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- )*'$SI' A: :'f;-x: F 'è' f) r. .' tl'.zctkb,:' lflzhè'ltcl)r sax,s oFFlcE I.J .S. DIST. COURT : t -, . ev. 1 1/1 1 ) Criminal Complaint kr. ox. .,u,. j...t . '. .,. ,.gi's . ,:-.; ji)j Aytk.-: ct- z !J.IZ - N, vjyj .,t 1 h' . à' ' '' .' ' . '. L. è<L - 5 ' ;q 2 . :r. ç '$t yjuE,; 1TE T TES lST CT R T for the AFR 1 i 2016 W estern D istrict of V irginia Ju DUD , BY'. U cLE nited States of America Richard Shaw case xo. l . ) q /u ) 67 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.