odollars i got enough to make it l20 fyoudjust txt me or something id like to know whats goin on'' Jason M ULLINAX to BUCHANAN, çil-ley w:r u at nt)w.?''

Allison to BUCHANAN, Gilm in emory on wJy to Daisy. J/'zf got that Id like to get it. J/- not 1 canjust get money back it dont matter. Please let me kptpw.'' BU CHANAN to Allison, içB there shortly''

M ULLIN AX to BUCHANAN, ççlam atyur hous', MULLW AX to BUCHANAN, GGRoger here said dont have to gofarl'' BUCHANAN to M ULLIN AX , iiB there Jp''

Based on m y training and experience, and m y knowledge of this investigation, I believe that Bubba BUCHANAN utilized the text m essaging service on his cellular telephone to obtain methamphetamine from Danny REECE. l believe that BUCHANAN then engaged in drug conversations with Toby M OCK, Lauren Allison, and Jason M ULLINAX . l believe that M ULLIN AX advised BUCHANAN that they could get additional m ethamphetamine from Roger LAW SON .

M ay 2, 2013

Toby M OCK to Roger LAW SON , çiWill u text Bubba an ask him to call me plez/jntoby 1 , LAW SON to M OCK, ièl'l'e 's been asleepfor hrs.', M OCK to LAW SON, i6Well hell...1 saved mine so 1 could do it with him ...1 been trying to get ahold ofhim all evening... Thankya anm aysjntoby ('i7' On M ay 21, 2013, CS-6 was interview ed in W ashington County, VA. CS-6 stated that on M ay 16 and 1 7, he/she was with Sam ROBBINS while he was attempting to obtain m ethamphetamine. CS-6 stated that he/she and ROBBINS received a ride from Tony DELP to the residence of Bubba BU CHAN AN and Stephanie PATRICK to purchase m ethamphetam ine. CS-6 stated that DELP provided the ride in anticipation of receiving metham phetam ine from ROBBINS. CS-6 stated that upon arriving at the residence of BUCHANAN and PATRICK , no one was hom e. CS-6 stated that DELP provided a ride to the residence of Toby M OCK in Country Living Estates in Glade Spring, VA . CS-6 stated that eventually, BUCHAN AN and PATRICK

36 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 37 of 106 Pageid#: 40

anived and gave M OCK a ride to obtain the m ethamphetam ine. CS-6 stated that upon their return, MOCK sold 2 grams of methamphetamine to ROBBINS for $300.00. CS-6 stated that ROBBIN S gave % gram of m etham phetam ine to M OCK for obtaining it, and another % gram of metham phetamine to DELP for the transportation.

On September 2, 2013 Stephanie PATRICK was arrested with Craig çsBubba'' BUCHANAN in Johnson County, TN for drug related offense after being found in possession of approximately 1 1.4 gram s of of methamphetam ine. Following her arrest PATRICK stated to Johnson County, TN Sheriff s Investigators she picked the metham phetam ine up from someone in Virginia earlier and had already sold an eight-ball (3.5 gms) earlier in the evening. PATRICK stated that she and BUCHANAN were tdfronted'' the m ethamphetam ine and they were attempting to sell the m eth. PATRICK stated she and BU CHANAN went to idlkusty's'' house. Based on the affiant's participation in the investigation it's believed that Sklkusty'' is Russell CASSELL. W hile at iilkusty's'' BUCHANAN and PATRICK weighed out an eight-ball (3.5 gms) of meth and sold it to Skllusty'', PATRICK stated diRusty'' paid her $ 154.00 for the m eth.

Stephanie M arie PATRICK

On April l0, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephone numbers, including those of Danny REECE, Roger LAW SON and Linda W ALTERS. In response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accounts from M arch 20 to M arch 27, 2013. The following is an excerpt from the search warrant results. On M arch 23, 2013, Linda W ALTERS received the following text m essage from telephone number (276) 706-2193: çGlley Stefherejust thought we would let u guys know why you haven 't heardh'om us someone called social service on us gotta give them 3 clean ones and wc will drop the investigation already gave them 2 so wont be long let D know so you have no worries it suxs but wont b to much longer take care $& c .f& '' Based on m y training and experience, and m y knowledge of this investigation, l believe that Stephanie PATRICK advised Linda W ALTERS to let Danny REECE know that she and Bubba BUCHANAN had to give three (3) clean urines to social services and then they would be returning as metham phetam ine customers. ln M arch of 2013, W ashington County, VA Departm ent of Social Services opened an investigation in to alleged drug use by PATRICK and BUCHANAN . During the investigation social workers conducted interviews of PATRICK and BUCHANAN, as well as their children. A safety plan was created that required PATRICK and BUCHANAN to provide three clean lzrine samples. The following are the results of the dnzg SCCCCHS:

M arch 18, 2013-Craig BUCHANAN (Refusal)

37 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 38 of 106 Pageid#: 41

M arch 18s zol3-stephanie PATRlCK-(Refusal) Stated she did not want patemal grandmother to 'ûwin.''

M arch 28, zol3-stephanie PATR-ICK (Negative) April 15. 2013- Craig BUCHANAN l egative) April 15. 2013- Stephanie PATRICK @ ot given, PATRICK left before being screened against social workers direction) M ay 29. 2013- Stephanie PATRICK (Negative)

According to the records of Verizon W irelesss telephone number (276) 274-3867 was resold to TracFone with no subscriber inform ation available. According to the following text messages, a fem ale named (tstef ' w as the user of this phone. As a result of this investigation, your affiant believes that the primary user of this phone number was Stephanie PATRICK .

On April 23, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephone numbers, including those of Danny REECE and Rick SHAW . ln response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accotmts from April 9 to April 23, 2013. The following is an excerpt from the search warrant results.

April 10, 2013 Stephanie PATRICK to Danny REECE, Goll'ey Stefhere where t/5' REECE to PATRICK, çGln the apt', PATRICK to REECE, iiu going 2 Dtown't REECE to PATRICK, iiI wtz.ç but canthnd nethg to go on/', REECE to PATRICK, Gçl-l'e wtan/ be home till tonight'' PATRICK to REECE, âGFuck that J';/.u '' REECE to PATRICK, içBeen tryin... im ready to head to Dtown ?yt?w an iv gotprob .25 in the glass that ill do withyafor one ofthose specialfavors yr so good atl't PATRICK to REECE, iccyanide shortly''

Based on m y training and experience, and m y knowledge of this investigation, I believe that Stephanie PATRICK contacted Danny REECE to determ ine if he had methamphetamine and if he was going to Damascus, VA CdDtown''). I believe that REECE advised PATRICK that the methamphetamine source of supply (Rick SHAW ) wasn't home, but REECE would share what little he had lef4 for a sexual favor.

On April 13, 2013 Angela SURBER was interviewed in Bristol, Virginia. SURBER stated she had used m ethamphetam ine w ith Bubba BUCHANAN and Stephanie PATRICK .

38 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 39 of 106 Pageid#: 42

SURBER stated she, PATRICK and BUCHANAN traded m ethamphetamine with each other when one another would run out.

On M ay 21, 2013, CS-6 was interviewed in W ashington County, VA . CS-6 stated that on M ay 16 and 1 7, he/she was with Sam ROBBINS while he was attempting to obtain m ethamphetamine. CS-6 stated that he/she and ROBBINS received a ride from Tony DELP to the residence of Bubba BUCHAN AN and Stephanie PATRICK to purchase m ethnmphetam ine. CS-6 stated that DELP provided the ride in anticipation of receiving metham phetam ine from ROBBINS. CS-6 stated that upon aniving at the residence of BU CHAN AN and PATRICK, no one was hom e. CS-6 stated that DELP provided a ride to the residence of Toby M OCK in Country Living Estates in Glade Spring, VA . CS-6 stated that eventually, BU CHAN AN and PATRICK arrived and gave M OCK a ride to obtain the methamphetamine. CS-6 stated that upon their return, M OCK sold 2 grams of methamphetamine to ROBBINS for $300.00. CS-6 stated that ROBBINS gave % gram of methnmphetam ine to M OCK for obtaining it, and another % grnm of m ethamphetam ine to DELP for the transportation.

On September 2, 2013 Stephanie PATRICK was arrested with Craig EsBubba'' BUCHANAN in Johnson County, TN for dnlg related offense after being found in possession of approxim ately 1 1.4 gram s of m etham phetam ine. Following her arrest PATRICK stated to Johnson County, TN Sheriff s Investigators she picked the m ethamphetam ine up from som eone in Virginia earlier and had already sold an eight-ball (3.5 gms) earlier in the evening. PATRICK stated she and BUCHANAN were Ctfronted'' the m ethamphetam ine and they were attempting to sell the m eth. PATRICK stated she and BUCHAN AN went to Siltusty's'' house. Based on the afliant's participation in the investigation it's believed that çûlkusty'' is Russell CASSELL. W hile at StRusty's'', BUCHANAN and PATRICK weighed out an eight-ball (3.5 gms) of meth and sold it to k'Rustf'. PATRICK stated StRusty'' paid her $154.00 for the meth.

Roger Dale LAW SON 8282 O Id M ill Road, Glade Spring, Virginia 24340

Roger Lawson has prior convictions for distribution of marijuana % ounce to 5 pounds, dnzgs: sell/provide for resale schedule l or 1l, possession of schedule l or l1. On September 20, 2012 CS-I purchased one (1) gram of methamphetamine from Roger LAW SON at his residence of 8282 Old M ill Road, Glade Spring, Virginia located in the W estern District of Virginia. During the transaction LAW SON explained to CS-I he weighed the m eth out on paper and provided a little for good m easure. LAW SON advised CS-I not to idfuck with it, it weighs right, taste right, and that's why it cost $120.00''.

On September 20, 2012 CS- 1 purchased two (2) grams of methamphetamine from Roger LA W SON at his residence of 8282 Old M ill Road Glade Spring, Virginia located in the W estern District of Virginia.

39 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 40 of 106 Pageid#: 43

On September 26, 2012 CS-I purchased two (2) grams of methamphetamine from Roger LAW SON in the W estern District of Virginia.

On December 14, 2012 Gary HOW ELL was arrested following a motor vehicle accident in Glade Spring, Virginia. During the accident investigations HOW ELL was discovered to be in possession of approximately ten (10) pounds of marijuana, twelve (12) ounces of methamphetamine and $2, 192.00 U.S. Currency. HOW ELL stated he sold meth for $2,400.00 an ounce and $100.00 per gram. HOW ELL stated he sold drugs (meth) to Roger LAW SON (an ounce a week).

On January 7, 2013 CS-2 was interviewed in Charlottesville, Virginia. CS-2 stated that Roger LAW SON purchased m etham phetam ine from Gary HOW ELL. LA W SON was HOW ELL'S m ost frequent custom er purchasing ounces of m ethamphetnm ine at a time.

On January 25, 2013 HOW ELL was interviewed pursuant to a proffer agreement. HOW ELL stated from August 2012 until December 2012 he supplied LAW SON with one (1) to two (2) ounces of methamphetamine per week. HOW ELL stated LAW SON owed him $2400.00 for methamphetamine.

On Thursday, January 31, 2013 CS-3 was interviewed in Roanoke, Virginia. CS-3 stated HOW ELL was dealing one-half (%) ounces of methamphetamine to LAW SON every five to seven days. CS-3 stated he had observed LAW SON on over thirty (30) separate occasions obtain drugs from HOW ELL.

According to the records of Verizon W ireless, telephone number (276) 206-3833 was resold to TracFone W ireless with no subscriber infozm ation available. This phone was active from February, 2013 until at least April 10, 2013. According to text messages received via court order, the user of this phone was 'A oger''. A s a result of this investigation, your affiant believes that the prim ary user of this phone number was Roger LAW SON . According to the records of Verizon W ireless, telephone number (276) 206-6462 was resold to TracFone W ireless with no subscriber inform ation available, This phone was active from approxim ately April 26, 2013 until at least November, 2013. According to text m essages received via court order, the user of this phone was StRoger''. As a result'of this investigation, your affiant believes that the primary user of this phone num ber was Roger LAW SON . (On M ay 14, 20 13, CS-6 was interviewed in Bristol, VA and stated that Roger LAW SON'S cellular telephone numbers were (276) 206-3833 and (276) 206-6462.)

On February 27, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the account of telephone number (423) 471-1541, the cellular telephone of Timothy GERACE. In response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in that account from January 26 to February 27, 20 13. The following is an excerpt from the search warrant results.

January 28,2013

Roger LAW SON to Tim othy GERACE, Gil'im how close r u? I can meet u''

40 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 41 of 106 Pageid#: 44

LAW SON to GERACE, %çliey. Tried to call need to no wJ/ tm tell my buddy. She 's been waiten 4me to /x/ her/''

January 31, 2013

LAW SON to GERACE, iiliey the girl that bough thefurniture wants to buy the 3 matchinpieces''

February 1,2013

LAW SON to GERACE, inl-ley that girl wtzs' wanting thapictures that went wl that ,çc/?'' LAW SON to GERACE, ççl'im call meplease''

February 2,2013 LAW SON to GERACE, ççbl'ey im sitten hear with tha girl who bought urfurniture @ she wants tha 6 chairsfor tha table so call me A.S.A.P. ?'' GERACE to LAW SON, iicall me Jmr''

Based on m y training and experience, and my knowledge of this investigation, 1 believe that Roger LAW SON utilized the text messaging service on his cellular telephone to com municate with Tim othy GERACE about the distribution of metham phetam ine to an unknown fem ale custom er.

February 24,2013 Roger LAW SON to Danny REECE, içls it ok to come over /t)#t# @ J or 4'' REECE to LAW SON, **10-4'' LA W SON to REECE, Qosee ya /& z7'' REECE to LA W SON, çL1 gotta run up the road ill textya when I Ieave there an we can meet at myplace't LAW SON to REECE, (ûO/c'' REECE to LAW SON, isFtlz/ can come on n/w''

Based on my training and experience, and my knowledge of this investigation, l believe that Roger LAW SON utilized the text messaging service on his cellular telephone to com municate with Darmy REECE to purchase m ethamphetam ine. I believe that REECE m ade a trip to Rick SHAW 'S to obtain the metham phetam ine, then notitied LAW SON that he had it.

February 26,2013 Roger LAW SON to Danny REECE, Qook to visit tonight @ 11?', REECE to LAW SON, çolts gonna be a lil while 1 'm tryin to get up with thatfeller rt ntlw. 1 'll let ya no asap'' LA W SON to REECE, *QOk.''

41 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 42 of 106 Pageid#: 45

Based on my training and expelience, and m y knowledge of this investigation, 1 believe that Roger LAW SON utilized the text messaging service on his cellular telephone to com municate with Danny REECE to pick up m ethamphetam ine. 1 believe that REECE notified LAW SON that he had to see Rick SHAW before he could sell metham phetam ine to LAW SON .

On M arch 22, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephone numbers, including that of Roger LAW SON. In response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in that account from February 23 to M arch 22, 2013. The following is an excerpt from the search warrant results.

M arch 1, 2013 Roger LAW SON to Linda W ALTERS, L*Do u know where Danny is? J/'nö/, can u help me? Wt?.jrcr'' W ALTERS to LAW SON, çil'le 's in th bed I believe. All 1 hav is one xtra'' W ALTERS to LAW SON, çiNo my apt r u n mc'' W ALTERS to LAW SON, GX FoodL ion'' LAW SON to W ALTERS, CEJ'CJ Foodlion ok be right there',

Based on my training and experience, and m y knowledge of this investigation, 1 believe that Roger LAW SON utilized the text messaging service on his cellular telephone to purchase methamphetam ine from Linda W ALTERS.

M arch 4, 2013

Danny REECE to Roger LAW SON, çill'ow much wJy you wantin to spendon those PDA/.5- -?'' LAWSON to REECE, çnWouldyou take @ 200.', REECE to LAW SON, iiBe 180. 1 geuss is what you mean/'t LAW SON to REECE, ççYeal. Not sure 1'm coming.', LAWSON to REECE, içls before 12 t?/c?'' REECE to LAW SON, LGl0-4. Ijust wanted to make sure 1 had enufparts'' LAW SON to REECE, $tt?F'

Based on my training and experience, and m y knowledge of this investigation, l believe that Roger LAW SON utilized the text messaging service on his cellular telephone to purchase m ethamphetam ine from Danny REECE.

M arch 5, 2013

Roger LAW SON to Danny REECE, içcould 1 come c u today/t, LA W SON to REECE, Giok to come over to get those parts tonight?''

LAW SON to Linda W ALTERS, iiHave u seen Danny? M aybe u can help me. Let me know please.''

42 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 43 of 106 Pageid#: 46

REECE to LAW SON, içM ans not at home 111 text ya asap'' LAW SON to REECE, iGOk''

REECE to LAW SON, iiok to come on''

Based on my training and experience, and my knowledge of this investigation, 1 believe that Roger LAW SON utilized the text m essaging service on his cellular telephone to purchase metham phetam ine from Danny REECE.

M arch 7 - 9, 2013

Roger LAW SON to Jason M ULLIN AX, ènc'an u help me /t?nflc'' M ULLINAX to LAW SON, LiGina 's', LAW SON to M ULLINAX, ç*Be there shortlyt'

Based on my training and experience, and m y knowledge of this investigation, 1 believe that Roger LAW SON utilized the text messaging service on his cellular telephone to purchase metham phetam ine from Jason M ULLINAX and Gina Lopez.

M arch 11 - 20, 2013

Danny REECE to Roger LAW SON, iâTeIl her these are .5s. They gofor l''

LAW SON to REECE, Giok. l)'é? 'll take care o./'/ï'' LAW SON to Linda W ALTERS, iiHave u seen Danny/''

LAW SON to REECE, iivjre u in D ftlwn.'' LAW SON to REECE, Liliey man are u in D town/b' LA W SON to REECE, inzqre u at home? Need to c u.''

LAW SON to W ALTERS, Lican u call me/'t W ALTERS to LAW SON, Qilfyou need tell me now cause 1 am tlking to him right now an 1 will getfor you too'' LAW SON to WALTERS, Q%1 need at least 1. Is it ok fl give TG urph. No. ?'' WALTERS to LAW SON, $;A7 I canpick one upforyou. Yea thtshne'' LAW SON to W ALTERS, Gçvqre yal com in to D town or u already there/'' W ALTERS to LAW SON, GiNo 1 am not but Dannyprobably will shortly do you want me to tell him so you canjst meet up with him tlvr there/'' LAW SON to W ALTERS, iQYesplease'' W ALTERS to LAW SON, çilie ne dwn there in bout 2 hours. X'' LAW SON to WALTERS, t$f will need @ J Ifhe can bring them. L et me /c?7ow.'' W ALTERS to LAW SON, *%He should b ther netime ffyt?z/ hurry an grab him b4 nebdy else gets ther 101''

43 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 44 of 106 Pageid#: 47

Based on my training and experience, and my knowledge of this investigation, l believe that Roger LAW SON utilized the text messaging service on his cellular telephone to com municate with Linda W ALTERS about purchasing methamphetamine from Dnnny REECE.

On April 10, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephone numbers, including those of Danny REECE, Roger LAW SON and Linda W ALTERS. ln response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accounts from M arch 20 to M arch 27, 2013. The following is an excerpt from the search warrant results.

M arch 21, 2013

Dazm y REECE to Roger LAW SON , çGlnhis is my no Dan't LA W SON to REECE, iik-ou gonna work in D town today?'' REECE to LAW SON, Gik-eah but it will be 5 or 6 before that guy gets home. Then 111 com e on

LAW SON to REECE, iiok can u text me when ur .:4)4)t/?'' REECE to LAW SON, *Gl0-4 will (1 ''

LAW SON to REECE, ççlley r u in D town/'' REECE to LAW SON, GiM anjus text me 111 hollor atya when in hand.'' LAW SON to REECE, iook''

REECE to LAW SON , GQGot them truckparts but not comin that wly till morning. Come up (/FONJ like t0'' Based on m y training and experience, and m y knowledge of this investigation, l believe that Roger LAW SON utilized the text m essaging service on his cellular telephone to com municate with Danny REECE about ptlrchasing m ethamphetam ine. l believe that REECE obtained the methamphetamine from Rick SHAW and notified LAW SON that it was available.

M arch 22, 2013

Roger LAW SON to Danny REECE, LQWhen u head this wtzy, will u give me a call #Iease?t' REECE to LAW SON , iil0-4prob be hr or J''

REECE to LA W SON , çGln D town ntaw'' LAW SON to REECE, **C u shortly'' R EECE to LA W SON , Gçl0-4''

LAW SON to REECE, Gnlkrould 12 be too late to come over/''

REECE to LA W SON, içBe-flne', LAW SON to REECE, GQok thankv'' LAW SON to R-EECE, iiNeed 2 cans ofgreese when 1 c u at 12,'

44 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 45 of 106 Pageid#: 48

REECE to LAW SON, çi10-4,,

Based on m y training and experience, and m y knowledge of this investigation, I believe that Roger LAW SON utilized the text m essaging service on his cellular telephone to purchase m ethamphetam ine from Danny REECE.

April 2, 2013

Toby M OCK to Roger LAW SON, iD id u ever decide fu were gona go to the mkt/jntoby (.75 LAW SON to M OCK, iiNot sure. Y'f do I 'll call zf.'' LAW SON to Danny REECE, G%Gonna be in D Fown today/', REECE to LAW SON , Gillere now'' LAW SON to REECE, iGcan 1 ask J/t?w long u will be there.J'' REECE to LAW SON, çt4 or 5 hrs but I don 't know Ifthparts will last that long?', LAW SON to REECE, Gncan u hang on to at least 3. 111 be there shortly. '' REECE to LAW SON, ''Fry my best'' LAW SON to REECE, %iOk.''

LAW SON to M OCK , inGetting ready to go to the market. Be ur wly unless u can meet me in Glade. ''

LAW SON to REECE, insave me at least J.''

Based on my training and experience, and my knowledge of this investigation, l believe that Roger LAW SON utilized the text m essaging service on his cellular telephone to purchase m ethamphetam ine from Darmy REECE for Toby M OCK.

April 5, 2013

Toby M OCK to Roger LAW SON , tûll'cn u goin to the mkt? Eddie here and wanted to sendfor somepaintjntoby @ ' LAW SON to M OCK, iscan go anytime but wait couple ofhrs. Callyal.'' M OCK to LAW SON , GGlgot somebody else brining me sum $ over to 1 ned to sendwith yabntoby @ '

Danny REECE to LAW SON , iQETA?'' LAW SON to REECE, Gils 11:30 to late/', REECE to LAW SON , $*Be tl/('' LAW SON to REECE, iilhanks''

M OCK to LA W SON, GGWher ya at?bntoby (v(.P' LAW SON to M OCK, iilust kiddin on our wtzy.'' M OCK to LAW SON, iiokey dokey...yal b carefulintoby (.25 LAW SON to M OCK, *K '

45 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 46 of 106 Pageid#: 49

M OCK to LAW SON , G*R yal close? intoby @ ' LAW SON to M OCK, iûFc.$ at Bub 'J''

M OCK to LAW SON , çGblave yal /:.# Bub 's yetjntoby @ ' LAW SON to M OCK , iil'm down at Kenny 's. Bub 's got z/r,ç.''

Based on m y training and experience, and my knowledge of this investigation, 1 believe that Roger LAW SON utilized the text m essaging service on his cellular telephone to purchase m ethamphetam ine from Danny REECE for Toby M OCK and Bubba BU CHAN AN .

On April 11, 2013 Angela SURBER was interviewed in Bristol, Virginia. SURBER stated she sm oked m ethamphetam ine with Roger LAW SON at his house when he lived in Glade Spring, Virginia. SURBER advised that LAW SON had given her m ethamphetam ine to deliver to his daughter in the past.

On April 23, 20 13, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellulr telephone num bers, including those of D anny REECE and Rick SHAW . ln response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accounts from April 9 to April 23, 2013. The following is an excerpt from the search warrant results.

April 10, 2013

Roger LAW SON to Danny REECE, nnlts Roger myph is screwfup. Did u try to text me? New no. 276 206 3398'' REECE to LAW SON , iiNo still haven 't heard nothin'' LAW SON to REECE, **So ur not likely to be over too soon. Just let me iwtpw'' REECE to LAW SON , **Well im over here but no pJr/5,'' LAW SON to REECE, çiok //ltzn/c5'.''

Rick SHAW to REECE, çnl'm home'' REECE to SHAW , i*l0-4 leavin D lhwn n/w''

REECE to ttBubba'' BUCHANAN , çcllidyou an Rodger want to come tonight/''

A pril 11, 2013

LAW SON to REECE, LGl-his is my zyew no. 276 206 6462 r u gonna in D Ftlwa today/'' REECE to LAW SON , ânk-eah in a couple hrs'' LAW SON to REECE, Giok f/tl?y#.ç''

LAW SON to REECE, St-drc u in Damascus? Roger'' REECE to LAW SON, *il0-4 fFa4?'' LAW SON to REECE, S*ll'ow long have 1 got to get there/t' REECE to LAW SON, ioprob be Iate Iate before I Ieave'' LAW SON to REECE, Giok be there about hn''

46 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 47 of 106 Pageid#: 50

REECE to LAW SON , iGl0-4,'

April 16, 2013

LAW SON to REECE, iiR u in Dlmown today/'' REECE to LAW SON , GGWhile it last! Yeah Dl-own't LAW SON to REECE, iizqre you still there f/'cçtp f 'lI b there in 20 mins'' REECE to LAW SON, Gçkreah', LAW SON to REECE, iiok''

LAW SON to REECE, çiR u still there? 1 need l more tirefor my trailer', Based on my training and experience, and my knowledge of this investigation, l believe that Roger LAW SON utilized the text messaging service on his cellular telephone to purchase metham phetamine from Danny REECE in Damascus, VA.

April 17, 2013

Rick SHA W to Danny REECE, iiHeaded home', REECE to SHAW , $1On wJy do u need nethingjbom town?'' SHAW to REECE, çiDrink''

Roger LAW SON to REECE, Lizqre u n D Ftawn tonight'' p'' REECE to LAW SON, i$C7/. REECE to LAW SON, nnGotpartst'

April 20 - 21, 2013

LAW SON to REECE, Lnzqre u gonna be in Dl-own today/'' REECE to LAW SON, iâFwd. D ude is gone to the RodRun don 't no when he will be home?'' LAW SON to REECE, GiAll I need is a 50 lb. bag o/lt?g/otl(f' REECE to SHAW , içblave you got any ideal what time you will be home/', SHAW to BU CHANAN, iç30min,t REECE to SHAW , Qilneeenfourrrr on wayjkom DTbwp'' LAW SON to REECE, çiok f/'f come over nt?w?'' REECE to LAW SON, GiYeahfor a lil,' LAW SON to REECE, çnok lm leavin Saltville nt?w.'' LAW SON to REECE, GëBe there in 20 minf' REECE to LAW SON , iil0-4''

47 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 48 of 106 Pageid#: 51

Based on my training and experience, and m y knowledge of this investigation, I believe that Roger LAW SON utilized the text messaging service on his cellular telephone to purchase m ethamphetam ine from Danny REECE, who was supplied by Rick SHAW .

On M ay 8, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephone numbers, including those of Danny REECE, Rick SHAW and Roger LAW SON . ln response to the execution of this search wanunt on Verizon W ireless, agents received text m essages stored in those accounts from April 26 to M ay 8, 2013. The following is an excerpt from the search w arrant results.

M ay 1, 2013

Toby M OCK to Roger LAW SON, Giliave u heard anything/bntoby (.W5 LAW SON to M OCK, iiNot yet.'' M OCK to LA W SON, çx jntoby tu!.7'

LAW SON to Danny REECE, Giu gonna be in D Ftpwn today/tt REECE to LAW SON, ëçlitn cf/y'' LAW SON to REECE, (iok /J2tzn/o'.'' LAW SON to REECE, **Ok to stop by D /er?'' IkEECE to LAW SON, ç*l0-4'' LAW SON to REECE, çiok''

Based on m y training and experience, and my knowledge of this investigation, l believe that Roger LAW SON utilized the text m essaging service on his cellular telephone to comm unicate with Toby M OCK and Dalm y REECE about obtaining m ethamphetam ine.

On August 13, 2013 CS-I 1 purchased one-half (%) grams of methamphetamine from Roger LAW SON in the W estern District of Virginia.

On September 5, 2013 CS-I 1 purchased one-half (%) grams of methamphetamine from Roger LAW SON at his residence of 8282 Old M ill Road Glade Spring, Virginia located in the Western District of Virginia. During the transaction CS-3 asked LAWSON what yossessed him to bond Craig (kBubba'' BUCHANAN and Stephanie PATRICK out of jail followlng their arrest in Mountain City, TN. LAW SON stated he wrote the bondsmen a $13,000.00 check and m entioned the bondsm an was holding the check for two weeks. LAW SON stated he would be in real trouble if he didn't come up with the m oney. lt is known to the affiant that BUCHANAN and PATRICK were arrested in Johnson County, TN on September 2, 2013 for possession of m ethnmphetam ine.

Toby Anne M O CK 13341 Country Living Lane, Glade Spring, VA 24340

Toby M ock has prior arrests/convictions for contempt of court.

48 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 49 of 106 Pageid#: 52

On April 3, 2013, CS-5 was interviewed in Bristol, Virginia. CS-5 stated in October of 2012 GERACE got called by Toby M OCK who wanted to sell a .22 pistol. GERACE and CS-5 went to meet M OCK at Bubba BUCHANNAN 'S garage. On the w ay GERACE told CS-5 to get the silver 9m m pistol and get out in the woods in case anything goes wrong. CS-5 did as he was told. Five to ten m inutes later GERACE called up and asked CS-5 if he/she w anted to buy this .22 caliber revolver for $500 that M OCK was selling. M OCK said it belonged to her boyfriend at the time. CS-5 and GERACE declined buying the pistol.

According to the records of Verizon W ireless, telephone number (276) 492-7023 was resold to TracFone with the following information available: no name at 13341 Country Living Ln., Glade Spring, VA, email [email protected]. As a result of this investigation, your affiant believes that the prim ary user of this phone num ber was Toby M OCK . (On April 1 1, 2013, Angela SURBER was interviewed in Bristol, VA and stated that Toby M OCK'S cellular telephone number was (276) 492-7023.) (On M ay 14, 2013, CS-6 was interviewed in Bristol, VA and stated that Toby M OCK'S cellular telephone number was (276) 492-7023.) On M arch 22, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephones, including that utilized by Roger LAW SON . ln response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accounts from February 23 to M arch 22, 2013. The following is an excerpt from the search warrant results.

February 25,2013 Toby M OCK to Roger LAW SON, iX you go meet Rachael will u holla at me Eddie wnet p'' somewhere an he may not make it bak n time to go meet Jlprï#zFt):. LAW SON to MOCK, Gil've not heardh'om her.', M OCK to LAW SON, iiL indajus text me bak and she good bnToby'' MOCK to LAWSON, kûr'p-c can holla at L inda fu want tojnlbby', MOCK to LAWSON, çiliow many ofthose rugs did u ned an l can text /?drlaFt?:.y'' LAW SON to M OCK, niliey is L inda gonna be there this evening/'' M OCK to LAW SON , itf 'm not sure 1 haven 't talkd to her anymore since earlier she probably will 1 rekonjnlnoby'' M OCK to LAW SON, $i1 think she is ready ntpw fu were wantin to yell at herjnlnoby''

LAW SON to M OCK , GiWere u wantin to go, or send/'' M OCK to LAW SON, GGsend fthat ok with ujnToby .,)'' M OCK to LAW SON, LGc'an Isend with u wen u go over? LnToby :)'' LAW SON to M OCK, içsure can.b' LAW SON to Danny REECE, iiïkrill it be ok to stop by @ 6 or 737,'

49 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 50 of 106 Pageid#: 53

Based on m y training and experience, and m y knowledge of this investigation, I believe that Toby M OCK utilized the text messaging service on her cellular telephone to eommunicate with Roger LAW SON in an attempt to obtain m etham phetam ine for a custom er, Eddie LNU . l believe that M OCK suggested Rachael PEAKE and Linda W ALTERS as suppliers, but LAW SON eventually went to Danny REECE for the m etham phetamine.

February 28,2013

Toby M OCK to Roger LAW SON, tiFbtf goin to thejlea mkt. this eveningànlbby :)'' LAW SON to M OCK, iik-eal flget moneytt M OCK to LAW SON, iiK 1 ned 2 and halfgallons ofpaint ànToby .',)'' LAW SON to M OCK, LLBe byt' M OCK to LAW SON, çiK Eddie bringing the money down so it b bout an hour bfore he gets herebnToby :)'' LAW SON to M OCK, L*Ok'' M OCK to LAW SON, çîl'le said he would b here (/?z didn 't mind to swing by an get /I& $ plezbnlnoby .*7'' LAW SON to M OCK , **Ok''

LAW SON to Danny R-EECE, inBe ok to head ur wlA about an hr. .?'' REECE to LAW SON , 6*10-4''

Based on m y training and experience, and my knowledge of this investigation, 1 believe that Toby M OCK utilized the text m essaging service on her cellular telephone to communicate with Roger LAW SON in an attempt to obtain m ethamphetam ine for a custom er, Eddie LNU . l believe that LAW SON eventually obtained the m ethamphetam ine from Danny REECE.

On April 1O, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephone num bers, including that of Roger LAW SON. In response to the execution of this search wanunt on Verizon W ireless, agents received text messages stored in that account from April 1 to April 10, 2013. The following is an excerpt from the search w arrant results.

April 2, 2013

Toby M OCK to Roger LAW SON, iD id u ever decide f/'lf were gona go to the mkt?bntoby @ ' LAW SON to M OCK, S*Not sure. J/V do 111 call ?z''

LAW SON to Danny REECE, iiGonna be in D Town today.J'' REECE to LA W SON, Giliere atpw'' LAW SON to REECE, çncan 1 ask how long u will be there/'' REECE to LAW SON, 1;# or 5 hrs but 1 don 't kptlw fthparts will last that long/'' LAW SON to REECE, içcan u hang on to at least 3. 111 be there shortly''

REECE to LAW SON , tIF/-.V my llp-çf'' LAW SON to REECE, ;tOk''

50 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 51 of 106 Pageid#: 54

LAW SON to M OCK, GGGetting ready to go to the market. Be ur wJy unless u can meet me in Glade.t'

LA W SON to REECE, Qçsave me at least 3.'t

Based on my training and experience, and my knowledge of this investigation, l believe that Toby M OCK utilized the text m essaging service on her cellular telephone to comm unicate with Roger LAW SON in an attempt to obtain m ethamphetam ine. l believe that LAW SON eventually obtained the methamphetamine from Danny REECE.

April 5, 2013

Toby M OCK to Roger LAW SON, içWen u goin to the mkt? Eddie here and wanted to sendfor some paintjntoby t:7' LAW SON to M OCK, iican go anytime but wait couple ofhrs. Callyal.'' M OCK to LAW SON , ii1 got somebody else brining me sum $ over to 1 ned to send with yabntoby @ 5

Danny REECE to LAW SON, iiETA/'' LAW SON to REECE, Gnls 11..30 to late?', REECE to LAW SON , içBe ok'' 'LAW SON to REECE, iil-hanks',

M OCK to LAW SON, Gnlkher ya at/bntoby t.W' LAW SON to M OCK, iuust kiddin on our wly.'' MOCK to LAW SON, içokey dokey...yal b carefuljntoby @ ' LAW SON to M OCK, ESA'''

M OCK to LAW SON, GiR yal close? Lntoby ('W' LAW SON to M OCK, Ctl'c,N at Bub 's'' MOCK to LAW SON, içblave ya1 Ieh Bub 's yetbntoby t'W' LAW SON to M OCK, ii1 'm down at Kenny 's. Bub 's got urs.''

Based on my training and experience, and m y knowledge of this investigation, 1 believe that Toby M OCK utilized the text m essaging service on her cellular telephone to comm unicate with Roger LAW SON in an attempt to obtain m ethamphetam ine for several customers. 1 believe that LAW SON eventually obtained the methamphetamine from Danny REECE and lefl M OCK'S share at the residence of Bubba BUCHANAN .

April 1 1, 2013 Angela SURBER was interviewed in Bristol, Virginia. According to SURBER, GERACE cam e to her and M OCK'S apartm ent everyday with twO to four grams of meth for each of them to distribute. SURBER stated she sold every bit of meth she could just to eat.

51 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 52 of 106 Pageid#: 55

On M ay 8, 2013, a search wanunt was applied for and obtained in the W estern District of V irginia for text messages stored in the accotmts of several cellular telephone numbers, including those of Dnnny REECE, Rick SHAW and Roger LAW SON . ln response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accounts from April 26 to M ay 8, 2013. The following is an excerpt from the search warrant results.

M ay 1, 2013

Toby M OCK to Roger LA W SON, iiHave u heard anything/bntoby (W ' LAW SON to M OCK, GQNotyett, M OCK to LAW SON , ix jntoby @ '

LAW SON to Danny REECE, iiu gonna be in D Ttlwn today/', REECE to LAW SON, QGkftn cjfy'' LAW SON to REECE, ièok thanks.'' LAW SON to REECE, çiok to stop by Iater?'' REECE to LAW SON, iil0-4'' LAW SON to REECE, çûO/c''

Based on m y training and experience, and m y knowledge of this investigation, l believe that Toby M OCK utilized the text m essaging service on her cellular telephone to comm unicate with Roger LAW SON in an attem pt to obtain methamphetamine. 1 believe that LAW SON eventually obtained the m etham phetamine from Danny REECE.

M ay 2, 2013

Toby M OCK to Roger LAW SON , çiWill u text Bubba an ask him to call me plez/bntoby (.j.p, LAW SON to M OCK, âibl'e 's been asleepfor hrs.'' M OCK to LA W SON, ççWell hell...I saved mine so I could do it with him ...I been trying to get ahold ofhim all evening... Thankya anm aysjntoby (J7' On M ay 21, 2013, CS-6 was interviewed in W ashington County, VA. CS-6 stated that on M ay 16 and 17, he/she was with Sam ROBBINS while he was attempting to obtain m etham phetam ine. CS-6 stated that he/she and ROBBW S received a ride from Tony DELP to the residence of Bubba BUCHANAN and Stephanie PATRICK to ptlrchase m ethamphetam ine. CS-6 stated that DELP provided the ride in anticipation of receiving metham phetam ine from ROBBINS. CS-6 stated that upon arriving at the residence of BU CHANAN and PATRICK , no one was hom e. CS-6 stated that DELP provided a ride to the residence of Toby M OCK in Country Living Estates in Glade Spring, VA. CS-6 stated that eventually, BUCHANAN and PATRICK anived and gave M OCK a ride to obtain the m ethamphetam ine. CS-6 stated upon their return, M OCK sold 2 gram s of methamphetamine to ROBBINS for $300.00. CS-6 stated ROBBINS gave % gram of methamphetam ine to M OCK for obtaining it, and another % gram of m ethamphetam ine to DELP for the transportation.

52 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 53 of 106 Pageid#: 56

On June 1, 2013 CS-6 purchased one (1) gram of methamphetamine from Toby M OCK in the W estern District of Virginia. CS-6 had previously paid $120.00 to M OCK on M ay 31, 2013 for methamphetamine but did not receive the one (1) gram of methamphetamine until June 1, 2013.

On June 7, 2013 CS-6 purchased one (1) gram of methnmphetamine from Toby M OCK at 13341 Countl'y Living Lane, Glade Spring, Virginia located in the W estern District of V irginia. CS-5 had previously paid $120.00 to M OCK on June 3, 2013 for methamphetnmine but did not receive the one (1) grnm of methamphetamine until June 7, 2013. On June 10, 2013 CS-6 purchased one (1) gram of methamphetamine from Toby M OCK at 13341 Countl'y Living Lane, Glade Spring, Virginia located in the W estern District of Virginia.

On June 12, 2013 CS-6 purchased one and one-half (1.5) grams of methamphetnmine from Toby M OCK at 13341 Country Living Lane, Glade Spring, Virginia located in the W estern District of Virginia.

On June 25, 2013 CS-6 purchased one (1) gram of methamphetamine from Toby M OCK at 13341 Country Living Lane, Glade Spring, Virginia located in the W estern D istrict of V irginia.

On July 2, 2013 CS-6 purchased 3.5 gram s of m ethnmphetamine from Toby M OCK at 13341 Country Living Lane, Glade Spring, Virginia located in the W estern District of Virginia.

On July 15, 2013 CS-6 purchased three (3) grams of methnmphetamine from Toby M OCK at the entrance to Countl'y Living Estates which is located approxim ately one-half m iles from M OCK'S residence located at 13341 Country Living Lane, Glade Spring, Virginia in the W estern District of Virginia.

Rachael Renee PEAKE

On April 1 1, 2013 Angela SURBER was interviewed in Bristol, Virginia. SURBER stated that she had sold methamphetamine over the years for Tim GERACE, Rick SHAW , Danny REECE and others. SURBER stated that one of her m ethamphetam ine custom ers was Rachael PEAKE.

According to the records of Tracfone W ireless, telephone number (276) 243-7583 was subscribed to by Rachael R. PEAKE at 61 1 Freedom Tabem acle, Atkins, VA. According to the records of Sprint, telephone number (276) 685-3 199 was subscribed to by Rachael PEAKE at 6 l 1 Freedom Tabernacle Ln., Atkins, VA. According to the records of Tracfone W ireless, telephone number (276) 378-4585 was subscribed to by Crystal Peake at 2508 Avery Ln., M arion, VA. According to the records of Sprint, telephone number (276) 685-6638 was subscribed to by Betty Peake at 573 Freedom Tabem acle Ln., Atkins, VA.

53 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 54 of 106 Pageid#: 57

For the purposes of this affidavit, your aftiant believes that Rachael PEAKE was the user of these telephones to send and receive the text m essages contained herein.

On M arch 22, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephones, including that utilized by Roger LAW SON . In response to the execution of this seareh warrant on Verizon W ireless, agents received text m essages stored in those accounts from Febnzary 23 to M arch 22, 2013. The following is an excerpt from the search warrant results.

February 25,2013 Toby MOCK to Roger LAW SON, i*1 couldn 't get ahold ofher...Rachael checkin on sum for mejnToby'' LAW SON to M OCK , i6Tell her to call or text me please.''

M OCK to LAW SON , çGilid she textya? ïaTbby'' LAW SON to M OCK, GiNotyet'' M OCK to LAW SON, iilt-you go meet Rachael will u holla at me Eddie went somewhere an he may not make it bak n time to go meet herbnl-oby''

M OCK to LAW SON , GoText RachaelbnToby't MOCK to LAW SON, â*she calling them at 1..00 so let me no fu want me to ask herfor A'ajnlhby''

LAW SON to Rachael PEAKE, içbley are u gonna take a trip/'' PEAKE to LAW SON, iGNo cuz 1 can 't get anythingfor myselfbut I can here real close. Same thing. 1 went Fri. they went wit ?pe.''

PEAKE to LAW SON, Q*Need to know what u need asap fu do'' LAW SON to PEAKE, çilust go with what u gt)/.'' PEAKE to LAW SON, ii1 don 't got anything to go with 1 wasjust gonna go here in town for u to Toby'' Based on my training and experience, and m y knowledge of this organization, I believe that Roger LAW SON inquired of PEAKE if she was going to go to see her m ethamphetam ine source of supply, possibly in M ountain City, TN . I believe that PEAKE advised LAW SON that she had m ade a trip with others on Friday, and that she could get metham phetam ine from the others for LAW SON and Toby M OCK.

February 26,2013

Rachael PEAKE to Roger LAW SON, tçllrcn do u think u will be able to do that again fu even do cuz 1 want to but don 't have close to his rules'' LAW SON to PEAKE, nQblow much do u need/t' PEAKE to LAW SON , %L1 only have 200'' LAW SON to PEAKE, ii1 'vp got 5 or more. Can u go tonight/',

54 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 55 of 106 Pageid#: 58

PEAKE to LAW SON, ççllon 't look like 111 be able to do anything until I can see Christy to let me borrow. 1 really don 't wanna go (/'f can 't get me something. So hopefully wcz? 1 can go u will still be able to.'' LAW SON to PEAKE, içU can go tonight/'' PEAKE to LAW SON, â*1 don 't knt?w cuz even fshe Iets me borrow $ she don 't get offtill 11 tonight. Don 't knt?w fdude lets anyone come aher certain /ï?nc.'' LAW SON to PEAKE, iiok 1 understand ''

Based on m y training and experience, and my knowledge of this organization, I believe that Rachael PEAKE inquired of Roger LAW SON if he was going to go see the metham phetam ine source of supply. l believe that PEAKE told LAW SON that she only had $200.00 and did not believe that the source would sell that small of a quantity. l believe that LAW SON told PEAKE that he had $500.00 or more and wanted PEAKE to go with him .

M arch 2, 2013

Rachael PEAKE to Roger LAW SON, i%1 guess I aint going cuz 1 don 't have but 500 unless u can come up with anything in next 30 min l triedgetting rent early even told her id take tp/fzpp fshe 'dpay early Roger W wtan '/ help he suck balls'' Sam uel ROBBIN S to LAW SON , 6*U coming by'' LAW SON to ROBBINS, isff will be late fnot early morning. Will try my best.t' Angeline Delp to LAW SON , iiHave u heard anything/'' LAW SON to Delp, Gx otyet.tt

LAW SON to PEAKE, çGWhat's goin on. Are u t?/c.?''

Toby M OCK to LAW SON, inll'as she made it backyet? 3nToby.')'' LAWSON to MOCK, iil've not heard#om /):r.''

M OCK to LAW SON, iCK. 111 try an call her to c wher she 9h?7Ft?:.p.'a)'' M OCK to LAW SON, LiHerphone is turned tp .J/'ïnrt?by.',)'' LAW SON to M OCK , iLGood luck'' MOCK to LAWSON, ièWell #-yl hearh'om herjus holla at me an 1 will do the same LnToby.'l'' A. Delp to LAW SON , çistill waiting/'' LAW SON to A. Delp, G*1 am to.''

LAW SON to PEAKE, GnRachael, what 's goin on? Gotpeople yelling at me.'' PEAKE to LAW SON, çLok how much ofthat wasyour $'' LAW SON to PEAKE, iilhought we came up with 5. I've got to give Toby some.'' PEAKE to LAW SON,tt0/c uhrst gave me 300for u then 50for meds. Then u met me 2nd time gave me 150 total of500. 1 'm gonna give u 4 and 50$ cash a/w. Then around lunch time 1'm gonna give you 50 more cash cuz im getting rent today cuzyesterday 1 wtzy desperate to get cash I told her Y'-ç/;c 'dgive me rent early 111 take l00 /7./'.:/ she

55 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 56 of 106 Pageid#: 59

paying me today. Will that be ok so all 111 tpwc u J-//er I give u yours tfr 50$ will be 50 at Iunch time is that cool'' LAW SON to PEAKE, *%R u coming on ntpw?'' PEAKE to LAW SON, CtFCJ can u meet me at shellplz about outta gas again 1 'll text wcn 1 leave here getting ready to leave in 15'' LAW SON to PEAKE, çiok butplease hurry. 1 'm leavin now. Put it down and come on.''

Based on m y training and experience, and m y knowledge of this organization, l believe that Rachael PEAKE and Roger LAW SON discussed $500.00 that LAW SON gave to PEAKE for drugs for himself, Sam ROBBINS, Angeline DELP and Toby M OCK. I believe that PEAKE agreed to give LAW SON four (4) grams of methamphetamine and $50.00 cash now, and an additional $50.00 cash when PEAKE collected rent from a tenant.

M arch 8 - 9, 2013

Roger LAW SON to Rachael PEAKE, inbley woman, katpw anything g/t)#?'' PEAKE to LAW SON, iiGoing to go here in about 30 min.'t LAW SON to PEAKE, iil-hink u couldpicksomething upfor me.'' PEAKE to LAW SON, iilfu will meet me.'' LAW SON to PEAKE, Gisure will where and what time?''

PEAKE to LAW SON, CiIJJJ.C u happy with that't LAW SON to PEAKE, Lçsure wJJ''

Based on my training and experience, and my knowledge of this organization, l believe that Rachael PEAKE agreed to pick up m ethamphetam ine for Roger LA W SON . 1 believe that after PEAKE supplied LAW SON , she inquired as to the quality of the m etham phetamine,

M arch 11, 2013 Roger LAWSON to Rachael PEAKE, QçDid u everhrure the deal on the money triangle'' PEAKE to LAW SON, içWhat r u talking about? The message 1 sent u explained everything. lpaid Toby her 50 that u give mefor the meds. She saidyou took care ofher with the other 50.'' LAW SON to PEAKE, içok, come me next time ur down.b'

PEAKE to LAW SON, içokay u gave me 300 the 1't time. The second tim e u gave me 150. Totaling 450. I gave u 4 and 50 cash. Ipaid Toby her 50 but that wasn 't even included. What is it u r thinking 1 'm confused'' LAW SON to PEAKE, i%1 'm satished Do uplan to go again. '' PEAKE to LAW SON , çiFri't

Based on m y training and experience, and my lcnowledge of this organization, I believe that Rachael PEAKE and Roger LAW SON discussed the prior drug transaction totaling $500.00. I believe that PEAKE told LAW SON that she was m aking another trip to purchase methamphetamine on Friday (possibly to M ountain City, TN).

56 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 57 of 106 Pageid#: 60

On April 23, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephone numbers, including those of Danny REECE and Rick SHAW . ln response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accounts from April 9 to April 23, 2013. The following is an excep t from the search warrant results.

April 10, 2013 Rachael PEAKE to Rick SHAW, *i1 got shitload ofrugs zitlw. f c/ me /czyt?w when u want me tt I 'll bring e-'' SHA W to PEAKE, G6ok tomar b 4 12:00 is gotaï' PEAKE to SHAW, ikol ifsomething happens 1 can 't get there before then l'llyell. Hell 1 got all time in world now old man wtp?7 '/ be homefor several days.'' SHAW to PEAKE, GQOIC''

April 11, 2013

PEAKE to SHAW , GQstill oklcomett SHA W to PEAKE, 1'Fc5''' PEAKE to SHAW , çiok 1 'm in Glade c u shortly'' SHA W to PEAKE, %*Ok,'

April 20 - 21, 2013 PEAKE to SHAW , Qiblello hun. Hope u enjoying sunshine. AIl kins ofgoodies. Shop rags & shop towels. M ore rugs and industrial trash bags.'' PEAKE to SHAW , ççsfeant to say 1 got u alI kinds ofgoodies'' SHA W to PEAKE, iiYeap goodl need them'' PEAKE to SHAW , GiWhen is a good timefor me to come over? Id like to talk to Danny about Iast time I m w him.', PEAIQE to SHAW , GQzjlso got u big roll ofbarbwirefor u to startfence with. Got boxfull findustrial glovest, SHAW to PEAKE, iiGood csll me tomar eveningt,

PEAKE to SHAW , Gil-lello hope u doing well this awesome sunny spring dayll Wanting to c fwe can come your wtl? Christy riding with me.'' SHAW to PEAKE, inon wJy b 2 :r-ç'' PEAKE to SHAW , çiok so around 430 ok'' SHAW to PEAKE, Gikkah u can but remind me what u sail'

Based on my training and experience, and m y knowledge of this organization, l believe that Rachael PEAKE communicated with Rick SHAW regarding m iscellaneous item s in her possession that she wished to trade for metham phetamine. l believe that PEAKE advised SHAW that she needed to speak with Danny REECE, a distributor for SHAW . l believe that SHAW agreed to trade with her the following day.

57 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 58 of 106 Pageid#: 61

On M ay 8, 2013, a search warrant was applied for and obtained in the W estern District of

Virginia for text messages stored in the accounts of several cellular telephone num bers, including those of Danny REECE, Rick SHAW and Roger LAW SON . ln response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accounts from April 26 to M ay 8, 2013. The following is an excerpt from the search warrant results.

April 27, 2013

Roger LAW SON to Rachael PEAKE, iiRachael u ripped me t? .J/.' f wtu supposed to get 22 and u only gave me 19,, PEAKE to LAW SON , iç1 will talk to u in person't PEAKE to LAW SON, Qican 't believe u wl/# say that to me. So n/w 1'm a rip off..like I intentionally short changed u. Have 1 ever done u wrong before? That really hurts my feelings. ''

M ay 3, 2013

PEAKE to LAW SON, LGbley what u doing this Rachael'' LAW SON to PEAKE, iuust got to Saltville. I'JJ/)tz/ r u up to/'' PEAKE to LAW SON , ççNothing much. Do u have anyplans on seeing Danny this evening? 1 went over last Fri that's w/cy #f#n 'tyell back atya.'' LAW SON to PEAKE, *i1 wtzcç texting him when u text me. I hope to c him, but haven 't heardh'om him.'' LAW SON to PEAKE, Sil'e.ç 1 will let u /fnt?w.'' PEAKE to LAW SON , içplz do. Do u want me 2 go aheadget ready and bring u $''' LAW SON to PEAKE, iill'e said it would be tomr. Im gonna call someone else.''

Based on m y training and experience, and m y knowledge of this organization, I believe that Rachael PEAKE and Roger LAW SON discussed obtaining m etham phetam ine from Danny REECE.

Jason M ichael M ULLINAX

Jason M ullinax has pzior arrests for possession of a controlled substance, delivery of drugs to prisoner, possession with intent to m anufacture/sell a schedule 1 or 11 substance and m ix: distribute etc of 28 to 226 gram s.

On January 30, 2013 CS-4 was interviewed in Bristol, Virginia. CS-4 stated in 2002 he/she began using m etham phetam ine with Brady LESTER and Jason M ULLINAX. CS-4 advised that continued until 2003/2004. CS-4 stated from 2004-2005 he/shes M ULLINAX, and several other individuals began working together to m anufacture large quantities of meth. CS-4 stated M ULLINAX would supply the necessary precursor that w ould allow them to cook several pounds of meth at a tim e. CS-4 advised he/she w ould personally cook approxim ately 2 lbs. of m etham phetam ine per week. CS-4 related that they were cooking m ultiple pounds at various sites. CS-4 stated it took approxim ately two to three days to complete a cook that would yield

58 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 59 of 106 Pageid#: 62

several pounds. M ULLINAX was the largest dealer and the best cook with m ost of his m eth being nearly 100% pure. CS-4 stated M ULLINAX introduced him/her to Rusty CASSELL in the fall of 201 1 . CS-4 stated in the fall/winter of 201 1 he/she and M ULLINAX were getting approximately four (4) ounces of meth per week from CASSELL. CS-4 stated this continued for approximately five to six m onths.

On M arch 8, 2013 CS-4 placed a recorded phone call to M ULLW AX at telephone number (276) 706-2972 for the purpose of purchasing methamphetamine. CS-4 asked M ULLINAX how much he could get. M ULLINAX stated it depended on how m uch m oney CS- 4 had. CS-4 said maybe an 8 ball (3.5 grams). M ULLINAX said there ain't no deal, you know that don't ya? M ULLINAX said it will have to be in the evening when he can do it. CS-4 said to give him a call and they'll do it. M ULLINAX replied that he will give CS-4 a call.

On M arch 11, 2013 CS-4 contacted MULLINAX at telephone number (276) 706-2972 for the purpose of purchasing one-half (%) ounces of methamphetamine. The following text messages were exchanged between CS-4 and M ULLINAX.

CS-4 to M ULLINAX, QGWill 1 have 2 take money with vc'' CS-4 to M ULLINAX, içll'ow long does it take you? It 's a lot ofmoney.l' M ULLW AX to CS-4, iiAll 1 hav rite ntpw ispersonal't M ULLINAX to CS-4, *çblow much'' CS-4 to M ULLINAX, ûsl) of' M ULIN AX to CS-4, Giilon 't kat?w wJ/ u r talking about I thought wc wtz.ç talking about m oney5: CS-4 to M ULLINAX , ië1000'' M ULLINAX to CS-4, Gçuqbout 2 or 3 hr tops.', CS-4 to M ULLW AX , Giïïrhen couldyou do jf'' M ULLINAX to CS-4, CIFt?.S f got a ride il let u i'ntlw it be ths eveninf' CS-4 to MULLINAX, inls itjustyou going? Ft/N want me to ride with you or 1 can give you a ride. Myfkiends aren 't wanting that much money to go thatfar. FJ know what im saying/'' M ULLINAX to CS-4, *iWi1l thtsfne 1 understand letsjst 4get about thn I cant tak nol cause 1 hav to ride with a certinperson ok but 1 ant never rI> anyl dr u no tht'' According to the records of Verizon W ireless, telephone number (276) 706-2972 was resold to TracFone w ith no subscriber inform ation available. This was the telephone num ber by which CS-4 contacted M ULLINAX in the aforem entioned telephone calls. As a result of this investigation, your affiant believes that the prim ary user of this phone num ber was Jason M ULLINAX.

On M arch 22, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephones, including that utilized by Roger LAW SON . ln response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accounts from February 23 to M arch 22, 2013. The following is an excep t from the search warrant results.

59 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 60 of 106 Pageid#: 63

February 27,2013

Jason M ULLINAX to Roger LA W SON, **Do u need to com c me?'' LAW SON to M ULLINAX, i*1 do but I need to borrow some money until Fri. Please about 50,' LAW SON to M ULLINAX, iGliey can u help ?pe?'' M ULLINAX to LAW SON, ççu need it til Fri.?'' LAW SON to M ULLINAX, isad I may not even have gas to make to ur house', M ULLTNAX to LAW SON, çilhav to askher il c her at 7J'' LAW SON to M ULLINAX, Giok, let me know asap.',

M U LLINAX to LAW SON , Gishe said no Rog couse wp mite hav to go bak zmorrow. Sorry budl wod fit wtz,& mine.'' Based on m y training and experience, and my knowledge of this investigation, I believe that Jason M ULLINAX utilized the text m essaging service on his cellular telephone to comm unicate with Roger LAW SON regarding the sale of m ethnmphetam ine. I believe that LAW SON asked M ULLINAX to front the metham phetam ine to LAW SON until Friday, but Gina Lopez, the source for the metham phetam ine and M ULLINAX' girlfriend, did not agree to do so.

M arch 7 - 9, 2013

Roger LAW SON to Jason M ULLW AX, çLc'an u help me tonite'' M ULLINAX to LAW SON, GoGina 's'' LAW SON to M ULLINAX, **Be there shortly''

Based on my training and experience, and my knowledge of this investigation, 1 believe that Jason M ULLINAX utilized the text m essaging service on his cellular telephone to com municate with Roger LAW SON regarding the sale of m ethamphetamine. 1 believe that LAW SON asked M ULLINAX if he had any m ethamphetam ine, and M ULLINAX told LAW SON that he would have to com e to Gina Lopez' residence.

M arch 12, 2013 Jason MULLINAX to Gina Lopez, ièDid u happen to Ieave thous 7 Iug nuts tht wod notflt here? 1 /cntpw soml who can use thml N(?w/'' Lopez to M ULLINAX , *iNo'' Lopez to M ULLINAX , ttzzlwc ur so sweetl They re expnsive... lug nuts/l Really/l'' M ULLINAX to Lopez, iilst a old# iend who ask me not to tell anyl his secrects. lsaid 1 wtptf not. I dident tell him any ofmine or your secrectsl''

M ULLINAX to Lopez, çocan i tell him tz-/ier lunch to come c mel'' Lopez to M ULLIN AX , iiAsssss. 1 knew it wtz.ç a dumb question... u dnt have to go on bout i J .1 ' 1 Lopez to M ULLINAX , **L ug nuts?.l?I?1?1?'' Lopez to M ULLINAX, **1 dont care wht u tell ''him ''111 They re so expensive',

60 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 61 of 106 Pageid#: 64

Lopez to M ULLINAX, GcWsntplannin return frpl/ til wetf But sure thanks love. Call Jtzy' M U LLINAX to Lopez, tsl'c,v lug nutsl He broke some yesterday replacing his tires. I told him 1 had 7 maybe morjst laying around but tht he coud hav 7for surefor 8 bucks'' Lopez to MULLINAX, Gilforgot 1 had those chrome babies! Good thinkin love. Thing is 1 had a 6 lug wheel. Prob 7 bucks... not much less ths time''

Based on m y training and experience, and my knowledge of this investigation, 1 believe that Jason M ULLm AX utilized the text m essaging service on his cellular telephone to ascertain from Gina Lopez if she had seven (7) grnms of methamphetpmine (Cslug nuts'') to sell to a customer of MULLINAX' for $800.00 (i$8 bucks'). l believe that Lopez agreed to sell six (6) gram s of metham phetam ine for $700.00 to M ULLINAX' customer.

M arch 13, 2013

Gina Lopez to Jason M ULLINAX, içWhat thepoint. J/'I/ wanted to b w me. U wouldn 't hve gone to the trouble ofhurting myfeelings by drivin ur appy ass to c Bubba n Shanno n #///y'' Lopez to M ULLINAX, iipleasejust do me afavor n bring tht stuffhere. Please pleaae. 1 don 't wanna burden u with having to c me tom. 1'm vpry serious. Please'' Lopez to M ULLINAX, ç*L eave it n the glove box. J/'j/ 's aprob. 111 come now. I've had MT/V'' Lopez to M ULLINAX, iilloes it make u# el better to turn ir godamnexphne om Fuck u keep the godmn money. Imfucled n e wtzl/'' M ULLINAX to Lopez, âL1 don 't want the ?nt/ncy./'' Lopez to M ULLFNAX, çiur not worth it kedp th shir 300. 00 is nothing when ur bout to loose ur truck. Ftz/lw caee Jason. Don 't contact me rcrDtf'

Based on m y training and experience, and my knowledge of this investigation, l believe that Gina Lopez was upset with Jason M ULLINAX for dealing with Bubba BUCHANAN and others. 1 believe that Lopez asked M ULLINAX to return either the m etham phetam ine or the money that he owed to Lopez.

M arch 14, 2013

Gina Lopez to Jason M ULLINAX , iiso reckon y buhda is circling myplace? I'FJIJ/J oing on Jason', M U LLINAX to Lopez, Sslr'/?y is Jltpw u kntpw its /?j?z7?'' M ULLINAX to Lopez, *GWat??? Your bs >:/'' Lopez to M ULLW AX, GQM itchell conhrmel' Lopez to M ULLINAX, çi. . .lma wlvc hisfuming ass on n nextpass'' Lopez to M ULLINAX, (trctz ul getyourselfcut tpf/'' Based on m y training and experience, and my knowledge of this investigation, I believe that Gina Lopez told Jason M ULLINAX that ''Buddha'' (Timothy GERACE) was spying on

61 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 62 of 106 Pageid#: 65

them . I believe that Lopez threatened to lead GERACE to M ULLINAX who would be Escut ofp' from GERACE'S m ethamphetam ine.

M arch 17, 2013

Toby M OCK to Roger LAW SON, ûCFI?!/ gona go to the market today?bnlnoby .')'' LAW SON to Danny REECE, çGzqre u l'n D F()wn.'' LAW SON to Gina Lopez, GGklight have to hollar at u little later.t' Lopez to LAW SON, ioBefore 8... illprob b at Jasonst' Lopez to LAW SON , iD o u wann meet me n a bit'' LAW SON to Lopez, *%L et me make a call. Call u right O ck'' LAW SON to Lopez, tûFC.S f do need to c u before u go to Jasons.'' LAW SON to Lopez, ç*D o u want me to come to u or u stop at Kennys. ?'' Lopez to LAW SON, i%1 m gonna b bout hafhour but JCJ.A to come to glade.. 1'm at Jasons. 1 'll call u n good #/'/ n c where u r. Stressingprob wtp?y t b xtra...'' LAW SON to Lopez, QiOk.''

LAW SON to Lopez, iil'm here how long'' Lopez to LAW SON , ii1 min'' LAW SON to Lopez, $$A'''

Jason M ULLINAX to Lopez, çGBabe Red n M iranda came w Bub'' Lopez to M ULLINAX, Giok 11 b rf/e thr''

Based on my training and experience, and my knowledge of this investigation, l believe that Roger LAW SON utilized the text messaging service on his cellular telephone to receive an order of m ethamphetamine from Toby M OCK . l believe that LAW SON attempted to obtain the methamphetamine from Dnnny REECE, then contacted Gina Lopez when REECE was unavailable. I believe that eventually, LAW SON obtained the m etham phetam ine from Lopez. I believe that while Lopez was selling the metham phetam ine to LAW SON , Bubba BUCHANAN , Steven Taylor (aka

M arch 18, 2013

Roger LAW SON to Jason M ULLINAX, Gkuqre u with Gina/', M ULLINAX to LAW SON, Lilam rite ?7t?wz'' LAW SON to M ULLINAX, Gi1 dnt think she can, but will u ask her fshe can help ?ne.'' M ULLINAX to LAW SON, GGvb'he ctzn/'' LAW SON to M ULLINAX, L*Ok //7Jn/o'.''

The aftiant believes M ULLINAX utilized the aforementioned text m essages to coordinate dnzg transactions with CS-4, Gina Lopez and Roger LAW SON .

On April 1 1, 2013 Angela SURBER was interviewed in Bristol, Virginia. SURBER stated Jason M ULLIN AX was a user of methamphetamine and was supplied by BUDDHA.

62 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 63 of 106 Pageid#: 66

On M ay 8, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephone numbers, including those of Darmy REECE, Rick SHAW and Roger LAW SON . In response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accounts from April 26 to M ay 8, 2013. The following is an excerpt from the search warrant results.

April 30, 2013

Jason M ULLINAX to Roger LAW SON, iiliave u talked to em yc/?''

LAW SON to M ULLINAX, iGstill /r.yj?7'' M ULLINAX to LAW SON, $$0/c''

M ULLINAX to LAW SON, tû-dn.p word/'' LAW SON to M ULLINAX, QiNope.'' M ULLINAX to LAW SON, çil)o u think it will happen.J'' LAW SON to M ULLINAX, Qi1 guess it could but 1'm getting awfully tired.'' M ULLINAX to LAW SON, Gih'fe 2. 1 coud have went somwer eles but soml told me it wtz,: closelt, LAW SON to M ULLINAX, ççWe1l he 's the only one 1 Fcntpw close.'' M ULLINAX to LAW SON, iiWell by goshl Wers it at? L OL '' LAW SON to M ULLINAX, içBeats me.''

Based on my training and experience, and m y knowledge of this investigation, I believe that Jason M ULLINAX utilized the text m essaging service on his cellular telephone to contact Roger LAW SON in an attempt to obtain m ethamphetam ine.

Roger Alan AUSTIN, Jr. Roger Austin has prior convictions for the manufacture of methamphetamine, perjury along with prior arrests for simple possession of cocaine, manufacturing cocaine, possession of cocaine with intent to sell and deliver, possession of drug paraphernalia, possession with intent to sell and deliver marijuana, maintaining a vehicle for storage and sale of controlled substance, receive firearm stolen or aid in concealing and possession of a firearm by a non-violent felon.

According to the records of Verizon W ireless, telephone number (336) 465-4993 was a prepaid cellular telephone with no subscriber inform ation available. According to the following text m essages, the user of this telephone was itRoger''. As a result of this investigation, your affiant believes that the primary user of this phone number was Roger AUSTIN . (On December 4, 2013, Brandi DUNFORD was interviewed in Bristol, VA. DUNFORD stated that Roger AU STIN was a m ethamphetam ine distributor and his cellular telephone number was (336) 465-4993.) On M arch 22, 20 13, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephones,

63 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 64 of 106 Pageid#: 67

including that utilized by Roger LAW SON. ln response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accounts from February 23 to M arch 22, 2013. The following is an excerpt from the search warrant results.

M arch 2, 2013

Rachael PEAKE to Roger LAW SON , Gilguess I aint going cuz 1 don 't have but 500 unless u can come up with anything in next 30 min 1 tried getting rent early even told her 1'd take tpf/-/pp fshe 'dpay early Roger ad won '/ help he suck balls'' Based on m y training and experience, and m y knowledge of this investigation, 1 believe that Rachael PEAKE utilized the text m essaging service on her cellular telephone to advise Roger LAW SON that Roger AUSTIN would not loan money to PEAKE for the purchase of m ethamphetam ine.

M arch 18, 2013

Roger AUSTIN to Roger LAW SON, iilts Roger canyou give me a callplease.'' AUSTIN to LAWSON, iilfyou are out and about can you bring that by here 1 need to talk to you to thanks'' LAWSON to AUSTIN, LQBe before too long.', AUSTIN to LAW SON, iiHave you heard anythingh'om anybodyyet', LAW SON to AU STm , çiNo', AUSTIN to LAW SON, içcan you call Rachel and see fshes can go'' Based on m y training and experience, and my knowledge of this investigation, 1 believt that Roger AUSTIN utilized the text messaging service cm his cellular telephone in an attempt to obtain metham phetam ine from Roger LAW SON. 1 believe that when LAW SON advised AUSTIN that he could not get in touch with the sottrce of supply, AU STIN suggested sending Rachael PEAKE to pick up methamphetamine.

M arch 20, 2013

Toby M OCK to Roger LAW SON, iilhosejïiends ofRogers are wantingh'om the market 4/z/ r going. Said they could b here by 6 with l40 fu could LToby:)'' LAW SON to M OCK , dtrc.s but let me make sure.'' M OCK to LAW SON, iiOkLToby.)'' M OCK to LAW SON, iilnhey may want fwt? ofthem...soon as u no text me so 1 can let Roger noàlbby:l''

Roger AUSTIN to LAW SON, iilhey will be here in 25 minutes with 280 dollars''

Based on m y training and experience, and my knowledge of this investigation, I believe that Toby M OCK and Roger AUSTW utilized the text messaging service on their cellular telephones to order metham phetam ine from Roger LAW SON for AU STW 'S drug customers.

64 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 65 of 106 Pageid#: 68

M arch 21, 2013

Roger AUSTIN to Roger LAW SON, i;Ft?z/ going to have any cabbage this weekend maybe 240for 300 bk'' LAW SON to AUSTIN, iGllnt Iook like it. Sorry. Iflbbys there, tell her to call zz7c.'' AUSTIN to LAW SON, Goshes asleep fshe gets up 1 will have her callyou thanks Rog ff you do I get my cash on the 28

Based on m y training and experience, and my knowledge of this investigation, 1 believe that Roger AUSTIN utilized the text messaging service on his cellular telephone to request a loan from Roger LAW SON .

On M ay 30, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephone num bers, including those of Danny REECE, Roger LAW SON and Toby M OCK. ln response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accounts from M ay 13 to M ay 30, 2013. The following is an excerpt from the search warrant results.

M ay 19, 2013

Roger AUSTIN to Toby M OCK, Gnlnhey got some shit in boone lsware its the best 1ve done sincepeanut butter in 2000 second hityou sweating they came down to see me Im Iike dam raln'' M OCK to AUSTW , QçHellfar lol...that would b nice jntoby .)'' AUSTIN to M OCK, çnlfl get my bkpayyall will see me plus 1 got to go to Memphis 4 a wcc/c 11 have a rlcw car I stop by tp/c''

Based on my training and experience, and my knowledge of this investigation, l believe that Roger AUSTIN utilized the text m essaging service on his cellular telephone to advise Toby M OCK that he had found som e really good m ethamphetamine in Boone, N C. I believe that AUSTIN advised M OCK that when he had the m oney, he was going to bring the methamphetamine to SW VA for her to try.

M ay 24, 2013 Toby M OCK to Roger AUSTIN, iolloes Angelic have aphone ... fso text me her number #leasebntoby .')'' AUSTIN to MOCK, t(f dont have anything to do with her since she rl/pt?l me offerased her number and aI1 fynu talk to her tell her to burn in hell''

M OCK to AUSTIN, *GLol 1 will she wtz,$ with Willie last nite an he rtpped me ta-f/'g the only reason 1 wtzy wantn her numberjntoby .)'' AUSTIN to M OCK, 612762746333'% AUSTIN to M OCK, GGcan you get rid ofa couple dogs 4 me'' M OCK to AUSTIN, çnlkrhat kindbfdogs r theyjntoby .)''

65 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 66 of 106 Pageid#: 69

AUSTIN to M OCK, iilhere ears hadnt been cutyet't M OCK to AUSTIN, 1i# u coming here/jntoby .)'' AUSTIN to MOCK, i*1 can fyou can do your f/cïng'' MOCK to AUSTIN, â*I can ... f cant wait to c ?z.?/ It wont take me long lt?/n# em a home

eitherjntoby .z)'' M OCK to Adam LNU, ;iCalI me w:n u get a minàntoby .')'' M OCK to AUSTIN, çiK do u have pups ncw? Ijus getn a eta so I can let my buddy nobntoby .')'' Adam LNU to M OCK, çivb'up get 0ff330'' MOCK to Adam LNU, içWell I can mayb help ya today /z/ want ne Lntoby .'/'' M OCK to Adam LNU, GD id u want ne? 1ts on it wJy and should b here bfore u get here t/'l? decide u wJn/ nebntoby .)'' Adam LNU to M OCK, ièl-lellya say'' M OCK to Adam LNU, ii# ... 1 wont b home till round 5 or so 1 will text wen 1 bak homejntoby .)'' Adam LNU to M OCK, ènoh u gonna have j/r' M OCK to Adam LNU, içïreabntoby .)'' AUSTIN to MOCK, iiok Jlt?w many dogs you got rid V ' M OCK to AUSTIN, Givjt Ieast 3 r u gona come on .. I ned to tell em something Lntoby .'/'' AUSTIN to MOCK, QGBe there in afew about JJ'' M OCK to AUSTm , iiK jntoby :)'' M OCK to Adam LNU, *G1 b home n bout 45mins 1 will callya wcp lget therjntoby .',)'' MOCK to AUSTIN, **B careful but hurry they chomping at the bit lol. Lntoby :)'' M OCK to Adam LNU, ççllid u stil want ne/jntoby .')'' MOCK to Bubba BUCHANAN, tk& offfrm workyetljntoby .)'' Adam LN U to M OCK , Liu got enought'

M OCK to AU STIN, Gilley r ya close? jntoby .',)''

Based on my training and experience, and my knowledge of this investigation, I believe that Roger AUSTIN utilized the text m essaging service on his cellular telephone to provide a telephone number for Angelic Counts to Toby M OCK. l believe that AU STW told M OCK that Counts had stolen m ethamphetam ine from him . 1 believe that M OCK advised AUSTIN that W illie Blevins had stolen m ethamphetam ine from her, and Counts was with him . l believe that AUSTIN requested M OCK to find customers for uncut methamphetamine (dçdogs''), and M OCK sold 3 gram s to Adam LNU . 1 believe that M OCK then attempted to contact Bubba BUCHAN AN to sell additional m etham phetamine for AUSTIN .

On Decem ber 4, 2013, Brandi DUN FORD was interviewed in Bristol, VA. DUNFORD stated that Roger AUSTIN and Toby M OCK were distributors of crystal metham phetam ine. DUN FORD stated that she had been involved with up to 15 ounces of metham phetamine at a tim e, as well as tens of thousands of dollars in drug proceeds. DUN FORD stated that the crystal

66 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 67 of 106 Pageid#: 70

m etham phetam ine with which she was involved had a bluish tint. DUNFORD stated that she had purchased m ethamphetam ine from AUSTm on m any occasions. DUNFORD stated that AUSTIN had approached her about selling m ethamphetam ine for him . DUN FORD stated that AUSTIN'S cellular telephone number was (336) 465-4993.

On M arch 8, 2014 Jeanne Sult w as arrested by Officer Eades of the M arion, Virginia Police Departm ent for shoplifting. During the arrest Sult was found to be in possession of approxim ately one half to one gram of crystal m etham phetam ine, a syringe, and a glass sm oking device. Sult stated to officers that she had purchased the m ethamphetmnine from Roger AUSTIN who was staying in the Virginia House M otel in M arion, V irginia and was distributing otm ces of metham phetam ine he obtained from North Carolina. On M arch 10, 2014 officers from the M arion Police Dept. and Smyth County Sheriff s Office spoke with Virginia House m anagement who confirm ed AUSTIN was a registered occupant of the m otel. Officers then traveled to the Virginia House and located AU STIN. AUSTFN allowed officers to enter the room but when officers asked for consent to seazch the room for illegal drugs AUSTIN told the officers they needed a search warrant. No search was conducted of the room .

On M arch 31, 2014 Jeanne SULT was interviewed in Abingdon, Virginia. SULT stated through personal conversations with AUSTIN she believed AU STIN was a dealer of metham phetamine and was supplied by Tim aka çfBuddha''. SULT stated Buddha looked like dtM ario'' the Nintendo gam e character. Buddha has previously been identified as Tim othy GERACE of 4970 Highway 91 N M ountain City, TN. SULT stated on two separate occasions in the past year she had been present at Nathan HALL'S lake house apm m ent in Abingdon when GERACE brought HALL % ounce of crystal m ethamphetam ine. SULT added GERACE was driving a beat up Jeep Cherokee.

Tim othy Brian GERACE aka RBUDDHA'' Tim othy Gerace has prior arrests for 3 rd d egreeburglary: illegal entry with intent to com mit a crim e, grand larceny, possession of a controlled substance, unlawful possession of a weapon by felon, aggravated burglary, and assault.

On January 30, 2013 CS-4 was interviewed in Bristol, Virginia. CS-4 stated he/she had cooked methamphetamine for ûSBUDDHA'' 5subsequently identified through photographs as Tim othy Brian GERACE. CS-4 stated he/she had used m ethamphetam ine with GERACE, and had sold methamphetamine for GERACE. CS-4 stated GERACE was a distributor of metham phetam ine in M ountain City, TN as well as in W ashington and Smyth Counties in Virginia. CS-4 stated he/she m et GERACE at Rusty CA SSELL'S residence in February 2012. CS-4 stated GERACE was supplying m eth to CASSELL at the tim e. CS-4 stated shortly after being introduced to GERACE he began going straight to GERACE to obtain metham phetamine. CS-4 stated in February 2012 he/she was present at CASSELL'S residence in W ashington County Virginia when GERACE brought m eth to CASSELL. CS-4 stated he/she saw GERACE hand CASSELL a quantity of meth. CS-4 added he/she shot up a needle of the meth im mediately afterwards. CS-4 stated the following day, he/she, Jason M ULLINAX , and CASSELL went to

67 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 68 of 106 Pageid#: 71

GERACE'S house in M ountain City, TN. CS-4 stated they spent the day sm oking m eth while he/she and GERACE talked. CS-4 stated in early to m id April 20 12 until July 4, 2012, he/she and GERACE would go to SHA W 'S residence located at 382 T Greer Road, M ountain City, TN approximately three tim es a week. CS-4 stated GERACE would call SHAW , they would then travel to SHAW 'S residence to do drugs. W hile present with SHAW , SHAW called people to com e to his house to pick up meth. CS-4 also advised he/she and GERACE would go out and sell meth for SHAW . CS-4 stated on one occasion he/she witnessed GERACE take $10,000.00 cash to SHAW 'S residence and observed GERACE personally hand the cash to SHAW . CS-4 related that he/she had also seen firearm s at SHAW 'S residence.

CS-4 stated between the approximate dates of April 2012 to July 2012 GERACE was providing meth to the following individuals:

Tim FIELDS. $2,000.00 cash at a time approximately two times a week. Rusty CASSELL (month or two later, CASSELL quit purchasing from GERACE). Bubba BUCHAN AN . Obtaining % ounce at time. Stephanie LNU (believed by your affiant to be Stephanie PATRICK). 1 ounce a week ($2700.00). Toby M OCK Angela SURBER (moving 1 otmce a week) On January 31, 2013 law enforcem ent contacted CS-4. CS-4 stated they had recorded phone conversations and a m eeting with GERACE. CS-4 stated dlzring the meeting GERACE offered them m etham phetam ine and a needle which they declined. GERACE discussed his drug trafficking activity, stating that things have slowed down and he is moving only % pound of metham phetam ine a week.

CS-4 stated that GERACE'S cellular telephone number was (423) 471-1541. According to the records of Verizon W ireless, telephone number (423) 47 1-1541 was subscribed to by Jeremy Gerace at 4970 Hwy. 91 N , M ountain City, TN. As a result of this investigation, agents believe the prim ary user of this telephone was Tim othy GERACE.

On January 3 1 , 2013 and February 2, 2013 CS-4 met with GERACE. W ords to the effect of the following were stated:

CS-4 talked about getting back into business with GERACE. GERACE said he wanted to m ake sure that is what they want to do. GERACE asked what they want to do. CS-4 asked GERACE for some shit (meth) to give Rebekah, a roommate from rehab as part of a nzse to obtain a quantity of m eth at the direction of law enforcem ent. GERACE recomm ended buying the m eth at first and then once they get on their feet then making it. GERACE said he will not m ake any protit but if they want to m ake m oney they would need to sell for $14,000. CS-4 said they need to make money fast. GERACE said he will come up with som e money. CS-4 asked how m uch GERACE paid for a half pound. GERACE stated he is paying $14,000 and the CI

68 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 69 of 106 Pageid#: 72

will need to charge $18,000 to m ake any m oney. GERACE said this dope will be com ing from M exico. CS-4 asked if it is the cartel. GERACE says yes, my neck is out there. GERACE told CS-4 that once he m ade the order he cnnnot back out. W hen he picks it up he has to be able to cover it. GERACE said he has lots of guns, a11 kinds, you nam e it, 1 have it! 1 bought a shitload. I have bought probably seventy (70) of them. I have been buying lots of gold, al1 kinds of shit, 1 trade for it. M ost are handguns, one shotgun. The CS asked if he has any S& W or any lady S& W . GERACE says he has several .38's.

Between the dates of Febnzary 4, 2013 and February 7, 2013 CS-4 m et with GERACE. W ords to the effect of the following were stated:

CS-4 asked GERACE about SHAW laundering m oney and how he did that. GERACE explained: SHAW finds people, you know you can't put that money in your bank account, you can only put so m uch away and save som e stuff. W hat you do is buy land, find someone who has good collateral, they buy the land, you give them the m oney and pay it off a little at the tim e, nothing more than $4,800.00, anything more than that sends up a flag. Or you buy a business with another person and put the m oney into the business and then get it back clean. GERACE says he knows a guy up north who has over 20 businesses and moves his coke and pot m oney through them. When l work a real job I make good money, $80,000-100,000 a year. That way l can m ake extra money and hide it like that. I bought this and that and prove it when I have a real job. I had a lot of extra money in the box but being off the last two years ttfucked me''. lt was fun but 1 am going to have to go back to work.

Between the dates of February 13, 2013 and Febnzary 16, 2013, CS-4 m et with GERACE. W ords to the effect of the following were stated:

GERACE said the dûlaw'' has been over at his house. GERACE said they (the police) are supposed to come back with a warrant. GERACE said: i11 will be fucked''. GERACE told them (the police) that if they want to come in here you need a wartant. CS-4 asked GERACE if he has anything (meth) in there. GERACE says isoh yeah, we are sitting good.

On April 3, 2013 CS-5 was interviewed in Bristol, Virginia. CS-5 stated from October 2012 through the first of December 2012 he/she met with GERACE no less than ten to fifteen times. Each time CS-5 received at least one-half (1/2) ounce of meth and paid GERACE $1000.00 per half ounce fronted each time. CS-5 met GERACE at his house/garage in M ountain City, TN on several occasions. At GERACE'S garage/shop CS-5 described seeing GERACE with a brick of methamphetamine (ice). CS-5 described the brick as approximately 8 to 10 inches long, 4 to 6 inches wide and 2 inches thick, a1l wrapped in clear cellophane, which he believed to be a kilo of m eth. On one occasion CS-5 stated GERACE had a garage cart that was approximately 2 feet wide and 3 feet long, having three shelves. Each of the shelves was full of these bricks of m eth that are believed to be kilos or pounds. CS-5 said he did not know how many were on the cart but it was a lot (50 plus). CS-5 keeps 8 balls (3.5 grams), ounces, etc. . .measured out in a small duftle bag that is kept in his jeep or car. GERACE also keeps a sm all bag of m eth for personal use in his gas tank cover of the vehicle he is driving. GERACE gloats that he has been stopped and searched several tim es and they have never found his stash. 69 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 70 of 106 Pageid#: 73

CS-5 stated that GERACE usually keeps a pistol in the back of his Jeep or car near the duftle bag of meth.

CS-5 stated that while dealing with GERACE, GERACE took him to Tiffany South's trailer five to six times to drop off cash. CS-5 stated that GERACE would stop by and tell SOUTH he needed to put the cash in the safe. On one occasion CS-5 stated that GERACE counted out $25,000.00 and told SOUTH we need to put this in the safe now.

On April 3, 2013 CS-4 purchased an eight-ball (3.5) grams of methamphetamine from Tim othy GERACE aka BUDDHA along Taylors Valley Road in M ountain City, TN.

On April 11, 2013 Angela SURBER was interviewed in Bristol, Virginia. SURBER stated approxim ately one year ago she was introduced to a man she called çcFred'' whose real nam e was Tim LNU out of M ountain City, TN. Through photographs provided by law enforcement, SURBER identified the m an she called (kFred'' as Timothy GERACE. SURBER stated GERACE started com ing to her and Toby M OCK 'S apartm ent everyday with (2) two to (4) four grams of meth for each of them to distribute. SURBER stated she sold every bit of meth she could just to eat. This continued for approximately three months until she moved to M arion, Virginia and rented a place from Rachael PEAKE. SURBER stated GERACE sold her meth for $ 1 10 per gram which was high and did not allow her to make much money off of it. SURBER stated the last time she saw GERACE was approximately two weeks ago (late M arch 2013) when GERACE brought her seven (7) grams of meth. SURBER added she paid GERACE $700.00 for the meth and she kept m ost of it for personal use, SURBER stated she dealt m ethamphetam ine to several individuals to include Rachael PEAKE, Devanna Bordwine, Toby M OCK and Bubba BUCHANAN . SURBER allowed agents to review infonnation contained within her cellular telephone. Saved under the name SkFred'' was telephone number (423) 471-1541. SURBER identified kçFred'' as Tim othy GERACE.

On August 16, 2013, a search warrant was executed at 19012 Lake Rd., Abingdon, VA , the residence of Nathan HALL, Brandi DUN FORD, W illiam HUN T, Jr. and others. Seized from the apartment of HALL and DUNFORD was a m ethamphetam ine lab. Subsequent to the search warrant, HALL, DUNFORD and HUNT were interviewed separately, HALL stated that he obtained his methamphetamine prim arily from CSBUDDHA'' aka Tim GERACE. HALL stated that GERACE was responsible for the majority of methamphetamine in SW VA. HALL stated that GERACE had been providing methamphetamine to SW VA for approximately two (2) years. HALL stated that GERACE usually brought % ounce to one (1) ounce of metham phetam ine at a tim e and dropped it off with his customers in VA . HALL stated that on August l4, 2013, GERACE brought over two (2) ounces of methamphetamine and lefl it with Billy Frank BUCHANAN and a fem ale. HALL stated that he was expecting GERACE to arrive at any m inute with m ethamphetam ine for HALL. HALL stated that GERACE'S other customers included ûdBig Angie'' (SUIIBER), Brady LESTER and Shnnna M ooretield.

70 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 71 of 106 Pageid#: 74

On Decem ber 4, 2013, Brandi DUN FORD was interview ed in Bristol, VA. DUNFORD stated that Tim GERACE, aka ECBUDDHA'' was the crystal m ethamphetam ine sotuve of supply to Nathan HALL. DUN FORD stated that from M ay to August 2013, she observed GERACE deliver approximately one (1) ounce of methamphetamine per day to HALL at the tçlwake House'' (W illiam HUNT, Jr.'s property). DUNFORD stated that she observed GERACE deliver up to two (2) ounces at a time. DUNFORD stated that she observed GERACE in possession of a gallon sized freezer bag full of methamphetam ine at the Gdlxake House''. DUN FORD stated that one of GERACE'S cellular telephone numbers was (423) 471-1541.

DUNFORD stated that she had accompanied GERACE while he delivered metham phetamine to drug custom ers in Konnarock, VA . DUNFORD stated that she received approximately one (1) ounce of crystal methamphetamine from GERACE approximately two (2) weeks ago and still owed him m oney. DUN FORD stated that she sm oked m ethamphetam ine with GERACE, Shanna M oorefield and others approximately one (1) week ago.

On M arch 31, 2014 Jeanne SULT was interviewed in Abingdon, Virginia. SULT stated through personal conversations with Roger AU STIN she believed AUSTIN was a dealer of m etham phetamine and was supplied by Tim aka CtBuddha''. SULT stated Buddha looked like ççM ario'' the Nintendo gam e character. Buddha has previously been identised as Tim othy GERACE of 4970 Highway 91 N M ountain City, TN. SULT stated on two separate occasions in the past year she had been present at N athan HALL'S lake house apartm ent in Abingdon when GERACE brought HALL IX ounce of crystal m ethamphetam ine. SULT added GERACE was driving a beat up Jeep Cherokee.

Throughout the course of this investigation, text messages were received via search warrant on telephone number (423) 47 1 -1541, which was utilized by Timothy GERACE. Excerpts from the data collected have been incorporated within this affidavit under the headings of the co-conspirators with whom GERACE comm unicated.

Angela SURBER

Angela Surber has prior arrests for possession of a schedule 1, 11 controlled substance and drugs: distribute/sell for profk schedule I or 11 substance.

On M ay 16n 2012 law enforcement conducted a controlled purchase of one (1) gram of metham phetam ine from Angela SURBER in Smyth County, Virginia in the W estern District of Virginia.

On M ay 2 1, 2012 law enforcement conducted a controlled purchase of one (1) gram of metham phetam ine from Angela SURBER in Smyth County, Virginia.

On January 30, 2013 CS-4 was interviewed in Bristol, Virginia. CS-4 stated between the approximate dates of April 20 12 to July 2012 GERACE was providing approximately one (1) ounce of meth per week to SURBER.

71 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 72 of 106 Pageid#: 75

Between February 4, 2013 and February 7, 2013 CS-4 m et with GERACE. During a conversation with GERACE, GERACE stated Angie (Angela SURBER) is working for him and m oving a % ounce per week.

According to the records of Sprint, telephone number (276) 685-3847 was subscribed to by Jonah Tolbert at 13341 Country Living Ln., Glade Spring, VA . On April 1 1, 2013, Angela SURBER was interviewed in Bristol, VA and provided that telephone number as her contact num ber. A s a result of this investigation, agents believe that the prim ary user of this telephone was Angela SURBER.

On February 27, 2013, a search warrant was applied for and obtained in the W estez.n District of Virginia for text messages stored in the account of telephone number (423) 471-1541, the cellular telephone of Tim othy GERACE. ln response to the execution of this search warrant on Verizon W ireless, agents Jeceived text messages stored in that account from January 26 to February 27, 2013. The following is an excem t from the search warrant results.

January 25 - 26, 2013

Angela SURBER to Tim GERACE, Snllid u get that'' SURBER to GERACE, QGlhe door is unlockedfor ya't GERACE to SURBER, **Ok't

Based on m y training and experience, and my knowledge of this investigation, I believe that Angie SURBER utilized the text messaging service on her cellular telephone to order methnmphetam ine from Tim GERACE.

January 31,2013

Timothy GERACE to Angela SURBER, ièuqre you up yc/?'' SURBER to GERACE, çck-eah 1 been up 1'm getting readyyo ho to wtprk here in Jx w m iN'% SURBER to GERACE, çiok it's in there now''

Based on m y training and experience, and my knowledge of this investigation, 1 believe that Angie SURBER utilized the text messaging service on her cellular telephone to advise Tim GERACE that his m oney was available to be picked up.

February 1, 2013

Tim othy GERACE to Angela SURBER, içWhats up'' SURBER to GERACE, iil'm at work but 1 will have thatfor u when 1 get offwork had it 1)4 but wo/c: up late't GERACE to SUM ER, Gçlts all .gotptf'

SURBER to GERACE, çGok well we can meet u tz-/ipr w/r/c u can come by up to u'' SURBER to GERACE, inlley 1'm offwork we getting on interstate ntpw should b home in 15 min so f/'Z/ want me to meet u let me /cnt/w so wc can come while we out''

72 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 73 of 106 Pageid#: 76

Based on my training and experience, and m y knowledge of this investigation, I believe that Angie SURBER utilized the text m essaging service on her cellular telephone to advise Tim GERACE that his m oney was available.

February 2,2013

Tim othy GERACE to Angela SURBER, ikW?'c you up'' SURBER to GERACE, Qnl'm up where u t#'' SURBER to GERACE, $iWell lgot to go to my dads today 1 wtu hopeing to c u b4 1 went its hard to tell /:tlw long they will keep ??7c'' SURBER to GERACE, iiplz call me as soon as u can 1 can 't get up to get what 1 got to get done today done I need ur /7c/p'' SURBER to GERACE, GGliey lgotta run to the store with J'l/tzyn: to get cigs r u close fya r 1 will wait on u b4 w: go'' GERACE to SURBER, çiNo'' SURBER to GERACE, Qiok 1 will go on to store then wc b back in afew min'' SURBER to GERACE, ç*1'm home door is unlockedforya 1'm on the couchprob b sleep or maybe watching /v''

Based on m y training and experiences and m y knowledge of this investigation, I believe that Angie SURBER utilized the text messaging service on her cellular telephone in an attempt to purchase methnm phetam ine from Tim GERACE.

February 10,2013

Angela SURBER to Timothy GERACE, içWell everybody and their mom and dads r calling me today 1 hope ya call me back tell me sumthan'' SURBER to GERACE, û*Well 1 guess wc r sol'' GERACE to SURBER, iilm trying'' SURBER to GERACE, içok Ijust wtl/cc up let me kntpw u can always lock it up in my CGr75

Based on m y training and experience, and my knowledge of this investigation, I believe that Angie SURBER utilized the text messaging service on her cellular telephone in an attempt to purchase m etham phetam ine from Tim GERACE for her custom ers.

February 17,2013

Angela SURBER to Timothy GERACE, *LPlz help me me and Wayne r split up I need sum help plz'' SURBER to GERACE, QâHave u llctzr# any good ncw.ç plz sayyes'' SURBER to GERACE, iiliey any ncwé''' GERACE to SURBER, QçNot yet'' SURBER to GERACE, **Ok well my car is still unlocked t/yl #t7''

73 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 74 of 106 Pageid#: 77

Based on m y training and experience, and m y knowledge of this investigation, I believe that Angie SURBER utilized the text m essaging service on her cellular telephone in an attem pt to purchase m ethamphetamine from Tim GERACE.

On April 3, 2013 CS-5 was interviewed in Bristol, Virginia. CS-5 stated that from October 2012 to November 2012 GERACE fronted SURBER two (2) ounces of meth per week. CS-5 stated in N ovember 2012 he/she and GERACE went to meet SURBER at her residence to pick up money. SURBER paid GERACE $1300.00 that she owed for previously provided meth.

On April 11, 2013 Angela SURBER was interviewed in Bristol, Virginia. SURBER stated she smoked methamphetam ine with Roger LAW SON at his house when he lived in Glade Spring, Virginia. SURBER added LAW SON had given her m ethnm phetam ine deliver to his daughter in the past. SURBER stated around 2009-2010 she m oved in with Danny REECE. SURBER advised after living with REECE for tw o m onths, REECE asked if SURBER would give him a ride to M ountain City, TN to obtain meth from Rick SHAW . SURBER stated she and REECE went to SHAW 'S to purchase meth approximately once a week for eight weeks. SURBER stated REECE obtained a téfistful'' size of m eth each tim e from SHAW . SURBER advised m ost of the deals with SHAW occurred at this house but one deal occurred at a property SHA W owned in Butler, TN . SURBER stated approximately one year ago (Spring of 2012) she was introduced to a man she called tçFred'' whose real nam e was Tim LNU out of M ountain City, TN . Through photographs provided by law enforcement, SURBER identified the m an she called SsFred'' as Tim othy GERACE. According to SURBER, GERACE came to her and M OCK'S apartm ent everyday with two to four gram s of m eth for each of them to distribute. SURBER stated she sold every bit of meth she could just to eat. SURBER stated the last time she saw GERACE was approximately two weeks ago (late- M arch 2013) when GERACE brought her seven grams of meth. She related that she paid GERACE $700.00 for the meth and kept most of it for personal use. SURBER stated she dealt m eth to the several individuals including Rachael Peake, Toby M ock and Bubba Buchmman. SURBER stated that her cellular telephone number was (276) 685-3847.

On August 16, 2013, a search warrant was executed at 19012 Lake Rd., Abingdon, VA, the residence of Nathan HALL, Brandi DUN FORD, W illiam HUNT, Jr., Jr. and others. Seized from the apartment of HALL and DUN FORD was a m ethamphetam ine lab. Subsequent to the seazch warrant, HALL, DUN FORD and HUNT were interviewed separately. HALL stated that he obtained his m etham phetamine prim arily from CCBUDDHA'' aka Tim GERACE. HALL stated that GERACE was responsible for the majority of m etham phetam ine in SW VA. HALL stated that GERACE had been providing methamphetamine to SW VA for approximately two (2) years. HALL stated that GERACE usually brought % ounce to one (1) ounce of methamphetamine at a time and dropped it off with his customers in VA .

74 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 75 of 106 Pageid#: 78

HALL stated that on August 14, 2013, GERACE brought over two (2) ounces of metham phetamine and left it with Billy Frnnk BUCHANAN and a female. HALL stated that he was expecting GERACE to arrive at any minute with methamphetamine for HALL. HALL stated that GERACE'S other customers included CdBig M gie'' (Angela SURBER), Brady LESTER and Shanna M oorefield.

Patricia Leann HALL

Learm Hall has prior arrests for trespass: afler being forbidden to do so.

According to the records of Sprint, telephone number (276) 492-58 19 was subscribed to by Patricia Hall at 507 Butt St. SW , Abingdon, VA. As a result of this investigation, your affiant believes that the prim ary user of this telephone was Patricia Leann HALL.

On February 27, 20 13, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the account of telephone number (423) 471-1541, the cellular telephone of Timothy GERACE. ln response to the execution of this search wanunt on Verizon W ireless, agents received text m essages stored in that account from January 26 to February 27, 2013. The following is an excerpt from the search warrant results.

January 26 - 27, 2013

Lennn HALL to Tim GERACE, *GCall me ASAP'' GEILACE to HALL, iGcall ?ne'' GERACE to HALL, tslfrcr: you J/?'' GERACE to HALL, GoWere you at/'' GERACE to HALL, Q*Were you J/?'' GERACE to HALL, iiWere you at?''

HALL to GERACE, çöWhat's Np3,' HALL to GERACE, i*Call Shanna ASAF '

January 29 - 30, 2013

HALL to GERACE, *iU round.J'' GERACE to HALL, GQujre you up'' HALL to GERACE, içk-ealt, GERACE to HALL, iV m ite stop iy''

HALL to GERACE, Lol-f'u r? Needs unlock'' HALL to GERACE, çnshana stil wont talk 2 me. ''

Based on m y training and experience, and my knowledge of this investigation, I believe that Leann HALL utilized the text m essaging service on her cellular telephone to com municate with Tim GERACE about locations (possibly for delivery of methamphetamine).

February 13 - 14, 2013

75 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 76 of 106 Pageid#: 79

Tim GERACE to Leann HALL, iiWere you at'' GERACE to HALL, ççWere you at'' HALL to GERACE, içlm home'' GERACE to HALL, Gil'o late'' HALL to GERACE, tûr '

Based on my training and experience, and m y knowledge of this investigation, l believe that Tim GERACE utilized the text messaging service on his cellular telephone in an attempt to determ ine Leann HALL'S whereabouts. 1 believe that by the tim e HALL responded, GERACE had sold out of m ethamphetam ine.

On M arch 22, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephones, including that utilized by Tim othy GERACE. ln response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accounts from February 24 to M arch 2 1, 2013. The following is an excerpt from the search warrant results.

M arch 3, 2013

Leann HALL to Timothy GERACE, GLliot companf' HALL to GERACE, iibley its Summer caI me ASAP''

M arch 11, 2013

HALL to GERACE, çu got bustd bout 6 amt'

Based on my training and experience, and m y knowledge of this investigation, l believe that Leann HALL utilized the text messaging service on her cellular telephone to com municate with Tim GERACE about co-conspirator Jason W idener, who was arrested on M arch 1 1, 2013 on drug related charges. l believe that HALL allowed a co-conspirator to utilize her cellular telephone to comm unicate with GERACE.

On April 3, 2013 CS-5 was interviewed in Bristol, Virginia. CS-5 stated that he/she m et Tim GERACE in early October 2012. CS-5 stated Learme HALL and another fem ale called him to the Alpine M otel in Abingdon and introduced him to GERACE and asked him to give HALL a ride to the hospital. GERACE gave CS-5 a 1/4 gram -l/z gram of m eth and $40 to drive HALL to the hospital. HALL refused to go, CS-5 returned to the m otel and GERACE provided him with another 1/2 gram of m eth and $20.

On December 4, 2013, Brandi DUN FORD was interviewed in Bristol, VA . DUNFORD stated that Tim GERACE, aka tCBUDDHA'' >was the crystal metham phetam ine source of supply to Nathan HALL. DUN FORD stated that she observed GERACE in possession of a gallon sized freezer bag full of methamphetamine at the iûlaake House'' (W illiam HUNT, Jr.'s property). DUN FORD stated that she had accom panied GERACE while he delivered metham phetamine to drug customers in Konnarock, VA. DUNFORD stated that she received approximately one (1)

76 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 77 of 106 Pageid#: 80

ounce of crystal methamphetamine from GERACE approximately two (2) weeks ago and still owed him m oney. DUN FORD stated that she was tlrst introduced to GERACE by Leann HALL approximately two (2) years prior. DUNFORD stated that one of HALL'S cellular telephone numbers was (276) 492-5819.

M ichael Brady LESTER

Brady Lester has prior convictions for manufacturing m ethamphetam ine, brandishing firearm as well as prior arrests for possession of prectzrsors to manufacttlre m eth, possession of schedule I or 11 substance and manufacture a schedule 1 or 11 substance.

On January 30, 2013 CS-4 was interviewed in Bristol, Virginia. CS-4 stated in 2002 he/she began using m ethamphetnmine with Brady LESTER, and Jason M ULLINAX. CS-4 advised that continued until 2003/2004 until he/she went to a drug rehabilitation center. CS-4 stated Brady LESTER cooked meth on his own, but also gave GERACE some of his meth on occasion.

According to the records of Verizon W ireless, telephone number (276) 782-2929 was resold to TracFone with no subscriber inform ation available. A s a result of this investigation, agents believe the prim al'y user of this telephone was Brady LESTER. According to text messages received via court order, the user of this telephone was in a romantic and drug relationship with Amy Roe, as well as the ex-lover of Anna Lester. A ccording to Smyth County, VA Detective Scott Prater as well as DEA Special Agent Brian Snedeker, both of whom have had num erous encounters with him, LESTER was currently dating Am y Roe and was the ex-husband of Arma Lester.

On M arch 22, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephones, including that utilized by Timothy GERACE. In response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accounts from February 24 to M r ch 2 1, 20 1 3. The following is an excerpt from the search w arrant results.

M arch 5, 2013

Brady LESTER to Timothy GERACE, çicall me no wtzy u had time to get home. I m ight be coming to see u here in a min. Just make arrangements somewhere there round shop. 1 know u ready to sleep'' GERACE to LESTER, ççMake it realfast'' LESTER to GERACE, **240 on the wtzy'' p'' LESTER to GERACE, çGon my wtz- GERACE to LESTER, diO/c'' LESTER to GERACE, *iBe there shortlypassing turn offpast Damascus', GERACE to LESTER, çGGofuckyour A':J/'' Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 78 of 106 Pageid#: 81

Based on m y training and experience, and m y knowledge of this investigation, l believe that Brady LESTER utilized the text messaging service on his cellular telephone to purchase two (2) grams ($240.00 worth) of methamphetamine from Tim GERACE.

M arch 10, 2013

Tim othy GERACE to Brady LESTER, GGWhats up dick Jlcltf' LESTER to GERACE, iisup bigger dickhcd Come to lake house. Bring me a bag ice'' LESTER to GERACE, iiBring me a g too't

Based on m y training and experience, and my knowledge of this investigation, I believe that Brady LESTER utilized the text messaging service on his cellular telephone to order crystal methamphetamine from GERACE to be delivered to W illiam HUNT, Jr.'s residence (Ctlake l house'). I believe that additionally, LESTER requested a gram (<çg'') for himself. Your affiant knows that one form of methnmphetamine is com monly referred to as Edcrystal meth'' and ûkice'' due to the drug's sim ilarity in appearance to crystals, ice, or shards of shattered glass. Based on several interviews conducted with individuals' fam iliar with GERACE'S m ethamphetamine, I know that GEIRACE obtains this type of m ethamphetam ine for resale.

M arch 11, 2013

Brady LESTER to Timothy GERACE, çiub'up queer. Amy 's dadputtn my shit outside. I needgo get it ...Dude at lake said he needs another t?nc.''

Based on m y training and experience, and my knowledge of this investigation, I believe that Brady LESTER utilized the text messaging service on his cellular telephone to order methamphetamine from GERACE for W illiam HUNT, Jr. (ildude at lake'').

M arch 18, 2013

Brady LESTER to Timothy GERACE, Lilfate to bother u 1'm vacation. But need to go to shop andshoot some pool... f/'z/ can get ahold ofAlbert'' GERACE to LESTER, (;0/c'' LESTER to GEARCE, iGI think wc goons b heading ur wJy soon. Can wc shootpool/b' LESTER to GERACE, GGBring #.p'7 GERACE to LESTER, (C&/c''

Based on m y training and experience, and my knowledge of this investigation, l believe that Brady LESTER utilized the text m essaging service on his cellular telephone to com municate with Tim GERACE that LESTER wanted to purchase 3.5 gram s of metham phetam ine, later changed to 4 grnms (çû4.0'') from Albert HAGUE.

78 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 79 of 106 Pageid#: 82

Your affiant knows that 3.5 gram s of m ethamphetam ine equals 1/8 ounce, com monly referred to as an ki8 ball'' or Skgam e''. Your aftiant believes that this was what LESTER was referring to when he stated he wanted to tûshoot some pool''.

M arch 19 - 20, 2013

Brady LESTER to Timothy GERACE, ;tW?7/ bothering u no more, but b4 I makejourney to da J/lj/y 1 ant gonna b on dry run, am i?? and God Damn Nate agrevating me wants 2 no fu got Bill??', GERACE to LESTER, iiNo notyet'' LESTER to GERACE, tûrel, screw Bill...what bout me', LESTER to GERACE, çnon my wJy atpw. B there n 30 min',

Based on my training and experience, and m y knowledge of this investigation, 1 believe that Brady LESTER utilized the text m essaging service on his cellular telephone to comm unicate with GERACE about supplying LESTER, N athan HALL and W illiam HUNT, Jr. with metham phetam ine.

On April 10, 20l 3, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephones, including those utilized by Tim othy GERACE and Brady LESTER. ln response to the execution of these search warrants on V erizon W ireless, agents received text messages stored in those accounts dating from M arch 23 to April 10, 2013. The following are excerpts from the search warrant results.

M arch 23, 2013

Nathan HALL to Brady LESTER, içl-im is on his wJy have you talked to hik/', LESTER to Timothy GERACE, çiBring me a /ct7f/'' HALL to LESTER, iiu need 2 hook up wit me and make something happen't LESTER to W illiam HUNT, Jr., êkl'im at Nates?'' HALL to LESTER, içWhat 's up tryin to sell some shit at the ofhce'' LESTER to HALL, Q%l'm outa dope, Atzn/c.ç close soon, ot no ride. 1ma going to Aetf' HUN T to LESTER, **U in Abingdon znite'' LESTER to HUNT, i*sup buddy..just awokeh'om a monthly mandatory 3 hour comatose ...sup w yal...sure like to get up w/Nate 1 wt73?/# really love to play my z/cw ph JOF . ' '

Based on my training and experience, and m y knowledge of this investigation, 1 believe that Brady LESTER utilized the text m essaging service on his cellular telephone to comm unicate with Nathan HALL, Tim GERACE and W illiam HUN T, Jr. regarding the availability of methnmphetam ine.

M arch 24, 2013

Brady LESTER to Tim othy GERACE, iiDickhead whers u at...1'm on my wtl to lake''

79 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 80 of 106 Pageid#: 83

LESTER to GERACE, i6Call me asap...need to get n my stuffim at condo't William HUNT, Jr. to LESTER, *iTell Nathan 2 drive u on cart 2 lower garage @ basketball goal... text me wcn u start on cartt' LESTER to HUN T, ;(# up there n 5'' LESTER to HUN T, Gion my wJy pcw'' LESTER to GERACE, çGWhats up round boy...fucking tell lwccky u gota go c ur son and come thefuck on'' LESTER to HUN T, **1 needa 4*4*4 inpyrex cook dish or something close'' LESTER to HUN T, **R u back..vl need that dish'' LESTER to HUN T, iiBill call Nate and tell him ti get up there... im in a hurry''

Based on m y training and experience, and m y knowledge of this investigation, 1 believe that Brady LESTER utilized the text messaging service on his cellular telephone to comm unicate with Tim GERACE and W illiam HUN T, Jr. regarding the m anufacturing of m ethamphetam ine at the residence of W illiam HUN T, Jr..

M arch 26, 2013 Brady LESTER to Timothy GERACE, çiFuckface... crawl offit. I need a halfl'm at the Bristol Hospital, sojust drop it tpf/'w Nate'' GERACE to LESTER, GQWere thefu is Nate'' LESTER to GERACE, içAsleep where r 1 need a g.'' GERACE to Nathan HALL, iicall me A.S.A.P.'' GERACE to LESTER, içcall me'' HALL to GERACE, çuust talked to Bill he can 't get out to go to ATM till 9am can 1 see you then? He did other things with my cash. '' GERACE to HALL, iil'c.& #pp'' HALL to GERACE, k'A'''

Based on m y training and experience, and my knowledge of this investigation, I believe that Brady LESTER utilized the text m essaging service on his cellular telephone to order m ethamphetamine from Tim GERACE. l believe that GEItACE arranged to drop off the m ethamphetamine with Nathan HALL, to be purchased by W illinm HUN T, Jr..

M arch 27, 2013

N athan HALL to Tim othy GERACE, LiBig guyl Bill had the you a t noon 1 didn 't hear the door. 1 'm not trying to bs u 1 got u. R u coming this wtzy? 1 can come 2 u fnot'' Brady LESTER to GERACE, Listop worrying boutpussy its what got u in shape u n ntlw god damn it wc well ftzkw care ofthatpigndue time. Nate needs to cu and so do l 1 need g have cabbaget' LESTER to GERACE, âGNate its soon gona wana meet u, he has a ride better call /0/z>l5' HALL to GERACE, iican you come over? Brady told me you have been busy so I've waited hours to text. F/lr?a'.'' LESTER to GERACE, çG1 got access to 450 maybe more u want thatpig get him cut ()/./.* Call me damn it''

80 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 81 of 106 Pageid#: 84

Based on m y training and experience, and my knowledge of this investigation, l believe that Brady LESTER utilized the text messaging service on his cellular telephone to initially order a gram of methamphetamine ($:g'') from Tim GERACE. l believe that LESTER and Nathan HALL requested GERACE to deliver the m ethamphetnm ine, and LESTER cam e up with an additional $450.00 to purchase methamphetamine.

M arch 31, 2013

N athan HALL to Timothy GERACE, içcan you come over? Bill andl need to see youl Gotyouh'om yesterday and some J#Jy?'' GERACE to HALL, i;Ok Iet me wtzk: up'' HALL to GERACE, Gilnhnxl''

HALL to Brady LESTER, ûf What did Tim say? Need to no how 2 get Bill out to Iate sis is on his ass.'' LESTER to HALL, Gozlin 't talked to him'' HALL to LESTER, âil-ext him let him no I 'll take care t/ytltt'' LESTER to GERACE, ë*Dude bring me a g Igot ctlitzgc'' LESTER to GERACE, i%Dude go c Nate, so him and Bill can take care ofme 1 'mfucking sick can u come c -e?''

HALL to GERACE, :$f ike to c u b4 Bill wastes more $ He 's killing ?Ne.'' HALL to GERACE, çiBill is trying to leave gate open. Is it gonna be awhile/'' GERACE to HALLS ûion my wtzy'' GERACE to HALL, Goclose gtz/e''

Based on my training and experience, and my knowledge of this investigation, I believe that Nathan HALL utilized the text messaging service on his cellular telephone to order metham phetam ine from Tim GERACE and assure him that he would get paid for yesterday's and today's. l believe that HALL told LESTER that W illiam HUNT, Jr. would pay for their metham phetam ine. I believe that HALL anunged with GERACE for the m ethamphetam ine to be delivered to HUNT'S residence.

On August 16, 2013, a search warrant was executed at 19012 Lake Rd., Abingdon, VA , the residence of Nathan HALL, Brandi DUN FORD, W illiam HUN T, Jr., Jr. and others. Seized from the apartm ent of HALL and DUNFORD was a metham phetamine lab. Subsequent to the search warrant, HALL, DUN FORD and HUNT were interviewed separately. HALL stated that he obtained his methamphetam ine prim arily from ItBUDDHA'' aka Tim GERACE. HALL stated that GERACE was responsible for the majority of m ethamphetam ine in SW VA . HALL stated that GERACE had been providing methamphetamine to SW VA for approximately two (2) years. HALL stated that GERACE usually bropght % ounce to one (1) otmce of methamphetamine at a time and dropped it off with his custom ers in VA.

81 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 82 of 106 Pageid#: 85

HALL stated that on August 14, 2013, GERACE brought over two (2) ounces of m ethamphetam ine and left it with Billy Frarlk BUCHANAN and a fem ale. HALL stated that he was expecting GERACE to arrive at any m inute with methamphetam ine for HALL. HALL stated that GERACE'S other customers included ;(Big Angie'' (Angela SURBER), Brady LESTER and Shanna M ooretield.

Joseph Nathan Hall

N athan Hall has prior arrests for possession of a schedule III substance, providing false identify to law enforcement, possession of marijuana, malicious wounding, possession of a schedule 1 or 11 substanee, throwing a m issile at an occupied vehicle, breaking and entering, obtaining drugs by fraud and drugs: m anufacture, sale, or possess a controlled substance.

According to the records of Verizon W ireless, telephone number (276) 206-6818 was resold to TracFone w ith no subscriber inform ation. According to the following text m essages, the user of this telephone was lfNate''. As a result of this investigation, agents believe that the prim ary user of this telephone was Nathan HALL. (On August 16, 2013, Brandi DUNFORD was interviewed in Abingdon, VA and stated that Nathan HALL'S cellular telephone number was (276) 206-6818.) On M arch 22, 20 13, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephones, including that utilized by Tim othy GERACE. ln response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accounts from February 24 to M arch 2 l , 20 13. The following is an excerpt from the search warrant results.

M arch 19 - 20, 2013

N athan HALL to Timothy GERACE, çil-ley this is Nate need to see you its been a long wec/c with no work give me a call asap. ThnxjNsnates'' HALL to GERACE, Gican 1 come see you? AJ/e'' HALL to GERACE, Gican 1 come on up? Just got straight. Thanka. M ate'' HALL to GERACE, **1 got that cash 1 tlwc you mateb' HALL to GERACE, iiDo you want me to stay at store?'' GERACE to HALL, t$FEw'' HALL to GERACE, ûi1'll be up what time you thinkyou b here my dada up. Redgate. F/l#lX'' HALL to GERACE, çnsorry about me asking what time my unclejust let me no your coming. Thaw. W M ate'' HALL to GERACE, Gizqre you gonna make it? Alfy uncle has cleaned house please try. F/ptza/cç X ate'' HALL to GERACE, QiDid 1 miss your somehow someone turned at gate? Sorry t/'f did.b' Brady LESTER to GERACE, GGzqnt bothering u no more, but b4 I makejourney to da

.1 //.3/ I ant gonna b on dry run, am i.?.? and God Damn Nate agrevating me wants 2 no (/';/ got Bill??,t

82 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 83 of 106 Pageid#: 86

GERACE to LESTER, içNo not yet'' LESTER to GERACE, iûrcl, ycrcw Bill...what bout me'' LESTER to GERACE, iion my wJy n/w. # there n 30 raïn''

Based on m y training and experience, and my knowledge of this investigation, I believe that Nathan HALL utilized the text m essaging service on his cellular telephone to order m ethnmphetam ine from Tim GERACE. I believe that HALL and GERACE arranged to meet at the residence of W illiam HUN T, Jr..

On April 10, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephones, including those utilized by Tim othy GERACE and Brady LESTER. ln response to the execution of these search warrants on Verizon W ireless, agents received text m essages stored in those accounts dating from M arch 23 to April 10, 2013. The following are excerpts from the search warrant results.

M arch 23, 2013

N athan HALL to Brady LESTER, iâl-im is on his wJy have you talked to hik/'' LESTER to Timothy GERACE, iiBring me a /JJ#'' HALL to LESTER, i6U need 2 hook up wff me and make something happent' LESTER to W illiam HUNT, Jr., iilnim at Nates/'' HALL to LESTER, LGWhat 's up tryin to sell some shit at the of/zce'' LESTER to HALL, iGl'm outa dope, banks close soon, ot no ride. 1ma going to :ctf' HUN T to LESTER, çiU in Abingdon znite'' LESTER to HUNT, QGvb'up buddy..just awokeh'om a monthly mandatory 3 hour comatose ...sup w yal...sure like to get up w/ Nate 1 would really love to play my ?7cw ph ftlll 11

Based on m y training and experience, and my knowledge of this investigation, I believe that N athan HALL utilized the text m essaging service on his cellular telephone to com municate with Brady LESTER about selling m ethamphetam ine.

M arch 26, 2013

Brady LESTER to Timothy GERACE, i4Fuckface ...crawl tpf/-/f. I need a halfl'm at the Bristol Hospital, sojust drop it tpf/'w Nate'' GERACE to LESTER, LGWere thefu is Nate'' LESTER to GERACE, inzqsleep where r 1 need a g.'' GERACE to Nathan HALL, çâCall me W.S.W.#.'' GERACE to LESTER, *LCall me'' HALL to GERACE, iilust talked to B i1l he can 't get out to go to ATM till 9am can I see you then? He did other things with my cash. '' GERACE to HALL, ktlrts 900', HALL to GERACE, CCA'''

83 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 84 of 106 Pageid#: 87

Based on m y training and experience, and my knowledge of this investigation, I believe that Brady LESTER utilized the text messaging service on his cellular telephone to order m ethamphetam ine from Tim GERACE. I believe that GERACE arranged to drop off the m ethamphetam ine with Nathan HALL, to be purchased by W illiam HUNT, Jr..

M arch 27, 2013

Nathan HALL to Tim othy GERACE, QnBig guyl Bill had the you a t noon I didn 't hear the door. 1'm not trying to bs u 1 got u. R u coming this wly? I can come 2 u fnot'' Brady LESTER to GERACE, çistop worrying boutpussy its what got u in shape u n aow god damn it wc well /1kw care ofthat pigndue time. Nate needs to cu and so do L 1 need # have cabbage'' LESTER to GERACE, çiNate its soon gona wana meet u, he has a ride better call him'' HALL to GERACE, Gican you come over? Brady told me you have been busy so l've waited hours to text. F/Jm .'' LESTER to GERACE, Gilgot access to 450 maybe more u want thatpig get him cut tp//' Call me damn it''

Based on my training and experience, and m y knowledge of this investigation, I believe that Brady LESTER utilized the text m essaging service on his cellular telephone to initially order a gram of methamphetamine (çûg'') from Tim GERACE. l believe that LESTER and Nathan HALL requested GERACE to deliver the methamphetamine, and LESTER came up with an additional $450.00 to purchase methamphetamine.

M arch 30, 2013 Timothy GERACE to Nathan HALL, isWillyou have allforpizza'' HALL to GERACE, i%1 #om yesterday, Bill'' GERACE to HALL, ii120'' HALL to GERACE, çisorry. Bill is buying halfpizza today. I buy you haVback tomorrowfor the l yesterday' GERACE to HALL, tiO/c''

Based on m y training and experience, and m y knowledge of this investigation, 1 believe that Nathan HALL utilized the text messaging service on his cellular telephone to notify Tim GERACE that HALL only had $100.00 (C$Bill'') to pay for yesterday's methamphetamine (dkpizza'). 1 believe that HALL arranged for W illiam HUNT, Jr. to purchase % gram of m etham phetam ine and prom ised that GERACE would get paid tom orrow. Your affiant knows that one (1) gram of crystal methamphetamine purchased in Southwest Virginia has a going rate of $ 120.00, which is what GERACE expected to be paid by H A LL.

M arch 31, 2013

Nathan HALL to Timothy GERACE, Lncan you come over? Bill and 1 need to see you! Gotyoufkom yesterday and some J#tzyp''

84 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 85 of 106 Pageid#: 88

GERACE to HA LL, **Ok let me wake up'' HALL to GERACE, ççlhnxl''

HALL to Brady LESTER, GiWhat did Tim say? Need to no how 2 get Bill out to late sis is on his ass.'' LESTER to HALL, Lnzqin 't talked to /?ïzn'' HALL to LESTER, içlkxt him let him no 1 'll take care ofyou.''

LESTER to GERACE, iiD ude bring me a g 1 got cabbage'' LESTER to GERACE, içDude go c Nate, so him and #W can take care ofme I 'mfucking sickcan u come c me.?''

HALL to GERACE, *QL ike to c u b4 Bill u/t7l/cl more $ He 's killing me. '' HALL to GERACE, %*Bill is trying to leave gate open. Is it gonna be awhile/'t GERACE to HALL, çion my wcy'' GERACE to HALL, Qiclose gate''

Based on my training and experience, and my knowledge of this investigation, I believe that N athan HALL utilized the text m essaging service on his cellular telephone to order metham phetam ine from Tim GERACE and assure him that he would get paid for yesterday's and today's. 1 believe that HALL told LESTER that W illiam HUN T, Jr. would pay for their m etham phetamine. I believe that HALL arranged with GERACE for the m ethamphetnm ine to be delivered to HUN T'S residence.

On June 20, 2013, CS-7 was interviewed in Abingdon, VA. CS-7 stated that several weeks prior, they had been with Nathan HALL at HALL'S apartm ent when HALL and a white m ale named Sk-fim '' attempted to m anufacture m ethamphetam ine. CS-7 rode with iû-l-im '' to purchase m atches and iodine while HALL and his m other ptlrchased Sudafed and tdl-leef'. CS-7 stated that a1l these m aterials were purchased for the ultim ate goal of m anufacturing metham phetam ine.

On August 16, 2013, a search warrant was executed at 19012 Lake Rd., Abingdon, VA , the residence of Nathan HALL, Brandi DUN FORD, W illiam HUNT, Jr., Jr. and others. Seized I from the apartment of HALL and DUNFORD was a methpmphetamine lab. Subsequent to the search warrant, HALL, DUNFORD and HUNT were interviewed separately. DUNFORD stated that HALL was a user of m ethamphetam ine. DUN FORD provided the names of several others who were involved with HALL in the use of metham phetamine. HALL stated that the liquids seized during the search warrant did not contain metham phetamine, as they were left over from previous çicooks''. HALL stated that he obtained his m etham phetam ine primarily from StBUDDHA'' aka Tim GERACE. HALL stated that GERACE was responsible for the majority of methamphetamine in SW VA. HALL stated that Rick SHAW was a big m etham phetamine supplier from TN.

On October 21, 2013, Bristol, VA Police Departm ent Officer Bobby Nichols responded to La Quinta 1nn in Bristol, VA. The employee tiled a complaint for unusual odor and property

85 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 86 of 106 Pageid#: 89

dam age related to a room rented by W illiam HUN T, Jr.. Upon arriving at the room , Ofc. Nichols observed a strong chem ical odor and burn marks on the ftr iture, both consistent with the production of methamphetamine. In addition, Ofc. N ichols observed a white powdery substance on the dresser which he believe to be consistent with the substance contained within batteries, which he knew to be used in the production of m ethnm phetam ine. ln the presence of Ofc. N ichols, the em ployee contacted HUN T by telephone to notify him of the dam age and possible credit card charges that would follow. HUN T told the employee that he didn't even stay in the room , that it w as Nathan HALL and Brandi DUNFORD who had stayed there.

On December 4, 2013, Brandi DUNFORD was interviewed in Bristol, VA . DUNFORD stated that Tim GERACE, aka (CBUDDHA'' 5was the crystal m etham phetam ine source of supply to Nathan HALL. DUNFORD stated that from M ay to August 2013, she observed GERACE deliver approximately one (1) ounce of methamphetamine per day to HALL at the çtake House'' (W illiam HUNT, Jr.'s property). DUNFORD stated that she observed GERACE deliver up to two (2) ounces at a time to HALL. DUNFORD stated that she observed GERACE in possession of a gallon sized freezer bag full of methamphdamine at the Cilaake House''.

On M arch 31, 2014 Jeanne SULT was interviewed in Abingdon, Virginia. SULT stated through personal conversations with Roger AUSTW she believed AU STIN was a dealer of m ethamphetam ine and was supplied by Tim aka dtBuddha''. SULT stated Buddha looked like çiM ario'' the Nintendo game character. Buddha has previously been identifed as Timothy GERACE of 4970 Highway 91 N M otmtain City, '1'N . SULT stated on two separate occasions in the past year she had been present at N athan HALL'S lake house apartment in Abingdon when GERACE brought HALL % ounce of crystal m ethamphetamine. SULT added GERACE was driving a beat up Jeep Cherokee.

W illiam Ham m ond HUNT, Jr., aka ç6BiI1 H UNT'' According to the records of Sprint, telephone nttmber (276) 492-8874 had no subscriber information. According to the records of Thomas Reuters (credit database), telephone number (276) 492-8874 was assigned to W illiam H. HUNT. As a result of this investigation, agents believe that the prim ary user of this telephone was W illiam Hamm ond HUN T, Jr.

On M arch 22, 2013, a search w arrant was applied for and obtained in the W estern Distrid of V irginia for text messages stored in the accounts of several cellular telephones, including that utilized by Timothy GERACE. In response to the execution of this search w arrant on Verizon W ireless, agents received text messages stored in those accounts from February 24 to M arch 21, 2013. The following is an excerpt from the search w arrant results.

M arch 19 - 20, 2013

N athan HALL to Tim GERACE, iiliey this is Nate need to see you its been a long wce/c with no work give me a call asap. ThnxbNsnates''

86 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 87 of 106 Pageid#: 90

HALL to GERACE, ç%c'an 1 come see you? Natet' HALL to GERACE, G%can 1 come on up? Just got straight. Thanka. M tz/e'' HALL to GERACE, Qilgot that cash I tlwc you mate'' HALL to GERACE, Gil)o you want me to stay at store?'' GERACE to HALL, %tFe.&'' HALL to GERACE, ii1 'Il be up what time you thinkyou b here my dada up. Redgate. F/7AY ' HALL to GERACE, Lnsorry about me asking what time my unclejust let me no your coming. Thaw. W M ate'' HALL to GERACE, nozjre you gonna make it? A/y uncle has cleaned house please try. Thanks Ligate'' HALL to GERACE, iiDidl miss your somehow someone turned at gate? Sorry (/'f did'' Brady LESTER to GERACE, iizqnt bothering u no more, but b4 1 makejourney to da .ç/lï/y 1 ant gonna b on dry run, am i?? and God Damn Nate agrevating me wants 2 no fu #&/ BilI?.?'' GERACE to LESTER, çnhïo notyet'' LESTER to GERACE, CtFtrt', xcrew Bill...what bout vc'' LESTER to GERACE, iLon my wJy now. B there n 30 ?AlfFl''

Based on m y training and experienee, and m y knowledge of this investigation, l believe that Nathan HALL utilized the text m essaging service on his cellular telephone to order m etham phetam ine from Tim GERACE. 1 believe that HALL and GERACE arranged to m eet at the residence of W illiam HUN T, Jr..

On April 10, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephones, including those utilized by Timothy GERACE and Brady LESTER. ln response to the execution of these search warrants on Verizon W ireless, agents received text m essages stored in those accounts dating from M arch 23 to April 10, 2013. The following are excerpts from the search warrant results.

Alarch 23,2013

Nathan HALL to Brady LESTER, çilnim is on his wJy have you talked to /?j/c?'' LESTER to Timothy GERACE, GçBring me a J/JI/'' HALL to LESTER, tSU need 2 hook up wit me and make something happen', LESTER to W illiam HUN T, Jr., Gilnim at Nates/'t HALL to LESTER, iiWhat 's up tryin to sell some shit at the tpf/3cd'' LESTER to HALL, t$f 'm outa dope, AJ/C/C.C close soon, ot no ride. 1ma going to dlc'' HUN T to LESTER, $:LJ în Abingdon znite'' LESTER to HUNT, insup buddy..just Jwo/ce/'tp??k a monthly mandatory 3 hour comatose ...sup w yal...sure like to get up w/Nate 1 would really love to play my ncw ph JOA . . ' '

87 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 88 of 106 Pageid#: 91

Based on my training and experience, and m y knowledge of this investigation, I believe that N athan HALL utilized the text m essaging service on his cellular telephone to communicate with Brady LESTER about selling m ethamphetam ine.

M arch 24, 2013

Brady LESTER to Timothy GERACE, GiD ickhead whers u at...I'm on my wJy to lake', LESTER to GERACE, i*Call me asap...need to get n my stuffim at condo', William HUNT, Jr. to LESTER, i%Tell Nathan 2 drive u on cart 2 lower garage @ basketball goal...text me wcn u start on cart't LESTER to HUN T, ;*B up there n j''5

LESTER to HIJNT, iion my wtz.y ntpw '' LESTER to GERACE, GiWhats up round boy...fucking tell fwce/c.p u gota go c ur son and come thefuck t?n5' LESTER to HUN T, *%1 needa 4*4*4 inpyrex cook dish or som ething close'' LESTER to HUN T, GGR u back...l need that dish'' LESTER to HUN T, **Bill call Nate and tell him ti get up there... im in a hurry''

Based on m y training and experience, and my lcnowledge of this investigation, I believe that Brady LESTER utilized the text m essaging service on his cellular telephone to com municate with Tim GERACE and W illiam HUNT, Jr. regarding the m anufacturing of metham phetamine at the residence of W illiam HUNT, Jr..

M arch 26, 2013 Brady LESTER to Timothy GERACE, iiFuckface...crawl t?x j/. 1 need a halfl'm at the Bristol Hospital, sojust drop it tpf/'w Nate'' GERACE to LESTER, Gnlkrere thefu is AW/:'' LESTER to GERACE, GGAsleep where r 1 need a g.'' GERACE to Nathan HALL, **CaIl me A.S.A.P.'' GERACE to LESTER, i%Call ??7c'' HALL to GERACE, iuust talked to Bill he can 't get out to go to ATM till 9am can I see you then? H e did other things with my cash.t' GERACE to HALL, Stl'c,& 900,, HALL to GERACE, ;$A'''

Based on m y training and experience, and my knowledge of this investigation, l believe that Brady LESTER utilized the text m essaging serviee on his cellular telephone to order metham phetam ine from Tim GERACE. 1 believe that GERACE arranged to drop off the metham phetam ine with N athan HALL, to be purchased by W illiam HUN T, Jr..

M arch 27, 2013

Nathan HA LL to Tim othy GERACE, GëBig g?z.p/ Bill had the you a t noon I didn 't hear the door. 1'm not trying to bs u 1 got u. R u coming this wtzy? 1 can come 2 u (/??of.''

88 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 89 of 106 Pageid#: 92

Brady LESTER to GERACE, Gistop worrying boutpussy its what got u in shape u n atpw god damn it wc well ftz/ckp care ofthatpigndue time. Nate needs to cu and so do f 1 need g have cabbage'' LESTER to GERACE, içNate its soon gona wana meet u, he has a ride better call /zf??7'' HALL to GERACE, i*can you come over? Brady told me you have been busy so I 'v: waited hours to text. F/ynx.'' LESTER to GERACE, Gi1 got access to 450 maybe more u want that pig get him cut t? .J/J Call me damn it',

Based on m y training and experience, and my knowledge of this investigation, I believe that Brady LESTER utilized the text m essaging service on his cellular telephone to initially order a gram of methamphetamine (Idg'') from Tim GERACE. 1 believe that LESTER and Nathan HALL requested GERACE to deliver the m ethamphetam ine, and LESTER cam e up with an additional $450.00 to purchase methamphetamine.

M arch 30, 2013

Timothy GERACE to Nathan HALL, t: Willyou have allfor pizza'' HALL to GERACE, iilfrom yesterday, Bi1l'' GERACE to HALL, **120', HALL to GERACE, iisorry. Bill is buying hafpizza today. 1 buyyou hafback tomorrowfor the l yesterday'' GERACE to HALL, CLOV'

Based on m y training and experience, and my knowledge of this investigation, 1 believe that Nathan HA LL utilized the text messaging service on his cellular telephone to notify Tim GERACE that HALL only had $100.00 (çiBill'') to pay for yesterday's methamphetamine (lkpizza''). I believe that HALL arranged for W illiam HUNT, Jr. to purchase % gram of m ethamphetamine and promised that GERACE would get paid tom orrow. Your affiant knows that one (1) gram of crystal methamphetnmine purchased in Southwest Virginia has a going rate of $120.00, which is what GERACE expected to be paid by HALL.

M arch 31, 2013

Nathan HALL to Tim othy GERACE, iican you come over? Bill and 1 need to see you! Gotyouh'om yesterday and some zday/', GERACE to HALL, Gnok let me wtz/cc up'' HALL to GERACE, dtr/7r/x/''

HALL to Brady LESTER, ççïk-hat did Tim say? Need to no how 2 get Bill out to Iate sis is on his ass.'' LESTER to HALL, Gçvqin 't talked to /?/zp'5 HALL to LESTER, iil-ext him let him no 1'11 take carc ofyou.'' LESTER to GERACE, çillude bring me a g Igot cabbage''

89 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 90 of 106 Pageid#: 93

LESTER to GERACE, GiDude go c Nate, so him and Bill can take care ofme I 'mfucking sick can u come c me.?''

HALL to GERACE, (tf ike to c u b4 Bill wastes more $ He 's killing me.'' HALL to GERACE, iiBiIl is trying to leave gate open. ls it gonna be awhile/'' GERACE to HALL, çion my wtzy'' GERACE to HALL, çiclose gate't

Based on m y training and experience, and my knowledge of this investigation, I believe that Nathan HALL utilized the text m essaging service on his cellular telephone to order m ethamphetam ine from Tim GERACE and assure him that he would get paid for yesterday's and today's. I believe that HALL told LESTER that W illiam HUNT, Jr. would pay for their m ethamphetam ine. I believe that HALL arranged with GERACE for the methamphetam ine to be delivered to HUN T'S residence.

On June 20, 2013, CS-7 was interviewed in Abingdon, VA. CS-7 stated that several weeks prior, they had been with N athan HALL at HALL'S apartment when HALL and a white m ale named tû-fim '' attem pted to m anufactlzre m ethamphetnm ine. CS-7 rode with di-l-im'' to purchase m atches and iodine while HALL and his m other purchased Sudafed and Cdl-leef'. CS-7 stated that al1 these m aterials were pttrchased for the ultim ate goal of manufacturing m ethamphetam ine. W hile HALL and ûd-fim '' were attempting to m anufacture metham phetamine, W illiam HUN T, Jr. cam e into the apartment and asked HALL if dcit'' was going to work, referring to the metham phetamine cook. HALL had some finished product in the apartm ent, and while the ktcook'' was ongoing, HUN T smoked metham phetamine while HALL and çi-l-im'' snorted it.

On August 16, 2013, a search warrant was executed at 19012 Lake Rd., Abingdon, VA, the residence of N athan HALL, Brandi DUNFORD, W illiam HUN T, Jr., Jr. and others. Seized from the apartment of HALL and DUNFORD was a m ethamphetam ine lab. Subsequent to the search warrant, HALL, DUNFORD and HUNT were interviewed separately. HALL stated that the liquids seized during the search warrant did not contain m ethamphetam ine, as they were left over from previous (ûcooks''. HALL stated that he obtained his m ethamphetnmine prim arily from SSBUDDHA'' aka Tim GERACE. HALL stated that W illiam HUNT, Jr. allowed HALL to stay at his residence in an effort to keep HALL Stclearf'. HALL stated that HUNT was a drug addict himseltl having been addicted to crack cocaine in the past. HA LL stated that HUN T m ight currently be under the influence of tdspeed''. HUN T stated that he knew nothing about drugs other than what he read in the new spapers. HUN T stated that he had been in HALL'S apartment tta few hours ago'' and had seen no evidence of methamphetam ine m anufacturing. HUN T was aware that HALL had been with Angelic Counts and Brandi DUNFORD when they were both arrested on methamphetm ine related charges, but did not think that HALL was involved with m ethamphetam ine. (During the interview with HUNT it was the opinion of agents/officers involved that HUNT was under the influence of a stimulant and w as not being truthful about his knowledge of the manufacturing of methamphetamine on his property.) Also seized ptzrsuant to the search warrant was the cellular telephone belonging to Nathan HALL. Contained within the phone were the following text messages with telephone

90 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 91 of 106 Pageid#: 94

number (276) 492-8874 (saved under the name çiBi11'' and known by law enforcement to be utilized by HUNTI: W illiam HUN T, Jr. to Nathan HALL, GiWat is the story'' HALL to HUNT, oGstl'll waiting on ctz/l.'' HUN T to HALL, iQKn' :, ncw s'' HUN T to HALL, $.4,7. HALL to HUNT, iLshe tryin to get ridw't HALL to HUNT, Sican Iget some cash.p'' HALL to HUNT, LGl'm out ofcigs an 1ce Cream.. '' HALL to HUNT, i*3 bills'' HALL to HUNT, (tAtfy dude is close'b

Based on m y training and experience, and m y ltnowledge of this investigation, 1 believe that W illiam HUNT, Jr. utilized the text messaging service on his cellular telephone to communicate with Nathan HALL about the availability of methamphetamine (ike Creamttj. I believe that HALL ordered the m ethamphetam ine to be delivered and told HUN T that it would cost him $300.00 (CtJ bills,t). The following text messages were contained within HALL'S cellular telephone under telephone number (276) 782-2929, known by your affiant as the telephone number utilized by Brady LESTER:

Brady LESTER to Nathan HALL, i*Bill gonapayfor hotel? Gotta b at s'/ltzwnc n 2 '5 hrs''

HALL to LESTER, 'ire.ç you may need to hold him t?.#'ln /lt?Nr...''

HALL to LESTER, Lilust got t?.#'/& phone with Bill. He don 't want anyone over tonight. 1 think he 's scared wc wtpn '/ be able to make that run...he will be here n 10 to take me to Bristolb'

HALL to LESTER, iiub'is woa '/ let anyone stay! You can come run 1. lt will be hard to keep itfkom her. Bill stays down here. .ww/lt?/ do you think? I'IS: canhsh the night JW JF.

Based on my training and experience, and m y knowledge of this investigation, l believe that Nathan HALL utilized the text messaging service on his cellular telephone to comm unicate with Brady LESTER about W illiam HUN T, Jr.'s involvem ent in the m anufacturing of methnm phetam ine. 1 believe that HUN T financed motel room s in which m ethamphetamine was m ade by HALL and LESTER. 1 believe that HUN T allowed HALL and LESTER to m anufacture m ethamphetamine on HUN T'S property which is located on South Lake Holston in Abingdon, VA. 1 know that dssis'' is the nicknnm e of HI7N T'S wife.

On August 23, 20l 3, DEA SA Brewer received a telephone call from W illiam HUN T, Jr.. HUNT told SA Brewer that he was being extorted and was told to send $5,000.00 via W estern Union to an unknown person, or else this person would divulge inform ation to 1aw

91 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 92 of 106 Pageid#: 95

enforcement about the m anufacturing of m ethamphetamine on HUN T'S property. HUNT provided telephone number (276) 492-8874 as his contact number.

On October 21, 2013, Bristol, VA Police Department Officer Bobby Nichols responded to La Quinta IM in Bristol, VA. The employee filed a complaint for unusual odor and property dam age related to a room rented by W illiam HUN T, Jr.. Upon arriving at the room , Ofc. Nichols observed a strong chem ical odor and burn marks on the furniture, both consistent with the production of methamphetamine. In addition, Ofc. N ichols observed a white powdery substance on the dresser which he believe to be consistent with the substance contained w ithin batteries, which he knew to be used in the production of metham phetam ine. ln the presence of Ofc. N ichols, the employee contacted HUN T by telephone to notify him of the dnm age and possible credit card charges that would follow. HUN T told the employee that he didn't even stay in the room , that it was Nathan HALL and Brandi DUNFORD who had stayed there.

Brandi M arie DUNFORD

Brandi Dunford has prior arrests for embezzlem ent, violation of probation, possess or distribute a controlled substmwe, possession of schedule IV controlled substance, possession of schedule VI, and possession of schedule 1Il substance.

On June 20, 20 l3, CS-7 was interviewed in Abingdon, VA. CS-7 stated that several weeks prior, they had been with N athan HALL at HALL'S apartm ent when HALL and a white m ale nam ed ds-fim '' attem pted to m anufacture methamphetam ine. CS-7 stated that while HALL and $(Tim'' were cooking the m ethamphetam ine, Brandi DUNFORD and W illiam HUNT, Jr. were also present and using m etham phetam ine.

On August 16, 2013, a search warrant was executed at 19012 Lake Rd., Abingdon, VA, the residence of N athan HALL, Brandi DUNFORD, W illiam HUNT, Jr., Jr. and others. Seized from the apartment of HALL and DUNFORD was a m ethamphetnm ine lab. Subsequent to the search warrant, HALL, DUN FORD and HUN T were interviewed separately. DUN FORD stated that HALL was a user of metham phetam ine. DUN FORD provided the nam es of several others who were involved with HALL in the use of m ethamphetam ine. HALL stated that the liquids seized during the search warrant did not contain m ethamphetnm ine, as they were left over from previous tccooks''. HALL stated that he obtained his metham phetamine prim arily from (tBUDDHA '' aka Tim GERACE. HALL stated that GERACE was responsible for the majority of methamphetamine in SW VA. HALL stated that Rick SHAW was a big methamphetamine supplier from TN.

On Septem ber 25, 2013, Brandi DUNFORD was arrested in Bristol, VA in possession of crystal metham phetamine. The crystal m ethamphetam ine in which DUN FORD was in possession had a bluish tint.

92 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 93 of 106 Pageid#: 96

On October 21, 2013, Bristol, VA Police Departm ent Oftk er Bobby Nichols responded to La Quinta 11%1 in Bristol, VA. The employee filed a complaint for unusual odor and property dam age related to a room rented by W illiam HUN T, Jr.. Upon aniving at the room, Ofc. Nichols observed a strong chemical odor and burn m arks on the furnittlre, both consistent with the production of m ethamphetam ine. ln addition, Ofc. Nichols observed a white powdery substance on the dresser which he believe to be consistent with the substance contained within batteries, which he knew to be used in the production of methamphetamine. ln the presence of Ofc. Nichols, the em ployee contacted HUN T by telephone to notify him of the dam age and possible credit card charges that would follow . HUNT told the em ployee that he didn't even stay in the room , that it was Nathan HALL and Brandi DUN FORD who had stayed there.

On Decem ber 4, 2013, Brandi DUNFORD was interviewed in Bristol, VA. DUNFORD stated that since August 20 l 3, she had been involved with the distribution of crystal m ethamphetamine with Toby M OCK , Roger AU STIN and others. DUNFORD stated that she had been involved with up to 15 ounces of m ethamphetam ine at a tim e, as well as tens of thousands of dollars in drug proceeds. DUNFORD stated that the crystal m ethamphetamine with which she was involved had a bluish tint. DUN FORD stated that Tim GERACE, aka CCBUDDHA'' was the crystal m ethamphetamine source of supply to Nathan HALL. DUNFORD stated that from M ay to August 2013, she observed GERACE deliver approximately one (1) ounce of methamphetamine per day to HALL at the ùtlwake House'' (W illiam HUNT, Jr.'s property). DUNFORD stated that she observed GERACE deliver up to two (2) ounces at a time. DUNFORD stated that she observed GERACE in possession of a gallon sized freezer bag full of m etham phetam ine at the 'tlaake House''. DUNFORD stated that one of GERACE'S cellular telephone numbers was (423) 471-1 54l . DUNFORD stated that she had accompanied GERACE while he delivered metham phetamine to drug custom ers in Konnarock, VA. DUN FORD stated that she received approximately one (1 ) ounce of crystal methamphetamine from GERACE in mid-November 2013and still ow ed him money. DUN FORD stated she sm oked metham phetam ine with l GERACE, Shanna Moorefield and others in late November 2013. DUNFORD stated that she was first introduced to GERACE by Leann HALL approximately two (2) years prior. DUNFORD stated that one of HALL'S cellular telephone numbers was (276) 492-5819. DUNFORD stated that Tim FIELD S was a distributor of m ethamphetamine. DUNFORD stated that FIELDS also grew his om z marijuana. DUNFORD stated that FIELDS' cellular telephone number was (276) 70 1-5394.

Tim othy Nickolas RABARA

Timothy Rabara has prior arrests for drugs: possess or distribute controlled substance, possession of marijuana, and hit and run: attended property damage. According to the records of Verizon W ireless, telephone number (276) 780-1337 was subscribed to by Timothy N . RABARA at 488 Hutton Br., M arion, VA . As a result of this

93 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 94 of 106 Pageid#: 97

investigation, your affiant believes that the prim ary user of this telephone was Tim othy RABARA.

On April 26, 2013, a search warrant was applied for and obtained in the W estem District of Virginia for text m essages stored in the accounts of several cellular telephones, including those utilized by Timothy GERACE, Brady LESTER and Nathan HALL. ln response to the execution of these search warrants on Verizon W ireless, agents received text m essages stored in those accounts dating from April 1 1 to April 26, 2013. The following are excem ts from the search warrant results.

April 13, 2013 Timothy RABARA to Nathan HALL, (CJ'J tell Nate to call me fyou talk to him. 1 need to holla. Got him 4 clean ones 2.'' RABARA to HALL, Lnlhis is Timmy. I gotyou three clean brand acw rigs. Holler at

./ 0 5 ' RABARA to HALL, iiliey fyou good. llz'c ready to ride. Got your clean rigs. Let me lptpw either wJy its Timmy''

Based on my training and experience, and m y knowledge of this investigation, l believe that Timothy RABARA advised Nathan HALL that RABARA had 4 unused needles (idclean rigs'') that he had obtained from work and was willing to exchange for methamphetamine.

April 20, 2013

Nathan HALL to Tim othy RABARA, GiHey.! My guy has 2b bk 2 M C. by 12:30. Call ll1 tl '%% RABARA to HALL, GiHey 1 need to run to town. At least got a halfsoldfor you'' RABARA to HALL, GGDude it 's here. Fozf want 1. Need that /ltz//J'' Based on m y training and experience, and m y knowledge of this investigation, I believe that Tim othy RABARA advised Nathan HALL that RABARA had at least % ounce of m ethamphetam ine sold for HA LL.

April 21, 2013

Tim othy RABARA to Nathan HALL, ;'G()/ J gone. L ol toldyou that wouldhappen.

ad/k-vkptz-p-ç-poN need to call PtIIX I)?AI a land line or something. Gotyour 20 also'' Based on my training and experience, and m y knowledge of this investigation, 1 believe that Tim othy RABARA advised Nathan HALL that RABARA had already sold 3 gram s of m ethamphetam ine for HA LL.

April 23, 2013

94 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 95 of 106 Pageid#: 98

Nathan HALL to Timothy RABARA, niHey.l My dude won'f b strait tillfri. JJN wtznf u can come to m.c and c mr. 111 Iook out 4 N.'' RABARA to HALL, çibley man 1 m trying to come down that wJy but 1 gotta talk to you hrst fyou do it fyou don t want to do thatjust let me know but 1 gotta knt?w what to do so holla backplease''

Based on m y training and experienee, and m y knowledge of this investigation, l believe that Nathan HALL utilized the text messaging service on his cellular telephone to invite Tim RABARA to M ountain City, TN to meet the methpmphetamine source of supply (Tim GERACE).

April 24, 2013

Tim othy RABARA to Nathan HALL, CtFI)?J still need anything. 1'm good down here.'' HALL to RABARA, iilm not sure. 1 willhnd out n 2 hrs can I come c u then.?...'t HALL to RABARA, GiHey.! 1'm sorry, 1 went under 1 wtz: sick as hell. 1'm at Al 's Al an I can comc an pick up when u give me a green light. I 'm sorry''

Based on m y training and experience, and m y knowledge of this investigation, l believe that Timothy RABARA advised Nathan HALL that RABARA had access to drugs if HALL did not. I believe that HALL eventually plnnned to obtain these dnzgs from RABARA.

April 26, 2013

Tim othy RABARA to Nathan HALL, tû. . .sfake sure you tell big head that 1 like him but fhe ever brings someone hear without asking mehrst 1'm gonna have to make them leave the door. No offense be safe holler on them perks.''

Based on m y training and experience, and m y knowledge of this investigation, 1 believe that Tim othy RABARA advised Nathan HALL that RABARA did not like m eeting strangers when involved in drug activities. I believe that when referring to C'perks'', RABARA was talking about Percocet prescription pills.

ln April, 2013, Smylh County Sheriff s Office Detective Scott Prater received a com plaint that a Departm ent of Corrections Ofticer, subsequently identified as Timothy RABARA, was stealing needles from the correctional facility infinnary and possibly selling dnlgs.

On M ay 2, 2013, M arion Police Officers responded to the residence of Tim othy RABARA for a welfare check. RABARA was employed by the Department of Corrections and did not show up for work. W hen officers encountered RABARA, drug paraphernalia and residue were seized from his person. ILABARA made statements that he smoked marijuana but the needles were clean. RABARA stated that he sold the needles for extra money.

On June 20, 20 13, CS-7 was interviewed in Abingdon, VA . CS-7 stated that several weeks prior, they had been with Nathan HALL at HALL'S apartm ent when HALL and a white

95 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 96 of 106 Pageid#: 99

male named Ck-l-im'' attempted to m anufacttzre m ethamphetam ine. HALL told CS-7 that id-l-im'' was cool because he was a law enforcem ent officer in M arion, VA . CS-7 rode with tt-l-im '' to purchase m atches and iodine while HALL and his m other purchased Sudafed and fdlleef'. CS-7 stated that all these m aterials were purchased for the m anufacturing of m ethamphetamine.

On August 16, 2013, a search warrant was executed at 19012 Lake Rd., Abingdon, VA, the residence of N athan HALL, Brandi DUNFORD, W illiam HUN T, Jr., Jr. and others. Seized pursuant to the search warrant was a m etham phetamine 1ab and HALL'S cellular telephone. Contained within HALL'S phone were the following text messages with telephone number (276) 780-1337 (Timothy RABARA):

Tim othy RABARA to Nathan HALL, ûC. . . Can '/.#z;# no shit up here. People Iook at me and sayyou want crack. L 01.'' RABARA to HALL, ièWent to reup and they gave me ourpure shit like before. L et me Ccntpw 111 come your wtzy. Ifyou can get rid ofa couple. 120,, RABARA to HALL, *%Heyp**** boy, I'mjust lettingyou know 1'm about to make a ride to the cï/y got a ncw connection Ifyou need anything let me kntpw 1'11 swing thru. Yep its back 1 get out a tp **** and wc 'll make some money. CyJ''

Based on my training and experience, and m y knowledge of this investigation, 1 believe that Tim othy RABARA advised Nathan HALL that RABARA was in search of metham phetam ine in the city, but could only find crack cocaine. I believe that RABARA eventually found a new source of supply for m ethamphetam ine and asked HALL to sell it for $120.00 per gram .

Albert Lee HAG UE

Albert Hague has prior arrests for felonious assault with a firearm , possession of schedule 11 for resale, violation of probation, possession with intent to m anufacture/sell schedule I or 11 substance, and possession of marijuana. On January 13, 201 1, Albert HAGUE was a passenger in a vehicle with three (3) other occupants when it was stopped by a Galax, VA police officer. Subsequent to a consent search on the vehicle, one (1) bag of marijuana, one (1) bag of methamphetamine and 12 small bags of cocaine were seized. Al1 four occupants of the vehicle were acested and charged with possession with intent to distribute narcotics. According to the records of Verizon W ireless, telephone number (423) 440-2255 was resold to TracFone with no subscriber inform ation available. According to text m essages received via court order, the user of this phone was ttAlbelf'. This phone was in contact with Timothy GERACE, Nathan HALL and Jeremiah Yates (possible methamphetamine source of supply to GERACE) from at least Febnzary to July, 2013. As a result of this investigation, your aftsant believes that the primary user of this telephone number was Albert HAGUE. According to the records of TracFone, telephone number (423) 213-0645 was subscribed to by Albert HAGUE at 808 W addell Rd., M ountain City, 'I'N. This phone was activated on

96 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 97 of 106 Pageid#: 100

M arch 12, 201 1 . This phone was in contact with Timothy GERACE from at least January to July, 2013. As a result of this investigation, your affiant believes that the prim ary user of this telephone num ber was Albert HAGUE. According to the records of Sprint, telephone number (423) 291-1395 was subscribed to by Albert HAGUE at 808 W addell Rd., M ountain City, TN. This phone was activated on M arch 24, 20 10. This phone was in contact with Tim othy GERACE and Nathan HALL from at least January to July, 2013. As a result of this investigation, your affiant believes that the primary user of this telephone num ber was Albert HA GUE.

On Februal'y 27, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the account of telephone number (423) 471-1541, the cellular telephone of Timothy GERACE. ln response to the execution of this search w arrant on Verizon W ireless, agents received text m essages stored in that account from January 26 to February 27, 2013. The following is an excerpt from the search w arrant results.

February 15, 2013

A lbert HAGUE to Tim othy GERACE, inlil'ey where u at 1ts AlbertjnL ori andAlbert''

On M arch 22, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephones, including that utilized by Timothy GERACE. ln response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in those accounts from February 24 to M arch 21, 2013, The following is an excerpt from the search warrant results.

M arch 11, 2013

Albert HAGUE to Tim othy GERACE, ikNo road block come onhnW/hcr/''

Based on m y training and experience, and my knowledge of this investigation, l believe that Albert HAGUE utilized the text messaging service on his cellular telephone to advise Tim GERACE that there was no police checkpoint and he was safe to transport drugs. I believe that GERACE utilized HAGUE and others to scout certain routes between Dam ascus, VA and M ountain City, TN in advance of GERACE to determine if it was safe to transport dnzgs along that route.

M arch 15, 2013 Albert HAGUE to Timothy GERACE, **I still cant get ahold ofnumb nuts in NC every thing else jy/ne'' HAGUE to GERACE, Gnllave u heardfrom dipshit yet l've tried since seven'' HAGUE to GERACE, çistill no Danny went //,?-?z slabtown and by school down that wly what nowbnAlbert'' HAGUE to GERACE, ièl'm heading back to shop waitinforfurther instructionst,

97 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 98 of 106 Pageid#: 101

HAGUE to GERACE, Gilpicked up 1520 Danny 9 Wayne 620 Danny 3tonight 1820 minus 20for gas leavesjust enufànAlbert'' GERACE to HAGUE, iiok Dan should have given you 4JpïrI'' HAGUE to GERACE, iiub'o he still tpwc.ç a a buckffty ritejnAlbert'' GERACE to HAGUE, ûkl'c.& / Larrys in the morning J!n'' HAGUE to GERACE, nLokjnAlbert''

Based on my training and experience, and m y krtowledge of this investigation, 1 believe that Albert HA GUE utilized the text m essaging service on his cellular telephone to advise Tim GERACE that HAGUE had collected $1,820.00 in dnzg proceeds from Danny, W ayne and Danny. l believe that GERACE advised HAGUE that Danny still ow ed $150.00 in addition to the $300.00 that he paid. I believe that HAGUE and GERACE were referring to Danny Osborne, whom this affiant knows is a drug associate of GERACE and Jeremiah YATES from N orth Carolina.

M arch 17, 2013 Albert HAGUE to Timothy GEM CE, çnhïever heardkom Danny want me to try gettin him want to get rid ofany morejnAlbert'' Based on my training and experience, and m y knowledge of this investigation, l believe that Albert HAGUE utilized the text m essaging service on his cellular telephone to advise Tim GERACE that he was unable to make contact with Danny Osborne to collect the rem ainder of the dnzg debt. l believe that HAGUE asked GERACE if there was any additional m ethamphetam ine to be sold.

On April 10, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephones, including that utilized by Tim othy GERACE. ln response to the execution of these search warrants on Verizon W ireless, agents received text messages stored in those accounts dating from M arch 23 to April 10, 2013, The following are excerpts fzom the search warrant results.

M arch 31 - April 1, 2013

Timothy GERACE to Albert HAGUE, Giliey let me Fcat/w fDanney stopbn'' HAGUE to GERACE, %*R u ok aint seen dipshit either 'W/bprf'' GERACE to HAGUE, ççlhankyou at Nate talking to Bill right kntlw about boat dock will call in pkïnt//chn''

GERACE to HAGUE, Lx veything all right .?ïa'' HAGUE to GERACE, CSF:J but didnt get none cumming in couple days becareful ffïn laruel law everyplace lookinfor dark suv it out run z/ylhnad/herf'' GERACE to HAGUE, GQlhanks manjn''

Based on m y training and experience, and my knowledge of this investigation, 1 believe that A lbert HAGUE utilized the text m essaging service on his cellular telephone to advise Tim

98 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 99 of 106 Pageid#: 102

GERACE that he still hadn't been in contact with Danny Osborne. l believe that GERACE advised HAGUE that GERACE was at the residence of N athan HALL and W illiam HUNT, Jr.. 1 believe that HAGUE advised GERACE that the m ethamphetam ine would not be available for a couple of days and to be careful of 1aw enforcem ent activity in the area of Laurel Bloom ery, TN .

On April 26, 20 13, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accounts of several cellular telephones, including those utilized by Timothy GERACE, Brady LESTER and Nathan HALL. ln response to the execution of these search warrants on Verizon W ireless, agents received text messages stored in those accounts dating from April 12 to April 26, 20 13. The following are excerpts from the search warrant results.

April 13, 2013

Albert HAGUE to N athan HALL, ççhïate call big guy asap got to get up with u quickbnzqlbert''

Based on my training and experience, and m y knowledge of this investigation, l believe that Albert HAGUE utilized the text messaging selwice on his cellular telephone to advise N athan HALL that Tim GERACE needed to speak with him .

April 20, 2013

Albert HAGUE to Nathan HALL, çiU r makin us real latebnAlbert'' HALL to HAGUE, iilnimmy hasn't called me. 111 b ready n 20*, HAGUE to HALL, GoNeed to do some thing soonjnAlbert'' HALL to HAGUE, kW '' HAGUE to HALL, iGpulled a Budda on me this time u iwcw it wtzs' at to hope u didnt Jcrew things up being latebnAlbert''

HAGUE to HALL, iiGetyour sweet and crazy ass out here pronto prick'' HALL to HAGUE, GGl'm on my wJy out the door''

Based on m y training and experience, and m y knowledge of this investigation, I believe that Albert HAGUE utilized the text m essaging service on his cellular telephone to give diredion to Nathan HALL in reference to the distribution of GERACE'S methamphetam ine. 1 believe that HALL was waiting on Tim othy RABARA, and HAGUE com pared HALL'S punctuality to that of GERACE (aka GèBuddattj.

A pril 22, 2013

Albert HAGUE to N athan HALL, èçWhere u atjnAlbert'' HALL to HAGUE, Gçl'm sat shop. Call me need 2 r-srts''

HAGUE to HALL, iiWhere u atjnzqlbert''

99 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 100 of 106 Pageid#: 103

HALL to HAGUE, çion my wJy J Abing. You good/'' HAGUE to HALL, GGlioing n/w dude wants his axlesfrom A'/ltwïztd/ber/'' HALL to HAGUE, iiok he said he would take care ofhim. I need 2 c u asapl'' HAGUE to HALL, *i1'lI holler as soon as 1 get backjnAlbert'' HALL to HAGUE, GiWhere u at ? Big guy needs 2 go homel''

HAGUE to HALL, iiHey dont make anypromises w: cant keep nothing happen here where u atbnAlbert'' HALL to HAGUE, GGlgot 4 gone''

Based on m y training and experience, and my knowledge of this investigation, I believe that Albert HAGUE utilized the text m essaging selarice on his cellular telephone to receive a drug order from Nathan HALL and advise HALL that HAGUE was going to pick up the methamphetamine (çiaxlest,) at GERACE'S garage (Gshop'à. 1 believe that HAGUE reprimanded HALL regarding the sales of m ethamphetamine at GERACE'S residence, and HALL advised HAGUE that he had already sold four (4) grams of methamphetamine.

April 23, 2013

Albert HAGUE to Timothy GERACE, t(f 'm done here how Iong befor u com this waybnAlbert'' GERACE to HAGUE, ikzqbout lhour l5jn''

N athan HALL to HAGUE, iQon my wJy over. Dude is Acc/c/'' HAGUE to HALL, GGlkl'ow long u bbnAlbert'' HALL to HAGUE, 1630 u gt)o#?'' HAGUE to HALL, çiNo told me b home in to hrsjnAlbert'' HALL to HAGUE, *X b there asap. Got 2 gonel'' Based on my training and experience, and my knowledge of this investigation, 1 believe that Albert HAGUE utilized the text m essaging servlce on his cellular telephone to comm tmicate with Tim GERACE and Nathan HALL about m eeting for the pum ose of selling methamphetmnine. I believe that HALL advised HAGUE that he had already sold two (2) grams of methamphetamine.

April 24, 2013

Nathan HALL to Albert HAGUE, çi9 months go njul 26. Call on those c-1 lzF': will cool dinner/', HAGUE to HALL, iol've been trying cant get no one to answer where u b at LnAlbert'' HALL to HAGUE, içW ith big guyl B over n a couple hrs.''

HAGUE to HALL, LGllam I 'vc mrade a dozen calls no luck I 'll keep trying gotph s'wtzlwtrtf' HAGUE to HALL, d;f 've got to run over gentry creek b back in f/vïr/ylnW/icr/'' HALL to HAGUE, QQK call me when u get back''

100 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 101 of 106 Pageid#: 104

HAGUE to HALL, nèllidn 't mean tofuck ur head up earlier dude wanted credit told him 1 had to call o//c: is a1l going okstill no cool supper holler hfzc/c'' Based on m y training and experience, and m y knowledge of this investigation, l believe that Albert HAGUE utilized the text m essaging service on his cellular telephone to com municate with Nathan HALL about a methamphetamine 1ab ($(w: will cool dinner/'t). I believe that HALL told HAGUE to call his dnlg custom ers, and HAGUE was unable to get them to answer. l believe that HAGUE met a dnzg custom er in Gentry Creek who wanted the m ethamphetam ine without paying for it (û$cr:Jff'') and HAGUE called HALL for direction. I believe that HAGUE advised HALL of the status of the methamphetamine cook (QGstill no cool supper'b. April 26, 2013

Albert HAGUE to Nathan HALL, i*Nate whats up man thought w: wtz-ç gonna workfuck u no 1 need money this is messed up hnxd/bcrf'' HAGUE to HALL, GnWhat thefuck is this the wtzy 1 getpaid backfor helpin u when big #u y wtzy down't

Based on m y training and experience, and m y knowledge of this investigation, 1 believe that Albert HAGUE utilized the text m essaging service on his cellular telephone to advise N athan HALL that he needed m oney and thought they were going to cook m ethamphetam ine again (k$wt?rk'') On August 16, 2013, a search warrant was executed at 19012 Lake Rd., Abingdon, VA, the residence of Nathan HALL, Brandi DUNFORD, W illiam HUNT, Jr., Jr. and others. Seized pursuant to the search warrant was a m ethamphetam ine lab and HALL'S cellular telephone. Listed in the Contacts List of HALL'S phone under the nam e EtBig Al'' was telephone num ber (423) 440-2255 (Albert HAGUE).

Kim berly Ann Bradley

Kimberly Bradley has a prior arrest for driving under the influence.

According to the records of Verizon W ireless, telephone number (423) 440-2315 was resold to TracFone with no subscriber inform ation available. According to text messages received via court order, the user of this telephone was :% im ''. According to the records of Thomas Reuters (credit report), this telephone number has been utilized by Kim BRADLEY at 103 George M iller St., Gray, TN and Kim berly A. BRADLEY at 341 Conville Ln., M ountain City, TN . As a result of this investigation, your affiant believes that the primary user of this telephone was Kim berly BRADLEY.

On February 27, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text messages stored in the accotmt of telephone number (423) 471-1541, the cellular telephone of Tim othy GERACE. ln response to the execution of this search warrant on Verizon W ireless, agents received text m essages stored in that account from January 26 to February 27, 2013. The following is an excerpt from the search warrant results.

101 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 102 of 106 Pageid#: 105

February 5,2013

Tim othy GERACE to Kim BRADLEY, Qnl-ley Kim I 'm in trouble is there any wcy f can get some ofthat/'' BRADLEY to GERACE, Qnlkkay come dwn here eat with us and smoke with usplz'' BRADLEY to GERACE, iilnhis guy is cool idfeel better fu come help or over see this <$àf/'' GERACE to BRADLEY, 'iDown where't BRADLEY to GERACE, éicut offhighway like going to Millcreek but stay on highway Jr-sf house on top ofhill on /c.# u c my Volvo'' GERACE to BRADLEY, çGOk'' BRADLEY to GERACE, çiWeIl it's cool here no pepple comes here or ivzf#n/ b doing this. Come on id like to have suml bc its been long time since ive done this...t' GERACE to BRADLEY, **Ok'' BRADLEY to GERACE, iivb'o wht u gonna or not. U no I wud notput u n harms wly'' GERACE to BRADLEY, déFey'' BRADLEY to GERACE, GGsounds like dude havn rough time. U met him hes cool but 1 think he may screw this up. 1dk how to do this kind ''

February 6, 2013

BRADLEY to GERACE, *iI need u show me how to do somethn. Ihad ball halfgot stolen put msn n but itsjustpowder need make it look chunky Wht do I do'' BRADLEY to GERACE, %è1 didn 't say nothn last nite bc ofthe dude. Its Jltzt/'n hafnow butpowder it needs look like rocks help me Az'' BRADLEY to GERACE, QQlve never done tht b4 but lgot to. 1ts not mine and im up the creek and 1 need talk to u bout L ee. But nol needs to hear wht im going to tell ?./.''

February 15,2013

GERACE to BRADLEY, çiWhats lw'' GERACE to BR ADLEY, içcall rne'' BRADLEY to GERACE, GGljust wo/cc up haven 't got hold anylt' BRADLEY and GERACE, iiïk'hn lhgure out wher to go wc will I do no its not across line n nc so waiting on him get hold me. lm damn tired ofwaiting. Need my clrptzrf''

February 16,2013

BRADLEY to GERACE, Giljust wo/œ up got txt sayn he b n mtn c 20 mins but my damn

phone wJ.$ turned tl.#'(z// nite ive called him n fxfl he don 't answer so idk wher he is'' BRADLEY to GERACE, çildk Ifhe gone on road or went home fhes n Wilkesboro 1 have u take me there but 1 got tohnd himhrst. 1 hate thisfknphone it turns itsel 0.J/'' Based on my training and experience, and m y knowledge of this organization, 1 believe that GERACE utilized the text m essaging selwice on his cellular telephone to communicate with Kim berly BRADLEY regarding the manufacturing of m ethamphetam ine. I believe that

102 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 103 of 106 Pageid#: 106

BRADLEY requested GERACE to come to a house where she and an unknown m ale had a m etham phetam ine ttcook'' so GERACE could assist them in the production of metham phetam ine. 1 believe that BRADLEY asked GERACE how to add M SM to m etham phetam ine and m aintain consistency. 1 believe that BRADLEY attem pted to obtain m etham phetam ine for GERACE from an unknown male from W ilkesboro, NC. I Your affiant knows that it is comm on for dnzg distributors to add M ethylsulfonylm ethane (M SM) to methamphetamine as a ûkcuf', or additive, to increase the quantity of drug substance for a m ore protkable product.

February 22, 2013

Tim othy GERACE to Kim BRADLEY, GiWhatyear car is f/7lfsn'' BRADLEY to GERACE, 661992 940 gl-so over j/'' GERACE to BRADLEY, Gilhanks . Happy birthday !n'' BRADLEY to GERACE, çblhnks my bday sucks L ori txtn wontn no about me being there 1 said u washxn my car-so over it'' According to Thomas Reuters (credit history) and NCIC, Kimberly Ann BRADLEY has a birth date of Febnzary 22, 1971. A ccording to Thom as Reuters, BRADLEY owns a 1991 Volvo 740.

February 23,2013 Kim BRADLEY to Wanda LNU, Gnïkho thefuck is this-so over it'' W anda LNU to BRADLEY, içstormy'' W anda LNU to BRADLEY, çiW/ the house do you have anythinf' BRADLEY to W anda LNU , $tf ord no. Wished 1 needzannys wht 1 need-so over it'' BRADLEY to W anda LNU, çiïkhos number is this-so over it'' W anda LNU to BRADLEY, çtA/y boy Ryan need some dope'' BRADLEY to W anda LNU , nillnt wc all.I hear tht Renee n Keith n Nichole n thm do but idk dntfuck with thm-so over f/'' BRADLEY to Samantha Snyder, Lisend me Nicholes num my cuz Wondajust txtd won/ to no pfncw anything out ofblu#m 828 num-so over 1*/7' Snyder to BRADLEY, is-zlzisxwcr thefuckinphone home nun Sn -oh so wc/'' Snyder to BRADLEY, çiplz bring myfone I need itfor bidnezzjn -oh so wc/'' BRADLEY to Snyder, Giugotpulled over I do evefbthng u ask u got the dope the money I've done everthng u ask 1 ant no nigger u gotpulld over bring my god damn scales -so over it'' BRADLEY to Snyder, GGu didnt go without shit whn 1 had dope n money Flt?w didya ????God damn it-so over ff'' BRADLEY to Snyder, i*zpeaces dope all 1 goth'm u lil money w/w look wht all 1 did 4 u.1 'm not God damn scared-so over ï/'' Snyder to BRADLEY, nnYour being a stupid bitch because dope and hookups. There is more to 144 than stupid shitl Thats one thing 1 thoughtyoufelt the same wly f did there''

103 Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 104 of 106 Pageid#: 107

BRADLEY to Snyder, LGl-l'ay chic wher r u I need my scalesfor real-so over f/'' BRADLEY to Kevin LNU, GGu wanna smk my shit while Ijust set their with my mouth shut bc cant understand me thtsjust real sweet ofu.l //t)/* # shine-so over f/'' Kevin LNU to BRADLEY, *i1 need a hit or 2 kim pleasel''

Based on m y training and experience, and my knowledge of this organization, l believe that Kim BRAD LEY utilized the text m essaging service on her cellular telephone to communicate with W anda LNU about obtaining methamphetamine (idopet'j for Ryan LNU. I believe that BRADLEY comm unicated with Sam antha Snyder about how BRADLEY had provided m ethamphetam ine to Snyder as well as how BRADLEY had sold m etham phetam ine for Snyder, and how BRADLEY wanted her scales back. I believe that BRADLEY com municated with Kevin LN U, a methnmphetamine custom er of BRADLEY. I Your affiant knows that scales are a necessity for drug dealers, as monetary amounts for drugs are based on exad weight, from gram s to ounces to pounds.

On M arch 22, 2013, a search warrant was applied for and obtained in the W estern District of Virginia for text m essages stored in the accounts of several cellular telephones, including those utilized by Tim othy GERACE and Kim berly BRADLEY. In response to the execution of this search warrant on Verizon W ireless, agents received text messages stored in those accounts from February 24 to M arch 21, 2013. The following is an excerpt from the search warrant results.

M arch 3, 2013 Kim BRADLEY to Linda LNU, çil)o u no ofany zannys-so over ff'' Linda LNU to BRADLEY, *i1 might. But right ntpw 1 am on the huntfor 2 grams offast.

Got 230 bucks. This is the last day 1 can do it. In need bad. ïn *.#oggy*'' BRADLEY to Linda LN U, ççWell 1'm waitn 4 thm to wtz/cc up cant do nothing until thy wtz/c: up-so over f/'' Linda LNU to BRADLEY, Qlet me see what 1 can do about the zannysbn t#'(?gp?*'' Based on m y training and experience, and m y knowledge of this organization, 1 believe that Kim BRADLEY utilized the text m essaging service on her cellular telephone to communicate with Linda LNU about Xanax (Gizannys't) and methamphetamine (ifasttt).

M arch 7, 2013 Kim BRADLEY to (423) 483-6494, QçGot u 2 more klopins waitn on zannys-so over it'' (423) 483-6494 to BRADLEY, **Ok doin goodget all u canjndm'' BRADLEY to (423) 483-6494, iiWill do-so over 2'' Based on m y training and experience, and my knowledge of this organization, I believe that Kim BRADLEY utilized the text m essaging service on her cellular telephone to Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 105 of 106 Pageid#: 108

comm unicate with a dnlg custom er regarding the availability of the prescription drugs Klonopin and Xanax.

Cooperating Sources

Throughout this aftidavit your aftiant will identify several individuals by nam e and several as Cooperating Sources (CS) which were interviewed during this investigation. Your affiant believes the inform ation provided by them , and included in this affidavit, to be credible and reliable for the following reasons: the debriefings included statements against their own penal interest, the information provided by them m atched inform ation received from other sources, and m uch of this inform ation was confirm ed by other investigative m ethods. Som e of these m ethods included surveillances and records acquired during the investigation, including records of phone calls and text messages between the co-conspirators. CS' are utilized for several reasons: a CS might be a member of the target organization and therefore have easy access to information needed by law enforcem ent; a CS m ight have a relationship with m em bers of the target organization, m aking it easy to purchase and/or locate illegal substances, profits, etc.; and in m any situations a CS provides to law enforcement the opportunity to intiltrate an organization when all other means are exhausted. CS-1, CS-4, and CS-5 were arrested for violations of the law, most of which were drug distribution charges. The CS' provided information on other crim es, including drug traffkkers, in retlzrn for consideration for reduced sentences. CS-2 cooperated with law enforcem ent and received no compensation. CS-3 provided inform ation to 1aw enforcem ent in retuz.n for consideration for charges which had not yet been brought against them . CS-6 was arrested for driving suspended and cooperated with 1aw enforcem ent for consideration on charges and w as paid com pensation after charges were resolved. CS-8 was arrested for possession of metham phetamine and provided inform ation for consideration for a reduce sentence and received no compensation. CS-9 provided information consideration on charges. CS-I 1 provided information to law enforcem ent in return for consideration for charges against Gary HOW ELL.

CO NCLUSION

Based on the aforem entioned factual inform ation and your aftiant's training and experience in crim inal investigations, your affiant believes that probable cause exists to conclude that, in or about 2009 until present, within the W estena District of Virginia and the Eastern District of Telm essee the aforem entioned persons com mitted one or m ore violations of: United States Code Sections 841 (a)(1) and 846 (Conspiracy and Controlled Substance Violations), criminal organizations engaged in conspiracies to manufacture and/or possess with Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 106 of 106 Pageid#: 109

intent to distribute cocaine, methamphetamine, marijuana and other dangerous drugs prohibited by law, search and seizure law , and many other facets of dnlg law enforcement. Based on the aforem entioned fadual inform ation and your affiant's training and experience in erim inal investigations, your affiant believes that probable cause exists to conclude that fruits, evidence and instrum entalities of the above mentioned criminal offenses may be located at the locations described in Attachm ent A.

REOUEST FOR SEALJNG

lt is respectfully requested that this Court issue an order sealing, until f'urther order of the Court, all papers subm itted in support of this application, including the application and search wm ant. l believe that sealing this document is necessary because the item s and inform ation to be seized are relevant to an ongoing investigation into the crim inal organizations as not a11 of the targets of this investigation will be searched at this tim e. Based upon my training and experience, I have learned that, online criminals actively search for crim inal affidavits and search warrants via the internet, and dissem inate them to other online crim inals as they deem appropriate. Premature disclosure of the contents of this affidavit and related documents may have a significant and negative im pact on the continuing investigation and may severely jeopardize its effectiveness.

1 declare under the penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. Executed on April , 2014, at Abingdon, Virginia.

IJ onathan Tabor, Special Agent Bureau Alcohol, Tobacco, Firearm s & Explosives

SW ORN AND SUBSCRIBED TO BEFORE M E THIS DAY OF APRIL, 2014

ONORABLE JUDGE PAM E M ADE SARGEN T UN ITED STATES DISTRICT URT IN THE W ESTERN DISTRICT OF VIRGINIA

106