Free Complaint - District Court of Delaware - Delaware

Case 1:07-cr-00109-SLR Document 1 Filed O4/25/2005 Page 1 of 2
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Umted States Dtstrtct Court
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UNITED STATES OF AMERICA
v.
JAMES R. GORDON Criminal Complaint
CASE NUMBER; 05- BOM
I, the undersigned complainant, being duly sworn, state the following is true and correct to the best ofmy knowledge and belief.
On or about Februag 22, 2005 in New Castle County, in the District of Delaware, defendant did
knowingly distribute Oxycodone
in violation ofTit|e 2I United States Code, Section(s) 84Iga)( I l and gh); I MC!
I further state that I am a(n) Special Agent, Drug Enforcement Administration and that this complaint is based
Ofliciztl Title:
on the following facts:
See attached Affidavit
Continued on the attached sheet and made a part hereof: Yes .
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Signature nant
Eric G. Miller
Special Agent, DEA
Sworn to before me and subscribed in my presence,
April 25, 2005 at Wilmin on DE
Date Cil *
Honorable Mary Pat Thynge I __
United States Magistrate Judge ` .-·`' * ‘“ `..,_ M
Name 8; Title ofludicial Ofticer I. Judicial Ofiiccr I f

Case 1:07-cr-00109-SLR Document 1 Filed O4/25/2005 Page 2 of 2
AFFIDAVIT
ERIC G. MILLER, being duly sworn, states as follows:
l. I am a Special Agent (S/A) with the Drug Enforcement Administration (DEA) and have
been so employed for fifteen years. During my law enforcement tenure, I have participated in over
three hundred narcotics investigations. In the course of my duties, I have conducted or participated
in physical and electronic surveillance, undercover transactions, the execution of search warrants,
debriefing of informants, interviews of witnesses, reviews of tape-recorded conversations involving
drug trafficking activities, and analyses of telephone toll records and other records kept by or
relating to drug traffickers. Through my training, education and experience, I have become
familiar with methods in which illegal drugs are imported, manufactured and distributed; methods
of payment for such drugs; and methods used by drug traffickers to avoid law enforcement
detection, including methods used to disguise the source and illegal nature of drug proceeds. I have
also testified as an expert witness in federal and state courts regarding illegal drug trafficking.
2. This Affidavit is in support of a criminal complaint against and arrest warrant for James
R. GORDON. I am the case agent responsible for the investigation in aid of which this application
is being made. This Affidavit is based on my personal knowledge and observations as well as
information provided to me by other lavtdenforcement officers who participated in the
investigation. Because this Affidavit is solely for the purpose of establishing probable cause, not
all facts relating to the investigation are included herein.
3. On February 22, 2005, a DEA agent acting in an undercover capacity purchased eighty
(80) Oxycodone tablets from GORDON in a parking lot at 3800 Kirkwood Highway, Newark, DE.
4. The tablets were analyzed by the DEA Laboratory and found to contain Oxycodone, a
schedule II controlled substance.
5. Based on the foregoing facts, Affiant submits that there is probable cause to believe that
James R. GORDON has committed a violation of Title 21, United States Code, Sections 84l(a )( 1)
and (b)(l)(C), distribution of oxycodone, and therefore respectfully requests that the Court issue a
criminal complaint and arrest warrant for GORDON.
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smc G. MIL " A
Special Agent, Drug Enforcement Admini.s·!rc:ti0n
Dated: April 25, 2005