Professional Documents
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DISTRICT OF CONNECTICUT
Plaintiff,
v. Civil No.
Now comes Plaintiff, United States of America, by and through its attorneys, David B.
Fein, United States Attorney for the District of Connecticut, and David X. Sullivan, Assistant
1. This is a civil action in rem brought pursuant to 21 U.S.C. § 881 (a)(7), for the
Property") which was used or intended to be used in any manner or part to commit or to facilitate
the commission of a violation of the Controlled Substances Act, 21 U.S.C. §§ 801 et seq. and
pursuant to 21 U.S.C. § 881 (a)(6) for the forfeiture of Five Hundred Thirty-Seven Thousand
Two Hundred Sixty-Six Dollars Eighty-Four Cents ($537,266.84) ("Defendant Currency") which
Case 3:10-cv-01019-VLB Document 1 Filed 06/28/10 Page 2 of 12
was derived from the proceeds of illegal narcotics activities and/or United States Currency which
represents actual proceeds of illegal narcotics activity in violation ofthe Controlled Substances
2. This Court has jurisdiction over this matter by virtue of28 U.S.C. § 1345 and § 1355.
1395.
5. The United States does not request authority from the Court to seize the Defendant
Property at this time. The United States will, as provided by 18 U.S.C. §§ 985(b)(1) and (c)(l):
(a) post notice of this action and a copy of the Complaint on the Defendant Property;
(b) serve notice of this action on the record owner of the Defendant Property, and any
other person or entity who may claim an interest in the Defendant Property, along
(c) execute a writ of entry for the purposes of conducting an inspection and inventory
(d) record a lis pendens on the Watertown Records ofthe Defendant Property's status
6. The United States will also, as provided by 19 U.S.C. § 1606, appraise the
7. The Defendant Property was acquired by Shpetim Hidri and Nebije Hidri from
Margaret Garassino, executrix of the estate of Raymond Garassino by Executor's Deed, recorded
on August 17, 1995, at Volume 796, page 295 of the Watertown Land Records.
information from law enforcement officers in Michigan that they uncovered an extensive
marijuana distribution ring that originates in California and has reached into Michigan and,
among other places, Watertown, Connecticut. Michigan officers told Watertown law
enforcement that a search and seizure warrant was executed on the residence of an individual
named Andrew Poag in San Francisco. Poag was described by Michigan officers as the ring
10. During the execution ofthe search warrant at Poag's residence, law enforcement
found approximately two pounds of marijuana packaged to ship and a Federal Express ("FedEx")
label addressed to Jason Schiffmiller of 161 Old Farms Road, Watertown, Connecticut.
Michigan officers told Watertown officers that Poag told them that Schiffmiller and an individual
know to them as "Vala" were actively involved in the trafficking organization. Watertown police
immediately recognized Schiffmiller's name and knew "Vala" to be an individual named Valdrin
Hidri of 59 Highmeadow Road in Watertown (the "Defendant Property"). Law enforcement has
arrested Schifmiller and Valdrin Hidri together in other cases over the last several years.
11. On April 30, 2010, Watertown officers conducted a trash pull from the curb at the
Defendant Property. Found in the garbage were several large empty FedEx boxes containing no
shipping labels and two larger FedEx boxes in which the smaller boxes had been shipped. The
larger boxes had shipping labels with a California return address. Also located in the trash pull
different drug related crime. At that time, a FedEx Operations Specialist at the store approached
the officers and informed them of suspicious activities going on at the FedEx store. The
Operations Specialist told police that on March 24, 2010, a store employee approached him with
a questionable package. The FedEx employee told the Operations Specialist that one individual
had been sending the same sized package to another person every Wednesday for months. The
package sent every Wednesday was addressed to Andrew Poag of 44 Santa Fe, San Francisco,
California. The individual sending the package every Wednesday, as represented on the airbill,
13. The FedEx Operations Specialist told Watertown police that on March 24,2010,
he opened the questionable suspicious package that the employee had provided to him. Inside
the package the FedEx Operations Specialist found a three inch rectangular shaped object
wrapped in newspaper. He opened the wrapping at the comer of the object and observed a stack
of one hundred dollar and twenty dollar bills. He estimated the total amount to be approximately
$15,000. Security personnel at FedEx instructed the Operations Specialist to allow the package
Search and Seizure Warrant on the Defendant Property. Arriving at the Defendant Property,
officers first attempted to place a telephone call to request that someone meet them at the front
door, but no one answered the call. Officers then noticed individuals moving within the
Defendant Property. After several knocks on the door, officers forced entry with a battering ram.
15. After entering the Defendant Property and announcing their presence, officers
first located Jeton Hidri exiting his second floor bedroom. After a brief struggle, Jeton Hidri was
placed on the floor and handcuffed. Jeton then refused to stand up and was forcibly taken to his
feet and removed from the Defendant Property and placed in a law enforcement vehicle. He was
16. Officers next located Shpetim Hidri at the top of the front staircase and he was
17. Officers then located Valdrin Hidri who was first observed running from his
bedroom to the garage and towards the basement. Valdrin ignored officers commands to stop
18. Officers next located Vetim Hidri in his bedroom. Vetim ran at officers when
confronted and had to be physically placed on the ground to be handcuffed. Also located in
Vetim's room were his wife and three year old daughter.
19. All of the individuals, with the exception of Jeton Hidri who was in the police
vehicle, were seated in the kitchen and read their Miranda rights.
20. While securing the Defendant Property, officers discovered an indoor marijuana
grow in the basement that Valdrin was running towards. In the basement, police found indoor
grow lamps heating 49 marijuana plants. Also found were two scales, three plastic bottles of
Monkey Juice (a liquid plant fertilizer), vacuum seal bags, a white plastic bag which held two
plastic ziplock bags of marijuana, and a wood stove that held partially burnt, dried marijuana.
While law enforcement was discussing the marijuana grow found in the basement, Shpetim said
21. Law enforcement continued their search of the Defendant Property. In Jeton
Hidri's room, law enforcement located $9,300 in counterfeit one hundred dollar bills in the
nightstand drawer. Police also forcibly opened a safe in leton's room and found, among other
things, a digital scale. Also located in the room were a computer and printer that may have been
22. In Valdrin Hidri's room, police found a small amount of marijuana in a white
paper fold located in a pair ofjeans, keys to a BMW and a Mercedes, which were later seized by
law enforcement. Officers found two vacuum sealers and a padded envelope from a California
23. In Vetim Hidri's bedroom, officers found a shotgun and ammunition, a plastic
bag with marijuana seeds, a ziplock bag containing marijuana, and a teeshirt rolled around
marijuana seeds.
24. Shpetim Hidri was arrested and charged with: Possession of Marijuana;
Possession of Marijuana with the Intent to Sell; Possession of Marijuana within 1500 feet of a
school; Operating a Drug Factory; Cultivating Marijuana; Risk ofInjury to a Minor; Possession
25. Vetim Hidri was arrested and charged with: Possession of Marijuana; Possession
of Marijuana with the Intent to Sell; Possession of Marijuana within 1500 feet of a school;
Operating a Drug Factory; Cultivating Marijuana; Risk ofInjury to a Minor; Possession of Drug
Paraphernalia; Forgery; Illegal Cultivation Without a License; Interfering with a Search Warrant;
26. Valdrin Hidri was arrested and charged with: Possession of Marijuana;
Possession of Marijuana with the Intent to Sell; Possession of Marijuana within 1500 feet of a
school; Operating a Drug Factory; Cultivating Marijuana; Risk ofInjury to a Minor; Possession
of Drug Paraphernalia; Forgery; Illegal Cultivation Without a License; Interfering with a Search
27. Jeton Hidri was arrested and charged with: Possession of Marijuana; Possession
of Marijuana with the Intent to Sell; Possession of Marijuana within 1500 feet of a school;
Operating a Drug Factory; Cultivating Marijuana; Risk of Injury to a Minor; Possession of Drug
Paraphernalia; Forgery; Illegal Cultivation Without a License; Interfering with a Search Warrant;
28. On June 3, 2010, Nebije Hidri, wife ofShpetim Hidri, surrendered to Watertown
Police to be processed on an active arrest warrant. She was read her rights and charged with:
29. On May 12 and 13,2010, law enforcement executed Search and Seizure Warrants
on bank accounts in the name of: Shpetim Hidri; Vetim Hidri; Jeton Hidri; Valdrin Hidri; and
Nebije Hidri. Law enforcement utilized bank records found during the search of the Defendant
Thomaston Savings Bank, account number XXXX40 at Greater Waterbury Healthcare Federal
XXXXXXXXXXX2079 at Wachovia Bank all in the name of Shpetim Hidri. Law enforcement
seized $213,962.1 0 from Thomaston Savings Bank, $1,431.32 from Greater Waterbury
Healthcare Federal Credit Union, $106,506.21 from Webster Bank, and $155,833.97 from
Wachovia Bank.
31. Law enforcement executed warrants on Webster Bank, Bank of America, and TD
Bank for accounts in the name of Vetim Hidri. Law enforcement seized $151.24 from Bank of
America. Due to threshold requirements the Government will not be forfeiting this currency.
32. Law enforcement executed a warrant on Webster Bank for accounts in the name
of Jeton Hidri. Law enforcement seized $270.04 from Webster Bank. Due to threshold
33. Law enforcement executed warrants on Watertown Federal Credit Union and
Wells Fargo for accounts in the name ofValdrin Hidri. Law enforcement seized $504.10 from
Wells Fargo. Due to threshold requirements, the Government will not be forfeiting this currency.
34. Law enforcement executed a warrant on account number XXXX7680 at CSE Federal
Credit Union in the name ofNebije Hidri. Law enforcement seized $59,533.24 from CSE
35. The total amount of currency seized by law enforcement was $537,266.84.
CONCLUSION
36. The Defendant, one parcel of property located at 59 Highmeadow Road, Watertown,
Connecticut, with all appurtenances and improvements thereon, is real property which was used
violation of the Controlled Substances Act in violation of21 U.S.C. 801 et seq., and is therefore
WHEREFORE, the United States of America respectfully asserts that there is probable
cause to believe that the Defendant Property is forfeitable to the United States pursuant to 21
(a) that pursuant to 18 U.S.C. § 985(b)(2), and 18 U.S.C. § 9830), which permits the
Court to "take any action to ... preserve the availability of the property subject to civil
forfeiture," the Court issue the proposed Writ of Entry attached to this Verified Complaint of
Forfeiture authorizing the United States Marshals Service, or its delegate, to enter the Defendant
Property, including any structures, on one or more occasions during the pendency ofthis in rem
forfeiture action:
(l) for the purpose of conducting an inspection and inventory and appraisal of the
Defendant Property, which inspection and inventory and appraisal may include
appraise the condition and value of the Defendant Property pursuant to 19 U.S.C.
§ 1606;
Property; and
(4) to be accompanied on any such occasion by any federal, state, or local law
enforcement officers selected by it to ensure the safety of any person acting under
(b) that the Court decree that the forfeiture of the Defendant, one parcel of property
improvements thereon, to the United States under 21 U.S.C. § 881(a)(7) is confirmed, enforced,
and ordered;
37. And that the Defendant Currency totaling $537,266.84 in United States Currency
was derived from the proceeds of illegal narcotics activities and/or United States Currency which
represents actual proceeds of illegal narcotics activity, in violation of21 U.S.c. § 801 et seq.
WHEREFORE, the United States of America respectfully asserts that there is probable
cause to believe that the Defendant Currency is forfeitable to the United States pursuant to 21
(a) that the Court decree that the forfeiture of the Defendant Currency totaling
$537,266.84, to the United States pursuant to 21 U.S.C. § 881(a)(6) is confirmed, enforced, and
ordered;
(b) that the Court award Plaintiff United States all other relief to which it is entitled,
Respectfully submitted,
DAVID B. FEIN
UNITED STATES ATTORNEY
J~~
~F~DIVISION
~J;1:_EY
DAVID X. SULLIVAN
_
ASSISTANT U.S. ATTORNEY
P.O. BOX 1824
NEW HAVEN, CT 06508
(203) 821-3700
FEDERAL BAR # ct03793
10
DECLARA nON
of Justice, and the agent assigned the responsibility for this case.
I have read the contents of the foregoing Verified Complaint of Forfeiture and the
statements contained therein are true to the best of my knowledge and belief.
I declare under penalty of perjury that the foregoing is true and correct.
11
SCHEDULE A
All that certain piece or parcel of land with all of the improvements thereon, situated on the
northwesterly side of Highmeadow Road, in the said Town of Watertown, known as Lot #54 as
shown on a map entitled "FERN-WOODS SUBDIVISION PLAN, SECTION 9, Scale 1"=100'
dated October 24, 1980" prepared by L.T. Scott-Smith Co., Surveyors, 33 Valentine Drive,
Waterbury, CT, which map is on file in the Watertown Town Clerk's Office as Map #2260,
bounded and described as follows:
SUBJECT TO:
1.) Right of Way and Easement - James B. White to The Connecticut Light and Power Company
dated May 26, 1927 and recorded in Watertown Land Records, Volume 69, Page 122; and dated
February 19, 1929 and recorded in Watertown Land Records, Volume 72, Page 286. MAY
AFFECT SAID PREMISES.
2.) Right of Way and Easement - Edna L. Russin to The Connecticut Light and Power Company
dated April 3, 1962 and recorded in Watertown Land Records, Volume 140, Page 236. MAY
AFFECT SAID PRENIISES.
3.) Easement - Raymond L. Garassino to the Connecticut Light and Power Company dated
March 25, 1977, recorded March 28, 1977 in Watertown Land Records, Volume 234, Page 18.