Free Opening Brief in Support - District Court of Delaware - Delaware

Case 1:06—cv—00009-GI\/IS Document 15-6 Filed 05/08/2006 Page 1 013
EXHIBIT D

Mar EB ’ 6 11 = 27 FR Tu 13@25'?3622u P. B2
_, Case 1 :06-cv-00009-Gl\/IS Document 15-6 Filed 05/08/2006 Page 2 of 3
Declaration of Chris Quaglino
_ 1. My name is Chris Quaglino. Ihave been employed as an agent with the Drug
Enforcement Administration f"DEA") since March 8, 1992.
2. I submit this declaration in support of my motions for summary judgment in the
matters of Write v. Marzec, C. A. No. 06-008-KA] (D. Del.) and Wearherspoou v. Mdrzec, C.A.
No. 06-009-KA] Del.),
3- In the summer of 2005, in my capacity as a DEA agent, I had ltnowledge of an
···· ·· investigation into··p·ossibl·e·illegal"rtarcoticstdeaiing ‘by‘Steve I=Ii‘cltm‘an1‘ “ "‘ ‘ ‘ ‘ ‘ ‘ " ‘ ‘ " ‘ ‘
4. In connection with the I·Iiclr.man investigation, on September 21, 2005, I helped
execute a search warrant of a trailer located at 9008 Greentop Road in Sussex County, Delaware-
Agents Ronald Marzec, Tom Jacobs and others assisted me in executing the search warrant. .
5. While we were executing the search warrant, Marzec, Jacobs and I all wore
. clothing that was prominently inscribed with either "Police" or "DEA.°’
6. When Marzec, Jacobs and I arrived at the trailer located at 9008 Greentop Road
_ on September 21, 2005 to execute the search warrant, Hickman was standing outside the
residence with other unidentified individuals. °
7. At that time, Marzec, Jacobs and I identified ourselves as police officers and
advised I-Iiclcman that we were going to execute a search warrant for his residence.
8. Shortly thereafter, two female adults exited the trailer, who identified themselves
as Sandra White and Tawanda Weatherspoon- Marzec, Jacobs and I again identified ourselves as
police officers and advised White and Weatherspoon that we were going to execute a search
warrant for the residence. I
9. Prior to that time, neither Matzec, Jacobs, I nor anyone else had entered the

MQY E1EI ’ @15 11 = 27 FR _ TD l3@25'?3522E P. @3
_ _ r, Case 1 :06-cv-00009-GI\/IS Document 15-6 Filed 05/08/2006 Page 3 of 3
trailer. I-Iickman, White and Weatherspoon were all detained during the search of the trailer.
Although I and others had our guns drawn during -the initial entry into the trailer, as is customary
while executing a search warrant involving possible illegal narcotics dealing, at no time did I or
anyone else point our guns at White or Weatherspoon. I and others entered the trailer through an
unlocked door; We did not force entry. ‘ I l
10. Under these circumstances, to formally knock and announce after Hiclcman, I
I White and Weatherspoon were already outside the trailer would have served no purpose.
.. . . ..... . . Marzec, .lacobs___and.I identitied.ourse12· the trailer.
In accordance with 28 U-S-C. ’ l'/46, I declare under penalty of perjury that the foregoing is true
and correct to the best of my knowledge and belief.
Dated this Sth day of May, 2006.
Chris Quaglino 4 E
was TUTFII. P•=1oE.12a3 was