Documente Academic
Documente Profesional
Documente Cultură
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 )
)
located in the Western District of Washington , there is now concealed (identify the
person or describe the property to be seized):
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
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.
Applicant’s signature
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
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
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1 ATTACHMENT B1
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4 I. Section I: Information to be Disclosed by Verizon Wireless
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
11 Attachment A:
13 about the customers or subscribers associated with the Accounts listed in Attachment A:
20 network addresses (such as Internet Protocol (“IP”) addresses) associated with those
3 h. Means and source of payment for such service (including any credit
1 distribute drugs), those violations occurring between May 2020 and August 2020
7 4. Evidence of the location and identity of the individuals using the Accounts.
9 U.S.C. § 2703(c).
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
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1 ATTACHMENT A2
3 Records and information associated with the cellular phone assigned call number:
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1 ATTACHMENT B2
3
4 I. Section I: Information to be Disclosed by T-Mobile
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
10 the following information to the government for each account or identifier listed in
11 Attachment A:
13 about the customers or subscribers associated with the Accounts listed in Attachment A:
20 network addresses (such as Internet Protocol (“IP”) addresses) associated with those
3 h. Means and source of payment for such service (including any credit
6 6. Evidence of the location and identity of the individuals using the Accounts.
8 U.S.C. § 2703(c).
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
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8 follows:
9 INTRODUCTION
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:
14 MESA is the listed subscriber for TT1 and has service provided by Verizon Wireless, a
16 Bedminster, NJ 07921. TT1 is described herein and in Attachment A1, and the location
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
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
27 to TT4 is provided by Verizon Wireless. TT4 was in use by J.S., whom is more fully
28
1 described below. TT4 is described herein and in Attachment A1, and the location
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
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
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
17 government-authorized persons will review that information to locate the items described
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
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.
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
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
5 substances, public corruption and civil rights violations, and other criminal matters which
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
12 enforcing the criminal laws of the United States, I am authorized by the Attorney General
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
26 (DHS-OIG), the United States Customs and Border Protection, Office of Professional
1 controlled substances and prescription drugs to inmates incarcerated at the Clallam Bay
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
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
14 WADOC’s system, including the introduction and sale of illegal substances, illicit financial
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.
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.
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
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
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
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
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
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
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:
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
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
20 nickname “Peebee”, and MESA was referred to in the third person to other callers as
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.
1 On their calls, they discuss financial transactions and what investigators believe to be drug
2 transactions;
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
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
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
1 strips ready to provide to KEODARA’s “auntie” and they discussed how the meeting could
4 phone calls where they discuss MESA meeting with other parties, including “Shay,” whom
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.
13 where they discuss attempts to obtain drugs and providing $350 to “Shanky” and $900 to
14 KEODARA’s “auntie.”
16 and provided her with an address. R.D. is linked to other DOC offenders involved in this
17 investigation. Those offenders have asked S.M. to send money to R.D. as well.
19 texted her.
21 who handles his money and drug operations. During the conversation, KEODARA asks,
22 “Are you ok with holding everything from here on out?” MESA then asks, “What risk?” to
23 which KEODARA replied, “Me letting you hold everything.” MESA then stated, “You
26 unidentified person in Bainbridge to pass off a package of chewing tobacco and suboxone
27 strips. During previous calls in the month of May 2020, J.M. and S.M. talked about an
28 unidentified person named Pedro and discussed keeping Pedro happy. They also discussed
1 obtaining the suboxone strips and tobacco and various financial transactions. In one phone
2 call on May 3, 2020 at 11:00am, J.M. tells someone to go and get “Say.” Investigators
3 then observed security footage which shows KEODARA coming to the phone with J.M.,
4 and after the call J.M. went and spoke with an offender J.H., who is discussed in greater
5 detail below.
7 handling what is suspected to be methamphetamine. They refer to the drug as “bakery” and
8 KEODARA asks MESA if it was in one piece or more. The following are excerpts of their
9 conversation:
10 KEODARA: “Do you remember the last time you fucking went to the bakery?” to
11 which MESA replied, “Yeah.” He asked, “When you got done making the muffins, or
12 whatever, did they come out in crumbles or was it the whole muffin?” She replied, “It was
13 the whole muffin.” He asked, “It wasn’t broken apart or nothing it was just all one?” Her
14 response was indecipherable in the recording. He then asked, “For the most part it was just
17 financial platform called CashApp. 3 On June 12, 2020, KEODARA gave A.M. TT 2 and
18 the Cash App name, “$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
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”.
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
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
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
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.
5 where they discuss “Pedro”, “Shay”, and having “KEODARA’s girl” meet up with Pedro.
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
22 and go to her girlfriend’s home to get “three zones” (methamphetamine) from her and to
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
1 MESA over the stolen money. Later in the day, MESA tells KEODARA she obtained
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
8 conversations. During the calls, they discuss making a $400 payment to an unidentified
9 female, KEODARA provides MESA with a phone number associated with another CBCC
10 offender, and they discuss what appear to be drug transactions with an unidentified female
13 where he instructed her to get money from her brother, A.M., and to keep it.
14 s. On July 12, 2020, J.S. provided KEODARA with the Cash App
15 username “$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
19 suboxone strips and, if she was able, to provide them to his “girlfriend.” They also
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
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
13 v. Of note on the August 10, 2020 phone call was when KEODARA
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
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
27
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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
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
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
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
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
23 19. During the operation on August 18, 2020, I took two phones from A.C. as
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,
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.
17 was conducted over the phone and A.C.’s attorney was present on the phone call. No
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
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.
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
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
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
28 communication’s contents.
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
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
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.
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,
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
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”
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.
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
28 their normal course of business. In my training and experience, this information may
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-
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
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
16 32. The search warrant will direct the wireless service providers to copy and
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
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
25 & (c)(1)(A). Specifically, the Court is “a district court of the United States . . . that - has
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
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15 The above-named agent provided a sworn statement to the truth of the foregoing
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J. RICHARD CREATURA
20 United States Magistrate Judge
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1 ATTACHMENT A1
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
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1 ATTACHMENT A2
3 Records and information associated with the cellular phone assigned call number:
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1 ATTACHMENT B1
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4 I. Section I: Information to be Disclosed by Verizon Wireless
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
11 Attachment A1:
13 about the customers or subscribers associated with the Accounts listed in Attachment A1:
20 network addresses (such as Internet Protocol (“IP”) addresses) associated with those
3 h. Means and source of payment for such service (including any credit
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
7 4. Evidence of the location and identity of the individuals using the Accounts.
9 U.S.C. § 2703(c).
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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
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1 ATTACHMENT B2
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4 I. Section I: Information to be Disclosed by T-Mobile
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
10 the following information to the government for each account or identifier listed in
11 Attachment A2:
13 about the customers or subscribers associated with the Accounts listed in Attachment A2:
20 network addresses (such as Internet Protocol (“IP”) addresses) associated with those
3 h. Means and source of payment for such service (including any credit
1 including, for each account or identifier listed on Attachment A2, information pertaining
6 6. Evidence of the location and identity of the individuals using the Accounts.
8 U.S.C. § 2703(c).
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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
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