A 0 91 (Rev. 12/93) Case 1:05-mj-00142-MPT Criminal Compiaint II
Document 6
Filed 01/03/2006
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United States District Court
DISTRICT OF
--UNITED STATES OF AMERICA
v.
DEMETRIUS BROWN
(Name and Addrsss of Defendant)
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Criminal Complaint 6 WZH- N PT
I, the undersigned complainant, being duly sworn, state the following is true and correct to the best ofmy knowledge and belief. On or about December 14,2005, in New Castle County, in the District of Delaware defendant, ~
r a c k ~ t ~ h ~ t ~ ~ ~ ~ ~ ~ ~
did knowingly possess with intent to distribute a controlled substance in violation of Title
21
United States Code, Section(s) 841(a)(l) and that this complaint is based
W~cial TiUs
I further state that I am a(n) Task Force Officer. Drug Enforcement Administration
on the following facts: SEE ATTACHED AFFIDAVIT Continued on the attached sheet and made a part hereof: YES
Task Force Officer Drug Enforcement Administratio
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I F -J . i 1
Sworn to before me and subscribed in my presence, December 23.2005
'Date
.at
. Honorable Kent A. Jordan
United States District Judge
Name & Title of Judicial Officer
Case 1:05-mj-00142-MPT
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AFFIDAVIT
Your affiant, Detective Thomas P. Looney, of the Wilmington Police Department, does solemnly swear that:
A
1.
1 am a sworn 'l'ask Force Officerind
a member of the Drug Enforcement
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Administration Task Force. I am also a sworn member of the Wilmington Police Department and have been so employed for approximately sixteen years. I have attained the rank of Master Corporal and have been assigned as a detective to the Wilmington Police Department's Drug, Organized Crime and Vice Division for a total of approximately eight years. During the course of my law enforcement career, I have participated in several hundred criminal investigations involving violations of Delaware narcotic laws, which led to arrests, convictions and seizures of narcotics and proceeds gained fiom illegal activity. I have attended numerous schools and seminars specifically dealing with narcotic investigations including identification of controlled substances as well investigative techniques for dealing with drug traffickers. 2. The information contained in this affidavit is based on both my personal
knowledge as well as information provided to me by other law enforcement officers who participated in this investigation. This affidavit is submitted in support of a criminal complaint against Demetrius BROWN.
3.
On December 14,2005, members of the Wilmington Police Department's Drug,
Organized Crime and Vice Division were conducting surveillance in the 2200 block of North Pine Street located in the City of Wilmington, Delaware. During the course of surveillance, Detective Charles Emory observed an individual known to law enforcement officers (LEO'S) as Demetrius BROWN standing in the middle of the block on the west side of the street engaging in activity consistent with hand to hand drug transactions. BROWN w a observed to meet with
Case 1:05-mj-00142-MPT
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Filed 01/03/2006
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approaching individuals for brief periods of time during which he appeared to hand something, believed to be controlled substances, to those individuals in exchange for what appeared to be
US currency, During some of these suspected transactions, BROWN was observed walking
-_________ __ _ - _- __ behind a trash can toretrieve what was believed to be controlled substances before returning to
consummate the suspected drug transaction. During surveillance, BROWN was also observed getting in and out of a blue Ford Crown Victoria parked in the vicinity on several occasions.
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-ilmington,
At approximately 8:30pm, BROWN was observed entering a residence located at Delaware. At approximately 958,BROWN was observed
exiting the residence and proceeding to enter the driver seat of the blue Ford Crown Victoria which then began to depart the area. Pursuant to a check of Delaware Motor Vehicle records, LEO'S had prior knowledge that BROWN did not have a valid Drivers License and initiated a traffic stop at 23rd and Spruce Streets in the City of Wilmington. Wilmington Police.Detective Daniel Silva approached the vehicle and observed BROWN in the driver seat and a second individual, identified as Larry LEE, in the passenger seat. BROWN'S right hand was on the steering wheel and Detective Silva observed a clear plastic bag containing an off-white rock like substance protruding from the cuff of BROWN'S right sleeve. BROWN was asked to step out of the vehicle and upon doing so BROWN dropped the clear plastic bag to the ground. Detective Silva retrieved the clear plastic bag which contained numerous pieces of an off-white rock like substance believed to be cocaine base and commonly referred to as crack cocaine. Your affiant field tested the substance which indicated positive for the presence of cocaine with a total approximate weight of 5 gross grams. BROWN was arrested and charged with violations of Delaware's Controlled Substance laws.
WHEREFORE, based upon the above-stated facts and your affiant's training,
Case 1:05-mj-00142-MPT Document 6 Filed 01/03/2006 Page 4 of 4 Demetrius BROWN has committed the crime of knowingly possessing with the intent to
distribute a mixture or substance containing a detectable amount of cocaine base, a schedule 1 , 1 controlled s u b s t ~ ~ i n v i o l a t i o n21 U.S.C. & 841(a)(l). In iight thereof, your affiant of respectfully prays that a criminal complaint be issued.
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