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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 1120 HOMEWOOD AVENUE,


BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT
PREMISES #1"). SUBJECT PREMISES #1 is a residence of
Kimberly McIntosh;

THE PREMISES KNOWN AND DESCRIBED AS 4007 FORDLEIGH ROAD,


APARTMENT C, BALTIMORE, MARYLAND AND ITEMS CONTAINED
THEREIN ("SUBJECT PREMISES #2"). SUBJECT PREMISES #2 is
a residence of Todd Duncan, a/k/a “Donnie;”

THE PREMISES KNOWN AND DESCRIBED AS 237 EAST LAFAYETTE


STREET, 2ND FLOOR, BALTIMORE, MARYLAND AND ITEMS CONTAINED
THEREIN ("SUBJECT PREMISES #3"). SUBJECT PREMISES #3 is
a residence of Duconze Chambers, a/k/a “Ducon;”

THE PREMISES KNOWN AND DESCRIBED AS 1502 AISQUITH STREET,


BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT
PREMISES #4"). SUBJECT PREMISES #4 is a residence of
Lamont Crooks;

THE PREMISES KNOWN AND DESCRIBED AS 2004 BALTIMORE


STREET, BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN
("SUBJECT PREMISES #5"). SUBJECT PREMISES #5 is a
residence of Davon McFadden, a/k/a “Ben;”

THE PREMISES KNOWN AND DESCRIBED AS 1204 WILCOX STREET,


BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT
PREMISES #6"). SUBJECT PREMISES #6 is a residence of Jon
Brice, a/k/a “Tiger;”

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THE PREMISES KNOWN AND DESCRIBED AS 1619 RIVERWOOD ROAD,
BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT
PREMISES #7"). SUBJECT PREMISES #7 is a residence of
James Harried, a/k/a “Smiley;”

THE PREMISES KNOWN AND DESCRIBED AS 5305B VALIQUET ROAD,


BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT
PREMISES #8"). SUBJECT PREMISES #8 the residence of
James Bullock and potential stash location for Duncan;

THE PREMISES KNOWN AND DESCRIBED AS THE DESK OF KIMBERLY


McINTOSH LOCATED INSIDE TOTAL HEALTH CARE, 1501 DIVISION
STREET, BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN
("SUBJECT PREMISES #9"). SUBJECT PREMISES #9 is the work
station of Kimberly McIntosh;

THE PREMISES KNOWN AND DESCRIBED AS 304 EAST 21ST STREET,


BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT
PREMISES #10"). SUBJECT PREMISES #10 is a residence of
Eric Ushry, a/k/a “E;”

THE PREMISES KNOWN AND DESCRIBED AS 1701 HARFORD AVENUE,


BALTIMORE, MARYLAND AND ITEMS CONTAINED THEREIN ("SUBJECT
PREMISES #11"). SUBJECT PREMISES #11 is the residence of
Sherice Foster;

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. §

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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 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,

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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 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.

7. The initial phase of this investigation was conducted

in February through April of 2009. During this period, DEA SIG

utilized wire intercepts of several cellular phones, including

contraband cellphones utilized by incarcerated members of BGF, which

demonstrated a pattern of racketeering activity and BGF’s control

of various prison facility.

8. 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 (“the 2009 Indictments”). Specifically, one Indictment

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

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(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 charged Randolph Edison, Roosevelt Drummond, and

Zachary Norman with involvement in the drug conspiracy as well as

participation in a Hobbs Act robbery conspiracy, in violation of 18

U.S.C. § 1951. A second Indictment (the “Glasscho Indictment”)

charged 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. In conjunction with the arrest

warrants for the 2009 Indictments, law enforcement executed 13

search warrants on various locations in and around Baltimore City,

as well as searches of 16 separate jail cells of alleged BGF members

located in various prison facilities throughout the State of

Maryland. As a result of these search warrants, law enforcement

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recovered approximately 500 grams of heroin, firearms, drug

paraphernalia and packaging material, BGF literature and hundreds

of documents and photographs linking the various members of the 2009

Indictments to each other and to BGF. Several of these individuals

have already pled guilty for their part in the conspiracy to

distribute and possess with the intent to distribute heroin,

including Robe, Habeebullah, Burrus, Smith, Robinson, Freeman,

Taylor, Taylor-bey and Hatchett.

9. Information developed during the initial

investigation, as well as from various cooperating witnesses,

demonstrated that the BGF was attempting to utilize the same

paramilitary structure successfully used by the enterprise in

prison, to control the heroin trade in Baltimore City.

Electronic Surveillance of BGF

10. On February 5, 2010, 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 (443)378-1737 and bearing international mobile

subscriber identity (“IMSI”) #316010166475527 (the "CHAMBERS

CELLPHONE” OR TARGET CELLPHONE #1), used by DUCONZE CHAMBERS, a/k/a,

“Duconze, a/k/a “Ducon,” with service provided by Sprint/Nextel,

including through the use of Sprint/Nextel’s Direct Connect/Dispatch

Services. Interception pursuant to this Order began on February 8,

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2010 and was terminated on April 7, 2010.

11. On March 1, 2010, 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 (443)224-0458 and bearing international mobile

subscriber identity (“IMSI”) #310410290776119 (the "DUNCAN

CELLPHONE” OR TARGET CELLPHONE #2), used by TODD DUNCAN, a/k/a,

“Donnie,” with service provided by T-Mobile. Interception pursuant

to this Order began on March 1, 2010 and was terminated on March 15,

2010.

12. On March 15, 2010, 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 (443)703-6325 and bearing international mobile

subscriber identity (“IMSI”) #310260460554293 (the “Crooks

CELLPHONE” or "TARGET CELLPHONE #3"), subscribed to Lamont Crooks,

200 Patterson Park Avenue, Baltimore, Maryland and utilized by

LAMONT Crooks, with service provided by T-Mobile; and wire

communication occurring over the cellular telephones assigned call

number (410)599-5750 and bearing international mobile subscriber

identity (“IMSI”) #310410261755076 (the “COIL CELLPHONE” or "TARGET

CELLPHONE #4"), subscribed to COIL, 1200 West Baltimore Street,

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Baltimore, Maryland and utilized by TODD DUNCAN, with service

provided by T-Mobile. Interception pursuant to this Order began on

March 16, 2010 and is ongoing for the Crooks Cellphone, but

interception of the Coil Cellphone was terminated on April 7, 2010.

13. On March 25, 2010, 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 (443)600-1364 and bearing international mobile

subscriber identity (“IMSI”) #310260254237302 ("TARGET CELLPHONE

#5"), subscribed to Aja M. Trice, 5307 Tramore Road, Baltimore,

Maryland 21214, used by TODD DUNCAN, a/k/a, “Donnie,” with service

provided by T-Mobile. Interception pursuant to this Order began on

March 25, 2010 and was terminated on April 7, 2010.

14. On April 6, 2010, 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)913-6234 and bearing electronic serial

number (“ESN”) #03510747825/23A3FFB1 ("TARGET CELLPHONE #6"), with

an unknown subscriber, used by KIMBERLY McINTOSH, a/k/a, “Sister

Kim,” with service provided by Verizon Wireless. Interception

pursuant to this Order began on April 6, 2010 and is ongoing.

15. Pursuant to these wiretaps, other law enforcement

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agents and I intercepted hundreds of calls in which BGF members made

arrangements for narcotics transactions and discussed acts of

violence in furtherance of their racketeering enterprise.2

III. The Indictments

16. On April 7, 2010, a Federal Grand Jury sitting in the

District of Maryland returned an Indictment charging a total of 12

BGF members and associates with drug-trafficking (the 2010

Indictment”). Specifically, the 2010 Indictment charges Todd

Duncan, a/k/a “Donnie,” Kimberly McIntosh, a/k/a “Sister Kim, “ and

ten others, including Lamont Crooks, Duconze Chambers, a/k/a

“Ducon,” Jermain Davis, a/k/a “Dirty Rice,” Jon Brice, a/k/a

“Tiger,” Davon McFadden, a/k/a “Ben,” Ronald Scott, a/k/a “Piper,”

Earl Moore, James Harried, a/k/a “ Smiley,” Eric Ushery, a/k/a “E,”

and Sherice Foster with participating in a conspiracy to distribute

and possess with intent to distribute heroin, in violation of 21

U.S.C. § 846. The offense charged in this Indictment was committed

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

racketeering enterprise.

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.

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IV. The BGF Criminal Enterprise

A. Overview

17. 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 as part of

its continued 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), Metropolitan Transition Center (MTC),

the Maryland Correctional Adjustment Center (MCAC), and the

Baltimore City Detention Center (BCDC). The evidence further

indicates that individual members, who have been released from

prison, have established regimes throughout Baltimore City. Each

section of the City functions as a regime, much like an individual

prison facilities. Each area, like each prison, has a commander and

a host of other positions or ranks, who report directly to a central

authority. The entire BGF organization is then controlled by this

central command structure, who are responsible for authorizing BGF

activities, including the collection of dues, the distribution of

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drugs, and the authority to engage in acts of violence.

18. Some of the leaders and members of BGF on the streets

of Baltimore, Maryland include, among others, the following:

a. KIM McINTOSH, a/k/a “Bonita Kim,” a/k/a “Sister

Kim,” (hereinafter “McIntosh”) who is responsible for coordinating

and overseeing BGF finance, overseeing the punishment of non

compliant BGF members and rival drug traffickers, and acts as a

processing and distribution manager for heroin trafficking in

Baltimore, Maryland. An inquiry into McIntosh’s criminal history has

revealed no arrests;

b. TODD Duncan, a/k/a “Donnie,” a/k/a “Donnie

Duncan,” (hereinafter “Duncan” or “Donnie”) has been identified as

the overall commander for BGF operations throughout the entire

Baltimore metropolitan area. Duncan oversees and coordinates the

criminal activity attributed to BGF in the Baltimore metropolitan

area. Duncan is the overall decision maker regarding BGF

activities. An inquiry into Duncan’s criminal history has revealed

convictions for 1st degree murder and attempted murder;

c. Lamont Crooks (hereinafter “Crooks”) has been

identified as a BGF affiliate, who is one of the heroin sources of

supply for BGF and others in the Baltimore metropolitan area. An

inquiry into Crooks criminal history has revealed convictions for

assault with intent to murder and felon in possession of a handgun.

Lamont Crooks is currently on federal supervised release after

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serving a 46 months sentence for being a felon in possession of a

firearm;

d. ERIK SEANTAE USHRY, a/k/a "E," (hereinafter

“Ushery”) has been identified as a BGF affiliate who purchases large

quantities of heroin from Crooks and utilizes McIntosh to mix and

package the heroin. An inquiry into Ushry’s criminal history

revealed convictions for possession with the intent to distribute

drugs;

e. DUCONZE CHAMBERS, a/k/a “Duconze,” a/k/a “Ducon,”

(hereinafter “Chambers”) has been identified as a high ranking BGF

member who distributes heroin for Todd Duncan in the eastern portion

of Baltimore City. An inquiry into Chambers criminal history

revealed convictions for assault with intent to murder and a handgun

violation;

f. RONALD SCOTT a/k/a "PIPER," (hereinafter “Scott”

or “Piper”) has been identified as a member of BGF who assists

Duncan with the distribution of heroin in Baltimore City. An

inquiry into Scott's criminal history has revealed no convictions;

g. DAVON McFADDEN a/k/a "BEN," (hereinafter

“McFadden” or “Ben,”) has been identified as a high ranking BGF

member who assists in the distribution of heroin for BGF. An

inquiry into McFadden's criminal history has revealed convictions

for possession with the intent to distribute drugs and possession

of a firearm;

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h. JAMES HARRIED a/k/a "Smiley," (hereinafter

“Harried” or “Smiley”) has been identified as a high ranking BGF

member who is responsible for investigating violations of BGF

protocol. An inquiry into Harried's criminal history has revealed

three convictions for possession with the intent to distribute

drugs;

i. JON DEVALLON BRICE a/k/a "Tiger Brice,” a/k/a

"Tiger," (hereinafter “Brice” or “Tiger”) has been identified as a

drug trafficker in the Baltimore area. An inquiry into Brice's

criminal history has revealed convictions for attempted manufacture

of a controlled substance and possession with the intent to

distribute drugs and two counts of drug possession;

j. DEVON LAMONT CRAWFORD, a/k/a “Taterman,” has been

identified as a hit-man for BGF who takes his orders from Duncan.

An inquiry into Crawford’s criminal history revealed a conviction

for second degree assault; and

k. JERMAIN DAVIS a/k/a “Dirty Rice, a/k/a “Man”

(hereinafter “Davis”) has been identified as a BGF member who

assists Duncan and McFadden in the sale of heroin in Baltimore.

Davis was arrested during the execution of a search warrant at his

home, where a quantity of heroin was recovered, on March 22, 2010.

An inquiry into DAVIS’s criminal history has revealed two previous

convictions for possession with the intent to distribute controlled

substances, a conviction for second degree assault, and a separate

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convictions for battery.

B. INFORMATION PROVIDED BY CONFIDENTIAL SOURCES

1. Confidential Source #1

19. During a series of debriefings between late November

2008 and January 2010, a reliable confidential informant CS1)3,who

is presently incarcerated and is a high-ranking member of BGF,

advised me and other 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.

a. BGF Leadership

20. 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

part of the regime. The only place Bush members hold rank is within

3
The information provided by CS1 has consistently proven
reliable and has been corroborated by independent investigation,
and led, in part, to the identification and indictment of 23 BGF
members and associates. CS1 continues to provide information in
expectation of assistance with upcoming parole hearings.

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the correctional system; once a Bush member is no longer

incarcerated, he or she is considered a regular BGF member.

However, BGF members on the streets have taken on a new vision on

how things should be handled. CS1 explained that within months of

the unsealing of the 2009 Indictments, the structure and

organization of BGF began to change on the streets on Baltimore.

21. CS1 stated that Duncan has assumed the role as the

overall “city wide commander” of BGF on the streets of Baltimore.

Assisting Duncan in this role is McIntosh, who is the “Field

Marshall,” overseer of finance and one of the main “shot callers”

throughout the Baltimore metropolitan area - additional members,

including Chambers, “Commander of east Baltimore,” Thomas Burrell,

“Commander of South Baltimore,” Gerimo, China Man, Greyling Chase,

Tank Top, Bentley Dixon, a/k/a Benji, a/k/a Uncle Benji, and Matthew

Talley, a/k/a Gene.

22. CS1 reported that Duncan works as a youth counselor

for a non-profit organization, which he uses to conceal his

involvement with BGF. As BGF members are released from prison,

Duncan assists them in obtaining jobs which enables them to conceal

their illegal activities associated with BGF from law enforcement.

CS1 obtained Duncan’s office number, (410)752-8500, from other

members of BGF. Duncan uses this number for BGF members to reach

him when he is not available by cellphone.

b. Drug-Trafficking

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23. CS1 stated that drug trafficking both inside and

outside of prison is BGF’s primary means of making money, and is a

significant part of BGF’s activities on the streets of Baltimore.

CS1 stated that all violent crime, including murders, associated

with BGF, is related to its drug-trafficking activities. CS1

explained that BGF will sell any drugs, but primarily traffics in

cocaine and heroin.

c. Acts of Violence/Extortion

24. 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.

25. BGF leadership 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.

26. CS1 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 knowledge of the gang’s history and

rules. Members who fail to demonstrate adequate familiarity with

the gang’s history and rules are “sanctioned,” or beaten. During

the executions of the previous search warrants after the 2009

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Indictments, law enforcement recovered graded “tests,” from both

jail cells and at least one location searched as part of the initial

phase of the investigation.

27. CS1 reported that Eric Brown, indicted in the 2009

Indictments, published a book, "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. CS1 advised that Brown remains

a drug trafficker and that BGF funds its operations primarily by

selling drugs. During the executions of the previous search

warrants, law enforcement recovered copies of the “Black Book.”

2. Confidential Source #2

28. During a series of debriefings, a confidential

informant (CS2)4, who is a high-ranking BGF member has provided

information regarding current BGF activities. During these

debriefings, CS2 provided the following names and associated

telephone numbers: William Rhodes, a/k/a “Jim Dog” (410)500-3790,

165*496*11477; Robert Jones, a/k/a “Seattle” (443)563-6196,

(443)909-5711; Nugget 165*493*56; Thomas Burrell, a/k/a “Cochise”

(410)690-2679; Bentley Dixon, a/k/a “Benji” (410)469-0682; Bird

4
CS2 is providing information in exchange for leniency
with criminal charges. CS2's information has been corroborated
to the extent possible and has proven accurate and reliable.

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165*492*652; Devon Butler, a/k/a “Body Target” (410)297-3793;

Stanley Brunson, a/k/a “Crackaz” 164*1008*1537; Dave (410)961-7979,

(443)623-6620, Dom (443)455-0904; Face (443)839-1556; Fase

183*935*41; Flatline (410)361-0386; Goat 164*1007*2346; (443)717-

9406; Hood 164*1014*4961; Jerry (443)623-1662; Jon Jon (410);710-

4692; Jr 165*497*1564; Kevin Moore (443)455-0322; Lil Ox

164*1014*5696; Lor Head (443) 790-4163; Mann (443)521-8210, Monkey

164*1007*13378; Pat 165*152156*1; Pimp (443)469-4433; Plak 164*1009-

2709; Rob 165*496*13846; Roe Roe 165*499*14119; Shaheed

165*493*11925, (202)731-5686; Shorts 164*1010*13322, 165*500*221;

Stevo 165*495*11003; Stizell 165*497*10563; Tank (443)500-2636; Tank

Top 165*498*10290 (443)224-6253; Will (443)992-1992; Wise

165*498*11514; Harris (443)790-7657. CS2 explained that BGF is

attempting to take control of the heroin sales in the McHenry and

Calhoun Street area in Baltimore City. CS2 advised that William

Rhodes, a/k/a Jim Dog, is a high ranking BGF member from South

Baltimore, who is trafficking heroin along McHenry Street and

Pennsylvania Avenue in Baltimore. CS2 stated that Rhodes had

recently been utilizing cellular telephone numbers (410)500-3790 and

(443)869-7458 along with push to talk numbers 165*496*11477 and

164*1012*7032 to conduct his drug trafficking activities. CS2

stated that the heroin is currently being sold under the name “Def

Jam.” According to CS2, a non BGF drug trafficker, identified only

as “Stizzel,” is Rhodes’s heroin trafficking competition in the

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McHenry Street area. CS2 explained that on November 16, 2009,

Rhodes advised that he wanted “Stizzel” either shot or a home

invasion conducted at his stash location.

29. On November 13, 2009, CS2 was debriefed regarding BGF

members operating in the southern portion of Baltimore City. CS2

stated that Thomas Burrell, a/k/a Gansta, a/k/a Cochise was

currently involved in heroin distribution and violence associated

with his drug distribution. According to CS2, one of Burrell’s BGF

associates is Rhodes. CS2 advised that Burrell was currently

utilizing cellular telephone number (410)690-2679 to conduct his day

to day BGF activities. CS2 also advised that McIntosh was

controlling BGF finance throughout Baltimore.

30. On November 23, 2009, CS2 was debriefed by law

enforcement officials regarding the BGF. CS2 advised that on

November 20, 2009, he/she was summoned to attend a BGF meeting in

Baltimore. Prior to the interview regarding the meeting, CS2

directed law enforcement to the location of the meeting, 1120

Homewood Avenue (SUBJECT PREMISE #1), the residence of McIntosh. CS2

was then debriefed on recent BGF activities.

31. CS2 advised that on Friday, November 20, 2009,

Bentley Dixon, a/k/a Benji was released from jail on a state drug

charge. Shortly after being released, Dixon telephoned CS2 and

requested a meeting in the Westport area of Baltimore City. Upon

arrival, CS2 advised that Dixon was speaking with Thomas Burrell.

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CS2 advised that Dixon informed CS2 that Burrell and other BGF

members had accused CS2 of stealing money from BGF finance. Dixon

explained to CS2 that Burrell had been contacted by McIntosh

regarding the missing funds.

32. According to CS2, McIntosh was approached by a BGF

member, identified as “D,” who requested $500.00 from finance for

the purchase of a handgun. McIntosh informed “D,” that there was

not enough money available for his purchase. According to CS2, “D”

became upset because he (“D”) and other unidentified BGF members,

had been providing membership dues to CS2, which CS2 was suppose to

give to central finance for these purposes.

33. CS2 advised that McIntosh and “D” attempted to

contact CS2 regarding the missing funds, but were unsuccessful. In

response to the unanswered call, CS2 explained that McIntosh, Kareem

Randall, a/k/a Kareem, “D” and another BGF member, “J,” from

Brooklyn, Maryland met with Antonio Davis, a/k/a Tank Top, regarding

the missing funds.

34. According to CS2, a short time later, CS2 received a

telephone call from Antonio Davis. Upon answering the call, Randall,

using Davis’s phone, began yelling at CS2 about the missing funds.

During the same call, CS2 stated that McIntosh retrieved the phone

from Randall, identified herself and advised CS2 that there are some

issues that needed to be discussed regarding finance. McIntosh told

CS2 to speak with Duncan, and that Duncan would be waiting at E.

21
Preston Street and Greenmount Avenue in east Baltimore

35. CS2 said that he/she attempted to explain to Dixon

that he/she was not responsible for any misappropriation of BGF

funds, but was advised that CS2 needed to explain things to Duncan.

36. CS2 stated that CS2 and Dixon responded to the area

of E. Preston Street and Greenmount Avenue. Upon their arrival, CS2

stated that he/she received an incoming call from BGF member “Twan”

from telephone number (410)558-7338. CS2 advised that “Twan” is a

heroin trafficker, who sells heroin in the area of N. Monroe and

Ramsey Streets. CS2 realized, however, that Duncan was using the

phone. Duncan instructed CS2 to respond to Homewood Avenue and

Biddle Street. Upon entering the block, CS2 observed BGF member

“Smiley” standing in front of 1120 Homewood Avenue, Subject Premise

#1.

37. CS2 advised that Dixon, Smiley, and CS2 then entered

1120 Homewood Avenue, Subject Premise #1. Upon entering the

residence, CS2 observed approximately 30 BGF members both known and

unknown to CS2, including Duncan, Smiley, McIntosh, Cutty, Kevin

Moore, Kareem Randall, Gerimo, and Antonio Davis, seated and

surrounding a central chair in the living room area of 1120 Homewood

Avenue, Subject Premise #1. In the center chair was Duncan.

38. As the meeting commenced, CS2 advised that it was

clear that CS2 and Dixon were being put on trial for

misappropriation of BGF funds. CS2 said that Duncan asked if CS2

22
was operating a “renegade wolf pack” by refusing to follow BGF

protocol. McIntosh then demanded to know whether CS2 had collected

money bound for finance, and whether or not CS2 told “D” that

Burrell had sanctioned a “hit” on an individual known as Gutter.

At that time, Duncan interjected and stopped the questioning. CS2

advised that Duncan, then pointed at Dixon and CS2 and asked if they

knew of Duncan’s position in BGF. McIntosh then advised that Duncan

had been voted, by high ranking BGF members, the new leader of BGF

outside of the prison system. CS2 stated that Duncan then advised

CS2 that he/she had been charged with stealing money from BGF

finance, and Dixon had been charged with knowing of the theft and

not correcting the problem. CS2 then said Kevin Moore, Gerimo,

Smiley, and an unknown BGF member walked into the kitchen and began

deliberating over the charges against CS2 and Dixon. CS2 said that

after several minutes the “four jurors” returned and whispered to

Duncan. Immediately after speaking with the “jurors,” Duncan

advised CS2 that he/she had been found guilty of stealing money from

BGF finance and was ordered to receive a two minute body beating

from various BGF members. Duncan advised Dixon that he also had

been found guilty and was ordered to receive a twenty second body

beating and was to be suspended from the BGF Bush for a period of

six months. CS2 advised that both CS2 and DIXON received their

beatings.

39. After the punishment, the BGF meeting continued. CS2

23
advised, that among other things, McIntosh spoke about the need to

have an individual identified as “Johnny Five” murdered for the

killing of a BGF comrade. CS2 advised that Duncan inquired about

the status of Johnny Five’s murder at which time he was told by

McIntosh that it was going to be taken care of by Burrell. McIntosh

also spoke about the need to obtain additional guns to keep in stock

for use by BGF members.

40. According to CS2, Duncan spoke of many BGF matters,

including the fact that he (Duncan) had implemented a “Defense

Team,” led by Kareem Randall. Duncan advised that the “Defense

Team” is always to be on stand by in case they are needed for

retaliation against anyone, who may interfere with BGF matters.

Additionally, Duncan stated that he is in the process of meeting

with Burrell to establish a second “Defense team.” CS2 stated that

toward the conclusion of the meeting, Duncan advised that all

members in attendance needed to be aware that he (Duncan) has a

source in the FBI that provides him with information. Duncan said

that if anyone learned of their meeting he would be able to

determine who was leaking BGF information and would handle things

accordingly.

41. During the latter part of the meeting, CS2 was

provided by members in attendance with the telephone number (443)

712-3603, which is being utilized by McIntosh. Shortly thereafter,

CS2 advised that Dixon and CS2 were allowed to leave the meeting.

24
42. At the conclusion of the interview, law enforcement

instructed CS2 to place a controlled telephone call to Thomas

Burrell at telephone number (410)690-2679 to discuss the recent BGF

meeting. During the conversation, Burrell and CS2 discussed the

meeting, including CS2's sanction.

43. Law enforcement then instructed CS2 to place a

controlled telephone call to “D” at (410)710-0299 to discuss the

recent BGF meeting and the accusations by “D” regarding the theft

of BGF funds by CS2. During the conversation, “D” acknowledged the

meeting and the accusations.

44. On December 4, 2009, CS2 was debriefed regarding

recent BGF activities. CS2 advised that on December 3, 2009, CS2

received a telephone call from BGF member, Brian Rainey, a/k/a

Shahid, who advised that he was currently being held on a $5,000

cash bail stemming from a felony drug arrest, which occurred on

November 19, 2009. During the conversation, Rainey requested that

CS2 place a telephone call to McIntosh at telephone number (443)712-

3603, and ask her for assistance in posting his bail. Ultimately,

CS2 agreed to make the call. A short time later, CS2 placed a non-

controlled telephone call to (443)712-3603, utilized by McIntosh.

During the conversation, CS2 notified McIntosh of Rainey’s

situation. McIntosh then advised CS2 that she would look into

Rainey’s bail situation.

3. Confidential Source #3

25
45. During the month of December 2009, CS35 was debriefed

regarding his/her knowledge of the BGF. CS3 had notified law

enforcement that he/she is a well known and respected BGF member.

Among other things, CS3 stated that BGF is the most violent drug

gang operating in the state of Maryland. CS3 provided the following

names and telephone numbers of active BGF members in Maryland,

William Rhodes, a/k/a “Jim Dog” 165*496*11477, (443)869-7458,

164*1012*7032; Thomas Burrell, a/k/a “Cochise” (410)690-2783;

Gorilla Black (443)740-1838, Germo a/k/a “Jerimo” (443)858-0345;

Gene, a/k/a Matthew Talley (443)277-7449; Corey (410)585-5405;

Rodney Reaves, a/k/a “Hot Rod” (443)455-9544; Kareem, a/k/a Kareem

Randall 165*500*4416, (410)485-1823; Mack (443)602-1710, Anthony

Banks, a/k/a “Nugget” 165*493*56, (443)891-4044; Ralf (410)0858-

1039; Rambo 164*1011*8878; Stink 165*503*381; Stizill 165*497*10563;

165*495*11003, 165*1007*15265; Antonio Davis, a/k/a “Tank Top”

(443)398-1790, (410)209-0669; Kimberly McIntosh, a/k/a “Sister Kim”

(443)712-3603; Abron Scott, a/k/a “Tink” (443)398-1790, (410)209-

0669; Robert Loney, a/k/a “Looney” (410)500-7260; Mike Beatty, a/k/a

“Mike B” (443)220-7625; Reds (443)320-6641; and Skebo (443)540-3263.

46. On December 15, 2009, law enforcement officials

debriefed CS3 regarding current BGF activities. During the

debriefing CS3 advised, among other things that he/she could meet

5
CS3 is providing information in exchange for leniency
with criminal charges. CS3's information has been corroborated
to the extent possible and has proven accurate and reliable.

26
in person with McIntosh regarding BGF protocol and the gangs drug

trafficking activities. CS3 advised that McIntosh is the highest

ranking female BGF member in Maryland. CS3 advised that McIntosh

utilized cellular telephone number (443)712-3603, to conduct her

drug trafficking business.

47. On December 15, 2009, at approximately 12:06 p.m.,

law enforcement officials transported CS3 to Total Health Care

located at 1501 Division Street, McIntosh’s place of employment.

CS3 was equipped with a recording device to capture the conversation

with McIntosh. During the meeting, law enforcement observed CS3

meet with McIntosh near the front of the building. At the

conclusion of the meeting, CS3 met with law enforcement officials

and advised that McIntosh agreed to obtain three (3) grams of heroin

for CS3 later that evening. At approximately 4:10 p.m.,

investigators again met with CS3 and searched his/her person and

vehicle for the impending drug transaction. Both CS3’s person and

vehicle were found to be free of any contraband. At approximately

4:50 p.m., CS3 placed a controlled and recorded telephone call to

McIntosh at telephone number (443)712-3603. During the brief

conversation, CS3 agreed to drive McIntosh home from work. Shortly

thereafter, law enforcement followed CS3 to a community market

located on Pennsylvania Avenue, a short distance from Total Health

Care. Agents and officers then followed CS3 and McIntosh to her

residence, 1120 Homewood Avenue, Subject Premise #1, where both were

27
observed to enter the location.

48. Upon entering the residence, McIntosh began a

conversation that lasted over one (1) hour. During this time, CS3

was equipped with a recording device and transmitter. The

conversation involved, among other things, drug trafficking

including McIntosh’s willingness and ability to mix/process heroin

for BGF members and affiliates, shootings and violent acts

associated with drug trafficking, including the threat of violence

toward law enforcement cooperators. As the conversation commenced,

McIntosh asked CS3, “Are you ready for your grams now?” CS3

responded, “Fuck yeah, I’m ready whenever.” A more casual

conversation then ensued. CS3 asked, “Hey you know what I forgot

to ask you.” McIntosh answered, “What?” CS3 continued, “You already

got the mix?” McIntosh answered, “Um, hum. I don’t know how many

caps I got left. I think I bought a new thing but I, you know, I

be doing this for somebody else and he always get me. You know I

do his thing for him and he don’t never have the things. I’ll check

upstairs, I should have some though. At least I can put it and you

can just tomorrow.” McIntosh then placed an outgoing telephone call,

which is overheard on CS3's recording device. As the call is

answered, McIntosh said, “Hey, how you?” An individual, later

identified as Lamont Crooks responded, “What’s happening?” McIntosh

responded, “I’m trying to see you.” Crooks continued, “Oh yeah.”

McIntosh asked, “You in the hood?” Crooks answered, “Yeah, yeah I’m

28
in the hood.” McIntosh asked, “Alright, could you see me about six

o’clock?” Crooks answered, “Yeah.” McIntosh asked, “You remember

the six o’clock thing?” Crooks answered, “Yeah, yeah.”

49. A subsequent review of the pen register on (443)712-

3603, McIntosh’s Cellphone, revealed a call during the date and time

of this portion of the conversation to (443)703-6325, the Crooks

Cellphone.

50. McIntosh and CS3 then continued their conversation

regarding BGF activities and drug trafficking. CS3 asked whether

McIntosh was supplementing her income with drug proceeds. McIntosh

advised, “Yeah I been doing something, a little something.”

McIntosh explained that a BGF member “Hot Rod,” a/k/a Rodney Reaves,

had recently been arrested and that their has been some in fighting

between certain BGF members that should not have occurred. McIntosh

explained that some of the fighting had resulted in murder, to

include “Ant.” McIntosh explained that some BGF members thought

that Ant was a “rat” but she did not believe it. McIntosh

explained, “And then in the next sentence you see how EB and UNC and

RAINBOW6 and all them just came home. And then on that indictment

shit you see how EB was fucking Vernon girl (a reference to Tomeka

Harris, who was charged and has pled guilty in the 2009 Indictments)

6
These individuals, EB (Eric Brown); UNC (Uncle Ray, Ray
Olivis); and Rainbow (Rainbow Williams) were indicted in the 2009
Indictments involving the BGF and its smuggling of drugs into and
control of the Maryland prison system.

29
and Vernon and Ant was best friends. Something seem real, real

shakey with that. Something seem real, real shakey with that. Like

maybe, Ant was saying some shit that he didn’t like and maybe was

going back to Vernon telling him. Or it was a, he might have been

a threat now cause he witnessing shit that really ain’t right and

they got rid of him. I don’t even know.” CS3 asked, “The thing is

who made that call?” McIntosh answered, “I don’t know. Like I said

when Rainbow came home, see now I don’t got no more gel caps, damn,

when Rainbow came home “Donnie”(a reference to Duncan) kind of

allowed him to kind of…” CS3 continued, “Take over.” McIntosh

continued, “Something like that, something like that.” CS3 advised,

“Yeah, but the thing is, you know we have to see it in black and

white.” McIntosh responded, “Yep.” CS3 continued, “You can’t go

off of what somebody says, you can’t.” McIntosh advised, “Yeah, we

should be good. You just gonna have to cap it up (a reference to

packaging heroin). Yeah I ain’t like that. Cause like I said, one

minute he here and he in extremely good standing and the next minute

he was out of there and, and right before they killed him he

disciplined somebody and the person deserved to get disciplined.

The boy said fuck J7. That’s that west situation and they beat the

7
Based upon my investigation into BGF, J is a reference
to Jamaa. Jamaa is a Swahili term for family and is used
primarily by BGF members interchangeably with other monikers to
describe BGF. For example, in conversation BGF members will say
that “he is ‘J’,” meaning the individual is a member of the
“family.” The family is the Black Guerilla Family (BGF). So the
individual is a member of their criminal enterprise.

30
shit out of him. Dre had a fit because that’s his cousin’s baby’s

father. I don’t give a fuck. So he gets to say fuck J (BGF), gets

to sit in the car right it’s two weeks later, say fuck J (BGF) one

time, get beat for it. Two weeks later sit in the car let his

homeboy kill a comrade, shoot a comrade five times in the back.

You strapped (armed) and don’t do shit about it. Then come to a

meeting a week after that and say do we really have to harm a

civilian, cause that’s my homeboy. They is all sitting at these

meetings. I swear if I was at that meeting I’d a probably tried to

fuck him up right then and there and Dre still talking about oh

that’s my, he’s a good brother. That’s my cuz. I don’t give a

shit. He the one that went back to Uncle Ray telling people,

telling him I’m beating people for no reason. No that wasn’t for

no reason.” CS3 responded, “Yeah, I heard, I remember when he was

down the pen because, I’m trying to think, me and another comrade

was talking about you and Ray Ray8, Ray Ray asked me about you. I

said that’s, man that’s the best comrade I ever met with me in my

life.” McIntosh responded, “I know he was probably disappointed

that you said that.” CS3 continued, “Right, so he was like what she

be doing. I said Sis (a reference to Sister Kim, a/k/a McIntosh)

is laid back you know. Unless you jump out there, jump out there,

Sis is laid back. I didn’t know that’s why he was asking me.”

8
Ray Ray, is a reference to Uncle Ray, or Ray Olivis,
see note 6.

31
McIntosh responded, “That’s why he was asking. He said I, I beat

people for no reason. I’m abusing my authority and I’m on that.

I stole forty seven thousand dollars from finance. I’m in hiding,

can’t go nowhere. Can’t no brothers find me. Cutty had his little

part in spreading the rumor to. When he came home they brought him

to me. Donnie (Duncan) done brought him to me and he said, at first

he said he ain’t never said none of that. I’m like ok Cutty, so if

I get ten brothers that was on the tier with you, that all came home

and looked at me like I was crazy cause I was walking down the

Avenue embracing brothers, you gonna call them a liar. Well no I

ain’t saying that I didn’t say it. What I’m saying is if I said it

I was just passing along something that somebody said to me. Since

when do we do that without verification? But ok, figuring out all

the other brothers who had this idea and came home and found out it

wasn’t true. When I asked them where they got it from they said

they got it from you. So if you didn’t originate it then where did

you get it from? Oh I don’t remember. And Donnie (Duncan) and them

just let it go like that. I don’t remember. Ok, ok well I didn’t

steal no, no money. I’m, I’m, I’m still here. I’m not in hiding

yeah, yeah. I think they did that, they suspended me. They

suspended me right and I think they real goal was, cause at first

when they suspended me they didn’t have a reason. Since when do we

suspend people without a reason? Oh, no they still can’t give me

a reason. Cause they’ve invested every, investigated every avenue.

32
Turned over every rock, every stone, every decision I’ve ever made

was brought into question and I passed every single one of them.

So like a few weeks later they was like ok you can go ahead and

resume your position. Well before I do that can you just let me

know what I was suspended for? Oh I’m going to get back to you on

that.” CS3 responded, “That’s supposed, that’s supposed to come

first.” McIntosh continued, “You not gonna take your position, your

not gonna take your position back? Yeah, I’m gonna take it as soon

as you all give me my charge papers so I can show people that I was

actually you know, cleared. Well Rainbow asked Uncle Ray what you

want us to tell her? Tell her it was administrative.” CS3 asked,

“So what’s that supposed to mean?” McIntosh answered, “That means

he got to do what the fuck he want to do cause he brought it here

from Cali9. That’s why I found out that Doc is alive. That’s why

I found out that Doc is alive, that they lied. And Doc10 loves me.

You hear me Doc loves me. Like he, he knows my mind from the little

bit that he done read and I ain’t even feed him a whole lot yet.

I ain’t, I still ain’t even tell him I’m J (BGF). I think he know

9
Through my investigation, I have learned that Ray
Olivis, a/k/a UNC, a/k/a UNCLE RAY, a/k/a RAY RAY was authorized
to open BGF in the State of Maryland prison system in the mid
1990's by the California factions of BGF after Olivis served a
prison sentence in California.
10
Doc is a reference to Doc Holiday, a/k/a James Herold
Holiday, who is currently incarcerated in Florence, Colorado.
Holiday was one of the founding member of BGF in California in
the 1960's.

33
now though. Cause in the last letter he wrote Kim and he put past

sister. So I think he know and then like I said he said I risen

from the grave before and then it said watch out for the ones from

on this side or from your side.” McIntosh then received an incoming

telephone call. McIntosh answered the call and said, “Hello. Hey

E. I been, I don’t know, hiding. No I’m home. Yep, I got a ride.

Was you, you know what I just called yo too. Oh he’s gonna, ok, no

problem. Ok, alright.” McIntosh completed the call and returned

to her conversation with CS3. McIntosh advised, “That’s so funny,

yo would have been coming to my house anyway. The dude would have

been coming to my house anyway. That, the other dude that I whip

up (process heroin) for he um must have just called him himself.

Gonna meet him here. Ain’t that funny?” CS3 responded, “Yo, yo be

taking it down huh?” McIntosh answered, “Yeah he…” CS3 continued,

“It must be good...,” McIntosh continued, “…Yeah it’s decent. It’s

decent. It’s better than what most of the people out here got. You

know people ain’t having nothing that you can put higher than a

three (a ratio of cutting agent to heroin). It really has been

real, people putting their shit on a two, two and a half (a ratio

of cutting agent to heroin) and just getting a medium reading.”

McIntosh explained that drug traffickers other than herself have

been mixing their heroin with “codeine with the oxy codeine” which

doesn’t turn out to be of good quality. The conversation continued

between McIntosh and CS3 regarding different types of cutting agents

34
used by heroin traffickers.

51. A subsequent review of the pen register on (443)712-

3603, McIntosh’s Cellphone, revealed a call during the time and date

of this portion of the conversation incoming from (443)378-0318

subscribed to Erik Ushry at Irvine, California, 200 N Patterson Park

Avenue, Baltimore, Maryland. The call was listed as incoming at

5:55:20 p.m., and lasted 41 seconds. At the completion of the call,

McIntosh identified the caller to CS3 as “E,” one of the individuals

that she mixes and cuts heroin.

52. On December 15, 2009, at approximately 5:58 p.m., TFO

Benson and other surveillance officers observed a dark colored Buick

bearing Maryland registration 2FM V79 park in front of 1120 Homewood

Avenue, Subject Premise #1. TFO Benson observed a heavy set black

male, approximately 6’ 4” in height exit the Buick and entered 1120

Homewood Avenue. A query of the Maryland Motor Vehicle

Administration (MVA) revealed the vehicle to be registered to Erick

Seantae Ushry, B/M, 6’ 4”, 300 lbs, with a date of birth (DOB) of

04/22/1984, and an address of 1207 Greenmount Avenue, Baltimore,

Maryland. TFO Benson and other surveillance officers were later

shown a photograph of Erik Ushry and positively identified the

driver of the Buick as Ushry. After Ushry’s arrival at McIntosh’s

residence, McIntosh, Ushry and CS3 engaged in drug related

conversation. McIntosh initially advised that they needed to go to

a separate location in the house because “Lamont” was going to be

35
coming. At approximately 6:18 p.m., TFO Benson observed a white

Dodge Charger bearing Alabama registration 47L78L8 park in front of

1120 Homewood Avenue, Subject Premise #1. A few minutes later, the

passenger exited the vehicle and entered 1120 Homewood Avenue.

During the same time frame, McIntosh received an incoming call. A

review of the pen register over (443)712-3603 revealed the incoming

call at 6:18:56 from (443)703-6325, the Crooks Cellphone. During

the telephone conversation McIntosh said, “Hello. Oh come on in.”

Crooks then enters the residence and greets McIntosh, Ushry and CS3,

who was still wearing the recording device. Crooks tells McIntosh,

“I’m gonna need a, a bag to put the grams in.” McIntosh asked, “You

need a scale too?” Crooks responds, “No, I got a scale.” As the

conversation continues Crooks advises the group, “…Something mean

supposed to be coming. Yeah man they uh, uh the only thing I’m

waiting. Cause I told you I took a loss (unintelligible) with the

last thing. But they supposed to straighten half of it. Cause we

took like a hundred ninety thousand dollar loss and they supposed

to straighten it. So I don’t know how long (unintelligible) half

but if I get like seventeen and my money back and they supposed to

send something with it. You know what I’m saying? They said it

supposed to have been. It’s coming out of Chicago and that shit

pure.” As the conversation continues, Ushry advised that the

heroin he has been getting from Crooks has been of good quality.

At approximately 6:25 p.m., TFO Benson observed Ushry exit Subject

36
Premise #1, enter the Buick and depart the area. Shortly

thereafter, TFO Benson observed Crooks exit 1120 Homewood Avenue,

enter the white Dodge Charger and depart the area. At approximately

7:16 p.m., surveillance officers observed CS3 exit 1120 Homewood

Avenue, Subject Premise 1, and depart the area with surveillance

officers following. CS3 was followed to a neutral location and

relinquished the quantity of heroin purchased from McIntosh and

Crooks. Both CS3’s vehicle and person were again searched and found

to free from any contraband.

53. During a subsequent debriefing, CS3 identified the

source who delivered the heroin for McIntosh as Lamont. CS3 was

shown several photographs and identified Lamont Crooks as the heroin

source of supply. CS3 also stated that the five grams of heroin

were purchased at a price of four hundred dollars which had been

provided by law enforcement. CS3 advised that once Crooks arrived

he provided one gram of heroin to McIntosh, and twenty grams to

Ushry. The CS advised that Crooks had stated that he obtained his

heroin source of supply when he (Crooks) and the source were

incarcerated together in a federal correctional institution.

According to Crooks, the heroin source was from Boston,

Massachusetts. CS3 also advised that Crooks had lost one hundred

and nine thousand dollars during a recent heroin purchase, but that

he and his source of supply were going to split the loss.

54. On December 16, 2009, at approximately 1:10 p.m., law

37
enforcement investigators again met with CS3 to place a controlled

call to McIntosh over (443)712-3603. The call was placed in the

presence of law enforcement and was recorded. During the

conversation, CS3 asked McIntosh for a contact number for Crooks.

McIntosh told CS3 that she needed to obtain the number from her

phone and would call right back. At approximately 1:12 p.m., CS3

received an incoming call from McIntosh over (443)712-3603. During

the brief conversation, McIntosh provided CS3 with telephone number

(443)703-6325, the Crooks Cellphone, but advised that Crooks may

want CS3 to conduct any drug transactions through her.

55. On December 21, 2009, investigators again met with

CS3 to purchase heroin from McIntosh. At approximately 4:29 p.m.,

CS3 called (443)712-3603, and left a message for McIntosh. A few

moments later, CS3 spoke with McIntosh over the push to talk feature

of (443)712-3603. During the brief conversation, CS3 advised, “Hey

um, I need to see you.” McIntosh responded, “Ok, um give me a

little while I’m gonna hit you back.” CS3 asked, “Alright, is um

my man ready?” McIntosh answered, “Um, I don’t know. I can check

on that now.” CS3 asked, “Alright how long you, you talking? Cause

I got to go back and pick my mom up.” McIntosh answered, “Um, I

don’t know. Let me make a call.” CS3 responded, “Alright hit me

right back.” McIntosh continued, “Ok, what was you talking anyway?”

CS3 answered, “Uh ten” (a reference to grams of heroin). McIntosh

responded, “Ok.” At approximately 4:34 p.m., McIntosh called CS3

38
and advised that everything was ready to go.

56. A subsequent review of the pen register over the

(443)712-3603 revealed an outgoing call to the Crooks Cellphone at

4:33:36 p.m., seconds prior to the return call to CS3 from McIntosh.

57. On December 21, 2009, law enforcement investigators

searched CS3 and the CS’s vehicle and found them free of any

contraband. CS3 was then provided with a recording device and eight

hundred dollars in government funds for the purpose of a controlled

purchase of ten grams of heroin from McIntosh. Investigators

followed CS3 to 1120 Homewood Avenue, Subject Premise #1, the home

of McIntosh. CS3 was observed to arrive at the residence at

approximately 4:58 p.m. Within minutes of CS3's arrival, McIntosh

placed an outgoing call over (443)712-3603. McIntosh asked, “Hey

can you come through? You know how long that’s gonna be? Ok what

time is it now? Ok, ok I’ll let him know.” McIntosh then told CS3,

“He said he gotta wait until the girl get off. It’s gonna be six.”

CS3 advised that he/she would return to McIntosh’s residence after

six o’clock. As the conversation continued, McIntosh asked, “Did

you just want to leave your um thing, in case he come through?” CS3

advised that he/she would hold the money in case CS3 did not return

that evening. A short time later, CS3 exited 1120 Homewood Avenue,

and was followed to a secure location. CS3 returned the official

funds and stated that McIntosh was waiting for Crooks to arrive with

the heroin after 6:00 p.m.

39
58. A review of the pen register over (443)712-3603

revealed an outgoing call to the Crooks Cellphone at 5:00:30 p.m.,

which lasted 42 seconds.

59. On December 21, 2009, at approximately 6:24 p.m.,

surveillance officers observed a four door Acura bearing Maryland

registration 7EX Y82 park near 1120 Homewood Avenue, Subject Premise

#1. Shortly thereafter, two unidentified males exited the vehicle

and entered the residence. At approximately 6:30 p.m., surveillance

officers observed the two unidentified males exit the dwelling and

engage in a conversation with McIntosh, who was standing in the

doorway. A few minutes later both males entered the Acura and

departed the area. A query of Maryland MVA revealed registration

7EX Y82 registered to a 2002 four door Acura registered to Davon

Jerome McFadden, DOB: 01/07/1986 at 2004 E. Baltimore Street,

Baltimore, Maryland 21231, SUBJECT PREMISE #5. At approximately

7:47 p.m., law enforcement officials again met with CS3 for the

purpose of a heroin purchase from McIntosh. CS3 and the CS vehicle

were again searched and found free of any contraband. CS3 was

provided with eight hundred dollars in government funds and was

equipped with a recording device. Investigators then followed CS3

to 1120 Homewood Avenue, Subject Premise #1, arriving at

approximately 7:55 p.m. Minutes after CS3's arrival, McIntosh

asked, “You wanted ten right?” McIntosh explained that she was

running out of minutes on (443)712-3603, but would replenish them

40
later in the evening. As the conversation continued, McIntosh

explained that she needed to obtain a new supply of “cut” and would

not be able to mix the heroin for CS3. CS3 asked where he/she could

obtain cutting agent and McIntosh stated, “They say Old Town Mall.

I know that’s where I get my, my vials from sometimes. It, down

there the vials are thirty, you get seven hundred for thirty. But

downtown you get five hundred for twenty and the cut, like I, they

said today that they got it down there. I can get it tomorrow but

that’s a hundred dollars, you know.” At approximately 8:17 p.m.,

surveillance officers observed CS3 exit the residence and proceed

out of the area. Investigators followed CS3 to a secure location

where CS3 relinquished a quantity of heroin purchased from McIntosh.

CS3’s person and vehicle were again searched and found to be free

from contraband.

60. A subsequent review of the pen register over

(443)712-3603 revealed two outgoing calls and one incoming call to

the Crooks Cellphone minutes after CS3 left McIntosh’s residence.

61. On January 11, 2010, law enforcement investigators

debriefed CS3 regarding the current activities of McIntosh and the

BGF. CS3 advised that currently he/she could not reach McIntosh

over the telephone but could speak with her at her place of

employment. Law enforcement officials then transported CS3 to

McIntosh’s place of employment at Total Health Care. CS3 was

equipped with a recording device and instructed to meet with

41
McIntosh. The following is a portion of the conversation between

McIntosh and CS3: McIntosh asked, “Did JIM (a reference to Rhodes)

ever get you a tone [firearm]?” CS3 responded, “Fuck no. He gave

me the runaround, kept sending me down south fucking Baltimore.”

McIntosh continued, “And I ain’t like that. You know why I didn’t

like that? Because Five (a reference to James Harris a/k/a Johnny

Five, a rival of BGF) is down there and you know him and Five be in

cahoots from time to time.” And you know he sent you, that’s why

I said, where did he send you? McIntosh explained that if “Five”

knows that a “comrade11” is in his drug trafficking area then he

would assume that the BGF member is there looking to cause him harm.

McIntosh explained that Harris would immediately inflict harm on

anyone he believes may cause him harm. McIntosh explained that

Rhodes has continued to have dealings with Harris even though,

“There’s been a green light out on yo since the beginning” (a

reference to an ordered murder of Harris by BGF). According to

McIntosh, Harris is responsible for the murder of a BGF member

causing BGF to order his death. McIntosh explained that it was

wrong for Rhodes to not advise CS3 of the ongoing problems with

Harris. McIntosh said, “You need to go holler at Donnie (Duncan),

Cause see Jim (Rhodes) just put himself on the fucking block (a

reference to being sanctioned for not following BGF protocol).

11
Comrade is a term used by BGF members to describe other
members or address each other, for example, “he’s a good comrade”
[he’s a respected member of BGF].

42
Cause if he did something, he robbed somebody who he shouldn’t have

robbed and it was really a misunderstanding. You know as where if

he would have came to the table it could have just got clarified.

He, he could have said oh I did get um, clearance [from the BGF

hierarchy]. I did try to find out if yo was that [a member of BGF]

and he said he wasn’t and they would have dealt with it in a whole

other way. Yo ain’t even showing up (a reference to attending BGF

meetings). He on the run from Donnie (Duncan) and them. He won’t

show up. He won’t come. He won’t call. Donnie and them want to

know where he live. McIntosh continued that she knows that the

mother of Rhodes lives near Washington Boulevard, but she was unsure

of where Rhodes is staying. McIntosh explained that Rhodes is

keeping a low profile and not being loyal to “J” (BGF).

62. As the conversation, continued CS3 asked, “You got

a new number?” McIntosh responded, “I got to get a new number.

They just made me back secretary (a rank within the BGF hierarchy,

specifically overseer of the organization’s finance).” CS3 asked,

“You got my number right?” McIntosh responded, “Yeah, yep. They

just made me back secretary too. So I’m gonna be getting me a J

(BGF) phone and I’m gonna get back all my little contacts and they

gave me the, a few other little areas (a reference to areas

controlled by BGF) that I, I get to deal with now.” The

conversation continued regarding activities being conducted by BGF

members. McIntosh advised that CS3 needed to go in person and

43
explain to Duncan the problem CS3 has been having with Rhodes.

63. On January 12, 2010, CS3 met with law enforcement

officials regarding the BGF. During the debriefing, at

approximately 2:39 p.m., CS3 placed a controlled call to McIntosh

at Total Health Care. Upon reaching McIntosh, CS3 was told to

immediately respond to her job because she needed to show CS3

something. Shortly thereafter, CS3 was equipped with a recording

device and followed to Total Health Care located at 1501 Division

Street. At approximately 3:01 p.m., CS3 arrived at McIntosh’s place

of employment and entered the building. During this time, law

enforcement investigators learned that there had been a shooting

near Total Health Care. A further inquiry revealed, Marc Antonio

Jackson had been arrested and charged with the attempted 1st degree

murder of Brandon Walker early on January 12, 2010. The location

of the shooting was listed as 500 Sanford Place, a short distance

from Total Health Care. At approximately 3:13 p.m., surveillance

officers observed McIntosh and CS3 exit the building and engage in

a conversation. During the conversation, McIntosh explained that

the shooting of Walker was BGF related. McIntosh explained that

within the last month the victim, Walker, had a verbal altercation

with Jackson, the shooting suspect, identified by McIntosh as

“Mark.” McIntosh explained that Mark had said to her that the next

time he sees the victim he is going to “burn him up” (a reference

to shooting the victim). As the conversation continued, CS3 and

44
McIntosh switched back and forth between the shooting and CS3’s

ongoing problem with Rhodes. McIntosh ultimately agreed that CS3

needed to address the problem with Duncan and Chambers. At

approximately 3:16 p.m., surveillance officers observed Kareem

Randall exit a white van, which had stopped near Total Health Care,

and approach CS3 and McIntosh. The three then engaged in a brief

conversation. During the conversation, Randall advised that the

“feds” were parked near the corner. Shortly thereafter, Randall

walked toward a gold Toyota 2 door bearing Maryland registration

6BZV83, which was parked at the corner of Pennsylvania Avenue and

Mosher Street, while McIntosh and CS3 continued their conversation.

At approximately 3:21 p.m., McIntosh returned to the building as CS3

walked toward the gold Toyota. At approximately 3:23 p.m., officers

observed Randall exit the passenger’s side of the Toyota and engage

in a conversation with CS3. During the conversation, CS3 told

Randall that he/she needed to obtain a handgun. Randall advised,

“We just lost mother fucking seven [because of the shooting that had

just occurred].” CS3 acknowledged the shooting as Randall

continued, “Yeah we had seven guns up there yo.” Randall then

explained that he needed to advise “Jim Dog” (a reference to Rhodes)

about the loss of the guns. Randall ultimately advised CS3 that

because of their loss he (Randall) could not provide CS3 with a

handgun. At approximately 3:26 p.m., the meeting between Randall

and CS3 concluded. A few minutes later, CS3 entered the CS vehicle

45
and was followed by law enforcement back to the DEA office. At

approximately 3:52 p.m., shortly after arriving at the DEA office,

CS3 received an incoming push to talk call from Randall. Due to the

unexpected activation by Randall, law enforcement was unable to

record the conversation. The conversation was, however, transmitted

over the speaker portion of CS3’S phone, which enabled agents to

hear the conversation. During the brief conversation, Randall

asked, in a heated manner, CS3’s current location. CS3 countered

and asked Randall’s current location. Investigators then heard an

unidentified male in the background whisper to Randall, “No, you ask

where he’s at?” Randall then asked CS3 if he/she was at a building

near a hotel. CS3 advised that he/she was currently downtown near

the Downtown Locker Room. Randall then abruptly advised that he

would call CS3 later. Based on the nature of the questioning and

the location of the DEA building adjacent to a hotel, law

enforcement believed that a BGF associate of Randall’s observed CS3

enter the DEA building. At approximately 4:23 p.m., law enforcement

unsuccessfully had CS3 call McIntosh to clarify the questioning by

Randall.

64. A few days after the conversation with Randall, CS3

met McIntosh at Total Health Care. During the brief conversation

with McIntosh, McIntosh avoided conversation related to BGF and/or

criminal activity, and instructed CS3 to enter rehab and get his/her

life together.

46
4. Confidential Source #4

65. After the 2009 Indictment, and at various times

including August 5, 2009, law enforcement debriefed a confidential

source (CS4).12 CS4 is a high-ranking member of the BGF, and a

contributor to the Black Book.

66. CS4 described BGF’s efforts to appear to be a

legitimate organization. According to CS4, the Black Book, which

was the brain child of Eric Brown was to “make [BGF] look like a

legitimate organization.” Brown and other high-ranking members of

BGF hoped that by using BGF’s control over the prison system, the

BGF could control violence in the institution and continue to enrich

themselves through the prison economy (smuggling contraband). CS4

indicated that Brown was able to convince several community leaders

including former Federal Bureau of Investigation agent Dr. Tyrone

Powers, Dr. Andre Bundley, a former mayoral candidate, and Bridget

Alston-Smith, who operated a non-profit organization called Partners

in Progress, of the message contained in the Black Book. These

individuals began assisting Eric Brown in teaching in prison the BGF

and other prison gangs, the message of the Black Book. According

to CS4, Brown and other members hoped that, much in the same way BGF

controlled prison violence through subtle coercion, control of the

12
CS4 is providing information in exchange for protection
by law enforcement from the BGF, who believe he/she is/was a
confidential source. CS4's information has proved accurate and
has been corroborated to the extent possible.

47
prison economy, extortion, and retaliation, members on the street

could control the violence in Baltimore City. According to CS4,

this would have the effect of legitimizing BGF, allow the enterprise

to continue to earn money through drug trafficking, and taxing of

others trafficking in drugs, as well as providing legitimate high-

paying jobs to high-ranking members of BGF funded by various

government grants.

5. Source of Information #1

67. On December 28, 2009, DEA investigators interviewed

source of information #1, hereafter referred to as SOI #113.

According to SOI #1, he/she has had close interaction with many high

level drug traffickers and BGF members in Baltimore to include

McIntosh, Duncan, Chambers, Henry Giles, Piper, Taterman, a/k/a

Devon Crawford, and Gerimo. SOI #1 said that all of these

individuals are involved in drug trafficking and violent activities

attributed to BGF. Regarding violence, SOI #1 identified Taterman

as a “hit man” for Duncan. SOI #1 also identified Kool Aid as

partner with Taterman and involved in acts of violence.

Additionally, SOI #1 provided the following telephone numbers for

active BGF members in Baltimore, Todd Duncan, a/k/a, “Donnie”

cellular (410)559-5750, office (410)752-8500 and 8501; Bunchy

13
SOI #1 is providing information because the violence
associated with BGF has gotten out of control, and SOI #1 feels
that he/she is in a position to assist law enforcement. SOI #1's
information has been corroborated to the extent possible and has
proven accurate and reliable.

48
(443)676-5412; Stacey Smith (443)927-4360; Lamont (410)599-8150; Mia

Wilson (410)350-4118; Duconze Chambers (443)378-1737; Piper

(410)599-8350; Nathan Barksdale, a/k/a “Bodie” (443)766-2380 and

(443)467-7222; Dirty Rice, a/k/a “Man” (410)783-1853, (410)539-1618,

(410)736-9634; a female correctional officer (443)630-7672; Kool Aid

(443)453-1394; Taterman (443)850-1780, and Marty (443)865-7335.

68. According to SOI #1, Duncan and Kimberly Mayfield

Jones, known to law enforcement as McIntosh are the leaders of BGF

on the streets of Baltimore. SOI #1 advised that both Duncan and

McIntosh report to Uncle Ray, a/k/a Ray Olivis, who is currently

housed in the Maryland Correctional and Adjustment Center (MCAC) on

federal charges (the 2009 Indictments). According to SOI #1, Duncan

currently works as a youth counselor in Baltimore for a non-profit

organization called COIL. However, SOI #1 advised that Duncan makes

his money by selling heroin in the area of Greenmount Avenue and E.

Preston Street. Persons who assist Duncan in his heroin business

were identified by SOI #1 as Chambers, Piper and Henry Giles. SOI

#1 explained that as recently as the middle of December 2009, Duncan

and Chambers were supplied 300 grams of heroin from Terry Johnson.

According to SOI #1, Duncan and Chambers began receiving the heroin

after Duncan’s cousin D-Nice, a/k/a Darnell Gray, was murdered by

associates of Johnson. SOI #1 said that Johnson is not charging

Duncan for the heroin because he believes that as long as Duncan

receives the heroin, Duncan and or his associates will not retaliate

49
against Johnson for the murder of Duncan’s cousin. SOI #1 stated

that Duncan and his associates are extremely violent and will

ultimately murder Johnson. A query of law enforcement databases

revealed that Darnell Gray, a/k/a “D-Nice,” was murdered on December

16, 2009.

69. During the course of the interview, SOI #1 advised

that he/she could place telephone calls to members of the BGF.

Specifically, SOI #1 advised that telephone calls could be made to

Chambers, Piper, Nathan Barksdale, a/k/a “Bodie,” and Dirty Rice,

a/k/a “Man.”

70. On December 28, 2009. at approximately 6:03 p.m., SOI

#1 placed an outgoing consensually monitored telephone call to

Chambers over the Chambers Cellphone. SOI #1 placed the cellular

telephone on speaker mode for investigators to monitor. During the

conversation, Chambers advised that he has been selling “shit” (a

reference to heroin) for Donnie (Duncan). Chambers stated he was,

“helping him out so they could make something (a reference to

money).” SOI #1 advised that Chambers should not trust Donnie,

“because he is doing some cruddy shit.” Chambers responded that,

“Donnie is alright.” SOI #1 then brought up the recent murder of

D-Nice, stating that, “Donnie may have been given the 300 (a

reference to 300 grams of heroin), but he’s going to steal what they

have and kill them boys anyway.” SOI #1 stated that Chambers goes

along with it because he is scared of Donnie. Chambers stated, he

50
is not scared of Donnie, “they are tight, they fight like brothers

sometimes, but they are tight.”

71. On December 28, 2009, at approximately 6:25 p.m., SOI

#1 placed an outgoing consensually monitored telephone call to Piper

at (410)599-8350. SOI #1 placed the cellular telephone on speaker

mode for the investigators to monitor. During the conversation, SOI

#1 asked Piper where they were. Piper responded, “Over west.” SOI

#1 then said, “I hear Donnie (Duncan) in the background you ain’t

over west.” SOI #1 then instructed Piper not to give Donnie SOI

#1’s number. Piper advised, “No problem…,” because he doesn’t want

Donnie mad at him. SOI #1 said, “Don’t tell him you are on the

phone with me.”

72. On December 28, 2009, at approximately 7:10 p.m., SOI

#1 placed an outgoing call to Jermain Davis, a/k/a, Dirty Rice at

(410)539-1618. SOI #1 placed the telephone on speaker mode for the

investigators to hear. During the conversation, SOI #1 mentioned

the murder of D-Nice. SOI #1 stated, “That if he is kin, you know

Donnie is going to kill them boys eventually, no matter how much

shit (a reference to heroin) they give him.” Davis agreed, saying,

“It is only a matter of time.” SOI #1 advised Davis to stay away

from Duncan. Davis explained that he is not worried about Donnie

(Duncan), he don’t trust him and goes out strapped (armed) to meet

him, but he is not worried about him.

73. On December 29, 2009, law enforcement investigators

51
met with SOI #1 regarding the BGF. During the meeting, SOI #1

provided the address of 2004 East Baltimore Street, Baltimore,

Maryland (the residence of McFadden, Subject Premise #5) as a

residence used by BGF to store handguns. SOI #1 stated that

approximately one month ago SOI #1 was parked outside of 2004 East

Baltimore Street, when a BGF member identified only as Capo exited

the residence and placed four 9 MM handguns into SOI #1’s vehicle.

The handguns were then transported to a residence frequented by

Taterman.

74. On January 5, 2010, SOI #1 contacted law enforcement

investigators regarding the BGF. SOI #1 advised that he/she had

recently been at a bar in southeast Baltimore frequented by BGF

members. While in the bar, SOI #1 overheard a conversation between

several men regarding a recent abduction and murder. SOI #1

reported that an individual named “Marquel” had been kidnapped two

days ago and was subsequently murdered. The victim’s body was later

located in the Park Heights area of Baltimore and the vehicle used

in the crime was found by law enforcement on Pennsylvania Avenue in

Baltimore. According to SOI #1, he/she overheard that the

individuals responsible for the abduction and murder are Jim Dog

(Rhodes) and several other BGF members. During the abduction, a

ransom was paid for the return of the victim. The person who picked

up the ransom money was Sister Kim, (McIntosh). Upon receiving the

information, investigators contacted the Baltimore Homicide Unit and

52
learned that on January 3, 2010, Marcal Antwan Walton was abducted

and later found murdered in the 2300 block of Ocala Avenue in the

Park Heights community. Homicide Detectives have identified Jim

Dog, a/k/a William Rhodes, as a possible suspect in the homicide.

75. On January 7, 2010, SOI #1 contacted law enforcement

regarding recent activities related to BGF. SOI #1 stated that on

January 6, 2010, shortly after 8:00 p.m., Duncan and Taterman were

involved in a verbal argument in the area of Homewood Avenue and

East Preston Street. During the argument, Duncan scolded Crawford

for not following the proper protocol when it came to committing

violent acts against the community. According to SOI #1, Duncan

explained that all of the shootings and murders Crawford had been

committing needed to be cleared through him, and that he (Crawford)

should not be handling things with out prior approval. SOI #1

stated that Crawford produced a large handgun and advised that he

will do what ever he wants and no one can stop him. As the argument

continued, SOI #1 stated that Sister Kim (McIntosh) was observed

walking from her home (Subject Premise #1) carrying a large

revolver. McIntosh also became involved in the argument, ultimately

telling Crawford that he needed to follow proper protocol.

76. Later on January 7, 2010, SOI #1 again contacted law

enforcement and advised that Duncan had been arrested in the evening

hours of January 6, 2010 for unknown reasons. A query of law

enforcement databases revealed that Duncan was arrested in the 1100

53
block of Homewood Avenue (the same block as Subject Premise #1, and

the location of the altercation with Taterman) at approximately 8:40

p.m., on January 6, 2010 for providing a false statement to a police

officer.

77. On January 21, 2010, law enforcement debriefed SOI

#1 regarding the current drug activity of Chambers and Duncan. SOI

#1 advised that Chambers is still controlling a street distribution

location for heroin in Baltimore. SOI #1 explained that the shop,

while controlled by Chambers is actually operated by an individual

known as Tiger (later identified as Jon Brice). SOI #1 provided

Tiger’s phone number as (410)940-4668. SOI #1 also explained that

Duncan is the source of heroin at the shop and that Duncan recently

provided the heroin directly to Tiger for distribution, while

relying on Chambers to collect the proceeds.

C. Communities Organized to Improve Life, Inc. (COIL)

78. As noted above, members of BGF have attempted to

legitimize the BGF by publicly calling for an end to inner city

violence. In strikingly similar fashion to Eric Brown’s efforts

with the Black Book, Duncan has been employed as a youth counselor

at Communities Organized to Improve Life, Inc. (COIL), a non-profit

organization committed to the reduction of violent crime. COIL is

funded by a grant announced on August 9, 2007 by then Mayor Shelia

Dixon and the Baltimore City Health Department for $382,600. The

funds were provided to COIL to implement Operation Safe Streets in

54
Southwest Baltimore. Operation Safe Streets is a community based

violence prevention program focused on reducing shootings and

homicides in Baltimore City. COIL is the second location for

Operation Safe Streets, the first location was in the McElderry

Park and Madison East neighborhoods. Funding for the Operation Safe

Streets initiative run by COIL is provided by a grant from the

United States Department of Justice.

79. CS4 previously provided information related to Duncan

and COIL. According to CS4, Duncan works at COIL as a way of

legitimizing himself in the eyes of law enforcement and the public.

Duncan gives the appearance of working with at risk youth, while

maintaining his role as leader of the BGF. Additionally, Duncan has

assisted other BGF members like Ronald Scott, a/k/a “Piper,” to

obtain jobs as youth counselors at COIL. CS4 related that the

Operation Safe Streets located in the McElderry Park and Madison

East neighborhoods is controlled by the BGF, specifically Anthony

Brown, a/k/a “Gerimo.” According to CS4, BGF members released from

prison can obtain employment from Operation Safe Streets.

80. On January 24, 2010, Duncan appeared on a local

Sunday morning television show, Grace and Glory. The brief segment

showed Duncan being interviewed by the show’s host highlighting the

“great” work COIL was doing. During the segment, Duncan identifies

himself as a “former” gang member.

81. On March 27, 2010, at approximately 3:28 p.m., Duncan

55
received an incoming call from (443)717-8417, utilized by Killa.

During the conversation Duncan advised, "I need you down here.

Cause I'm down here with the brothers, Meech and all them." Killa

asked, "Where at?" Duncan answered, "Down by my job (a reference

to COIL)." Killa asked, "What time?" Duncan answered, "Right now

if you can get here. But ev, everybody here." Killa responded,

Alright, alright um that's Cal, down there where we used to come at,

Baltimore and Calhoun right?" Duncan answered, "Carrollton." Killa

responded, "Carrollton, alright I'm gonna try to get a ride now."

Based on their training and experience and other information

developed during this investigation, law enforcement agents believe

that Duncan was holding a BGF meeting at COIL, the corner of W.

Baltimore Street and S. Carrollton Avenue.

D. Intercepted Communication

82. Throughout this investigation, law enforcement has

intercepted calls corroborating the information provided by the

sources listed above. These intercepted calls identify not only

BGF’s illegal activity, including drug trafficking, but BGF’s

organization, structure and hierarchy as a racketeering enterprise.

1. Gang Activity

83. On February 14, 2010, at approximately 11:58 a.m.,

Chambers received an incoming call from Duncan using the Duncan

Cellphone. During the conversation, Duncan asked, “What happened

last night? They talking about running you through.” Chambers

56
responded, “Who gonna run me through?” Duncan continued, “They said

they got to fighting and you ain’t assist them.” Chambers

continued, “Cause I wasn’t, I wasn’t over there. Me and Lamont was

right there. When I got there I made a sure them mother fucking

niggers…When we got over there we just (inaudible). I’m like man

what the fuck? Who the fuck, that’s Dill. So man Dill come to me

said yo go over your table man. So I go over there to your table

and I said what the fuck going on? So he said the niggers is going

out. Man, well tell them to run me through. Cause Lamont, all of

them over there. Tell them, tell them, tell them run me through.”

Duncan responded, “But Lamont and them don’t got nothing to do with

nothing.” Chambers continued, “But we (inaudible), how the fuck you

gonna attack, how I’m gonna assist you when we don’t know what the

fuck going on. When we, when me and Lamont really got over there

he, we seen Dill. Cause Dill told me he said yo that’s Taterman,

grab Taterman. So I go over to Taterman and said what the fuck

going on? He said the nigger, we didn’t even know who the niggers

they was fighting. So really I thought like… I’m like what the fuck

going on? So Dill try to actually tell me like, the nigger threw

some water. I said the nigger threw some water. So when me and

Lamont got over there, I said that’s Dill fighting. So when Dill

come over he say yo grab Taterman. I said what the fuck going on.

So I grab, so I go over to Taterman, Taterman already zapped out.

I said what’s going on? Taterman saying, man I knocked these

57
niggers out. I said you knocked them out? He said yeah, I said the

nigger threw some water. Me, me and your cousin (inaudible). So

I didn’t leave nowhere. Me and Lamont ain’t leave nowhere after we

found out what’s going on. So I like man, he said, so Taterman said

look yo they getting the dude just like gave me a whatya call’m.

So Kool Aid said I’m going out by myself. I’m the last one going,

and then I didn’t go to sleep until everybody was clear. I called

Dill and everything. So I’m like, he said, I said meet us down the

whatya call’m. So Lamont was like, Lamont, me and Lamont get on the

truck we had the man, he said come on yo let’s get them, niggers

getting ready to come out. So (inaudible), so we ain’t, I still

don’t go nowhere until Dill like, you all good. Don’t, you all good.

Kool Aid got it (a gun) on him now. Now you all can come out. So

we come out, I said man the dude was already pointing the gu, one

of ours was on, our little homey was already on point. To go and

do what they get, do, do what they get. So I said ok. I still

don’t leave till Gutter, I call Taterman and hundred times yo. I

said you still right there we turning back to get you now. He said

we good yo, we gone, we gone. I said man we coming to get you right

now. He said we good, we gone. I said alright. I still don’t

leave until I knew all of them was safe.” Duncan responded, “Well,

Black said they in there fighting, Black said they in there

fighting, Black the one that running you through.” Chambers

continued, “Well tell him run me through...cause I wasn’t over

58
there, cause I know how… He wasn’t fighting. I ain’t see him

fighting. When I go over he was standing, when we got over, when,

when me and Lamont got over, we, when we got over there and find out

who it was, Black was right there. He’s like man you know this and

that. I said man who the fuck you said, who the fuck was fighting?

So when they turn I just seen Dill. But we didn’t even know

Taterman or none of the comrades cause we thought it was little

homeboys. Me and Lamont thought it was little homeboys fighting.

We didn’t know Taterman, Kool Aid and them was fighting. Cause we

wasn’t over there when the shit got off. So when I asked Dill, I

was like yo what the fuck happened? He said nigger threw the water

and Taterman knocked him out. I want him to run me through. Yeah

this time I want him to run me through. Cause this time Lamont and

them, they got to come and play. I want them to come. I want them

to run me through. Cause he sitting there running his fucking

face.” Based on their training and experience and other information

developed during this investigation, law enforcement agents believe

that Duncan was notifying Chambers that he is being brought up on

BGF charges (a reference to being “run through”) by BGF member

Black. According to Duncan, Black said that Chambers did not help

“comrades,” Taterman and Kool Aid, when they were involved in a

fight at a club.

84. On March 8, 2010, at approximately 11:40 a.m., Duncan

placed an outgoing call to (410)913-6234 utilized by McIntosh.

59
During the conversation McIntosh advised, "I got about three things

for you. What you doing today?" Duncan answered, "A rack of shit.

Why what's up?" McIntosh answered, "Um the first thing is I got a

call this morning from um Chanell. Rem baby mother. He at it on

her again." Duncan advised, "I don't want to hear nothing more with

that. Go ahead." McIntosh continued, "Ok second thing, who do, who

should I direct that to?" Duncan answered, "I don't even, I don't

even care nothing about that. Go ahead." McIntosh continued, "Ok

second thing is um, Twan is reaching out again." Duncan asked,

"Which one?" McIntosh answered, "The one, south Baltimore one. I

just told him to right up his complaints and pass it in." Duncan

responded, "Alright." McIntosh continued, "And that, that's how I,

you feel what I'm saying? And then Rem gonna lean on him telling

him he shouldn't have gone over east. They dealing with the shit

on this side. Something, something, something." Duncan asked,

"What he mean (unintelligible)." McIntosh continued, "So you feel

what I'm saying? I'm not, I'm, I don't want deal with it cause he

gonna think it's a personal." Duncan advised, "Don't worry about

it I'll send somebody over there." McIntosh responded, "Ok good

enough." As the conversation continued Duncan advised, "I'm

trying, I'm trying to make, make something happen but um, I'm a, I'm

a try to do it." McIntosh responded, "Ok and remember um, remember

um, what was it, the day before yesterday." Duncan answered,

"Yeah." McIntosh continued, "I think you can go four." Duncan

60
responded, "Huh, oh yeah!" McIntosh continued, "I think you, yep,

yep." Duncan asked, "Oh wit, wit, wit, wit, with the old peoples?"

McIntosh answered, "With the new peoples. With the old, old. You

know the, the new joint." Duncan responded, "Wit a, wit, with the

huh?" McIntosh continued, "Limpy boy." Duncan responded, "Yeah

that's what I'm saying, yeah." McIntosh responded, "Yep." Duncan

responded, "Alright that's what's up." McIntosh advised, "I heard

all, like you know one to ten. Like past ten. They couldn't even

say ten. It was like twelve or thirteen." Duncan asked, "For real?

And what you put yourn'?" McIntosh answered, "Um now that's the

key, that's the key. I uh, under three. Barely under three."

Duncan responded, "So mines, mines should be good then. Cause I,

I done a three and a half." McIntosh responded, "Yep, you should

be, you should be fine." Duncan responded, "Alright that's what's

up." McIntosh continued, "Yep you should be fine. I had got a call

late, late last night they was oh yeah, oh yeah. Ok." Duncan

responded, "Alright that's, that's what's up." Based on their

training and experience and other information developed during this

investigation, law enforcement agents believe that in the beginning

of the conversation McIntosh was advising Duncan, who is the overall

city wide commander of BGF, about BGF matters related to "Reem" (a

reference to Kareem Randall); and complaints by BGF member "Twan."

Regarding Randall, Duncan advised, "Don't worry about it I'll send

somebody over there." Regarding Twan, McIntosh advised, "I just

61
told him to right up his complaints and pass it in (a reference to

having high ranking BGF members review the complaints).” As the

conversation continued Duncan and McIntosh discussed a recent supply

of heroin, how many times the heroin could be cut, and the overall

quality. McIntosh advised, "I heard all, like you know one to ten.

Like past ten. They couldn't even say ten. It was like twelve or

thirteen" (a reference to Duncan having heroin with a high purity.)

McIntosh and Duncan then discuss how they processed and mixed their

heroin. McIntosh said, "I uh, under three. Barely under three,"

and Duncan responded, "So mines, mines should be good then. Cause

I, I done a three and a half." McIntosh responded, "Yep, you should

be, you should be fine."

85. On March 8, 2010, at approximately 8:23 p.m., Duncan

received an incoming call from McIntosh. During the conversation

McIntosh advised, "Remember the little one I told you, that little

uh number one from south?" Duncan responded, "Yeah." McIntosh

continued, "He, he over that jail." Duncan responded, "Again?"

McIntosh continued, "Yeah I told you it was a warrant out." Duncan

asked, "For what?" McIntosh advised, "They reopened, that they re,

they, there was a warrant out um and they reopened up one of his

cases." Duncan responded, "Oh damn." McIntosh continued, "Yep one

that was put on the stet that got him out." Duncan responded,

"Yeah." McIntosh continued, "They reopened, they reopened it. I

don't know why. I ain't never seen no shit like that in the

62
computer. They reopened it." Duncan asked, "The feds got him?"

McIntosh answered, "Um no I doubt it. No he over the jail." Duncan

advised, "They might. Yeah but I'm saying, that, they would reopen

his case. The thing is you see it got put on the stet before. He

ain't never set on the stet." McIntosh continued, "Um yeah he be

getting, he escapes all the time. I don't even (unintelligible)."

Duncan advised, "No but you know they, you know they can reopen your

shit if it's on a stet." McIntosh responded, "Oh well yeah that,

that's what happened. But I ain't see no (unintelligible) cards.

Or I'll go in there tomorrow though." Duncan responded, "Oh, yeah

that, that was right too." McIntosh responded, "Yeah?" Duncan

continued, "Yeah." McIntosh continued, "Ok. We gonna have to work

something out here though. You know that right?" Duncan responded,

"(Unintelligible) yes." McIntosh responded, "Huh?" Duncan advised,

"I'm listening." McIntosh continued, "Ok I think, we'll think,

we'll come up with something fair." Duncan advised, "Here you go

with your shit. You (unintelligible). You paying seventy five

dollars already for it." McIntosh advised, "Well that's cool too,

that's cool." Duncan continued, "Yeah." McIntosh continued,

"That's cool." Duncan advised, "You feel what I'm saying? I'm not,

I'm, I'm not doing it for nobody else just you." McIntosh

responded, "That's fine." Duncan continued, "You know what I'm

saying? You and Ben (McFadden) the only two. You feel what I'm

saying?" McIntosh responded, "Yeah." Duncan continued, "Ain't

63
nobody, I ain't doing it for nobody else." McIntosh responded, "Ok,

ok, ok. Oh I (unintelligible)." Duncan responded, "Huh?" McIntosh

continued, "Like (unintelligible)." Duncan advised, "Yeah I'm about

to get a new number too. So um…" McIntosh responded, "Me to, me

to." Duncan continued, "Um I'm a call you from a new number."

McIntosh advised, "No don't call me on this phone." Duncan advised,

"Alright soon as these, these minutes run out." McIntosh advised,

"Wait, wait for me to um get a new phone and then you call me on my

new phone." Duncan responded, "Alright." McIntosh continued,

"Cause you calling me on this phone is the same. Like you know what

I'm saying?" Duncan responded, "Right yeah." McIntosh continued,

"So like I'm a, I'm a try to get a new phone." Duncan responded,

"Yeah." McIntosh continued, "And you call me on that phone and then

that will be the new. You feel what I'm saying?" Duncan responded,

"Right." McIntosh continued, "Yeah I think, yeah I'll do that

tomorrow. Or maybe not tomorrow." Duncan and McIntosh then

discussed new homes for McIntosh and Duncan's mother. McIntosh then

said, "Alright well um, was there something else, no I guess that's

it. That was the main thing. You already know that was the main

thing." Duncan responded, "Right." McIntosh continued, "Yeah I

don't know and I, there's a few people over there you know." Duncan

responded, "Right so, but um the right people there so they already

know. So you know." McIntosh responded, "I know, I know let's

hope." Duncan advised, "If a mother fucker over there…" McIntosh

64
advised, "You know Rudy over there." Duncan continued, "Right so

if a mother fucker make a, make a call out here I'm gonna be very

disappointed." McIntosh responded, "Yeah I know." Duncan

continued, "You feel, you feel what I'm saying?" Based on their

training and experience and other information developed during this

investigation, law enforcement agents believe that during the

initial portion of the conversation McIntosh was advising Duncan

that "that little uh number one from south,” (a reference James

Harris, a/k/a Johnny Five) was arrested on a warrant and is

currently being house at the Baltimore City Detention Center. The

conversation then shifted to Duncan, McIntosh and McFadden's drug

trafficking activities. McIntosh advised that she and Duncan needed

to talk about the profits being made from the sale of their drugs.

Duncan explained, "You paying seventy five dollars already for it

(a reference to seventy five dollars per gram of heroin).” McIntosh

advised, "Well that's cool too, that's cool." Duncan continued,

"Yeah." McIntosh continued, "That's cool." Duncan advised, "You

feel what I'm saying? I'm not, I'm, I'm not doing it for nobody

else just you." McIntosh responded, "That's fine." Duncan

continued, "You know what I'm saying? You and Ben the only two."

(Duncan was referring to selling heroin to McIntosh and McFadden for

seventy five dollars per gram of heroin which is at a lower cost

than any of Duncan's other drug purchasers.) The conversation then

returned to the arrest of Harris. McIntosh advised, "there's a few

65
people over there you know" to which Duncan responded, "Right so,

but um the right people there so they already know. So you know."

McIntosh responded, "I know, I know let's hope." Duncan advised,

"If a mother fucker over there…" McIntosh advised, "You know Rudy

over there." Duncan continued, "Right so if a mother fucker make

a, make a call out here I'm gonna be very disappointed." During

this part of the conversation McIntosh and Duncan were discussing

how there were BGF members at the detention center with Harris that

are expected to inflict bodily harm on Harris. Duncan explained

that no one should have to contact him from inside the detention

center to verify whether or not Harris should be harmed, they should

already know what should happen to Harris. During the

investigation, law enforcement has learned from confidential sources

that Harris is being held responsible for murdering a BGF member.

The murder Harris committed was not sanctioned by Duncan, therefore,

Harris is to be harmed on sight

86. On March 21, 2010, at approximately 4:42 p.m.,

Chambers received an incoming call over the Chambers Cellphone from

Loc. During the conversation Chambers told Loc to advise Nut that

he was getting ready to walk up. As Chambers is speaking with Loc,

McIntosh was heard in the background stating, "If you register them

without their money right. (Unintelligible). And, and they don't

got the (unintelligible). In thirty days we should have three

thousand dollars from every comrade and every comrade should

66
(unintelligible). Then from that point when the thirty days on

(unintelligible) for my registration. But I know that

(unintelligible) is not going to stop until the thirteenth. That

gives people a chance to really try to get it together." Based on

their training and experience and other information developed during

this investigation, law enforcement agents believe that McIntosh was

advising the high ranking BGF members attending the meeting that she

had devised a plan for registering new members that would net the

gang a large profit. According to McIntosh, each area commander

would be expected to pay to finance in thirty days three thousand

dollars from their immediate underlings. This influx of cash would

enable the gang to boost the amount of money they currently have in

BGF finance.

87. On March 27, 2010, at approximately 6:31 p.m.,

Chambers received an incoming call over the Chambers Cellphone from

McFadden. During the conversation McFadden advised, "Hey Dookie,

I need you to uh, get a count of everybody that's gonna register yo.

And get that twenty five dollars from em' and I'll come holler at

you." Chambers responded, "Right." McFadden continued, "And call,

call me as soon as you get everything together." Chambers

responded, "Alright, I, I'm, I'm waiting for um, I gotta…" McFadden

advised, "I need it by Monday." Chambers responded, "Ok I'm, I'm

already on top of all that." McFadden responded, "Alright." Based

on their training and experience and other information developed

67
during this investigation, law enforcement agents believe that

McFadden was instructing Chambers to collect twenty five dollars

from each BGF member under his command which he, McFadden would

collect and place into BGF finance.

88. On March 27, 2010, at approximately 6:23 p.m., Duncan

received an incoming call from Smiley. During the conversation

Harried, a/k/a Smiley, said, "Yo, hey I wanted to ask you a question

right." Duncan responded, "Yeah." Harried continued, "I'm down

here with uh, with uh, uh Ben and you know Sean right." Duncan

responded, "Yeah." Harried continued, "And Sis (McIntosh), uh you

(unintelligible) counted their little, their little money. But Sis

wants uh, them to uh write down the names and stuff. Can you please

get it from her later on today?" Duncan responded, "Alright, just

text me and tell me how much it's supposed to be." Harried

responded, "Uh nah, nah, nah. Uh, uh Ben got the money." Duncan

responded, "Alright so Ben gonna text me again." Harried asked,

"You hear me?" Duncan responded, "Say it again." Harried

responded, "Ben got the money but she got the names." Duncan

responded, "Right, so you all, you all want the papers. You all,

so you all want the names from her?" Harried responded, "I mean

that's what you, that, I mean that's what you were saying." Duncan

responded, "I ain't, I don't understand Smiley." Harried continued,

"I mean, you know she got, she got you know their, their names and

phone numbers and stuff like that." Duncan responded, "Right, yeah

68
but I…" Harried continued, "If you want her to keep it she can."

Duncan responded, "Yeah she, she, that, that's her job." Harried

responded, "Ok I'll just hand them to her." Duncan responded,

"Yeah, alright." Based on their training and experience and other

information developed during this investigation, law enforcement

agents believe that Harried, McIntosh and McFadden were together

counting the money that had been collected from BGF members and were

completing a detailed list of the BGF members who had provided money

toward BGF finance. Harried advised Duncan that McFadden had the

money from the BGF membership. However, Harried was unclear whether

the list of BGF contributors should be delivered to Duncan. Duncan

advised that the list should be left with McIntosh. Harried

explained, "I mean, you know she got, she got you know their, their

names and phone numbers and stuff like that." Duncan responded,

"Right, yeah but I…" Harried continued, "If you want her to keep

it she can." Duncan responded, "Yeah she, she, that, that's her

job."

89. On March 29, 2010, at approximately 10:42 a.m.,

Duncan placed an outgoing call to McIntosh. During the conversation

Duncan advised, "I definitely got to get up with you today for

real." McIntosh responded, "Oh yeah." Duncan continued, "Yeah."

McIntosh responded, "Ok, ok. Well I'm at work. I know you don't

got to work today." Duncan responded, "Right." McIntosh continued,

"And it's a rainy day too." Duncan responded, "I know. I talked to

69
um Bow (a reference to Rainbow William, who was indicted in the 2009

Indictments)." McIntosh asked, "Uh the old man?" Duncan answered,

"Uh he ain't old. Bow." McIntosh responded, "Oh Moe." Duncan

yelled, "Bow." MCINTSOH responded, "My, oh, oh, yeah." Duncan

advised, "Yeah and um your name, my name came up." McIntosh asked,

"What we do now?" Duncan yelled, "Just listen. You know where he

at [federal detention awaiting trial]." McIntosh answered, "Yeah,

oh for real!" Duncan answered, "Yeah." McIntosh responded, "Ok."

Duncan continued, "And, and, and the crazy thing is right, you hear

me?" McIntosh answered, "Yeah." Duncan continued, "Like it wasn't

nothing bad. You feel what I'm saying?" McIntosh responded,

"Yeah." Duncan continued, "They asked you know, uh they were

telling him or whatever right." McIntosh responded, "Yeah." Duncan

continued, "But you, um, the dude R (Ray Olivis) and the dude E

(Eric Brown) right." McIntosh responded, "Yeah." Duncan continued,

"But they, they, it was like ya'll, ya'll was the main ones at

first." McIntosh asked, "For real?" Duncan answered, "Yeah that's

how they got started." McIntosh responded, "Oh shit. But that's

crazy though cause at that time, you got to think about that time.

I was quiet for a whole like eight months. I didn't talk to them

at all. You feel what I'm saying? At all, at all. Nobody over

there." Duncan responded, "Right." McIntosh continued, "So I don't

know how, you see what I'm saying." Duncan responded, "Yeah."

McIntosh continued, "Oh my. Yeah you gonna definitely have to sit

70
down and fill me in on all the little details on that." Duncan

responded, "Yeah cause he really didn't get in to it but um, I'm

gonna have somebody go see him though, visit him for real."

McIntosh responded, "Alright." Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Duncan was

advising McIntosh that he received word from "Bow" (a reference to

Rainbow Williams) regarding McIntosh. Duncan explained that law

enforcement began their initial investigation of BGF centered on

McIntosh, Ray Olivis, a/k/a Uncle Ray, and Eric Brown, a/k/a EB.

Duncan advised, "But you, um, the dude R and the dude E right."

McIntosh responded, "Yeah." Duncan continued, "But they, they, it

was like ya'll, ya'll was the main ones at first." McIntosh asked,

"For real?" Duncan answered, "Yeah that's how they got started."

McIntosh responded, "Oh shit. But that's crazy though cause at that

time, you got to think about that time. I was quiet for a whole

like eight months. I didn't talk to them at all." During the

initial investigation McIntosh, Olivis, Williams, and Brown were

identified by law enforcement as high ranking BGF members. Ray

Olivis, Rainbow Williams, and Eric Brown are currently in federal

custody pending trial for conspiracy to distribute heroin. McIntosh

was not charged during the initial BGF investigation.

90. On March 29, 2010, at approximately 1:48 p.m., Duncan

placed an outgoing call to Barry. During the conversation Duncan

71
asked, "Hey now what was going on? Barry answered, "Alright like

I said that same incident that happened over there right. What it

was they got a little com, you know comrade out here right." Duncan

responded, "Right." Barry continued, "He made accusations that he

gonna start putting his hands on other brothers right. So um…"

Duncan responded, Right." Barry continued, "You know they giving,

a matter a fact he was down with C. You know so uh they getting a

little, a little thing about that right. So early that morning I

comes out here. He gets to beefing with some old men. He bumps the

old man car and the old man get out. They get to arguing. He beat

the old man with a shovel and then bust the old man windows. They

get, you know, telling about that, no you was wrong about that. So

he tell the comrade alright, you nah mean I'm, I'm a see. He rolls

out, comes back with a gun. The (unintelligible) dude was foxin'.

Oh no you can't do this. He (unintelligible). So he shoots him,

shoots the man. So the dude took the gun back so he shoot him

back." Duncan asked, "For real?" Barry responded, "Yeah so he on,

he, he, he, he on the run now. But the thing is you, he goes down

there with a gun to do harm to another brother." Duncan responded,

"Right." Barry continued, "And just happy he ain't hit another

dude." Barry and Duncan continued to discuss the shooting

situation. Barry then advised, "Moe and them made a suggestion

right. I just got to talking to him. Well I know the suggestion

to give to you right. He…" Duncan responded, "Yeah." Barry

72
continued, "But it's more so dealing with the Sister (McIntosh)

right. He was, he feels that you know, she should no longer receive

any type of paperwork. Saying that her name supposedly keep coming

up." Duncan responded, "Oh yeah." Barry continued, "You know, a

that's a suggestion he said (unintelligible) we should give to you.

For me to give to you." Duncan responded, "Ok." Barry continued,

"Shouldn't receive no more. You know. I said yo since her name you

know cause that puts safeguards definitely on you. It's about

(unintelligible)." Duncan responded, "Right." Barry continued,

"Man if anything that she'd have, she should you know give it up.

Because if not you know if so man you know, sh, sh, she might be the

one that they go through just to bring us down. Cause I'm saying

they know there's some ones out there that escaped you know that

they really want. And you know uh…" Duncan responded, "Right."

Barry continued, "And my main man you know he one of em'. You nah

mean?" Duncan responded, "Yeah." Barry continued, "Yeah brother

you got to know, you, you got to think that. You know what I mean?

And, and, and, and, and then when we talking on this thing (a phone)

like this man we got to go back to our Swahili roots man." Duncan

responded, "Alright that's what's up." Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Barry was

explaining that he had a problem with a BGF member who had violated

protocol by attacking an older gentleman and then later shooting a

73
BGF comrade, both of which are in violation of BGF protocol. Later

in the conversation Barry advised that he and others believe that

law enforcement has not concluded their investigation into BGF.

Barry and others believe that McIntosh may be the downfall of BGF.

Barry advised, "she should no longer receive any type of paperwork.

Saying that her name supposedly keep coming up." Barry continued,

"Man if anything that she'd have, she should you know give it up.

Because if not you know if so man you know, sh, sh, she might be the

one that they go through just to bring us down. Cause I'm saying

they know there's some ones out there that escaped."

2. Drug-Trafficking/Drug Smuggling

91. On February 10, 2010, at approximately 12:53 p.m.,

Chambers received an incoming call from (410)327-0407, utilized by

Shelly. During the conversation Shelly asked, "Did it fall

through?" Chambers answered, "No that mother fucking weather14 been

stopping me yo." Chambers then asked to speak with "Fat Ass."

Shelly then put Toot, a/k/a Fat Ass, on the telephone. Chambers

asked, "What's up fat boy?" Toot responded, "Oh man just

maintaining waiting on the boat come through. So we can get this

shit started." Chambers advised that because of the snow he has

been confined. Toot advised, "Well if you ever need another spot

you need to let me know. I'm on a, I'm trying to get up here on a

14
This telephone call coincides with the two major
snowstorms in the Baltimore area in early 2010.

74
Biddle and a Patterson Park. I want something new (a new drug

distribution location). I ain't going back around there. There

ain't nothing around there." Chambers responded, "Right, but a

bunch of bull shit ass niggers that want to beef (fight over drug

territory)." Toot continued, "Yep but like, but like up on Milton

with some shit like that." Chambers advised, "Like, like that shit

right, that's why I really got mad. You know what I mean? That's

why I came around there. You know what I'm saying? Because that

some bull shit yo was on." Toot continued, "Yeah man cause I ain't

even do nothing to that nigger. I got locked up that nigger even

called that nigger and told that nigger. That nigger and I told him

I used the money. He said ok. When I came home he was like, I said

man I know you ain't gonna cut me off. I know you gonna give me a

chance to get the money back. He like nah I ain't gonna cut you off

(halt the supply of drugs). I ain't gonna cut you off. Like three

months went past. You know I mean? I supposed to keep asking him.

So then soon as I finally got my hand on something, the same day I

finally got my hand on something he gonna send the boy James

Finchman, the boy James up there. You know what I mean? Then James

go back down there and tell him yeah Toot up there. So then him,

that shit is crazy." Chambers responded, "Yeah I ain't like that

either yo." Toot advised that after that time he had problems

obtaining a new supply of drugs. Toot said, "He stagnated me."

Based on their training and experience and other information

75
developed during this investigation, law enforcement agents believe

that the recent snowstorm has caused problems with their ability to

sell drugs, and past problems with money and obtaining consistent

supplies of drugs.

92. On February 17, 2010, at approximately 3:42 p.m.,

Chambers placed an outgoing call from the Chambers Cellphone to

Duncan on the Duncan Cellphone. During the conversation Chambers

advised, "Yo I', I said I'm right here with Dre he want to holler

at you." Duncan responded, "Wait, he gotta, you gotta wait. I'll

call ya'll back." Chambers responded, "Alright, well you want me

to give him the number?" Duncan responded in a heated tone, "I'm

waiting on a call. I'll call you back." At approximately 3:43

p.m., Duncan returned the call to Chambers using the same phones.

Upon answering the call Chambers advised, "Hey here go Dre he want

to holler at you." Duncan asked, "What Dre is this?" Chambers

answered, "Tall Dre, right here." Duncan asked, "Which one? Yeah,

who kept my mother fucking money!" Dre then used the Chambers

Cellphone to speak with Duncan. Dre said, "Yo." Duncan asked, "Hey

what's with my money man?" Dre answered, "Huh?" Duncan yelled, "My

money." Dre responded, "Yo, I told you soon when I get it I got

you." Duncan responded, "Man I'd a been locked up on some bull

shit." Dre continued, "Right I been looking uh, uh, uh, uh, uh I

been looking for you. I been, I been looking for you. I been

sending messages to you." Duncan advised, "Well I didn't get none

76
of your messages." Dre responded, "You didn't get none of my

messages. Killer ain't tell you my message?" Duncan continued,

"None of them, none of them." Dre advised, "You is, you is kidding

me." Duncan advised, "No, I didn't get none of your messages." Dre

responded, "That's crazy. Every time I come over I see yo and I

tell him, yo tell Donnie (Duncan) I been in contact." Duncan

advised, "No, nobody gave me no message." Dre advised, "Man I

really, really, really need to holler at you though." Duncan

advised, "Well I'm on my way to Delaware right now to the guy that

be frontin'." DRE asked, "When, when, when, when a good time?"

Duncan advised, "I, I'm leaving for Delaware now. Tomorrow…" Dre

continued, "I say… Tomorrow? Around what time?" Duncan continued,

"Yeah." Dre asked, "And where at?" Duncan advised, "It don't make

a difference tomorrow. Just hit my, just get this number from um,

Ducon (Chambers)." Dre responded, "Alright, alright, alright."

Based on their training and experience and other information

developed during this investigation, law enforcement agents believe

that Dre owed Duncan for a past drug transaction and Duncan wanted

the money prior to any additional drug sales to Dre. Duncan stated

he was going to Delaware, "to the guy that be frontin'" (a reference

to being supplied drugs on consignment) and that if Dre wanted to

purchase additional drugs from Duncan he would be available the

following day.

93. On February 18, 2010, at approximately 12:45 p.m.,

77
Chambers received an incoming call over the Chambers Cellphone from

Chips. During the conversation Chips asked, "You know somebody that

work down Brockbridge?" Chambers answered, "Yeah." Chips

continued, "Oh alright you know my other cousin, you know his

brother down there." Chambers responded, "Bug." Chips advised,

"Yeah we trying to handle something." Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Chips was

inquiring whether Chambers knew of a corrections officer at the

Brockbridge Correctional Facility who may help them smuggle

contraband into the facility for his cousin Bug. Chips advised,

"Yeah, we trying to handle something," and Chambers acknowledged

that he had an individual that would help them.

94. On March 2, 2010, at approximately 7:34 p.m., Duncan

placed an outgoing call to Jermain Davis. During the conversation

Davis commented on how Duncan hurt his (Davis’s) feelings when

Duncan questioned him about his (Davis's) drug trafficking

activities. Davis said, "Nigger that's how the fuck I was doing

what I was doing when we was rollin'. You feel me? Hello, huh."

Duncan responded, "Yeah I'm here. (Unintelligible)." Davis

continued, "Yeah I said, I said that's how I was doing what I was

doing when we was rollin'." Duncan responded, "You just take so

fucking long." Davis asked, "What time you get out the, huh?"

Duncan continued, "You just be taking so fucking long. I understand

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what your doing but god damn." Davis responded, "Yo, yo for real

yo, no for real yo it be the police yo." Duncan responded, "I, I

already know that." Davis continued, "Soon as a nigger came out yo,

the knockers (police) came. I said what the fuck!" Duncan

continued, "Yeah I already know. Look I had left some things with

her but how anybody gonna get it?" Davis responded, "And you left

them." Duncan continued, "Sitting here I thought about

(unintelligible). I said fuck that shit." Davis continued, "Yeah

and she looked. I had like seven of them under my balls right."

Duncan responded, "Yeah." Davis continued, "So when I seen them I

ate them. I said man what the fuck. So Emo was like yo, I need you

yo. So I was like yeah I get me, I can get some of these mother

fuckers in right now. You know what I'm saying?" Duncan responded,

"Right." Davis continued, "So when you was calling me." Duncan

responded, "Yeah." Davis continued, "I was running to get the

what's a names." Duncan responded, "Oh." Davis continued, "You

know what I'm saying? The one's I had left." Duncan responded,

"Right." Davis continued, "But Emo's like why the fuck is you

breathing? I said man look I was running." Based on their training

and experience and other information developed during this

investigation, law enforcement agents believe that Davis was

explaining to Duncan that the reason Duncan could not reach Davis

by phone was because Davis was busy on the streets of Baltimore

selling drugs for Duncan and trying to avoid being arrested by the

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"knockers" (a reference to narcotics officers).

95. On March 5, 2010, at approximately 6:17 p.m., Duncan

placed an outgoing call to Davis. During the conversation Davis

said, "Come holler at me man. Yo you still right?" Duncan

answered, "Not yet I'm waiting for the call now." Davis responded,

"Alright so you know what yo when, when I get it right." Duncan

responded, "Um hum." Davis continued, "And I see them that's what

it be best for me to do is mix it. You know what I'm saying?"

Duncan responded, "Alright." Davis continued, "So I can just go

with the flow." Duncan responded, "Right." Davis continued, "You

know what I'm saying? Then I be, you know doing it faster." Duncan

responded, "Right." Davis asked, "You understand what I'm saying?"

Duncan responded, "Alright that's what's up." Davis continued,

"That's fine, see I meant yo…" Duncan answered, "Yeah." Davis

continued, "And you see how shit been you know turning and it ain't

been that, it ain't been slow like that." Duncan responded,

"Right." Davis advised, "I had that since early today though. I

got yourin' out of the way first." Duncan advised, "Alright, I'll

be there." Based on their training and experience and other

information developed during this investigation, law enforcement

agents believe that Davis had been mixing and selling drugs for

Duncan throughout the day however the quality of the drugs was not

that good. Davis asked if Duncan was obtaining a new quantity of

drugs to which Duncan said he was. Davis then advised that he would

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mix the new drugs with the bad quality drugs, which would allow the

drugs to be easier to sell. Davis asked, "Yo you still right?"

Duncan answered, "Not yet I'm waiting for the call now." Davis

responded, "Alright so you know what yo when, when I get it right."

Duncan responded, "Um hum." Davis continued, "And I see them that's

what it be best for me to do is mix it."

96. On March 8, 2010, at approximately 7:57 p.m., Duncan

placed an outgoing call to Davis using (410)736-9634. During the

conversation Davis asked, "Yo why you ain't answer your phone

chief?" Duncan answered, "No cause I, I swear to god I didn't even

know the mother fucker was ringing." Davis advised, "I could have

been robbed yo. Somebody could have ended up killing me yo."

Duncan responded, "I didn't know, I didn't know that it was

ringing." Davis asked, "Oh, yo where my fifty dollars yo?" Duncan

advised, "I got you. I'm ready to um…" Davis asked, "Where you

at?" Duncan responded, "I'm on my way back down there so I can give

you…" Davis continued, "I'm leaving out she talking

(unintelligible) from Sis (McIntosh)." Duncan responded, "Alright

why you um, go get the um what's a name." Davis asked, "What?"

Duncan responded, "There's a single bag with four and I put the

other one in there." Davis responded, "Alright where it at?"

Duncan advised, "It's, tell her get it out the spot

(unintelligible)." Davis responded, "Alright I'll tell her." Davis

and Duncan then briefly discussed food and money Davis owes to a

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male named Sid, and then Davis calls, "Sis." McIntosh in the

background responded, "Yes." Davis continued, "He said give me the,

the four seams in the bag." McIntosh responded, "Of what?" Davis

continued, "There's four, there's four of them in a bag." Based on

their training and experience and other information developed during

this investigation, law enforcement agents believe that Duncan was

telling Davis to obtain the drugs he had left at McIntosh's

residence so he (Davis) could deliver them to Duncan. During the

call Duncan indicates that McIntosh has a hidden location in her

residence, Subject Premise #1, where she conceals the drugs.

97. On March 9, 2010, at approximately 10:22 p.m.,

Chambers placed an outgoing call to Davis using (410)539-1618.

During the conversation Davis advised, "Angie had leaned on Donnie

(Duncan) because I be helping this nigger eat yo. You feel me?"

Chambers answered, "Right." Davis continued, "And shit before the

police grabbed me I was doing like three, four hundred joints a day.

You hear me Ducon." Chambers answered, "I know." Davis continued,

"And then when I have to fall back and take it long, yo what are you

doing. Yo hold up. Who the fuck you think you talking to! You

hear me?" Chambers answered, "Right." Davis continued, "I'm like

yo, who the fuck is you think you talking to yo. Nigger I'm helping

you eat. And then he know what the fuck I be doing. I, I be

fucking with Emo and them right." Chambers responded, "Right."

Davis continued, "To slide shit in. You know I'm saying? So I can

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slide his shit in...and I told him nigger you be giving me bull

shit...where as though I got to get, you know I got to get with them

to mix the shit up. Dump, dump all of it out and mix it up...so I

won't fuck my name up. So nigger, cause he called me one day, got

a whole bunch of people on the squares." Davis continued, "So we

in Sis (McIntosh) house. So he called me like, yo what the fuck is

you doing yo? You playing games? I said man don't call my mother

fucking phone while I'm doing what I'm doing and I got. So he

called back like oh yeah yo it's like that. What the fuck's wrong

with you? So I hung up right. So after I got finished doing what

I was doing....so I called, so I called, he called me from Sis phone

right Ducon (Chambers)." Chambers responded, "Yeah." Davis

continued, "So he wouldn't get on the phone so I, I called Angie and

got Angie to call her, call him right. He's like yo what's going

on this and that. So uh, so Angie asked me. So I told her right.

I said man yo that nigger got to be crazy. When you helping this

nigger eat don't nobody do nothing for him but you." Chambers

responded, "Right." Davis continued, "So when I see him face to

face yo, I'm like yo what the fuck. You gonna act like you don't

know what the fuck I be doing. Oh yo my bad yo I'm sorry yo. I

wasn't even thinking because we was talking about something. I said

yeah you don't never think nigger. What the fuck is wrong with you?

You know the fuck I be swindling nigger miss, mixing and matching

nigger. Fuck is wrong with you? You know what the fuck I been

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doing for you. The whole time fucking with them and you know what

I'm saying? Not letting them niggers know. You know, you know

sliding shit in. When the fuck a, a, a, a jimmy mack is only

fifteen joints and you know what I'm saying? I got to dump that out

and bam, bam. Oh yeah I'm a give them their money first so you know

what I'm saying, their hundred, hundred dollars first. You know

what I'm saying? To get them out the way so I can slide ours in."

Chambers responded, "Right." Davis continued, "Dumb ass nigger

don't be asking me no questions. He like yo my bad this, yeah

alright yo. I said yo you be on some bull shit yo." Chambers

responded, "Don't he!" Davis continued, "No yo I'm sorry this and

that. Uh then he keeping asking me about fifty dollars. I said

Donnie (Duncan) I'm not giving you no fifty dollars man, fuck you.

I'm not giving you no fifty dollars." Chambers advised, "That man

is crazy." Davis continued, "I said I'm not giving you no fifty

dollars man. You got to be crazy. Then what fucked me up right,

this what fucked me up right. You know I had to go see Sis

(McIntosh) for him right." Chambers responded, "Right." Davis

continued, "So she gonna slide me her shit. You feel me?" Chambers

responded, "Right. She a sneaky mother fucker too." Davis

continued, "Listen, so he ain't answering his phone. You know he

don't, when it come down to his money yo haul ass. You feel me?"

Chambers responded, "Right." Davis continued, "So I put two and two

together, what the fuck. So I asked her. I like oh that was yours?

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She was like yeah. I said hold yo. I said Sis why you do that?

When you could have called me and asked me to take care of something

for you. You feel me?" Chambers responded, "Yeah." Davis

continued, "You ain't got to use slim and I told Donnie, yo don't

you never do that again yo. Cause the way me and you do business

you let me do it at my pace. You know what I'm saying? Cause she

calling me, calling me, calling me like you know what I'm saying,

like hurry up. What the fuck! You feel me?" Based on their

training and experience and other information developed during this

investigation, law enforcement agents believe that Davis was

advising Chambers that he was selling three hundred to four hundred

units of heroin for Duncan on a daily basis. Davis advised that in

addition to selling drugs for Duncan he (Davis) also was selling

drugs for an individual identified as "Nemo." Davis explained that

Duncan was receiving poor quality heroin and he (Davis) was mixing

Duncan's drugs with Nemo's drugs to get Duncan’s to sell. Davis

explained that Duncan recently had Davis sell drugs for "Sis" (a

reference to McIntosh) without asking him (Davis). Davis explained

that Duncan did not have to conceal the fact that he (Davis was

selling McIntosh's drugs because he would have sold them for her

anyway.

3. Acts of Violence

98. On February 8, 2010, at approximately 9:46 p.m.,

Chambers received an incoming call from (443)630-2120 utilized by

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Little Mike. At the initiation of the conversation Chambers

advised, "What's up Little Mike. The nigger can't find the dude

man." Little Mike asked, "You said you can't find him?" Chambers

continued, "No, then I heard brothers on him and everything. We

gonna keep on trying to flush his ass out boy but I ain't seen him."

Little Mike responded, "Yeah, yeah, yeah he goin, he gonna come

around. You know what I mean? Got to, he ain't got no where to

go." Chambers acknowledged, "Right." Little Mike continued, "You

know what I'm saying? Hey yo, man I need your help G man. Trying

to bounce back of that bullshit yo. That shit fucked us up." As

the conversation continued, Little Mike asked, "Yeah just grab, yeah

yo how much of that shit can you grab us yo?" Chambers asked, "What

you trying, what you trying to go?" Little Mike, "Man listen we

already got, we already, we just coped up on a QP of that shit

right. Man we just doing, just throw, just throw a little

something, put, put with that shit (inaudible)." Chambers

responded, "I can do that, I can do that for tomorrow." Little Mike

and Chambers then continue to discuss the distribution of different

drugs and making money from drug trafficking. Eventually, Little

Mike explains, "Yeah straight, you know what I mean? Soon as we

track that shit out. Yo a day or two yo. Straight send that shit

right back to you yo. I'd grab the white, grab the white

(inaudible). Whatever you can for real yo. Yeah the nigger we

gonna send through there he the one that gonna bring it straight to

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us. You see what I'm saying?" Chambers advised, "Right. You all

ain't selling nothing out here? I don't deal with that shit but I,

my man get it and I know, I know he a do, he do right by us."

Little Mike responded, "That's all we, we already spent almost all

our cake. That nigger fucked us up. Uh, uh, uh Ducon (Chambers)

yo, that nigger fucked us up yo. You hear me? Yeah that nigger

fucked us up yo. You hear what I'm saying? We, we took the little

cake we did have and straight coped up on some, straight coped up

on some ready (crack) real quick. You know what I'm saying? But

that shit ain't enough for us to do what we trying to do though.

You know what I'm saying? Because the nigger we was sending

through, you know we got bills to pay too. You see what I'm saying?

And we trying to make that shit right back yo. You know what I'm

saying?" Chambers acknowledged, "Right." Little Mike continued,

"Yeah we trying to call on some favors man. We need to get shit

back right boy. We need some help G. You know what I mean?

Straight like that. You feel me?" Chambers advised, "Yeah, I'm

trying to tell you. I'm, I'm man, my peoples, I ain't even be doing

shit. But I'm just saying you got some money I can go at that

nigger for you then." Little Mike advised, "Nah, we already spent

what we had. That's what I'm trying to tell you." Chambers

advised, "Well then, I can't do nothing if I ain't got no money

cause I'm, you know what I mean? I'm (inaudible) man. I'm waiting

on my shit. Again, the conversation continues regarding drug

87
trafficking and Little Mike says, "Yeah man we spent that shit with

yo and he won't do shit for us. So now we got what we got. So now

we on a tip where as though man we just trying to grab one extra,

extra OZ or two real quick yo. You know what I'm saying? You can

(inaudible). That's why we ain't, ain't looking for nothing crazy.

We just trying to get an ounce or two man." Based on their training

and experience and other information developed during this

investigation, law enforcement agents believe that Little Mike is

distributing marijuana and cocaine and is asking Chambers to supply

him with a new quantity of cocaine. However, at the current time

Little Mike has little money because a drug associate absconded with

some of his proceeds. Chambers acknowledged the loss and advised

that he (Chambers) and his close associates have been looking for

the unidentified thief. Chambers advised, "The nigger can't find

the dude man,” Chambers continued, "No, then I heard brothers on him

and everything. We gonna keep on trying to flush his ass out boy

but I ain't seen him." Little Mike responded, "Yeah, yeah, yeah he

goin, he gonna come around. You know what I mean? Got to, he ain't

got no where to go." It is the belief of law enforcement that due

to the violent nature of the BGF that once the thief is located he

will be physically harmed and possibly murdered. As the

conversation continued, the content shifted to the sale and purchase

of quantities of different drugs. Little Mike advised that he

recently purchased a "QP" (a reference to a quarter pound of

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marijuana). Eventually, Chambers advised that he would contact one

of his drug associates and ascertain whether they had a supply of

cocaine.

99. On March 2, 2010, at approximately 8:22 p.m., Duncan

placed an outgoing call to (410)913-2466 utilized by McIntosh.

During the conversation Duncan asked, “They told you Jim (a refernce

to Jim Dog, a/k/a William Rhodes) was locked up?” McIntosh

answered, “Yep, I, oh I knew. I wanted to tell you. I told Ben

(McFadden) today.” Duncan advised, “Yeah I, Ben told me.” McIntosh

responded, “Yeah I told him today. I got the paperwork and

everything. It’s not a pretty situation either.” Duncan responded,

“Yeah I heard.” McIntosh continued, “And that was last, last April,

April twenty fourth oh nine.” Duncan responded, “That’s crazy ain’t

it?” McIntosh continued, “Yep shit comes back to haunt your ass.

I heard they got DNA, somebody must have got cut and they got DNA

and all type of shit. They gonna axe me if D, if yo blood mixed

with somebody else blood can they still it’s yo blood. Yeah I

believe so.” Duncan responded, “Yeah they know what two different

blood type is mixed.” McIntosh continued, “Yeah see technology

nowadays is a bitch.” Duncan asked, “Yeah they don’t, they don’t

watch what’s a name?” McIntosh laughed and said, “I guess it’s just

the CSI.” Duncan continued, “Yeah.” McIntosh continued, “Yeah, yes

sir. So yeah, but I’m gonna tell you the whole little crazy story.

You know yo came, the, the other one came and hollered at me. Told

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the baby mother to call me.” Duncan responded, “Oh I bet she did

now.” McIntosh continued, “I, oh yeah came through like this, you

know he got to mix me up in their whole little, you see what I’m

saying. (Unintelligible).” Duncan advised, “Yeah I, I already know

what he up to now. (Unintelligible).” McIntosh continued, “Yep, yep

they was like, yep I called. I, I told her I was like tell him call

me. So she told him to call me. He needed to see me face to face.

So I tell her tell him give me five minutes. I’m in the middle of

something. Mind you I’m at work. You see what I’m saying? Give me

five minutes I’ll be out there. She call me back cracking up

laughing. She said it can’t wait five minutes it might, he might

not have enough time.” Duncan responded, “Yeah.” McIntosh

continued, “And you just passed me earlier and ain’t say shit.”

Duncan asked, “He say he don’t want…” McIntosh continued, “Your

boy, and your boy just passed me on Friday. I called him out. Like

damn Jim that’s how you do now, as he walked past me.

(Unintelligible) And the funny, funny thing is I specifically

remember, cause I heard this shit in the streets. You heard me?”

Duncan responded, “Right.” McIntosh continued, “I specifically

remember inquiring. I didn’t know who, what, when, why or where.

I just knew that, that had happened. And I had just…” Duncan

advised, “Oh here’s who I need for you to get in contact with me.

Get in contact with Stephon for me.” McIntosh responded, “Oh, uh,

hum, yep ok I will.” Duncan responded, “Yeah.” McIntosh then made

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several unintelligible sounds. McIntosh continued, “Yep I, I asked

about that. I, that was so funny. Don’t tell Sis, don’t tell her.

Yeah don’t tell me. That’s right. Thank you very much.” Duncan

then advised that he would call her back after nine. McIntosh

responded, “Ok, ok that’s cool.” Duncan asked, “Why what’s up? Who

you want to (unintelligible).” McIntosh advised, “Uh your boy came

through.” Duncan asked, “Who?” McIntosh continued, “Your boy, your

boy was was supposed to come here yesterday at what six o’clock,

when we talked to him. Call me at twelve thirty last night asking

if it was too late, it really was. So I told him call, catch up to

me in the morning. And he calls me in a panic…” Duncan asked,

“Which one?” McIntosh answered, “Kev! Calls me in a panic this

morning talking about he only got forty five minutes. This, this,

that. Now I already left and went to work right. But when I

explained to him what, what it was he was like it’s not, ain’t no

money in there? No.” Duncan responded, “Right.” McIntosh

continued, “So I, I me being the being the dumb sister, oh no I

meant me being the good sister.” (Laughing) Duncan responded,

“Right.” McIntosh continued, “Told him flat out I have a hundred

dollar’s in my pocket. I need it back by the end of the day. In

front of Styles I will yo for real to minute on this one, like for

real. Cause I don’t have it. You see what I’m saying?” Duncan

responded, “Yeah.” McIntosh continued, “But I understand the

situation so, I, but I’m telling you it’s going to go to the line.

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Based on their training and experience and other information

developed during this investigation, law enforcement agents believe

that McIntosh was reporting to Duncan, the city wide commander of

BGF, current BGF matters. McIntosh advised that “Jim” (a reference

to William Rhodes, a/k/a Jim Dog) had been arrested for a violent

crime that he had committed on April 24, 2009. McIntosh said that

she had in her possession the “paperwork” (a reference to Rhodes’s

charging paperwork) which revealed that Rhodes was linked to the

violent crime through his DNA. On March 2, 2010 investigators

learned that Rhodes had been arrested for an abduction and murder

which occurred in April 2009. During the latter portion of the

conversation McIntosh that “Kev” had come to her asking for money.

McIntosh advised that there was no money in the house (a reference

1120 Homewood Avenue, Subject Premise #1). In accordance with BGF

rules, the person in charge of finance (McIntosh) would have in her

possession money gained from BGF dues, any taxes paid to the BGF and

any proceeds obtained by criminal means. It is believed that “Kev”

was asking for money from BGF finance to help him get on his feet.

McIntosh told Duncan that because there was no money available that

she gave “Kev” some of her personal money, but expected the money

to be returned within a day. McIntosh told Duncan, “I’m telling you

it’s going to go to the line (a reference to having Kev sanctioned

for not repaying the money she lent him.)” Law enforcement has

learned that being sanctioned by BGF results in the paying of fines,

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physical assault, or possible death.

100. On March 6, 2010, at approximately 2:04 p.m., Duncan

placed an outgoing call to (443)806-6730, utilized by Davon. During

the conversation Duncan asked, "God damn where my cut at yo?" Davon

asked, "On what?" Duncan continued, "You all sell the truck yet?"

Davon responded, "Man you ain't, they ain't tell you what happened?"

Duncan answered, "No them niggers didn't ain't tell me what

happened." Davon continued, "Man those dummies go to uh get the

joint and the mother fucker been towed." Duncan asked, "Oh the

nigger told!" Davon responded, "Yeah I don't know what the fuck.

Wherever the fuck they park at that bitch got towed. So they really

ain't even got no truck." Duncan asked, "It got towed or the nigger

told?" Davon answered, "Say it again." Duncan continued, "What the

nigger, it, I thought you said the nigger told. But the car got,

the truck got towed." Davon responded, "Yeah it got towed like a

tow truck got that bitch." Duncan asked, "So when the fuck, why

didn't they go get it?" Davon answered, "I don't even know. I'd

rather, you know I ain't even ask them that. He told me like yo,

you ain't gonna believe this, yeah the shit got towed. I'm like

that's crazy. I hung up like I got to tell (unintelligible) this."

Duncan asked, "Right it ain't, it ain't reported stolen or nothing

is it?" Davon answered, "I don't know that's what I'm thinking like

why would it got towed. You feel me? Cause it ain't, the what they,

where they parked it that wasn't no tow away zone, it ain't no snow

93
route or nothing. They parked on a little side street up Whitelock.

So I'm thinking like why would it have just got towed. It might

have been reported. You know what I mean?" Duncan responded,

"Right so a nigger get something, how much you all get from the

store though?" Davon answered, "I ain't, I ain't (unintelligible).

I told you I got a little ass uh, twenty inch flat screen. They

keep trying to give me fifty dollars for it at the pawn shop. I

ain't, I'm about to put that bitch on Craig's List." Duncan asked,

"So what they get for the ear rings?" Davon answered, "All that

shit was fake." Duncan responded, "Oh my god!" Davon continued,

"That's what I'm saying (unintelligible). Duncan asked, "You still

believe them?" Davon continued, "And, and dummy keep saying like

yo, I'm telling you the shit was still in there, the shit was still

in there. I'm like shorty, they don't got nothing and then he tell

me he want a fake jewelry (unintelligible)." Duncan responded,

"Yeah he always do that." Davon continued, "Right you know he keep

talking, I'm telling you like yo niggers don't know. I'm like

shorty you can't tell me shit. Like if a nigger holding he not

gonna be wearing no fake jewelry." Duncan then asked, "The only

that was real was the bag then right?" Davon asked, "The what?"

Duncan responded, "The bag." Davon continued, "Bag, the bag what,

oh yeah, yeah, yeah, yeah, yeah the Jimmy Choo bag." Duncan then

asked an unidentified female in the background how much money a

Jimmy Choo bag was worth. Davon advised that an unidentified female

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associate returned the bag to Nordstrom's and received a "couple

hundred dollars." Based on their training and experience and other

information developed during this investigation, law enforcement

agents believe that Davon and other unidentified BGF members

committed a commercial robbery along with an auto theft and were

selling the items on the streets of Baltimore. Some of these items

were taken to a pawn shop and at least one Jimmy Choo bag was

returned to Nordstrom's Department Store for profit. Duncan was

expecting to obtain a portion of the profits made from the

commercial robbery and the theft of the truck. Duncan asked, "God

damn where my cut at yo?" Davon asked, "On what?"… After learning

the truck was towed prior to being sold for profit, Duncan asked,

"How much you all get from the store though?"

101. On March 7, 2010, at approximately 10:04 a.m.,

Duncan placed an outgoing call to McIntosh. During the conversation

McIntosh asked, "You come out yet?" Duncan answered, "Not yet."

McIntosh advised, "Boss you need to make this the first stop when

you come out." Duncan asked, "Why what happened?" McIntosh

responded, "Um oh your boy Stephon." Duncan asked, "Which Stephon,

which one?" McIntosh responded, "Uh, the crazy one." Duncan asked,

"Alright what happened?" McIntosh answered, "Oh I guess he was

look, missing something last night. Something very minor and minute

and whipped out on all the people. In front of little kids and all

that, brothers and all that." Duncan responded, "Alright." Based

95
on their training and experience and other information developed

during this investigation, law enforcement agents believe that

McIntosh was notifying Duncan, the overall city wide commander of

BGF, who she referred to as "Boss," that BGF member "Stephon" lost

an item last evening and in response "whipped out" (a reference to

displaying a handgun.) Based on Stephon's behavior McIntosh was

notifying Duncan so he could handle things with Stephon

appropriately.

102. On March 29, 2010, at approximately 2:51 p.m.,

Duncan received an incoming call from (443)807-0715, utilized by B.

During the conversation, Duncan advised that he was in the company

of Mike Grey. Duncan told B, "I'm gonna let you talk to him and

what you, what you was telling me." B responded, "Yeah." Duncan

continued, "Just tell him everything you had told me." B responded,

"Alright." Duncan then put Mike Grey on the telephone." Grey

asked, "What's up nigger you talking about me?" B responded, "What

it do?" Grey asked, "What's up?" B responded, "Ain't nothing. Nah,

bas, basically, basically you nah mean." Grey asked, "What, what

about the Noodle, about the Noodles part?" B answered, Yeah. Just,

just basically um little kid, little kid was like, he talked to some

kid, he talked to some kids. Um some dudes from over east Baltimore

and they was like, somebody said don't look up to it. But you know

there's some peoples over there saying that your name had came up

in, in, involved in it, whatever." Grey responded, "Yeah." B

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continued, "So I was like I, I don't know nothing about that. You

see what I'm saying? I said that they are just summin' but I don't

think it was, it, it (unintelligible) to that. You know what I

mean?" Grey responded, "Yeah." B continued, "So I don't know what,

I what happened but, but the little kid axed to meet um some dudes

over there and they was, they told him like yo don't even ax nothing

else about that. Leave that alone. As far as yo…" Grey responded,

Yeah." B continued, "You know what I'm saying? Then I was like oh

really. So it bet, basically I left, I ain't say nothing else to

him about it. I ain't even ax, yo who told you this who told you

that because he told…" Grey responded, "Yeah." B continued, "He

said that they said leave it alone. I left the shit, I, I left it

alone. But I talked to Sister Kim (McIntosh) and Donnie (Duncan)

um, about Donnie about it." Grey responded, "Yeah." B continued,

"It's just like your name came up and Gene name. So I was like well

Gene, I said how Gene name come up. I said some of these niggers

are chit chattin' on the phone. I said I talked to Gene on, on yo

phone." Grey responded, Yeah." B continued, "So I was like yeah,

I was like I don't know, I don't know nothing about that. You know

what I mean?" Grey advised, "Yeah but I'm on GPS. I ain't, I ain't

do nothing to him. I ain't like him but I ain't do nothing to him

though." B responded, "Right. See I knew you all didn't get along

but I, I just figured it, it wasn't like that." Grey responded,

"Yeah. Yeah but he did that. You know what I mean? He stole from

97
us and shit. So I, I was always on the shit that if I can't

(unintelligible)." Grey and B then talk over each other. B

continued, "But yeah, what, what they said was but he called

somebody else. He called, alright he called, one day I was with

him, he called the dude, I think his name Randy. And…" Grey

responded, "Yeah." B continued, "Randy said that they, I mean they

was saying that you was saying that you had shot Noodles or

something." Grey responded, "Um hum." B continued, "They said that

you said that you had shot Noodles and you supposed to been doing

something to um, damn this a Oakie. You and, and you supposed to

been trying to shot Oakie too or something. But (unintelligible)

got." Grey responded, "Man no." B continued, "They said you had

shot Noodles right. So Noodles went and got, Noodles went and got

all this hospital paper stuff and, and showed me um the hospital

thing, the police had shot him and so forth and so forth. You see

what I'm saying?" Grey responded, "Yeah me, me and Oakie was

together." B responded, "Huh?" Grey continued, "Me and Oakie was

together. Me and Oakie was partners when Noodles and them stole

from Oakie." B responded, "Oh yeah." Grey continued, "Yeah that's

why we was going to get him." B responded, "Oh shit, I don't know…"

Grey continued, "Yeah." B continued, "…nothing about that." Grey

responded, "Yeah." B continued, "Then we heard about

(unintelligible). I just know that, that him, he called some dude

named Rand, Randy and Randy said that you, you said you had shot

98
Noodles or something. And Noodles was like yo ain't shot me yo.

The police shot me or whatever. You feel what I'm saying?" Grey

responded, "Um hum." B continued, "So I was like alright. You know

I ain't never, I never heard nothing bout you, you supposed to shot

(unintelligible)." Grey responded, "Yeah." B continued,

"(unintelligible. I didn't know you all was beefin'." Grey

responded, "No we was on him cause he stole, he (unintelligible).

You know how mother fucker him and Major been going out robbing

every morning. So we had it set up so that they can come up there

and get, get stuff from the little kid's before they go out." B

responded, "Right." Grey continued, "Come and get his jumper." B

responded, "Right." Grey continued, "And then one morning Major

pulled a gun on the little kid's." B responded, "Oh yeah." Grey

continued, "Yeah and that's how…" B asked, "Oh Major, Major robbed

you." Grey continued, "Yeah, yeah that's how Major got shot in his

head." B responded, "Oh yeah, yeah, yeah, yeah." Grey continued,

"Yeah, yeah Noodles right there with him though." B asked, "Oh

Noodles, Noodles was with him?" Grey responded, "Yeah. They was

partners." B advised, "Cause they say Greg was with me, um Major

when yo got shot." Grey responded, "Yeah but Noodles, Noodles,

Noodles might have been the driver that day. (Unintelligible)."

B advised, "Yeah he must have been drunk. He know, he must have

been drivin' but, but yo, yo um, Greg was with him when he got shot

that day. Cause Greg,…" Grey responded, "Yeah." B continued,

99
"…Greg called me yeah, Greg called me about that." Based on their

training and experience and other information developed during this

investigation, law enforcement agents believe that Mike Grey had

been accused by an unidentified person in Baltimore of the recent

murder of BGF member Asia Carter, a/k/a Noodles, which occurred in

March of 2010. Grey, who had been speaking with Duncan, utilized

Duncan's phone to clear his name from the murder. Grey explained

that he did not like Carter because he had assisted in robbing

Grey’s and Oakie's (a/k/a David Rich) drug operation, but he (Grey)

was not responsible for the murder.

V. SUBJECT PREMISES

103. Based on the information set forth elsewhere in this

affidavit, my training, experience, and participation in narcotics

investigations, and my conversations with other law enforcement

officers, there is probable cause to believe that the Subject

Premises are locations being used for the storage and distribution

of narcotics, narcotics proceeds, and the facilitation of narcotics

offenses. Additionally, there is probable cause to believe that the

BGF is an association-in-fact racketeering enterprise, and the

Subject Premises are used by the enterprise to further the

enterprise’s illegal activities.

70. Based upon my training and experience and my

participation in this and other narcotics investigations, as well

as my conversations with other agents, I know the following:

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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

101
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 items securely.

104. I am further aware based upon my training and

experience and my participation in this and other investigations,

as well as my conversations with other agents that:

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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

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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

104
to identify and locate other gang 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.

g. 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

105
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.

A. SUBJECT PREMISES #1 - 1120 Homewood Avenue, Baltimore,


Maryland

105. Based on evidence developed during this

investigation, including information provided by confidential

sources and calls intercepted during wiretaps, I have learned that

Kimberly McIntosh, a/k/a “Sister Kim,” is the highest ranking female

member of BGF in Baltimore. As more fully described above, calls

intercepted over the wiretaps in this investigation indicate that

McIntosh is responsible for the finance of the BGF on the streets

of Baltimore. Additionally, she utilized Subject Premise #1 for the

cutting, packaging, the sale of heroin, and other controlled

substances, as well as near daily meetings of other high ranking

members of BGF. During these meeting, various racketeering

activities of the BGF are discussed and debated among the ranking

structure of BGF, to include, the sale of drugs, acts of violence,

and the disciplining of non-compliant BGF members. In addition to

the calls summarized above, throughout the investigation law

enforcement has intercepted conversations between McIntosh and

others discussing the use of Subject Premise #1. For example:

106
a. On March 7, 2010, at approximately 11:09 a.m.,

Duncan placed an outgoing call to Jermain Davis a/k/a Dirty Rice.

During the conversation Duncan asked, "You got some empty caps?"

Davis answered, "Yeah." Duncan responded, "I need them yo. I'm

over Sis house (a reference to Sister Kim’s house, Subject Premise

#1)." Davis responded, "Alright." Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Duncan was

advising Davis that he needed some "empty caps" (a reference to

gelatin capsules used for packaging heroin). Davis advised that he

had what Duncan needed at which time Duncan told Davis to bring the

item to "Sis house" (McIntosh's residence, Subject Premise #1.).

b. On March 8, 2010, at approximately 6:21 p.m.,

Duncan received an incoming call from Davis. During the

conversation Davis asked, "Where you at yo?" Duncan answered, "I

had to dip off." Davis asked, "Oh you coming back?" Duncan

responded, "Yeah go to the house and get it." Davis responded,

"Alright." Duncan continued, "Alright I'll be back though but go

to the house and get it." Based on their training and experience

and other information developed during this investigation, law

enforcement agents believe that Duncan was advising Davis to go to

McIntosh's, 1120 Homewood Avenue, Subject Premise #1, and obtain the

heroin which Davis was to sell. On March 7, 2010, SOI #1 notified

law enforcement that Duncan had called he/she on (410)599-5750, the

107
Coil Cellphone, and instructed SOI #1 to have Davis come to

McIntosh's residence because he (Duncan) needed Davis to sell heroin

for McIntosh. A short time after law enforcement received the

information from SOI #1, surveillance officers observed Duncan meet

with Davis near the McIntosh residence.

c. On March 21, 2010, at approximately 2:39 p.m.,

Duncan placed an outgoing call to (443)540-5082 utilized by an

unidentified male (UM). During the conversation Duncan asked,

"Where you exactly at?" The UM responded, "Um I'm coming from

church brother. Now is not a good time. Hello." Duncan responded,

"I'm listening." The UM advised, "Yeah now is not a good time

brother. I'm coming from church." Duncan spoke to McIntosh in the

background, "He say he ain't gonna be able to make your all meeting

he coming from church." McIntosh responded, "Ok what time he get

out a church?" Duncan advised, "He coming from church now." The

UM asked, "Where the brother, where the brother at?" Duncan

responded, "No it's (unintelligible). No I ain't talking about that

situation. I'm talking about you need to get with these, with your

other brothers. (Unintelligible) obligation. Your obligation, if

you can't fulfill it then let me know now." The UM yelled, "Stop

the bull crap alright yo." Duncan responded, "It's a meeting. So

could you make it or not?" The UM yelled, "I told you I'm coming

from church. What can I do yo? (Unintelligible) loud on me when

you in front of them niggers, Donnie (Duncan). What you doing man?

108
What you gonna do yo?" Duncan responded, "That's what I'm asking.

You can't make it let me know." The UM responded, "Alright I can't

do it yo."

d. On March 21, 2010, at approximately 2:44 p.m.,

Duncan received an incoming call from the same UM as the preceding

call. During the conversation the UM advised, "You cannot be upset

with these little, little spur of the moment meetings." Duncan

responded, "I don't got nothing to do with the committee they, they

call the meetings brother. You see what I'm saying? And…" McIntosh

was then heard in the background, "It's like, and it's an

emergency." Duncan continued, "It's an emergency, it's an emergency

meeting and if you can't make then you can't make it." Duncan then

spoke to an unknown person on another phone. Duncan then returned

to the UM and said, "There ain't nobody here yet. But everybody is

on their way here (a reference to McIntosh’s residence, Subject

Premise #1)." Duncan explained that he and "Smiley" were the only

individuals at McIntosh's residence. The UM advised that he was on

his way. Based on their training and experience and other

information developed during this investigation, law enforcement

agents believe that during the preceding two calls Duncan, McIntosh

and other high ranking BGF members were having an unscheduled

"emergency" BGF meeting and wanted every high ranking BGF member to

be in attendance. During these calls, law enforcement was

monitoring a camera positioned to view the 1100 block of Homewood

109
Avenue, the location of Subject Premise #1. Law enforcement was

able to observe Duncan, Harried, a/k/a Smiley, and Erik Ushry near

the entrance to Subject Premise #1.

106. 1120 Homewood Road, Baltimore, Maryland, identified

herein as Subject Premise #1, is a three story painted red brick row

home with a white entry door with a white mailbox to the left of the

entry door. I have learned from records maintained by Baltimore Gas

and Electric (“BGE”) that the utilities for Subject Premise #1 are

in the name of Danisha M. McIntosh.

107. Beginning on or about March 5, 2010, law enforcement

installed a pole camera. The camera maintained a view of the 1100

block of Homewood Avenue, on the same side of the street as Subject

Premise #1. Because of the location of the camera, law enforcement

could not view the front door of Subject Premise; however, it was

possible to view individuals approaching the location. At various

times during this investigation, law enforcement was able to observe

Duncan, McIntosh, Harried, and others going to and from Subject

Premise #1. As recently as April 5, 2010, law enforcement has

surveilled McIntosh entering and exiting this location.

108. 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 Premise #1 the items set forth in

Attachment A, which constitute evidence, fruits and/or

110
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; 18 U.S.C. § 1959, which prohibits violent crimes

in aid of racketeering, and 18 U.S.C. § 1956(d), which prohibits

conspiracy to launder money.

B. SUBJECT PREMISES #2 - 4007 Fordleigh Road, Apt C.,


Baltimore, Maryland

109. Based on evidence developed during this

investigation, including information provided by confidential

sources and calls intercepted during wiretaps, I have learned that

Todd Duncan, a/k/a “Donnie,” is the citywide commander of BGF. As

more fully described above, calls intercepted over the wiretaps in

this investigation indicate that Duncan participates in the daily

operation of the BGF enterprise and supervises all facets of BGF’s

illegal activities to include: the sale of drugs, acts of violence,

and the disciplining of non-compliant BGF members.

110. The residence at 4007 Fordleigh Road, Apartment C,

Baltimore, Maryland, identified herein as Subject Premise #2, is the

residence of Todd Duncan, a/k/a “Donnie.” The main entrance to

Subject Premise #2 is glass door with a blue awning with the numbers

4007 in white on the awning. The apartment is a green door on the

111
second floor to the left of the entry with the letter C affixed in

the center of the door.

111. On February 16, 2010, law enforcement agents

established surveillance in the area of Subject Premise #2. At

approximately 9:00 a.m., Duncan was observed exiting the apartment

building, 4007 Fordleigh Road, with a small child. Duncan placed

the child in a gray 2001 Chevy Tahoe with Maryland registration

42124M2. After Duncan was observed exiting the apartment building,

law enforcement requested the utilities for all apartment units in

4007 Fordleigh Road. Based on these requests, law enforcement

learned that Apartment C has utilities in the name of Chamera

Wilson. According to SOI #1, whom SOI #1 described as Mia Wilson,

Wilson is the girlfriend of Duncan. SOI #1's description of the

location of Duncan’s residence matched the location for Subject

Premise #2. Further, on March 31, 2010, law enforcement established

surveillance at Subject Premise #2, at approximately 7:55 a.m., law

enforcement observed Duncan exit the apartment building, 4007

Fordleigh Road, on his way to court for his January 6, 2010 arrest

for making a false statement to an officer (discussed above).

Finally, electronic surveillance authorized by the orders to

intercept Duncan’s phone places Duncan in the vicinity of 4007

Fordleigh Road most overnights.

112. Based upon the foregoing and on my training,

experience, and participation in narcotics and gang investigations,

112
I respectfully submit that there is probable cause to believe that

there will be found in Subject Premise #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; 18 U.S.C. § 1959, which prohibits violent crimes

in aid of racketeering and 18 U.S.C. § 1956(d), which prohibits

conspiracy to launder money.

C. SUBJECT PREMISES #3 - 237 East Lafayette Avenue, 2nd


floor, Baltimore, Maryland

113. Based on evidence developed during this

investigation, including information provided by confidential

sources and calls intercepted during wiretaps, I have learned that

Duconze Chambers, a/k/a “Ducon” is a high ranking member of BGF and

controls a street level drug shop. In addition to the calls

summarized above, throughout the investigation law enforcement has

intercepted conversations between Chambers and others discussing the

the sale of drugs from a Chambers’s residences. For example:

a. On February 22, 2010, at approximately 4:27

p.m., Chambers placed an outgoing call to (443)804-8962, subscribed

to Crystal Owens at 22 Stockmill Road, Apartment K, Baltimore,

113
Maryland, and utilized by Chips. During the conversation Chips

asked, "What's up Dookie?" CHAMBER responded, "What's up yo?"

Chips asked, "What's up?" Chambers responded, "You man." Chips

continued, "Shit what's up? You good?" Chambers answered, "What

time, I told you I'm trying to make that move with you. I'm trying

to holler at you." Chips advised, "Oh alright, I'm gonna come down

there." Chambers asked, "When?" Chips answered, "I got, listen I

just dropped my girl off all the way out this motherfucker. I'm out

Essex. So soon as I leave Essex." In the background, "Well I gotta

turn up here somewhere." Chambers advised, "Come straight to me."

Chips responded, "Huh?" Chambers advised, "Come straight to me."

Chips asked, "Straight to you?" Chambers answered, "Yeah." Chips

responded, "Alright, where you at down the house?" Chambers

answered, "Yeah." Chips ended, "Alright that's what it be." Based

on their training and experience and other information developed

during this investigation, law enforcement agents believe that

Chambers was conducting a drug transaction with Chips at Chambers

residence, located at 1017 E Preston Street, Baltimore, Maryland,

Chambers former residence.

b. On February 22, 2010, at approximately 4:46 p.m.,

Chambers received an incoming direct connect call from

316010168595225 with an unknown subscriber, utilized by an

unidentified male (UM). During the conversation Chambers advised,

"Yo what's up? Hey I told you I, I'm not gonna call you until I

114
really got it, you know right. You said you wanted to check it out.

Main man, me and yo down here now and shit." The UM responded,

"Alright you gotta give me a couple days yo cause I'm, I'm on flat

zero right now. I need at least three days. I'll be straight

probably like Wednesday." Chambers asked, "What you say?" The UM

answered, "Probably like Wednesday. I'm on flat zeros right now.

So probably like Wednesday." Chambers responded, "Alright that's

what it is." Based on their training and experience and other

information developed during this investigation, law enforcement

agents believe that Chambers was in the process of conducting a drug

transaction with Chips. During the anticipated drug transaction

Chambers spoke with an unknown drug associate to determine whether

the UM wanted to examine, and purchase a quantity of drugs from

Chips. The UM advised he currently had no money, but would on

Wednesday.

c. On February 22, 2010, at approximately 4:52 p.m.,

Chambers received an incoming call from (443)804-8962, subscribed

to Crystal Owens at 22 Stockmill Road, Apartment K, Baltimore,

Maryland, and utilized by Chips. During the conversation Chambers

advised, "Come downstairs you here up now yo." Chips responded, "No

boy I got Janece with me. Come on man." Chambers responded,

"Alright." Based on their training and experience and other

information developed during this investigation, law enforcement

agents believe that Chambers was conducting a drug transaction with

115
Chips at Chambers residence, located at 1017 E Preston Street,

Baltimore, Maryland. At approximately the same time as the call,

4:52 p.m., surveillance officers observed a silver 2000 Saturn

bearing Maryland registration 8ADH25 park near Chambers's residence.

A few moments later, the male driver of the 2000 Saturn entered 1017

E. Preston Street. A query of the MVA revealed the vehicle is

registered to Crystal Lorraine Owens, 2650 Lauretta Avenue,

Baltimore, Maryland, the same name as the subscriber of the cell

phone utilized by Chips.

114. On March 29, 2010, at approximately 2:35 p.m.,

Chambers received an incoming call from (443)762-5482, utilized by

Mark Johnson. During the conversation Johnson asked, "You at work?"

Chambers answered, "No at my house." Johnson responded, "Up your

house." Chambers continued, "Yeah on Lafayette and Guilford."

Johnson advised, "Alright I gotta try to get that. I'm a, I'm a,

I'm in east Baltimore already. Um I'm a ready to come that way."

Chambers responded, "Alright how long you gonna be? I'm gonna be

here though." Johnson advised, "Oh alright I ain't gonna be no more

than bout a half an hour." Chambers responded, "Huh?" Johnson

advised, "I said I ain't gonna be no more than bout a half an hour."

Chambers responded, "Alright." Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Johnson was going

to meet Chambers at his residence to pick up a drug related item.

116
Johnson advised, "Alright I gotta try to get that" (a reference to

a drug related item). Chambers advised that his residence was

located near the corner of Lafayette Avenue and Guilford Avenue.

It is believed by law enforcement, based on this call and others

indicating that Chambers was moving, that Chambers is currently

living with his girlfriend at her residence located at 237 E.

Lafayette Avenue 2nd floor, Baltimore, Maryland. On April 2, 2010

at approximately 10:19 a.m., law enforcement was conducting

surveillance at Subject Premise #3, and observed Chambers exit the

front door of 237 East Lafayette Avenue.

115. 237 E. Lafayette Avenue 2nd floor, Baltimore,

Maryland, identified herein as Subject Premise #3, is the residence

of Chambers, and his girlfriend, who has been previously identified

as Renata Harlaque. I have learned that the utilities for Subject

Premise #3 are in the name of Renata Clark Harlaque, and a

subscriber to a cellphone that contacts Chambers over his cellphone

is subscribed to at Subject Premise #3. Subject Premise #3 is a

three story light gray apartment with a green door. The numbers 2

3 7 are above the door on a brown placard in gold.

116. 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

117
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. SUBJECT PREMISES #4 - 1502 North Aisquith Street,


Baltimore, Maryland

117. Based on evidence developed during this

investigation, including information provided by confidential

sources and calls intercepted during wiretaps, I have learned that

Lamont Crooks is an associate of the BGF, and a source of supply of

drugs for the organization and others. In addition to the calls

summarized above, throughout the investigation law enforcement has

intercepted conversations between Crooks and others discussing the

sale of drugs from locations utilized by Crooks, including Subject

Premise #4. For example:

a. On March 21, 2010, at approximately 7:46 p.m.,

Crooks received an incoming call from (443)600-0645, utilized by

Earle Moore, a/k/a Harold Moore. During the conversation Moore

asked, "What's up Big Homie?" Crooks responded, "Ain't nothing

what's happening with you?" Moore responded, "Hey I got that for

you." Crooks responded, "Alright, alright. I'm a um, what you, you

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still around the way?" Moore responded, "Huh?" Crooks asked, "You

still around, around the way or you at your house?" Moore answered,

"Nah I', I'm home." Crooks responded, "Oh alright, alright. I'm

a try to shoot through there." Moore responded, "Alright." Based

on their training and experience and other information developed

during this investigation, law enforcement agents believe that Moore

had drug proceeds that he owed to Crooks from a past drug

transaction. Moore advised, "Hey I got that for you" (a reference

to drug proceeds.)

b. On March 21, 2010, at approximately 10:08 p.m.,

Crooks received an incoming call from Moore. During the

conversation Crooks advised, "Hey yo I been waiting on this still,

on a mother fucking ride man. Mother fucking taking kind of long.

So I might just have to get with you like early in the morning or

something." Moore responded, "Alright cause I get up, I, I'll be up

like early in the morning like seven, eight." Crooks responded,

"Alright so that'll work. Yeah so I, you know. I'll be straight

to you. Oh, I mean you in though right." Moore responded, "Yeah."

Crooks continued, "What time, what time you going out tonight?"

Moore advised, "Oh I ain't even going back out tonight. I'm, I'm…"

Crooks responded, "No I'm talking about what time you going to

sleep?" Moore answered, "Oh I'm up for a second. Just hit me."

Crooks responded, "Alright yeah so if, you know if this nigger, if

he ever come through. Then, you know what I'm saying? Crooks

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explained that he does not have a vehicle to drive at the current

time. Crooks advised, "So you know I'll hit you back tonight or you

know, or tomorrow morning." Moore responded, "Ok." Based on their

training and experience and other information developed during this

investigation, law enforcement agents believe that Crooks and Moore

had planned a drug related meeting; however, currently Crooks did

not have a ride to meet with Moore. Crooks advised that they may

have to conduct their drug related meeting the following morning.

c. On March 22, 2010, at approximately 8:58 a.m.,

Crooks received an incoming call from Moore. During the

conversation Moore asked, "Yo what's up Big Homie?" Crooks

responded, "Ain't nothing man. I'm waitin', I'm waitin' on the uh,

the Homie to come swoop me now." Moore responded, "Alright."

Crooks asked, "Alright so what you, you still at the house or you

gonna be down the way?" Moore answered, "Uh, I'm a probably, I'm

gonna be at one of em'. Cause I'm, I'm getting ready to see what

my uncle want. Cause if you need me to I can bring it to you if you

need me to." Crooks responded, "Oh alright um, what's, are you

mobile?" Moore responded, "I, when my uncle come he a bring me

wherever I needed to go at." Crooks responded, "Oh alright." Moore

continued, "That's why I (unintelligible) hand it to you. Cause

mother fucker's keep calling me worrying me and I'm like shit I just

got up. Like damn." Crooks responded, "Yeah. Alright…" Moore

advised, "(Unintelligible). I, I can call you and find out what you

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want me do." Crooks responded, "Alright so um that, that, the other

thing we'll just, you, you want that?" Moore responded, "Well yeah,

I'd grab and go ahead, go ahead and do that." Crooks responded,

"Alright, alright so um, that way I'll know cause I'm a have to run,

you know. Well I mean, just let, let me know when he, hit me when

he get there. Then that way I know what I have to um do." Moore

responded, "Alright yeah but I'll go ahead and grab that, alright."

Crooks responded, "Alright." Based on their training and experience

and other information developed during this investigation, law

enforcement agents believe that Crooks and Moore had planned a drug

related meeting during which Moore was to give Crooks drug proceeds

and in turn Crooks was going to supply Moore with a new quantity of

drugs. Moore advised, "Alright yeah but I'll go ahead and grab

that, alright (a reference to obtaining drugs.)” Crooks responded,

"Alright" (an agreement to supply Moore with a new quantity of

drugs.)

d. On March 22, 2010, at approximately 9:09 a.m.,

Crooks received an incoming call from Moore. During the

conversation Moore advised that he had a ride to come and meet with

Crooks. Crooks asked, "You know where the Rite Aid at on Harford

Road?" Moore answered, "Yeah." Crooks continued, "Harford in

between like Federal and Oliver?" Moore responded, "Yeah." Crooks

advised, "Yeah meet me right there." Moore responded, "Alright."

Based on their training and experience and other information

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developed during this investigation, law enforcement agents believe

that Crooks and Moore had planned to meet at the Rite Aid located

at 1521 Harford Road to conduct a drug transaction.

e. On March 22, 2010, at approximately 10:03 a.m.,

Crooks received an incoming call from Moore. During the

conversation Moore advised, "I'm here." Crooks responded, "Alright,

alright I'll be right there." During this conversation law

enforcement established surveillance at the Rite Aid located at 1521

Harford Road, approximately three blocks from Crooks’s residence.

A few minutes after this conversation, Crooks walked onto the

parking lot and met with Moore and George Cunningham, the driver of

the vehicle. Moments later, Crooks, Moore, and Cunningham entered

Cunningham’s vehicle and left the lot. Law enforcement followed the

vehicle to the 1500 block of Aisquith Street. Crooks then exited

the vehicle and walked to the front door of his residence located

at 1502 Aisquith Street, Subject Premise #4. Moore and Cunningham

then drove out of the area. Based on the calls between Crooks and

Moore, as well as the surveillance of the drug related meeting, a

car stop was conducted on the vehicle occupied by Moore and

Cunningham. Upon approaching the vehicle, law enforcement observed

a clear bag containing numerous gelatin capsules containing

suspected heroin inside of the vehicle. Both Moore and Cunningham

were arrested. Based on their training and experience and other

information developed during this investigation, law enforcement

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agents believe that Crooks had supplied the heroin seized from Moore

and Cunningham during their meeting at the Rite Aid located at 1521

Harford Road. It is believed by law enforcement that Crooks

obtained the heroin from his residence located at 1502 Aisquith

Street and returned to the residence, Subject Premise #4, with the

money discussed with Moore in the preceding calls.

118. The residence at 1502 North Aisquith Street,

Baltimore, Maryland, identified herein as Subject Premise #4, the

residence of Lamont Crooks, is a two story brick row home with a red

front entry door with the numbers 1502 displayed on the right side

of the building near the entry door. On March 18, 2010, law

enforcement established surveillance at Subject Premise #4. At

approximately 10:32 a.m., Crooks was observed smoking a cigarette

in backyard of the that location. Later that same day, at

approximately 11:35 a.m., law enforcement observed Crooks exit

Subject Premise #4 via the front door.

119. 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 Premise #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

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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; 18 U.S.C. § 1959, which prohibits violent crimes

in aid of racketeering and 18 U.S.C. § 1956(d), which prohibits

conspiracy to launder money.

E. SUBJECT PREMISE #5 - 2004 East Baltimore Street,


Baltimore, Maryland

120. Based on evidence developed during this

investigation, including information provided by confidential

sources and calls intercepted during wiretaps, I have learned that

Davon McFadden, a/k/a Ben, is a BGF member. McFadden and Duncan

sometime pool their money to purchase larger quantities of drugs.

On several occasions during this investigation law enforcement has

intercept conversations demonstrating McFadden’s involvement in the

BGF criminal enterprise. For example:

a. On March 2, 2010, at approximately 8:31 p.m.,

Duncan placed an outgoing call to (443)759-2466, utilized by

McFadden. During the conversation Duncan advised, "Yo I had to go

back to work right but yo good though." McFadden asked, "He's

straight?" Duncan answered, "Yeah." McFadden responded, "Alright

tell him, alright I'm about, I'm, I'm, I'm probably gonna have to

wait. I'm gonna see what's up though. See if yo give me something

else. You can take that for yourself." Duncan responded,

"Alright." Based on their training and experience and other

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information developed during this investigation, law enforcement

agents believe that Duncan was advising McFadden that "yo", (a

reference to a UM, whom Duncan was observed by law enforcement

having a drug related meeting with at 8:00 p.m., the same day) had

the money to purchase a quantity of drugs from Duncan. Duncan

advised McFadden of this to ascertain whether McFadden wanted to

participate in the drug transaction with the UM. McFadden advised,

"I'm probably gonna have to wait. I'm gonna see what's up though.

See if yo give me something else. You can take that for yourself."

It is believed by law enforcement that Duncan and McFadden on

occasion work together selling drugs when a large purchase is

requested. This type of working relationship is common within the

hierarchy of BGF. High ranking members of BGF not only want

themselves to be successful in their criminal endeavors but also

want gang members to be able to live a comfortable life.

b. On March 5, 2010, at approximately 11:24 a.m.,

Duncan received an incoming call from McFadden. During the

conversation Duncan said, "Yeah I just calling you letting you know

the knockers (police) was around there." McFadden asked, "What?"

Duncan asked, "You heard me?" McFadden asked, "What?" Duncan

advised, "I was calling to let you know them knockers was around

there. On Biddle and Greenmount." McFadden responded, "You said

what?" Duncan responded, "The police yo, the police." Based on

their training and experience and other information developed during

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this investigation, law enforcement agents believe that Duncan was

warning McFadden that the police were in the area of Biddle Street

and Greenmount Avenue, an area where McFadden sells drugs. During

this time frame law enforcement was notified that a Baltimore City

Narcotics squad was making drug arrests in the area of Greenmount

Avenue and Biddle Street.

c. On March 5, 2010, at approximately 2:25 p.m.,

Duncan placed an outgoing call to McFadden. During the conversation

Duncan advised, "Hey you know Trap locked up to yo." McFadden

responded, "Yeah I know Lope told me. He said he got locked up

right after he came and seen me. (Unintelligible) I said I had got

a little something from Ensor Street and shit. That's when he got

locked up by them. (Unintelligible)." Duncan responded, "Oh

alright then that's all I wanted to know." Based on their training

and experience and other information developed during this

investigation, law enforcement agents believe that Duncan was

inquiring of McFadden the circumstances of "Trap’s" arrest. McFadden

advised, "He said he got locked up right after he came and seen me"

(a reference to Trap being arrested after obtaining drugs from

McFadden). The arrest of "Trap" matches the drug arrest conducted

by the Baltimore Police Department earlier in the day.

d. On March 22, 2010, at approximately 11:35 a.m.,

Duncan placed an outgoing call to McFadden. During the conversation

Duncan advised, "Yo they just raided what's a name and them house

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yo." McFadden asked, "Who?" Duncan continued, "Where Dirty Rice,

(a/k/a Jermain Davis), at." McFadden asked, "For real?" Duncan

responded, "Yeah." McFadden responded, "Oh my god man." Duncan

asked, "You gave him something?" McFadden answered, "Yeah." Duncan

responded, "Man." McFadden continued, "God damn yo. This nigger

got no luck yo. Um, um, um. Who went in there?" Duncan answered,

"Um probably the knockers (police) and the blue and whites."

McFadden asked, "Where you at?" Duncan answered, "Around there

trying to see what the fucks going on." McFadden asked, "Who out,

who around the way?" Duncan responded, "Huh?" McFadden asked, "Who

around the way?" Duncan answered, "Nobody." McFadden asked, "What

made them do that?" Duncan answered, "Man they raided more, they,

they, his house ain't the only house raided, they going up in. They

going in all them houses around there. They going in like two

people houses in that court." Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Duncan was

advising McFadden that Jermain Davis, a/k/a Dirty Rice, a member of

their drug organization had been arrested at his house during a drug

raid. McFadden was concerned because McFadden had recently given

Davis heroin. Duncan asked, "You gave him something?" (a reference

to providing Davis drugs.) McFadden answered, "Yeah." It was later

learned by law enforcement that Baltimore City narcotics

investigators arrested Jermain Davis, a/k/a Dirty Rice at his

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residence, 847 Abbott Court, during the execution of a search

warrant. Seized during the arrest was a quantity of heroin.

121. On March 10, 2010 at approximately 10:45 a.m., law

enforcement established surveillance at 2004 East Baltimore Street,

Subject Premise #5. At approximately, 1:14 p.m., law enforcement

observed McFadden exit Subject Premise #5 and enter a gold colored

mini-van with a North Carolina registration. On a previous

occasion, December 21, 2009 (discussed above), law enforcement

observed McFadden operating a 2002 four door Acura registered in

McFadden’s name at Subject Premise #5. On March 31, 2010, law

enforcement again observed McFadden exit Subject Premise #5 and

enter the gold mini-van; however the van had different plates and

was registered to McFadden at Subject Premise #5.

122. The residence at 2004 East Baltimore Street,

Baltimore, Maryland, identified herein as Subject Premise #5, is a

three story brick row home with two windows with green trim to the

left of the entry door. A white placard with the numbers 2004 in

black is on the left side of the entry door, and black railing

leading to the door. The property is listed to the Housing

Authority for Baltimore City

123. 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

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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; 18 U.S.C. § 1959, which prohibits violent crimes

in aid of racketeering and and 18 U.S.C. § 1956(d), which prohibits

conspiracy to launder money.

F. SUBJECT PREMISES #6 - 1204 Wilcox Street, Baltimore,


Maryland

124. Based on evidence developed during this

investigation, including calls intercepted during wiretaps, I have

learned that Jon Brice, a/k/a “Tiger,” is a member of BGF and works

along with other members in the distribution of heroin in east

Baltimore. Several calls were intercepted during this investigation

in which Brice, a/k/a “Tiger,” discussed the distribution of heroin.

a. On March 9, 2010, at approximately 10:10 a.m.,

Duncan placed an outgoing call to (410)940-4668, subscribed to Tiger

Brice, PO BOX 54988, Irvine, California, utilized by Jon Brice.

During the conversation Duncan advised, "I need you to come around

here and do something real quick." Brice responded, "Alright." At

approximately 1:24 p.m., Duncan placed an outgoing call to Brice.

During the conversation Duncan asked, "Tell me something." Brice

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responded, "We good shorty." Duncan responded, "Alright." Brice

advised, "On a scale I'd give it an eight." Duncan responded,

"Alright that's what's up." Based on their training and experience

and other information developed during this investigation, law

enforcement agents believe that Duncan obtained a sample of his

heroin from McIntosh's house, and transported it to Brice’s house,

1204 Wilcox Street, Subject Premise #6, and then had Brice test the

quality of the heroin. According to Brice, on a scale from one to

ten he give's the quality an "eight." During the course of the

these calls surveillance observed Duncan at McIntosh’s residence and

the Brice residence.

b. On March 18, 2010, at approximately 1:25 p.m.,

Duncan placed an outgoing call to (443)467-7687, utilized by Brice.

During the conversation Duncan advised, "Meet me around there."

Brice responded, "Alright." Duncan continued, "I'll call you when,

yeah meet me around there. I'm on my way around there now,

alright." Brice responded, "Alright, alright." Duncan advised,

"I'm gonna be about ten minutes." Brice responded, "Alright."

Duncan said, "They set around, go around and sit down there on the

steps." Brice responded, "Alright." Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Duncan was

instructing Brice to meet him (Duncan) at McIntosh's home, so Brice

could handle a drug related matter for Duncan. Shortly after the

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call law enforcement observed Brice approach the McIntosh residence

on a bike. A short time later, Duncan arrived and approached the

front of McIntosh's residence. Moments later, Duncan and Brice were

observed leaving the front of the residence. Brice then rode on the

bike toward his residence located at 1204 Wilcox Street. A few

minute's later agents and officers observed Brice enter his

residence. Based on their training and experience and other

information developed during this investigation, law enforcement

agents believe that Duncan was having Brice handle a drug related

matter for him. During the course of the investigation Brice has

been identified as a tester or quality control advisor for heroin

that is sold by Duncan. On at least one occasion, Duncan has been

observed leaving McIntosh's residence, 1120 Homewood Avenue, Subject

Premise #1, and shortly thereafter entering the residence of Brice.

After staying only a short period of time, Duncan then left Brice’s

residence and departed the area. Shortly after leaving Brice's

residence Duncan spoke with Brice over the telephone and was

informed by Brice of the quality of some heroin.

c. On March 19, 2010, at approximately 12:15 p.m.,

Duncan placed an outgoing call to Brice. During the conversation

Duncan asked, "You in the house Tiger?" Brice responded, "Nah I'm

around here on Ensor Street." Duncan advised, "So I need, I need

to get in your house for a minute." Brice asked, "You need to get

in the house?" Duncan answered, "Yeah." Brice responded,

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"Alright." Based on their training and experience and other

information developed during this investigation, law enforcement

agents believe that Duncan needed access to Brice's home, 1204

Wilcox Street, Subject Premise #6, to conduct drug related business,

specifically the mixing and packaging of heroin. Brice allow Duncan

to use his home for his drug business.

d. On March 14, 2010, at approximately 5:31 p.m.,

Chambers received an incoming call from Duncan. During the

conversation Chambers asked, “Who’s this?” Duncan answered,

“Donnie.” Chambers responded, “What’s up, ain’t shit.” Duncan

responded, “Yeah, hey do me a favor.” Chambers responded, “Yeah.”

Duncan continued, “Call Tiger (Brice) and just see, see if he’s in

the house (Subject Premise #6) and then call me right back.”

Chambers responded, “I don’t know. I don’t think he in there.

Cause they just bust his windows out.” Duncan asked, “Who bust his

windows out?” Chambers answered, “Little Darry and them.” Duncan

asked, “Why?” Chambers answered, “Man I think, I think he owes

them, he said, he said that shorty money got stolen.” Duncan

responded, “Got stolen?” Chambers continued, “Yeah like you know

Darian was staying there and like four hundred and something

dollars.” Duncan responded, “Damn.” Chambers continued, “Yeah you

know Terry got that white boy in there too.” Duncan responded,

“Right. Well the windows don’t look that bad. I just rode past

there.” Chambers explained that he would call Brice. Based on

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their training and experience and other information developed during

this investigation, law enforcement agents believe that Duncan

wanted Chambers to contact Brice so he (Duncan) could meet with

Brice to discuss drug related business. Chambers advised that Brice

was unlikely to be home because he is being held responsible for the

theft of four hundred dollars of drug money belonging to Darry a/k/a

Darian.

125. The residence at 1204 Wilcox Street, Baltimore,

Maryland, identified herein as Subject Premise #6, is the residence

of Jon Brice, a/k/a “Tiger.” Subject Premise #6 is a two story

brick row house with a black screen/metal door, and green front

entry door, with the numbers 1204 in black affixed to the entry

door.

126. 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 Premise #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

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drug-trafficking; 18 U.S.C. § 1959, which prohibits violent crimes

in aid of racketeering and 18 U.S.C. § 1956(d), which prohibits

conspiracy to launder money.

G. SUBJECT PREMISE #7 - 1619 Riverwood Road, Essex, Maryland

127. Based on evidence developed during this

investigation, including calls intercepted during wiretaps, I have

learned that James Harried, a/k/a “Smiley,” is a member of BGF.

Harried’s presence has been requested on several occasions by BGF

members to participate in the investigations of BGF member, who are

accused of violating BGF rules.

a. On February 14, 2010, at approximately 1:06 p.m.,

Chambers placed an outgoing call to Harried. As the call was being

placed Chambers, is heard in the background saying, "Where the fuck

Taterman at? He said the security guard, nah he said Taterman just

knocked a nigger out. I said what the fuck going on? He said the

nigger threw some water. So Lamont like yo everybody, I said man

I don't know who up…" Harried then answered the call. Chambers

said, "Hello Smiley." Harried responded, "Yeah." Chambers

continued, "This Ducon (Chambers) man." Harried said, "What's up?"

Chambers continued, I'm, I'm, I'm telling this, I'm, I'm calling you

man because they, I need to see you man cause…" Harried asked, "Why

what's up?" Chambers answered, "Alright, why because um, you know

Donnie (Duncan) say um, um Black running me through and, and, and,

and he running me through for something that I don't have, I really

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didn't have knowledge of. You know what I'm saying?" Harried

asked, "What?" Chambers continued, "I didn't have knowledge of."

Harried asked, "Who the hell is Black?" Chambers answered, "Rome,

that's his name Black, Rome." Harried responded, "Alright, um, you,

you need to see me now or, or…" Chambers answered, "Well you close

by?" Harried answered, "No I'm out in the county." Chambers asked,

"Alright so you good to come down tomorrow then?" Harried

responded, "Yeah." Chambers responded, "Alright." Harried asked,

"This your number right?" Chambers answered, "Yeah." Harried

advised, "Alright I'm gonna call you as soon as I get in town."

Chambers responded, "Alright." Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Chambers wants

to meet with Harried, a/k/a Smiley, a high ranking BGF member, to

explain his version of the events surrounding the fight and Black's

request to have Chambers "run through" for not assisting fellow BGF

members in the fight. CS2 had previously identified “Smiley” as one

of the BGF members who took part in having CS2 sanctioned

(physically beaten) for the misappropriation of BGF funds.

b. On February 15, 2010, at approximately 5:04 p.m.,

Chambers placed an outgoing call to (443)909-5173, utilized by

Roddy. Upon answering the call, which was on speaker mode, Chambers

advised, "I said we got Unc here now. But I'm saying, I was telling

them about the situation and shit. I was letting them know that you

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was there too." Roddy responded, "Right." Harried, a/k/a Smiley,

a/k/a Unc asked, "Like ok, can you tell me what happened?" Roddy

explained, "Alright as far as um, I mean I would say far as anybody

being aware of the situation, I would say that's impossible because

it's like, you know we was all there but like the brother didn't put

us on point basically. So like when it happened it was just, far

as it, you know just being spontaneous and then you know just a

whole shit just broke out. Cause like, you know what I mean? Once

the shit went down everybody just went everywhere. So you know it's

dark and you can't tell who's who and…" Harried responded, "Yeah."

Roddy continued to explain his version of the events regarding the

fight. Chambers then chimed in and began explaining his version of

the events. Based on their training and experience and other

information developed during this investigation, law enforcement

agents believe that Chambers, Harried, and other unknown males were

together and speaking with Roddy on speaker phone regarding the

fight and the events that led to the investigation of Chambers.

Ultimately, Harried was in charge of conducting the investigation

for BGF.

c. On February 20, 2010, at approximately 4:27 p.m.,

Chambers received an incoming call from Harried. The call went

unanswered and went to voicemail. As the call was being connected,

Harried was heard in the background stating, "Nah matter a fact, uh,

matter a fact sell him a hundred." An unidentified male, again in

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the background, responds, but was unintelligible. Harried then

continued, "That or that, either one." The unidentified male asked,

"Yeah but can, can he handle it?" Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Harried was

advising one of his drug associates to sell an unidentified person

a quantity of drugs, "sell him a hundred."

d. On March 21, 2010, at approximately 12:56 p.m.,

Chambers received an incoming call from (443)600-5191, subscribed

to Lawanne Jackson, 1619 Riverwood Road (Subject Premise #7), Essex,

Maryland, utilized by Harried. During the conversation Chambers

advised, "Soon as Rudy bring the whatya call’m to me I'm, I'm a

shoot that, the hundred down there probably to you or Sister Kim

(McIntosh)." Harried responded, "Yeah give it, give it to a, give

it to Sis (McIntosh) cause um we out, we out right now." Chambers

responded, "Alright where you at?" Harried answered, "Uh going to

take care of something." Chambers responded, "Oh ok. I thought you

all was, oh he, oh did you go down there?" Harried responded,

"Huh?" Chambers advised, "You know, you know double R was down

Sister Kim house." Harried responded, "Yeah, yeah, yeah I got it."

Chambers advised, "You already, you, I was just down there."

Harried responded, "Oh so you already know about it." Harried

responded, "Yeah we get ready to go take, straighten the shit out

now." Chambers responded, "Oh ok, alright." Harried advised, "So

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I'll, I'll, I'll tell you when we get down there." Based on their

training and experience and other information developed during this

investigation, law enforcement agents believe that there was a BGF

meeting that was to occur at McIntosh's residence. During the

meeting each member was to pay their BGF dues. Additionally, prior

to the meeting, Duncan and Harried were handling an unidentified

problem with a BGF member. Harried advised, "Yeah we get ready to

go take, straighten the shit out now."

e. On March 19, 2010, at approximately 9:02 a.m.,

Duncan received an incoming call from Harried. During the

conversation Duncan asked, "Kevin locked up?" Harried answered,

"Yeah he, he um need four hundred more dollars to get out. He said,

she said, he said if I got it, trying to get out. He said he got

like six thousand dollars (unintelligible). I guess she got the

rest, she got some of the money but she needs four hundred more."

Duncan advised, "I'm gonna call Ben (McFadden) and them." Harried

asked, "Alright you uh, you want this number so you can call the

girl back?" Duncan responded, "I don't want to talk to her."

Harried asked, "Oh you gonna give it Ben (McFadden) and them?"

Duncan responded, "I'm, I'm a call Ben and them and tell Ben to call

you. But I'm gonna tell him what, what to do though. But when I

get the money, once they get the money then they just call her and

give her the money to get, bail yo out." Harried responded,

"Alright that's what's up." Duncan asked, "Yeah what's up with you

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though?" Harried answered, "Nothing I'm like she's like, she's like

can I speak to ‘brother Smiley.’ I'm like who the fuck is this?"

Duncan responded, "Yeah." Smiley continued, "You know he wrong for

doing that shit like that. He supposed to (unintelligible)."

Duncan responded, "Yeah, right and my thing is I gave him a hundred

dollars, he owes Sis (McIntosh) three hundred dollars, he say he was

getting put out and all this shit. I give him a hundred dollars so

he can go get his car fixed." Harried responded, "Yeah." Duncan

continued, "He got to much shit going on with him." Harried asked,

"Alright you want to let him sit for a while we can let him sit for

a while, if you want to let him sit." Duncan responded, "Yeah he

wants, I'm, I'm a make sure they don't raise his bail. You feel

what I'm saying?" Harried responded, "Yeah." Duncan continued, "Or

whatever but um man nobody keep going through all that shit."

Harried responded, "Alright let him sit for a while. Shit you know

how I feel." Duncan then instructed Harried to call and find out

the reason for Kevin’s incarceration. Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Harried was

advising Duncan that BGF member Kevin needed additional bail money.

Duncan explained that he would advise McFadden and have him

(McFadden) call Harried. Ultimately, Duncan and Harried agree to

let Kevin sit in jail for a while to show him that he can't keep

breaking the law, getting caught and expecting BGF to come to his

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rescue.

f. On March 19, 2010, at approximately 11:04 a.m.,

Duncan received an incoming call from Harried. During the

conversation, Harried advised he spoke with a female regarding

Kevin. Harried asked, "You want to let him sit? Cause if you want

to let him sit I, I, I won't call her back." Duncan answered, "No,

no we gonna get him. But my, my, my thing is as soon as Ben

(McFadden) put some minutes on his phone I'm gonna tell him to go

around and collect some dues from everybody and get his ass out.

But man that shit crazy." Harried advised, "Yeah but he still gonna

have to pay when he get out though." Duncan responded, "Yeah he

gonna pay that shit when he get out." Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Duncan was going

to have BGF member McFadden collect dues from BGF members in the

community to post Kevin’s bail.

128. 1619 Riverwood Road, Baltimore, Maryland, identified

herein as Subject Premise #7, is the residence of James Harried,

a/k/a “Smiley.” Subject Premise #7 is a two story red brick row

house with a white entry door and the numbers 1619 in black on a

white placard to the left of the door. The entrance is covered by

a roof with a black railing leading to the entry. According to

records maintained by BGE, the utilities for Subject Premise #7 are

in the name of Lawanne S. Jackson. Lawanne S. Jackson is also the

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subscriber for cellular telephone (443)600-5191, the cellphone

utilized by Harried. Further the phone is subscribed to at the

address of Subject Premise #7. Finally, on March 24, 2010, law

enforcement were conducting surveillance at Subject Premise #7. At

approximately 6:05 a.m., Harried was observed exiting Subject

Premise #7.

129. 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 Premise #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; 18 U.S.C. § 1959, which prohibits violent crimes

in aid of racketeering and 18 U.S.C. § 1956(d), which prohibits

conspiracy to launder money.

H. SUBJECT PREMISE #8 - 5305B Valiquet Avenue, Baltimore,


Maryland

130. Based on a series of telephone conversations and

contemporaneous surveillance conducted by law enforcement on March

19, 2010, SUBJECT PREMISE #8 has been identified as a possible stash

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location for Duncan and the BGF enterprise. The series of calls and

surveillance is described below:

a. On March 19, 2010, at approximately 9:02 a.m.,

Duncan received an incoming call from (443)540-5082, utilized by an

unidentified male (UM). During the conversation the UM explained,

"The little nigger from over west Baltimore he ain't getting back

or nothing." Duncan responded, "Oh yeah." The UM responded, "Yeah.

This shit crazy yo. What's going on with you?" Duncan answered,

"I, I want to, I, I want to um you know take care of what needs to

be tooken care of. You see what I'm saying?" The UM answered,

"Yeah." Duncan continued, "But we definitely need that from little,

from shorty." The UM advised, "Sh, he ain't answering. I just told

Cali in the beginning yo." Duncan responded, "I know what you

saying. You, you know what I'm saying?" The UM responded, "Yeah."

Duncan advised, "I'm, I'm a, I'm a you know just fuck with Tay."

The UM asked, "Say it again." Duncan responded, "Just fuck with

Tay." The UM responded, "Oh yeah." Duncan continued, "That, that,

that, that's the only legit thing." The UM asked, "Oh he came

through?" Duncan answered, "Yeah." The UM responded, "Wow."

Duncan continued, "You feel what I'm saying?" The UM asked, "You,

you hit him again?" Duncan answered, "No I'm, you know, you already

know like what we got to do." The UM responded, "Man let's do that

shit asap yo." Duncan responded, "I know yo." The UM continued,

"God damn Donnie. Man come get me, come get me yo. I'll do it."

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Duncan responded, "I got my son, I, I, I'm going to but my son

gettin' his hair done right now." The UM responded, "Alright what

time you think you be done." Duncan advised, "Waiting, waiting on

him now. It ain't gonna take long. So just answer your phone.

Where you at?" The UM responded, "I'm at my mother house." Duncan

continued, "Alright that's what's up." Duncan and the UM then spoke

about Duncan's son. The UM then said, "Yeah yo hit, hit, hit me yo.

I'll do that shit. I'll even do it at Calvin's just have them all

in three hundreds or whatever yo. Give that nigger everything."

Duncan responded, "Right." The UM continued, "Give him everything

yo." Duncan advised, "Yeah I, that's, that's the only way it'll

work out any old way." The UM responded, "Yeah." Duncan continued,

"You see what I'm saying? Cause I'll (unintelligible). When I

called yo I want to like you know, the shit will be today for real."

The UM responded, "Yeah." Duncan asked, "You feel me?" The UM

responded, "Yeah that was (unintelligible)." Duncan continued, "He,

he, yeah he wasn't trippin or nothing." The UM responded, "Yeah hey

I just want to start from scratch yo." Duncan responded, "I know."

Based on their training and experience and other information

developed during this investigation, law enforcement agents believe

that Duncan and the UM are pooling their money to purchase a new

shipment of heroin from Tay because they had a problem with their

alternate drug source. The problem with the alternate drug source

is believed to be the quality of the drugs making it difficult to

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profit from the sale. Duncan advised, "I'm, I'm a, I'm a you know

just fuck with Tay." The UM asked, "Say it again." Duncan

responded, "Just fuck with Tay." The UM responded, "Oh yeah."

Duncan continued, "That, that, that, that's the only legit thing"

(a reference to drugs being of good quality). The UM asked, "Oh he

came through?" Duncan answered, "Yeah." As the conversation

continued the UM advised, "Give him everything yo" (a reference to

drug money). Duncan advised, "Yeah I, that's, that's the only way

it'll work out any old way" (a reference to the two of them making

money selling drugs.) The UM explained, "Yeah hey I just want to

start from scratch yo." Duncan responded, "I know" (a reference to

getting back to making a lot of money from the sale of drugs.)

b. On March 19, 2010, law enforcement established

surveillance at 102 South Bouldin Street, the home of Angie Wilson,

a paramour of Duncan. At approximately 10:12 a.m., law enforcement

observed Duncan exit the address with a small child and enter his

2001 Chevy SUV. Duncan was then followed to several locations,

including 127 Collington, the home of his mother, where he dropped

off his child. At approximately 10:38 a.m., Duncan was observed to

return to the area of South Bouldin Street and enter 102 South

Bouldin. At approximately 11:19 a.m, law enforcement observed

Ronald Scott, a/k/a “Piper,” arrive in the 100 block of South

Bouldin Street. Scott was driving a 2004 Infiniti and was

accompanied by another black male. Scott and the unknown male stood

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outside of 102 South Bouldin, and at approximately, 11:21 a.m.,

Duncan was observed to exit 102 South Bouldin and speak with Scott

and the unknown individual. The meeting lasted approximately 4

minutes after which, Duncan approached his vehicle and Scott and the

unknown male approached theirs and both drove from the area.

c. On March 19, 2010, at approximately 11:26 a.m.,

Duncan received an incoming call from (443)449-1474, subscribed to

Henry Giles, 1210 Wilcox Street, Baltimore, Maryland, utilized by

Henry. During the conversation Duncan asked Henry if Potter was in

school. Duncan advised, "If Potter in school get the key and call

Piper and give it to Piper." Henry responded, "Alright." At

approximately 11:33 a.m., Duncan received an incoming call from

Henry. During the conversation Henry advised, "I don't got Piper

phone number in my phone. Tell him to call me. I got the key

though." Duncan responded, "Alright, alright." Based on their

training and experience and other information developed during this

investigation, law enforcement agents believe that Duncan was

telling Henry to obtain a key for McIntosh's home, Subject Premise

#1, from Potter and give the key to Piper.

d. On March 19, 2010, at approximately 11:39 a.m.,

Duncan received an incoming call from (410)504-2763, utilized by an

unidentified male (UM). During the conversation the UM advised,

"Alright yo we got the key. Now what's up?" Duncan answered,

"Alright go to the house." The UM responded, "Um to uh… Hello."

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Duncan responded, "Go to Tiger's (Brice’s), alright." The UM

responded, "Huh?" Duncan responded, "Go to Tiger's." Duncan

explained to the UM to go to Tiger's until he (Duncan) gets there.

Based on their training and experience and other information

developed during this investigation, law enforcement agents believe

that Duncan wanted one of his drug associates to meet him at

Tiger's, a/k/a Brice’s home so he could help Duncan with some drug

related business.

e. At approximately 11:42 a.m., Duncan was observed

to pull into the driveway of 5305B Valiquet Road, Subject Premise

#8. Duncan exited his vehicle and entered the location. Duncan

stayed inside the location for approximately ten minutes and then

was observed exiting the location carrying an object he placed under

the driver’s seat of his 2001 Chevy Tahoe. Duncan then briefly

returned to side of Subject Premise #8 then reentered his vehicle

and left the area.

f. On March 19, 2010, at approximately 12:21 p.m.,

Duncan received an incoming call from the same unidentified male

(UM). During the conversation the UM advised, "Yo saying he don't

know where to at in, in, in Sister Kim's." Duncan responded, "Um

that's the whole thing is ya'll got to look upstairs somewhere. It

should be in one of them bags yo." The UM responded, "So you want

us to go upstairs and look inside one of the bags?" Duncan

responded, "Yeah." The UM advised, "Only thing, only thing we gonna

146
need is the um…" Duncan advised, "It should be in, in the white bag

I had. Cause I'm around Tiger's (Brice’s) house (1204 Wilcox,

Subject Premise #6) now." The UM advised, "This mother fucker don't

want to go in there." In the background Scott, a/k/a Piper, then

said, "I'm going in there." The UM advised, "So I'm, alright,

alright no he going." Duncan responded, "Man, it's not time for you

all playing games man." Scott then used the UM's phone to speak

with Duncan. Duncan asked, "You don't know where to look at?"

Scott answered, "No I know about the drawer but nah I don't

(unintelligible)." Duncan responded, "No I ain't talking about the

drawer. Nah look, look in the closet." Scott responded, "Uh huh."

Duncan advised, "Look in the closet. It should be a white bag and

the um, the jelly beans should be in the white bag." Scott

responded, "Alright." At approximately 12:26 p.m., Duncan received

an incoming call from (443)504-2763, utilized during the call by

Scott. During the conversation Scott advised, "Alright I'm, I'm at

the closet so…" Duncan asked, "You couldn't, ain't, ain't no bag

right there?" Scott answered, "Nah I see like tampon bags and shit

like that." Duncan asked, "You look on the side?" Scott continued,

"A white, a white plastic bag or a Victoria Secret bag?" Duncan

asked, "How the white bag look?" Scott answered, "This white

Victoria Secret bag got a teddy bear and shit in it. A bunch of

liquor. (Unintelligible)." Duncan responded, "It's white, it's not

that bag." Scott continued, "White plastic bag got a box of

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tampons." Duncan advised, "Look, look, look, look, look on the side

of the closet then." Scott responded, "Alright." Duncan responded,

"Yeah." Scott was then heard moving items around in the background.

Duncan advised, "It should be a H&M bag, the bag that we had."

Scott asked, "A H&M?" Duncan answered, "Yeah." Scott was again

heard moving items around in the background. Duncan asked, "You

don't see no H&M bag in there nowhere in there?" Scott answered,

"No." Duncan continued, "On the side of, on the side of the

closet?" Scott responded, "Nah at the top or bottom. I'm looking

at the top and bottom." Duncan responded, "No, no on the, don't

know how, not when you go in the closet. Like (unintelligible) at

the door is open. It should be a bag on the side of the closet."

Scott responded, "Ok, oh alright you want this whole bag?" Duncan

advised, "Look in there and see if every, if everything that we,

that we need." Scott responded, "Um the strainers the, the, yeah

everything is in here." Duncan responded, "Alright come on. I'm,

I'm around here already." Scott responded, Alright." During the

conversation law enforcement observed Scott arrive at McIntosh's

residence, 1120 Homewood Avenue, Subject Premise #1, and depart

moments after the conclusion of the call. Scott was observed

leaving the McIntosh’s residence with a weighted white plastic bag.

Moments later, law enforcement observed Scott arrive in the 1200

block of Wilcox Street, near 1204 Wilcox Street, Subject Premise #6,

the home of Brice. Based on their training and experience and other

148
information developed during this investigation, law enforcement

agents believe that Duncan had instructed Scott to retrieve the drug

paraphernalia, including strainers needed to mix and package heroin

from the McIntosh’s residence.

g. At approximately 11:54 a.m., Duncan was observed

getting gas at a Shell station on Frankford Road and Cedonia Avenue.

At approximately 12:10 p.m., Duncan was observed briefly entering

127 Collington Avenue. At approximately 12:22 p.m., Duncan was

observed to park his vehicle in front of 1204 Wilcox Street,

“Tiger’s house,” Subject Premise #6. Shortly thereafter, Scott was

observed parking his vehicle on the side of Wilcox Street.

131. Based upon this series of calls and surveillance,

I believe that Duncan obtained a quantity of heroin from 5305B

Valiquet, Subject Premise #8, then contacted Scott to obtain the

cutting agents and various packaging paraphernalia from 1120

Homewood, Subject Premise #1, and then transported those items to

Subject Premise #6, 1204 Wilcox, for preparation for street level

distribution.

132. 5305B Valiquet, Baltimore, Maryland, identified

herein as Subject Premise #8, is a possible stash location for BGF.

Subject Premise #8 is a two story light brown duplex with the

numbers 5305 over the front door. There are wooden stairs leading

to the white side door and the letter B is affixed to the side door.

The utilities for 5305B Valiquet are in the name of James Bullock.

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Bullock has a significant criminal history, including two prior drug

distribution felonies. Further, Bullock was arrested on August 28,

2007 along with McFadden and others for participating in a craps

game in the 700 block of east Preston Street.

133. 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 Premise #8 the items set forth in

Attachment H, 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; 18 U.S.C. § 1959, which prohibits violent crimes

in aid of racketeering and 18 U.S.C. § 1956(d), which prohibits

conspiracy to launder money.

I. Subject Premise #9 - desk of Kimberly McIntosh located at


Total Health Care 1501 Division Street, Baltimore,
Maryland

134. Based on evidence developed during this

investigation, including information provided by confidential

sources and calls intercepted during wiretaps, I have learned that

Kimberly McIntosh, a/k/a “Sister Kim,” is the highest ranking female

150
member of BGF in Baltimore. As more fully described above, calls

intercepted over the wiretaps in this investigation indicate that

McIntosh is responsible for the finance of the BGF on the streets

of Baltimore. Additionally, she utilized Subject Premise #1 for the

cutting, packaging, the sale of heroin, and other controlled

substances, as well as near daily meetings of other high ranking

members of BGF. During these meeting, various racketeering

activities of the BGF are discussed and debated among the ranking

structure of BGF, to include, the sale of drugs, acts of violence,

and the disciplining of non-compliant BGF members.

135. On occasion, McIntosh has met with a confidential

source at her place of employment, Total Health Care, located at

1501 Division Street, Baltimore, Maryland. On at least one

occasion, the source entered 1501 Division Street and spoke with

McIntosh. During this encounter, McIntosh agreed to provide the

source (CS3), with a quantity of heroin after she finished work.

136. Additionally, several intercepted conversations

indicate that McIntosh routinely discusses BGF activity while she

is at work. For example:

a. During a series of calls on March 9, 2010, from

approximately 9:48 a.m. to 10:17 a.m., Duncan contacts McIntosh, who

is again at work. Duncan then requests McIntosh’s key to her home,

Subject Premise #1. After this call, electronic surveillance,

authorized by the Court’s order to intercepts Duncan’s cellular

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phones, indicated that Duncan traveled to the area of Total Health

Care, and then from there to the area of Subject Premise #1.

b. On March 29, 2010, at approximately 10:42 a.m.,

Duncan speaks to McIntosh, who indicates that she is at work.

Duncan then proceeds to inform McIntosh of the information that he

(Duncan) received from “Bow (a reference to Rainbow Williams).”

This call was summarized above.

137. Subject Premise #9 is a business, Total Health Care,

located at 1501 Division Street, Baltimore, Maryland, and McIntosh’s

place of employment. McIntosh has been surveilled at the location

on several occasion, and as late as April 1, 2010. Further, her own

conversations place her at that location on a near daily basis.

138. The precise location of McIntosh’s work space is

unknown to law enforcement because it is impossible for law

enforcement to conduct surveillance inside the business. Because

McIntosh routinely meets and/or discusses BGF activity while working

at Total Health Care, law enforcement believes that McIntosh may

maintain books, ledgers, contact lists, talley sheet and other items

of evidentiary value at her desk. The search of Subject Premise #9

will, therefore, be confined to the immediate desk and/or work space

of Kimberly McIntosh.

J. SUBJECT PREMISE #10 - 304 East 21st Street, Baltimore,


Maryland

139. Based on evidence developed during this

investigation, including calls intercepted during wiretaps, I have

152
learned that Erik Ushry, a/k/a “E,” is a wholesale customer of

heroin of Crooks. Additionally, recorded conversations between

McIntosh and CS3 on December 15, 2009 indicate that McIntosh

processes heroin for Ushry (see above). Duncan has also been

observed on at least one occasion, March 21, 2010, in and around

1120 Homewood Avenue, Subject Premise #1, during the “emergency” BGF

meeting, (see above).

140. On March 30, 2010, law enforcement was conducting

surveillance at 304 East 21st Street. At approximately 5:42 p.m.,

Ushry was observed to exit that location.

141. Further, on March 31, 2010, Duncan asks Ushry to

meet him near his (Ushry’s) mother place prior to going to court.

Duncan and Ushry are then observed together at the District Court

of Maryland for Duncan’s trial for giving a false statement to

officer. While awaiting trial, Duncan was arrested for violation

of his parole (a parole retake warrant) and taken into custody in

the courtroom. Law enforcement officers were present in the

courtroom and observed Duncan hand his personal effects to

individuals in the courtroom. Ultimately, law enforcement observed

Ushry take possession of the cellular telephones that are the

subject of the court orders to intercept Duncan’s communications.

Law enforcement continued to surveil Ushry and observed him leave

the courthouse and begin to travel toward Subject Premise #10

142. 304 E. 21st Street, Baltimore, Maryland, identified

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herein as Subject Premise #10, is the residence of Ushry. Public

record databases confirm that Ushry uses Subject Premise #10 as his

place of residence. Subject Premise #10 is a three story row home.

The first floor is painted white and the upper two floors are black.

There is a white front entry door with the numbers 304 in black

above the door.

143. 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 Premise #10 the items set forth in

Attachment J, 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.

I. SUBJECT PREMISE #11 - 1701 Harford Avenue, Baltimore,


Maryland

144. Based on evidence developed during this

investigation, including calls intercepted during wiretaps, I have

learned that Lamont Crooks is a source of supply of heroin for the

BGF. Crooks has been observed on at least one occasion conducting

154
a drug transaction with Earle Moore after using the Crooks Cellphone

to arrange for the transaction. Intercepted calls further indicate

that Crooks utilized Sherice Foster to process and mix the heroin

at her home, Subject Premise #11. During a series of intercepted

phone calls over the Crooks Cellphone, Crooks discusses with Foster

the processing of heroin. For example:

a. On March 26, 2010, at approximately 2:36 p.m.,

Crooks placed an outgoing call to (410)261-6110, assigned to the

Charles Village Safeway, utilized by Sherice Danielle Foster.

During the conversation Crooks asked, "What time you get off?"

Foster answered, "Um six o'clock." Crooks responded, "You get off

at six." Foster responded, "Right and then I'm going to a tattoo

party." Crooks responded, "Huh?" Foster asked, "Why what's up?"

Crooks responded, "Yeah, yeah um and then what?" Foster responded,

"I'm going to a tattoo party oh but I be home. I'm gonna go home

first." Crooks responded, "Say she going home then she going to a

tattoo party." Foster then spoke of getting a new tattoo. Crooks

advised, "No we had some uh, something for you to uh, here I wanted

to drop something off." Foster asked, "When you, when they, when

you, when you all need them done by?" Crooks answered, "Um like

tomorrow." Foster advised, "Oh I work eight to four thirty. Just,

I'll do them tonight. I'm do em' tonight when I finish doing what

I was doing." Crooks responded, "Alright." Foster advised,

"Alright just drop it off." Crooks responded, "Ok." Based on their

155
training and experience and other information developed during this

investigation, law enforcement agents believe that Crooks was taking

a large quantity of drugs to Foster so she could package the drugs

for street sale. Crooks advised, "No we had some uh, something for

you to uh, here I wanted to drop something off." Foster asked,

"When you, when they, when you, when you all need them done by?"

Crooks answered, "Um like tomorrow." Foster advised, "I'm do em'

tonight when I finish doing what I was doing."

b. On March 27, 2010, at approximately 3:50 p.m.,

Crooks placed an outgoing call to (410)261-6110, assigned to the

Charles Village Safeway, utilized by Foster. During the

conversation Crooks asked, "What time you get off?" Foster

answered, "Four thirty." Crooks said in the background, "She said

four thirty homie." Crooks then asked Foster, "Um how many of them

demonstrations you get through?" Foster answered, "All of em'."

Crooks then spoke to a unidentified male in the background. Crooks

said, "Alright shoot back." The UM responded, "Alright." Crooks

then advised Foster, "Yeah he said he gonna uh, uh, the homie said

he gonna come get you." Foster asked, "From work?" Crooks

answered, "Yeah not unless you got a ride." Foster advised, "No he

can come get me. Alright you coming with him?" Crooks responded,

"Oh, oh no. They um, is they, it's, it's in the house?" Foster

answered, "Yeah in that same bag." Crooks responded, "Oh alright

but, yeah who in there?" Foster answered, "I don't know. But he

156
gonna come get me right?" Crooks advised, "Alright I'm a, uh, uh

nah I probably shoot and get it. Yep that's what I was thinking

about. I'll probably shoot. Cause you know I'm fucked up. But I'm

a shoot and get it." Based on their training and experience and

other information developed during this investigation, law

enforcement agents believe that Crooks was asking Foster how much

of the drugs he (Crooks) provided to her were packaged. Crooks

asked, "Um how many of them demonstrations you get through (a

reference to units of drugs)” and Foster answered, "All of em'."

Crooks asked, "They um, is they, it's, it's in the house, Subject

Premise #11?" Foster answered, "Yeah in that same bag (a reference

to having the drugs stored in the Foster residence.)”

c. On April 2, 2010, at approximately 12:31 p.m.,

Crooks received an incoming call from (443)278-3855, subscribed to

Danielle Foster, 1701 Hartford Road, Baltimore, Maryland, utilized

by Foster. During the conversation Crooks asked, "You at work?"

Foster answered, "Um." Crooks responded, "Oh shit. What time you

get off?" Foster answered, "Two forty five. I'm a do them when I

come home. I ain't got (unintelligible.)" Crooks advised, "No you

good." Based on their training and experience and other information

developed during this investigation, law enforcement agents believe

that Crooks was inquiring whether Foster had finished packaging the

quantity of drugs he had recently given her to package for sale.

As a result of the conversation surveillance was established at the

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Charles Village Safeway, 2401 N. Charles Street, Baltimore,

Maryland. At approximately 3:06 p.m., law enforcement observed

Foster exit the Safeway and enter a vehicle. Law enforcement then

followed Foster to 1701 Harford Avenue, Baltimore, Maryland, Subject

Premise #11. At approximately 3:13 p.m., Foster exited the vehicle

and entered the front door to her residence located at 1701 Harford

Avenue, Baltimore, Maryland, Subject Premise #11. A query of public

record databases revealed the current residence for Sherice Danielle

Foster as 1701 Harford Avenue, Baltimore, Maryland.

145. 1701 Harford Road, Baltimore, Maryland, identified

herein as Subject Premise #11, is the residence of Sherice Foster.

Public record databases confirm that Foster uses Subject Premise #11

as her residence, and the utilities are in her name. Additionally,

the cellular phone used by Foster is subscribed to in her name at

Subject Premise #11. Subject Premise #11 is a red brick building

with the address 1701 Harford Avenue on a white sign affixed to the

building to the right of the white entry door.

146. 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 Premise #10 the items set forth in

Attachment I, 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

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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. Computers

147. Based on evidence developed during this

investigation, including calls intercepted during wiretaps, I have

learned the BGF is highly sophisticated criminal enterprise and use

various forms of media to communicate. For example:

a. On March 27, 2010, Duncan and Harried speak with

each other regarding the collection of BGF dues and the registration

of members. During the conversation, Duncan tells Harried “text

me...how much it suppose to be.”

b. Further on February 11, 2010, at approximately

2:28 p.m., Chambers received an incoming call from Crooks. During

the conversation Crooks advised, “Hey yo I just got your text uh

about Keko. Where, where he was at?” Chambers answered, “Oh I

don’t know where Keko and them but that, oh shit you know I don’t

know how to respond on that shit but Keko up his house.” Crooks

responded, “Oh alright. Well if, if, if, if he calls you back tell

him, tell him um, tell him call me. Give him my number.” Chambers

continued, “Alright he don’t got no phone. I be hitting him on

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Facebook.” Crooks responded, “Oh alright. Then I got to get him

on my page then.” Chambers advised, “Yeah just go to my page and

you’ll see that he my friend and hit it and, and send him a friend

request. He probably still on there.” Crooks responded, “Alright,

alright that’s what I’ll do then.” Based on their training and

experience and other information developed during this

investigation, law enforcement agents believe that Keko is

attempting to purchase a quantity of drugs from Crooks through

Chambers. The content of the drug purchase was sent to Crooks from

Chambers through a text message. When Crooks requested that

Chambers to have Keko call him directly, Chambers advised that he

communicates with Keko only through the use of the website Facebook.

Chambers instructed Crooks to view Chambers Facebook page, locate

Keko under his friends section and ask Keko to become one of his

friends. By “friending” Keko, Crooks can communicate with Keko

regarding drug trafficking directly via the website Facebook. A

review of Chamber Facebook page by law enforcement revealed several

photographs of Chambers friends. One such friend, identified as

Regulator Keko is in several photographs surrounded by other males

displaying hand gestures identified as being used by gangs.

148. Based on the above conversation, it is clear that

at least some members of BGF communicate through computers. As a

result, law enforcement requests permission to seize computers, if

they are located at the Subject Premises, with the exception of

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SUBJECT PREMISE #9, and if necessary separate search warrants will

be prepared for the computers.

VII. Night-Time Execution

149. These warrants are being executed for offense

related to Title 21 of the United States Code, involving narcotics

trafficking. On an almost daily basis the indicted individuals

engaged in a city-wide conspiracy to distribute heroin. Along with

continuous drug trafficking, law enforcement has intercepted calls

demonstrating the highly organized and violent nature of this

organization. Based on those reasons, and the multitude of

conversations listed above, I request permission, pursuant to 21

U.S.C. § 879, to execute the warrants at anytime to protect the

integrity of the investigation, prevent the destruction of evidence

and to ensure the safety of the agents executing the warrants.

VIII. Authorization for No Knock Entry

150. On March 17, 2010, at approximately 8:17 p.m.,

Crooks placed an outgoing call to (443) 271-9198, subscribed to

James Bondd, PO Box 54966, Irvine, California, utilized by Fella.

During the conversation Crooks asked, "Yo you ever get mobile yet?"

Fella answered, "No not yet I'm waitin' on my car. I'm in the house

yo." Crooks responded, "Oh alright." Fella asked, "You alright?"

Crooks answered, "Yeah, yeah when you um, when you um, you slide

through, yeah, yeah definitely holler at me though. You still is

straight?" Fella responded, "Nope I, I, I, I'm, I got a dude. He

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just got straight or whatever. Told me when I get mobile to come

holler at him. He got…" Crooks responded, "Oh ok." Fella

continued, "Hey yo there's another dude right. That I'm gonna

holler at right." Crooks responded, "Yeah." Fella continued,

"Their Q's, with, with, with Q's there shit is outstanding." Crooks

responded, "Oh ok." Fella continued, "Man I'm talking about really

it's outstanding." Crooks responded, "Yeah." Fella continued, "So

that's what you were trying to do?" Crooks answered, "Yeah um plus

I probably, I probably gonna need that um, that forty (a firearm).

You still needed it?" Fella answered, "That what?" Crooks

continued, "That forty dollars you were talking about. You still

needed it?" Fella answered, "Yeah, hell yeah." Fella advised that

he would be able to meet Crooks in about an hour. Based on their

training and experience and other information developed during this

investigation, law enforcement agents believe that Crooks was asking

to purchase a quantity of drugs from an unidentified source of

supply known to Fella. However, Fella advised that his regular

source did not have the drugs Crooks wanted but, Fella had another

drug source who had just received a new shipment. Crooks advised,

"Yeah, yeah when you um, when you um, you slide through, yeah, yeah

definitely holler at me though. You still is straight?" Fella

responded, "Nope I, I, I, I'm, I got a dude. He just got straight

or whatever." As the conversation continued Crooks asked, "I

probably gonna need that um, that forty. You still needed it?" (a

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reference to a forty caliber handgun.) Fella advised that at this

time he still needed to obtain the weapon from Crooks. Ultimately,

Fella agreed to meet with Crooks later in the evening to discuss the

purchase of drugs by Crooks.

151. I personally have participated in a previous arrest

of Crooks. At the time of this arrest on November 30, 2004, Crooks

was observed to exit 1502 Aisquith Street, Subject Premise #4, en

route to conduct a home invasion robbery. At the time of his

arrest, Crooks and his two conspirators were in possession of three

firearm, including an 9mm semi-automatic Uzi and a magazine with 32

rounds. On Crooks’s person was a loaded Taurus 9mm handgun. Crooks

ultimately pled guilty to being a felon in possession of a firearm.

He was sentenced to 46 months in federal prison and is still on

supervised release.

152. I am aware that firearms are “tools of the trade”

in drug trafficking. Crooks’s personal history and the nature of

the telephone call described above, which, based upon my training

and experience, is discussing a firearm, I believe that any attempt

to “knock and announce” prior to making entry at Subject Premise #4,

creates an unacceptable risk to the officers executing the warrant

at this particular location. Accordingly, I request that the agents

and officers executing the search warrant at 1502 Aisquith Avenue,

Subject Premise #4, be permitted to execute that warrant without

first knocking and their presence.

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