James Bullock Complaint

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    FILED

    U.S. DlSTRICr C O i{F n

    UNiEJj< ~TA :T E S " D IS fif il c T C O U R T

    l t t ~ I P U C f 3O~ ~~OLAND

    UNITED STATES OF AMERICA ~~ E~ K 'SprF J ,~EIe. r ,u'\L T d d)r _

    CASE NUMBER:

    v.

    JAMES BULLOCK

    5305B Valiquet Avenue

    Baltrimore,'Marylalnd

    8'1' __ , .. CRIMIWAL COMPLAINT

    / 0 - -1 2 ;0 1 5 K -C - -

    I, the undersigned complainant, being duly sworn state the following is true and correct to

    the best of my knowledge and belief. On or about April 12, 2010, defendant, (Track Statutory Language Offense)

    James Bullock, d~d knowingly, intentionally and unlawfully possess with the intent to distribute a

    mixture or substance substance containing a detectible amount of heroin, a Schedule I controlled

    substance,

    in violation of Title -.2.L United States Code, Section(s) 841

    I further state that I am a Task Force Officer of the Drug Enforcement Administration, and that this

    complaint is based on the following facts: Official Title

    SEE ATTACHED AFFIDAVIT

    Continued on the att~ched sheet and made a part hereof: 0Yes 0No

    William Nic

    Drug Enfor

    es, Task Force Officer

    ent Administration

    Susan K. ai.rv~y:j

    United States Migistrate Judge# ' . " . . ~

    . . .

    " " 41 ; ; ;. ~ . . . ." . ,. "'. . ; ,

    . , -~ - .

    . -

    Baltimore, Maryland

    Case 1:10-mj-01339-SKG Document 1 Filed 04/12/10 Page 1 of 4

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    AFFIDAVIT

    This affidavit is submitted in support of an application for a criminal complaint charging James

    Bullock ("the defendant") with violating 21 U.S.C. S841 to wit: possession with the intent to distribute

    heroin, a Schedule I controlled substance.

    I, William Nickoles, am a Detective with the Baltimore Police Department and have been

    so employed since 1992. I have been deputized as a Task Force Officer with the DEA for

    approximately nine (9) years. I am currently assigned to the DEA's Special Investigations Group

    (DEA SIG), which investigates large-scale narcotics trafficking organizations in the Baltimore area.

    During my time as a law enforcement officer, I have participated in numerous investigations of

    unlawful drug distribution and investigations of violent gangs, including the use of confidential

    I

    informants and cooperating witnesses, undercover transactions, physical and electronic surveillance,

    telephone toll analysis, investigative interviews, the execution of search warrants, and the recovery

    of substantial quantities of narcotics, narcotics proceeds, and narcotics paraphernalia. I have

    reviewed taped conversations, as well as documents and other records relating to narcotics

    trafficking and gang activity. I have interviewed drug dealers, users and confidential informants and

    have discussed with them the lifestyles, appearance and habits of drug dealers and users. Through

    my training, education and experience, I have become familiar with the manner in which illegal

    drugs are transported, stored, and distributed; the methods of payment for such drugs; the possession

    and use of firearms in connection with the trafficking of such drugs; and the manner in which

    narcotics traffickers store and conceal the proceeds of their illegal activities.

    On April 8, 2010 law enforcement obtained search warrants, as part of an on- going

    investigation conducted by DEA SIG into narcotics trafficking associated with the Black Guerilla

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    Family (BGF). These warrants, signed by the Honorable 1. Frederick Motz, United States District

    Court Judge, were for 11 locations in and around Baltimore City, including 5305B Valiquet Avenue

    in Baltimore, Maryland ("the Valiquet address"). On April 12, 2010 at approximately 6:00 a.m., law

    enforcement executed the search warrant at the Valiquet address. Upon entering the location, law

    enforcement encountered the defendant inside the residence. After being secured by law enforcement,

    the defendant, who is a prohibited person, told the officer that he had a gun under his mattress. The

    defendant was then read his rights and informed the officers of the locations of the drugs in the

    residence.. An orderly search was then conducted. During the search, agents/officers recovered

    approximately 100 gelatin capsules of suspected heroin in a pot on the kitchen counter; inside a ,child's

    cup on a shelf in the kitchen was approximately 24 grams of suspected heroin; inside another child's

    cup in the dishwasher was another 4 gr~ms of suspected heroin; in an ashtray in the living room were

    4 baggies containing a total of23 gelatin capsules of suspected heroin; in the kitchen in a cooler were

    two bottles of quinine; used to process heroin; in the laundry room was four Cap M' Quick units, a

    large bag with empty gelatine capsules, and a large bag with suspected cutting agents. In the bedroom

    under the mattress, where a child was sleeping, was a 9mm Glock 26, in the locked-back position, next

    to the firearm were two loaded magazines. Also in the bedroom was a ballistic vest. A sampling of

    the gelatin~ capsules tested positive for the presence of heroin.

    I know, based on his training and experience, that the evidence seized from the Valiquet

    address is consistent with the preparation, pack~ging and distribution of heroin. On the foregoing, it

    is therefore my belief that James Bullock is in violation 21 U.S.C. 9841, to wit: possession with the

    intent to distribute heroin.

    koles, Task Force Officer

    cement Administration

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    Signed, sworn and subscribed to before me this (Z-day of April, 2010.

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