UNITED STATES DISTRICT COURT FOR THE

DISTRICT OF MARYLAND

IN THE MATTER OF THE SEARCH OF )

CERTAIN SPECIFIED PREMISES ) Misc. No. 09-_____
)

SEALED AFFIDAVIT IN SUPPORT OF SEARCH WARRANTS

WILLIAM NICKOLES, a Detective with the Baltimore Police Department and a

Task Force Officer with the Drug Enforcement Administration (“DEA”), being duly sworn, deposes

and states:

1. I am a Detective with the Baltimore Police Department and have been so

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

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

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

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

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

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

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

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

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

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

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

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

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

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

narcotics traffickers store and conceal the proceeds of their illegal activities.
 2. This affidavit is being submitted in support of an application for search

warrants for the premises set forth below:

THE PREMISES KNOWN AND DESCRIBED AS 5637 UTRECHT ROAD,

BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT
PREMISES #1"). SUBJECT PREMISES #1 is a residence of Deitra Davenport.

THE PREMISES KNOWN AND DESCRIBED AS 1113 EAST BELVEDERE

AVENUE, APARTMENT C, BALTIMORE, MARYLAND AND ITEMS
CONTAINED THEREIN ("SUBJECT PREMISES #2"). SUBJECT PREMISES #2
is a residence of Rainbow Williams.

THE PREMISES KNOWN AND DESCRIBED AS 600 S. HIGHLAND AVENUE,

APARTMENT A, BALTIMORE, MARYLAND AND ITEMS CONTAINED
THEREIN ("SUBJECT PREMISES #3"). SUBJECT PREMISES #3 is a residence
of Tomeka Harris.

THE PREMISES KNOWN AND DESCRIBED AS 420 WOODLAKE COURT #

C, GLEN BURNIE, MARYLAND AND ITEMS CONTAINED THEREIN
("SUBJECT PREMISES #4"). SUBJECT PREMISES #4 is a residence of Terry
Robe.

THE PREMISES KNOWN AND DESCRIBED AS 15 HIAWATHA COURT,

OWINGS MILLS, MARYLAND AND ITEMS CONTAINED THEREIN
("SUBJECT PREMISES #5"). SUBJECT PREMISES #5 is a residence of
Musheerah Habeebullah.

THE PREMISES KNOWN AND DESCRIBED AS 4001 DUVALL AVENUE,

FLOOR 2, BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN
("SUBJECT PREMISES #6"). SUBJECT PREMISES #6 is a residence used by
Kevin Glasscho.

THE PREMISES KNOWN AND DESCRIBED AS 1909 FOREST PARK

AVENUE, APT. S3, GYNN OAK, MARYLAND AND ITEMS
CONTAINED THEREIN ("SUBJECT PREMISES #7"). SUBJECT
PREMISES #7 is a residence of Kevin Glasscho and Cassandra Adams.

THE PREMISES KNOWN AND DESCRIBED AS 1102 N. MOUNT STREET,

BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT
PREMISES #8"). SUBJECT PREMISES #8 is a residence of Calvin Robinson.

THE PREMISES KNOWN AND DESCRIBED AS 3908 NORFOLK AVENUE,

BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT

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 PREMISES #9"). SUBJECT PREMISES #9 is a residence of Darnell Holmes, a/k/a
“Moe.”

THE PREMISES KNOWN AND DESCRIBED AS 2735 ST. PAUL STREET,

APARTMENT 1, BALTIMORE, MARYLAND AND ITEMS CONTAINED
THEREIN ("SUBJECT PREMISES #10"). SUBJECT PREMISES #10 is a
residence of Lakia Hatchett.

THE PREMISES KNOWN AND DESCRIBED AS 448 TUBMAN COURT,

BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT
PREMISES #11"). SUBJECT PREMISES #11 is a residence of Darryl Taylor.

THE PREMISES KNOWN AND DESCRIBED AS 5 WOODBRIAR COURT,

APARTMENT C, BALTIMORE, MARYLAND AND ITEMS CONTAINED
THEREIN ("SUBJECT PREMISES #12"). SUBJECT PREMISES #12 is a
residence of Tyrone Dow.

3. Based on the facts set forth in this affidavit, I respectfully submit that there

is probable cause to believe that BGF is engaged in an ongoing and continued pattern of violations

of federal law and that there is presently concealed in the premises set forth above (collectively “the

SUBJECT PREMISES”) the items set forth in the respective attachments hereto, all of which

constitute evidence, fruits, and instrumentalities of, inter alia, violations of 18 U.S.C. § 1962, which

prohibits participation in a racketeering conspiracy; 21 U.S.C. §§ 841 and 846, which prohibits the

distribution and possession with intent to distribute controlled substances, and conspiracy to commit

those offenses; 21 U.S.C. § 843, which prohibits the use of a communication facility in furtherance

of drug-trafficking; and 18 U.S.C. § 1959, which prohibits violent crimes in aid of racketeering.

4. Because this Affidavit is being submitted for the limited purpose of

establishing probable cause for warrants to search the premises set forth above, I have not included

every detail of every aspect of the investigation. Rather, I have set forth only those facts that I

believe are necessary to establish probable cause. I have not, however, excluded any information

known to me that would defeat a determination of probable cause. The information contained in this

3
Affidavit is based upon my personal knowledge, my review of documents and other evidence, and

my conversations with other law enforcement officers and other individuals. All conversations and

statements described in this Affidavit are related in substance and in part unless otherwise indicated.

I. Background

5. Since September 2008, DEA’s Special Investigations Group (DEA SIG) has

been conducting an investigation of the “Black Guerilla Family” (BGF), a violent gang that operates

in prison facilities and major cities throughout the United States, including in Baltimore, Maryland.

The investigation has involved, among other things:

a. physical surveillance in multiple locations, including the locations of

the SUBJECT PREMISES;

b. debriefings of multiple confidential informants (“CSs”);1

c. seizures of narcotics and narcotics proceeds and other contraband;

d. review of monitored telephone calls over prison telephones; and

e. electronic surveillance of approximately eight cellphones used by BGF

members and leaders and their associates.

6. As more fully described below, the evidence obtained through these and other

means has established that BGF is a violent gang that is engaged in drug-trafficking, extortion, and

acts of violence in Baltimore City and elsewhere.

1
The reliability of each of the CSs is discussed below.

4
II. Electronic Surveillance of BGF

7. On February 20, 2009, the Honorable J. Frederick Motz, United States

District Judge, signed an Order pursuant to Title 18, United States Code, Section 2518, authorizing

the Government to intercept wire communications occurring over (a) the cellular telephone assigned

call number (410) 206-6980 and bearing international mobile subscriber identity (“IMSI”)

#310410216356569 ("TARGET CELLPHONE #1"), subscribed to Deitra Davenport , 5637 Utrecht

Road, Baltimore, Maryland, and used by Eric Brown, a/k/a “Dee Brown,” a/k/a “E,” a/k/a “EB,”

with service provided by AT&T, and (b) the cellular telephone assigned call number (410) 361-0046

and bearing IMSI #316010011580887 ("TARGET CELLPHONE #2"), subscribed to Charlene

Pearson at 3 Norham Ct Apt I, Baltimore, Maryland, and used by Gregory Fitzgerald, a/k/a “Joe,”

with service provided by Sprint/Nextel, including through the use of Sprint/Nextel’s Direct

Connect/Dispatch Services. On February 23, 2009, it was learned that on February 13, 2009, the

call number assigned to TARGET CELLPHONE #1 had been changed to (410) 245-2435 and that

the call number assigned to TARGET CELLPHONE #2 had been changed to (410) 361-0110.

Accordingly, on February 23, 2009 and February 24, 2009, Judge Motz signed Amended Orders

authorizing the interception of wire communications occurring over TARGET CELLPHONE #1 and

TARGET CELLPHONE #2 and listing the new call numbers assigned to those cellphones.

Interception over TARGET CELLPHONE #1 began on February 23, 2009, and interception over

TARGET CELLPHONE #2 began on February 24, 2009. Interception over TARGET

CELLPHONE #1 remains active, but interception over TARGET CELLPHONE #2 was terminated

on March 3, 2009. Wire communications involving some of the TARGET SUBJECTS have been

intercepted pursuant to these Orders.

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 8. On March 10, 2009, the Honorable J. Frederick Motz, United States District

Judge, signed an Order pursuant to Title 18, United States Code, Section 2518, authorizing the

Government to intercept wire communications occurring over the cellular telephone assigned call

number (410) 336-0375 and bearing international mobile subscriber identity (“IMSI”)

#310410186013066 ("TARGET CELLPHONE #3"), subscribed to Raymond Williams, 123 Main

Street, Baltimore, Maryland 21222 and used by Rainbow Williams, with service provided by AT&T.

Interception pursuant to that Order commenced on March 10, 2009 and remains active. Wire

communication involving some of the TARGET SUBJECTS have been intercepted, pursuant to that

Order.

9. On March 13, 2009, the Honorable J. Frederick Motz, United States District

Judge, signed an Order pursuant to Title 18, United States Code, Section 2518, authorizing the

interception and recording of wire communications occurring over the cellular telephone assigned

call number (443) 255-4288 and bearing international mobile subscriber identity (“IMSI”)

#310410130470002 ("TARGET CELLPHONE #4"), subscribed to Frank Oliver, 264 N. Hilton

Street, Baltimore, Maryland and utilized by Kevin Glasscho, a/k/a “KG,” with service provided by

AT&T, the cellular telephone assigned call number (443) 452-0505 and Push to Talk number

165*493*2643 and bearing IMSI #316010160765307 ("TARGET CELLPHONE #5"), subscribed

to Keon Ball, 4422 Park Heights Ave, Baltimore, Maryland 21215 and utilized by Kevin Glasscho,

a/k/a “KG,” with service provided by Sprint/Nextel, including through the use of Sprint/Nextel’s

Direct Connect/Dispatch Services, and the cellular telephone assigned call number (443) 653-9728

and bearing IMSI #310260872288340 ("TARGET CELLPHONE #6"), subscribed to Nelson Abugo

Best Ambulance, 9411 Philadelphia Rd, Baltimore, Maryland 21237 and utilized by Kevin

6
Glasscho, a/k/a “KG,” with service provided by T-Mobile. Interception pursuant to that Order

commenced on March 13, 2009, on TARGET CELLPHONES #’s 4 and 5. Wire communication

involving some of the TARGET SUBJECTS have been intercepted, pursuant to that Order. On

March 13, 2009, law enforcement was advised by the provider that service for TARGET

CELLPHONE #6 was terminated for alleged fraud on March 11, 2009. As a result, the Order for

TARGET CELLPHONE #6 was not executed. On April 2, 2009, interception over TARGET

CELLPHONE #5 was terminated, but the interception of TARGET CELLPHONE #4 remains

active.

10. On March 27, 2009, the Honorable Wanda K. Heard, Judge of Circuit Court

for Baltimore City, signed an Order pursuant to Maryland Courts and Judicial Proceedings Article,

Section 10-408, authorizing the interception and recording of wire communications occurring over

the cellular telephone assigned call number (410) 294-4839 and bearing international mobile

subscriber identity (“IMSI”) #310410130470002 ("STATE LINE A"), subscribed to Antonio

Guevara, 987 Potee, Baltimore, Maryland 21225 and utilized by Tyrone Dow, a/k/a “Flavor,” with

service provided by AT&T. Interception pursuant to that Order commenced on March 27, 2009 and

remains active. Wire communication involving some of the TARGET SUBJECTS have been

intercepted, pursuant to that Order.

11. On March 31, 2009, the Honorable Wanda K. Heard, Judge of Circuit Court

for Baltimore City, signed an Order pursuant to Maryland Courts and Judicial Proceedings Article,

Section 10-408, authorizing the interception and recording of wire communications occurring over

the cellular telephone assigned call number (443) 683-4573 and bearing international mobile

subscriber identity (“IMSI”) #310410130470002 ("STATE LINE B"), Antonio Guevara, 987 Potee,

7
Baltimore, Maryland 21225 and utilized by Tyrone Dow, a/k/a “Flavor,” subscribed to Darryl

Chetam, 4410 Park Heights Avenue, Baltimore, Maryland with service provided by T-Mobile.

Interception pursuant to that Order commenced on March 31, 2009 and remains active. Wire

communication involving some of the TARGET SUBJECTS have been intercepted, pursuant to that

Order.

12. Pursuant to these wiretaps, other law enforcement agents and I intercepted

hundreds of calls in which BGF members made arrangements for narcotics transactions and

discussed acts of violence. Other agents and I also intercepted numerous calls between Glasscho

and his suppliers and customers in which Glasscho made arrangements to receive and distribute

quantities of heroin.2

III. The Indictments

13. On April 8, 2009, a Federal Grand Jury sitting in the District of Maryland

returned separate Indictments charging a total of 25 BGF members and associates with drug-

trafficking and other offenses. Specifically, one Indictment (the “Brown Indictment”) charged Eric

Brown and thirteen others, including Deitra Davenport, Rainbow Williams, Marlow Bates, and

current or former corrections employees Terry Robe, Asia Burrus, Musheerah Habeebullah, and

Takevia Smith, with participating in a conspiracy to distribute and possess with intent to distribute

controlled substances, in violation of 21 U.S.C. § 846; the same indictment also charges Randolph

2
Based on my training and experience, I know that narcotics traffickers often use codes
when speaking on the telephone about their illegal activities, and, specifically, often speak in
code about narcotics, quantities of narcotics, payments for narcotics, and the proceeds of
narcotics-related transactions. Where I have described those conversations in this affidavit, I
have done so only in substance and in part. Based on my training and experience and other
investigation in this case, including other intercepted calls, I have included my interpretation of
these calls in brackets and at the end of the summary of each call.

8
Edison, Roosevelt Drummond, and Zachary Norman with involvement in the drug conspiracy, but

with also participating in a Hobbs Act robbery conspiracy, in violation of 18 U.S.C. § 1951. A

second Indictment (the “Glasscho Indictment”) charges Kevin Glasscho and 10 others, including

Cassandra Adams, Tyrone Dow, Calvin Robinson, Avon Freeman, James Huntley, Darnell Holmes,

a/k/a “Moe,” Darryl Taylor, Joe Taylor-Bey, a/k/a “Joe Taylor,” Darien Scipio, a/k/a “Reds,” and

Lakia Hatchett, with participating in a conspiracy to distribute and possess with intent to distribute

one kilogram or more of heroin, in violation of 21 U.S.C. § 846. All of the offenses charged in these

Indictments were committed in furtherance of, or were committed by members of, the BGF

racketeering enterprise. Copies of those Indictments, which have been filed under seal, are attached

hereto.

IV. The BGF Criminal Enterprise

A. Overview

14. As more fully described below, BGF is attempting to take over the illegal

drug trade at multiple locations in Baltimore, Maryland and is committing drug-related acts of

violence and extortion schemes as part of its efforts to expand its influence from inside the prison

walls to the streets of Baltimore. The evidence obtained to date has established that BGF is active

in numerous prison facilities in Maryland, including, among others, North Branch Correctional

Institution (NBCI), Western Correctional Institution (WCI), Eastern Correctional Institution (ECI),

Roxbury Correctional Institution (RCI), Maryland Correctional Institution – Jessup (MCIJ),

Maryland Correctional Institution – Hagerstown (MCIH), Baltimore City Correctional Center

(BCCC), and Metropolitan Transition Center (MTC), and that the leaders and members of BGF in

Maryland include the following, among others:

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 a. Eric Brown, a/k/a “Dee Brown,” a/k/a “E,” has been identified as one

of the leaders of BGF in the State of Maryland. Brown is currently incarcerated at the Maryland

Transition Center (MTC) in Baltimore, Maryland. Brown has a 1992 conviction for possession with

intent to distribute a controlled substance and two 1990 convictions for unlawful manufacture of

controlled substances.

b. Ray Olivis, a/k/a “Uncle Ray,” a/k/a “Unc,” is one of the founding

members and leaders of the BGF movement in Maryland. Olivis was until recently incarcerated at

MTC but is now at the Baltimore City Correctional Center. Olivis has a 1979 conviction for assault,

a 1987 conviction for robbery with a deadly weapon, a 1990 conviction for felony theft, a 2001

conviction for burglary, a 2004 conviction for possession with intent to distribute a controlled

substance, and a 2007 conviction for being a felon in possession of a firearm.

c. Deitra Davenport is Brown’s wife who assists with the smuggling of

contraband into facilities and is a corporate officer of “DeeDat Publishing,” which is the publishing

company that produces the “Black Book,” a purported BGF manual described infra.

d. Rainbow Williams, who has been identified as one of the leaders of

BGF, is a lieutenant who handles the day-to-day drug distribution network and is also involved in

the smuggling of contraband into correctional facilities. Williams has a 1998 conviction for murder.

e. Tomeka Harris is a member of BGF who is involved in financial

operations of the gang and is also an owner of Club 410.

f. Marlow Bates is a BGF member who is involved in the smuggling of

contraband into correctional facilities.

10
 g. Randolph Edison, a/k/a “Uncle Rudy,” is a BGF leader who is

involved in acts of violence committed on behalf of the gang.

h. Roosevelt Drummond, a/k/a “June,” is a BGF member who is involved

in acts of violence committed on behalf of the gang.

i. Zachary Norman, a/k/a “Zack,” is a BGF member who is involved in

acts of violence committed on behalf of the gang.

j. Terry Robe, Asia Burrus, Musheerah Habeebullah, and Takevia Smith,

among others, are corrections personnel recruited by BGF to assist in the smuggling of contraband

to incarcerated members of BGF, who in turn sell those items for the financial gain of the enterprise.

k. Thomas Bailey, Robert Nedd, a/k/a “Pizza,” and Daryl Moore, a/k/a

“Nutty Bar,” are among other BGF leaders in Maryland prisons.

15. As more fully described below, BGF member Kevin Glasscho, a/k/a “KG,”

is a BGF member who operates a heroin-trafficking organization that distributes heroin in the

Baltimore area and smuggles heroin into BGF members and others in Maryland prisons. Glasscho

has a 1981 conviction for second-degree murder, a 1993 conviction for possession with intent to

distribute a controlled substance; a 1993 conviction for possession of a handgun, and a 1993

conviction for failure to appear. Other members of Glasscho’s organization include the following,

among others:

a. Cassandra Adams, an individual Glasscho claims is his wife,

who assists him in counting and structuring deposits of drug money;

b. Darnell Holmes, a/k/a “Moe,” who operates one of Glasscho’s stash houses

11
and assists in the daily operation of his drug trafficking organization;

c. Tyrone Dow, who is Glasscho’s source of supply of controlled substances;

and

d. Darryl Taylor, who assists Glasscho in smuggling controlled substances

to inmates in correctional facilities.

B. Structure/Overall Operations of BGF

16. During a series of debriefings in late 2008 and early 2009, a reliable confidential

informant (CS1)3 who is a member of BGF advised investigators that BGF is a nationwide prison

gang with a presence in every correctional institution in the country. CS1 related that he/she has

been in various prisons throughout the country and at each institution there has been a faction of

BGF. CS1 related that BGF is violent both inside and outside prison, but that historically BGF has

not been well-organized outside of prison. CS1 stated that currently, BGF is attempting to change

this within Baltimore, Maryland by becoming more organized and effective on the streets.

17. CS1 explained that within the prisons, BGF has a group of individuals who are

in leadership roles/positions of authority and that this leadership group is known as the "Supreme

Bush." All members who are not in the Supreme Bush are considered "members" of the Bush or

Mansion. The only place Bush members hold rank is within the correctional system; once a Bush

member is back out on the streets, he or she is considered a regular BGF member.

18. CS1 identified BGF leaders at multiple Maryland prisons, including Eric Brown,

who is incarcerated at MTC and who is coordinating and organizing BGF’s activities on the streets

3
CS1 is cooperating in hopes of receiving a reduced sentence. Information
provided by CS1 to date has consistently proven reliable and has been corroborated by
independent investigation.

12
of Baltimore. CS1 reported that Brown has a cellphone inside the prison, which Brown uses to

communicate with BGF members outside of the prison. As described below, a court-authorized

wiretap was later installed on Brown's cellphone, identified herein as TARGET CELLPHONE #1.

19. During a series of debriefings over the past several months, a confidential

informant (CS5)4 who is an incarcerated and a BGF member identified "Uncle Ray" or "Ray Ray"

– later identified as Ray Olivis – is a high-ranking member and one of the founders of BGF in

Maryland. CS5 reported that "Uncle Ray," who is incarcerated at MTC, is coordinating BGF

operations throughout the Maryland correctional system by utilizing a contraband cellphone bearing

call number (443) 310-9570. That cellphone number has been corroborated by intercepted jail calls.

CS5 identified Eric Brown as a high-ranking BGF member who is assisting "Uncle Ray" in

coordinating BGF operations. CS5 identified TARGET CELLPHONE #1 as the cellphone number

for Eric Brown, which Brown is using to conduct BGF business. According to corrections officials

Ray Olivis is scheduled to be released from prison in December 2009. As more fully described

below, the information provided by CS5 has been corroborated by, among other things, numerous

intercepted calls involving Brown, Olivis, and other BGF members.

20. Multiple confidential sources described herein have told law enforcement that

BGF members often refer to each other as “comrades.”

21. On April 13, 2009, a BGF meeting was held at Druid Hill Park in Baltimore,

Maryland, near the Maryland Zoo. At least approximately 100 BGF members were in attendance,

including Rainbow Williams, who was one of the leaders. After observing what they deemed to be

4
CS5 has been cooperating with law enforcement for the past several months and
has been compensated for the information provided. The information provided by CS5 has
proven reliable and has been corroborated by independent investigation.

13
suspicious activity, Baltimore Police officers responded to the vicinity of the meeting. Upon

observing the police, the BGF members quickly dispersed on foot and in vehicles. Officers

recovered, among other things, one firearm, multiple copies of the Black Book, BGF t-shirts

emblazoned with the slogan, “Revolution is the Only Solution,” and a document listing BGF

members who have violated BGF rules and the sanctions imposed on each for those violations.

Following this incident, calls were intercepted over the wiretaps in which Eric Brown chastised

Rainbow Williams for holding the meeting in such a manner as to draw the attention of law

enforcement. Brown stated in a scolding manner, “I been tellin’ you and tellin’ you, and you ain’t

listenin’.” In reference to being stopped by the police, Brown added, “Ain’t nothin’ good about that,

yo.”

C. BGF Code of Conduct

22. CS1 and another reliable confidential informant (CS6)5 both advised that BGF

members are required to learn and abide by a code of conduct for the gang, and that BGF members

are periodically tested on their knowledgeof the gang’s history and rules. Members who fail to

demonstrate adequate familiarity with the gang’s history and rules are “sanctioned,” or beaten.

23. CS1 reported that Eric Brown had recently published "The Black Book –

Empowering Black Families and Communities" (hereinafter the "Black Book"). According to CS1,

Brown is purportedly distributing the book in order to disseminate BGF doctrine, but that the Black

Book is a ploy by Brown to make BGF in Maryland appear to be a legitimate organization and not

involved in criminal activity, whereas CS1 advised that Brown is a drug trafficker and that BGF

5
CS6 has pled guilty to federal charges and is cooperating in the hopes of receiving
a reduced sentence. The information provided by CS6 has consistently proven reliable and has
been corroborated by independent investigation.

14
funds its operations primarily by selling drugs.

24. CS1 stated that Brown is making money from the publishing of the Black Book

and that all of Brown's money is handled by Brown's wife or girlfriend, Deitra Davenport, who is

also involved with BGF operations.

25. In January 2009, a reliable confidential informant (CS2)6 reported that Eric

Brown recently wrote a book called "The Black Book – Empowering Black Families and

Communities." Although Brown is the author of the book, the author is listed as "La Eusi Jamaa

(The Black Family)."

26. Law enforcement has obtained a copy of the Black Book, whose author is listed

as "La Eusi Jamaa (The Black Family)." The Black Book was reportedly published by "DeeDat

Publishing Company" trading as Harambee Jamaa Inc., which, is owned or operated by Deitra

Davenport. The corporate officers listed for Harambee Jamaa Inc. are Eric Brown, president, and

Deitra Davenport, secretary. An order form in the book indicates that the price is $15 for "prisoners"

and $20 for "non-inmates."

27. Pursuant to monitoring of recorded jail calls and electronic surveillance

conducted during this investigation, numerous calls were intercepted in which Eric Brown and other

BGF members discussed the publication and distribution of the Black Book, the structure of BGF,

and internal discipline of BGF members.

a. For instance, on or about November 18, 2008, an outgoing call was

placed from a recorded telephone line at NBCI to (410) 365-8152. Tyshawna LNU answered and

6
CS2 who has not been promised or provided with any monetary or other form of
compensation for the information provided. Information provided by CS2 to date has
consistently proven reliable and has been corroborated by independent investigation.

15
arranged a three-way call between Thomas Bailey at NBCI and Eric Brown at MTC. Bailey and

Brown greeted each other, and Brown explained that he was currently on the other line with

“Comrade Doc” from Roxbury [an apparent reference to a BGF member at Roxbury Correctional

Institution]. Brown then put the three of them together on a conference call. Bailey explained that

he had gotten Brown’s telephone number from Joe [a reference to Gregory Fitzgerald]. Brown

asked, “What’s happening man?” Bailey answered, “Man, ain’t nothing man. Rustling man, trying

to get this together [a reference to his on-going efforts to advance BGF within NBCI], man. You

know what I mean? Goodness gracious, you put a burden on me, man.” Bailey went on to explain

that “Pizza” [a reference to Robert Nedd] is in population now and is doing a lot of crazy stuff.

Bailey stated, “I need some political recourse with this dude, man. I’m trying to work with him [a

reference to Bailey attempting to persuade Robert Nedd to follow the BGF protocols] without

ramming him [a reference to harming Robert Nedd for his failure to comply], right?” Brown

responded, “Right, right, right, he hard, ain’t he man?” Bailey said, “He got this utopia thing man,

which don’t exist.” Brown asked, “You get a copy of the book [a reference to the Black Book]?”

Bailey answered, “Nah.” Brown went on, “Well we gotta mail you one tonight then. I’m going to

tell the misses [a reference to Deitra Davenport, Brown’s wife] to take one to work tomorrow and

mail you one tomorrow.” Brown stated, “Man it don’t get better than you and you know, you and

that crew, man. I mentioned you uh, in, in the book [a reference to the Black Book]. You

understand what I’m saying? I mentioned the struggle [a reference to BGF’s continued efforts

against the establishment]. You know what I mean? You know, I’m just so proud of you, man, and

Nutty [a reference to Daryl Moore, a/k/a “Nutty Bar”], man, and how you built me up. It carries me

and how much I learned from you all. You know what I mean?” Bailey responded, “Yeah, yeah.”

16
Brown continued, “I just think how much I learned from you. How sharp you is. Because you got

that guerrilla thing on lock, a lot of people don’t get to know about your brains. You understand

what I’m saying?” Bailey responded, “Right, right, right.” Bailey went on to explain that Joe [a

reference to Gregory Fitzgerald] was out there with “Man,” light skinned man. Bailey said, “Joe

put a whole lot of foot work in for me, man. You know what I mean?” Brown responded, “Yeah,

yeah of course, of course man. Cause when he used to travel with that kind of cake [a reference to

a large amount of drug proceeds] right. I’m keeping records. You understand what I’m saying?”

b. Later in the conversation, Brown and Bailey discussed BGF’s future

plans. Brown said, “Listen, man, we on the verge of big things, man.” Bailey explained, “Alright

man, uh you know what I mean? You already know man, I’m a solid soldier. Whatever you need,

whatever you need me to do man, I’m there, man.” Brown explained, “OK, this positive movement

that we are embarking upon now, right, is moving at a rapid pace, right. It’s happening on almost

every location [all prisons and other locations where BGF is active].” Bailey explained that they

needed to be brought up to speed. Brown stated, “Revolution is the only solution brother.” Bailey

made it known that whatever direction Brown says it is going is fine because right now Brown has

the reins [is the leader of BGF in Maryland]. Brown went on to explain that the book [Black Book]

is full of lessons and study guides [lessons and related materials to help new members learn the

history and ways of BGF] to which Bailey replied, “Alright, I’m waiting on it man.” Brown went

on to explain that the study guides are used to teach the lessons and that Brown will have a book sent

to Bailey personally. The book sent to Bailey will have something the others do not have, which

is the test along with the answer keys. Brown stated that each section should be taught as a class

and that this is happening everywhere [all prisons and other locations where BGF is active]. Brown

17
said he does not want anyone to get left behind.

c. On February 26, 2009, at approximately 10:56 pm, Brown placed an

outgoing call to Deitra Davenport. During the conversation Brown told Davenport, “I wanted you

to do something.” Davenport asked, “What you want me to do?” Brown said, “Go to the firing

range.” Davenport asked, “Why?” Brown continued, “Bust that gun for a minute. You ain’t been

out there in a while.” As the conversation continued, Brown received an incoming call from (410)

242-6954 with an unknown subscriber and utilized by an individual known only as “Bones.” Bones

told Brown, “I got 50 books [a reference to the Black Book], right. That’s basically left over. Um,

I can run the cover for them and all that. But um, you know next week I go and see my PO [an

apparent reference to a parole or probation officer]. So I don’t know how that’s gonna go. I’m

trying to see if you want to snatch them or if you just, you know what I mean? Cause I don’t got

nothing to do with them. You know what I mean? Like I ain’t charging you for them or nothing

like that. You feel me?” Brown asked, “Alright, what you want for them?” Brown and Bones then

agreed on a price of $100 for the remaining books. Brown explained that “D” [a reference to Deitra

Davenport] would be ready for him with the money whenever Bones could deliver the books.

Brown said that he would give Bones Davenport’s contact number. Brown then asked, “Hey, Bones,

how many books have I bought so far?” Bones explained, “The first run was 200, this last run was

200 and then I think you got like two runs in between or you may got three runs in between for a

hundred. So they would be 700 easy, right there.” Brown explained, “I counted 900.” Bones

responded, “900, it’s possible.” As the conversation regarding the Black Book continued, Brown

connected Bones and Davenport on a three-way call. All three then discussed the time frame in

which the Black Book had been first published and distributed. Based on my training and

18
experience and other information developed during this investigation, I believe that in the initial part

of this conversation, Brown was instructing Davenport to go to a firearms range in order to improve

her skills with a firearm she has in her possession, consistent with BGF rules requiring female

members to be proficient with firearms. When Bones called Brown, they discussed the publication

and dissemination of at least 700-900 copies of the Black Book.

D. Drug-Trafficking/Drug Smuggling

28. CS1 stated that drug trafficking both inside and outside of prison is the primary

means by which BGF makes money and is a significant part of BGF's activities on the streets of

Baltimore. CS1 explained that BGF will sell any drugs, but primarily cocaine and heroin.

According to CS1, Brown is coordinating sales of cocaine and heroin on the streets of Baltimore

from inside of prison. CS1 said that Brown's key lieutenants on the streets for drug-trafficking

activities include Rainbow Williams, Gregory Fitzgerald, a/k/a "Joe," and Austin Roberts, a/k/a

"Yellow."

29. CS2 advised that multiple prison guards and other employees of the Maryland

Department of Corrections are assisting BGF members in smuggling contraband – including drugs,

tobacco, cellphones, and weapons – into prison facilities in Baltimore.

30. Pursuant to monitoring of recorded jail calls and electronic surveillance

conducted during this investigation, agents and officers intercepted numerous calls in which Eric

Brown and other BGF members discussed and arranged narcotics transactions.

a. For instance, on or about November 18, 2008, an outgoing call was

placed from a recorded telephone line at NBCI to (410) 365-8152. Tyshawna LNU answered and

arranged a three-way call between Thomas Bailey at NBCI and Eric Brown at MTC. During that

19
conversation, Bailey told Brown, “Right now man, I’m short of a girl. I need, you know, I need

somebody to work the post office for me and carry some mail [smuggle drugs and/or other

contraband to Bailey at NBCI].” Brown responded, “Right, right.” Bailey asked, “You got

somebody with that type of interest?” Brown stated, “Okay, okay, okay, okay, I’ll get on top of that,

I’ll get on top of that. That’s not a problem.” Brown then explained that he does not want Bailey

to get mad if he makes a bad pick when he gets the girl. Bailey stated, “I can’t afford that right now.

I’m in a tough situation.” Brown assured him, “I understand, I understand. I’m going to help you

as much as I can.” Brown explained that he would look around for a trustworthy friend. Bailey

said, “It’s a gamble anyway. You know what I mean?” Bailey even explained that his mother had

offered to be the girl [courier] coming to the prison but that he had declined the offer. Later in the

conversation Brown asked, “What is it you need me to do for you personally?” Bailey answered,

“I need a girl [female courier], man. I need the girl.” Brown responded, “Is that it?” Bailey

answered, “That’s it.” Brown confirmed, “You sure?” Bailey explained, “Right now I need the girl.

That’s the most important thing man. You know what I mean?” Brown assured Bailey, “OK, so

what I’ll do, I’ll get on top of the girl.” As the conversation came to an end, Brown made it clear

that Bailey needed to keep in constant contact with Brown. Bailey stated, “I need the girl, man.

Once I get the girl, man, everything, everything.” Brown acknowledged his problem, “Man I’ve

been in that situation before man. I know where you’re coming from, then everything will fall into

place. I got you, man.” Based on my training and experience and on other information developed

during this investigation, including other intercepted calls, I believe that in this call, Brown and

Bailey are discussing the problems associated with finding a female courier to smuggle drugs into

correctional facilities. Brown also assures Bailey that once a satisfactory method of smuggling

20
drugs into the facility is accomplished, Bailey’s situation will improve.

b. On February 24, 2009, at approximately 3:12 pm, Brown made an

outgoing call to Deitra Davenport. During the call, Brown told Davenport, “Give five of them cans

to Rainbow and give him $300 too.” Davenport asked, “Do what?” Brown continued, “Give

Rainbow the five cans today and give him $300 too.” Davenport responded, “Um huh.” Brown then

said, “He should have $300. That’s what I was getting at when I was asking you, what about the

money, don’t he owe some money for them books [a reference to the Black Book]. Don’t he?”

Davenport went on to explain that she believed that Williams currently owed money for 30 books.

Brown then explained that he would investigate. Based on my training and experience and other

information developed during this investigation, I believe that, in this conversation, Brown was

instructing Davenport to deliver “five cans,” which I believe to contain contraband and $300 to

Rainbow Williams. The “five cans,” which on occasion contain tobacco, would be delivered to

Williams for the purpose of having him arrange for the items to be smuggled into the prison where

Brown is currently being housed. The $300 referenced is believed by law enforcement to be payment

that was to be provided to an unidentified corrections officer who would be responsible for

smuggling the contraband into the prison facility. During the course of this investigation law

enforcement has learned from prison officials, confidential sources, and cooperating inmates that

there are correctional officers working in the Maryland prison system that are assisting inmates with

the smuggling of illegal contraband into the different prisons. Some of these items include tobacco,

weapons, and controlled substances including heroin and ecstasy.

c. On February 24, 2009, at approximately 5:19 pm, Brown received

an incoming call from Deitra Davenport. After the two greeted each other Davenport said, “I need

21
you to call Rainbow and see where he, where I need to meet him at.” Brown asked, “You can’t

catch him?” Davenport answered, “I don’t have his number.” At this time Brown then placed a

three-way call to Rainbow Williams. The three-way call went unanswered. Brown then returned

to his conversation with Davenport and said, “Just go ahead and lay back, he just got to come see

you.” Davenport then said, “Alright.” Based on my training and experience and other information

developed during this investigation, I believe that this communication was a follow up to Brown and

Davenport’s earlier conversation regarding the “five cans” and the “$300.” Davenport was inquiring

about when and where she should meet Williams to make the delivery of the contraband.

d. On February 24, 2009, at approximately 9:14 pm, Brown placed an

outgoing call to Deitra Davenport. During the conversation Brown asked, “So how far are you away

from him?” Davenport answered, “We supposed to be meeting down, right here on Harford Road

and Hamilton. But I don’t see him yet.” Brown then said, “Let me call him.” Brown then placed

an outgoing call to (410) 336-0375, utilized by Rainbow Williams, which went unanswered. Brown

then returned to his call with Davenport and asked, “You there and he ain’t there?” Davenport

answered, “No I don’t see him.” Brown then said, “Alright just roll out then.” Davenport

responded, “What?” Brown continued, “Yeah, just roll out I’ll deal with his ass some other time.

I, I don’t like shit like that. I don’t like shit like that, having you out there like that.” Davenport

continued, “He said ten minutes.” Brown continued, “He just fucked up. He ain’t even answering

his phone.” Davenport asked, “You wanna call him again before I go all the way back home?”

Brown answered, “Yeah, I’ll call him again.” Brown then attempted a three way call with Williams

which went unanswered. Brown then said, “Yeah go ahead, roll out D.” Brown then received an

incoming call from Williams. Brown then conducted a three-way call with himself, Davenport and

22
Williams. Brown said, “D.” Williams responded out of turn, “Yeah.” Brown explained, “Yeah,

yeah she on there, Bow.” Williams responded, “You there already?” Davenport responded, “You

said ten minutes.” Williams continued, “Alright, I’m almost there. I’m almost there, I’m coming

right down the street now.” Davenport explained, “Alright I’m going to pull into this Wachovia.”

Williams responded, “Alright.” The three-way conversation with Williams then concluded. Brown,

however, continued to stay on the phone with Davenport as if he was making sure she was safe.

Based on my training and experience and other information developed during this investigation,

including other intercepted calls, I believe that in this conversation, Williams was meeting with

Davenport, at the direction of Brown for the purpose of receiving the five cans of contraband that

Brown wanted smuggled into the prison.

e. On March 1, 2009, at approximately 12:45 pm, Brown received an

incoming call from (443) 520-2121, utilized by Marlow Bates. During the conversation Bates

asked, “Did you ever get your sweat suit and your tenners?” Brown responded, “Nah.” Bates asked,

“Why it’s hard getting them in?” Brown responded, “I got knocked off trying to get the tenners in

the visiting room.” Bates commented, “Oh you did! Who, who knocked, you off?” Brown

answered, “A little African girl.” Bates said, “You know when I did that last time, you know when

I did that, you supposed to, you supposed to go in there with your shoe laces like unloose, where as

though you ain’t gotta fuck with it.” Brown said, “I did, I did, it was Rainbow fucked that up.”

Bates asked, “Oh what he had to untie, he had to bend down to untie them?” Brown responded, “No

he had them untied. But he had them untied to the point that you could see that shoe lace, like

hanging. That just look like a dead give-away.” Bates said, “I was wondering if you get that shit

on there now.” Bates went on the explain that he will be going to court the next day and that he

23
wants Brown to keep his phone on so that Bates could contact Brown from court and update him on

Bates’s situation. Based on my training and experience, I believe that Bates had supplied Rainbow

Williams with a pair of shoes which had an illegal substance hidden in the shoes. Williams in turn,

according to Brown, wore the shoes into the prison during a visit with Brown and was attempting

to pass them off to Brown. Due to the way Williams had the shoes tied a female guard was able to

stop the attempted delivery. Other law enforcement agents and I have learned from corrections

officials that during visits with inmates, individuals often attempt to swap shoes which contain

controlled substances with the inmate they are visiting.

f. On March 8, 2009, at approximately 1:21 am, Brown received an

incoming call from (443) 742-3874, utilized by Melvin Gilbert, a heroin-trafficker who is currently

incarcerated at the Maryland Correctional Adjustment Center (MCAC) pending trial on federal drug

conspiracy and witness-murder charges. During the conversation, Gilbert said, “Man I need you in

a big way man.” Brown asked, “What’s going on?” Gilbert replied, “I need the joint, I need the

(unintelligible). I need, I need the (unintelligible). You know, the phone.” Brown responded,

“Man, I thought you got that man.” Gilbert replied, “You didn’t send it over, did you?” Brown

answered, “I told Pig to take it.” Gilbert then instructed Brown to hold on. Gilbert continued,

“Yeah, uh man he didn’t get nothing over here. He said she’ll holler at me. Man look man, if, if you

all have a way man that I can get somebody, I can get my lady to go, go get grab the motherfucker

tomorrow and then get it to somebody. But I got a way, just tell me what to do.” Brown responded,

“Nah, nah, nah they, the problem is the way. Yeah shit, it ain’t, it ain’t, it ain’t none of that. None

of that ain’t the problem. The problem is the way, like damn.” Gilbert responded, “Oh.” Brown

continued, “They got our ass boy, they shut this motherfucker down. You hear me? They shut this

24
motherfucker down and now they come to get every, everyone that’s in this motherfucker.” Gilbert

responded, “God damn.” Brown continued, “Let me tell you, if something don’t come up, if they,

if we don’t open a hole up by the end of this month it probably don’t be no more than about twenty

phones left in this motherfucker. I’m telling you. They’re tearing our ass up, Melvin.” Gilbert

advised, “Yeah, they heavy over here too [a reference to MCAC]. But over here they ain’t fucking

with you, they just knocking these motherfuckers off.” Brown continued, “We just, we just trying

to find us a way right now.” Brown went on to explain that he was recently expecting four new

phones to come in, but when they arrived one was missing. Brown said that he believed that the

missing phone had been delivered to Gilbert. Gilbert explained that he never received the phone.

As the conversation continued, Gilbert asked, “You know the big titty motherfucker who used to

work in MCIJ. She used to work for us though.” Brown asked, “What’s her name?” Gilbert

answered, “Simmons.” Brown acknowledged that he knows Simmons. Gilbert then said, “Man,

holler at that bitch for us. She over here and she working, but she’s staying away from me.” Gilbert

explained that Simmons was doing things for other prisoners who are “low budget” when in fact she

should be working for Gilbert. Brown went on to further identify Simmons as a Sergeant, who had

at one time worked in the kitchen at MTC. Gilbert went on to reference another unidentified female

corrections officer, who he believes is smuggling items into MCAC. As the conversation continued,

Gilbert mentioned another corrections officer who is pregnant with his child and who is believed

to be providing information regarding other inmates. Gilbert explained that this corrections officer

recently was threatened by an unidentified inmate. This corrections officer told Gilbert that she was

in fear for her safety, but Gilbert said he told her, “‘Don’t you ever call me and tell me, like you’re

worried about another motherfucker. Them niggers be bluffing.’ I said, ‘I’m not a bluffer.’ I said,

25
‘I’m the one that you gotta worry about.’” Based on my training and experience and other

information developed during this investigation, I believe that in this conversation, Gilbert was

asking for Brown’s assistance in obtaining a cellular telephone in prison. The two discussed the fact

that even though they both have corrupt corrections officers working for them, there has been a

heightened security presence which is affecting their smuggling operation.

g. On or about April 4, 2009, Eric Brown was intercepted during two

lengthy phone conversations with a BGF member identified as “Kiru” a/k/a “Cabo.” During these

calls, Brown and the other BGF member discussed a recent theft of 18 grams of heroin that had been

smuggled into a prison facility secreted inside of a cellphone. During these conversations, Brown

and the other BGF member discussed efforts to identify the individuals responsible for the theft of

the heroin and to recover the stolen heroin. Brown told the other BGF member that he was going

to conduct an investigation into the theft and attempt to purchase some of the stolen heroin using

“fake money,” an apparent reference to a Green Dot card. Intercepted calls revealed that the

individual believed to be responsible for the theft was assaulted by other BGF members in the prison

and that ultimately Brown was able to recover approximately 2.5 grams of the stolen heroin and a

cellphone.

31. Pursuant to the electronic surveillance conducted during this investigation,

numerous calls were intercepted with prison guards or other employees in which Eric Brown or

Rainbow Williams discussed smuggling contraband to BGF members in prison facilities.

a. For instance, on February 24, 2009, at approximately 10:52 pm, Brown

placed an outgoing call to (443) 449-9240, utilized by corrections employee Takevia Smith a/k/a

“Kiki.” Brown asked, “What’s up with the big controversy concerning you?” Smith asked, “What

26
controversy?” Brown continued, “You, you telling on some girl.” Smith responded, “Ain’t nobody

telling….” Brown continued, “I’m just asking you what’s up with it, that’s all.” Smith continued,

“Nothing, Emmanuel and I talked about some Little Earl and the nigger Ski told him that shit and

we all pulled each other up and they never told him no shit like that. Cause Little Earl was standing

there when the shit happened. Poe my witness on that. I ain’t never tell nobody no shit like that.

They always got my name in something like that. They don’t like me in that kitchen.” Brown then

asked Smith who Smith had last had sex with in the kitchen. Smith said that she had not had sex with

anyone in the kitchen. Smith went on to explain that unidentified persons had spread the rumor that

she had been fired from her job. Smith explained that they were obviously wrong because she was

still employed. Smith said, “It take a lot to bring me up on the smallest shit, I got the Union behind

me.” Brown then asked Smith if she was alright and wished her a happy birthday. The call then

disconnected. Based on my training and experience and other information developed during this

investigation, I believe that in this conversation, Brown was asking Smith whether or not she had

provided information to other correctional officers regarding an unidentified inmate who was

violating prison regulations. Brown was also questioning Smith about non-regulation activities that

she was involved in while working in the prison. Smith stated that although she might have

committed small violations in the institution, she was not worried about her job because she had the

“Union” behind her and it would be difficult for her to be fired.

b. On February 24, 2009, at approximately 10:58 pm, Brown received an

incoming call from corrections employee Takevia Smith, a/k/a “Kiki.” During the conversation

Smith said, “Yeah, ain’t nothing going on with me. They just always got my name in some bullshit.

Ask Earl I ain’t start that one.” Brown responded, “I heard that. But I’m just saying.” Smith

27
continued, “I just hope he don’t even say nothing to me. Just stop keep telling people little shit

about me. Like cause they come right back and tell me like, yeah why Emmanuel said you ratted

on me. How can I rat on you like, even if oh I caught you all….Make your mind up. If that the case

you a rat cause you ratting on one. What the fuck. Cause these niggers in there got it all fucked up,

like leave me alone.” Brown then asked if she has been alright. Smith said, “Yeah, I be alright

every day. I don’t loose no sleep over that bull crap.” Brown then asked, “When you gonna take

care of me?” Smith responded, “Uh, see last week I was off of work.” Brown responded, “Oh

yeah.” Smith explained that Brown needed to keep in contact with her. Based on my training and

experience and other information developed during this investigation, I believe that in the initial

conversation, Brown was inquiring whether or not Smith had been providing information regarding

unidentified inmates to other correctional officers, which she denied. When Brown asked, “When

you gonna take care of me?” Brown was referring to Smith smuggling illegal contraband into the

prison facility for Brown. Smith explained that Brown needed to keep in contact with her in order

to arrange that type of transaction.

c. On February 24, 2009, at approximately 11:27 pm, Brown placed an

outgoing call to corrections employee Takevia Smith, a/k/a “Kiki.” During the conversation, Brown

and Smith discussed provocative photographs of Smith which Smith had sent to Brown via text

message. Later in the conversation Brown asked, “What if it’s like I came over there and picked

something up from somebody too though right.” Smith responded, “Right, well they let you in the

back of the kitchen. Like I don’t know I just be on my shit. I be like, I’m very sneaky so like I get

them in and I get them out. You see what I’m saying?” Brown responded, “Yeah.” Based on my

training and experience and other information developed during this investigation, including other

28
intercepted calls, I believe that Smith was acknowledging that she was engaged in prostitution inside

of the correctional facility. This is in part based on information recently obtained from corrections

officials and confidential sources who have personal knowledge of Smith’s criminal activity.

According to at least one confidential source, Smith obtains money in exchange for sex in the prison.

d. On March 3, 2009, at approximately 10:24 pm, Brown received an

incoming call from Takevia Smith, a/k/a “Kiki.” During the conversation Smith said, “Just cause

I don’t work over there no more, don’t mean you all got to stop calling me.” Brown talked about

how he has been sick recently. Smith continued, “I’m stress free now. That damn job was stressing

me out.” Brown asked why she was stressed with her job. Smith said, “Because they was stressing

me out and I, I had went there last week. I took off my bag and they was stressing me out. The big

boss called me back, but they didn’t find anything. I left.” Smith went on to explain that she wants

to be a nurse. Smith explained, “That job [the prison job] be cool while it lasted. But that shit like

having a McDonald’s job, I got to break the law to get money.” Smith continued, “Before I even

got caught up in some old bull shit. Getting knocked off or motherfuckers keep on spreading

rumors, I’d rather quit.” Based on my training and experience and other information developed

during this investigation, I believe that Smith, who had recently resigned from her position at the

prison following a search of her person as she entered the facility, was advising Brown that she had

quit her job before she was arrested smuggling illegal contraband into the facility.

e. Some other examples of such calls involving particular corrections

employees are discussed infra in the sections relating to those individuals.

32. During a series of calls intercepted in April 2009, Eric Brown discussed with

Deitra Davenport and others the fact that he and other BGF members were smuggling champagne

29
and Grey Goose vodka into MTC. Brown attempted to get lobster into the facility but ultimately

was able to smuggle in only “salmon with shrimp” and “crab imperial.” Brown asked Davenport

to smuggle a “good cigar” into the facility so he could enjoy a “good cigar” while he was drinking.

E. Extortion/Financial Transactions

33. CS1 stated that BGF is extremely violent, both inside and outside prison

facilities, and is responsible for numerous crimes of violence and related crimes, including robbery,

extortion, and murder for hire.

34. CS2 further advised that several guards with the Department of

Corrections are assisting BGF members with an extortion scheme under which BGF offers

"protection" while in jail to newly arrested persons who are not BGF members. In exchange for this

"protection," an arrested person is required to pay money to BGF. Specifically, BGF supplies the

person to be protected with a credit card number of a prepaid credit card (sometimes referred to as

a "Green Dot" card), and the person to be protected is required to have family members or friends

place money onto the card when periodically directed to do so by BGF. The credit card is often held

by one of the corrections officers who are assisting BGF or by BGF members on the street. The

credit card is then used to pay for items for BGF members. If the newly arrested inmate does not

agree to pay for the "protection," then he or she is targeted for violent crimes while in prison.

35. Pursuant to the electronic surveillance conducted during this investigation,

numerous calls were intercepted in which Eric Brown and other BGF members discussed financial

transactions involving the use of “Green Dot” cards.

a. For instance, on February 23, 2009, at approximately 9:44 pm and

9:46 pm Brown made outgoing calls to 1-800-473-3636, assigned to the Money Pac Hotline, which

30
is part of the Green Dot Financial Network. During the 9:44 pm call, Brown added $50.00 to the

account number ending in 2087. During the 9:46 pm call, Brown added $50.00 to the account

number ending with the numbers 2135. Based on my training and experience and other information

developed during this investigation, I believe that Brown and other BGF members are laundering

illegal proceeds gained from the sale of controlled substances, the sale of contraband including

tobacco, and the extortion of non BGF prisoners inside of the correctional facilities by using Green

Dot debit cards.

b. On February 23, 2009, at approximately 9:48 pm, Brown placed an

outgoing call to (443) 597-8806 with an unknown subscriber, utilized by Jesse LNU. When the call

connected, Brown asked, “May I speak to Jesse?” Jesse responded, “This is her.” Brown continued,

“How you doing, this EB, Jesse. Uh, Tay wanted to buy some books or something.” Jesse

responded, “Yeah what do you need that, what do you need that Green Dot number?” Brown

answered, “Yeah if that what he want, if that’s how he wants to do it?” Jesse responded, “I guess,

he told me to get a Green Dot for $25. Is that what you need?” Brown continued, “That’s how we’ll

do it then.” Jesse then provided Brown account number 9190 9909 7411 7177 407, which Brown

acknowledged. Brown then asked, “Where the books go now? Where do I mail them to?” Jesse

told Brown to mail the books to DOC number 278 512 under the name Dante Smith. Based on my

training and experience and other information developed during this investigation, I believe that, in

this conversation, Brown was obtaining payment through the use of a Green Dot debit card for

selling copies of the Black Book to DOC inmate Dante Smith.

c. On March 1, 2009, at approximately 1:28 pm, Brown received an

incoming call from BGF member Joe Edison, a/k/a “Outlaw.” During the conversation Edison

31
asked, “How do you know if your Green Dot account is froze?” Edison continued, “When you go

to use the card, it won’t let you use the card. Like to go buy something.” Brown added, “Or take

money off it.” Edison said, “Yeah, cause my sister wanted to get some money today, they wouldn’t

let her do it.” Brown explained, “They gonna contact you.” Based on my training and experience,

I believe that during the conversation between Brown and Edison the two were discussing the use

of Green Dot debit cards which are commonly used by inmates for the purpose of laundering illegal

proceeds.

F. Acts of Violence

36. CS1 stated that BGF is extremely violent, both inside and outside prison

facilities, and is responsible for numerous crimes of violence and related crimes, including robbery,

extortion, and murder for hire. CS1 explained that BGF employs "Death Angels" or hitmen to carry

out murders on its behalf. CS1 related that only certain people know the identity of each "Death

Angel." CS1 advised that BGF will employ others to act as hitmen who may or may not be "Death

Angels." According to CS1, there are enough violent members of BGF to carry out murders. CS1

identified Joe Fitzgerald, later identified as Gregory Fitzgerald, a/k/a "Joe," a BGF member who was

recently released from prison, as someone who has killed people in the past – including multiple

stabbings on behalf of BGF while in prison. CS1 advised that Rainbow Williams is also an

extremely violent BGF member. According to CS1, Williams has committed multiple murders,

including numerous assaults/stabbings while in prison. CS1 stated that both Fitzgerald and Williams

are loyal to, and take orders from, Brown.

37. Pursuant to the electronic surveillance conducted during this investigation,

numerous calls were intercepted in which Eric Brown and other BGF members discussed acts of

32
violence committed or to be committed on behalf of BGF.

a. Based on a review of law enforcement records and discussions with

other law enforcement officers, I have learned that on March 13, 2009, BGF members Randolph

Edison, a/k/a “Uncle Rudy,” Zachary Norman, and Roosevelt Drummond, a/k/a “June,” were

stopped in a vehicle. Drummond was in possession of a firearm at the time of the stop. Officers

recovered handcuffs, rubber gloves, and a mask. Drummond was taken into custody, but Edison and

Norman were released. Later that day, at approximately 6:42 pm, Brown placed an outgoing call

to Edison at (443) 980-1230. During the conversation Edison explained, “We just had some bad

luck man. Yeah, we just had some bad luck.” Brown asked, “What’s that?” Edison continued, “We

was in the car, yeah and they pulled us over, right. You know we gonna do something, but the coon

that was setting the whole degree up, he’s the rat. He set all us up.” Brown asked, “Q [a reference

to Roosevelt Drummond] there?” Edison answered, “Yeah Q [Drummond] had the burner [a

reference to a firearm] on him and he had just gotten out of the car.” Brown exclaimed, “Damn.”

Edison said, “Yep, just happened, just happened.” Brown responded, “God damn.” Edison

continued, “Just happened E. Just lucky I ain’t carry that thing. I said, I said leave it Ock. You, you

good with (unintelligible).” Brown then yelled in the background for “Unc,” a reference to Ray

Olivis. Edison said, “I’m glad I ain’t have, sh, oh.” Brown responded, “Man, ain’t no bull shit man,

that’s the last thing you need boy.” Edison continued, “Especially Q man. Oh man.” Brown then

told Olivis that he had someone on the phone that wanted to speak with him. Olivis then used

Brown’s cellular telephone to speak with Edison. Edison then handed his phone to Zachary

Norman. Norman said to Olivis, “Rats out here now yo. You got to be so careful man. We just

almost went to the Penitentiary for the rest of our life, me, Rudy, (unintelligible).” Olivis asked,

33
“For what?” Norman explained, “Yeah, we were going straight do it tonight and we figured

afterwards that (unintelligible) was a rat. He was on the phone the whole time. All of us, all of us

don’t want to say nothing but (unintelligible). We got to talking, now his cellphone’s off.” Olivis

responded, “Right, right, right.” Norman continued, “But the nigger, nigger man!” Olivis said,

“Good god all mighty.” Norman continued, “I got to go and give her the bad news right, man I think

this dude’s a rat.” Olivis advised, “Man you all got to be safe. You all stay, be safe man. You all,

I’m the only motherfucker with some (unintelligible) in here left, so all got to really be safe man.

You know whatever you do man. You know?” Later in the conversation, Norman said, “There’s

no probable cause, I asked them, I kept asking them why he stop the car. He never would answer.

They let me and Rudy go. The rat motherfucker supposed to had a warrant.” Olivis said, “Alright,

we need to know here he at. I’ll be on top of all of it.” Based on my training and experience and

other information developed during this investigation, I believe that Edison and Norman were

reporting to Brown and Olivis about their encounter with police while en route to commit a drug-

related armed robbery, and that Norman and Olivis were discussing possible retaliation against a

suspected informant.

b. During this same conversation, Norman asked Olivis, “...You know

Pudgy, right?” Olivis asked, “Pudgy, right?” Norman answered, “Right, he’s responsible for my

little brother’s death.” Olivis asked, “You talking about that red bitch Pudgy?” Norman answered,

“Yes, he set it up.” Olivis responded, “Oh yeah.” Norman continued, “Yeah with Calvin. Then he

was telling dudes instead (unintelligible).” Olivis asked, “You talking about your little brother,

Zack, the little one, right?” Norman answered, “Yeah (unintelligible).” Olivis explained that he did

not even know about the death. Norman said, “He said both of them on court side [an apparent

34
reference to a pretrial detention area], right. I need some torpedoes. I’m gonna take care of him.

I’m gonna take care of him. I got, I’m gonna take something in there to him. Find out who it is and

what they need. Tell me where they gonna be (unintelligible).” Olivis advised, “Alright Bear, I’m

already on top of that man.” Norman continued, “I want them to let them know (unintelligible).”

Olivis asked, “Why you and Rudy ain’t been got in touch with me about that man?” Norman

advised, “They just got locked up about three weeks ago.” Olivis said, “Okay.” Norman continued,

“Have them sent over there. I wanted to deal with it myself. Dig what I’m saying? But my mother

was so fucked up she didn’t want me to, you know. Listen man, niggers got to (unintelligible).”

Olivis advised that they did not need to talk about the situation any longer. Olivis said, “Man you

all, you should have been in contact. I, I ask Calvin about you and Rudy every time I talk to him.

Man, he said he be seeing you all.” Norman advised, “That shit just been rough man. Me and

shorty been getting, trying to make something happen man.” As the conversation continued Olivis

said, “Alright let me figure out a way for that man. Let me figure out a way myself. You know what

I mean?” Norman said, “To get, find out who on court side and think about how we can work this

with June [a reference to Drummond].” Olivis responded, “Okay, alright, alright.” Based on my

training and experience and other information developed during this investigation, I believe that

Norman and Olivis were discussing plans to murder an inmate suspected of being responsible for

the murder of Norman’s brother.

c. Toward the end of this call, an unidentified male got on the telephone

and spoke briefly with Norman. At the conclusion of their conversation the unidentified male said,

“Look I got take care of something with, I got to take care of something with Uncle Ray [a reference

to Olivis]. So, I’m a give ah, the General [a reference to Brown] uh, the phone.” Brown then

35
returned to the telephone, had a brief conversation and then ended the call.

d. On April 1, 2009, Nathaniel King was stabbed to death at the

Baltimore City Detention Center. According to corrections officials the suspect for the murder is

Kelly Toomer, who is incarcerated at the Baltimore City Detention Center pending a murder trial.

On April 4, 2009, at approximately 12:24 pm, Rainbow Williams placed an outgoing call to (443)

869-7063, utilized by inmate Lance Walker, who was recently sentenced to 40 years imprisonment

on federal drug charges and who is pending a murder trial in state court. During the conversation

Walker advised that he had some bad news. Walker said, “I’m hearing, you already know about our

little homey with the dreads, man. That shit ain’t right. Shit ain’t right man. We sitting here right

now like really fucked up about this shit man.” Williams advised, “And brother that ain’t even the

worst part, man.” Walker asked, “What’s wrong now?” Williams said, “Nigger used my name

[claimed to have been authorized by Williams to commit the murder], man.” Walker responded,

“That’s crazy.” Williams continued, “Anybody that know me know man, not that. Is you serious?”

Walker advised, “Niggers been rapped about that and that shit was under the table. Like I ain’t

understand. You ain’t even got to say, that’s crazy man. That’s feds, man that ain’t even right.

That’s what I’m saying yo, shit’s fucked up. Niggers ain’t, man shit’s fucked up.” As the

conversation continued, Williams advised, “With my head slammed on the chopping block , yo [a

reference to Williams’ being punished if he had ordered a murder without proper authorization from

BGF leadership]. My thing is even if I did, you feel me?” Walker advised, “You all niggers know

I go to trial um, the thirteenth yo. Monday I’m supposed to go down here and start this shit man.”

Williams asked, “Monday, what time?” Walker responded, “Nine o’clock, Mitchell Courthouse.

I don’t know what room. You know that shit be down there up on the thing. But April the thirteenth

36
we supposed to kick it off. So I need ya”ll support. You know what I’m saying?” Williams

responded, “Right, I’ll be down there man, I’ll be down there man.” As the conversation continued

a BGF member identified as “Big Spike” utilized Williams’ cellular telephone to speak with Walker.

“Big Spike” advised that he is currently selling drugs. “Big Spike” said, “Shit a little, I mean it’s

up and down right now but yo, shit is, it’s been way better. You feel me?” “Big Spike” then

advised that he also would be at the trial for Walker on April 13. Based on my training and

experience and other information developed during this investigation, I believe that Williams has

been identified as the person responsible for ordering the murder of Nathaniel King. Williams,

however, advised that he had taken no part in that murder but because he is believed to have ordered

the murder he may feel some type of retribution for not having the murder authorized by higher

ranking members of BGF. Later in the conversation Williams and “Big Spike” advised that they

both would be at the trial that Walker is facing on April 13. It is believed that the purpose of the two

appearing at Walker’s trial is to intimidate witnesses and potential jurors.

e. On April 5, 2009, at approximately 11:14 am, Williams received an

incoming call from an unidentified male inmate. During the conversation the inmate advised, “Man

you won’t believe this one. The brother done used your name again on, on a, on the CoCo

situation.” Williams asked, “On what situation?” The inmate answered, “CoCo.” Williams asked,

“CoCo who?” The inmate answered, “CoCo that’s over the jail. The one that’s uh, beefing with uh

D cousin Will. You know anything about that situation?” Williams answered, “Nah.” The inmate

continued, “Alright well he told the, he told the brothers over there that the directive [order to

commit an act of violence] came straight from E [a reference to Eric Brown] to you and you sent it

in to the jail to them. To go ahead and green light on ... [approve an act of violence against] the boy

37
CoCo.” Williams responded, “Are you serious?” The inmate responded, “Man I’m, hold up I got

them on the other line, hold on, hold on.” No connection with the third caller was able to be

accomplished. At approximately 11:17 am, Williams placed a return call to the unidentified inmate.

The unidentified inmate then conferenced in several other callers, including Ray Olivis and other

BGF members, including “Killer” and “Hot Rod.” During the ensuing call, Olivis essentially

conducted a conference among BGF members and commanders. Among other things, Olivis and

the others discussed how day-to-day operations of BGF are to be conducted, violations of the articles

of the BGF movement, and sanctions that have been and should be ordered against those who violate

BGF rules.

V. Search Warrants for SUBJECT PREMISES#1-5

A. Deitra Davenport/SUBJECT PREMISES #1

38. Based on evidence developed during this investigation, including information

provided by confidential sources and calls intercepted during wiretaps, I have learned that Deitra

Davenport, the “wife” of Eric Brown, is a BGF member who assists Brown in running the gang’s

operations. As more fully described above, calls intercepted over the wiretaps in this investigation

indicate that Davenport is smuggling drugs and other contraband to Brown in prison. In addition,

information provided by confidential sources and intercepted calls indicate that Davenport is the

publisher of the Black Book and is assisting Brown and BGF in disseminating the Black Book to

other BGF members, including in prisons.

39. The residence at 5637 UTRECHT ROAD, BALTIMORE, MARYLAND,

identified herein as SUBJECT PREMISES #1, is the residence of Deitra Davenport. Based on a

review of records maintained by the Maryland Department of Assessments and Taxation, I have

38
learned that SUBJECT PREMISES #1 is listed to Deitra Davenport. In addition, based on a review

of records maintained by Baltimore Gas and Electric (“BG&E”), I have learned that the BG&E

account for SUBJECT PREMISES #1 is in the name of Deitra Davenport. As recently as March 27,

2009, law enforcement officers have surveilled Deitra Davenport entering and exiting this location.

40. SUBJECT PREMISES #1 is a two story half brick red row home with the top

half of the residence being siding. There is a white front door and a white storm door. The numbers

5 6 3 7 are written in form stone to the left of the door and on the mailbox post that is to the right

of the front porch steps in the front yard.

41. Based upon my training and experience and my participation in this and other

investigations, as well as my conversations with other agents, I know that certain items are

commonly maintained at the residences of gang members and individuals involved in drug-

trafficking, as set forth in Exhibit 1 and Exhibit 2, which are incorporated herein by reference.

42. Based upon the foregoing and on my training, experience, and participation in

narcotics and gang investigations, I respectfully submit that there is probable cause to believe that

there will be found in SUBJECT PREMISES #1 the items set forth in Attachment A, which

constitute evidence, fruits and/or instrumentalities of violations of, inter alia, 18 U.S.C. § 1962,

which prohibits participation in a racketeering conspiracy; 21 U.S.C. §§ 841 and 846, which

prohibits the distribution and possession with intent to distribute controlled substances, and

conspiracy to commit those offenses; 21 U.S.C. § 843, which prohibits the use of a communication

facility in furtherance of drug-trafficking; and 18 U.S.C. § 1959, which prohibits violent crimes in

aid of racketeering.

39
 B. Rainbow Williams/SUBJECT PREMISES #2

43. Based on evidence developed during this investigation, including information

provided by confidential sources and calls intercepted during wiretaps, I have learned that Rainbow

Williams is a BGF member who assists Brown in running the gang’s operations. As more fully

described above, calls intercepted over the wiretaps in this investigation indicate that Williams

participates in smuggling drugs and other contraband to Brown in prison and in discussions about

acts of violence committed by the gang.

44. In addition to the calls summarized above, numerous other calls were

intercepted during this investigation in which Williams and others arranged drug transactions on

behalf of BGF, discussed acts of violence to be committed on behalf of BGF, and conducted other

BGF business.

a. For instance, on March 15, 2009, at approximately 8:03 pm, Williams

received an incoming call from (443) 388-4235, subscribed to Stephen Dorsey, 210 Guilford Ave,

Baltimore, Maryland 21202, and utilized by a male identified as Moe. During the conversation Moe

said, “Call Dre and tell him to leave them boys alone. Let them have they meeting.” Williams

responded, “Alright, alright, alright, alright, alright, alright we’ll do.” Moe asked, “You got Kareem

number, you got Kareem number?” Williams answered, “Yeah I got it.” Moe continued, “Call

Kareem, cause that’s what I was ready to see if you were gonna call and ask him what’s going on.”

Williams responded, “Alright.” Moe responded, “Alright then call, then call me back.” At

approximately 8:07 pm, WIILIAMS placed an outgoing call to (443) 388-4235, utilized by Moe.

As the call was connected Williams was actively speaking with an unidentified BGF member over

a separate telephone which was on speaker through the use of the push to talk feature on the phone.

40
The unidentified male was telling Williams that he has been arguing with other BGF members about

them not attending BGF meetings. Williams explained, “Alright, this what we gonna do. Tomorrow

you, (unintelligible), all you all man, we gonna sit down man. We just gonna get this shit out of the

way man. Me and Devon ain’t got time to be doing (unintelligible). I mean we got other crews.

See what I’m saying. We got a lot of people to plug man and we can’t keep focusing on what’s

going on in West Baltimore because brothers don’t like each other.” The unidentified male

responded, “I ain’t even fighting. You feel me? I ain’t gonna have no nigger saying fuck me, you

feel me.” The unidentified male continued to explain that he is not going to continue to have

problems with these unnamed BGF members. Williams explained that he understands the

unidentified male’s point of view. Williams said, “Alright man, tomorrow man I’ll be over there

man. After I go see my PO man I’m coming straight over there man.” The unidentified male

continued on about how he is having an ongoing argument with BGF members, specifically Dre.

Williams explained, “Alright man, I’ll be over there tomorrow man. I’m, I’m getting tired of this

shit man. As soon as I get from Guilford man I’m, I’ll be over there man. Get the cat Gotti, let him

tell Kareem to bring his ass there, Slim Dog, all of them, man.” The unidentified male said, “If not

I’m ready to call the comrade [BGF member] right now.” Williams then ended the conversation

with the unidentified male and began speaking with Moe. Williams and Moe went on to discuss the

current problems with some BGF members. Moe said that he told another member, “You tell Dre,

you know, he know the consequences behind whatever he do.” Later in the conversation Moe

explained, “If a brother ain’t registered man and he ain’t doing what he supposed to do by us and

by law then he ain’t no brother. How can you say you a brother, cause he come to one meeting.”

Williams responded, “Right, right, right.” Moe continued, “Come on now, you got people out there

41
on the front line.” Williams responded, “Ain’t no question.” Williams explained that when Moe

has a break tomorrow they will go and handle the problem with some of the BGF members. Moe

explained that they all need to just get along. If a BGF member comes to one of the meetings and

isn’t paying “dues,” and interrupts the meeting then he should not be attending the meetings. Moe

explained, “Whatever going on at the meeting, that’s what’s going on in the meeting. We ain’t

gonna sit there and be a probation officer for them.” Based on my training and experience and other

information developed during this investigation, I believe that currently there is an ongoing feud

between different members of BGF who are operating on the streets of Baltimore. As a result of this

feud Williams has decided that he needs to hold a meeting with the feuding BGF members in an

attempt to settle the dispute. These calls corroborate that Williams is a high-ranking leader in the

BGF organization.

b. On March 21, 2009, at approximately 12:03 pm, Rainbow Williams

placed an outgoing call to Marlow Bates. During the conversation Bates advised that he wanted to

come see Williams that day and see what has been going on. Williams stated that he tried calling

Bates last week. Bates said, “Man I ain’t see you calling me yo. Everybody thought they called me

yo. By me chilling, I was chilling last week. A little disgusted about something there yo. My

phone, I’m like, I’m just waiting on a phone call on my other phone. So I really was like in the crib

for real.” Bates went on to explain that recently a close BGF “comrade” of Bates was disrespected

by an unidentified person. Bates explained that he wanted to talk to Williams in person about that

situation. Williams and Bates both agreed that BGF members and affiliates should not be arguing

or fighting with each other. Bates said, “Like they know me, like, like Rainbow they know me,

before, before I took, you know what I mean? When I had that oatmeal, they know how I like, they

42
know me though, like, come on man, just cause we, we good brothers now man like, that don’t, that

don’t give you no borders to play with no of us. You feel me?” Williams responded, “Right, right.”

Bates continued, “Come on man, my niggers, I’m a keep them in check. They comrades [BGF

members] but they still, they, they still my niggers too. So, you know what I mean? They ain’t

gonna jump without, without my, you know what I mean!” Bates explained that, “Jim Dog is

wrong. He called him a bitch.” Bates explained, “My man wanted to holler at you and shit.

Another good comrade [BGF member], a good brother for real. And yo a straight fool with it right.

I, I, I been chilling yo. I don’t be with none of that dumb ass shit. You know what I be chasing for

real. So, I was a little knuckle head when I was a juvey man, but you no what I mean, I ain’t with

that shit right now. I ain’t with that shit no more. So I just be, you already know what type shit I

be on. I be on my fall back shit for real.” At approximately 6:39 pm, Williams placed an outgoing

call to Bates. During the conversation Bates advised, “Uh, man I didn’t forget you Rainbow. I’m

getting ready to come over there in a little bit yo. I was just running around. You know how it be

sometimes. Alright, I’m a bring, I’m a have somebody that don’t have a car ride with me too, yo.

If that’s cool? He a good dude. If you know he with me, he a good dude.” Williams responded,

“Alright man, I’ll let that slide brother.” Based on my training and experience and other information

developed during this investigation, I believe that Bates has a close BGF associate who is planning

to retaliate against an unidentified person who disrespected him. Bates described the associate as

a “straight fool with it,” a reference to the male being armed with a weapon with the intent to cause

harm to people. Williams advised that he would speak with Bates regarding the situation. Williams

later advised that Bates could bring an unidentified person with him to meet with Williams so they

could discuss how they should respond to the BGF member being disrespected.

43
 c. On March 22, 2009, at approximately 1:34 pm, Williams placed an

outgoing call to (410) 370-6042, with an unknown subscriber and utilized by Dacron Hobbs, an

inmate in the Maryland correctional system. During the conversation Hobbs started discussing an

inmate named Tavon who was incarcerated and may have provided information to law enforcement.

Hobbs stated that he and “Scales” were in the cut together when they received word from the

“comrades” [BGF members] at MCIJ that the unknown person had cooperated with law

enforcement. Hobbs said that the suspected cooperator ultimately was transferred to MCIJ around

the same time that Hobbs was transferred there. Hobbs said that while at MCIJ he began having a

sexual relationship with the correctional officer who was in charge of his tier. This unidentified

female corrections officer told Hobbs that the cooperator had told her he was not safe and asked to

go into segregation. Williams then attempted to conduct a three-way conversation with a separate

inmate who was “putting the investigation out.” Williams then completed a three-way call with an

inmate identified as Black. Hobbs again described the situation regarding the inmate who is a

suspected cooperator. Williams, Hobbs and Black discussed the potential cooperator and how he

should be handled. They also discussed the BGF movement inside different correctional facilities,

including ECI. Based on my training and experience and other information developed during this

investigation, I believe that Williams, Hobbs and Black were discussing whether an unidentified

inmate was cooperating and, if so, how BGF should retaliate against the inmate.

d. On March 22, 2009, at approximately 3:20 pm, Williams placed an

outgoing call to (443) 413-3911, with an unknown subscriber and utilized by Lance Walker. During

the conversation Walker asked, “Man, who the fuck is this nigger Greazy, yo? Greazy!” Williams

asked, “Greazy?” Walker continued, “Yeah, he supposed to have just came home. Talking about

44
there’s a green light on [“hit” out on] me.” Williams said, “I don’t know that nigger.” Walker

continued, “I know he be with Five and them. That’s all I know.” Williams responded, “Oh he do?

Oh, okay.” Walker continued, “He just came home Tuesday. He seen somebody and told them

there supposed to be a green light on me. They, waiting for me to go with the feds and to get back

over the jail and niggers supposed to (unintelligible).” Williams responded, “Oh, okay so that’s see

if we can’t find out who Greazy is.” Walker responded, “Right.” Williams continued, “See why

we can’t make a green light on him.” Walker said, “Thank you, that’s what I’m saying, black man.”

Williams continued, “What the fuck is he talking about. I don’t know them niggers.” Based on my

training and experience and other information developed during this investigation, I believe that

Williams is going to place a hit on “Greazy” in response to “Greazy”’s having placed a hit on

Walker.

e. On March 25, 2009, at approximately 1:17 pm, Williams received an

incoming call from (410) 868-4246, utilized by Tomeka Harris. During the conversation Harris

advised Williams, “You know they transferred Unc [a reference to Ray Olivis]? They transferred

Unc out of the jail last night.” Williams asked, “Where, where they send him at?” Harris said that

the location where he was sent had some C’s in the name of the jail. Williams then realized that

Olivis had been sent to BCCC. Williams stated that Olivis would be fine, because “over there you

can get things done faster, quicker, better.” Based on my training and experience and other

information developed during this investigation, I believe that Harris was advising Williams that

Olivis had been transferred to BCCC the previous night. Williams reassured Harris that Olivis was

now in a better location to further BGF operations, including the distribution of drugs inside of the

prison.

45
 f. On April 9, 2009, at approximately 1:01 pm, Williams placed an outgoing

call to (443) 938-2462, utilized by Jimmy LNU. After the two greeted each other Williams advised,

“I need three man.” Jimmy responded, “Three?” Williams answered, “Yeah.” Jimmy asked, “You

said three?” Williams responded, “Yeah.” Jimmy advised, “Alright I’m getting ready to call my

little cousin and tell him to bring me over that shit now.” Williams responded, “Alright, alright.”

Jimmy advised, “I’ll hit you back. It’ll take 20 minutes yo.” Williams advised that he had some

other things he had to take care of first then the two could meet later. Jimmy advised Williams to

call when he was ready to meet him. Based on my training and experience and other information

developed during this investigation, I believe that Williams was asking Jimmy to supply him with

a quantity of drugs.

45. The residence at 1113 EAST BELVEDERE AVENUE, APARTMENT C,

BALTIMORE, MARYLAND, identified herein as SUBJECT PREMISES #2, is the residence of

Rainbow Williams. During multiple intercepted telephone calls, Rainbow Williams provided the

address of SUBJECT PREMISES #2 as his address. In addition, records maintained by the

Maryland Division of Parole and Probation and by the Maryland Motor Vehicle Administration

(MVA) list SUBJECT PREMISES #2 as the residence of Rainbow Williams. As recently as March

6, 2009, law enforcement officers have surveilled Williams leaving the apartment building of

SUBJECT PREMISES #2.

46. SUBJECT PREMISES #2 is a three story form stone residence with a black

storm door and black front door. The numbers 1 1 0 2 are in brass on the front door.

47. Based upon my training and experience and my participation in this and other

investigations, as well as my conversations with other agents, I know that certain items are

46
commonly maintained at the residences of gang members and individuals involved in drug-

trafficking, as set forth in Exhibit 1 and Exhibit 2, which are incorporated herein by reference.

48. Based upon the foregoing and on my training, experience, and participation in

narcotics and gang investigations, I respectfully submit that there is probable cause to believe that

there will be found in SUBJECT PREMISES #2 the items set forth in Attachment B, which

constitute evidence, fruits and/or instrumentalities of violations of, inter alia, 18 U.S.C. § 1962,

which prohibits participation in a racketeering conspiracy; 21 U.S.C. §§ 841 and 846, which

prohibits the distribution and possession with intent to distribute controlled substances, and

conspiracy to commit those offenses; 21 U.S.C. § 843, which prohibits the use of a communication

facility in furtherance of drug-trafficking; and 18 U.S.C. § 1959, which prohibits violent crimes in

aid of racketeering.

C. Tomeka Harris/SUBJECT PREMISES #3

49. Based on evidence developed during this investigation, including calls

intercepted during wiretaps, I have learned that Tomeka Harris is a close associate of Eric Brown

and Rainbow Williams and a BGF member who assists Brown and Williams in running the gang’s

operations. Harris is the wife of BGF member Vernon Harris, who is incarcerated at ECI, although

intercepted calls indicate that Harris is romantically involved with Brown as well. Calls intercepted

over the wiretaps in this investigation indicate that Harris engages in financial transactions involving

“Green Dot” cards on behalf of BGF members. Intercepted calls also indicate that Harris assists in

smuggling contraband to Brown in prison and relays information among BGF members.

a. For instance, on March 5, 2009, at approximately 12:39 am, Eric Brown

received an incoming call from (410) 868-4246, subscribed to Capital First, 9050 Iron Horse La, Apt

47
318, Pikesville, Maryland and utilized by Tomeka Harris. During the conversation, Harris explained

to Brown why her nightclub, Club 410, is in the process of being shut down by the city of Baltimore.

According to Harris, Baltimore Police have documented three shootings, one handgun arrest, and

an assault associated with Club 410. Brown explained that Harris should deliver the police

paperwork to her lawyer. Brown then advised that his friends “the McCabe Boys” had frequented

the club. As the conversation continued, Harris discussed how, through her job, she is able to

establish different fraudulent corporations for some of her associates. Based on my training and

experience and other information developed during this investigation, I know that BGF members,

including Rainbow Williams, frequent Club 410, which is owned and/or operated by Harris. In

addition, I believe that Harris was telling Brown that one of her other business ventures is

establishing bogus corporations for close associates so that they can obtain loans from banks in order

to purchase high priced items such as vehicles.

b. On March 7, 2009, at approximately 3:33 pm, Eric Brown placed an

outgoing call to (410) 868-4246, subscribed to Capital First and utilized by Tomeka Harris. During

the conversation, Harris explained that she loves Brown, but because of her relationship with Vernon

[known to law enforcement as Vernon Harris], she and Brown may not be able to continue their

relationship. Harris said that because Brown had previously informed her that BGF members are

forbidden to have a relationship with another BGF member’s female companion, there may end up

being problems among Tomeka Harris, Vernon Harris, and Brown. Brown explained, "I know how

to get around it though. You got to help me, that's all I'm saying. You follow what I'm saying? You

know what I'm doing. I know what I'm doing." Harris responded, "I'm glad you know, I don't."

Brown said, "I'll fill you in a little more when you come down here, alright. I know how he gonna

48
carry it." Harris continued, "His homeboy just called me this morning on some stupid shit. Like,

he called me like, Vernon just called him and then the homeboy called me. Just like, you know he

love you more than anything in this world. But I'll make sure you okay out here. He's gonna go

crazy. All of this stuff like we still together. I'm tired." Brown responded, "I got, I got something

for him. I got something for all of that. I got something for all that." Harris asked, "What is it?"

Brown answered, "I'll tell you when you come down. I, I mean I ain't got nothing for that but I got

something in my mind I want to roll around and bounce off you. Harris responded, "Huh?" Brown

continued, "I got something in my mind I want to bounce off you. So the first chance you get um,

Wednesday is the first visit. Can you come down Wednesday?" Harris advised that she would come

to see Brown on Wednesday. Based on my training and experience and other information developed

during this investigation, I believe that Brown and Tomeka Harris have an ongoing relationship.

Tomeka Harris also has a relationship with BGF member Vernon Harris, who is also incarcerated.

Harris and Brown had discussed the fact that BGF members cannot have a relationship with the

same woman because that is a violation of the BGF code. Ultimately, Brown explained that he had

something in mind to deal with this problem, which goes against the BGF code. Brown advised that

he did not want to speak over the telephone regarding the solution for this relationship problem and

that he wanted to talk to Harris in person. It is believed by law enforcement that Brown may be

planning some type of violent act against Vernon Harris, which would address the current

relationship issue.

c. On March 8, 2009, at approximately 12:36 am, Eric Brown received an

incoming call from (410) 868-4246, utilized by Tomeka Harris. During the conversation, Brown

explained that in regards to the "young man,” a reference to Vernon Harris, he will need to get

49
himself a bottle of Moet. Brown said he is going to say, "Brother, that woman that you is grabbing

on, she's mine. From the bottom of her feet to the top of her head and because of that and I know

you didn't know, I know you didn't know. But because you grind her, I'm going to do this. I'm

going to take that Moet bottle and smash him across the top of his god damn head with it." As the

conversation continued Brown again, as if talking to Vernon Harris said, "I'm gonna take this bottle

and I'm going to crack you across your god damn head with it and you’re gonna go out and I'm

gonna beat your, I'm gonna beat the living shit out of you when you out." Based on my training and

experience and other information developed during this investigation, I believe that Brown was

explaining to Tomeka Harris that if the opportunity presents itself he will assault fellow BGF

member Vernon Harris.

d. On March 24, 2009, at approximately 1:59 am, Eric Brown placed an

outgoing call to (410) 868-4246 subscribed to Capitol First and utilized by Tomeka Harris. During

the conversation Brown stated, “Every light on in this motherfucker.” Harris asked, “Why you still

on the phone then?” Brown said that the “comrades” [BGF members] are looking out for him.

Based on my training and experience and other information developed during this investigation, I

believe that by openly talking on a cellular telephone and the fact he has “comrades” watching out

for him, Brown is indicating that he believes he has control over the activities that occur in the

facility where he is being housed.

e. On March 24, 2009, at approximately 9:50 am, Eric Brown received an

incoming call from (410) 868-4246, utilized by Tomeka Harris. During the conversation Brown

asked, “What you driving?” Harris responded, “Um, my van.” Brown asked, “What color?” Harris

advised, “Gold.” Brown then told an unidentified person in the background, “A gold van.” Brown

50
then asked, “Where you at?” Harris answered, “On Fayette Street, I’ll be there.” Brown asked, “Oh

you know where she at?” Harris answered, “Yeah, she told me to meet her, she told me to meet her

a block over the street behind um, Greenmount and Eager. So, I’ll be there.” Brown advised, “I’m

trying to hang in, but I got to be to work at 10 too.” Based on my training and experience and other

information developed during this investigation, I believe that Brown was having an unidentified

correctional officer meet with Harris to obtain illegal contraband which was to be smuggled into the

prison for Brown. The area of Greenmount Avenue and Eager Street is approximately one block

from the prison.

50. Based on discussions with other law enforcement officers, I have learned that

Harris was arrested on February 6, 2009 on federal fraud charges. She is currently on pretrial

release while those charges are pending.

51. The residence at 600 S. HIGHLAND AVENUE, APARTMENT A,

BALTIMORE, MARYLAND, identified herein as SUBJECT PREMISES #3, is the residence of

Tomeka Harris. The cellular telephone used by Tomeka Harris, and with which she has been

intercepted during wiretaps, is subscribed to “Capital First” at 600 South Highland Avenue,

Baltimore, Maryland. I have learned that “Capital First” is a business name that has been used by

Tomeka Harris. In addition, on March 13, 2009, Rainbow Williams was observed entering and

exiting the apartment building of SUBJECT PREMISES #3 and then proceeding to the door of

Apartment A. On that same date, Williams received a parking ticket while he was parked in front

of the apartment building of SUBJECT PREMISES #3.

52. SUBJECT PREMISES #3 is a two story red brick building. The glass door

with gold frame plaque is on the north east side of the building. The number 6 0 0 A is on the right

51
side of the door. Once you enter the glass door apartment A is the dark brown door on the right.

53. Based upon my training and experience and my participation in this and other

investigations, as well as my conversations with other agents, I know that certain items are

commonly maintained at the residences of gang members and individuals involved in drug-

trafficking, as set forth in Exhibit 1 and Exhibit 2, which are incorporated herein by reference.

54. Based upon the foregoing and on my training, experience, and participation in

narcotics and gang investigations, I respectfully submit that there is probable cause to believe that

there will be found in SUBJECT PREMISES #3 the items set forth in Attachment C, which

constitute evidence, fruits and/or instrumentalities of violations of, inter alia, 18 U.S.C. § 1962,

which prohibits participation in a racketeering conspiracy; 21 U.S.C. §§ 841 and 846, which

prohibits the distribution and possession with intent to distribute controlled substances, and

conspiracy to commit those offenses; 21 U.S.C. § 843, which prohibits the use of a communication

facility in furtherance of drug-trafficking; and 18 U.S.C. § 1959, which prohibits violent crimes in

aid of racketeering.

D. Terry Robe/SUBJECT PREMISES #4

55. Based on evidence developed during this investigation, including information

provided by confidential sources and calls intercepted during wiretaps, I have learned that Terry

Robe was a corrections officer who assisted in smuggling drugs and other contraband to Eric Brown

at MTC. Numerous calls were intercepted during this investigation in which Robe discussed the

smuggling of contraband and in which BGF members discussed Robe’s participation in such

activity.

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 a. For instance, on February 25, 2009, at approximately 12:22 am, Eric

Brown received an incoming call from Rainbow Williams. Upon answering the phone Brown asked,

“What’s up?” Williams responded, “It’s done.” Brown continued, “My man. I appreciate it. Hey

you know what, what happened again though.” Williams asked, “What?” Brown continued,

“Forgot to uh, get the uh….” Williams immediately responded, “I forgot. But you know what? I

put the cans in the trunk and the bottle sitting right there.” Brown asked, “You did what?” Williams

continued, “I said, I said I gave her the cans and the pills sitting right there in the box.” Brown said,

“That’s alright cause I’d rather you get, get with Robe [a reference to Terry Robe] and give Robe

the pills than the same guard anyway.” Williams responded, “Oh, alright, they [Robe and another

guard] was together too. Just let me know what else to do bro, that’s all.” Based on my training and

experience and other information developed during this investigation, including other intercepted

calls, I believe that Williams was confirming that he had delivered the “five cans,” believed to be

tobacco, to an unidentified corrections officer who was to smuggle the items into the prison for

Brown. When Brown inquired about the “pills,” which are believed by law enforcement to be

controlled substances, specifically ecstasy, Williams stated that he had forgotten about them. Brown

explained that this was fine, because he wanted a different corrections officer, Terry Robe, to handle

the smuggling of the “pills” into the prison for him. Williams advised that the corrections officer

to whom he had delivered the five cans had been with Robe at the time of the delivery.

b. On February 27, 2009, at approximately 1:53 pm, Eric Brown placed

an outgoing call to (410) 499-8933, utilized by Terry Robe. During the conversation Robe advised,

"I wanted to call and tell you that I used, I used up some money off the card." Brown asked, "All

of it?" Robe answered, "Yes, every penny. I had to pull two sixty to give to the mechanic." Based

53
on my training and experience and other information developed during this investigation, I believe

that in this call, Robe was telling Brown that she had used all of the money from a Green Dot card

to which Brown had been adding money gained from drug and contraband sales inside of the prison.

c. On March 8, 2009, at approximately 12:44 pm, Eric Brown placed

an outgoing call to (410) 499-8933, utilized by Terry Robe. During the conversation Brown asked,

“You gonna uh, bring me some of them pills today?” Robe answered, “No, I ain’t got no bottle.

I gotta find a bottle. You know I ain’t even got no (unintelligible). I got to find one of them too.”

Brown advised, “You supposed to had all that done, because today is supposed to be the day you

supposed to do that. It’s always, it’s easier on the weekends all the time.” Robe asked, “How, how

am I supposed to have it done and I have no car. What, get it done how? Everything I need to get

done, has to be put on hold. I have to wait to do everything. I have to wait on (unintelligible). I

didn’t have it done, cause I don’t have a car to get it done.” Brown said, “I’ll have to bring you a

bottle myself then. I’m a bring you a bottle myself then.” Robe said, “Okay, bring me a bottle and

then what? I don’t have a pocket book. I gotta get to the store to find a clear pocket book.” Brown

continued, “This is a god damn shame. Every time I need something done I gotta go through a

whole bunch of bull shit to get it done.” Based on my training and experience and other information

developed during this investigation, I believe that Brown was attempting to have Robe smuggle

controlled substances into the prison for him. Brown was expressing frustration that Robe was not

ready to smuggle the drugs in at that time, because it was easier to smuggle contraband into the

prison on the weekend. Robe was explaining that she needed a prescription pill bottle and a clear

purse to smuggle in the drugs. Based on my training and experience, and on conversations with

corrections officials, I believe that Robe was planning to use a prescription pill bottle and a clear

54
purse for the smuggling operation because other prison guards would be less likely to search her or

otherwise detect that she was smuggling the drugs into the prison for an inmate.

d. On March 9, 2009, at approximately 4:12 pm, Eric Brown received

an incoming call from (410) 499-8933, utilized by Terry Robe. During the conversation Brown

asked, “You gonna call me and tell me when you gonna get me them pills, cause I need them?”

Robe responded, “Okay, I’m going to work on that today.” Based on my training and experience

and other information developed during this investigation, I believe that Brown and Robe were again

discussing plans for Robe to smuggle a controlled substance into Brown at MTC.

56. I have learned that Terry Robe was recently fired from her position as a

corrections officer after she was caught attempting to smuggle a cellular phone into MTC for Eric

Brown.

57. The residence at 420 WOODLAKE COURT # C, GLEN BURNIE,

MARYLAND, identified herein as SUBJECT PREMISES #4, is the residence of Terry Robe.

BG&E records indicate that the account at SUBJECT PREMISES #4 is in the name of Terry Robe.

In addition, Maryland MVA records list SUBJECT PREMISES #4 as the residence of Terry Robe.

Based on information obtained by subpoena from the management company of the apartment

complex for SUBJECT PREMISES #4, I have learned that Terry Robe is the lessee of SUBJECT

PREMISES #4. As recently as April 2, 2009, law enforcement officers surveilled Robe exiting and

re-entering the apartment building of SUBJECT PREMISES #4.

58. SUBJECT PREMISES #4 is a three story brick apartment building with a glass

front door with the numbers 4 2 0 displayed on the building to the right of the door. Apartment C

has a grayish metal door with a silver knocker and the letter C is affixed to it.

55
 59. Based upon my training and experience and my participation in this and other

investigations, as well as my conversations with other agents, I know that certain items are

commonly maintained at the residences of gang members and individuals involved in drug-

trafficking, as set forth in Exhibit 1 and Exhibit 2, which are incorporated herein by reference.

60. Based upon the foregoing and on my training, experience, and participation in

narcotics and gang investigations, I respectfully submit that there is probable cause to believe that

there will be found in SUBJECT PREMISES #4 the items set forth in Attachment D, which

constitute evidence, fruits and/or instrumentalities of violations of, inter alia, 18 U.S.C. § 1962,

which prohibits participation in a racketeering conspiracy; 21 U.S.C. §§ 841 and 846, which

prohibits the distribution and possession with intent to distribute controlled substances, and

conspiracy to commit those offenses; 21 U.S.C. § 843, which prohibits the use of a communication

facility in furtherance of drug-trafficking; and 18 U.S.C. § 1959, which prohibits violent crimes in

aid of racketeering.

E. Musheerah Habeebullah/SUBJECT PREMISES #5

61. Based on evidence developed during this investigation, including calls

intercepted during wiretaps, I have learned that Musheerah Habeebullah is a corrections officer at

MCIJ who assists Eric Brown and BGF in the smuggling of contraband into correctional facilities.

Numerous calls were intercepted during this investigation in which Habeebullah discussed the

smuggling of contraband for BGF.

a. For instance, on March 8, 2009, at approximately 9:00 pm, Eric Brown

received an incoming call from (410) 530-7154, utilized by Musheerah Habeebullah. During the

conversation, Brown and Habeebullah talked at length about different inmates with whom the two

56
have had interaction. As the conversation continued, Habeebullah made reference to an individual

who is currently at “the Pen,” a reference to a Maryland prison facility. Habeebullah said, “He

probably not used to the Pen cause he know it so wide open. He ain’t really used to that kind of

environment and I think they said down there he was like on the top. Like he was the only one who

was doing stuff. But you know down there, there are so many people who doing shit [smuggling

and selling contraband], you know it’s impossible, it’s impossible to be the only one. It’s

impossible, it’s impossible.” Brown responded, “Right, right, everybody going to get their thing on

[make money by selling contraband].” Habeebullah continued, “Yeah, it’s, it’s too many people and

like down there, they said it’s like the girl Williams and the girl, I guess the dummies are messing

with, it, all they got is two of them. Or like one [corrections officer] on each shift that be really

making moves [smuggling contraband in for inmates]. (Unintelligible), now you got like seven,

eight people [corrections officers smuggling contraband for inmates]. Soon it’s the whole damn

shift.” Brown responded, “Right, right, right, right.” Habeebullah said, “Where is it possible for

you to take over. You know what I’m saying? You ain’t, you might make out and make a couple

dollars that you can get in. I was, I was telling him that before he went down there. I was like, you

can probably get it in [smuggle contraband] cause you know Frank used to get it in [smuggle

contraband] and he used to make, you know what I’m saying? I know a lot of people be getting it

in [smuggling contraband] but you ain’t gonna be on top [making as much money] like you was

down there, cause it’s too many horses [people participating in smuggling]. Too many ways.”

Brown explained, “Yeah, ain’t nobody going to be the only game in town.” Habeebullah continued,

“Not that, he was down there but not at this new spot. There’s a new sheriff in town. That’s

impossible. You see down there, you know the um, comrades [BGF members] wasn’t really

57
functioning like that, like they wasn’t really, you know what I’m saying.” Brown went on to say,

“They ain’t just gonna let a motherfucker take over. If you ain’t gonna, if you the only motherfucker

ain’t making moves [smuggling contraband] there’s going to be a problem.” Habeebullah continued,

“There’s a whole different caliber of dudes in there. You know what I’m saying.” Brown

responded, “Yeah, it ain’t gonna sit right with people.” Habeebullah went on to explain that she had

recently provided an inmate identified as “Baby” with a battery for the inmate’s phone and within

two weeks it was seized. Habeebullah stated, “It’s so tight down there like I said, well I ain’t gonna

be able to do no, a battery that’s small, I can, I can get that in. A charger, yeah, a phone I don’t trust

that.” Habeebullah went on to explain that “Baby” had asked for Brown’s number. She said that

maybe someone else gave him a phone since she knows that “Baby” would not call from the “blue

phone” [an apparent reference to the recorded prison phones]. As the conversation continued

Habeebullah discussed other corrections officials who are smuggling items into inmates and

identified four of the corrupt corrections officers by name. Based on my training and experience and

other information developed during this investigation, I believe that Habeebullah is smuggling

illegal items into correctional facilities for Brown and other inmates.

b. On March 11, 2009, at approximately 10:32 pm, Brown received an

incoming call from (410) 530-7154, utilized by Musheerah Habeebullah. During the conversation

Habeebullah, who at the time was utilizing a second telephone, left a message, “AB [an apparent

reference to corrections officer and co-defendant Asia Burruss], call me when you get this.”

Habeebullah then turned to speak with Brown and said, “She ain’t answering the phone.” Brown

responded, “Man, I know.” Habeebullah said, “You know she got inservice.” Habeebullah said,

“Let me see, cause I know she um, I got both of the numbers, let me see what the other one is. It’s

58
um, yeah, eight two five, nine oh seven three.” Brown asked, “Four, four three, right?”

Habeebullah answered, “Yeah. I know she said she had inservice so she, so she get off at seven, you

know three o’clock.” Brown asked, “She get off at three?” Habeebullah said, “Yeah, you know she

got inservice in the morning so she works from seven to three tomorrow.” Brown responded, “Oh

shit, well what about tonight?” Habeebullah went on to explain that this corrections officer

[Burruss] is probably sleeping, since she has to awaken early in the morning for her inservice

training. Based on my training and experience and other information developed during this

investigation, I believe that in this portion of the conversation Brown was utilizing corrections

officer Habeebullah to contact a second corrections officer, co-defendant Asia Burruss, for the

purpose of having illegal contraband smuggled into the prison facility for Brown.

62. The residence at 15 HIAWATHA COURT, OWINGS MILLS, MARYLAND,

identified herein as SUBJECT PREMISES #5, is the residence of Musheerah Habeebullah.

Although Maryland MVA records list 5430 Price Avenue, Baltimore, Maryland, as Habeebullah’s

address, law enforcement has learned that that address is the residence of Habeebullah’s sister.

During surveillance at 5430 Price Avenue, law enforcement officers used a ruse to speak with the

resident at that address, who was Habeebullah’s sister. Habeebullah’s sister indicated that

Habeebullah lived in Owings Mills and described the location, which law enforcement recognized

as SUBJECT PREMISES #5. Surveillance was then conducted at SUBJECT PREMISES #5 and

as recently as April 8, 2009, Habeebullah was surveilled exiting the residence in her corrections

officer uniform. She then entered a 1996 Oldsmobile which is registered to the Price Avenue

address. In addition, BG&E records indicate that the account at SUBJECT PREMISES #5 is in the

name of Musheerah Habeebullah, and a check of law enforcement databases also indicates that

59
SUBJECT PREMISES #5 is listed as Habeebullah’s residence.

63. SUBJECT PREMISES #5 is a two story row house with tan aluminum siding.

The residence has a light brown front door with the numbers 1 5 over top of the front door in black.

There is a black mail box to the left of the front door attached to the house.

64. Based upon my training and experience and my participation in this and other

investigations, as well as my conversations with other agents, I know that certain items are

commonly maintained at the residences of gang members and individuals involved in drug-

trafficking, as set forth in Exhibit 1 and Exhibit 2, which are incorporated herein by reference.

65. Based upon the foregoing and on my training, experience, and participation in

narcotics and gang investigations, I respectfully submit that there is probable cause to believe that

there will be found in SUBJECT PREMISES #5 the items set forth in Attachment E, which

constitute evidence, fruits and/or instrumentalities of violations of, inter alia, 18 U.S.C. § 1962,

which prohibits participation in a racketeering conspiracy; 21 U.S.C. §§ 841 and 846, which

prohibits the distribution and possession with intent to distribute controlled substances, and

conspiracy to commit those offenses; 21 U.S.C. § 843, which prohibits the use of a communication

facility in furtherance of drug-trafficking; and 18 U.S.C. § 1959, which prohibits violent crimes in

aid of racketeering.

VI. The Glasscho Drug Organization

66. Based on intercepted wiretap calls and information provided by confidential

sources, I have learned that BGF member Kevin Glasscho operates a drug-trafficking organization

that distributes multi-kilogram quantities of heroin in the Baltimore area and surrounding areas.

67. CS1 advised law enforcement that Kevin Glasscho is a major Baltimore drug

60
trafficker. CS1 further stated that Glasscho sold large amounts of heroin while Glasscho was

incarcerated in the Maryland Correctional System. CS1 specified that while in prison, Glasscho was

not interested in obtaining small amounts of heroin. Department of Corrections records corroborate

that Glasscho is listed as having special alerts in prison, specifically as being a part of a threat group,

the BGF.

68. Pursuant to the electronic surveillance conducted during this investigation,

numerous calls were intercepted in which Kevin Glasscho and other members of his organization

discussed and arranged narcotics transactions, including transactions in which drugs were smuggled

into prison facilities. The following are just a few examples of such calls. Other such calls are

summarized infra, in the sections relating to specific members of Glasscho’s organization.

a. On March 1, 2009, at approximately 1:28 pm, a call was intercepted

between Eric Brown and Kevin Glasscho. During that conversation, Glasscho told Brown, “Man

you got a main line number that you ain’t gotta never worry about losing me. You called me on it

before. The two five, five number.” Brown responded, “I got about four numbers on you.”

Glasscho advised, “Yeah, but man, a lot of times you got to understand, I got to do, I got to change

the numbers.” Brown said, “I know, I know.” Glasscho continued, “But you got a main line number

that you know what I mean, don’t nobody have in them joints, but except you, my brother, and, and

Joe. You know what I’m saying?” Brown responded, “Yeah.” Based on my training and

experience, I believe that during the conversation between Brown and Glasscho, the two were

discussing the fact that Glasscho has multiple telephone numbers and changes his telephone numbers

frequently, which is common among drug dealers.

b. On March 14, 2009, at approximately 8:47 am, Glasscho received

61
an incoming call from (213) 346-9480, subscribed to the LA County Sheriffs Department, Los

Angeles, California, and assigned to the Maryland Correctional Institution at Hagerstown. Upon

receiving the telephone call the caller identified himself as Joe Taylor-Bey. During the conversation

Glasscho and Taylor-Bey discuss the smuggling of drugs, provided by Glasscho, into the

Hagerstown prison facility. Glasscho said, “Let me say this Joe, let me say this. Man, I mean, I

mean, cause I’m getting, I’m getting the impression that uh, that uh, you uh, you avoiding you know,

the part time work.” Taylor-Bey said, “I don’t understand what you mean.” Glasscho continued,

“I mean the person (unintelligible) as far as her acknowledgement of that.” Taylor-Bey responded,

“Oh, oh check this out. I thought that, I though I been told you that. She don’t want no parts of that

and she don’t have to have, you know she don’t have to be involved in that, right. And like I say

see, it’s a situation where…The last time we talked about it all she asked me was, Joe just be careful.

I said I’m gonna be careful with it. You know what I mean? Yo, that’s just so, I respected the fact

that she don’t want no parts of it. You see what I’m saying. So it, so it’s a situation where I

definitely didn’t, didn’t want her to know that her truck was involved.” Glasscho responded, “Oh,

okay, okay, yeah, yeah, yeah, yeah, yeah, yeah.” Taylor-Bey continued, “You see what I’m

saying…Yeah I don’t keep it all the way away from her but I definitely do not want her to know that

that truck was involved.” Glasscho stated he understood what Taylor-Bey meant by wanting to keep

things away from his female companion. Taylor-Bey explained that his female companion knows

what he does and advised, “Because you know god damn well I don’t work for Sparrows Point. You

know what I mean? We just don’t talk about it.” Glasscho advised that he understands what Taylor-

Bey means. Based on my training and experience and other information developed during this

investigation, I believe that Glasscho is responsible for supplying drugs which are being smuggled

62
into the Hagerstown prison for Taylor-Bey and others. Glasscho was reassuring himself that Taylor-

Bey was still going to actively be involved in the smuggling process as well as the distribution inside

of the prison facility. In turn, Taylor-Bey advised that was his job when stating, “Because you know

god damn well I don’t work for Sparrows Point.”

c. On March 15, 2009, at approximately 8:52 am, Glasscho received an

incoming call from (213) 346-9480, subscribed to the LA County Sheriffs Department, Los Angeles,

California, and assigned to the Maryland Correctional Institution at Hagerstown and utilized during

this call by Joe Taylor-Bey. During the conversation Glasscho asked, “What color was the joint?”

Taylor-Bey answered, “It was more a beige, like beige.” Glasscho responded, “The sock man, the

sock.” Taylor-Bey answered, “Oh, oh, oh, oh, oh uh purple or blue all the way down.” Glasscho

responded, “Alright, alright, alright I thought he might have changed the joint when I gave it to

him.” TAYOR-BEY said, “No, no, uh, uh, nah, nah. I know what it was see, that needs to be sifted.

That’s the only way, it’s got to be.” Glasscho said, “Nah, but you know what happened. What

happened was this. I uh, I uh, I always get it to that point, right. So I won’t have to do it. You see

what I’m saying? Always get it to that point. So, so it shouldn’t have been, maybe because it was

been wrapped tight for the last two or three weeks, I don’t know.” Taylor-Bey said, “Yeah see, nah

see, I’m going to teach you something else about light dope and heavy dope. Yeah that’s what that

was, it was heavy. Because you know how many I got out, out of three?” Glasscho asked, “How

many? Outta what?” Taylor-Bey answered, “Thirty eight out of three. Cause you know I do

weight. I be selling weight.” The conversation continued at length regarding the smuggling and

distribution of heroin involving Glasscho and Taylor-Bey inside of the Hagerstown correctional

facility. Based on my training and experience and other information developed during this

63
investigation, I believe that Glasscho has an ongoing heroin smuggling operation involving Taylor-

Bey and other inmates incarcerated in Hagerstown, Maryland.

d. On March 15, 2009, at approximately 4:28 pm, Glasscho made an

outgoing call to (443) 564-7238, with an unknown subscriber and utilized by Frankie LNU, a/k/a

“Nitty.” During the conversation Glasscho asked, “Where you at?” Nitty answered, “On my way

over the way.” Glasscho responded, “Oh yeah you get ready to go back on the block huh?” Nitty

answered, “Got to stay out there baby. You know what I’m saying?” Glasscho advised, “Hey yo,

guess who I’m hitting off [selling drugs to] now?” Nitty asked, “Who?” Glasscho answered, “Uh,

uh Kim’s, Kim’s husband.” Nitty again asked, “Who?” Glasscho answered, “Kim husband.” Nitty

asked, “Kim who?” Nitty eventually realized to whom Glasscho was referring. Glasscho later

explained that an individual known by the two of them may be cooperating with the police and that

Nitty should avoid him. Based on my training and experience and other information developed

during this investigation, I believe that Glasscho was openly advising that he is selling drugs. Nitty

also openly admitted that he is selling drugs on the streets of Baltimore.

e. On March 16, 2009, at approximately 8:07 pm, Glasscho placed an

outgoing call to (443) 956-7893, with an unknown subscriber and utilized by an unidentified male.

During the conversation the unidentified male asked, “Hey, uh on that T-shirt man what, you know

uh, you got the Obama’s or you got the…?” Glasscho answered, “Man they, they correct, they just

ninety cent that’s all, you know. They correct.” The unidentified male asked, “Where you want me

to meet you at? You wanna come by the house?” Towards the end of the conversation Glasscho

and the unidentified male agreed to meet at the unidentified male’s home. At approximately 8:32

pm, Glasscho placed an outgoing call to (443) 956-7893, utilized by the unidentified male who had

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inquired about the T-shirts. During the call Glasscho advised that he was outside of the male’s

home. The unidentified then male invited Glasscho to come into his home. Glasscho responded,

“I thought you wanted to come out of the house and look at this?” The unidentified male responded,

“Oh yeah, yeah, yeah, yeah. I got to check the tire out, ok.” Based on my training and experience

and other information developed during this investigation, I believe that Glasscho was advising the

unidentified male that he is selling heroin for $90 per gram, based on the reference to ninety cent

T-shirts. During the follow up call Glasscho had traveled to the male’s home with a sample of the

heroin so the unidentified male could look at its quality.

f. On March 16, 2009, at approximately 8:43 pm, Glasscho received an

incoming call from Avon Freeman. During this conversation Freeman said, “I’m still sitting here

waiting for this dude man.” Glasscho responded, “Yeah.” Freeman continued, “Yeah man that’s

only my little hold up. I mean I got like seven dollars up, of my money, but you know what I’m

saying? It cleaned me out, it cleared me out. I’m just was waiting on him. You know what I’m

saying?” Glasscho responded, “Yeah.” Freeman continued, “Shit, but um, I’m a try, like I said, I’m,

I’m just gonna give him…Man he down Annapolis now so I’m just giving him a hour. I fucks with

him real heavy so…Just waiting on him though.” Based on my training and experience and other

information developed during this investigation, including other intercepted calls, I believe that

Freeman has $7,000 in his possession which is wants to put towards the purchase of a quantity of

drugs from Glasscho. Before the deal can transpire Freeman is waiting on one of his drug partners

to arrive from Annapolis with the rest of the money needed for the drug purchase from Glasscho.

g. On March 17, 2009, at approximately 4:54 pm, Glasscho placed an

outgoing call to (443) 865-3517, utilized by Avon Freeman. During the conversation Freeman and

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Glasscho arranged to meet at a UPS store in the vicinity of Benson Avenue and Sharonleigh Avenue.

Investigators were conducting surveillance of Glasscho and the area of Benson Avenue in Baltimore,

Maryland. During the surveillance, investigators observed Glasscho leave his residence with a

female companion. Glasscho was then followed to the area of Benson Avenue near Sharonleigh

Avenue. Prior to Glasscho’s arrival investigators observed a 1993 GMC Safari van bearing

Maryland registration 20W 543, driven by Freeman and parked near the intersection. Within a few

minutes, investigators observed Glasscho arrive and park behind the GMC van. Glasscho and

Freeman were observed to exit their vehicles, have a brief conversation and then conduct a hand to

hand exchange. Both individuals then entered their vehicles and drove away in opposite directions.

Based on my training and experience and other information developed during this investigation, I

believe that during these calls and subsequent meeting/exchange Glasscho delivered drugs to

Freeman.

h. On March 24, 2009, at approximately 4:40 pm, Glasscho placed an

outgoing call to (443) 802-5783, utilized by Darien Scipio. During the conversation Glasscho told

Scipio, “Yeah you gotta come down to the Belvedere Hotel homey.” Scipio responded, “Alright,

I’m gonna call you when I’m close.” At approximately 5:11 pm, Scipio called Glasscho and said,

“I’m outside.” Based on my training and experience and other information developed during this

investigation, I believe that Glasscho and Scipio were meeting in person to discuss a drug

transaction. However, at approximately 5:11 pm, Glasscho received an incoming call from Scipio.

When Glasscho answered the call Scipio asked, “You tell somebody to meet me?” Glasscho

answered, “Nah! Why you say that?” Scipio went on to explain, “Some dude just hit my phone,

talking about did I meet somebody at the Belvedere. Boy let me holler at you one second. Didn’t

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you just meet somebody at the Belvedere? You feel me?” Glasscho responded, “Ahh!” Scipio then

spoke with two individuals in the background. Scipio then returned to the conversation and said,

“KG, get the fuck away from there. They, they just told me the peoples [a reference to law

enforcement] is on you. You hear what I said?” Glasscho responded, “Alright.” Scipio continued,

“My man just hit me, it’s on the scanner [police scanner].” Glasscho responded, in an upset manner,

“Alright, alright, alright.” Based on my training and experience and other information developed

during this investigation, I believe that agents conducting surveillance of the Glasscho and Scipio

meeting were compromised during their radio transmissions. Shortly thereafter, Glasscho ceased

using TARGET CELLPHONE #5 and proceeded to a cellphone store to obtain a replacement phone.

However, law enforcement quickly learned the number of, and obtained wiretap authorization for,

that replacement phone.

i. On March 25, 2009, at approximately 8:00 am, Glasscho received an

incoming call from (443) 798-0359, utilized by Evertt Glasscho, Kevin Glasscho’s father. During

the conversation, Everett Glasscho informed Kevin Glasscho that he had received mail from two

inmates, James Henderson, a/k/a “Hindu,” and Kevin Dooley, a/k/a “Little Kebo.” Glasscho

explained that “Little Kebo” was his man and that “he killed, he the one that killed Aaron, Little

Aaron.” Based on my training and experience and other information developed during this

investigation, I believe that Glasscho’s father is acting as a conduit for mail being sent to and

received from incarcerated BGF members. The name Kevin Dooley, a/k/a “Little Kebo,” is believed

to be a reference to Kevin Dudley, a high-ranking BGF member in Maryland state prison.

j. On April 2, 2009, at approximately 1:19 pm, Glasscho received an

incoming call from (443) 831-7376, subscribed to Prepaid, 1 Main Street, Schenectady, New York,

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and utilized by an unidentified inmate. During the conversation the unidentified inmate said, “Man

I don’t know what the fuck wrong with the mail system. You know, cause uh, she definitely took

care of it yo.” Glasscho responded, “Okay, okay. I’m just letting you know I didn’t get it that’s all.”

The unidentified inmate responded, “Yeah, yeah cause uh, that shit killed me right. Cause uh, I,

cause I’m saying that I know that she took care of it.” Glasscho continued, “Yeah, well I’m just

saying that I didn’t get it, that’s all. You know well that’s where she say she mailed it there. I

should have got it.” The unidentified male continued, “Yeah here the address, yeah no doubt and

um, I sent it to four thousand one Duvall, four thousand one, well no I got it written down right here,

four thousand one Duvall, Baltimore, Maryland two one two one six.” Glasscho did not hear what

the unidentified inmate said so he repeated the address of 4001 Duvall Avenue. Glasscho advised,

“I guess, I guess ain’t get it, that’s all.” The unidentified male advised that a female associate of his

had just left from seeing the inmate. The unidentified inmate advised, “I told her as soon as she get

down there to send you uh, the money for the girl, right. So, all the girl need is a hundred dollars.”

Glasscho asked, “A hundred dollars?” The unidentified inmate continued, “Yeah um and uh, just

wrap the things up right and um, I’m a get, I’m a get this in Green Dot so you can uh, you can put

it straight on your card.” Glasscho responded, “Yeah, but I’m saying, you don’t want me to separate

it or nothing right?” The unidentified male responded, “Nah, nah, nah, nah, nah. Glasscho asked,

“Keep it all just…” The unidentified inmate advised, “Yeah, just keep it the same way. Um this,

this coming in through a horse [drug courier]. Um, the PoPo, right [an apparent reference to a

corrections officer who is participating in the smuggling of the drugs].” Glasscho asked, “What

about the tobacco and all that shit?” The unidentified male explained that he has a separate person

handling the other items. Glasscho and the unidentified male went on to discuss the delivery of the

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“things.” The unidentified male went on to explain that his wife would get the Green Dot card, then

Glasscho could access the card, and remove the money needed to pay for the “horse.” Glasscho

explained that he would transfer the money to his card and then deliver the money and the drugs to

the unidentified person responsible for bringing the drugs to the correctional institution. The

unidentified inmate told Glasscho to tell the female the items were for “T-Rock” from “Little

Kevin.” The unidentified inmate said that “T-Rock” is the “horse” and that the girl Glasscho was

to meet is named Danielle. Based on my training and experience and other information developed

during this investigation, I believe that Glasscho is supplying the unidentified male with drugs,

which are being smuggled into an unidentified prison. Once in the prison, the unidentified inmate

then sells the drugs and then pays off his debt for the drugs to Glasscho by sending the money

through correspondence that is delivered to Kevin Glasscho at 4001 Duvall Avenue, Baltimore,

Maryland, the residence of Kevin Glasscho’s father, Everett Glasscho. This correspondence is

believed to contain Green Dot account numbers and other forms of monetary instruments used for

the payment of drugs supplied by Glasscho.

69. Pursuant to the electronic surveillance conducted during this investigation, calls

were intercepted in which Kevin Glasscho and other members of his organization discussed an

exchange of a firearm for drugs.

a. On April 1, 2009, at approximately 4:39 pm, Glasscho placed an outgoing

call to (410) 710-5827, utilized by James Huntley. During the conversation Huntley advised, “Hey

I got that set up for us for today. What’s up?” Glasscho responded, “Oh yeah?” Huntley advised,

“Yeah what you wanted.” Glasscho asked, “What time?” Huntley answered, “When you ready.”

Glasscho asked, “Oh okay, that’s the one we gotta go ride at?” Huntley responded, “I’ll go do, I’ll

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do the riding and everything. You just meet me at the spot.” Glasscho responded, “Right there!

Uh, that might not be a good spot there.” Huntley responded, “Alright pick, pick another spot.”

Glasscho responded, “Uh, you know which one, the one that we always go at uh, play the lotteries

at.” Huntley responded, “Alright we, on that lot around the corner.” Glasscho responded, “Yeah,

yeah. Yeah cause that spot there ah, we wearing that out. I mean we good far as with that, what we

doing eating pizza. But hey.” Huntley then agreed to the alternate meeting location. Huntley asked,

“How much I tell you?” Glasscho answered, “You told me two fifty. Why what’s up?” Huntley

advised, “Cause shorty he, he talking more.” Huntley then spoke with an unidentified person.

Huntley then told Glasscho, “Alright well do this, do this. I’ll, I’ll handle it. Uh, on the thing me

and you do, alright give me four of them and I, and I, I’ll handle shorty.” Glasscho asked, “Four of

them? Alright that’s what’s up.” Huntley advised he would call when he was on his way. At

approximately 5:20 pm, Glasscho received an incoming call from (410) 710-5827, utilized by

Huntley. Huntley advised, “Yo, I’m on my way. I’ll be there in ten minutes yo.” Glasscho advised,

“Pull out, pull out in about uh, what you say seven.” Huntley responded, “In ten minutes.”

Glasscho said, “Alright pull out in ten minutes.” Huntley responded, “I’m already in, on the move.

Uh we, we got that and you know we already filthy.” Glasscho responded, “Yeah that’s why I said

pull out in ten minutes.” Huntley responded, “Alright, well we can’t stop we’re just going.”

Glasscho responded, “Alright, alright, alright.”

b. Later that evening, Glasscho placed an outgoing call to Huntley. During

the conversation Glasscho advised, “Man uh, you can keep what I gave you man but I don’t want

this. That motherfucker too rusty for me. Yeah, I don’t like it. I mean you can keep what I got if

you find another victim, that probably want that, you know just give me three dollars and get this

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one here back.” Huntley asked, “You sure now, that’s a good one yo, I’m telling you.” Glasscho

responded, “Nah, I don’t like it. I don’t like it. I don’t want it.” Huntley asked, “You want

something new out of the box?” Glasscho answered, “Yeah I prefer, you know what I mean? That’s

close to new. That motherfucker there boy look like one of them dirty joints we used to buy a lot.

You know, but I’m saying you can keep what you got. You find, find somebody else, just give me

three dollars.” Huntley advised, “Alright just hold it. I’ll get, I’ll get somebody uh, uh, uh that want

one and uh, bop, bop, bop we’ll do it that way.” Glasscho responded, “Right, right, right.” Based

on my training and experience and other information developed during this investigation, I believe

that Glasscho was arranging to sell Huntley four grams of heroin in exchange for a handgun. I

further believe that Glasscho was dissatisfied with the handgun Huntley had given him in exchange

for the four grams of heroin, because it was too old (“That motherfucker too rusty for me.”).

Glasscho said that he wanted a handgun that was nearly new, not an older type of handgun like those

he used to purchase in years past. Glasscho instructed Huntley to keep the heroin and return “three

dollars,” a reference to $300, for the heroin provided by Glasscho. The dollar amount coincides with

the price of approximately $80 per gram that Glasscho is charging for the heroin.

VII. Search Warrants for SUBJECT PREMISES#6-12

A. Kevin Glasscho/SUBJECT PREMISES #6

70. The residence at 4001 DUVALL AVENUE, FLOOR 2, BALTIMORE,

MARYLAND, identified herein as SUBJECT PREMISES #6, is the residence of Kevin Glasscho’s

father, Everett Glasscho, and a residence used by Kevin Glasscho. According to records maintained

by B&E, the listed subscriber for SUBJECT PREMISES #6 is Mary Glasscho, the mother of Kevin

Glasscho. Maryland MVA records indicate that Kevin Glasscho has a 2005 Acura listed to the

71
address of SUBJECT PREMISES #6. In addition, as indicated above, intercepted calls have

established that Glasscho receives mail from drug customers and fellow BGF members at SUBJECT

PREMISES #6.

71. SUBJECT PREMISES #6 is a two story white single family home with a light

brown wooden door and a glass storm door with the numbers 4 0 0 1 displayed in black on the

dwelling to the left of the front door.

72. Based upon my training and experience and my participation in this and other

investigations, as well as my conversations with other agents, I know that certain items are

commonly maintained at the residences of gang members and individuals involved in drug-

trafficking, as set forth in Exhibit 1 and Exhibit 2, which are incorporated herein by reference.

73. Based upon the foregoing and on my training, experience, and participation in

narcotics and gang investigations, I respectfully submit that there is probable cause to believe that

there will be found in SUBJECT PREMISES #6 the items set forth in Attachment F, which

constitute evidence, fruits and/or instrumentalities of violations of, inter alia, 18 U.S.C. § 1962,

which prohibits participation in a racketeering conspiracy; 21 U.S.C. §§ 841 and 846, which

prohibits the distribution and possession with intent to distribute controlled substances, and

conspiracy to commit those offenses; 21 U.S.C. § 843, which prohibits the use of a communication

facility in furtherance of drug-trafficking; and 18 U.S.C. § 1959, which prohibits violent crimes in

aid of racketeering.

B. Kevin Glasscho/Cassandra Adams/SUBJECT PREMISES #7

74. Pursuant to the electronic surveillance conducted during this investigation,

multiple calls were intercepted in which Kevin Glasscho’s wife, Cassandra Adams, was discussed

72
in connection with, or was intercepted discussing, Glasscho’s drug-trafficking operation and drug-

related financial transactions.

a. For instance, on March 1, 2009, at approximately 1:39 pm, Eric Brown

placed an outgoing call to Glasscho. During this conversation, Glasscho mentioned that he had “the

misses” [an apparent reference to Cassandra Adams] “riding with me yesterday hitting

motherfuckers [distributing drugs to customers].” The two of them then laughed about Glasscho’s

last statement. Glasscho said, “She don’t be hanging out with me too tough, I’m going. You know

she bring the thing up in them joints too [smuggling drugs to inmates in prisons].” Brown

responded, “Yeah.” Glasscho said, “Yeah, I just have her doing that too [smuggling drugs to

inmates in prisons]. When they took me off the list [prison visitor list] I was sending her off to

Cumberland [a Maryland prison], old jail [another Maryland prison], Roxbury [another Maryland

prison], you know. Man shorty [an apparent reference to Adams] a trooper, shorty a trooper.”

b. On March 18, 2009, at approximately 11:14 pm, Glasscho received

an incoming call from Cassandra Adams. During the brief conversation Glasscho told Adams, “I’m

making this last stop. So hurry up and get your ass home. You got some counting to do nigger.”

Adams responded, “Alright then.” Based on my training and experience and other information

developed during this investigation, I believe that Glasscho wanted his wife to go home so she could

help him count the drug proceeds from the night’s transactions.

c. On March 21, 2009, at approximately 4:11 pm, Glasscho placed an

outgoing call to Cassandra Adams. During the conversation Glasscho advised, “I got to put you

down with something that me and Car Wash was talking about too. So it’s, it’s, it’s extremely good

that you did what you did. That’s what I was telling him, let my wife do it. She said man good.

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You can’t, you can’t go over nine [an apparent reference to $9,000].” Cassandra responded, “Yeah,

yeah, yeah, yeah. Over ten [an apparent reference to $10,000].” Glasscho continued, “Well they

say ten [an apparent reference to $10,000] but to be on the safe side, nine [an apparent reference to

$9,000]. Then I told him what you bringing home, that fifty. He said oh yeah she can account for

hers.” As the conversation continued Cassandra said, “This is what I’m gonna do. Only gotta put

one more in, in one of them to make it nine [an apparent reference to $9,000], right.” The two then

continued discussing how much money can be placed into a bank account before the authorities start

to investigate where the money is coming from. Based on my training and experience and other

information developed during this investigation, I believe that Adams and Glasscho are structuring

deposits of drug money into bank accounts to avoid detection by law enforcement.

75. The residence at 1909 FOREST PARK AVENUE, APT. S3, GYNN OAK,

MARYLAND, identified herein as SUBJECT PREMISES #7, is a residence of Kevin Glasscho and

Cassandra Adams. BG&E records indicate that the account for SUBJECT PREMISES #7 is listed

to Cassandra Adams, the wife of Kevin Glasscho. Maryland MVA records list the address of

SUBJECT PREMISES #7 as the residence of Cassandra Adams. On numerous occasions, law

enforcement officers have surveilled both Glasscho’s and Adams’s vehicles parked in the parking

lot of the apartment building for SUBJECT PREMISES #7. Law enforcement officers have also

surveilled Glasscho and Adams exiting that apartment building on multiple occasions. In addition,

as more fully described below, law enforcement officers intercepted calls in which Dow and

Glasscho agreed to meet at Glasscho’s house, and law enforcement thereafter surveilled Dow

arriving at SUBJECT PREMISES #7 carrying a bag containing what is believed to be multiple

kilograms of heroin.

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 76. SUBJECT PREMISES #7 is a two story apartment building with a glass front

door with the numbers 1 9 0 9 in white. Apartment S3 is a light blue door and S 3 appears in white

above the eye hole in the center of the door.

77. Based upon my training and experience and my participation in this and other

investigations, as well as my conversations with other agents, I know that certain items are

commonly maintained at the residences of gang members and individuals involved in drug-

trafficking, as set forth in Exhibit 1 and Exhibit 2, which are incorporated herein by reference.

78. Based upon the foregoing and on my training, experience, and participation in

narcotics and gang investigations, I respectfully submit that there is probable cause to believe that

there will be found in SUBJECT PREMISES #7 the items set forth in Attachment G, which

constitute evidence, fruits and/or instrumentalities of violations of, inter alia, 18 U.S.C. § 1962,

which prohibits participation in a racketeering conspiracy; 21 U.S.C. §§ 841 and 846, which

prohibits the distribution and possession with intent to distribute controlled substances, and

conspiracy to commit those offenses; 21 U.S.C. § 843, which prohibits the use of a communication

facility in furtherance of drug-trafficking; and 18 U.S.C. § 1959, which prohibits violent crimes in

aid of racketeering.

C. Calvin Robinson/SUBJECT PREMISES #8

79. Based on evidence developed during this investigation, including calls

intercepted during wiretaps, I have learned that Calvin Robinson is a wholesale customer of Kevin

Glasscho’s who distributes large quantities of heroin to customers in the Baltimore area. Numerous

calls were intercepted during this investigation in which Robinson and Glasscho discussed and

arranged narcotics transactions.

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 a. For instance, on March 18, 2009, at approximately 10:50 pm,

Glasscho received an incoming call from (443) 271-4779, utilized by Calvin Robinson. During the

conversation Robinson asked, “You still out and about?” Glasscho advised, “Yeah, yeah, yeah I’m

floating around.” Robinson responded, “Alright you wanna um scoot past, I got most of that. You

know what I mean? But you got to try to get that to me as early, as soon as you can.” Glasscho

responded, “Alright, alright, alright…I’m, I’m a bring that too.” Robinson asked, “Okay, everything

is still dry like it was?” Glasscho answered, “It’s the same, it’s the same thing.” Based on my

training and experience and other information developed during this investigation, I believe that

Robinson is bringing drug proceeds he owed to Glasscho from a previous drug transaction. When

Glasscho said, “I’m a bring that too,” he was advising that he would be providing an additional

quantity of drugs on consignment to Robinson when they meet. When Robinson asked if it was “dry

like it was,” he was inquiring about the quality of the drugs, and Glasscho replied that it was “the

same thing,” a reference to the same quality as the prior shipment.

b. On March 20, 2009, at approximately 6:59 am, Glasscho placed

an outgoing call to (443) 271-4779, utilized by Calvin Robinson. During the conversation Glasscho

asked, “You wanted a whole dollar or the half?” Robinson answered, “Uh, it don’t matter. You can

bring me the um, bring it to me in two half’s.” Glasscho went on to explain that it would less work

for him if he gave Robinson the “whole dollar.” Robinson ultimately agreed and the two planned

to meet after Robinson finished taking a shower. Based on my training and experience and other

information developed during this investigation, I believe that Glasscho was planning on selling a

large quantity of drugs to Robinson and was not going to break the drugs down into two separate

packages.

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vehicles and then entering SUBJECT PREMISES #8.

81. SUBJECT PREMISES #8 is a three story form stone residence. It has a black

storm door and black front door. The numbers 1 1 0 2 are in brass on the front door.

82. Based upon my training and experience and my participation in this and other

investigations, as well as my conversations with other agents, I know that certain items are

commonly maintained at the residences of individuals involved in drug-trafficking, as set forth in

Exhibit 2, which is incorporated herein by reference.

83. Based upon the foregoing and on my training, experience, and participation in

narcotics investigations, I respectfully submit that there is probable cause to believe that there will

be found in SUBJECT PREMISES #8 the items set forth in Attachment H, which constitute

evidence, fruits and/or instrumentalities of violations of, inter alia, 21 U.S.C. §§ 841 and 846, which

prohibits the distribution and possession with intent to distribute controlled substances, and

conspiracy to commit those offenses; and 21 U.S.C. § 843, which prohibits the use of a

communication facility in furtherance of drug-trafficking.

D. Darnell Holmes, a/k/a “Moe”/SUBJECT PREMISES #9

84. Based on evidence developed during this investigation, including calls

intercepted during wiretaps, I have learned that Darnell Holmes, a/k/a “Moe,” helps operate a stash

house at SUBJECT PREMISES #9 for Glasscho and delivers drugs to Glasscho for distribution to

customers and that Holmes also sells drugs to his own customers. Numerous calls were intercepted

during this investigation in which Holmes and Glasscho discussed the status of and arranged for

deliveries of narcotics.

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something, if you might can get a hold of something right. Yeah I mean, yeah I might need to talk

to you about something you know.” Glasscho advised, “Yeah I’m, I’m on my way out Security if

you want to come out in the mall and holler at me.” The two then agreed to meet in person at

Mondawmin Mall instead of Security Mall. Based on my training and experience and other

information developed during this investigation, I believe that Holmes wanted to meet with Glasscho

to discuss obtaining a quantity of drugs from Glasscho.

d. On March 16, 2009, at approximately 4:10 pm, Glasscho placed an

outgoing call to Holmes. During the call Glasscho asked, “You doing anything?” Holmes

answered, “Nope, but one, one of them, one of them, yeah I did one.” Glasscho responded, “Okay,

so you basically still got three whole, three whole fifty cents right?” Holmes answered, “Yeah just

about.” Glasscho asked, “So you got two of them still together.” Holmes answered, “Yeah.”

Glasscho advised, “Alright call me when you get in the house.” Based on my training and

experience and other information developed during this investigation, I believe that this call related

to Glasscho’s early morning conversation with Holmes on March 14, 2009. During the March 14,

2009, conversation Glasscho arranged to meet with Holmes. A short time after that call Glasscho

called and said, “Let me know what that book sound like when you do touch it” which is believed

to be a reference to the quality of the drugs Glasscho delivered to Holmes. This conversation on

March 16, 2009, was a follow up, with Glasscho asking Holmes, “You doing anything?” Based on

information developed during this investigation, including other intercepted calls, I believe that

Holmes is in the process of selling the drugs that Glasscho had provided to him on March 14, 2009.

e. March 17, 2009, at approximately 4:32 pm, Glasscho placed an

outgoing call to Holmes. During the conversation Glasscho asked, “You do anything last night?”

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Holmes answered, “Um, I did two, three, yeah three of them I think. Two or three.” Glasscho

asked, All together?” Holmes responded, “Yeah. I got, I gotta go holler at somebody about one of

them. But yeah everything straight though.” Glasscho responded, “Yeah, alright I’ll give you a

call.” Based on my training and experience and other information developed during this

investigation, including other intercepted calls, I believe that Glasscho was inquiring whether

Holmes had had any drug sales the previous night. Holmes replied that he had made two or three

drug sales.

f. On March 17, 2009, at approximately 8:28 pm, Glasscho placed an

outgoing call to Holmes. During the conversation Glasscho asked when Holmes was leaving for

work in the morning. Holmes advised he would leave around nine o’clock. Glasscho said, “I’ll give

you a holler if I need you, you hear.” Holmes responded, “Alright.” Glasscho later asked, “You do

anything today?” Holmes answered, “I got three out, three, three of them. You want that?”

Glasscho answered, “Nah, nah I get it to you, I get it from you tomorrow or something.” Based on

my training and experience and other information developed during this investigation, including

other intercepted calls, I believe that Holmes is helping Glasscho distribute drugs as well as

providing his residence as a storage location for the drugs.

g. On March 18, 2009, at approximately 7:23 am, Glasscho placed an

outgoing call to Holmes. During the conversation Glasscho explained he was at the Acura dealer

located at 6559 Baltimore National Pike and wanted Holmes to bring him “two ten cents.” Holmes

agreed to meet Glasscho at the dealership and bring him the “two ten cents.” Based on my training

and experience and other information developed during this investigation, including other

intercepted calls, I believe that Holmes was delivering a quantity of drugs to Glasscho so he could

81
in turn deliver the items to a drug customer.

h. On March 18, 2009, at approximately 8:39 pm, Glasscho placed an

outgoing call to Holmes. Glasscho told Holmes, “I might be calling you in about an hour. I might

need it, need, need uh fifty cent.” Holmes responded, “Alright.” Glasscho asked, “You do anything

today?” Holmes answered, “No I ain’t do nothing.” Based on my training and experience and other

information developed during this investigation, including other intercepted calls, I believe that

Glasscho was advising Holmes that in approximately one hour he may need to meet Holmes and

pick up a quantity of drugs. Additionally, during the call Glasscho had inquired whether Holmes

had made any drug sales during the day.

i. On March 18, 2009, at approximately 10:52 pm, Glasscho placed an

outgoing call to Holmes. Glasscho called and said, “I need that other one too.” Holmes asked,

“Now?” Glasscho responded, “Yeah, yeah I’ll call you when I’m on my way. But uh, put that on

the uh, what’s a name, make sure that’s a fifty cent.” Holmes responded, “Alright.” Based on my

training and experience and other information developed during this investigation, including other

intercepted calls, I believe that Glasscho was advising Holmes that he needed Holmes to weigh out

a quantity of drugs because Glasscho needed to come pick up the drugs for a sale.

j. On March 18, 2009, at approximately 11:09 pm, Glasscho called

Holmes and advised, “I’m coming to you now, Moe. I’m trying to get all this shit out of the way

man. I’m trying to get all this shit out of the way so I can get my ass in the house.” Based on my

training and experience and other information developed during this investigation, including other

intercepted calls, I believe that Glasscho was advising Holmes that he was finishing one drug

transaction and was going to be on his way to pick up the other quantity of drugs from Holmes.

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 k. On March 20, 2009, at approximately 12:59 pm, Glasscho placed an

outgoing call to Holmes. During the conversation Glasscho asked, “You say that’s a seven huh?”

Holmes answered, “Yeah, I give this a seven and a half but boy it went up some a little. Yeah I give

it like about seven, eight, something like that. It’s straight though.” Glasscho asked, “So it’s, it’s

a keeper then, huh?” Holmes answered, “Oh yeah, definitely it’s a keeper.” Based on my training

and experience and other information developed during this investigation, including other

intercepted calls, I believe that Holmes had tested the quality of the new shipment of drugs obtained

by Glasscho and was reporting to Glasscho that the drugs were of high quality (“I give it like about

seven, eight ... definitely it’s a keeper”).

85. The residence at 3908 NORFOLK AVENUE, BALTIMORE, MARYLAND,

identified herein as SUBJECT PREMISES #9, is the residence of Darnell Holmes. Based on a

review of records maintained by the Maryland Department of Assessments and Taxation and BG&E,

I have learned that SUBJECT PREMISES #9 is listed to Edith M. Holmes. Maryland MVA records

list SUBJECT PREMISES #9 as the residence of Darnell Holmes. As recently as April 1, 2009, law

enforcement officers surveilled Holmes come out of SUBJECT PREMISES #9 and get into Kevin

Glasscho’s vehicle. Surveillance ultimately observed Holmes exit Glasscho’s vehicle and re-enter

SUBJECT PREMISES #9.

86. SUBJECT PREMISES #9 is a two story brick home (duplex). There is white

trim on the front and tan siding on the upper level of the home. The home has a white storm door

and a wood door behind that. The numbers 3 9 0 8 are above the front door.

87. Based upon my training and experience and my participation in this and other

investigations, as well as my conversations with other agents, I know that certain items are

83
commonly maintained at the residences of individuals involved in drug-trafficking, as set forth in

Exhibit 2, which is incorporated herein by reference.

88. Based upon the foregoing and on my training, experience, and participation in

narcotics investigations, I respectfully submit that there is probable cause to believe that there will

be found in SUBJECT PREMISES #9 the items set forth in Attachment I, which constitute evidence,

fruits and/or instrumentalities of violations of, inter alia, 21 U.S.C. §§ 841 and 846, which prohibits

the distribution and possession with intent to distribute controlled substances, and conspiracy to

commit those offenses; and 21 U.S.C. § 843, which prohibits the use of a communication facility

in furtherance of drug-trafficking.

E. Lakia Hatchett/SUBJECT PREMISES #10

89. Based on evidence developed during this investigation, including calls

intercepted during wiretaps, I have learned that Lakia Hatchett obtains drugs from Glasscho on

behalf of one of her associates and acts as a go-between for messages between Glasscho and one of

his customers.

a. For instance, on March 19, 2009, at approximately 5:07 pm, Glasscho

received an incoming call from (410) 807-6792, subscribed to Roger Harris, Catonsville, Maryland

and utilized by an unidentified male. During the conversation Glasscho asked, “Man where you

been at?” The unidentified male responded, “Man, man long story man. Motherfucking, minor little

set-backs man.” Glasscho advised, “Comes with this game boy.” Glasscho went on to explain that

he had been calling the male and his female companion but was not able to reach the unidentified

male. Glasscho explained that he was just going to move on. The unidentified male asked, “What

time you think you could hook up with her?” Glasscho answered, “What time she ready? What she

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was trying, what she was trying to do?” The unidentified male answered, “Um, get 20 of them.”

Glasscho responded, “Alright, is she ready now?” The unidentified male answered, “Yeah. Is it the

same thing or something?” Glasscho responded, “Same thing, same thing. I’m a um, when I get it

in my hand I’m gonna call her. Is she ready? Her phone still on?” The unidentified male

responded, “Yeah she ready now.” Glasscho advised, “Alright, when I get it in my hand I’m gonna

call her.” Based on my training and experience and other information developed during this

investigation, I believe that the unidentified male was arranging for a female associate, later

identified as Lakia Hatchett, to purchase a quantity of drugs from Glasscho and was inquiring about

the quality of the drugs (“Is it the same thing or something?”).

b. On March 19, 2009, Glasscho placed an outgoing call to (410) 713-

6729, with an unknown subscriber and utilized by Lakia Hatchett. During the conversation, Hatchett

advised, “Hey could you call him real quick, cause he on the other line. Call him and um, he gonna

call me back.” Glasscho responded, “Alright.” At approximately 5:15 pm, Glasscho placed an

outgoing call to (410) 807-6792, utilized by the unidentified male. During the conversation the

unidentified male asked, “You call her?” Glasscho answered, “Yeah she told me to call you real

quick and then he gonna call me back.” The unidentified male responded, “Well I mean she, she’s

ready, cause I, I’m talking to her, she just clicked over and hung up.” Glasscho reiterated that

Hatchett had instructed Glasscho to call the unidentified male back. The unidentified male

explained, “Nah, it’s what I told you. You know what I mean? But I didn’t know how long you was

gonna take.” Glasscho responded, “Nah, I should be there bout, I’m a call her, I’m a call her back

man, let her know I’ll be there in about 20 minutes.” At approximately 5:16 pm, Glasscho placed

an outgoing call to (410) 713-6729, utilized by Hatchett. Glasscho advised, “I should be there about

85
20 minutes. You, you, you be ready?” Hatchett responded, “Yeah, I’ll be ready.” At approximately

5:35 pm, Glasscho placed an outgoing call to (410) 713-6729, utilized by Hatchett. Hatchett

advised, “I’m two minutes away, I’m coming down now.” At approximately 5:40 pm, Glasscho was

observed meeting with Hatchett on the BP gas station parking lot located at Howard Street and 23rd

Street. Agents observed Glasscho exit his vehicle, approach Hatchett, and drop a white in color

object directly into Hatchett’s purse. Hatchett then left the location. Within a few minutes, law

enforcement officers surveilled Hatchett’s vehicle parked directly in front of 2735 ST. PAUL

STREET, the apartment building for SUBJECT PREMISES #10. Based on my training and

experience and other information developed during this investigation, I believe that Glasscho

delivered a quantity of drugs to Hatchett at the direction of the unidentified male and that Hatchett

took the drugs directly to her residence.

90. The residence at 2735 ST. PAUL STREET, APARTMENT 1, BALTIMORE,

MARYLAND, identified herein as SUBJECT PREMISES #10, is the residence of Lakia Hatchett.

Based on a review of records maintained by BG&E, I have learned that the account for SUBJECT

PREMISES #10 is listed to Kim S. Van Dyke. However, law enforcement has determined that Kim

Van Dyke is not in fact a resident at SUBJECT PREMISES #10. Moreover, Lakia Hatchett is the

listed customer for the BG&E account at 730 McCabe Avenue, Baltimore, Maryland, but the bill

for that account is sent to Hatchett at 2735 Saint Paul Street, Apartment 1, Baltimore, Maryland, the

address of SUBJECT PREMISES #10. Based on a search of law enforcement databases, I have

learned that 730 McCabe Avenue, Baltimore, Maryland and SUBJECT PREMISES#10 are both

listed as addresses for Hatchett. Hatchett’s vehicle has been surveilled parked in front of SUBJECT

PREMISES #10, and Hatchett has been surveilled entering and exiting that premises. In addition,

86
law enforcement officers have observed Hatchett’s name on the mailbox of SUBJECT PREMISES

#10.

91. SUBJECT PREMISES #10 is a three story brown and red brick row home.

There is a brown wood front door with the numbers 2 7 3 5 in black and gold. Apartment 1 is

entered through a white door.

92. Based upon my training and experience and my participation in this and other

investigations, as well as my conversations with other agents, I know that certain items are

commonly maintained at the residences of individuals involved in drug-trafficking, as set forth in

Exhibit 2, which is incorporated herein by reference.

93. Based upon the foregoing and on my training, experience, and participation in

narcotics investigations, I respectfully submit that there is probable cause to believe that there will

be found in SUBJECT PREMISES #10 the items set forth in Attachment J, which constitute

evidence, fruits and/or instrumentalities of violations of, inter alia, 21 U.S.C. §§ 841 and 846, which

prohibits the distribution and possession with intent to distribute controlled substances, and

conspiracy to commit those offenses; and 21 U.S.C. § 843, which prohibits the use of a

communication facility in furtherance of drug-trafficking.

F. Darryl Taylor/SUBJECT PREMISES #11

94. Based on evidence developed during this investigation, including calls

intercepted during wiretaps, I have learned that Darryl Taylor obtains heroin from Kevin Glasscho

and smuggles the heroin to BGF members and other inmates in Maryland prisons. Multiple calls

were intercepted during this investigation in which Taylor and Glasscho discussed drug smuggling

activities and arranged drug transactions.

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 a. For instance, on March 14, 2009, at approximately 4:00 pm, Glasscho

received an incoming call from (410) 710-8620, subscribed to and utilized by Darryl Taylor. Upon

answering the telephone Taylor advised, “Hey everything good alright.” Glasscho responded, “My

man, my man. You didn’t have no problems getting it in?” Taylor answered, “No uh, uh.”

Glasscho asked, “Yeah, see did you talk to talk to him about how you feel comfortable coming? Did

you talk to him about the way you feel comfortable coming in?” Taylor answered, “Well you know

what I mean, it, it was like, no I didn’t.” Taylor advised, “Yeah, look man I, I, I did right but uh,

I told him. I’m like man I have to you know, get some practice in for that man. Cause I ain’t, you

know I ain’t never, I ain’t, I ain’t never had to utilize nothing like that.” Glasscho asked, “What you

uh, what he want you to carry it between your cheeks?” Taylor answered, “Yeah.” Glasscho

responded, “Yeah that’s how I do it. I carry it between my cheeks.” Taylor advised, “Right I

understand that right. But I ain’t, I ain’t, you know I ain’t, I ain’t never, I ain’t never did it that way

right. But like I told him, I will have to you know, uh, uh, uh, being you know uh, uh, get home and

get some practice. You know what I mean? That way I’m, I’m, I’m familiar with it and

comfortable.” Glasscho said, “Yeah, carrying it between your cheeks is the best way though man.”

Taylor responded, “That’s what he said.” Glasscho continued, “Yeah they can never, he, he ain’t

lying about that. He ain’t lying about that. That’s how I do it.” Taylor said, “Right, yeah he told

me.” Glasscho went on in detail on exactly how carries the item into the facility and how it is

removed and passed to the inmate without being detected by corrections officials. Based on my

training and experience and other information developed during this investigation, including other

intercepted calls, I believe that in this call, Glasscho and Taylor were discussing a transaction in

which Glasscho supplied drugs to Taylor, who in turn smuggled the drugs into a prison facility,

88
believed to be located in Hagerstown, by body-carrying the drugs into the facility, which Glasscho

indicated is the method he uses as well.

95. The residence at 448 TUBMAN COURT, BALTIMORE, MARYLAND,

identified herein as SUBJECT PREMISES #11, is the residence of Darryl Taylor. Based on a

review of Maryland MVA records, I have learned that SUBJECT PREMISES #11 is listed as the

residence for Darryl Taylor. The cellphone on which Taylor was intercepted is subscribed to him

at the address of SUBJECT PREMISES #11. Law enforcement databases also list Darryl Taylor’s

residence as SUBJECT PREMISES #11. During a visit to WCI in Cumberland, Maryland, Taylor

was stopped entering the prison. At that time, he provided DOC officials with a Maryland driver’s

license reflecting an address of 448 Tubman Court, Baltimore, Maryland, the address of SUBJECT

PREMISES #11. On April 7, 2009, a uniformed officer knocked on the door of SUBJECT

PREMISES #11. At that time, Taylor answered the door and was positively identified by the officer.

Taylor advised the officer that he resides at SUBJECT PREMISES #11 with his grandmother.

96. SUBJECT PREMISES #11 is a two story red brick residence. The residence

has a red metal door with the metal screen door attached. The numbers 4 4 8 are above the door.

97. Based upon my training and experience and my participation in this and other

investigations, as well as my conversations with other agents, I know that certain items are

commonly maintained at the residences of individuals involved in drug-trafficking, as set forth in

Exhibit 2, which is incorporated herein by reference.

98. Based upon the foregoing and on my training, experience, and participation in

narcotics investigations, I respectfully submit that there is probable cause to believe that there will

be found in SUBJECT PREMISES #11 the items set forth in Attachment K, which constitute

89
evidence, fruits and/or instrumentalities of violations of, inter alia, 21 U.S.C. §§ 841 and 846, which

prohibits the distribution and possession with intent to distribute controlled substances, and

conspiracy to commit those offenses; and 21 U.S.C. § 843, which prohibits the use of a

communication facility in furtherance of drug-trafficking.

G. Tyrone Dow/SUBJECT PREMISES #12

99. Based on evidence developed during this investigation, including calls

intercepted during wiretaps, I have learned that Tyrone Dow is one of Glasscho’s heroin suppliers

who distributes large quantities of heroin to Glasscho and other heroin distributors. Numerous calls

were intercepted during this investigation in which Dow and Glasscho discussed and arranged drug

transactions.

a. For instance, on March 18, 2009, at approximately 9:57 pm, Glasscho

received an incoming call from (443) 563-4012, subscribed to Andrew Brown, PO Box 54988,

Irvine, California, and utilized by “KK.” When Glasscho answered the call, Tyrone Dow was heard

talking in the background. Glasscho told KK, “We was just sitting here talking about you.” KK

responded, “Oh yeah. Who that, Flav [a reference to Dow]?” Glasscho answered, “Yeah.” KK said

that he had recently tried to reach Dow at the “shop.” As the conversation progressed KK said,

“Yeah man I gotta go up there, I gotta come up there man, you know.” Glasscho responded, “Yeah

we was just asking when you was coming up.” KK continued, “Yeah that’s what I’m saying. I, I

gotta come up there. I’ll probably come in two weeks and shit. You know what I’m saying? I

needed to talk to him and shit to see what, you know.” Glasscho responded, “Yeah. Here he go,

hold on.” Dow then used Glasscho’s telephone to speak with KK. Dow asked, “When you coming

in town?” KK answered, “Um, I’ll be, I’m saying first, I was kind a fucked up. Kind of feeling

90
fucked up man. I said if it ain’t really worth it man I ain’t coming up there. I’m just crazy, shit is

crazy. You know what I’m saying?” Dow responded, “Yeah.” KK asked, “What you think, I

should come up there? Like cause you know the spring break and Easter break and shit is like in

two weeks. What you think I should come up?” Dow answered, “Yeah come on and hang out, just

to hang out with us.” KK responded, “Yeah, yeah.” KK said he had tried recently reaching Dow

at the shop was told he wasn’t there. Dow said, “Yeah, come on up man. Um, um Cuzzo probably

be through by the time you come up. That’s all I’ll be waiting on.” KK responded, “Yeah, yeah.

What’s, what’s up with Edo, he chilling man?” Dow answered, “Yeah he’s chilling. I just left him

not too long ago.” KK said, “Oh yeah cause I didn’t know his number, I didn’t know your number,

I just wanted to say good looking out. I, I couldn’t get in touch with nobody.” Dow responded,

“Well you know I got you man. That’s what I be trying to explain, I got you no matter what.” KK

said, “Yeah that’s why I was calling around. I called, I been calling it ever since. You know what

I’m saying? I was like damn I sure appreciate, you know what I’m saying?” Dow continued, “Yeah

it’s no matter what. You my man, it ain’t, it ain’t just about that. You know what I mean?” KK

responded, “Yeah, yeah man that’s what’s up man. Hell yeah I appreciate that man, you know.”

Dow continued, “Yeah you my man. But uh, I’m a try to do something before you come. But um,

come on up.” KK responded, “Alright, alright man.” Dow told KK that he could even just come

up and hang out and that Dow would pay KK’s travel expenses. KK responded to that offer,

“Alright man that’s what’s up man, hell yeah.” Dow continued, “But I’m gonna do something

before, cause that, you said in about two weeks right?” KK answered, “Yeah, yeah you know the

um, you know the Easter, Easter like the first week, it’s like gonna be around that Easter time. You

know the little Easter break.” Dow said, “Alright cause I’m, I’m hoping he come through before

91
then. But even if he don’t, I, I’ll pay your way up.” KK responded, “Alright my man, my man.”

Glasscho then returned to speak with KK and said, “I’m gonna give him this number, I’m gonna

give him this number. This the Boost joint right?” KK answered, “Yeah, yeah.” Based on my

training and experience and other information developed during this investigation, I believe that KK

is an out-of-state supplier of drugs. KK has been trying to reach Dow to determine whether or not

KK should send a shipment of drugs to Maryland. Dow advised that he and his associates are

currently obtaining their drugs from Cuzzo, but that KK should send a shipment. Dow advised,

“Um, um Cuzzo probably be through by the time you come up. That’s all I’ll be waiting on.”

Additionally it is believed that Dow provided information to KK regarding what I believe to be a

drug shipment that was seized by law enforcement. KK appears to have been avoiding sending any

drugs to Maryland until he was reassured that someone there would be capable of distributing a large

quantity. Ultimately, Dow said that even if KK did not send any drugs at this time, he would pay

for KK to come to Maryland to “hang out” with Dow and his drug associates.

b. On March 21, 2009, at approximately 9:09 am, Glasscho placed an

outgoing call to (410) 294-4839, utilized by Dow. Glasscho advised that he had to work from ten

until six o’clock in the evening. Glasscho asked, “Do you feel like riding out there?” Dow

answered, “Yeah, yeah I’ll ride out.” Glasscho responded, “My man, my man, my man, my man.

Give me a call when you get out.” Based on my training and experience and other information

developed during this investigation, I believe that Glasscho wanted to have a drug related meeting

with Dow in person at his place of employment.

c. On March 21, 2009, at approximately 2:08 pm, Glasscho placed an

outgoing call to (410) 294-4839, utilized by Dow. During the conversation Glasscho asked, “What

92
time you gonna try to slide out here?” Dow answered, “I’ll be there in the next forty minutes.”

Glasscho advised that he was on his lunch break and would be returning to work at 2:45 pm. Dow

advised, “Alright, I’ll be there. I’m gonna leave in five minutes then.” Glasscho responded, “Yeah

I’d like, I’d like to see you before I get off my lunch break. You know what I’m saying? Try to be

here about two thirty or something like that. Get here about two thirty or twenty of.” Dow

responded, “Okay.” Glasscho responded, “Alright, come on.” At approximately 2:40 pm, Glasscho

placed an outgoing call to (410) 294-4839, utilized by Dow. During the brief conversation Dow

advised that he was at Glasscho’s place of employment. Glasscho then said he was coming to meet

Dow. Based on my training and experience and other information developed during this

investigation, I believe that Glasscho wanted Dow to meet him at his place of employment so

Glasscho could deliver the proceeds from a drug sale he had conducted earlier.

d. On March 28, 2009, at approximately 5:09 pm, Dow received an

incoming call from (443) 799-9143 with an unknown subscriber and utilized by an unidentified

male. During the brief conversation Dow advised, “I’ll be calling you in about an hour. Why don’t

you be down there in about an hour.” The unidentified male asked, “But is you already cool?” Dow

answered, “Nah, ‘bout, ‘bout an hour.” The unidentified male explained that he was going to “go

across town” but would stay in the area until seven o’clock. Based on my training and experience

and other information developed during this investigation, I believe that the unidentified male is

attempting to purchase a quantity of drugs from Dow. When the unidentified male asked, “But is

you already cool?” and Dow answered, “Nah, ‘bout, ‘bout an hour,” the unidentified male was

inquiring whether Dow was prepared to sell the unidentified male the quantity of drugs.

e. On March 30, 2009, at approximately 1:18 pm, Dow placed an

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outgoing call to (443) 622-1345, with an unknown subscriber and utilized by an unidentified male.

Dow asked, “You know uh, Twin?” The unidentified male answered, “Uh Twin, I know the twins

out of Sandtown that write numbers.” Dow continued, “Nah, this Twin he was going down there

hollering at um, your man down there, across the street from the market.” The unidentified male

responded, “Yeah, yeah.” Dow continued, “But I’m out of town. Is it alright if I give him your

number?” The unidentified male answered, “Yeah, absolutely.” Dow continued, “Alright, okay

I’m gonna give him your number.” Based on my training and experience and other information

developed during this investigation, I believe that Dow was referring a drug customer to the

unidentified male. The unidentified male is believed to be a source of supply for a type of drug that

Dow currently does not have in his possession.

f. On April 7, 2009, at approximately 3:03 pm, Dow placed an outgoing

call to Glasscho. During the conversation Glasscho asked where Dow currently was located. Dow

advised, “I ain’t gonna be able to get there till four, four thirty.” Glasscho responded, “You won’t

be able to get to the house till four thirty?” Dow continued, “Yeah, I, I might could make it by four.

Between four and four thirty.” Glasscho responded, “I need to see you as soon as you can man.”

Dow advised, “Alright, okay.” Based on my training and experience and other information

developed during this investigation, I believe that Glasscho needed to meet with Dow as soon as

possible to obtain a new supply of drugs. During the course of this and other communications, law

enforcement agents were conducting surveillance of Glasscho. At approximately 3:59 pm, Dow

received an incoming call from Glasscho. During the conversation, Dow advised, “Meet you in

fifteen minutes.” At approximately 4:15 pm, agents observed Dow arrive at Glasscho’s residence,

SUBJECT PREMISES #7. Upon exiting his vehicle Dow was observed to remove a brown paper

bag from the passenger compartment of the vehicle. Agents were able to see that the brown bag was

94
weighted down and took the shape of several rectangular items, believed to be kilograms of heroin.

Dow then entered Glasscho’s residence, departing a short time later. Not long after Dow departed

Glasscho’s residence, Glasscho began calling several of his identified drug customers – including,

among others, Calvin Robinson – indicating that he had drugs available for sale.

g. On April 10, 2009, at approximately 9:04 am, Dow placed an

outgoing call to Glasscho. During the conversation Dow asked, “What time you say you got to be

to work?” Glasscho answered, “Two o’clock. Come meet me at the house, come meet me at the

house.” Dow responded, “Alright.” Glasscho asked, “You on your way?” Dow responded, “No,

I’m a be about forty minutes.” At approximately 11:27 am, Dow received an incoming call from

Glasscho. During the brief conversation Dow advised, “I’ll be at the house in about twenty minutes

or you gonna be at your house?” Glasscho answered, “Nah, you got to be at my house man. Cause

I got to, I got to move.” Dow responded, “I’m on my way. I’ll be there in twenty minutes.” Based

on my training and experience and other information developed during this investigation, I believe

that Glasscho needed to meet with Dow in person to have a drug-related meeting, which is believed

to be payment of a drug debt. During this time period agents were conducting surveillance at 5

Woodbriar Court, Baltimore, Maryland, the residence of Tyrone Dow. At approximately 11:40 am,

agents observed Dow walking down the steps from the second floor apartments located at 5

Woodbriar Court, Baltimore, Maryland. Dow then entered his vehicle and drove out of the area.

A short time later Dow advised Glasscho, “I’m coming up the hill,” a reference to an area near

Glasscho’s residence.

100. The residence at 5 WOODBRIAR COURT, APARTMENT C, BALTIMORE,

MARYLAND, identified herein as SUBJECT PREMISES #12, is a residence used by Tyrone Dow.

95
be found in SUBJECT PREMISES #12 the items set forth in Attachment L, which constitute

evidence, fruits and/or instrumentalities of violations of, inter alia, 21 U.S.C. §§ 841 and 846, which

prohibits the distribution and possession with intent to distribute controlled substances, and

conspiracy to commit those offenses; and 21 U.S.C. § 843, which prohibits the use of a

communication facility in furtherance of drug-trafficking.

VIII. Request for Authorization for Nighttime Execution

104. Based on the information contained in this affidavit, including information

regarding gang membership, acts of violence, and the presence of narcotics and firearms, which I

know based on my training and experience are frequently found in premises controlled by drug

traffickers, I respectfully submit that there is probable cause to believe that grounds exist for the

service of the search warrants for SUBJECT PREMISES #6-12 at any time of the day or night.

Accordingly, pursuant to 21 U.S.C. § 879, I respectfully request that law enforcement officers be

authorized to serve the search warrants for SUBJECT PREMISES #6-12 at any time of the day or

night.

IX. Conclusion

105. Based upon the foregoing, I respectfully submit that there is probable cause

to believe that there will be found in the SUBJECT PREMISES the items set forth in the respective

attachments hereto, which constitute evidence, fruits, and instrumentalities of, inter alia, the

aforementioned violations of federal laws.

106. Given the confidential nature of this continuing investigation, I respectfully

request that this affidavit and all of the papers submitted herewith be maintained under seal until

otherwise ordered by this Court, except that two (2) certified copies shall be provided to the United

97
States Attorney’s Office.

WHEREFORE, in consideration of the facts presented, I respectfully request that this

Court issue a search warrant for each of the SUBJECT PREMISES and authorize the search and

seizure of the items described in the respective attachments hereto.

WILLIAM NICKOLES
Detective, Baltimore Police Department
Task Force Officer, DEA

Sworn to before me this

_____ day of April, 2009.

____________________________________
UNITED STATES MAGISTRATE JUDGE
DISTRICT OF MARYLAND

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 Attachment A

ITEMS TO BE SEIZED
5637 UTRECHT ROAD, BALTIMORE, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #1")

1. Correspondence, drawings, letters, cards, notes, papers, postcards,

photographs and video recordings of individuals, and items of clothing documenting membership
in BGF and establishing relationships between members and associates of BGF;

2. Phone and address lists; dues lists; other lists of gang members; documents
or other items reflecting gang “tags”; spray-paint, wide tip marking pens, or other items used to
create gang “tags”;

3. Rule books, codes of conduct, or other documents setting forth the rules
governing BGF and its members; pre-paid credit cards and documents relating thereto;

4. Firearms, ammunition, magazines for storing and loading ammunition, gun

boxes, holsters, gun parts, shell casings, items used to clean and maintain firearms, firearms-related
publications, firearms-related documents, and other indicia of gun possession;

5. Records of narcotics transactions including, but not limited to, books, ledgers,
receipts, notes, pay and owe sheets, and other papers relating to the manufacture, transportation,
possession, and distribution of controlled substances or the receipt and disposition of proceeds
derived from the sale of illegal narcotics;

6. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to, currency;
financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s checks and
receipts for such checks; Western Union receipts; money orders; money order receipts; credit card
records; vehicle registrations; real estate records; income tax returns and any documentation relating
to the payment of any income tax; mail and contract mail carrier records; documentation and receipts
relating to any safe deposit boxes and keys to safe deposit boxes; documentation and receipts
relating to any storage facilities and keys to those storage facilities; devices capable of counting
large sums of currency; other items of value or proceeds derived from the sale of illegal narcotics;
and any other documents or evidence of financial transactions involving the receipt and disposition
of the proceeds of illegal narcotics sales;

7. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the numbers
and other data stored within those telephones; pagers and personal digital assistants, and the
numbers stored inside those devices; devices capable of recording incoming telephone numbers, and
the numbers stored within those devices; records of telephone calls, whether recorded electronically
or in writing; notes reflecting telephone and pager numbers, or papers which reflect names,
addresses, and telephone numbers of suspected co-conspirators; photographs (to include still photos,
negatives, movies, slides, video tapes, and undeveloped film); and audiotape recordings of

1
conversations, including those made over telephone answering machines;

8. Two-way radios and police scanners;

9. Documents or other records relating to state court proceedings involving other

co-conspirators, including, but not limited to, charging documents and bail records;

10. Identification documents;

11. Records of travel including, but not limited to, tickets, transportation
schedules, passports, automobile rental records, notes and receipts related to travel, and motel/hotel
receipts;

12. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts, canceled
checks, utility, cable, and telephone bills, titles, registration documents, and other documents;

13. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked; hidden
compartments that may contain any of the foregoing; and the contents thereof.

2
 Attachment B

ITEMS TO BE SEIZED
1113 EAST BELVEDERE AVENUE, APARTMENT C, BALTIMORE, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #2")

1. Correspondence, drawings, letters, cards, notes, papers, postcards,

photographs and video recordings of individuals, and items of clothing documenting membership
in BGF and establishing relationships between members and associates of BGF;

2. Phone and address lists; dues lists; other lists of gang members; documents
or other items reflecting gang “tags”; spray-paint, wide tip marking pens, or other items used to
create gang “tags”;

3. Rule books, codes of conduct, or other documents setting forth the rules
governing BGF and its members; pre-paid credit cards and documents relating thereto;

4. Firearms, ammunition, magazines for storing and loading ammunition, gun

boxes, holsters, gun parts, shell casings, items used to clean and maintain firearms, firearms-related
publications, firearms-related documents, and other indicia of gun possession;

5. Records of narcotics transactions including, but not limited to, books, ledgers,
receipts, notes, pay and owe sheets, and other papers relating to the manufacture, transportation,
possession, and distribution of controlled substances or the receipt and disposition of proceeds
derived from the sale of illegal narcotics;

6. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to, currency;
financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s checks and
receipts for such checks; Western Union receipts; money orders; money order receipts; credit card
records; vehicle registrations; real estate records; income tax returns and any documentation relating
to the payment of any income tax; mail and contract mail carrier records; documentation and receipts
relating to any safe deposit boxes and keys to safe deposit boxes; documentation and receipts
relating to any storage facilities and keys to those storage facilities; devices capable of counting
large sums of currency; other items of value or proceeds derived from the sale of illegal narcotics;
and any other documents or evidence of financial transactions involving the receipt and disposition
of the proceeds of illegal narcotics sales;

7. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the numbers
and other data stored within those telephones; pagers and personal digital assistants, and the
numbers stored inside those devices; devices capable of recording incoming telephone numbers, and
the numbers stored within those devices; records of telephone calls, whether recorded electronically
or in writing; notes reflecting telephone and pager numbers, or papers which reflect names,
addresses, and telephone numbers of suspected co-conspirators; photographs (to include still photos,
negatives, movies, slides, video tapes, and undeveloped film); and audiotape recordings of

1
conversations, including those made over telephone answering machines;

8. Two-way radios and police scanners;

9. Documents or other records relating to state court proceedings involving other

co-conspirators, including, but not limited to, charging documents and bail records;

10. Identification documents;

11. Records of travel including, but not limited to, tickets, transportation
schedules, passports, automobile rental records, notes and receipts related to travel, and motel/hotel
receipts;

12. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts, canceled
checks, utility, cable, and telephone bills, titles, registration documents, and other documents;

13. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked; hidden
compartments that may contain any of the foregoing; and the contents thereof.

2
 Attachment C

ITEMS TO BE SEIZED
600 S. HIGHLAND AVENUE, APARTMENT A, BALTIMORE, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #3")

1. Correspondence, drawings, letters, cards, notes, papers, postcards,

photographs and video recordings of individuals, and items of clothing documenting membership
in BGF and establishing relationships between members and associates of BGF;

2. Phone and address lists; dues lists; other lists of gang members; documents
or other items reflecting gang “tags”; spray-paint, wide tip marking pens, or other items used to
create gang “tags”;

3. Rule books, codes of conduct, or other documents setting forth the rules
governing BGF and its members; pre-paid credit cards and documents relating thereto;

4. Records of narcotics transactions including, but not limited to, books, ledgers,
receipts, notes, pay and owe sheets, and other papers relating to the manufacture, transportation,
possession, and distribution of controlled substances or the receipt and disposition of proceeds
derived from the sale of illegal narcotics;

5. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to, currency;
financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s checks and
receipts for such checks; Western Union receipts; money orders; money order receipts; credit card
records; vehicle registrations; real estate records; income tax returns and any documentation relating
to the payment of any income tax; mail and contract mail carrier records; documentation and receipts
relating to any safe deposit boxes and keys to safe deposit boxes; documentation and receipts
relating to any storage facilities and keys to those storage facilities; devices capable of counting
large sums of currency; other items of value or proceeds derived from the sale of illegal narcotics;
and any other documents or evidence of financial transactions involving the receipt and disposition
of the proceeds of illegal narcotics sales;

6. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the numbers
and other data stored within those telephones; pagers and personal digital assistants, and the
numbers stored inside those devices; devices capable of recording incoming telephone numbers, and
the numbers stored within those devices; records of telephone calls, whether recorded electronically
or in writing; notes reflecting telephone and pager numbers, or papers which reflect names,
addresses, and telephone numbers of suspected co-conspirators; photographs (to include still photos,
negatives, movies, slides, video tapes, and undeveloped film); and audiotape recordings of
conversations, including those made over telephone answering machines;

7. Two-way radios and police scanners;

1
 8. Documents or other records relating to state court proceedings involving other
co-conspirators, including, but not limited to, charging documents and bail records;

9. Identification documents;

10. Records of travel including, but not limited to, tickets, transportation
schedules, passports, automobile rental records, notes and receipts related to travel, and motel/hotel
receipts;

11. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts, canceled
checks, utility, cable, and telephone bills, titles, registration documents, and other documents;

12. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked; hidden
compartments that may contain any of the foregoing; and the contents thereof.

2
 Attachment D

ITEMS TO BE SEIZED
420 WOODLAKE COURT # C, GLEN BURNIE, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #4")

1. Correspondence, drawings, letters, cards, notes, papers, postcards,

photographs and video recordings of individuals, and items of clothing documenting membership
in BGF and establishing relationships between members and associates of BGF;

2. Phone and address lists; dues lists; other lists of gang members; documents
or other items reflecting gang “tags”; spray-paint, wide tip marking pens, or other items used to
create gang “tags”;

3. Rule books, codes of conduct, or other documents setting forth the rules
governing BGF and its members; pre-paid credit cards and documents relating thereto;

4. Records of narcotics transactions including, but not limited to, books, ledgers,
receipts, notes, pay and owe sheets, and other papers relating to the manufacture, transportation,
possession, and distribution of controlled substances or the receipt and disposition of proceeds
derived from the sale of illegal narcotics;

5. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to, currency;
financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s checks and
receipts for such checks; Western Union receipts; money orders; money order receipts; credit card
records; vehicle registrations; real estate records; income tax returns and any documentation relating
to the payment of any income tax; mail and contract mail carrier records; documentation and receipts
relating to any safe deposit boxes and keys to safe deposit boxes; documentation and receipts
relating to any storage facilities and keys to those storage facilities; devices capable of counting
large sums of currency; other items of value or proceeds derived from the sale of illegal narcotics;
and any other documents or evidence of financial transactions involving the receipt and disposition
of the proceeds of illegal narcotics sales;

6. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the numbers
and other data stored within those telephones; pagers and personal digital assistants, and the
numbers stored inside those devices; devices capable of recording incoming telephone numbers, and
the numbers stored within those devices; records of telephone calls, whether recorded electronically
or in writing; notes reflecting telephone and pager numbers, or papers which reflect names,
addresses, and telephone numbers of suspected co-conspirators; photographs (to include still photos,
negatives, movies, slides, video tapes, and undeveloped film); and audiotape recordings of
conversations, including those made over telephone answering machines;

7. Two-way radios and police scanners;

1
 8. Documents or other records relating to state court proceedings involving other
co-conspirators, including, but not limited to, charging documents and bail records;

9. Identification documents;

10. Records of travel including, but not limited to, tickets, transportation
schedules, passports, automobile rental records, notes and receipts related to travel, and motel/hotel
receipts;

11. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts, canceled
checks, utility, cable, and telephone bills, titles, registration documents, and other documents;

12. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked; hidden
compartments that may contain any of the foregoing; and the contents thereof.

2
 Attachment E

ITEMS TO BE SEIZED
15 HIAWATHA COURT, OWINGS MILLS, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #5")

1. Correspondence, drawings, letters, cards, notes, papers, postcards,

photographs and video recordings of individuals, and items of clothing documenting membership
in BGF and establishing relationships between members and associates of BGF;

2. Phone and address lists; dues lists; other lists of gang members; documents
or other items reflecting gang “tags”; spray-paint, wide tip marking pens, or other items used to
create gang “tags”;

3. Rule books, codes of conduct, or other documents setting forth the rules
governing BGF and its members; pre-paid credit cards and documents relating thereto;

4. Records of narcotics transactions including, but not limited to, books, ledgers,
receipts, notes, pay and owe sheets, and other papers relating to the manufacture, transportation,
possession, and distribution of controlled substances or the receipt and disposition of proceeds
derived from the sale of illegal narcotics;

5. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to, currency;
financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s checks and
receipts for such checks; Western Union receipts; money orders; money order receipts; credit card
records; vehicle registrations; real estate records; income tax returns and any documentation relating
to the payment of any income tax; mail and contract mail carrier records; documentation and receipts
relating to any safe deposit boxes and keys to safe deposit boxes; documentation and receipts
relating to any storage facilities and keys to those storage facilities; devices capable of counting
large sums of currency; other items of value or proceeds derived from the sale of illegal narcotics;
and any other documents or evidence of financial transactions involving the receipt and disposition
of the proceeds of illegal narcotics sales;

6. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the numbers
and other data stored within those telephones; pagers and personal digital assistants, and the
numbers stored inside those devices; devices capable of recording incoming telephone numbers, and
the numbers stored within those devices; records of telephone calls, whether recorded electronically
or in writing; notes reflecting telephone and pager numbers, or papers which reflect names,
addresses, and telephone numbers of suspected co-conspirators; photographs (to include still photos,
negatives, movies, slides, video tapes, and undeveloped film); and audiotape recordings of
conversations, including those made over telephone answering machines;

7. Two-way radios and police scanners;

1
 8. Documents or other records relating to state court proceedings involving other
co-conspirators, including, but not limited to, charging documents and bail records;

9. Identification documents;

10. Records of travel including, but not limited to, tickets, transportation
schedules, passports, automobile rental records, notes and receipts related to travel, and motel/hotel
receipts;

11. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts, canceled
checks, utility, cable, and telephone bills, titles, registration documents, and other documents;

12. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked; hidden
compartments that may contain any of the foregoing; and the contents thereof.

2
 Attachment F

ITEMS TO BE SEIZED
4001 DUVALL AVENUE, FLOOR 2, BALTIMORE, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #6")

1. Correspondence, drawings, letters, cards, notes, papers, postcards,

photographs and video recordings of individuals, and items of clothing documenting
membership in BGF and establishing relationships between members and associates of BGF;

2. Phone and address lists; dues lists; other lists of gang members;
documents or other items reflecting gang “tags”; spray-paint, wide tip marking pens, or other
items used to create gang “tags”;

3. Rule books, codes of conduct, or other documents setting forth the rules
governing BGF and its members; pre-paid credit cards and documents relating thereto;

4. Records of narcotics transactions including, but not limited to, books,

ledgers, receipts, notes, pay and owe sheets, and other papers relating to the manufacture,
transportation, possession, and distribution of controlled substances or the receipt and
disposition of proceeds derived from the sale of illegal narcotics;

5. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to,
currency; financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s
checks and receipts for such checks; Western Union receipts; money orders; money order
receipts; credit card records; vehicle registrations; real estate records; income tax returns and any
documentation relating to the payment of any income tax; mail and contract mail carrier records;
documentation and receipts relating to any safe deposit boxes and keys to safe deposit boxes;
documentation and receipts relating to any storage facilities and keys to those storage facilities;
devices capable of counting large sums of currency; other items of value or proceeds derived
from the sale of illegal narcotics; and any other documents or evidence of financial transactions
involving the receipt and disposition of the proceeds of illegal narcotics sales;

6. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the
numbers and other data stored within those telephones; pagers and personal digital assistants,
and the numbers stored inside those devices; devices capable of recording incoming telephone
numbers, and the numbers stored within those devices; records of telephone calls, whether
recorded electronically or in writing; notes reflecting telephone and pager numbers, or papers
which reflect names, addresses, and telephone numbers of suspected co-conspirators;
photographs (to include still photos, negatives, movies, slides, video tapes, and undeveloped
film); and audiotape recordings of conversations, including those made over telephone
answering machines;

7. Two-way radios and police scanners;

1
 8. Documents or other records relating to state court proceedings involving
other co-conspirators, including, but not limited to, charging documents and bail records;

9. Identification documents;

10. Records of travel including, but not limited to, tickets, transportation
schedules, passports, automobile rental records, notes and receipts related to travel, and
motel/hotel receipts;

11. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts,
canceled checks, utility, cable, and telephone bills, titles, registration documents, and other
documents;

12. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked;
hidden compartments that may contain any of the foregoing; and the contents thereof.

2
 Attachment G

ITEMS TO BE SEIZED
1909 FOREST PARK AVENUE, APT. S3, GYNN OAK, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #7")

1. Correspondence, drawings, letters, cards, notes, papers, postcards,

photographs and video recordings of individuals, and items of clothing documenting
membership in BGF and establishing relationships between members and associates of BGF;

2. Phone and address lists; dues lists; other lists of gang members;
documents or other items reflecting gang “tags”; spray-paint, wide tip marking pens, or other
items used to create gang “tags”;

3. Rule books, codes of conduct, or other documents setting forth the rules
governing BGF and its members; pre-paid credit cards and documents relating thereto;

4. Controlled substances, as well as paraphernalia used in the manufacture,

preparation, packaging, or weighing of illegal narcotics in preparation for distribution;

5. Firearms, ammunition, magazines for storing and loading ammunition,

gun boxes, holsters, gun parts, shell casings, items used to clean and maintain firearms, firearms-
related publications, firearms-related documents, and other indicia of gun possession;

6. Records of narcotics transactions including, but not limited to, books,

ledgers, receipts, notes, pay and owe sheets, and other papers relating to the manufacture,
transportation, possession, and distribution of controlled substances or the receipt and
disposition of proceeds derived from the sale of illegal narcotics;

7. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to,
currency; financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s
checks and receipts for such checks; Western Union receipts; money orders; money order
receipts; credit card records; vehicle registrations; real estate records; income tax returns and any
documentation relating to the payment of any income tax; mail and contract mail carrier records;
documentation and receipts relating to any safe deposit boxes and keys to safe deposit boxes;
documentation and receipts relating to any storage facilities and keys to those storage facilities;
devices capable of counting large sums of currency; other items of value or proceeds derived
from the sale of illegal narcotics; and any other documents or evidence of financial transactions
involving the receipt and disposition of the proceeds of illegal narcotics sales;

8. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the
numbers and other data stored within those telephones; pagers and personal digital assistants,
and the numbers stored inside those devices; devices capable of recording incoming telephone
numbers, and the numbers stored within those devices; records of telephone calls, whether

1
recorded electronically or in writing; notes reflecting telephone and pager numbers, or papers
which reflect names, addresses, and telephone numbers of suspected co-conspirators;
photographs (to include still photos, negatives, movies, slides, video tapes, and undeveloped
film); and audiotape recordings of conversations, including those made over telephone
answering machines;

9. Two-way radios and police scanners;

10. Documents or other records relating to state court proceedings involving

other co-conspirators, including, but not limited to, charging documents and bail records;

11. Identification documents;

12. Records of travel including, but not limited to, tickets, transportation
schedules, passports, automobile rental records, notes and receipts related to travel, and
motel/hotel receipts;

13. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts,
canceled checks, utility, cable, and telephone bills, titles, registration documents, and other
documents;

14. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked;
hidden compartments that may contain any of the foregoing; and the contents thereof.

2
 Attachment H

ITEMS TO BE SEIZED
1102 N. MOUNT STREET, BALTIMORE, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #8")

1. Controlled substances, as well as paraphernalia used in the manufacture,

preparation, packaging, or weighing of illegal narcotics in preparation for distribution;

2. Records of narcotics transactions including, but not limited to, books,

ledgers, receipts, notes, pay and owe sheets, and other papers relating to the manufacture,
transportation, possession, and distribution of controlled substances or the receipt and
disposition of proceeds derived from the sale of illegal narcotics;

3. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to,
currency; financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s
checks and receipts for such checks; Western Union receipts; money orders; money order
receipts; credit card records; vehicle registrations; real estate records; income tax returns and any
documentation relating to the payment of any income tax; mail and contract mail carrier records;
documentation and receipts relating to any safe deposit boxes and keys to safe deposit boxes;
documentation and receipts relating to any storage facilities and keys to those storage facilities;
devices capable of counting large sums of currency; other items of value or proceeds derived
from the sale of illegal narcotics; and any other documents or evidence of financial transactions
involving the receipt and disposition of the proceeds of illegal narcotics sales;

4. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the
numbers and other data stored within those telephones; pagers and personal digital assistants,
and the numbers stored inside those devices; devices capable of recording incoming telephone
numbers, and the numbers stored within those devices; records of telephone calls, whether
recorded electronically or in writing; notes reflecting telephone and pager numbers, or papers
which reflect names, addresses, and telephone numbers of suspected co-conspirators;
photographs (to include still photos, negatives, movies, slides, video tapes, and undeveloped
film); and audiotape recordings of conversations, including those made over telephone
answering machines;

5. Two-way radios and police scanners;

6. Documents or other records relating to state court proceedings involving

other co-conspirators, including, but not limited to, charging documents and bail records;

7. Identification documents;

8. Records of travel including, but not limited to, tickets, transportation

schedules, passports, automobile rental records, notes and receipts related to travel, and

1
motel/hotel receipts;

9. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts,
canceled checks, utility, cable, and telephone bills, titles, registration documents, and other
documents;

10. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked;
hidden compartments that may contain any of the foregoing; and the contents thereof.

2
 Attachment I

ITEMS TO BE SEIZED
3908 NORFOLK AVENUE, BALTIMORE, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #9")

1. Controlled substances, as well as paraphernalia used in the manufacture,

preparation, packaging, or weighing of illegal narcotics in preparation for distribution;

2. Records of narcotics transactions including, but not limited to, books,

ledgers, receipts, notes, pay and owe sheets, and other papers relating to the manufacture,
transportation, possession, and distribution of controlled substances or the receipt and
disposition of proceeds derived from the sale of illegal narcotics;

3. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to,
currency; financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s
checks and receipts for such checks; Western Union receipts; money orders; money order
receipts; credit card records; vehicle registrations; real estate records; income tax returns and any
documentation relating to the payment of any income tax; mail and contract mail carrier records;
documentation and receipts relating to any safe deposit boxes and keys to safe deposit boxes;
documentation and receipts relating to any storage facilities and keys to those storage facilities;
devices capable of counting large sums of currency; other items of value or proceeds derived
from the sale of illegal narcotics; and any other documents or evidence of financial transactions
involving the receipt and disposition of the proceeds of illegal narcotics sales;

4. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the
numbers and other data stored within those telephones; pagers and personal digital assistants,
and the numbers stored inside those devices; devices capable of recording incoming telephone
numbers, and the numbers stored within those devices; records of telephone calls, whether
recorded electronically or in writing; notes reflecting telephone and pager numbers, or papers
which reflect names, addresses, and telephone numbers of suspected co-conspirators;
photographs (to include still photos, negatives, movies, slides, video tapes, and undeveloped
film); and audiotape recordings of conversations, including those made over telephone
answering machines;

5. Two-way radios and police scanners;

6. Documents or other records relating to state court proceedings involving

other co-conspirators, including, but not limited to, charging documents and bail records;

7. Identification documents;

8. Records of travel including, but not limited to, tickets, transportation

schedules, passports, automobile rental records, notes and receipts related to travel, and

1
motel/hotel receipts;

9. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts,
canceled checks, utility, cable, and telephone bills, titles, registration documents, and other
documents;

10. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked;
hidden compartments that may contain any of the foregoing; and the contents thereof.

2
 Attachment J

ITEMS TO BE SEIZED
2735 ST. PAUL STREET, APARTMENT 1, BALTIMORE, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #10")

1. Controlled substances, as well as paraphernalia used in the manufacture,

preparation, packaging, or weighing of illegal narcotics in preparation for distribution;

2. Records of narcotics transactions including, but not limited to, books,

ledgers, receipts, notes, pay and owe sheets, and other papers relating to the manufacture,
transportation, possession, and distribution of controlled substances or the receipt and
disposition of proceeds derived from the sale of illegal narcotics;

3. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to,
currency; financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s
checks and receipts for such checks; Western Union receipts; money orders; money order
receipts; credit card records; vehicle registrations; real estate records; income tax returns and any
documentation relating to the payment of any income tax; mail and contract mail carrier records;
documentation and receipts relating to any safe deposit boxes and keys to safe deposit boxes;
documentation and receipts relating to any storage facilities and keys to those storage facilities;
devices capable of counting large sums of currency; other items of value or proceeds derived
from the sale of illegal narcotics; and any other documents or evidence of financial transactions
involving the receipt and disposition of the proceeds of illegal narcotics sales;

4. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the
numbers and other data stored within those telephones; pagers and personal digital assistants,
and the numbers stored inside those devices; devices capable of recording incoming telephone
numbers, and the numbers stored within those devices; records of telephone calls, whether
recorded electronically or in writing; notes reflecting telephone and pager numbers, or papers
which reflect names, addresses, and telephone numbers of suspected co-conspirators;
photographs (to include still photos, negatives, movies, slides, video tapes, and undeveloped
film); and audiotape recordings of conversations, including those made over telephone
answering machines;

5. Two-way radios and police scanners;

6. Documents or other records relating to state court proceedings involving

other co-conspirators, including, but not limited to, charging documents and bail records;

7. Identification documents;

8. Records of travel including, but not limited to, tickets, transportation

schedules, passports, automobile rental records, notes and receipts related to travel, and

1
motel/hotel receipts;

9. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts,
canceled checks, utility, cable, and telephone bills, titles, registration documents, and other
documents;

10. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked;
hidden compartments that may contain any of the foregoing; and the contents thereof.

2
 Attachment K

ITEMS TO BE SEIZED
448 TUBMAN COURT, BALTIMORE, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #11")

1. Controlled substances, as well as paraphernalia used in the manufacture,

preparation, packaging, or weighing of illegal narcotics in preparation for distribution;

2. Records of narcotics transactions including, but not limited to, books,

ledgers, receipts, notes, pay and owe sheets, and other papers relating to the manufacture,
transportation, possession, and distribution of controlled substances or the receipt and
disposition of proceeds derived from the sale of illegal narcotics;

3. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to,
currency; financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s
checks and receipts for such checks; Western Union receipts; money orders; money order
receipts; credit card records; vehicle registrations; real estate records; income tax returns and any
documentation relating to the payment of any income tax; mail and contract mail carrier records;
documentation and receipts relating to any safe deposit boxes and keys to safe deposit boxes;
documentation and receipts relating to any storage facilities and keys to those storage facilities;
devices capable of counting large sums of currency; other items of value or proceeds derived
from the sale of illegal narcotics; and any other documents or evidence of financial transactions
involving the receipt and disposition of the proceeds of illegal narcotics sales;

4. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the
numbers and other data stored within those telephones; pagers and personal digital assistants,
and the numbers stored inside those devices; devices capable of recording incoming telephone
numbers, and the numbers stored within those devices; records of telephone calls, whether
recorded electronically or in writing; notes reflecting telephone and pager numbers, or papers
which reflect names, addresses, and telephone numbers of suspected co-conspirators;
photographs (to include still photos, negatives, movies, slides, video tapes, and undeveloped
film); and audiotape recordings of conversations, including those made over telephone
answering machines;

5. Two-way radios and police scanners;

6. Documents or other records relating to state court proceedings involving

other co-conspirators, including, but not limited to, charging documents and bail records;

7. Identification documents;

8. Records of travel including, but not limited to, tickets, transportation

schedules, passports, automobile rental records, notes and receipts related to travel, and

1
motel/hotel receipts;

9. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts,
canceled checks, utility, cable, and telephone bills, titles, registration documents, and other
documents;

10. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked;
hidden compartments that may contain any of the foregoing; and the contents thereof.

2
 Attachment L

ITEMS TO BE SEIZED
5 WOODBRIAR COURT, APARTMENT C, BALTIMORE, MARYLAND
AND ITEMS CONTAINED THEREIN ("SUBJECT PREMISES #12")

1. Controlled substances, as well as paraphernalia used in the manufacture,

preparation, packaging, or weighing of illegal narcotics in preparation for distribution;

2. Records of narcotics transactions including, but not limited to, books,

ledgers, receipts, notes, pay and owe sheets, and other papers relating to the manufacture,
transportation, possession, and distribution of controlled substances or the receipt and
disposition of proceeds derived from the sale of illegal narcotics;

3. Financial records and other records or documents reflecting narcotics-

trafficking activity or the disposition of narcotics proceeds, including, but not limited to,
currency; financial instruments; stocks; bonds; jewelry; precious metals; bank checks; cashier’s
checks and receipts for such checks; Western Union receipts; money orders; money order
receipts; credit card records; vehicle registrations; real estate records; income tax returns and any
documentation relating to the payment of any income tax; mail and contract mail carrier records;
documentation and receipts relating to any safe deposit boxes and keys to safe deposit boxes;
documentation and receipts relating to any storage facilities and keys to those storage facilities;
devices capable of counting large sums of currency; other items of value or proceeds derived
from the sale of illegal narcotics; and any other documents or evidence of financial transactions
involving the receipt and disposition of the proceeds of illegal narcotics sales;

4. Records that identify other co-conspirators, including, but not limited to:
address books; telephone books; rolodexes; telephone bills and records; telephones and the
numbers and other data stored within those telephones; pagers and personal digital assistants,
and the numbers stored inside those devices; devices capable of recording incoming telephone
numbers, and the numbers stored within those devices; records of telephone calls, whether
recorded electronically or in writing; notes reflecting telephone and pager numbers, or papers
which reflect names, addresses, and telephone numbers of suspected co-conspirators;
photographs (to include still photos, negatives, movies, slides, video tapes, and undeveloped
film); and audiotape recordings of conversations, including those made over telephone
answering machines;

5. Two-way radios and police scanners;

6. Documents or other records relating to state court proceedings involving

other co-conspirators, including, but not limited to, charging documents and bail records;

7. Identification documents;

8. Records of travel including, but not limited to, tickets, transportation

schedules, passports, automobile rental records, notes and receipts related to travel, and

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motel/hotel receipts;

9. Indicia of occupancy, residency, rental, control, and/or ownership of the

premises, including keys, photographs, deeds, mortgages, lease agreements, rental receipts,
canceled checks, utility, cable, and telephone bills, titles, registration documents, and other
documents;

10. Safes, combination or key-lock strong boxes or other secure storage

containers, suitcases, file cabinets and other types of containers, whether locked or unlocked;
hidden compartments that may contain any of the foregoing; and the contents thereof.

2
 Exhibit # 1

1. Based upon my training and experience and my participation in this and other
investigations, as well as my conversations with other agents, I know the following:

a. Gang members will often maintain and/or possess a roll call where they list the
gang name and then list the members’ names below. Roll call lists often include
dollar amounts that signify and track dues payments made by gang members at
meetings. They may also list the names of allies and rival gangs. Dues are used
to help certain gang members who are incarcerated for acts of violence and/or
drug trafficking post bail or obtain an attorney. They are also used to purchase
weapons or as a “tithe” to higher-ranking gang members.

b. Gangs use graffiti to mark their territory and graffiti can be used to disrespect or
make threats against rival gangs, by crossing out the rival gang’s graffiti, or “tag,”
and placing their own “tag.” “Tagging” is an activity where the participants
and/or gang adopt a unique written nickname known as a “tag.” Gang members
“tag” on public or private property and will often include the gang name in order
to show the gang’s area of control and their personal affiliation with the gang.
The writing of the “tags” results in the crime of destruction of property.
“Taggers” often write their friends’/fellow gang members’ names in tagging
scrapbooks. They also record their “tags” in these books and will cut out
newspaper articles on graffiti and put them in their scrapbooks. They often will
write their unique “tag,” nickname, and/or gang name on their personal property
to identify their property or to practice their tag. This personal property often
includes papers, sketchbooks, bedroom walls, backpacks, and other personal
items. They will sometimes try variations of their “tag” to see how it looks when
done differently. Gang members often possess many items such as spray-paint
and wide tip marking pens for this purpose.

c. Gang members will often maintain photographs, video recordings, clothing,

drawings, letters, notes, cards, or other correspondence which show their
association and/or membership with the gang as well as their relationship to other
members and associates of the gang. These videotapes and/or photographs
sometimes depict the gang members committing criminal acts, admitting to the
crimes, and making threats against rival gangs. The correspondence often
contains directives from more senior incarcerated gang members instructing
persons on the street to carry out various criminal acts and must be maintained by
persons on the street as their proof that they have the authority to commit certain
criminal acts. The correspondence also often includes discussions about criminal
acts committed on behalf of BGF. This correspondence constitutes evidence of
criminal acts committed in furtherance of the underlying criminal enterprise but
also documents the gang member’s association with that enterprise. Your affiant
also knows that gang members in this investigation have referred to and used the
Internet to contact other members. Your affiant knows that there are websites that
gang members use to establish profiles and to identify and locate other gang

1
 members.

d. Gang members keep in close contact with members of their gang as well as
members of allied gangs. They often maintain phone and address lists of their
associates. These lists will typically include the person’s nickname or “street
name” as well as their real name. Gang members have been known to use
beepers, cell phones, and two-way digital radios to keep in contact with each
other and to plan and advise about gang meetings. Gang members often
communicate with each other through letters, particularly when they are
incarcerated. Their letters sometimes detail criminal acts they have done as well
as referring to other gang members and disclosing their identities and crimes they
have committed.

e. Gangs, including BGF, have books or other documents that set forth the rules
and/or code of conduct for members of the gang. These books are distributed to
and maintained by gang members. BGF members are required to study, and are
tested on their knowledge of, these materials.

f. BGF members use prepaid credit cards as a means of financing the gang’s illegal
activities, and often maintain such cards and documents relating to such cards.

2. Based on participation in this investigation as well as discussions with other law

enforcement officers, I know that the type of documents and records described above are
typically found at the residences of gang members and that such evidence assists in
proving the allegiance of a particular individual to the gang. I am aware from search
warrants conducted in connection with this and other gang investigations that
document(s) that refer or relate to the individual’s membership in the gang are often
located among the individual gang member’s personal belongings.

2
 Exhibit #2

1. Based upon my training and experience and my participation in this and other
investigations, as well as my conversations with other agents, I know the following:

a. Narcotics traffickers often maintain on hand large amounts of both narcotics and
currency in order to maintain and finance their on-going narcotics business, as
well as paraphernalia used in the manufacture, packaging, preparation, and
weighing of illegal narcotics in preparation for trafficking, and narcotics
traffickers maintain these items where they have ready access to it.

b. Narcotics traffickers often maintain financial records and financial instruments

related to their narcotics transactions and the profits derived from those
transactions including, but not limited to, currency, bank checks, cashiers checks,
Western Union receipts, money orders, stocks, bonds, precious metals, and real
estate records;

c. Narcotics traffickers frequently maintain records of their narcotics transactions

including, but not limited to, books, ledgers, records and other documents relating
to the manufacture, transportation, possession, and distribution of controlled
substances. Such documents are frequently maintained where the traffickers have
ready access to them, including in their homes;

d. Narcotics traffickers commonly maintain books, records and other documents that
identify and contain the names, addresses and/or telephone or pager numbers of
associates in their narcotics-trafficking or money-laundering activities, including,
but not limited to: address books, telephone books, rolodexes, telephones, pagers,
or personal digital assistants with stored telephone information, notes reflecting
telephone and pager numbers, photographs (to include still photos, negatives,
movies, slides, video tapes, and undeveloped film), and audiotape recordings of
conversations, including those made over telephone answering machines;

e. Narcotics traffickers commonly maintain identification and travel documents,

including, but not limited to, tickets, transportation schedules, passports, notes
and receipts related to travel, and motel/hotel receipts;

f. Indicia of occupancy, residency and/or ownership of the premises to be searched

are often present in such premises;

g. Narcotics traffickers commonly maintain many of the foregoing items in

computer files; and

h. Narcotics traffickers commonly maintain the foregoing items inside combination

or key-lock safes or strong boxes, suitcases, locked cabinets and other types of
locked or closed containers, or hidden compartments, which are secreted in
locations such as the SUBJECT PREMISES, where they may maintain these

1
items securely.