Heroin

Case 1:09-mj-01168-SKG

Document 1

Filed 03/30/2009

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UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND

UNITED STATES OF AMERICA

v. CRIMINAL COMPLAINT

FrankAIDOO

CASE NUMBER:

00/ -I /~ rsKC-

I, Richard Federico, the undersigned complainant being duly sworn state the following is true and correct to the best of my knowledge and belief. On or about March 30, 2009 in the District of Maryland, defendant did, (Track Statutory Language Offense)

Knowingly and intentionally import into the United States of America, from a place outside thereof, 1.2 kilograms or more of a mixture or substance containing a detectable amount of heroin, a Schedule I controlled substance, and did knowingly and intentionally possess with the intent said quantity of heroin, in violation of Title

.lL United

States Code, Section(s) 952(a), 960 (a) and 841.

I further state that I am a Special Agent of the U.S. Immigration and Customs Enforcement, and that this complaint is based on the following facts: Official Title

SEE ATTACHED AFFIDAVIT CdJhtinuedon the attached sheet and made ~ part hereof: ~

Sworn to before me and subscribed in my presence,

March 30, 2009 Date

United States Magistrate Judge

at

No

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AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT I.

Purpose of the Affidavit 1.

This affidavit is submitted in support of a criminal complaint charging

Frank AIDOO with conspiracy to import 1.2 kilograms or more of a quantity of a mixture or substance containing heroin, a Schedule I controlled substance, into the United States from a place outside the United States, to wit, Ghana and elsewhere, in violation of21 U.S.C. sections 952(a) and 960(a). II.

Your Affiant

2.

Your affiant, Richard Federico, is a Special Agent of the United States

Department of Homeland Security, Immigration and Customs Enforcement (ICE), in Baltimore, Maryland. As such, your affiant is a law enforcement officer of the United States within the meaning of Section 2510(7) of Title 18 of the United States Code, that is, an officer empowered by law to conduct investigations of, and make arrests for, offenses enumerated in Section2516 of Title 18.

3.

Your affiant is a Special Agent with United States Immigration and

Customs Enforcement (ICE), under the Department of Homeland Security and is presently

assigned

to the

Smuggling/Narcotics

Group, at the

Baltimore

Washington International (BWI) Airport. During his tenure as a Federal Criminal Investigator, your affiant has participated in numerous investigations involving smuggling, narcotics, and other unlawful activities. These investigations have included the use of surveillance techniques and the execution of search, seizure, and arrest warrants. Your affiant has attended the Criminal Investigator Training

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Program and Customs Basic Law Enforcement Academy at the Federal Law Enforcement Training Center. Your affiant is familiar with the facts and circumstances of the investigation that is the subject of this search warrant application. Your affiant has been employed with

u.s

Customs Service /ICE

since January 1998. III.

Probable Cause 4. On Friday, March 27, 2009, at approximately 1801 hours, Frank AIDOO, Citizen of Netherlands (Ghana born) (DOB 12-02-54) arrived at Baltimore Washington International Airport, Baltimore, Maryland aboard a British Airways Flight Number 229 from London Heathrow International Airport, London, Great Britain England. Customs and Border Protection (CBP) Officer obtained information regarding AIDOO's airfare and prior activities. AIDOO's ticket was purchased (cash) three days prior to flight. Intelligence obtained alleged that AIDOO had been involved in heroin smuggling activities. AIDOO had traveled to an address in New York utilized by Nigerian heroin smugglers, who were apprehended at John F. Kennedy Airport and in Boston. Upon questioning by CBP Officers, AIDOO became very nervous and did not know where he was staying. AIDOO indicated that his purpose for travel was that he was visiting his nephew for a couple of weeks. CBP Officers contacted the alleged nephew, and the stories told by AIDOO and alleged nephew were different. Upon further questioning, AIDOO informed the CBP inspectors that he had ingested pellets of heroin. AIDOO was taken to Baltimore Washington Medical where he passed 100

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pellets of heroin; total weight of 1.2 kilograms of heroin. A field test.on a sample of the pellets was positive for heroin.

5. On Saturday, March 28, 2009, Immigration and Customs Enforcement, Special Agents (SA) Rick Federico and Irina Kuvykina identified themselves and explained to AIDOO that he under arrest for the smuggling of heroin. At approximately 1301' hours, SA Federico advised AIDOO of his Miranda Rights in the English language witnessed by SA Kuvykina. AIDOO indicated that he understood his rights and requested to speak with an attorney before answering any question. At this time, the interview was terminate~. IV.

Conclusion Based on the foregoing, I submit that there is probable cause to believe that Frank AIDOO did knowingly and intentionally import 1.2 kilograms or more of a quantity of a mixture or substance containing heroin, a Schedule I controlled substance into the United States from a place outside the United States, and did possess heroin with the Intent to distribute it, in violation of21 U.S.C. 952, 960 and 841(a).

f~

Richard Federico ~ Special Agent, U.S. Immigration and ~s~

J--

Enforcement

..