UNITED STATES DISTRICT COURT

DISTRICT OF MARYLAND

!i
UNITED STATES OF AMERICA

v: CRIMINAL COMPLAINT
WADECdATS CASENUMBER: _
629 N. Duncan Street

Baltimor~, Maryland : •••• 0 9 .2126 P · G

I, the undersigned complainant, being dnly sworn state the following is true k\(~orrect to
the best afmy knowledge and belief. On or about April 28, 2009, defendant, (Track Statutory Language Offense)

.. I; . j'

Wade!iCoat~, did
knowingly, intentionally and unlawfully combine, conspire, confeder~te and agree
with others known and unknown to distribute and posses with intent to distribute 1 kilogram or more
of a substance containing a detectable amount of heroin, a Schedule I controlled substance and
cocaine, a Schedule II contrdlled
,I
substance,

in violation of Title -1..L United States Code, Section(s) 846

I
I ! ':

I furyher ,state that I am a Special Agent of the Drug ,Enforcement Administration, ~nd that this
complaint is based on the following facts: Official Title

SEE ~ TT ACHED AFFIDAVIT

ffYes D No

Sworn t6'before me and subscribed in my presence,

Baltimore, Maryland
", 09 2124 PWG '09 212bPWG
AFFIDAVIT

This affidavit is submitted in support of an application for a criminal complaiht charging

Jose Cavazos; Ronald Brown and Wade Coats with violating 21 U.S.C. ~846 to wit: conspiracy
"

to distribute 1 kilogram or rJore

II
of heroin, a Schedule I controlled substance and 5 kilograms or

more of cocaine, a Schedule II controlled substance.

I, ALBERT B. PERRY, being duly sworn, depose and state as follows:

i

Ii

I ~m a law enforcement officer of the United States within the meaning of Sedtion
, i'

2;510(7) of Title 18 ofthe United States Code, that is, an officer empowered by law to conduct

investigations of, and make arrests for, offenses enumerated in Section 2516 of Title 18.
"II
I;

I am a Special Agentrwith the Drug Enforcement Administration (DEA) currently

assigned to the Washington Field Office and have been so employed since May 14, 1992. Prior

to th~t d~~e, I was a sworn police officer with the Metropolitan Police Department, ~ashington,
~
II I.
~ I: •

D.C:, froin 1982 to 1992. While so assigned, I was involved in the investigation of narcotic
, .
violations for six years. I have participated in hundreds of drug related arrests and purchased

illicit and dangerous drugs while working in an undercover capacity on at least one hundred
• ;1

occasions. I was responsible for obtaining and executing over one hundred search and arrest

warrants, and performed observations on hundreds of occasions which lead to the arr~st of drug
. I

violJtorsl I have received specialized training in narcotic investigations and identific~tion as well
i~

as the laws of search and seizure.

The facts and information contained in this affidavit are based upon my personal

knowledge and the investig~tion and observations of other officers and agents involved in this

investigation. All observation referenced below that were not personally made by me were

-1-
-~ 09 2124 PWG 09 2126PWG ,- ~ '.~.,...
ji

relat~d to;me by the persans who, made such abservatians.

Statement of Facts

In April af2009, members afDEA Task Farce HIDTA (High Intensity Drug Trafficking

Area) Graup 54 made cantadt with a reliable canfidential saurce (CS) af infarmatian. This CS' s
II •

infarmatian has led to, the recavery af kilagram quantities af cacaine and heroin, as well as the

seizure
,
.
af aver $200,000 in U.S. Currency .

!I The CS explained that a black male named "Truck" was distributing large quJntities af

herain and cacaine an the east side af Baltimare, Maryland. The CS explained that "Truck"

aperated a black Dadge R~ Pickup truck, a gald Lexus and a silver BMW with license plate

5DE R83. The CS further si~ted that the CS has been present far several large drug transactians

invalving "Truck."

Based upan the infarmatian pravided by the CS, law enfarcement searched v1riaus
"

indices and learned that the BMW was registered to, Ranald and Lisa Brown at 5 Cliffwaad

Raad, Baltimore, Maryland 21206. Law enfarcement also, determined that Ranald Brawn has a

priar felany canvictian invalving cantralled substances far which he received a 15 year sentence

in the Circuit Caurt for Baltimore City, as well as a Rabbery canvictian. A phatagraph af

Ranald Brawn was shawn the CS, and the CS pasitively identified the phata as the individual the
ii '
CS Knaws as "Truck."

During the week af April 22 thraugh April 28, 2009, law enforcement met with the CS

far the purpase af making a purchase af cantralled substances fram Ranald Brawn, aYkJa

"Truck.'" The CS was seard~ed and faund to, be free af any cantraband ar currency, and law

enfarcement established physical surveillance af 5 Cliffwaad Avene. Once surveillance was in

-2-
'...:.'raf'.
':'(
 019 2124PWG t 09 2126P~ j;

plac¥, the CS was directed to contact Brown. Brown advised the CS to meet him at ~,pre-

determined location. Law enforcement then traveled with the CS to the pre-determined location,

and observed the CS to travel directly to the location without meeting anyone else. Meanwhile,

surveillance units at 5 Cliff~ood Avenue advised that Ronald Brown had left the residence and

was operating a Dodge Ram with Maryland registration OOV 987. A short time later, Brown was

observed operating the same vehicle and arriving at the meet location. Law enforcement agents
.11.
:
Ii
!:
i,',
II

obse~ved"Brown and the CS to meet at Brown's vehicle, and after this brief encountet, the CS

walkced directly back to the law enforcement agents monitoring the transaction. The CS

explained that he/she had pl*ced an order for heroin and that Brown was going to get it.

Law enforcement maintained surveillance of Brown and observed him to drive to 1112

Harwall Road in Baltimore, Maryland. Surveillance units observed him to park and walk to the

rear ~ntr~nce of that location. Surveillance units then followed Brown back to the pre-arranged
" I" ';

location with the CS. Surveillance units observed the CS to meet briefly with Brown at this

vehicle. The CS then walked directly to the agents monitoring the transaction and relinquished
I:
'I

control of a brown substancJ" which investigators believed, based upon their training and

experience, was heroin.

On April 27, 2009, the CS again made contact with law enforcement and advised that
, i
il :: i.'

"Tr*k" had just informed the CS that he ("Truck" a/k/a Ronald Brown) had just received a large

amount of heroin and cocaine. Law enforcement established surveillance of Brown, and

observed him to be operating a silver BMW with Maryland registration 5DE R83. At
;, 'j

approximately 10:23 p.m., law enforcement observed Brown park his vehicle on the eastbound

side of the 1000 block of Eastern Avenue in Baltimore City, Maryland and utilize a cellular

-3-
,. 09 2124 PWG
,
phone. At approximately 10:25 p.m, surveillance members observed a white Lincol~ bearing
:1 i; !I

Virgtnia registration XUNI084 park directly behind Brown. At that time, the driver of the white

Lincoln, ~ black male, later identified as Wade Coats, exited his vehicle and walked to the

passenger side of Brown's B:MW and opened the door. After a brief conversation, Brown exited

his car and both walked to a garden area in the block beside the two vehicles. The two sat on a

ledgy, as.Brown began looking up and down the street, as if he were conducting survrillance.
II ,
II : ::
Bro\}rn then removed a white bag from his rear pants area and dropped it into the open window of

the white'Lincoln. This white bag was in a large square shape and resembled what law

enforcement believed was p~ckaged money. After the item was dropped into the vehicle, both

Brown and Coats entered their respective vehicles and left the area. Surveillance units followed

Coats directly to the Marriot Waterfront Hotel and park in front of that location. Coats was then

obse:rved!to remove several luggage-like bags from his trunk and enter the hotel. Approximately
1 I"~ I:

thirtY minutes later, Coats was observed exiting the front door of the hotel without the bags.

Coats was then followed to Mo's Seafood and then directly to a phone store located in the 600

block N. Duncan Street.

At approximately midnight, members began surveillance of Coats and his vehicle at 629

N. Duncan Street. At approximately 1:35 a.m., on April 28, 2009, members of the slfrveillance
,.

tea~ obs'erved Coats exit the business located at 629 N. Duncan Street, Baltimore M~land
, :!
, --
carrying bags, and placing them into the trunk area of the vehicle. At this time, law enforcement

stopped Coats outside of his vehicle, and identified themselves as law enforcement. Coats
"

appeared to be nervous and {vas asked where he had been that evening. Coats replied at his

girlfriends house off Bel Air. Road, Mo's Seafood, and at 629 N. Duncan Street. Coats was asked

-4-
~ ,
')
'''~''092124PWG J: 09 2126 PWG
ifhe,lhad!yisited the MarriotWaterfront Hotel tonight, and he stated "no, not at all." ~ecause of
l :; .

i .1

Coat~ denying his trip to the hotel a canine unit was asked to respond to Duncan Street. Officer
I

Colbert r~sponded to the scene and conducted a canine scan of the exterior of Coats' vehicle.

Officer Colbert indicated that he (Colbert) had observed his trained canine partner to make a
,I

positive reaction for the pre~ence of narcotics in the vehicle. Law enforcement then conducted a

search of the vehicle and located a handheld radio frequency scanner that was monitqring all of
II :' Ii
the Baltimore
Ii t,
Police Department's radio channels, and also the Baltimore District Office
i:
of the

DEA's radio channels. Additionally, two Maryland Driver's License's with Coats's picture but

different personnel information were recovered. While searching the vehicle, law enforcement
I

observed Coats to be making movements consistent with that of an armed person. Law

enforcement then approached Coats, who attempted to move his right hip away from ,the officers.
:;"

At tl}is ti~e, detectives forcefully took Coats to the ground and removed one silver i~ color .40
P t i,
" Ii
caliber semi-auto handgun loade~ with nine rounds of ammunition from his person. Coats was

arrested and a search incident to that arrest approximately $7,000.00 in U.S. currency, $5,000.00

of which was hidden in Coats's right sock, was recovered from his person. Coats was advised of
,i

his rights, at which time he agreed to speak with law enforcement. Coats stated that the gun was

for protection, and that he had bought the "police scanner" at "K-Mart." Coats was again asked

ifh~:had'ibeen to the Marriot Hotel today, and he stated "no." He was also asked ifh~ had been
. I' .

to any hotel today, and he stated "no." Coats was advised that he was observed going into the

Mart-iot Hotel, and he stated "there's your story, there's my story, and there is the truth. Let's see

what the judge decides." A(this time, Coats was transported to Central Booking for processing.
'.~092124 PWG' • 09 2126PWG
A~ approximately 3:15 a.m., law enforcement traveled to the Marriot Waterfront Hotel

loca~ed at 700 Aliceanna Street, and met with hotel security. Hotel security advised that Wade
'II II Ii

Coats was registered in room 943 at the hotel. Law enforcement knocked on the doo~ of Room
,\ I;

943 and a Hispanic male, later identified as Jose Cavazos, with an address of 601 N. 1st Street,

Midlothean Texas 76065, answered the door. Law enforcement then secured Cavazos and the
If
'i
room. After making sure ndtother individuals were in the room, Cavazos was advised of his

rights. Cavazos acknowledged that he understood his rights, and agreed to speak with law

enforcement. Cavazos stated that "1am just the money counter, no drugs in the room". He

stateo that, "They [the drugs] are not here yet, 1 count the money and make sure that it is good."
II I i
I '
:, i~ I:

Cavazos ~
:~as asked how much money was in the room and he stated "like $200,000.'; Cavazos .

was 'aske'd where the rest of the money was, and he stated "the Jamaican has it." 1 know that

Coats is of Jamaican descent. Cavazos was asked how he traveled to Baltimore and he

responded that "I believe 1 should

.; , speak with my lawyer now". At thistime, Cavazos, was taken

into custody and detained_~*he Baltimore District Office of the DEA. Meanwhile, Detective

Lunsford, traveled by foot through the parking garage of the Marriott Waterfront Hotel, located at

720 Aliceanna Street. Lunsford observed a white Dodge Caravan bearing Texas registration
, I' "

GS~ 27~. Law enforcement ran the vehicle information and learned that the vehiclel:was
Ii !,' "

,: i~
registered to a Crystal Cavazos of Midlothean, Texas. Lunsford then contacted a canine handler

to conduct a scan of the vehicle. At approximately 9:10 a.m., Detective Day conducted a canine

scan of the exterior of the ve,hicle, and advised Lunsford that he had observed his canine to make
!j

a positive reaction for the pi~sence of narcotics coming from the described vehicle.

Based upon the abov,e described information, law enforcement obtained search and

-6-
(~
" 09 2124 PWG p 09 2126PWG
seizure Warrants on April 28, 2009 from the Honorable Judge Hong of the District C9urt of
"ij i l
L

MarYland for the following: 5 Cliffwood Road, Baltimore Maryland; 1112 Harwall R9ad, Gwynn

Oak, Maryland; 700 Aliceanna, Room 943, Baltimore, Maryland; 629 N. Duncan Street,

Baltimore, Maryland and a 2:007 Dodge Caravan with Texas registration GSH 276 located in the

garage at 720 Aliceanna Street in Baltimore, Maryland.

The searches of the locations revealed the following:

From Room 943, law enforcement seized one large black bag containing several heat

sealed packages wrapped in aluminum foil. Each bundle contained a sum of U.S. Currency for a

totaL of approximately $275,000. Agents also located several cellular phones and chargers. Also
.I
~1

located was a tally sheet andl.a Texas drivers license in the name of Jose Cavazos. Located in a

suitcase in the hallway of the room were three boxes of food saver heat sealing bags, a heat

sealipg n}achine, and aluminum foil. Located in the closet of the room was an electr9nic money
.
counter. ,:

From the Dodge Caravan, law enforcement recovered an orange suit case which

contained several heat seale4 bags containing approximately $335,000 in U.S. Currency.

From 1112 Harwall, law enforcement encountered Ronald Brown alk/a "Truck" in the

basement of the dwelling. Brown was advised of his rights and agreed to speak with law
"

enfo~cenient agents. Brown was asked if the dwelling contained any narcotics and B}own was
Ii .:

observed to drop his head and shake it. Located in the dwelling were a "Nike" bag containing

red/white capsules, a large bag filled with purple/white gelatine capsules, a gelatine cap press,

and scales, a metal stainer and spoon all of which is consistent with the packaging of controlled
"
substances. Law enforcement also located a bag containing a brown substance believ.ed to be

-7-
..

• 1;09 2124PWG'
! I.
"092126 Rwe
heroin, and a pane of glass with white/brown substances on it, also believed to be heroin (a
,i

subs~queht field test of the s,ubstance on the pane of glass was positive for the presence of heroin.

Additionlilly, a black bag containing three plastic bags containing a rock substance, later

determined to be approximately 374 grams of cocaine hydrochloride (powder cocaine) was

recovered.
" ii'

.'
From 629 North Duncan Street, agents observed the location to be a business "Keeping In

Touch Communications" with and attached living area. The living area contained approximately
"i

$16,000 in U.S. Currency, a money counter, and numerous heat seal bags, like those used around

the currency recovered from the Marriott Waterfront Hotel, as well as a magazine to a firearm.
II 'I i,
;i

I believe, based upon my training knowledge and experience, that the approxi'ITmtely

$600,000 in U.S. currency seized, pursuant to the execution of search and seizure warrants, at the
.j
Marriott Waterfront Hotel would have been used to purchase kilogram quantities of controlled'

substances.

Conclusion

Based upon the foregoing, I submit that probable cause exists to charge Jose Cavazos,

Ronald Brown and Wade C0ats

II
with conspiracy to distribute and possess
"
distribute heroin and cocaine.

-8-