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Case 3:21-mj-05013-JRC

AO 106 (Rev. 04/10) Application Document


for a Search WarranW 0RGLILHG:$:' 1 Filed 01/15/21 Page 1 of 38

UNITED STATES DISTRICT COURT FILED LODGED


RECEIVED

for the
Jan 15, 2021
Western District
__________ of Washington
District of __________ CLERK U.S. DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON AT TACOMA
BY DEPUTY
In the Matter of the Search of )
(Briefly describe the property to be searched )
or identify the person by name and address) ) Case No. MJ21-5013
The 7 Mobile Telephones, more fully described in )
Attachments A )
)

APPLICATION FOR A SEARCH WARRANT


I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):
The 7 Mobile Telephones more fully described in Attachments A, incorporated herein by reference.

located in the Western District of Washington , there is now concealed (identify the
person or describe the property to be seized):

See Attachments B, incorporated herein by reference.

The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
✔ evidence of a crime;
u
✔ contraband, fruits of crime, or other items illegally possessed;
u
✔ property designed for use, intended for use, or used in committing a crime;
u
u a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section Offense Description
18 U.S.C. § 1956 Money Laundering
21 U.S.C. § 841 and 846 Distribution and Conspiracy to Distribute Controlled Substances

The application is based on these facts:


✔ See Affidavit of Special Agent Richard Schroff, continued on the attached sheet.

X  Delayed notice of 30 days (give exact ending date if more than 30 days: LVUHTXHVWHG
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.

3XUVXDQWWR)HG5&ULP3WKLVZDUUDQWLVSUHVHQWHG ✔ E\UHOLDEOHHOHFWURQLFPHDQVRU WHOHSKRQLFDOO\UHFRUGHG


Digitally signed by
RICHARD RICHARD SCHROFF
Date: 2021.01.13 12:48:34
SCHROFF -08'00'

Applicant’s signature

Richard Schroff, Special Agent


Printed name and title

7KHIRUHJRLQJDIILGDYLWZDVVworn to before me and signed in my presenceRU


7KHDERYHQDPHGDJHQWSURYLGHGDVZRUQVWDWHPHQWDWWHVWLQJWRWKHWUXWKRIWKHIRUHJRLQJDIILGDYLWE\WHOHSKRQH
I WKHIRUHJRLQJDIILGDYLWE\WH

Date: 01/15/2021
Judge’s signature

City and state: Tacoma, Washington J. Richard Creatura, United States Magistrate Judge
Printed name and title

USAO: 2020R00599
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 2 of 38

1 ATTACHMENT A1

2 Property to Be Searched and Subscriber/Subject Information

3 Records and information associated with the cellular phones assigned call numbers:

4 TT1: 214-437-6862

5 TT2: 360-809-8988

6 TT3: 253-778-5404

7 TT4: 253-392-4366

8 TT6: 206-945-6572

9 TT7: 360-477-0834

10 that are in the custody or control of Verizon Wireless, a service provider headquartered at

11 180 Washington Valley Road Bedminster, NJ 07921.

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ATTACHMENT A1 - 1 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 3 of 38

1 ATTACHMENT B1

2 Particular Things to be Seized

3
4 I. Section I: Information to be Disclosed by Verizon Wireless

5 To the extent that the information described in Attachment A is within the

6 possession, custody, or control of Verizon, regardless of whether such information is

7 located within or outside of the United States, including any records, files, logs, or

8 information that has been deleted but is still available to Verizon, or has been preserved

9 pursuant to a request made under 18 U.S.C. § 2703(f), Verizon is required to disclose the

10 following information to the government for each account or identifier listed in

11 Attachment A:

12 1. Subscriber/Account Information. The following non-content information

13 about the customers or subscribers associated with the Accounts listed in Attachment A:

14 a. Names (including subscriber names, usernames, and screen names);

15 b. Addresses (including mailing addresses, residential addresses,

16 business addresses, and e-mail addresses);

17 c. Local and long-distance telephone connection records from May 1,

18 2020 to August 18, 2020;

19 d. Records of session times and durations, and the temporarily assigned

20 network addresses (such as Internet Protocol (“IP”) addresses) associated with those

21 sessions from May 1, 2020 to August 18, 2020;

22 e. Length of service (including start date) and types of service utilized;

23 f. Telephone or instrument numbers (including MAC addresses,

24 Electronic Serial Numbers (“ESN”), Mobile Electronic Identity Numbers (“MEIN”),

25 Mobile Equipment Identifier (“MEID”), Mobile Identification Number (“MIN”),

26 Subscriber Identity Modules (“SIM”), Mobile Subscriber Integrated Services Digital

27 Network Numbers (“MSISDN”), International Mobile Subscriber Identity Identifiers

28 (“IMSI”), or International Mobile Equipment Identities (“IMEI”);

ATTACHMENT B1 - 1 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 4 of 38

1 g. Other subscriber numbers or identities (including the registration

2 Internet Protocol (“IP”) address); and

3 h. Means and source of payment for such service (including any credit

4 card or bank account number) and billing records.

5 2. Historical Cell Cite Location Information.

6 a. All records and other information (not including the contents of

7 communications) relating to wire and electronic communications sent or received by the

8 Accounts from May 1, 2020 to August 18, 2020, including:

9 i. the date and time of the communication, the method of the


10 communication, and the source and destination of the communication (such as the
11 source and destination telephone numbers (call detail records), email addresses,
12 and IP addresses); and
13 ii. historical cell site information regarding the cell tower and
14 antenna face (also known as “sectors”) through which the communications were
15 sent and received. This information is to be provided irrespective of the
16 application, name, or report utilized by the Verizon Wireless. Accordingly, this
17 information includes the following data sets to the extent that they are collected by
18 the Verizon Wireless: RTT, PLU, PCMD, NELOS, EVDO, TruCall, ALULTE,
19 and Timing Advance.
20 b. The physical address and coverage maps of cell towers used by the
21 Accounts.
22
The Provider is hereby ordered to disclose the above information to the
23 government within 14 days of issuance of this warrant.
24
II. Section II: Information to Be Seized by the Government
25
All information described above in Section I that constitutes evidence of violations
26
of 18 U.S.C. § 1956 (money laundering) ,21 U.S.C. § 841 (distribution of, and possession
27
with intent to distribute controlled substances, and 21 U.S.C. § 846 (conspiracy to
28

ATTACHMENT B1 - 2 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 5 of 38

1 distribute drugs), those violations occurring between May 2020 and August 2020

2 including, for each account or identifier listed on Attachment A, information pertaining to

3 the following matters:

4 1. Evidence of the sale and possession of illegal drugs.

5 2. Evidence of money laundering.

6 3. Evidence of the relationship between co-conspirators.

7 4. Evidence of the location and identity of the individuals using the Accounts.

8 5. All non-content subscriber/account information provided pursuant to 18

9 U.S.C. § 2703(c).

10 6. Evidence of introduction of drugs into a confinement facility.

11 7. Evidence of a conspiracy to distribute drugs.

12
13 Law enforcement personnel (who may include, in addition to law enforcement

14 officers and agents, attorneys for the government, attorney support staff, agency

15 personnel assisting the government in this investigation, and outside technical experts

16 under government control) are authorized to review the records produced by the Verizon

17 Wireless in order to locate the things particularly described in this Warrant.

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ATTACHMENT B1 - 3 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 6 of 38

1 ATTACHMENT A2

2 Property to Be Searched and Subscriber/Subject Information

3 Records and information associated with the cellular phone assigned call number:

4 TT5: (206) 696-9070

5 that is in the custody or control of T-Mobile, a service provider headquartered at

6 4 Sylvan Way, Parsippany, NJ 07054.

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ATTACHMENT A2 - 1 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 7 of 38

1 ATTACHMENT B2

2 Particular Things to be Seized

3
4 I. Section I: Information to be Disclosed by T-Mobile

5 To the extent that the information described in Attachment A is within the

6 possession, custody, or control of T-Mobile, regardless of whether such information is

7 located within or outside of the United States, including any records, files, logs, or

8 information that has been deleted but is still available to T-Mobile, or has been preserved

9 pursuant to a request made under 18 U.S.C. § 2703(f), T-Mobile is required to disclose

10 the following information to the government for each account or identifier listed in

11 Attachment A:

12 1. Subscriber/Account Information. The following non-content information

13 about the customers or subscribers associated with the Accounts listed in Attachment A:

14 a. Names (including subscriber names, usernames, and screen names);

15 b. Addresses (including mailing addresses, residential addresses,

16 business addresses, and e-mail addresses);

17 c. Local and long-distance telephone connection records from May 1,

18 2020 to August 18, 2020;

19 d. Records of session times and durations, and the temporarily assigned

20 network addresses (such as Internet Protocol (“IP”) addresses) associated with those

21 sessions from May 1, 2020 to August 18, 2020;

22 e. Length of service (including start date) and types of service utilized;

23 f. Telephone or instrument numbers (including MAC addresses,

24 Electronic Serial Numbers (“ESN”), Mobile Electronic Identity Numbers (“MEIN”),

25 Mobile Equipment Identifier (“MEID”), Mobile Identification Number (“MIN”),

26 Subscriber Identity Modules (“SIM”), Mobile Subscriber Integrated Services Digital

27 Network Numbers (“MSISDN”), International Mobile Subscriber Identity Identifiers

28 (“IMSI”), or International Mobile Equipment Identities (“IMEI”);

ATTACHMENT B2 - 1 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 8 of 38

1 g. Other subscriber numbers or identities (including the registration

2 Internet Protocol (“IP”) address); and

3 h. Means and source of payment for such service (including any credit

4 card or bank account number) and billing records.

5 2. Historical Cell Cite Location Information.

6 a. All records and other information (not including the contents of

7 communications) relating to wire and electronic communications sent or received by the

8 Accounts from May 1, 2020 to August 18, 2020, including:

9 i. the date and time of the communication, the method of the


10 communication, and the source and destination of the communication (such as the
11 source and destination telephone numbers (call detail records), email addresses,
12 and IP addresses); and
13 ii. historical cell site information regarding the cell tower and
14 antenna face (also known as “sectors”) through which the communications were
15 sent and received. This information is to be provided irrespective of the
16 application, name, or report utilized by T-Mobile. Accordingly, this information
17 includes the following data sets to the extent that they are collected by T-Mobile:
18 RTT, PLU, PCMD, NELOS, EVDO, TruCall, ALULTE, and Timing Advance.
19 b. The physical address and coverage maps of cell towers used by the
20 Accounts.
21
The Provider is hereby ordered to disclose the above information to the
22 government within 14 days of issuance of this warrant.
23
II. Section II: Information to Be Seized by the Government
24
All information described above in Section I that constitutes evidence of violations
25
of 18 U.S.C. § 1956 (money laundering) ,21 U.S.C. § 841 (distribution of, and possession
26
with intent to distribute controlled substances, and 21 U.S.C. § 846 (conspiracy to
27
distribute drugs), those violations occurring between May 2020 and August 2020
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ATTACHMENT B2 - 2 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 9 of 38

1 including, for each account or identifier listed on Attachment A, information pertaining to

2 the following matters:

3 3. Evidence of the sale and possession of illegal drugs.

4 4. Evidence of money laundering.

5 5. Evidence of the relationship between co-conspirators.

6 6. Evidence of the location and identity of the individuals using the Accounts.

7 7. All non-content subscriber/account information provided pursuant to 18

8 U.S.C. § 2703(c).

9 8. Evidence of introduction of drugs into a confinement facility.

10 9. Evidence of a conspiracy to distribute drugs.

11
12 Law enforcement personnel (who may include, in addition to law enforcement

13 officers and agents, attorneys for the government, attorney support staff, agency

14 personnel assisting the government in this investigation, and outside technical experts

15 under government control) are authorized to review the records produced by T-Mobile in

16 order to locate the things particularly described in this Warrant.

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ATTACHMENT B2 - 3 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 10 of 38

1 AFFIDAVIT IN SUPPORT OF AN APPLICATION FOR


A SEARCH WARRANT
2
3 STATE OF WASHINGTON )
4 ) ss
COUNTY OF PIERCE )
5
6
7 I, Richard C. Schroff Jr., being first duly sworn, hereby depose and state as

8 follows:

9 INTRODUCTION

10 1. I make this affidavit in support of an application for a search warrant under

11 18 U.S.C. §§ 2703(a), 2703(b)(1)(A) and 2703(c)(1)(A)) for subscriber information and for

12 information about the location of the cellular telephones assigned call numbers:

13 a. 214-437-6862 (hereafter Target Telephone 1 or “TT1”). Melissa

14 MESA is the listed subscriber for TT1 and has service provided by Verizon Wireless, a

15 wireless telephone service provider headquartered at 180 Washington Valley Road,

16 Bedminster, NJ 07921. TT1 is described herein and in Attachment A1, and the location

17 information to be seized is described herein and in Attachment B1.

18 b. 360-809-8988 (hereafter Target Telephone 2 or “TT2”). TT2 is a

19 prepaid phone registered to “Syke Sixteen” but is known to be used by MESA. TT2 and

20 has service provided by Verizon. TT2 is described herein and in Attachment A1, and the

21 location information to be seized is described herein and in Attachment B1.

22 c. (253) 778-5404 (hereafter Target Telephone 3 or “TT3”). Service

23 to TT3 is provided by Verizon Wireless. TT3 was in use by A.M., whom is more fully

24 described below. TT3 is described herein and in Attachment A1, and the location

25 information to be seized is described herein and in Attachment B1.

26 d. (253) 392-4366 (hereafter Target Telephone 4 or “TT4”). Service

27 to TT4 is provided by Verizon Wireless. TT4 was in use by J.S., whom is more fully

28

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 1 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 11 of 38

1 described below. TT4 is described herein and in Attachment A1, and the location

2 information to be seized is described herein and in Attachment B1.

3 e. (206) 696-9070 (hereafter Target Telephone 5 or “TT5”). Service

4 to TT5 is provided by T-Mobile, a wireless telephone service provider headquartered at 4

5 Sylvan Way, Parsippany, NJ 07054. TT5 was in use by D.N., whom is more fully

6 described below. TT5 is described herein and in Attachment A2, and the location

7 information to be seized is described herein and in Attachment B2.

8 f. (206) 945-6572 (hereafter Target Telephone 6 or “TT6”). Service

9 to TT6 is provided by Verizon Wireless. TT6 was in use by S.M., whom is more fully

10 described below. TT6 is described herein and in Attachment A1, and the location

11 information to be seized is described herein and in Attachment B1.

12 g. 360-477-0834 (hereafter Target Telephone 7 or “TT7”). Service to

13 TT7 is provided by Verizon Wireless. TT7 was in use by A.C., whom is more fully

14 described below. TT7 is described herein and in Attachment A1, and the location

15 information to be seized is described herein and in Attachment B1.

16 2. Upon receipt of the information described in Section I of Attachments B,

17 government-authorized persons will review that information to locate the items described

18 in Section II of Attachments B. The wireless telephone service providers identified in

19 Paragraph 1(a) through (g) are referred to throughout this affidavit and attachments as the

20 “wireless provider,” “the wireless service providers,” or “the wireless service providers

21 identified in Attachments A.”

22 AGENT BACKGROUND

23 3. I am a Special Agent (SA) with the FBI and have been employed as a

24 criminal investigator with the FBI since July of 2014. I am a graduate of the FBI Academy

25 in Quantico, Virginia, and have attended various other trainings such as the U.S.

26 Department of Justice, Asset Forfeiture/Money Laundering Section’s Basic Financial

27 Investigation Seminar, the FBI’s economic crimes conference, and the FBI’s public

28 corruption seminar. I have also received training and have gained experience through my

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 2 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 12 of 38

1 investigations in obtaining and analyzing financial records, communication records, and

2 location records for mobile devices and computers. The FBI is responsible for enforcing

3 federal criminal statutes of the United States. While employed by the FBI, I have

4 investigated violent crime, internet child exploitation, violations involving controlled

5 substances, public corruption and civil rights violations, and other criminal matters which

6 can generally be referred to as white collar crime. At present, I am primarily assigned to

7 investigate public corruption. I have gained experience through training and everyday work

8 relating to conducting these types of investigations. I have also regularly applied for and

9 been granted search warrants for both physical locations and electronic records, searched or

10 had others conduct searches, and used evidence found during those search warrants to

11 further my criminal investigations. As a federal law enforcement officer engaged in

12 enforcing the criminal laws of the United States, I am authorized by the Attorney General

13 to apply for search warrants.

14 4. The facts in this affidavit come from my personal observations, my training

15 and experience, and information obtained from other agents and witnesses. This affidavit

16 is intended to show merely that there is sufficient probable cause for the requested warrant

17 and pen-trap, and therefore does not set forth all of my knowledge about this matter.

18 5. Based on the facts set forth in this affidavit, there is probable cause to

19 believe that violations of 18 U.S.C. § 1956, 21 U.S.C. § 841 and 846 have been committed

20 by Say KEODARA, Melissa MESA and others. There is also probable cause to believe

21 that the location information described in Attachments B will constitute evidence of these

22 criminal violations.

23 PROBABLE CAUSE

24 6. In May 2020, the FBI, in partnership with the Washington Department of

25 Correction (WADOC), Department of Homeland Security, Office of the Inspector General

26 (DHS-OIG), the United States Customs and Border Protection, Office of Professional

27 Responsibility (USCBP-OPR), and the Olympic Peninsula Narcotics Enforcement Task

28 Force (OPNET) initiated an investigation into a conspiracy designed to introduce

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 3 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 13 of 38

1 controlled substances and prescription drugs to inmates incarcerated at the Clallam Bay

2 Corrections Center (CBCC), a Washington State Correctional Facility. Individuals

3 involved in this conspiracy include incarcerated inmates at CBCC, staff members

4 employed by WADOC and assigned to work at CBCC, and other members of the

5 community. In order to carry out the scheme, inmates would arrange for community

6 members to obtain and pay for controlled substances, and then arrange for the substances to

7 be introduced into CBCC by staff members. When WADOC’s investigation revealed that

8 Melissa M. MESA, a United States Customs and Border Protection Officer, was a

9 community member involved in that conspiracy, they contacted the FBI requesting

10 partnership in the investigation.

11 7. WADOC Investigator Conrad Artis initiated the case and was the primary

12 investigator for WADOC. He has a limited law enforcement commission for the State of

13 Washington and has experience investigating a range of criminal activity within

14 WADOC’s system, including the introduction and sale of illegal substances, illicit financial

15 transactions in support of that introduction and sale, the exploitation of communications

16 between inmates and between inmates and community members, and the investigation of

17 staff members who have become “compromised” and participate in criminal conspiracies.

18 Mesa and Keodara.

19 8. WADOC Investigators became aware of this conspiracy in the spring of

20 2020 through reporting from confidential sources and a review of recorded jail calls and

21 other electronic communications made to and from CBCC inmates. They discovered that

22 Clallam Bay inmate Say KEODARA was in a romantic relationship with MESA.

23 According to WADOC records, KEODARA is incarcerated for one count of first-degree

24 murder, three counts of first-degree assault, two “other” assault charges, and one count of

25 second-degree burglary. His estimated release date is October 2, 2054. During their

26 relationship, KEODARA asked MESA to meet with individuals in the community in order

27 to obtain illegal drugs and illegally obtained prescription drugs for the purpose of passing

28 the drugs to others for introduction into CBCC. KEODARA also asked MESA to conduct

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 4 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 14 of 38

1 financial transactions on his behalf in furtherance of the drug conspiracy. WADOC

2 investigators learned of these transactions by reviewing a significant number of recorded

3 phone calls and online messages, videos, and pictures. This affidavit summarizes some, but

4 not all, of the information obtained from those communications to outline not only

5 MESA’s involvement as an actor in the conspiracy, but also her knowledge that the

6 contraband she obtained was done so in violation of the law.

7 9. During their review of phone calls, WADOC learned that the primary

8 phone number MESA used to communicate with KEODARA was 214-437-6862 (TT 1).

9 They later learned that MESA had obtained another phone number. Soon thereafter,

10 WADOC observed that MESA was using the number 360-809-8988 (TT 2) to

11 communicate with KEODARA. The FBI obtained records from Verizon Wireless on June

12 29, 2020 and learned that TT 1 was assigned to MESA and TT 2 was a prepaid account

13 assigned to the name “Syke Sixten.”

14 10. During the investigation, the FBI obtained copies of records and phone

15 calls from WADOC for communications between MESA and KEODARA. Among the

16 records received from WADOC was Investigator Artis’ report of investigation. In his

17 report, Investigator Artis provided summaries of those calls. He noted where, based on his

18 training and experience and from what he heard on the calls, he believed KEODARA,

19 MESA, and others discussed drugs, exchanges of drugs, and financial transactions related

20 to those exchanges. I have reviewed some of these calls during my investigation. In

21 reviewing the calls, it appears that KEODARA and MESA intentionally talk in vague

22 terms and use code words when they appear to be discussing drugs and financial

23 transactions. This manner of speech differs from when they talk about other things, such as

24 their relationship and other matters which do not seem to refer to criminal activity. In the

25 following paragraphs, I describe communications between various individuals. Except

26 where specifically indicated with quotation marks, the descriptions are summaries of the

27 conversations and are not intended to present a verbatim recitation of the words used by the

28 participants. I know through training and experience, as well as the training and experience

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 5 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 15 of 38

1 of other law enforcement officers familiar with this investigation, that individuals involved

2 in the distribution of controlled substances and other criminal activity often use vague

3 references and/or code words and phrases when discussing illegal activity. When such

4 words are used in the investigation, I have used this training and experience, as well as the

5 training and experience of other law enforcement officers familiar with this investigation,

6 to include what I believe to be an accurate translation of these code words and phrases.

7 Individuals Involved.

8 11. Below is a brief summary of the relationship between several of the parties

9 involved in the summarized phone calls and their relationships. They include calls made

10 between:

11 a. KEODARA and Mesa were in a romantic relationship as judged by

12 the nature and content of many of their calls. Between May 1, 2020 and August 18, 2020,

13 KEODARA and MESA had 505 recorded jail phone calls using TT1 and nine calls using

14 TT2, in addition to a significant number of other communications and financial

15 transactions using the J-Pay system 1. Their relationship may have begun when MESA’s

16 son was incarcerated at CBCC with KEODARA. In addition to the calls summarized in this

17 affidavit, there are other calls in the Government’s possession where MESA and

18 KEODARA discuss financial transactions and what investigators believe are drug

19 transactions. At times during various communications, KEODARA was identified by the

20 nickname “Peebee”, and MESA was referred to in the third person to other callers as

21 KEODARA’s “auntie,” “wife,” or “girlfriend”;

22 b. KEODARA had a personal relationship with a community member

23 referred to as A.M., who based on historical jail calls has a long history with KEODARA

24 and is affiliated with the “Rolling 60’s Crips” street gang. Between May 1, 2020 and

25 August 18, 2020, KEODARA and A.M. had 69 recorded jail phone calls. A.M. used TT3.

26
27 1
J-Pay is a private entity which offers services to many different corrections agencies in several U.S. states. Their
28 services include money transfer, email, videos, tablets, music, education, and parole and probation payments.

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 6 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 16 of 38

1 On their calls, they discuss financial transactions and what investigators believe to be drug

2 transactions;

3 c. KEODARA had a personal relationship with a community member

4 referred to as J.S. Between May 1, 2020 and August 18, 2020, KEODARA and J.S. had 54

5 recorded jail phone calls. Based on historical jail calls, J.S. appears to be A.M.’s sister. J.S.

6 used TT4 in her communications with KEODARA. On their calls, they discuss financial

7 transactions and what investigators believe to drug transactions.

8 d. KEODARA had a personal relationship with a community member

9 referred to as D.N., who was released from CBCC in or around 2019, and was known to

10 use the nickname, “Shanky.” Between May 1, 2020 and August 18, 2020, KEODARA and

11 D.N. had 11 recorded jail phone calls. D.N. used TT5. On their calls, they discuss financial

12 transactions and what investigators believe to be drug transactions.

13 e. CBCC offender J.M. had a personal relationship with a community

14 member referred to as S.M. J.M. had a relationship with KEODARA and CBCC offender

15 J.H. while incarcerated at CBCC. Between May 1, 2020 and August 18, 2020, J.M. and

16 S.M. had 27 recorded jail phone calls. S.M. used TT6. On their calls, they discuss financial

17 transactions and what investigators believe to drug transactions.

18 Summarized Telephone Calls and Transactions.


19 12. The below summary includes the observations of both Investigator Artis
20 and myself and are ordered sequentially by time. The calls summarized here take place
21 between May 1, 2020 and August 18, 2020:
22 a. On May 1 and 2, 2020, KEODARA and D.N. had a series of phone
23 calls where they discuss obtaining suboxone strips 2 and their cost. They also discuss
24 “clear” and the selling price. In my training and experience, I believe “clear” refers to
25 methamphetamine. On May 2, 2020, D.N. told KEODARA that he had 125 Suboxone
26
27 2
According to drugs.com, Suboxone is a schedule 3 prescription only drug that is used to help treat opioid addiction
and is considered to have moderate abuse potential. (https://www.drugs.com/pro/suboxone.html accessed
28 10/23/2020)

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 7 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 17 of 38

1 strips ready to provide to KEODARA’s “auntie” and they discussed how the meeting could

2 be arranged and conducted.

3 b. On May 2 and 3, 2020, MESA and KEODARA had a series of

4 phone calls where they discuss MESA meeting with other parties, including “Shay,” whom

5 DOC investigators identified as a community member referred to as S.M. KEODARA

6 refers to Shay as “his brother,” and discussed obtaining 125 suboxone strips and potentially

7 other drugs. They spoke about the substances in code, using the word “groceries” to

8 describe them. KEODARA tells MESA how to drop the drugs off and observe them being

9 picked up by a third party in a manner where she is to avoid meeting in person. MESA and

10 KEODARA have an argument over MESA not having followed KEODARA’s instructions

11 as it is clear from the conversation that she had met the third party face-to-face.

12 c. On May 2, 2020, KEODARA and A.M. have a series of phone calls

13 where they discuss attempts to obtain drugs and providing $350 to “Shanky” and $900 to

14 KEODARA’s “auntie.”

15 d. On May 9, 2020, KEODARA asked MESA to send $1,000 to R.D.

16 and provided her with an address. R.D. is linked to other DOC offenders involved in this

17 investigation. Those offenders have asked S.M. to send money to R.D. as well.

18 e. On May 19, 2020, KEODARA gave A.M. TT 1 and asked if he had

19 texted her.

20 f. On May 21, 2020, KEODARA appears to ask MESA to be the one

21 who handles his money and drug operations. During the conversation, KEODARA asks,

22 “Are you ok with holding everything from here on out?” MESA then asks, “What risk?” to

23 which KEODARA replied, “Me letting you hold everything.” MESA then stated, “You

24 don’t have to, that’s up to you.”

25 g. On May 27, 2020, offender J.M. and S.M. discuss meeting an

26 unidentified person in Bainbridge to pass off a package of chewing tobacco and suboxone

27 strips. During previous calls in the month of May 2020, J.M. and S.M. talked about an

28 unidentified person named Pedro and discussed keeping Pedro happy. They also discussed

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 8 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
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SEATTLE, WASHINGTON 98101
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Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 18 of 38

1 obtaining the suboxone strips and tobacco and various financial transactions. In one phone

2 call on May 3, 2020 at 11:00am, J.M. tells someone to go and get “Say.” Investigators

3 then observed security footage which shows KEODARA coming to the phone with J.M.,

4 and after the call J.M. went and spoke with an offender J.H., who is discussed in greater

5 detail below.

6 h. On June 6, 2020, KEODARA and MESA talk in code about

7 handling what is suspected to be methamphetamine. They refer to the drug as “bakery” and

8 KEODARA asks MESA if it was in one piece or more. The following are excerpts of their

9 conversation:

10 KEODARA: “Do you remember the last time you fucking went to the bakery?” to

11 which MESA replied, “Yeah.” He asked, “When you got done making the muffins, or

12 whatever, did they come out in crumbles or was it the whole muffin?” She replied, “It was

13 the whole muffin.” He asked, “It wasn’t broken apart or nothing it was just all one?” Her

14 response was indecipherable in the recording. He then asked, “For the most part it was just

15 one?” She replied, “Yeah.”

16 i. Multiple transactions occurred in June 2020 through an online

17 financial platform called CashApp. 3 On June 12, 2020, KEODARA gave A.M. TT 2 and

18 the Cash App name, “$psykeo610.” On June 14, 2020, a CBCC Offender “J.G.” provided

19 a community member referred to as “M” with the number for TT2 and told her to send

20 MESA $500 via Cash App. On June 14, 2020, KEODARA and A.M. discuss money

21 transactions and A.M. provides the Cash App username, “$Antoinemosley60.” They

22 discuss getting the $500 mentioned in the phone call between J.G. and M to KEODARA’s

23
24
3
Cash App is a mobile application owned by Square Inc. that allows users to make certain financial transactions
25 such as sending and receiving money or purchasing Bitcoin and stocks. To open an account, Cash App may require
a user to submit their name, email address, text-enabled mobile phone number, street address, zip code, date of birth,
26 social security number, and a government issued form of identification. Once an account is established, users choose
a unique username referred to as a “Cashtag”. In their normal course of business, Cash App maintains records about
27 both financial transactions and transactions associated with using their service, such as Internet Protocol Address
information.
28

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 9 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 19 of 38

1 auntie. On June 17, 2020, KEODARA and A.M. discuss sending KEODARA’s auntie

2 $1800. On June 19, 2020, KEODARA and A.M. had a phone conversation where they

3 provide the Cash App username “$Jay1mccann.” On June 21, 2020, KEODARA and A.M

4 had a phone conversation where A.M. provides his new Cash App username “$Antmos60”.

5 j. On June 25, 2020, KEODARA, using another offender’s phone

6 account, had a conversation with MESA where they appear to discuss money and drugs.

7 KEODARA asks MESA what the total was, to which she replies “one,” and then, after a

8 long pause, says “three.” KEODARA then asks her to give it all to “his bro” the “same way

9 it came” and asks if she remembers Shay.

10 k. Between June 28 and June 30, 2020, KEODARA and MESA have a

11 series of phone calls where they discuss what appears to be drug business. In these

12 discussions, they talk about contacting and meeting with a person named “Pedro” and

13 “Shay.” They also discuss money transactions and the use of the Cash App electronic

14 payment platform. Of note, during this phone call MESA made several statements to

15 KEODARA including:

16 On a call made on June 29, 2020 at 11:21am., MESA and KEODARA are fighting

17 about their relationship. Starting at two minutes and sixteen seconds into the phone call,

18 MESA speculates that KEODARA won’t admit he is leaving her because, she had his

19 money. She told KEODARA, "I risked my fucking ass for your ass."

20 On a subsequent call made on June 29, 2020 at 11:45 am, KEODARA and MESA

21 continue their fight. At four minutes and sixteen seconds into their conversation, MESA

22 says, "How much did I fucking carry around…of that bullshit…how much huh? Enough to

23 put me how long away?"

24 On a subsequent call made on June 29, 2020 at 12:51 pm KEODARA and MESA

25 continue their fight. At approximately one minute and seventeen seconds into the call,

26 MESA twice yells something inaudible followed by “You have your fucking money.” She

27 later says, “Call your people, they have your fucking shit,” and “Call your people, I sent it

28 the way it came.” He asks her if she gave them the phone number as well. Later, MESA

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 10 UNITED STATES ATTORNEY


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Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 20 of 38

1 says, "You know I jeopardized my career, my livelihood, my life for you, for this

2 bullshit..." KEODARA and MESA mention the possible implications on her job for being

3 married to a felon and KEODARA says that is the only thing she could get in trouble for.

4 l. On June 29, 2020, KEODARA and A.M have a phone conversation

5 where they discuss “Pedro”, “Shay”, and having “KEODARA’s girl” meet up with Pedro.

6 m. On June 30, 2020, at 1:45pm KEODARA, using another offenders

7 phone account, had a conversation with MESA. She said she is meeting another female

8 during the phone call. KEODARA tells MESA to check it this time because “it” wasn’t

9 what it was supposed to be last time and he said it was a “midget” short. MESA said that

10 she checked it. KEODARA said to make sure she is tight and make sure there is no air at

11 all and it is air tight. In my training and experience, I believe KEODARA is telling MESA

12 to make sure that a package of drugs has the proper weight or volume and is packaged

13 properly. MESA said there were a few “big ones.” KEODARA speaks cryptically to

14 MESA and asks her to change something around and describes changing “the other one” to

15 “the normal thing that it has before it and do yin, and sign, yang triple 7.” He then talks

16 about sending something indecipherable to that one to make sure its usable. In my training

17 and experience, I believe KEODARA is asking MESA to create a Cash App account

18 named “$yin&yang777” and to conduct a transaction with the account to test it.

19 KEODARA coaches MESA to text message someone and refer to the party she is texting

20 as “big brother” and herself as “little sister.”

21 n. On July 3, 2020, KEODARA told A.M. to text message “his girl”

22 and go to her girlfriend’s home to get “three zones” (methamphetamine) from her and to

23 tell her to make sure “it’s airtight.”

24 o. On July 4, 2020 KEODARA and MESA engage in a series of phone

25 calls where MESA describes meeting up with an unidentified female for the believed

26 purpose of obtaining methamphetamine. MESA explains that the female took $1,200 from

27 her but did not return with the drugs. This led to an altercation between KEODARA and

28

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Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 21 of 38

1 MESA over the stolen money. Later in the day, MESA tells KEODARA she obtained

2 approximately one ounce of what was believed to be methamphetamine while at a casino.

3 p. On July 7, 2020, MESA and KEODARA had two phone

4 conversations. In the first, they appear to talk about drugs in code and discuss the increase

5 in prices with cost going up, “$300, $450, and $500 within a month.” MESA also provides

6 KEODARA with her new Cash App username, “$1yingyang777.”

7 q. On July 8, 2020, MESA and KEODARA had at least three phone

8 conversations. During the calls, they discuss making a $400 payment to an unidentified

9 female, KEODARA provides MESA with a phone number associated with another CBCC

10 offender, and they discuss what appear to be drug transactions with an unidentified female

11 and contacting A.M. and “Sherrie” to conduct additional cash transactions.

12 r. On July 10, 2020, KEODARA had a phone conversation with J.S.

13 where he instructed her to get money from her brother, A.M., and to keep it.

14 s. On July 12, 2020, J.S. provided KEODARA with the Cash App

15 username “$Cr1p60” and they discuss KEODARA having $2,700 in J.S.’s bank account.

16 Later, on this same day, MESA and KEODARA discuss sending $2,500 to A.M. at his

17 Cash App username “$$Crip60”.

18 t. On July 26, 2020, KEODARA asked J.S. to attempt to find some

19 suboxone strips and, if she was able, to provide them to his “girlfriend.” They also

20 discussed other financial matters and transactions.

21 u. Between July 27 and August 15, 2020, KEODARA and J.S. have a

22 number of phone conversations during which they discuss various financial transactions,

23 obtaining suboxone strips, and the cost of a suboxone strip being $7. During those phone

24 calls, they talk about obtaining suboxone strips from “Dino,” who investigator Artis

25 understands to be D.N., and liquid marijuana from A.M. During a call on August 10, 2020,

26 J.S. said she met with “Cousin K” whom she thought she was supposed to get drugs from.

27 KEODARA explained that “Cousin K” was the “end game” and said, “That’s family, he is

28 just a “one time.” In his training and experience, Investigator Artis understands that

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 12 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 22 of 38

1 “Cousin K” refers to A.C., who is further discussed below, whose last name makes the

2 sound of the letter K. Further, the phrase “end game” refers to the final person in the chain

3 of people handling contraband intended for introduction to CBCC, and a “one time” is

4 prison slang for a corrections officer. The word “family” is in reference to A.C. being an

5 ethnic Pacific Islander as is KEODARA. KEODARA tells J.S. that he wants her to meet

6 “Cousin K” again next Monday, which would be Monday, August 17, 2020. They further

7 discuss in detail obtaining chewing tobacco, methamphetamine, liquid Marijuana, and her

8 paying “Cousin K” $3,000. KEODARA tells MESA that the drugs J.S. was to obtain

9 would be passed from her to “Twonson,” whom investigators believe to be A.M., then to

10 “Little Bro Psycho,” and then to “Cousin K” while “Cousin K” is in Tukwila. KEODARA

11 also passed TT1 to J.S. and asked her to contact MESA to learn about Suboxone Strips and

12 how to package them.

13 v. Of note on the August 10, 2020 phone call was when KEODARA

14 told J.S. what to ask MESA. He said,

15 “Ask her about the mask thing but be specific.” Then, “Yeah you have to be specific

16 and roll it out for her and shit. Like from top to bottom. Like the rubber bands for the ears,

17 for the fucking, to the little fucking, everything, like she’s stupid so it just, you know,

18 fucking, specifics, and the ugh, that’s if Fat Boy or my cousin Dino, then don’t have any

19 place to make mask then, then you just hit her up, its best to hit her up right now actually.

20 Yeah, let her know, with her you have to say, you’re fucking husband, you know what I

21 mean, he wanted me to ask that…”

22 In this exchange, it is believed that mask refers to suboxone. I believe that when

23 KEODARA tells J.S. to tell MESA that her husband asked, that he wants to make sure that

24 J.S. referred to KEODARA as MESA’s husband to keep her happy. Also on August 10,

25 2020, KEODARA and D.N. had a phone discussion about providing 50 suboxone strips to

26 J.S. at a cost of $7 per strip.

27
28

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Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 23 of 38

1 Phone Toll Investigation and WADOC Corrections Officer Arrest.

2 13. On August 17, 2020, I conducted a partial review of phone tolls for TT1

3 where I searched for contacts between TT1 and other numbers known to me in the

4 investigation. I found that TT1 made one call to TT3 on May 28, 2020 and received one

5 call from TT3 on May 29, 2020. No other contacts between any other Target Telephones

6 were found, though at the time of this affidavit, the investigative team only has call records

7 for TT1 and TT2 through approximately June 24, 2020.

8 14. On August 18, 2020, WADOC, OPNET and the FBI conducted an

9 operation to interdict A.C., a WADOC corrections officer assigned to CBCC, who was

10 believed to have obtained contraband for introduction into CBCC from J.S. A.C. was

11 known to use TT7. Investigator Artis and I interviewed A.C., and he provided consent for a

12 search of his vehicle, lunch box, two cell phones, and his person.

13 15. During the consent search of A.C.’s car, OPNET Detectives discovered a

14 note, which read as follows:

15 “So, I’m ready to rock ASAP. There’s no need to worry about anything on this

16 end. Things are quiet over here and we are being sage. I need to stack some chips for

17 an attorney, and I want to make this good for you as well. I have 3 racks for you ready

18 to go – and another 2 racks upon delivery. Sweeten the pot for everyone. If you have

19 any issues with size, you can deliver half to me now and half later – this will alleviate

20 any concern you may have about size. Remember, you can always see Moses over

21 there if that is easier. I don’t want to mess with the crystal anymore – its too loud –

22 just the blue packages and the chew – that’s it. All you need to do is text “J” at [TT4]

23 and ask how her and husband are doing. She will get back to you immediately and

24 you guys can figure it out. No worries – we keep our hands clean over here and

25 everyone gets taken care of. We make sure family is first and everyone is eating!

26 (smiley face drawn) And we stay away from the phones – that’s always the #1

27 concern. So, as far as your 2 racks after delivery, you’ll have to wait a week before

28 texting “J” back – give me time to transfer more $ her way. She’s a sweetheart – will

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 14 UNITED STATES ATTORNEY


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USAO # 2020R00599
SEATTLE, WASHINGTON 98101
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Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 24 of 38

1 meet you wherever you need to meet. Just understand this should be done ASAP – I

2 need some chew! (smiley face drawn) BTW – there a couple 40’s over here who keep

3 updated on things – everything here is good. See you soon. Respects”

4 16. I believe “J” refers to the user of the Cash App account, “$Jaym1mccann.”

5 Investigators believe “J” to be the same person as J.S. based on the use of TT4,

6 information obtained by reviewing jail calls, and information revealed by A.C. Investigator

7 Artis believes “Moses” to refer to another offender who worked a prison job in the same

8 unit where A.C. was assigned and who also has links to the CBCC offenders discussed in

9 this affidavit.

10 17. During the interview, A.C. admitted to having received the note from J.H.,

11 who was the cell mate of KEODARA. He described having communicated with a person

12 named “J” using his primary cell phone which was associated with TT7. A.C. said he

13 arranged for “J” to drop something off in the trunk of his car while he was on a trip to

14 Tukwila, WA with his family. When A.C. returned home, he moved the items left by “J”

15 into his other car, a Nissan Altima, so that the items would not be discovered by his family.

16 At the time of this interview, A.C. denied having met with anyone else to obtain

17 contraband. Following the interview, A.C. was arrested by Clallam County Deputies.

18 18. OPNET Detectives obtained a Search Warrant for A.C.’s Nissan Altima,

19 which was parked at his residence in Port Angeles, WA. During the execution of that

20 warrant, Detectives found and seized 61 grams of methamphetamine, 215 suboxone strips,

21 suspected liquid THC, and $2,300. The items were found inside a plastic bag inside A.C.’s

22 gym bag in the trunk.

23 19. During the operation on August 18, 2020, I took two phones from A.C. as

24 evidence, as A.C. admitted to having used them to communicate about contraband

25 introductions. One was the flip phone found in A.C.’s car and the other was his primary

26 cell phone. A.C. gave me his consent to search both phones. I later conducted a consent

27 search of the phone that was associated with TT7, A.C.’s primary cell phone. Though no

28 communications were found between TT7 and another other target telephone numbers,

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 15 UNITED STATES ATTORNEY


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Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 25 of 38

1 there was a contact card stored on the phone for “J” and listing TT4 as the contact number.

2 On September 3, 2020, I conducted a search of the flip phone taken from A.C. During the

3 search, I found only one contact for “Scott” using the phone number TT6. I know Scott to

4 be the same person as S.M. This is the number Investigator Artis found to belong to S.M.

5 and had been in contact with other WADOC offenders. The call log listed several calls

6 between the flip phone and “Scott” on January 28, March 5, and March 14, 2020. There

7 was also a text message thread between the flip phone and “Scott” on May 26 and 27,

8 2020. The text messages arrange a brief meeting between A.C. and “Scott” where they “do

9 a hand off” at the Bainbridge Island Ferry Terminal and “Scott” immediately turns around

10 and re-boards the ferry returning to Seattle. In the text message exchange, A.C. asks, “is

11 the money on the mango?” to which “Scott” replies, “yep”. Prior to the search of both

12 phones, I contacted A.C. and his attorney and ensured that the FBI still had A.C.’s

13 permission to search the phone without a warrant, and ensured that A.C. was able to

14 contact me by telephone while I was searching the phones if he decided to revoke his

15 consent.

16 20. I conducted a second interview of A.C. on October 2, 2020. The interview

17 was conducted over the phone and A.C.’s attorney was present on the phone call. No

18 specific benefits were extended to A.C. by me or the Clallam County Prosecuting

19 Attorney’s Office for participating in the interview. A.C. told me that J.H. was his main

20 contact and that KEODARA, “was a tool of [J.H.].” A.C. first contacted a “Debbie,” who

21 he thought was J.H.’s wife. “Debbie” did not want to meet with A.C. as she did not know

22 him, so A.C. then arranged a meeting with “Scott.” A.C. and “Scott” met at the Bainbridge

23 Island Ferry Terminal and “Scott” gave him a Mango chip bag that had a Ziplock bag

24 inside of it, which appeared to contain loose leaf tobacco and also $2,000 in cash which

25 was payment to him. A.C. did not look inside the bag of tobacco, claiming he did not want

26 to know what else may be inside. A.C. said there was a second meeting scheduled with

27 “Scott” but that it was cancelled. A.C. then met with a woman named “J” after being

28 instructed to do so via a note from J.H. He met “J” at a retail store, where “J” was confused

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 16 UNITED STATES ATTORNEY


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Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 26 of 38

1 about the nature of the relationship and attempted to give A.C. money in exchange for

2 suboxone, though no exchange actually occurred. A.C. later communicated with “J” and

3 arranged for her to drop off the items which he had discussed in his first interview and

4 which were found in his car during the execution of the State search warrant.

5 BACKGROUND REGARDING WIRELESS SERVICE PROVIDERS

6 21. Based on my training and experience, I know each cellular device has one

7 or more unique identifiers embedded inside it. Depending on the cellular network and the

8 device, the embedded unique identifiers for a cellular device could take several different

9 forms, including an Electronic Serial Number (“ESN”), a Mobile Electronic Identity

10 Number (“MEIN”), a Mobile Identification Number (“MIN”), a Subscriber Identity

11 Module (“SIM”), a Mobile Subscriber Integrated Services Digital Network Number

12 (“MSISDN”), an International Mobile Subscriber Identifier (“IMSI”), or an International

13 Mobile Equipment Identity (“IMEI”). The unique identifiers -- as transmitted from a

14 cellular device to a cellular antenna or tower -- can be recorded by pen-traps and indicate

15 the identity of the cellular device making the communication without revealing the

16 communication’s content.

17 22. Based on my training and experience, I know that when a cell phone

18 connects to a cellular antenna or tower, it reveals its embedded unique identifiers to the

19 cellular antenna or tower, and the cellular antenna or tower records those identifiers as a

20 matter of course. The unique identifiers -- as transmitted from a cell phone to a cellular

21 antenna or tower -- are like the telephone number of an incoming call. They can be

22 recorded by pen-trap devices and indicate the identity of the cell phone device making the

23 communication without revealing the communication’s content. In addition, a list of

24 incoming and outgoing telephone numbers is generated when a cell phone is used to make

25 or receive calls, or to send or receive text messages (which may include photographs,

26 videos, and other data). These telephone numbers can be recorded by pen-trap devices and

27 then used to identify the parties to a communication without revealing the

28 communication’s contents.

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Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 27 of 38

1 23. Based my training and experience, I know that a cell phone can also be

2 used to exchange text messages with email accounts. The email addresses associated with

3 those text messages can be recorded by pen-trap devices and then used to identify parties to

4 a communication without revealing the communication’s contents.

5 24. Based on my training and experience, I know that cellular phones can

6 connect to the internet via a cellular network. When connecting through a cellular

7 network, internet communications sent and received by the cellular phone each contain the

8 same unique identifier that identifies cellular voice communications, such as an ESN,

9 MEIN, MIN, SIM, IMSI, MSISDN, or IMEI. Internet communications from a cellular

10 phone also contain the IP address associated with that cellular phone at the time of the

11 communication. Each of these unique identifiers can be used to identify parties to a

12 communication without revealing the communication’s contents.

13 25. In my training and experience, I have learned that Verizon Wireless and T-

14 Mobile are companies that provides cellular telephone access to the general public. I also

15 know that certain providers of cellular telephone service have technical capabilities that

16 allow them to collect and generate information about the locations of the cellular

17 telephones to which they provide service, including cell-site data, also known as

18 “tower/face information” or cell tower/sector records. Cell-site data identifies the cell

19 towers (i.e., antenna towers covering specific geographic areas) that received a radio signal

20 from the cellular telephone and, in some cases, the “sector” (i.e., faces of the towers) to

21 which the telephone connected. These towers are often a half-mile or more apart, even in

22 urban areas, and can be 10 or more miles apart in rural areas. Furthermore, the tower

23 closest to a wireless device does not necessarily serve every call made to or from that

24 device.

25 26. When using a cellular connection to receive or transmit data, a cellular

26 phone typically utilizes a cell tower to make telephone calls, send or receive text messages,

27 send or receive emails, surf the internet, carry out application-initiated data transfers,

28 among other things.

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 18 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 28 of 38

1 27. Based on my training and experience, I know that wireless service

2 providers can collect cell-site data about the Target Cell Phone. Based on my training and

3 experience, I know that for each communication (including data connections) a cellular

4 device makes, its wireless service provider can typically determine: (1) the date and time of

5 the communication; (2) the telephone numbers involved, if any; (3) the cell tower to which

6 the customer connected at the beginning of the communication; (4) the cell tower to which

7 the customer connected at the end of the communication; and (5) the duration of the

8 communication. I also know that wireless providers typically collect and retain cell-site

9 data pertaining to cellular devices to which they provide service in their normal course of

10 business in order to use this information for various business-related purposes.

11 28. Different service providers use different systems, applications, and reports

12 to collect or analyze cell site data. These systems, applications, and reports are referred to

13 by a variety of names including, but not limited to real-time tool or “RTT” (Verizon),

14 Periodic Location Updates or “PLU” (Verizon), per call measurement data or “PCMD”

15 (Sprint), Network Event Location System or “NELOS” (AT&T), EVDO, ALULTE,

16 Timing Advance, and TruCall. RTT data, for example, estimates the approximate distance

17 of the cellular device from a cellular tower based upon the speed with which signals travel

18 between the device and the tower. This information can be used to estimate an

19 approximate location range that is more precise than typical cell-site data.

20 29. Based on my training and experience, I know that wireless providers

21 typically collect and retain information about their subscribers in their normal course of

22 business. This information can include basic personal information about the subscriber,

23 such as name and address, and the method(s) of payment (such as credit card account

24 number) provided by the subscriber to pay for wireless communication service. I also

25 know that wireless providers typically collect and retain information about their

26 subscribers’ use of the wireless service, such as records about calls or other

27 communications sent or received by a particular device and other transactional records, in

28 their normal course of business. In my training and experience, this information may

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 19 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 29 of 38

1 constitute evidence of the crimes under investigation because the information can be used

2 to identify the Target Cell Phone’s user or users and may assist in the identification of co-

3 conspirators and/or victims.

4 30. In the instant matter, I have not sent a preservation request the wireless

5 service providers as I know from my experience that the providers maintains the records I

6 am seeking for a period of year. The entire scope of my investigation occurred less than

7 one year ago.

8 INFORMATION TO BE SEARCHED AND THINGS TO BE SEIZED

9 31. Pursuant to Title 18, United States Code, Section 2703(g), this application

10 and affidavit for a search warrant seeks authorization to permit wireless service providers

11 Verizon and T Mobile, and their agents and employees, to assist agents in the execution of

12 this warrant. Once issued, the search warrant will be presented to the wireless service

13 providers with direction that it identify the accounts described in Attachments A to this

14 affidavit, as well as other subscriber and log records associated with the accounts, as set

15 forth in Section I of Attachments B to this affidavit.

16 32. The search warrant will direct the wireless service providers to copy and

17 produce subscriber information and location information.

18 33. I, and/or other law enforcement personnel will thereafter review the copy of

19 the electronically stored data and identify from among that content those items that come

20 within the items identified in Section II to Attachments B, for seizure.

21 CONCLUSION

22 34. Based on the forgoing, I request that the Court issue the proposed search

23 warrant. This Court has jurisdiction to issue the requested warrant because it is “a court of

24 competent jurisdiction” as defined by 18 U.S.C. § 2711. 18 U.S.C. §§ 2703(a), (b)(1)(A)

25 & (c)(1)(A). Specifically, the Court is “a district court of the United States . . . that - has

26 jurisdiction over the offense being investigated.” 18 U.S.C. § 2711(3)(A)(i).] and is in . . .

27 a district in which the provider . . . is located or in which the wire or electronic

28 communications, records, or other information are stored.” 18 U.S.C. § 2711(3)(A)(ii).

AFFIDAVIT OF SPECIAL AGENT SCHROFF - 20 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 30 of 38

1 Pursuant to 18 U.S.C. § 2703(g), the government will execute this warrant by serving the

2 warrant on the wireless service providers. Because the warrant will be served on Verizon

3 and T Mobile, who will then compile the requested records and data, reasonable cause

4 exists to permit the execution of the requested warrant at any time in the day or night.

5 Accordingly, by this Affidavit and Warrant, I seek authority for the government to search

6 all of the items specified in Section I, Attachments B (attached hereto and incorporated by

7 reference herein) to the Warrant, and specifically to seize all of the data, documents and

8 records that are identified in Section II to that same Attachment.

9 RICHARD Digitally signed by


RICHARD SCHROFF
10
SCHROFF Date: 2021.01.13
12:52:38 -08'00'
11
Richard Schroff, Affiant
12 Special Agent
13 Federal Bureau of Investigation

14
15 The above-named agent provided a sworn statement to the truth of the foregoing

16 affidavit by telephone on 15th day of January, 2021.

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J. RICHARD CREATURA
20 United States Magistrate Judge
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AFFIDAVIT OF SPECIAL AGENT SCHROFF - 21 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 31 of 38

1 ATTACHMENT A1

2 Property to Be Searched and Subscriber/Subject Information

3 Records and information associated with the cellular phones assigned call numbers:

4 TT1: 214-437-6862

5 TT2: 360-809-8988

6 TT3: 253-778-5404

7 TT4: 253-392-4366

8 TT6: 206-945-6572

9 TT7: 360-477-0834

10 that are in the custody or control of Verizon Wireless, a service provider headquartered at

11 180 Washington Valley Road Bedminster, NJ 07921.

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ATTACHMENT A1 - 1 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 32 of 38

1 ATTACHMENT A2

2 Property to Be Searched and Subscriber/Subject Information

3 Records and information associated with the cellular phone assigned call number:

4 TT5: (206) 696-9070

5 that is in the custody or control of T-Mobile, a service provider headquartered at

6 4 Sylvan Way, Parsippany, NJ 07054.

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ATTACHMENT A2 - 1 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 33 of 38

1 ATTACHMENT B1

2 Particular Things to be Seized

3
4 I. Section I: Information to be Disclosed by Verizon Wireless

5 To the extent that the information described in Attachment A1 is within the

6 possession, custody, or control of Verizon, regardless of whether such information is

7 located within or outside of the United States, including any records, files, logs, or

8 information that has been deleted but is still available to Verizon, or has been preserved

9 pursuant to a request made under 18 U.S.C. § 2703(f), Verizon is required to disclose the

10 following information to the government for each account or identifier listed in

11 Attachment A1:

12 1. Subscriber/Account Information. The following non-content information

13 about the customers or subscribers associated with the Accounts listed in Attachment A1:

14 a. Names (including subscriber names, usernames, and screen names);

15 b. Addresses (including mailing addresses, residential addresses,

16 business addresses, and e-mail addresses);

17 c. Local and long-distance telephone connection records from May 1,

18 2020 to August 18, 2020;

19 d. Records of session times and durations, and the temporarily assigned

20 network addresses (such as Internet Protocol (“IP”) addresses) associated with those

21 sessions from May 1, 2020 to August 18, 2020;

22 e. Length of service (including start date) and types of service utilized;

23 f. Telephone or instrument numbers (including MAC addresses,

24 Electronic Serial Numbers (“ESN”), Mobile Electronic Identity Numbers (“MEIN”),

25 Mobile Equipment Identifier (“MEID”), Mobile Identification Number (“MIN”),

26 Subscriber Identity Modules (“SIM”), Mobile Subscriber Integrated Services Digital

27 Network Numbers (“MSISDN”), International Mobile Subscriber Identity Identifiers

28 (“IMSI”), or International Mobile Equipment Identities (“IMEI”);

ATTACHMENT B1 - 1 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 34 of 38

1 g. Other subscriber numbers or identities (including the registration

2 Internet Protocol (“IP”) address); and

3 h. Means and source of payment for such service (including any credit

4 card or bank account number) and billing records.

5 2. Historical Cell Cite Location Information.

6 a. All records and other information (not including the contents of

7 communications) relating to wire and electronic communications sent or received by the

8 Accounts from May 1, 2020 to August 18, 2020, including:

9 i. the date and time of the communication, the method of the


10 communication, and the source and destination of the communication (such as the
11 source and destination telephone numbers (call detail records), email addresses,
12 and IP addresses); and
13 ii. historical cell site information regarding the cell tower and
14 antenna face (also known as “sectors”) through which the communications were
15 sent and received. This information is to be provided irrespective of the
16 application, name, or report utilized by the Verizon Wireless. Accordingly, this
17 information includes the following data sets to the extent that they are collected by
18 the Verizon Wireless: RTT, PLU, PCMD, NELOS, EVDO, TruCall, ALULTE,
19 and Timing Advance.
20 b. The physical address and coverage maps of cell towers used by the
21 Accounts.
22
The Provider is hereby ordered to disclose the above information to the
23 government within 14 days of issuance of this warrant.
24
II. Section II: Information to Be Seized by the Government
25
All information described above in Section I that constitutes evidence of violations
26
of 18 U.S.C. § 1956 (money laundering) ,21 U.S.C. § 841 (distribution of, and possession
27
with intent to distribute controlled substances, and 21 U.S.C. § 846 (conspiracy to
28

ATTACHMENT B1 - 2 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 35 of 38

1 distribute drugs), those violations occurring between May 2020 and August 2020

2 including, for each account or identifier listed on Attachment A1, information pertaining

3 to the following matters:

4 1. Evidence of the sale and possession of illegal drugs.

5 2. Evidence of money laundering.

6 3. Evidence of the relationship between co-conspirators.

7 4. Evidence of the location and identity of the individuals using the Accounts.

8 5. All non-content subscriber/account information provided pursuant to 18

9 U.S.C. § 2703(c).

10 6. Evidence of introduction of drugs into a confinement facility.

11 7. Evidence of a conspiracy to distribute drugs.

12
13 Law enforcement personnel (who may include, in addition to law enforcement

14 officers and agents, attorneys for the government, attorney support staff, agency

15 personnel assisting the government in this investigation, and outside technical experts

16 under government control) are authorized to review the records produced by the Verizon

17 Wireless in order to locate the things particularly described in this Warrant.

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ATTACHMENT B1 - 3 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 36 of 38

1 ATTACHMENT B2

2 Particular Things to be Seized

3
4 I. Section I: Information to be Disclosed by T-Mobile

5 To the extent that the information described in Attachment A2 is within the

6 possession, custody, or control of T-Mobile, regardless of whether such information is

7 located within or outside of the United States, including any records, files, logs, or

8 information that has been deleted but is still available to T-Mobile, or has been preserved

9 pursuant to a request made under 18 U.S.C. § 2703(f), T-Mobile is required to disclose

10 the following information to the government for each account or identifier listed in

11 Attachment A2:

12 1. Subscriber/Account Information. The following non-content information

13 about the customers or subscribers associated with the Accounts listed in Attachment A2:

14 a. Names (including subscriber names, usernames, and screen names);

15 b. Addresses (including mailing addresses, residential addresses,

16 business addresses, and e-mail addresses);

17 c. Local and long-distance telephone connection records from May 1,

18 2020 to August 18, 2020;

19 d. Records of session times and durations, and the temporarily assigned

20 network addresses (such as Internet Protocol (“IP”) addresses) associated with those

21 sessions from May 1, 2020 to August 18, 2020;

22 e. Length of service (including start date) and types of service utilized;

23 f. Telephone or instrument numbers (including MAC addresses,

24 Electronic Serial Numbers (“ESN”), Mobile Electronic Identity Numbers (“MEIN”),

25 Mobile Equipment Identifier (“MEID”), Mobile Identification Number (“MIN”),

26 Subscriber Identity Modules (“SIM”), Mobile Subscriber Integrated Services Digital

27 Network Numbers (“MSISDN”), International Mobile Subscriber Identity Identifiers

28 (“IMSI”), or International Mobile Equipment Identities (“IMEI”);

ATTACHMENT B2 - 1 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 37 of 38

1 g. Other subscriber numbers or identities (including the registration

2 Internet Protocol (“IP”) address); and

3 h. Means and source of payment for such service (including any credit

4 card or bank account number) and billing records.

5 2. Historical Cell Cite Location Information.

6 a. All records and other information (not including the contents of

7 communications) relating to wire and electronic communications sent or received by the

8 Accounts from May 1, 2020 to August 18, 2020, including:

9 i. the date and time of the communication, the method of the


10 communication, and the source and destination of the communication (such as the
11 source and destination telephone numbers (call detail records), email addresses,
12 and IP addresses); and
13 ii. historical cell site information regarding the cell tower and
14 antenna face (also known as “sectors”) through which the communications were
15 sent and received. This information is to be provided irrespective of the
16 application, name, or report utilized by T-Mobile. Accordingly, this information
17 includes the following data sets to the extent that they are collected by T-Mobile:
18 RTT, PLU, PCMD, NELOS, EVDO, TruCall, ALULTE, and Timing Advance.
19 b. The physical address and coverage maps of cell towers used by the
20 Accounts.
21
The Provider is hereby ordered to disclose the above information to the
22 government within 14 days of issuance of this warrant.
23
II. Section II: Information to Be Seized by the Government
24
All information described above in Section I that constitutes evidence of violations
25
of 18 U.S.C. § 1956 (money laundering) ,21 U.S.C. § 841 (distribution of, and possession
26
with intent to distribute controlled substances, and 21 U.S.C. § 846 (conspiracy to
27
distribute drugs), those violations occurring between May 2020 and August 2020
28

ATTACHMENT B2 - 2 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970
Case 3:21-mj-05013-JRC Document 1 Filed 01/15/21 Page 38 of 38

1 including, for each account or identifier listed on Attachment A2, information pertaining

2 to the following matters:

3 3. Evidence of the sale and possession of illegal drugs.

4 4. Evidence of money laundering.

5 5. Evidence of the relationship between co-conspirators.

6 6. Evidence of the location and identity of the individuals using the Accounts.

7 7. All non-content subscriber/account information provided pursuant to 18

8 U.S.C. § 2703(c).

9 8. Evidence of introduction of drugs into a confinement facility.

10 9. Evidence of a conspiracy to distribute drugs.

11
12 Law enforcement personnel (who may include, in addition to law enforcement

13 officers and agents, attorneys for the government, attorney support staff, agency

14 personnel assisting the government in this investigation, and outside technical experts

15 under government control) are authorized to review the records produced by T-Mobile in

16 order to locate the things particularly described in this Warrant.

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ATTACHMENT B2 - 3 UNITED STATES ATTORNEY


700 STEWART STREET, SUITE 5220
USAO # 2020R00599
SEATTLE, WASHINGTON 98101
(206) 553-7970

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