Minni Criminal Complaint

Case 6:22-mj-00572-MJP Document 1 Filed 04/15/22 Page 1 of 30
AO 91 (Rev. 11/11) Criminal Complaint
UNITED STATES DISTRICT COURT

for the
Western District of New York
United States of America )

V. )
) Case No. 22-MJ-572
RAPLH MINNI )
)
)
)
Defendant(s)
CRIMINAL COMPLAINT
l, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of on or about May 2018 to April 2022 in the county of Monroe in the
Western District of ---------
New York , the defendant(s) violated:
Code Section Offense Description

Title 21, United States Code, Possession with the intent to distribute, and to distributed marijuana, a
Sections 841 (a)(1), (b)(1)(B). Schedule I controlled substance, and conspiracy and attempting to possess
(b)(1 )(C), and 846 with the intent to distribute, and to distribute, marijuana, a Schedule I
controlled substance, and 500 grams or more of cocaine, a Schedule II
controlled substance
This criminal complaint is based on these facts:
See the attached affidavit of USPS-OIG Special Agent Brendan M. Boone.
� Continued on the attached sheet.
Complainant's signature
Brendan M. Boone, Special Agent, USPS-OIG

Printed name and title
Sworn to telephonically by the affiant.
Date: April 15, 2022

Judge 's signature
City and state: Rochester, New York Hon. Mark W. Pedersen, U.S.M.J.
Printed name and title
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

STATE OF NEW YORK )
COUNTY OF MONROE ) SS:
CITY OF ROCHESTER )
I, Brendan M. Boone, being duly sworn, state as follows:
1. I am a Special Agent with the United States Postal Service (USPS), Office of
Inspector General (OIG), in Buffalo, New York, and have been so employed since April 2020.
Before my hiring with the USPS OIG, I was employed as a Special Agent with the United
States Secret Service assigned to the Washington, D.C. Field Office for over 3 years. My
current duties include investigating allegations of fraud, waste, and abuse in matters involving
the USPS. I am currently assigned to investigate allegations of mail theft committed by USPS
employees or contractors. I have completed the Criminal Investigator Training Program at
the Federal Law Enforcement Training Center in Brunswick, Georgia. I have also received
additional training covering various topics, including interviewing, legal issues, search
warrants, investigative techniques, and fraud investigations. I have received specialized
training regarding internal mail theft, mail processing, and schemes and techniques employed
by internal mail thieves. In the course of my law enforcement career, I have conducted or
participated in numerous types of investigations, including counterfeit United States currency,
financial crimes, embezzlement, identity theft, fraud, delay and destruction of mail, mail
theft, and narcotics.
2. This affidavit is made in support of a Criminal Complaint charging RALPH
MINNI (MINNI) with possession with the intent to distribute, and to distribute marijuana, a
Schedule I controlled substance, in violation of 21 U.S.C. §§ 84l(a)( l ) and (b)( l )(C), and
conspiracy to possess and attempt to possess with the intent to distribute, and to distribute,
marijuana, a Schedule I controlled substance, and 500 grams or more of cocaine, a Schedule
II controlled substance, in violation of 21 U.S.C. § 84l(a)( l ), (b)( l )(B), (b)( l )(C), and 846.
3. The facts set forth in this affidavit are based on my personal knowledge
obtained through my participation in this investigation, my review of Federal Bureau of
Investigation (FBI) affidavits submitted to this court, my review of reports and documents
prepared by the USPS OIG and FBI, my review of lawfully installed closed circuit television
(CCTV) cameras inside and around the Greece Branch Post Office (GPO), my review of
lawfully installed CCTV cameras inside MINNI'S office at the GPO, information obtained
from a global positioning system (GPS) device on MINNI'S vehicle, my review of
information obtained from internal USPS databases available to USPS OIG Special Agents;
my review of information from USPS OIG databases and reports, information obtained from
USPS employees, and knowledge obtained from other law enforcement agents involved in
this investigation. Because this affidavit is submitted for the limited purpose of establishing
probable cause for the requested warrant, this affidavit does not set forth all of my knowledge
regarding this matter. Rather, I have set forth only those facts I believe are necessary to
establish probable cause to show MINNI violated 21 U.S.C. § 84l(a)( l ), and 21 U.S.C. § 846.
SOURCES OF INFORMATION
4. The USPS OIG and the FBI Buffalo Division, Rochester Resident Agency have
conducted an investigation into the drug trafficking activities of MINNI and others known to
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this investigation. MINNI is the station manager of the GPO located at 3245 Latta Road,
Rochester, NY 14612 and has been employed by the USPS since 1998. The investigation to
date has revealed that MINNI is using his position and facilities for the purpose of obtaining
quantities of narcotics, and is then distributing the narcotics to other co-conspirators. The
investigation has also shown that MINNI has obtained narcotics directly through the USPS
mail stream and distributed the narcotics with the assistance of USPS employees and other
individuals. To this end, one of the USPS employees who has assisted MINNI is GRACE
LOPEZ (LOPEZ). Finally, the investigation has indicated that MINNI was supplied by an
unknown source in California and that MINNI may be supplying other postal employees
within the Western District of New York with narcotics.
INFORMATION RECEIVED FROM SOURCES
CONFIDENTIAL SOURCE ONE
5. Confidential Source One (hereinafter, "CS-1 ") has provided information to law
enforcement as an anonymous caller and concerned citizen. On February 24, 2018, the
Monroe County Public Safety Department received an anonymous tip regarding MINNI.
CS-1 advised MINNI resides at 12 Kimbrook Circle, Rochester, New York, and that he is
employed as a USPS manager. CS-1 also advised MINNI is Caucasian and that he owns a
black Chrysler 300 and a white Ford F lS0 Roush. CS-1 stated MINNI sells cocaine and
marijuana and that, specifically, he supplies it to an individual who in turn sells the narcotics.
An FBI Special Agent contacted CS-1 via telephone on or about June 11, 2018, and CS-I
confirmed all of the details he/she had provided over the internet tip site. Additionally, CS-
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1 advised the people who are involved in MINNI's narcotics business know him as "Joe" and
not as Ralph.
6. The FBI established the credibility of CS-1 through law enforcement databases,
surveillances, and other facts presented in this affidavit. My review of a USPS OIG database
confirmed MINNI is the station manager of the GPO in Greece, New York; Rochester, New
York Police Department reports obtained and reviewed by the FBI indicate MINNI has used
the name "Joe" when patronizing prostitutes in order to maintain confidentiality with his
family; at the time of CS-l's reporting, an FBI Special Agent queried the eJusticeNY
Integrated Justice Portal and determined MINNI was the registered owner of a black Chrysler
300 and a white Ford F l50 Roush. Law enforcement agents have observed both of these
vehicles parked in the driveway overnight at 12 Kimbrook Circle on numerous occasions.
Members of the investigative team began conducting physical surveillance in and around 12
Kimbrook Circle in May 2018 and have intermittently conducted physical surveillance in this
area through the present date. In June 2018, FBI agents initiated CCTV coverage in the area
of 12 Kimbrook Circle. This coverage has been viewed by the FBI on an almost daily basis
and has continued through the present date. In addition, my review of CCTV footage in and
around the GPO has confirmed MINNI utlizes a white Ford F l50 Roush pick-up truck on a
daily basis.
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CONFIDENTIAL SOURCE THREE
7. Confidential Source Three (hereinafter, "CS-3") has provided information to
the RFD and the ATP since May 29, 2018 and to the FBI since June 22, 2018. CS-3 continues
to cooperate with all three agencies. 1 The following is a summary of some of the information
provided by CS-3 to the investigative team regarding this investigation:
a. On May 29, 2018, CS-3 advised a member of the investigative team that
LOPEZ is an employee of the Henrietta USPS station2. CS-3 also stated LOPEZ told CS-3
she [LOPEZ] can obtain ten pounds of marijuana through the mail every day.
b. On August 9, 2018, CS-3 met with LOPEZ at LOPEZ's residence, 365
Rosewood Terrace, Rochester, New York. While at her residence, LOPEZ took CS-3 to her
garage and showed him/her a bullet proof vest and some kind of protective helmet. LOPEZ
told CS-3 that her friend at the post office told her that he knows he is being watched and that
he had given her these items to get rid of. LOPEZ also advised that her friend at the post
office had all of his guns shipped to an ex-girlfriend or ex-wife in Texas because he fears that
he is being watched. Further, LOPEZ stated that this same friend had just gotten a $30,000.00
shipment of narcotics. Finally, LOPEZ showed CS-3 that she had two pounds of marijuana
that she is selling for $1,900.00 per pound.
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CS-3 has pleaded guilty to a federal narcotics distribution charge and related federal firearms
charge, and has provided information to the RPD, the ATF, and the FBI in return for
consideration at sentencing. CS-3 also has a prior misdemeanor conviction for unauthorized
use of a motor vehicle. CS-3 has known LOPEZ for several years and has provided
information about her that has been corroborated by multiple sources and techniques. Since
the start of this investigation, CS-3 has also conducted 8 (eight) controlled purchases of
marijuana from LOPEZ and recorded the conversations with LOPEZ during and leading up
to these transactions. CS-3 has also conducted two (2) controlled purchases of firearms from
LOPEZ as well. For these reasons, your affiant believes CS-3 to be credible.
2
My review of a USPS OIG database confirms LOPEZ is a USPS employee, assigned
to the Rochester Processing and Distribution Center, 1335 Jefferson Road, Rochester, NY
since 2016.
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c. On August 24, 2018, CS-3 advised the FBI that "Ralph" is LOPEZ'S boyfriend
who works at the United States Post Office and provides her with quantities of marijuana to
sell. CS-3 advised "Ralph" is 48 years old and drives a pick-up truck.
d. On August 31. 2018, CS-3 recorded a conversation with LOPEZ in which
LOPEZ discussed the fact that l\1INNI is scared and has temporarily stopped distributing
narcotics. LOPEZ stated, "In December nothing happens to him I think he'll probably start
trying to like, he says a year, but I think the money pressure will get to him eventually where
he'll come back out." She then stated, "You got all that work and you can't move it. He's
stuck right now cause he's afraid." In the same conversation the following exchange occurred
between LOPEZ and CS-3:
CS-3: He's movin' it through the mail, huh?
LOPEZ: Thirty pounds or more at once. It wasn't under his name or anything.
He says they don't have anything. He donated- I went with him to the gun club - mad bullets.
At least $10,000.00 worth. It's all tactical, not deer hunting. Protecting himself.
e. On November 27, 2018, CS-3 met with LOPEZ and recorded the
meeting. During this meeting, LOPEZ and CS-3 discussed, among other things, the logistics
of receiving packages of narcotics. CS-3 asked LOPEZ how "Ralph" did it and she stated
that she never asked him how he did it. She stated further that if he got indicted, it wouldn't
affect her or her job. Later in the conversation, LOPEZ told CS-3 that he (meaning MINNI)
doesn't have friends in the "feds" but that MINNI was alerted casually. She explained that a
friend of MINNI'S was talking to some individuals who revealed that there was an
investigation on someone in the Greece Post Office. This friend in tum told MINNI and
MINNI said, "oh shit everything's cut the fuck off."
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f. On January 12, 2019, CS-3 contacted a member of the investigative
team and advised CS-3 spoke with LOPEZ, who told CS-3 MINNI had started selling
narcotics again. LOPEZ further told CS-3 that MINNI is trying to impress a new girl at the
post office and needs to get his money flowing again.
g. On January 28, 2019, CS-3 contacted a member of the investigative
team and advised LOPEZ had just used Face Time to show CS-3 a quantity of marijuana that
she had available to sell. The quantity was approximately one pound. She also advised that
the pound of marijuana was from MINNI.
h. On March 13, 2019, CS-3 contacted a member of the investigative team
and advised CS-3 had just spoken to LOPEZ and that LOPEZ told CS-3 that MINNI is
getting marijuana from California for $1,000.00 a pound.
1. On March 25, 2019, CS-3 met with LOPEZ and recorded the meeting. During
the meeting, CS-3 asked LOPEZ whether MINNI would meet directly with CS-3 for the
purpose of engaging in narcotics transactions. Among other things, LOPEZ stated, "He only
fuckin with the people he knows for sure wouldn't be out there, and that is after months and
months of not selling anything. He did almost ten months without selling anything." She
further indicated that MINNI would not be likely to introduce anyone "new to the circle."
J. On June 11, 2019, CS-3 contacted a member of the investigative team and
advised LOPEZ indicated to CS-3 that MINNI had just received a quantity of marijuana
through the mail and that they were ready to sell CS-3 pound quantities of marijuana.
k. On July 15, 2019, CS-3 contacted a member of the investigative team and
advised LOPEZ had just told CS-3 that MINNI had just received a fresh shipment of
marijuana and that MINNI is expecting CS-3 to make a purchase.
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1. On January 17, 2020, CS-3 contacted a member of the investigative team and
advised he/she had just communicated with LOPEZ. LOPEZ advised CS-3 that she and
MINNI want to buy a kilogram of cocaine from CS-3 and that they are considering giving
CS-3 an address to which CS-3 can have his/her suppliers ship the cocaine directly. LOPEZ
also advised that MINNI had just received four pounds of marijuana.
CONTROLLED PURCHASES
8. The controlled purchases that follow as described occurred between CS-3 and
LOPEZ. This investigation and the facts communicated in this affidavit have established that
although the purchases were made directly from LOPEZ, her source of supply for the
marijuana was :MINNI.
August 15, 2018

9. Paragraph 7(b) above describes a meeting between CS-3 and LOPEZ at
LOPEZ's residence, 365 Rosewood Terrace. During this meeting on August 9, 2018, LOPEZ
showed CS-3 two pounds of marijuana and told CS-3 that she is charging $1,900.00 per
pound.
10. On Wednesday, August 15, 2018, at the direction of the investigating team,
CS-3 contacted LOPEZ via telephone and arranged to meet her at her residence to purchase
a pound of marijuana. The investigative team conducted a surveillance and observed CS-3
arriving at 365 Rosewood Terrace. In and around the same time that CS-3 arrived at LOPEZ's
residence, a consensually monitored video device captured LOPEZ standing on the porch of
365 Rosewood Terrace. While at LOPEZ's residence, CS-3 purchased a pound of marijuana
from LOPEZ for $1,900.00. During this transaction, LOPEZ made the following statement,
"Let me connect with this dude today and give him the money and see what he says". After
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the transaction was complete, CS-3 departed the residence. Surveilling agents then observed
LOPEZ leaving her residence five minutes after the departure of CS-3. Pen register coverage
reviewed by the FBI of 585-831-2185, a phone number used by MINNI at the time of the
controlled purchase, indicated a series of three text messages between MINNI and 585-397-
2914 which were initiated within 20 minutes ofLOPEZ's departure from her residence. The
investigation had determined 585-397-2914 was a telephone number used by LOPEZ, as it is
the same number that CS-3 used to coordinate the purchase from LOPEZ. Following two
brief stops along the way, LOPEZ arrived at 12 Kimbrook Circle, exited her black Honda and
walked to the house. Approximately two hours later, CCTV coverage in the area ofMINNl'S
residence captured MINNI and LOPEZ exiting 12 Kimbrook Circle, entering MINNI'S
Chrysler 300, and departing the area.
11. On this same date, agents took custody of the marijuana from CS-3. It had a
total package weight of 1.65 pounds to include all packaging. It was leafy green in appearance
and smelled like marijuana.
May 11, 2019
12. On May 11, 2019, CS-3 contacted a member of the investigative team and
advised that he/she had just received a call from LOPEZ. LOPEZ told CS-3 that MINNI
has four pounds of marijuana ready for CS-3 to purchase once she gets out of work. LOPEZ
contacted CS-3 again and advised him/her that she wanted CS-3 to go to her house to make
the purchase because she already had the marijuana there. Agents met with CS-3 at
approximately 3:00 PM. on this date and directed him/her with detailed instructions how to
complete the controlled purchase with LOPEZ. Agents also put a recording device on CS-3
and provided him/her with $8,600.00 for the purchase. Each pound of marijuana was
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$1,900.00 and LOPEZ wanted an additional $1,000.00 for her role in securing MINNI as a
source of supply for the marijuana.
13. On May 11, 2019, at 3:10 p.m., agents initiated surveillance in the vicinity of
LOPEZ's residence, 365 Rosewood Terrace, Rochester, NY. At 3:24 p.m., agents observed
CS-3's vehicle tum into the driveway of 365 Rosewood Terrace. At 3:36 p.m., agents
observed CS-3's vehicle departing from 365 Rosewood Terrace. At 3:53 p.m., agents
observed LOPEZ departing the area in a black Chrysler 300 bearing New York plates FSX
26103 • At 4:22 p.m., agents observed this vehicle pulling into the driveway of 12 Kimbrook
Circle.
14. Continuing on May 11, 2019, members of the investigative team met with CS-
3 and took custody of the marijuana from CS-3. The marijuana was packaged in four
individually wrapped quantities and appeared to be a green and leafy substance with a strong
marijuana odor. The marijuana was packaged in Food Saver clear bags and had a total
package weight of 2.38 kilograms, which is approximately 5.23 pounds.
June 13, 2019
15. On June 11, 2019, CS-3 advised a member of the investigative team that he/she
had just spoken to LOPEZ and that LOPEZ and MINNI were ready to sell pounds of
marijuana to CS-3. CS-3 thought LOPEZ indicated that MINNI had just received six (6)
pounds in the mail.
16. On June 13, 2019, agents met with CS-3 and provided him/her with detailed
instructions on how to conduct the controlled purchase of four pounds of marijuana from
LOPEZ. Agents provided CS-3 with a body recorder and $8,600.00 for the purchase.
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On this date, this vehicle was registered to MINNI, 12 Kimbrook Circle.
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17. On June 13, 2019, at 3:45 p.m., surveillance was initiated in the vicinity of 365
Rosewood Terrace. At 4:23 p.m., agents observed CS-3's vehicle turning onto Rosewood
Terrace. At 4:46 p.m., agents observed CS-3's vehicle departing the vicinity of 365 Rosewood
Terrace. At 5: 10 p.m., LOPEZ was observed in her black Honda Accord leaving the vicinity
of 365 Rosewood Terrace. At 5:38 p.m., agents observed LOPEZ's vehicle parked in the
driveway of 12 K.imbrook Circle.
18. On June 13, 2019, agents met with and took custody of the marijuana from CS-
3. The marijuana was packed in four individual vacuum sealed Food Saver bags and enclosed
in a cardboard box. The picture and detailing of the cardboard box indicated that it had
originally contained an "Ion Sport" portable speaker. The marijuana appeared green and
leafy.
19. After a member of the investigative team reviewed CCTV footage from the
vicinity of 12 Kimbrook Circle, the following observations were made:
IDATE ITIME 'OBSERVATIONS
MINNI and LOPEZ arrived at 12 K.imbrook Circle in the black
Chrysler 300. MINNI retrieved a box from the trunk and they both
06/10/19 7:11 PM
walked to the front of the house. The box was identical to the Ion
Sport portable speaker box that the marijuana was contained in.
LOPEZ pulled into MINNI's driveway. MINNI exited his residence,

10:47 walked to his white F l 50 and gets a large brown box out of the back
06/11/19
AM driver's seat. He then returned to his residence through the side garage
door.
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21. On March 13, 2020, agents met with CS-3 and provided him/her with detailed
instructions regarding the controlled purchase of two pounds of marijuana from LOPEZ.
Agents placed a recording device on CS-3 and provided CS-3 with $4,600.00 for the purchase.
22. On March 13, 2020, surveillance was initiated in the vicinity of the Seneca Park
Zoo. Additionally, members of the investigative team were watching CCTV coverage of 12
Kimbrook Circle. At 4:53 p.m., LOPEZ exited MINNl's residence, 12 Kimbrook Circle,
carrying a brown box and entered her Honda Accord and departed from the residence. At
5:09 p.m., agents observed LOPEZ park her vehicle alongside CS-3's vehicle and enter the
vehicle. At 5:37 p.m., agents observed LOPEZ exit CS-3's vehicle and enter her Honda
Accord. At 5:45 p.m., agents observed LOPEZ departing the Seneca Park Zoo area. Upon
reviewing CCTV coverage after the surveillance was terminated, agents observed LOPEZ
arriving back at 12 Kimbrook Circle at 6:12 p.m. LOPEZ exited her vehicle and walked to
the residence with a dark bag.
23. On March 13, 2020, agents took custody of the marijuana from CS-3. The
marijuana was packaged in two clear Ziploc baggies inside of a brown cardboard USPS box.
The total package weight was 2.3 kilograms and the marijuana was green and leafy and had
a strong marijuana odor.

24. Members of the investigative team reviewed CCTV coverage in and around the
GPO from March 11, 2020, and observed the following:
9:08 a.m. l\11NNI carries what appears to be a white priority box into his office
and within a minute exits his office without the box.
9:09 a.m. l\11NNI returns to his office.
9:10 a.m. l\11NNI leaves his office with the white priority box.
9:13 a.m. MINNI returns to his office with an empty tan/brown box.
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9:14 a.m. MINNI leaves his office with a sealed tan/brown box. The box appears
to be identical to the one he had brought into his office that was empty.
9:14:51 a.m. MINNI carries the tan/brown box to his vehicle and places it in his
truck.
11 :00 a.m. MINNI departs the GPO in his truck.
25. An FBI Special Agent reviewed CCTV coverage from March 11, 2020, that
was recorded in the vicinity of 12 Kimbrook Circle, which showed MINNI arriving home at
11:04 a.m. and carrying a box to his residence. An FBI Special Agent also reviewed a pen
register on MINNI'S phone, 585-794-1681, from that same day and determined there were
six contacts, all of which were voice calls, between 585-794-1681 and LOPEZ's phone (585-
397-2914), from 7:06 am to 4:34 pm.
EVIDENCE OBTAINED FROM TRASH SEIZURES
26. On August 2, 2018, members of the investigative team seized trash placed at
the curb for collection from MINNI's residence, 12 Kimbrook Circle, Rochester, New York.
Among the items seized were the following: one "Shield N Seal" storage package with small
amounts of a green leafy substance which field tested positive for the presence of marijuana;
one empty "Shield N Seal" storage package that smelled like marijuana; one handwritten
ledger containing nine names and various numbers adjacent to each name.
27. On October 31, 2019, members of the investigative team seized trash placed at
the curb for collection at 12 Kimbrook Circle, Rochester, New York. Among the items seized
by agents were the following: one USPS Parcel Select Box; one USPS Priority Mail Envelope;
one UPS Express Pad Pak; one USPS Medium Box; one thin rectangular brown box; four
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FoodSaver clear rectangular storage bags that had been cut open; two Ziploc Vacuum Sealed
System clear bags that has been cut open; three smaller FoodSaver clear storage bags that had
been cut open. Based upon my training and experience and my knowledge of and
participation in this investigation, and the evidence collected above, I believe MINNI was
discarding marijuana packaging from marijuana shipments that MINNI received from his
supplier in the U.S. Mail stream. CCTV footage from the GPO as well as at MINNI'S
residence has often captured MINNI departing the post office with cardboard boxes and
arriving at his residence with boxes only minutes later.
28. On May 21, 2020, members of the investigative team seized the trash from 12
Kimbrook Circle, Rochester, New York. Among the items seized by the team were the
following: one cardboard shipping box; two FoodSaver clear freezer bags both of which had
a marijuana odor. Based upon my training and experience and my knowledge of and
participation in this investigation, and the evidence collected above, I believe MINNI was
discarding marijuana packaging from marijuana shipments that MINNI received from his
supplier.
MINNI DIVERTING A NARCOTICS PACKAGE AT THE GPO

29. On January 22, 2021, CS-3 conducted a controlled purchase of approximately
two (2) pounds of marijuana from LOPEZ. The meeting between LOPEZ and CS-3 was
consensually recorded. During the meeting, LOPEZ advised that she and Ralph [MINNI]
were traveling to California in June to meet with his supplier. LOPEZ stated Ralph is going
to grab "mad shit" during this trip. Furthermore, during this meeting, CS-3 told LOPEZ that
he/ she needed a way to move cocaine up to Rochester without losing it. In response, LOPEZ
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told the CHS that he/she could send the box to her house and that Ralph [MINNI] would
tell her if they are watching her.
30. On January 23, 2021, CS-3 contacted an FBI Special Agent via telephone and
advised that he/she had spoken to LOPEZ again about the shipment of cocaine through the
GPO. LOPEZ told CS-3 that Ralph [MINNI] is willing to have it shipped through his branch
station (the GPO) to provide a degree of protection once it arrives in Rochester. LOPEZ and
CS-3 agreed that LOPEZ and Ralph [MINNI] would get $5,000.00 for each shipment that
came through the GPO. LOPEZ further advised that she would be seeing Ralph [MINNI]
later in the day and would firm things up with him.
31. On January 25, 2021, CS-3 met with LOPEZ at her residence, 130 Afton Street,
Rochester, New York 14612, and recorded the meeting, reviewed by a member of the
investigative team. LOPEZ discussed how drug packages come through MINNI'S office, the
Greece Station, and how he grabs the packages from the station. She made it clear MINNI
does not have control over the drug package until it reaches his station but that once it reaches
his station there is no risk ofit being seized or of him getting caught in a sting by the inspectors.
She stated "Ralph's [MINNI'S] packages have gotten seized before. So, it doesn't have to do
with Ralph being able to have a set up where his packages don't specifically get seized. At
the end of the day, he has no control over any of this shit until the package gets to his station."
LOPEZ directed CS-3 to tell his/her suppliers to send the shipment of cocaine to her address
and mail destined for her residence goes through the GPO. She also told CS-3 to use either
"Richard Hampton" or'-----' Hampton as the addressee (Your affiant has purposely omitted
the second name LOPEZ provided because it is the name of her minor son). LOPEZ went
on to explain "Richard Hampton" is the name of the father of her child, and if anyone caught
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Ralph removing the package from the station, he [MINNI) could just say that he knew it was
going to LOPEZ (his girlfriend at the time) and that he was going to drop it off to her. LOPEZ
also made the following statement: "We were talking about whether there were other
addresses we could send it to because I was definitely not comfortable with mine but he
[MINNI] tried to make me feel safe about it, so. We were gonna say that if they seize the
package with my shit on it, I was gonna be like 'My baby's dad must uh, you know, doing
some crazy ass shit cause I don't know why he would put my son's, you know what I mean,
like some story we was gonna come up with." Finally, LOPEZ made the following two
statements: "My address goes to his station. The carrier we have on there, she's, she'd be like
'hey, here ya go'.", and "He's gonna grab it and bring it to me. Ralph is grabbing it from the
station."
32. On February 23, 2021, CS-3 and LOPEZ exchanged text messages in which
LOPEZ advised she was back in town, and CS-3 replying "Good, they dropping it in the mail
tonight." LOPEZ replied, "Perfect." That same day, at the direction of an FBI Special Agent,
an undercover employee mailed a box with an approximate total weight of 2 lbs 12 oz to'---
' Hampton, 130 Afton Street, Rochester, New York 14612. The package was described as a
cardboard box containing fake narcotics, specifically fake cocaine. These exchanges were
relative to the plan discussed in paragraphs 29 through 31 for shipping a package of cocaine
through the GPO to LOPEZ'S residence.
33. On February 25, 2021, the package of fake cocaine was delivered to the main
processing center in Rochester, New York and was then transported to the GPO. At 9:39
a.m., CCTV camera footage in and around the GPO captured MINNI take a box into his
office. At 9:48 a.m., LOPEZ entered MINNI'S office. At 9:49 a.m., MINNI and LOPEZ
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exited MINNI's office, with LOPEZ now carrying the box. At 11:14 a.m., LOPEZ pulled
her vehicle alongside CS-3's vehicle at the Fastrac, 375 West Ridge Road, Rochester, New
York 14615. LOPEZ then entered CS-3's vehicle. At 11: 18 AM, LOPEZ exited CS-3's
vehicle and departed. At 11 :24 AM, a member of the investigative team took possession of
the box from CS-3. This box was the identical box shipped by the undercover employee from
Los Angeles on Febuary 23, 2021. The meeting between CS-3 and LOPEZ was recorded and
reviewed by a member of the investigative team. During the meeting, CS-3 paid LOPEZ
$5,000.00 and LOPEZ provided the box to CS-3. As soon as she [LOPEZ] entered CS-3's
vehicle she stated the following, "I am fucking pissed not only that but there is two (2) in there
and not one (I) and he knows that shit. Don't do that, I'm dead ass fucking serious. You told
me one (1), that's what I told him. That's the risk he was willing to take. He was like, 'this
is not one, Grace.' He wants me and him to get paid $5,000.00. And he don't like the way
you packaged it." Based on my training and experience, and my knowledge of and
participation in this investigation, I believe that LOPEZ's statements about how there were
"two in there and not one", and that LOPEZ and MINNI were expecting "one," "one
and "two" refer to one and two kilograms of cocaine.
MINNI'S CONTINUED USE OF THE GPO TO FURTHER NARCOTICS

ACTIVITIES
34. As described above, MINNI has been observed on numerous occasions
throughout this investigation at the GPO via CCTV footage removing packages from the post
office floor and taking them into his assigned office. Later, he emerges with a package -
sometimes one that appears to have been repackaged- and takes the item to his personal
18
vehicle in the GPO parking lot before departing the GPO in his vehicle immediately or shortly
thereafter. There is no apparent legitimate business reason for these actions, and postal
records show that on days referenced below when l\1INNI engaged in this conduct, no parcels
were being delivered to l\1INNl'S residence. l\1INNI'S residence falls within the delivery
responsibilities covered by the GPO.
35. On May 15, 2021, CCTV in the vicinity of the Greece Station captured MINNI
taking a priority box into and out of his office. Further, it appeared that the box was wrapped
in a white plastic bag. The FBI's review of the GPS tracker on MINNI's vehicle indicated
MINNI arrived at the GPO at 6:24 AM and returned to 12 Kimbrook Circle directly from the
GPO at 9:54 AM. Later that morning, CCTV in the vicinity of 12 Kimbrook Circle and
captured MINNI returning to his residence at 9:54 AM. MINNI retrieved a package from
the rear compartment of his vehicle an took it to his residence. The package consisted of a
white plastic bag with a solid object inside which appeared to be a rectangular box. On May
16, 2021, at 3:21 PM, a black Chevy Avalanche identical to one driven by a known co
conspirator arrived at 12 Kimbrook Circle. The white male driver, believed to be the known
co-conspirator, walked to the house. At 3:38 p.m., l\1INNI and the co-conspirator, carrying
a white bag, walked to the driveway where upon the white bag was put into the driver's
compartment of the Avalanche prior to departing. Based upon my participation and
knowledge of the investigation, I believe MINNI secured a package containing narcotics from
the GPO on May 15, 2021. MINNI then transported the package to his residence and on May
16, 2021, MINNI conducted a narcotics transaction with a co-conspirator at his residence.
36. On January 20, 2022, at 7:27 a.m., CCTV coverage in the GPO captured
MINNI carrying a white box from the delivery floor into his office. Over the next few hours,
19
MINNI enters and exits his office, sometimes empty handed, and at least twice (at 9: 19 a.m.
and 10:08 a.m.) entered his office carrying what appeared to be flattened cardboard. At 10:30
a.m., MINNI exited his office carrying a white box. MINNI walked to his vehicle with the
white box and at 10:31 a.m., placed the box inside his vehicle. MINNI then returned inside
to the GPO at 10:32 a.m. Later, at 1:33 p.m., MINNI entered his vehicle and subsequently
drove away. A member of the investigative team reviewed CCTV coverage in the vicinity of
12 Kimbrook Circle and observed MINNI returning to his residence at 3:27 p.m. MINNI
retrieved a white box from the rear driver's side compartment of his vehicle and walked to the
house. Based upon my participation and knowledge of the investigation, I believe MINNI
secured a package containing narcotics from the Greece Station on January 20, 2022. MINNI
then used his vehicle to transport the narcotics back to his residence.
37. On February 16, 2022, at 6:47 a.m., CCTV coverage in the vicinity of the GPO
captured MINNI carrying a white box from the workroom floor into his office. At 6:53 a.m.,
MINNI exited his office with a white box and at 6:55 a.m., MINNI returned to his office
without the white box. At 10:38 a.m., MINNI entered his office with what appeared to be a
flattened white box. At 11:53 a.m., MINNI exited his office with a closed white box. At 11:54
a.m., CCTV coverage captured MINNI carrying a white box next to his vehicle in the GPO
parking lot. At 11:55 a.m., the MINNI'S vehicle departed the GPO. At 12:45 p.m., CCTV
coverage in the vicinity of 12 Kimbrook Circle captured MINNI returning home in his Ford
F150 Roush. MINNI exited his vehicle and opened the rear driver side compartment door
and retrieved a white box and brought it to his residence. Based upon my participation and
knowledge of the investigation, I believe MINNI secured a package containing narcotics from
20
the GPO on February 16, 2022, and used his vehicle to transport the narcotics back to his
residence.
OBSERVATIONS WITIDN MINNI'S OFFICE INSIDE THE GPO
38. On February 28, 2022, and pursuant to court order, a CCTV camera was
lawfully installed by members of the investigative team inside MINNI'S assigned office at the
GPO. On March 31, 2022, the court order was reissued and a second CCTV camera was
lawfully installed inside the MINNI'S office. CCTV footage obtained from the camera system
revealed numerous instances of MINNI opening boxes obtained from the USPS mail stream
and, at times, removing suspected narcotics from the package(s). CCTV camera footage also
captured MINNI supplying USPS employees with user quantity amounts of suspected
narcotics.
39. On March 1, 2022, at 7:32 a.m., CCTV coverage captured MINNI and a male
USPS employee ("Employee 1 ") inside MINNI'S office. MINNI, holding a clear plastic bag,
removed a small, white, rock-like object from the bag and placed the item onto his desk.
Employee 1, using a credit card or similar object, divided the white rock into three sections
and slid two pieces to MINNI. MINNI put the pieces into a small, folded sheet of paper and
placed the paper containing the substance in front of Employee 1. MINNI proceeded to tie
the clear plastic bag and, after doing so, appeared to place the bag into the right breast pocket
of his sports coat. Employee 1 crushed the remaining white substance into a powder and
formed the powder into a line. Employee 1 leaned over the line and appeared to ingest the
white powdery substance through his nasal cavity. Employee 1 took possession of the
aforementioned piece of paper and MINNI brushed off the remaining white powder from his
21
desk using his hand. Based upon my participation and knowledge of the investigation, I
believe MINNI possesed on his person a quantity of narcotics, some of which he provided to
Employee 1. Furthermore, the white substance was prepared and used by Employee 1 in a
manner consistant with the use of powder cocaine.
40. On March 7, 2022, at 6:54 a.m., CCTV coverage in the vicinity of the GPO
captured MINNI remove, and at 6:55 a.m. walk away with, a large brown box from a USPS
mail container on the workroom floor. CCTV coverage from inside MINNI'S office showed
MINNI move a large box underneath his desk and out of camera view. After the office lights
were turned on, MINNI sat in a chair and put on work gloves. MINNI leaned and reached
under his desk, appearing to manipulate the box out of sight. MINNI eventually pulled the
box from under the desk and partially into camera view. MINNI opened the top of the box
and pulled out approximately seven separate bundles enclosed in black wrapping. MINNI
placed each bundle into or around filing cabinets next to his desk, and soon after departed his
office and returned with two stacks of USPS Priority Mail cardboard envelopes that appeared
to be new and unused. MINNI placed a majority of the cardboard envelopes into the rifled
brown box, and secured the box with brown packaging tape. At 7:05 a.m., MINNI departed
his office with the brown box. Between 7:10 a.m. and 7:13 a.m., MINNI brought into his
office two empty brown boxes. MINNI opened the filing cabinet drawers and divided the
previously mentioned black wrapped bundles into the two brown boxes. MINNI sealed each
box with tape and departed his office with both boxes. At 7:19 a.m., CCTV coverage in the
vicinity of the GPO captured MINNI place both boxes in the rear compartment of his vehicle.
Based upon my participation and knowledge of this investigation, I believe MINNI was
removing narcotics from a box he had taken from the floor of the GPO. MINNI exercised
22
caution while opening the box by wearing gloves, opening the box on the floor behind his
desk, and concealing the contents of the box inside and around filing cabinet drawers.
41. Continuing on March 7, 2022, a member of the investigative team reviewed
CCTV footage in the vicinity of MINNI'S residence. At 10:50 a.m., MINNI returned to the
home in his vehicle. MINNI removed two brown boxes from the rear driver's side
compartment and took them to his house. At 4:32 a.m., a white Chrysler 200, identical to one
driven by a suspected co-conspirator, arrived. The white male driver exited the vehicle and
walked to the house. At 4:35 p.m., the driver returned to the vehicle and departed. As
described in paragraphs 26 through 28, multiple trash seizures from MINNI'S residence
throughout the course of the investigation yielded discarded storage and vacuum sealed bags
indicative of packaging used to ship and transport quantities of marijuana. Controlled
purchases made from LOPEZ, who in tum was supplied by MINNI, has returned quantities
of marijuana packaged in similar storage bags. A trash seizure on October 31, 2019, also
yielded numerous boxes, to include USPS and UPS containers, a USPS priority mail
envelope, and storage bags which appeared to be cut open. CCTV footage from the GPO as
well as at MINNI's residence has captured MINNI departing his office and the GPO with
cardboard boxes and subsequently arriving to his residence with boxes. I believe on March 7,
2022, based upon my experience and knowledge and my knowledge of and participation in
this investigation, MINNI removed a box containing narcotics, likely marijuana, from the
GPO work room floor and brought it to his office. Furthermore, I believe MINNI removed
the narcotics from the box and repackaged the narcotics into two separate boxes before
removing the packages from the GPO and transporting them to his residence for eventual
dispersal.
23
42. On March 12, 2022, at 8:02 a.m., CCTV coverage captured MINNI and a male
USPS employee4 (Employee 2) inside the Target Location. MINNI reached into a desk
drawer and pulled out a small piece of paper. Employee 2 removed from his wallet what
appeared to be a green plastic card and later one currency note. MINNI untied a small clear
plastic bag containing a white substance, reached inside, and placed an unseen object into the
small piece of paper before Employee 2 took possession of the tom paper. MINNI again
reached into the clear plastic bag and removed a small white rock substance, placing it in front
of Employee 2 on the desk. MINNI retied the clear plastic bag which still appeared to contain
a white substance, and placed the bag into his right front pants pocket. Employee 2 folded the
piece of paper and placed it into his wallet. Using the currency note, Employee 2 covered the
white rock substance and with the plastic card appeared to crush the item. Once the note was
removed, Employee 2 formed the now white powdery substance into a line with the plastic
card. Employee 2 rolled the currency note, leaned over the white powder line, and appeared
to ingest the substance through his nasal cavity on two occasions seconds apart. Based upon
my participation and knowledge of the investigation, I believe MINNI possessed on his
person a quantity of narcotics, some of which he provided to Employee 2. Furthermore, the

white substance was prepared and used by Employee 2 in a manner consistent with the use
of powder cocaine.
captured MINNI remove, and walk away with, a white box from a USPS mail container on
the workroom floor. MINNI entered his office with the box at 7:29 a.m.. At 7:30 a.m., CCTV
coverage from inside MINNI'S office showed MINNI wearing work gloves and appearing to
4
The male subjects denoted as "Employee l " and "Employee 2" are separate employees.
24
manipulate an item underneath his desk and out of camera view. At 7:31 a.m., MINNI
brought into camera view a plastic accordion style binder. MINNI untied a cord in front of
the binder and pulled from the container what appeared to be white cardboard or paper
wrapped in clear plastic and enclosing a pliable material. MINNI placed the object into the
middle drawer of a filing cabinet next to his desk. At 7:33 a.m., MINNI, back at his desk,
brought into camera view what appeared to be an empty USPS priority mail Tyvek envelope.
MINNI then folded and again placed the envelope underneath his desk. Continuing at 7:33
a.m., MINNI retrieved a roll of clear tape from a previously opened desk drawer and
continued to manipulate the unseen item underneath his desk. At 7:34 a.m., MINNI reached
underneath his desk and brought into camera view a closed, white, USPS priority mailbox,
which MINNI departed the office with. At 7:35 a.m., CCTV coverage in the vicinity of the
Greece Station captured MINNI place the white box into or around the same USPS container
on the workroom floor the mailing was earlier removed from.
43. A short while later, at 9:13 a.m., CCTV footage from inside MINNI'S office
captured MINNI holding an empty black and white box. MINNI proceeded to open the
middle drawer of the filing cabinet located next to his desk and reach inside. MINNI, while
turned away from the CCTV camera, appeared to remove a white object from the middle
drawer and place the item inside the black and white box resting at his feet. MINNI then
turned in his chair and placed the now-closed black and white box onto his desk. MINNI
retrieved a roll of clear tape from his desk drawer and sealed the top of the box with a strip of
tape. At 9:14 a.m., MINNI departed his office carrying the box. At 9:15 a.m., CCTV footage
in the vicinity of the GPO captured MINNI place the black and white box into the rear
compartment of the white Ford FISO Roush. Based upon my participation and knowledge
25
of this investigation, I believe MINNI removed a box containing narcotics from the floor of
the GPO and took it to his office to repackage, and eventually remove from, the GPO.
MINNI again exercised caution when handling the box by wearing gloves, manipulating the
box on the floor behind his desk, and initially concealing the contents of the box inside a filing
cabinet drawer.
44. Continuing on March 25, 2022, a member of the investigative team reviewed
CCTV footage in the vicinity of MINNI'S residence. At 12:06 p.m., a male co-conspirator
arrived to the home in a gray Dodge Ram pick-up truck. At 12:08 p.m., MINNI arrived to
the residence in his vehicle. MINNI exited the white Ford 150 Roush and removed a black
and white box from the rear compartment. The aforementioned box appeared to the be the
same box earlier observed in MINNI'S office. MINNI handed the box to the male subject
while standing in the driveway. The co-conspirator secured the box in the rear compartment
of his vehicle, before he and MINNI walked to the residence. At 12: 12 p.m., MINNI and the
co-conspirator returned to their respective vehicles and departed.
captured MINNI remove, and walk away with, what appeared to be a white USPS priority
mailbox from a USPS mail container on the workroom floor. MINNI entered his office
carrying the white box. CCTV footage from inside MINNI'S office showed MINNI place the
white USPS priority mailbox underneath his desk and out of camera view. At 7:34 a.m.,
MINNI donned work gloves and appeared to manipulate the box while leaning forward in
his chair and with MINNI'S hands under the desk. At 7:36 a.m., MINNI placed a knife or
boxcutter type object onto his desk, removed the work gloves, and turned his attention
towards his laptop computer as a USPS employee entered the doorway of the office. Shortly
26
thereafter, MINNI departed the office and returned at 7:40 a.m.. At 7:41 a.m., MINNI
brought into camera view an object which appeared to be enclosed in a clear plastic bag and
placed it into the drawer of a filing cabinet to the left of his desk. At 7:42 a.m., after :MINNI
placed a roll of tape and the work gloves into a desk drawer, MINNI reached under his desk
and brought into camera view a closed USPS priority mail box. :MINNI departed his office
with the box seconds later. At 7:43 a.m., CCTV coverage in the vicinity of the GPO
workroom floor captured MINNI place the priority mailbox into a USPS container. Based
upon my participation and knowledge of this investigation, , I believe MINNI removed a box
containing narcotics from the floor of the GPO and took it to his office to repackage, and
eventually remove from, the GPO. As in prior instances, :MINNI exercised caution when
handling the box by wearing gloves, manipulating the box on the floor behind his desk, and
storing contents removed from the box into a filing cabinet drawer. MINNI hurriedly ceased
all activity and removed his gloves when he was alerted an employee was passing by or near
his office.
46. At 7:48 a.m., CCTV footage from inside MINNI'S office captured :MINNI
enter the office carrying an empty brown box and open at the top. MINNI reached into the
middle drawer of the aforementioned filing cabinet and retrieved the object enclosed in clear
plastic. MINNI placed the item into the brown box, closed the top, and using a roll of clear
tape, sealed the box. At 8:02 a.m., MINNI carried the sealed brown box out of his office. At
8:03 AM, CCTV footage captured MINNI entering the white Ford F150 Roush while in
possession of the brown box before departing camera view.
27
47. Continuing on March 26, 2022, at 8:07 a.m., CCTV footage in the vicinity of
MINNI'S residence captur<:!d :MINNI returning home in his vehicle. :MINNI exited the
vehicle with a brown box and took it to his residence.
48. On April 2, 2022, at 7:24 a.m., :MINNI and Employee 1 are observed on CCTV
footage inside MINNI'S office. MINNI, sitting in his chair, reached into his front right pants
pocket, and removed and untied a clear plastic bag containing a white substance, and
subsequently placed the bag onto the office desk. MINNI retrieved a plastic straw from his
desk drawer and gave it to Employee 1, who sat in a chair opposite from MINNI. Employee
1 cut the straw with scissors and removed from his wallet a plastic card similar to that of a
credit card. :MINNI removed from the plastic bag a white powdery substance and placed it in
front of Employee 1. :MINNI re-tied the plastic bag and placed it back into his right front
pants pocket. Employee 1 used the plastic card to separate the white powder into two piles,
with one pile being formed into a line. Employee I leaned over the line of white powder, and
using the plastic straw, appeared to ingest the substance through his nasal cavity. Employee
1 swept the remaining white powder from the desk into a small piece of paper, folded it, and
placed it into his wallet. MINNI and Employee 1 departed the office together at 7:30 a.m.
Based upon my participation and knowledge of the investigation, I believe :MINNI possesed
on his person a quantity ofnarcotics, some of which he provided to Employee 1. Furthermore,
the white substance was prepared and used by Employee I in a manner consistant with the
use of powder cocaine.
28
CONCLUSION
49. Based upon the foregoing, I respectfully submit that there is probable cause to
believe that between in or about May 2018 and in or about April 2022, RALPH MINNI
possessed with the intent to distribute, and distributed marijuana, a Schedule I controlled
substance, in violation of 21 U.S.C. §§ 84 l (a)(l ) and (b)(l )(C), and conspired with others to
possess and attempt to possess with the intent to distribute, and to distribute, marijuana, a
Schedule I controlled substance, and 500 grams or more of cocaine, a Schedule II controlled
substance, in violation of 21 U.S.C. § 841(a)( l), (b)(l)(B), (b)(l )(C), and 846.
/z=.:-::-e_.c_, �_ -------
Special Agent, United States Postal Service,
Office of Inspector General
Affidavit submitted electronically by email in .pdf format. Oath administered,

and contents and signature, attested to me telephonically pursuant to
Fed. R. Crim. P. 4.1 and 4(d) on April 15, 2022.
HON. MARK W. PEDERSEN

United States Magistrate Judge
29

Minni Criminal Complaint

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Case 6:22-mj-00572-MJP Document 1 Filed 04/15/22 Page 1 of 30

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

United States of America )

Code Section Offense Description

This criminal complaint is based on these facts:

See the attached affidavit of USPS-OIG Special Agent Brendan M. Boone.

� Continued on the attached sheet.

Brendan M. Boone, Special Agent, USPS-OIG

Sworn to telephonically by the affiant.

Date: April 15, 2022

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Brendan M. Boone, being duly sworn, state as follows:

employees or contractors. I have completed the Criminal Investigator Training Program at

warrants, investigative techniques, and fraud investigations. I have received specialized

participated in numerous types of investigations, including counterfeit United States currency,

theft, and narcotics.

2. This affidavit is made in support of a Criminal Complaint charging RALPH

obtained through my participation in this investigation, my review of Federal Bureau of

from a global positioning system (GPS) device on MINNI'S vehicle, my review of

within the Western District of New York with narcotics.

INFORMATION RECEIVED FROM SOURCES

CONFIDENTIAL SOURCE ONE

vehicles parked in the driveway overnight at 12 Kimbrook Circle on numerous occasions.

CONFIDENTIAL SOURCE THREE

7. Confidential Source Three (hereinafter, "CS-3") has provided information to

provided by CS-3 to the investigative team regarding this investigation:

b. On August 9, 2018, CS-3 met with LOPEZ at LOPEZ's residence, 365

that she is selling for $1,900.00 per pound.

d. On August 31. 2018, CS-3 recorded a conversation with LOPEZ in which

between LOPEZ and CS-3:

CS-3: He's movin' it through the mail, huh?

MINNI said, "oh shit everything's cut the fuck off."

f. On January 12, 2019, CS-3 contacted a member of the investigative

post office and needs to get his money flowing again.

g. On January 28, 2019, CS-3 contacted a member of the investigative

the pound of marijuana was from MINNI.

h. On March 13, 2019, CS-3 contacted a member of the investigative team

getting marijuana from California for $1,000.00 a pound.

marijuana and that MINNI is expecting CS-3 to make a purchase.

marijuana was :MINNI.

August 15, 2018

investigation had determined 585-397-2914 was a telephone number used by LOPEZ, as it is

Chrysler 300, and departing the area.

and smelled like marijuana.

May 11, 2019

source of supply for the marijuana.

package weight of 2.38 kilograms, which is approximately 5.23 pounds.

June 13, 2019

pounds in the mail.

driveway of 12 K.imbrook Circle.

vicinity of 12 Kimbrook Circle, the following observations were made:

IDATE ITIME 'OBSERVATIONS

MINNI and LOPEZ arrived at 12 K.imbrook Circle in the black

LOPEZ pulled into MINNI's driveway. MINNI exited his residence,