Pinellas County Sheriff's Detective Philip Pione Deposition

1 IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA

2 CRIMINAL DIVISION
3 CASE NO.: 17-060080 CF

Division I
4
5
STATE OF FLORIDA,
6
Plaintiff,
7
vs.
8
WESLEY TOWNSEND,
9
Defendant.
10 ________________________________/
11
12 DEPOSITION OF: DETECTIVE PHILIP PIONE.

13 TAKEN BY: Defendant.
14 DATE: August 23, 2017
15 PLACE: Victim Witness Office, Room

Criminal Justice Center,
16 14250 49th Street North,
Clearwater, Florida 34620
17
REPORTED BY: Phyllis B. Pennington, RPR, CP,
18 Notary Public,
State of Florida at large.
19
20
21 __________________________________________________
(Pages 1 thru 84)
22 __________________________________________________
23
24
25
Kanabay Court Reporters - Serving the Tampa Bay Area

727 821-3320
2
1 APPEARANCES:
2 RANGER JACKSON, ESQ.,
Assistant State Attorney,
3 State Attorney's Office,
Criminal Justice Center,
4 Clearwater, Florida,
Counsel for State of Florida.
5
PAUL DeCAILLY, ESQ.,
6 DeCailly Law Group, PA,
Post Office Box 490,
7 Indian Rocks Beach, Florida 33785,
Counsel for Defendant.
8 ______________________________________
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

727 821-3320
3
1 INDEX TO DEPOSITION
2 PAGE
3 DEPONENT: DETECTIVE PHILIP PIONE
4 Direct, by Mr. DeCailly....................... 4

5 (No cross)
6 Reporter's Affidavit of Oath.................. 81

Signature Page................................ 82
7 Reporter's Certificate........................ 83
Errata Sheet.................................. 84
8 ______________________________________
9
EXHIBITS TO DEPOSITION
10
EXH. DESCRIPTION PAGE
11
(No exhibits.)
12
______________________________________
13
14
15
16
17
18
19
20
21
22
23
24
25

727 821-3320
Detective Philip Pione - August 23, 2017 4
1 (Deponent sworn.)
2 THE DEPONENT: I swear.
3 __________________________________________________
4 WHEREAS,
5 DETECTIVE PHILIP PIONE,
6 the deponent herein, being first duly sworn, was
7 examined and testified as follows:

8 __________________________________________________
9 DIRECT EXAMINATION
10 BY MR. DeCAILLY:
11 Q. Okay.
12 Detective, can you -- for clarity of the

13 record can you spell your last name?
14 A. P-I-O-N-E.
15 Q. Okay.
16 A. An my first name Philip, has one l.

17 Q. Okay. Yeah, I misspelled it a couple of
18 times, but I got it straight I think.
19 All right. I want to go back. I want to get
20 a little history on you.
21 What kind of education do you have for being
22 a police officer?
23 A. For being a police officer, I went to the
24 police academy.
25 Q. Okay. Here in Florida?

727 821-3320
1 A. Yes. In Palm Beach County.

2 Q. And what year did you do that?
3 A. 2001.
4 Q. Okay.
5 Any other post academy associates or
6 bachelor's degrees?
7 A. I have a bachelor's degree in economics from

8 the University of Florida.
9 Q. Okay.
10 And you got that before you went into law
11 enforcement?
12 A. Yes.
13 Q. Okay.
14 Now, since you've been in law -- well, let me
15 ask you this. How long have you been with the Pinellas
16 County Sheriff's Office?

17 A. Since the beginning of 2012.
18 Q. Okay.
19 Prior to that had you worked as a law
20 enforcement officer anywhere else?
21 A. No.
22 Q. So your career to date has been here in
23 Pinellas County?
24 A. Correct.
25 Q. Now, when you started with Pinellas County,

727 821-3320
1 did you start on road patrol or did you start in the

2 jail?
3 A. On road patrol.
4 Q. Okay.
5 And what is your proper title now?
6 A. Detective.
7 Q. Detective. Okay.
8 Is that a promotion from road patrol?
9 A. Uh, I get paid more.

10 Q. Okay.
11 A. And they changed my title so I would assume
12 so.
13 Q. Okay.
14 And how long have you had the title of
15 detective?
16 A. Since 2014.
17 Q. Okay.
18 Now, since you've been with the Pinellas
19 County Sheriff's Office have you had any specialized
20 training in drug enforcement?
21 A. Yes.
22 Q. Okay.
23 What kind of training is that?
24 A. I've taken specialized courses at numerous
25 different teaching facilities.

727 821-3320
1 Q. Throughout Florida or have you had --

2 A. I've also gone to Quantico as well.
3 Q. Okay.
4 So you've been to the FBI --

5 A. No, DEA.
6 Q. DEA training?
7 A. I did methamphetamine and clandestine

8 laboratory drug enforcement training.
9 Q. Okay.
10 Do you know what year that was?
11 A. 2016.
12 Q. Okay.
13 A. Last year. Early.
14 Q. And did you get some kind of certificate from
15 that?
16 A. Mm-hmm.
17 Q. Is that a yes?
18 A. Yes.
19 Q. She can't --
20 A. Yeah.
21 Q. So I'm just reminding you of that. I'm not
22 trying to be a jerk about it. I'm just reminding you
23 so we have a clear record.
24 A. Okay.
25 Q. During that training at Quantico did you get

727 821-3320
1 like a textbook?
2 A. Yes.
3 Q. Okay.
4 Is this a book that you were able to keep and

5 bring home with you or did you have to turn it in?
6 A. I was able to take it home with me, all the
7 teaching materials.
8 Q. Okay.
9 Have you had any involvement in any

10 multi-jurisdictional drug enforcement task force?
11 A. Yes. I'm currently a member of the HIDTA,
12 High Intensity Drug Trafficking Area for central

13 Florida.
14 Q. And who is in charge of the task force?
15 A. I believe it's a collaboration. I'm not
16 exactly sure who the head person is.

17 Q. Okay.
18 Well, when you make reports about arrests or
19 about your activities, do they just go to the Pinellas
20 County Sheriff's Office or do they go to a task force?
21 A. I believe they submit statistics and reports
22 to the task force, but that's something above my pay
23 grade. I don't do any of that.
24 I do it for my agency and then they forward
25 it on wherever they need to.

727 821-3320
1 Q. Do you know if this task force is headed up

2 -- not only is it multi-jurisdictional, it also
3 includes FBI, DEA resources as well?
4 A. I believe so. I don't know. Like I said,

5 that's above my pay rate.
6 Q. Okay.
7 Does the task force issue any guidelines or

8 memorandum on how you're supposed to operate?
9 A. I follow my agency's policies and guidelines.

10 Q. Okay.
11 So there are no task force specific
12 guidelines?
13 A. Not that I'm aware of. I don't know.
14 Like I said, that is all above what I'm told.
15 Q. Okay.
16 So you haven't been given -- or given a class

17 or anything on specific task force activities?
18 A. No.
19 Q. Okay.
20 All right, I want to turn to the case before
21 us. Is the case that we have here today, Mr.
22 Townsend's case, is that part of a task force
23 investigation?
24 A. I believe it's a HIDTA case. However, it was
25 investigated by just the Pinellas County Sheriff's

727 821-3320
1 Office.
2 Q. So no outside agencies provided any support
3 whatsoever?
4 A. I don't believe so, no.

5 Q. Okay.
6 When you say, "I don't believe so," are you
7 considered the officer in charge of this case?

8 A. I'm in charge of this case but I'm not the
9 head person for HIDTA for my agency.

10 Q. Okay.
11 Who's the head person for HIDTA in your
12 agency?
13 A. That would be my sergeant, would be the
14 controlling member for our HIDTA task force --
15 Q. And what's his name?
16 A. -- it's Sergeant Bowman.

17 Q. And he's with the Pinellas County Sheriff?
18 A. She is --
19 Q. Or she is, okay.
20 A. -- with the Pinellas County Sheriff's Office.
21 Q. Okay.
22 Now, I'm going to turn to this case. In your
23 report it indicates that you had been provided with a
24 telephone number of somebody who could -- who would
25 sell marijuana, cocaine and pills.

727 821-3320
1 A. Mm-hmm.
2 Q. Okay.
3 I want to talk a little bit about that
4 person. Is it a specific person or was is it a group

5 of people who provided you with this information?
6 A. Uh, whatever is in the report is all I can
7 talk about. You have to certify anything else on that.

8 Q. Okay.
9 Well there's nothing in the report about it

10 that I can see so I'm trying to find out was this an
11 individual -- I'm not asking their name right now, I'm
12 just asking is it an individual or is it a group of

13 individuals?
14 A. Certify that as well.
15 Q. Okay. So it wasn't an anonymous tip that
16 came in?
17 A. No, it was not an anonymous tip.
18 Q. Okay.
19 So in your report you don't label this person
20 as a confidential informant. As a matter of fact, I
21 believe that the information I have been given from the
22 State Attorney's Office is this does not involve
23 confidential informants.
24 Would you label the person who gave you that
25 information as a confidential informant?

727 821-3320
1 A. Well, I guess you're assuming that's a person

2 and not a group of individuals at this point,
3 correct --
4 Q. Okay.
5 Well, would you --
6 A. -- based on that question.
7 Q. Okay.
8 So -- well, I'll ask you.
9 I asked you if it was an individual and you

10 couldn't tell me.
11 A. Mm-hmm.
12 Q. So is the individual or group of individuals

13 considered confidential informants?
14 A. Certify that as well.
15 Q. Okay.
16 Had you had any prior -- other than this

17 case, any prior or other dealings with the confidential
18 informants, the individuals or the group of people that
19 provided you the information?
20 A. Prior dealings, meaning like narcotic
21 transactions or prior --
22 Q. Yeah.
23 A. -- in person or --
24 Q. No, I mean prior -- you know, their
25 involvement in prior cases that led to an arrest.

727 821-3320
1 A. Let me see.
2 Uh, certify that one.
3 Q. Okay.
4 So you can't tell me whether or not you had a

5 prior working relationship with the source of
6 information in this particular case?
7 A. Correct.
8 Q. Okay.
9 Do you know what the bases of that informant

10 or confidential informant's knowledge was?
11 A. The basis? You mean --
12 Q. Yeah, where they got their -- where they got

13 their knowledge of whether or not somebody would sell
14 you narcotics, and the phone number?
15 A. Where they got that their number from? Do I
16 know it?
17 Q. Right.
18 A. Uh, let me just make sure I'm thinking
19 correctly.
20 So you're basically asking me do I know where
21 they -- how they met this person or where --
22 Q. Right.
23 A. -- got it? Yes.
24 Q. Okay.
25 So you have a -- you know where their -- the

727 821-3320
1 basis of their information to you came from?

2 A. Correct. Yes.
3 Q. Okay.
4 Maybe if I just ask the way I wrote it, maybe

5 it would be easier.
6 Were these informants or confidential
7 informant or informants engaged in the same activities?

8 A. Engaged in activities of --
9 Q. Dealing drugs when you met them.

10 A. Certify that.
11 Q. Okay.
12 The relationship between -- that you

13 gathered, that you created between you and the suspect
14 in this case, the alleged defendant, or the defendant
15 in this case, the alleged suspect, uh, was that
16 facilitated at all by these individuals who are either

17 confidential informants or --
18 A. Facilitated meaning --
19 Q. Other --
20 A. -- they gave me the phone number.
21 Q. Other than just giving the phone number. Did
22 they make any introductions, did they attend a meeting
23 with you, anything like that?
24 A. Uh, let me look to make -- I want to answer
25 you if I can, so, uh --

727 821-3320
1 Say your question one more time.

2 Q. Did this -- the people or person who provided
3 you the phone number --
4 A. Mm-hmm.
5 Q. -- did they aid you in any way beyond just
6 providing you a phone number in developing your
7 relationship with the alleged suspect in this matter?

8 A. No. I contacted them on my own via phone.
9 Q. Okay.
10 A. They walk up and --
11 Q. They didn't make any -- they didn't make
12 introductions on the phone or anything like that?

13 A. No.
14 Q. Okay.
15 When you spoke with the person arrested, that
16 you arrested in this case, uh, for the first time, did
17 you -- did you tell him how you came about his name and
18 number?
19 A. I believe so, yeah. Yes, I did.
20 Q. Okay.
21 And what kind of phone did you use? Was this
22 a cell phone when you made the first initial contact?
23 A. That I was calling from?
24 Q. Yeah.
25 A. Yes.

727 821-3320
1 Q. And is it a department-issued phone?

2 A. I'm not sure.
3 No, this was not a department cell phone this
4 time.
5 Q. Okay.
6 What cell phone were you -- who owned the
7 cell phone?
8 A. I owned the cell phone. The department gives
9 us a stipend.
10 Q. Okay.
11 And is the cell phone that you used
12 restricted for work purposes?

13 A. It has a separate line for work purposes.
14 Q. Okay.
15 Is that cell phone and all activities related
16 to this case preserved currently?

17 A. As far as I know, yes.
18 Q. Okay.
19 The confidential informants or the group of
20 them in this particular case, were they providing
21 information in exchange for anything back, such as
22 reduced charges or lower bonds?
23 A. Uh, I'm not the -- if it is a confidential
24 informant, I'm not the handling person for them, so you
25 would probably have to ask their handler, but, uh --

727 821-3320
1 Q. Who would the handler be? Who would I ask?

2 A. Detective Livernois.
3 Q. And is it a he or she?
4 A. He.
5 Q. And does he work for the Pinellas County
6 Sheriff's Department?
7 A. Yes.
8 Q. All right.
9 We're going to move on to --

10 A. I'll save you the time for that one. I can
11 tell you that they were compensated monetarily.
12 Q. Okay.
13 So they were paid for the information.
14 A. Yes.
15 Q. Okay.
16 So now I want to move on to your pre-contact

17 investigation. This is the time period between getting
18 the phone number, getting the information and your
19 first contact, okay?
20 A. Okay.
21 Q. What kind of investigative steps did you take
22 to verify information that you had been given prior to
23 making that first phone call?
24 A. We have internal data bases, initial data
25 basis that we use to verify and cross-check

727 821-3320
1 information.
2 Q. Okay.
3 One of those things that you -- did you run
4 the alias "Short"?

5 A. Yes.
6 Q. Okay.
7 Do you recall about how many hits you got on

8 that?
9 A. I don't recall.
10 Q. Was it more than one?
11 A. Probably, yes.
12 Q. Okay.
13 And what system -- what's that system called
14 that you used?
15 A. ACISS is our internal system.
16 Q. ACISS? Okay.
17 And is that only comprised of aliases for
18 Pinellas County Sheriff's Department known to them or
19 does that include known aliases from St. Petersburg,
20 from Clearwater PD, from Largo PD?
21 A. Uh, I do -- I'm not a technical person or in
22 charge of how that system works.
23 Q. Okay.
24 A. I have the skill level of about -- I put in
25 the information and it spit back out.

727 821-3320
1 Q. Right.
2 So your basis of knowledge for that is you go
3 to it, you put in what you need and it gives you a
4 result?
5 A. Yeah.
6 Q. You don't know where that result came from?
7 A. No. I would assume -- I can only assume it

8 comes from the Tampa Bay area.
9 Again, I don't maintain it for -- I'm not

10 exactly sure how it works.
11 Q. Okay.
12 And did you go through each and every hit for

13 Short and check the description of the individual?
14 A. Each and every -- say that again.
15 Q. It came up with more than one person for the
16 name Short?
17 A. Mm-hmm.
18 Q. We've already established that.
19 Did you run -- did you click on all of those,
20 all of them to verify the person's ethnicity, tattoos,
21 height, weight, whether or not they were in jail or
22 not?
23 A. No.
24 Q. Okay.
25 How many did you go through?

727 821-3320
1 A. Uh, I don't recall.

2 Q. More than one?
3 A. Yes.
4 Q. Okay.
5 And when you log on to this ACISS system, do
6 you do it with a log-on name and a password?
7 A. Yes.
8 Q. Okay.
9 And so the activities that you conducted are

10 recorded through your log-on name and your password?
11 A. I don't know.
12 Q. Okay.
13 But when you conducted these searches you
14 used your log-on and password to it?
15 A. Yes.
16 Q. Did you run the phone number prior to calling

17 it?
18 A. Yes.
19 Q. And what did it -- did it come up to an
20 owner?
21 A. Yes.
22 Q. And who was that owner?
23 A. Uh --
24 Q. Just for the sake of the record, just say,
25 "Hey, I need to look at my report," so we know when

727 821-3320
1 you're answering by looking at your report and when

2 you're answering just off the top of your head, okay?
3 A. Okay.
4 Let me refer to my report for a second.

5 Repeat your question for me, please.
6 Q. You ran the cell phone number?
7 A. Mm-hmm.
8 Q. Is that a yes?
9 A. Yes.
10 Q. Okay.
11 And you came up -- you came up with ownership
12 information?
13 A. Yes.
14 Q. And who did it say owned it?
15 A. The person by the nickname of Wii Bow Biz.
16 W-I-I. B-O-W. B-I-Z.

17 Q. And did you identify a carrier? The carrier
18 of who -- the cell carrier.
19 A. No, I didn't.
20 Q. Okay.
21 So you never issued any investigative
22 subpoenas for this cell phone?
23 A. At this time, no.
24 Q. At some point did you?
25 A. I did, yes.

727 821-3320
1 Q. Okay.
2 A. Actually -- I would have to look at my report
3 to see which database I submitted the information to.
4 As far as a subpoena, are you talking about

5 like phone tolls --
6 Q. Right.
7 A. -- to try to get information directly from

8 the carrier?
9 Q. Right.
10 A. Uh, I don't believe I did for this individual
11 because I already had him identified.
12 Let me refer to my report and see if I

13 notated it anywhere. If I didn't notate it, then I
14 didn't.
15 I don't believe I did for this one.
16 Q. You said something interesting though before

17 that. Now, I'm talking just the period of time between
18 your first getting the phone number and before the
19 meeting. You indicated you already had -- you already
20 had identified the individual?
21 A. Yes.
22 Q. And how did you do that?
23 A. Certify that. It's one of our investigative
24 techniques.
25 Q. Okay.

727 821-3320
1 So you identified the person before you made

2 that first phone call.
3 Did you obtain a specific location where you
4 could -- where dealing activities could be found?

5 A. Dealing activities?
6 Q. Yeah.
7 A. Meaning?
8 Q. Where drug deals may be --
9 A. Like geographically, which part the county or

10 street or --
11 Q. Right, right. Not an exact location. Did
12 somebody tell you in the parking lot of the post

13 office, you know, they're always doing business there.
14 At the bowling alley.
15 Did you identify anything like that prior to
16 your first phone call?

17 A. Let me refer to my report.
18 No.
19 Q. Okay.
20 So prior to your first contact with --
21 A. Hold on. Actually -- in Pinellas County. I
22 guess that -- if you're asking for -- it's a broad
23 range, but, yes, in Pinellas County was the information
24 that I learned.
25 Q. Okay.

727 821-3320
1 So you didn't have an opportunity to set up

2 any pre-first meeting surveillance?
3 A. No.
4 Q. So prior to your first meeting with the

5 suspect in this case, you had not witnessed or seen any
6 drug deals or any fruits of drug deals?
7 A. Correct.
8 Q. Okay.
9 did you have anybody do any control buys

10 prior to your first meeting to verify the information
11 that this -- the individual that you had identified was
12 in fact dealing drugs?

13 A. No.
14 Q. Okay.
15 Had you ever had any prior knowledge,
16 contact, prior arrests of Mr. Townsend in this matter?

17 A. No.
18 Q. So prior to this information you had never
19 met him?
20 A. Correct.
21 Q. No previous investigations involving him?
22 A. No.
23 Q. No? Okay.
24 Other than your police report are there any
25 other written notes or recordings of any kind regarding

727 821-3320
1 the activities that you conducted prior to making that

2 first phone call?
3 A. No.
4 Q. Did you have handwritten notes at one time?

5 A. No, I usually just type in the database.
6 It's easier that way.
7 Q. And the database is what produces the report?

8 A. In the database, yes.
9 Q. All right.
10 Now I want to go to the first buy.
11 A. Okay.
12 Q. I think you sort of already answered this

13 question, but you contacted the suspect in the case on
14 your own? Nobody helped facilitate that first contact?
15 A. Correct.
16 Q. Did you request to purchase a certain

17 quantity?
18 A. Yes.
19 Q. Okay.
20 And did you know at that time the quantity
21 requested would have been of a trafficking amount?
22 A. I knew it was not a trafficking amount.
23 Q. You knew it was not?
24 A. Correct.
25 Q. Okay.

727 821-3320
1 And was the first buy arranged by text, voice

2 or both?
3 A. Both.
4 Q. Okay.
5 Did you preserve all of the text
6 conversations?
7 A. Well, I didn't do anything to destroy them.

8 So I don't know how long they're automatically kept.
9 So --
10 Q. Well, you still have the phone, correct?
11 A. Yes.
12 Q. Okay.
13 And you're saying, you're testifying that you
14 didn't hit delete?
15 A. Correct.
16 Q. Okay.
17 What kind of texting program is on the phone?
18 A. It's like a Google Voice program.
19 Q. Okay.
20 And it's not the standard text thing that
21 comes with --
22 A. No.
23 Q. Okay.
24 Because the phone we're talking about has two
25 numbers, correct?

727 821-3320
1 A. Correct.
2 Q. And is the number that we're talking about,
3 was that a Google Voice number?
4 A. Yes.
5 Q. So all the activity regarding this case is
6 also connected to a Google Voice account?
7 A. Yes.
8 Q. Okay.
9 And you're the holder of that account?

10 A. Yes.
11 Q. Is that account in any way connected to your
12 personal email or anything like that in Google?

13 A. No. I have my own personal email, but I have
14 a registered email, too --
15 Q. Right.
16 A. -- to establish a number.
17 Q. Okay.
18 And did the -- was there any cost involved in
19 establishing the number or using the number?
20 A. No.
21 Q. Okay.
22 MR. DeCAILLY: (To State Attorney:) I'm
23 going to be requesting all the information from
24 that Google account.
25 MR. JACKSON: Okay.

727 821-3320
1 THE DEPONENT: The email account or the

2 Google Voice account?
3 BY MR. DeCAILLY:
4 Q. Well, did you use the email account in

5 connection with this?
6 A. No.
7 Q. Okay.
8 Just the Google Voice?
9 A. Mm-hmm.
10 Q. I'm not interested in your personal emails.
11 Who arranged the meeting point?
12 A. Uh, it was a negotiation thing kind of.

13 What's-closer-to-you, what's-closer-to-me type of deal.
14 It was mutual.
15 Q. Okay.
16 So it was a mutual --
17 A. Correct.
18 Q. You guys came to a mutual spot?
19 A. Yeah.
20 Q. Okay.
21 And how long did it take for, uh, for you two
22 to come up with the meeting. A couple hours, a few
23 minutes, a day or two?
24 A. Uh, I have to refer to my report.
25 Q. Okay.

727 821-3320
1 A. I don't recall exactly how long it took for

2 us to negotiate. If I were to estimate, I'd say
3 probably a couple of hours.
4 Q. Okay.
5 What phone number is connected to that Google
6 Voice account?
7 A. (727) 209-7755.
8 Q. And that's a number produced by Google?
9 A. Yes.
10 Q. You didn't make it up yourself? They --
11 A. They give you a pool of numbers and you just
12 click one.
13 Q. Okay.
14 Now, you and I have spoken a couple of times
15 since the arrest. Is that the same number that I used?
16 A. Yes.
17 Q. Okay.
18 Is that number earmarked for just this
19 particular case or is it --
20 A. It's just for work purposes.
21 Q. Well, I understand. But I'm sure that you
22 have more than one case going --
23 A. Yeah, I use this number on other cases.
24 Q. On other cases. Okay.
25 Okay. And how did you get to the meeting

727 821-3320
1 point?
2 A. Drove in a car.
3 Q. What kind of car?
4 A. Uh, like the make and model of the car?

5 Q. Well, let me ask you this. Is it a personal
6 vehicle or a vehicle --
7 A. No, it's a work vehicle.

8 Q. Okay.
9 Well, obviously, it doesn't have a sheriff's

10 license plate on the back.
11 A. Correct. It's an unmarked vehicle.
12 Q. Okay.
13 And by unmarked, there's absolutely nothing
14 on this vehicle that would indicate that it's owned or
15 operated by the police?
16 A. Correct.
17 Q. No computers inside?
18 A. Correct.
19 Q. Okay.
20 And when you drove there, where did you start
21 from?
22 A. From our -- my office.
23 Q. Okay.
24 Is that the one on Ulmerton Road?
25 A. No.

727 821-3320
1 Q. Okay.
2 Where's your office?
3 A. You will have to certify that.
4 Q. So you drove from your office to the meeting

5 place. How long did you take, did that take?
6 A. Certify that.
7 Q. Okay.
8 Now, when the exchange happened you gave
9 money and you got back pills?

10 A. Yes.
11 Q. Okay.
12 Did you do anything, any testing on site

13 before the two of you parted ways to determine whether
14 or not what you were receiving were indeed what you
15 wanted to buy?
16 A. No.
17 Q. Okay.
18 Did you count them?
19 A. Yes.
20 Q. Okay.
21 And at any point during this first buy did
22 you make it look like you were ingesting or taking the
23 controlled substance?
24 A. No.
25 Q. Was there surveillance on this buy?

727 821-3320
1 A. No. I had backup. There are people there

2 for my protection.
3 Q. Right.
4 A. But not like to pick up surveillance on him,

5 no.
6 Q. No video surveillance?
7 A. No.
8 Q. So there's no video surveillance of this
9 particular transaction?
10 A. Correct.
11 Q. And there's no still photographs of this
12 particular transaction?
13 A. No.
14 Q. Okay.
15 And there's no audio from a bug or a wire or
16 anything of this transaction?

17 A. There is audio of the transaction.
18 Q. Okay.
19 Was this on something that you were wearing?
20 A. Certify that.
21 Q. Do you know if the audio from this
22 transaction has been logged into evidence?
23 A. It should be, yes.
24 Q. Okay.
25 Do you know if that audio has been altered in

727 821-3320
1 any way?
2 A. It should not be altered.
3 Q. Do you have any handwritten notes from this
4 buy?
5 A. No.
6 Q. Okay.
7 So after the buy you go back to your office

8 and put in what happened?
9 A. You mean like --

10 Q. Right, type it in --
11 A. Correct.
12 Q. Because you don't do really a lot of

13 handwritten notes?
14 A. Correct.
15 Q. Okay.
16 Now after -- after the two of you parted

17 ways, uh, you drove away in your unmarked car, correct?
18 A. Yes.
19 Q. Okay.
20 Did you perform any tests yourself on the
21 pills to see if they were indeed what you ordered, what
22 you requested?
23 A. No.
24 Q. Okay.
25 So what did you do with them after you two

727 821-3320
1 broke -- separated?
2 A. What did I do with the pills?
3 Q. Yeah.
4 A. Put them into evidence.

5 Q. Okay.
6 Now, did you put them into an evidence bag
7 on -- like right away or did you wait until you got

8 back to your office or to the evidence room?
9 A. No, entered it into the evidence room.

10 Q. Okay.
11 So the evidence room gave you the bag to put
12 it in and the tag to tag it?

13 A. Yes.
14 Q. Okay.
15 You didn't have it in the car with you --
16 A. No.
17 Q. -- or anything like that?
18 So is this evidence room at your office or is
19 this the standard evidence room for the Sheriff's
20 Department?
21 A. The Sheriff's Department has multiple
22 different evidence rooms at different locations that I
23 use.
24 Q. Okay.
25 Do you know how long it took you -- so from

727 821-3320
1 the time you left the buy point until you got it in
2 evidence, the evidence room, the pills were where,
3 sitting on the -- in your pocket or sitting --
4 A. In my pocket.
5 Q. In your pocket. Okay.
6 So how long were they in your pocket for?
7 A. Certify that.
8 Q. Did you put them in the bag yourself and fill
9 out the tag?

10 A. Yes.
11 Q. Okay.
12 What information goes on the tag?

13 A. The -- you want me to list you all the
14 different -- like --
15 Q. Well, how big is the tag? About six inches?
16 A. Five or six inches.

17 Q. Okay.
18 Does it -- do you put the name of the
19 individual that you're investigating?
20 A. Sometimes.
21 Q. Okay.
22 In this particular case do you know if you
23 put down the suspect Wesley Townsend on the tag?
24 A. I don't recall exactly what name, but, uh, it
25 should -- I mean you can pull up the evidence bag if

727 821-3320
1 you want. You can check it out of evidence to see.

2 Q. Well, I'm going to go. But before I go and
3 look at it I want to find out what you remember.
4 A. Okay.
5 It should say Wesley Townsend on it.
6 Q. Okay.
7 You don't specifically remember writing that

8 at the time?
9 A. No. But I don't remember -- let me see.

10 No, I don't recall if I wrote his name on it
11 or not. It's not required. The only required
12 information is the case number that it goes under.

13 Q. Okay.
14 And the case number on this particular case
15 is the one that exists on the top of the reports?
16 A. Yes.
17 Q. SO 17-10574?
18 A. Yes.
19 Q. Has the date that you acquired the evidence?
20 A. Yes.
21 Q. Does it have a specific time that you
22 acquired the evidence?
23 A. No.
24 Q. So you don't write down what time you got it?
25 A. No.

727 821-3320
1 Q. Does it have the date and time that it was

2 logged into evidence?
3 A. It has the date.
4 Q. It has the date.

5 Do you know if there's a log book that says
6 date and time that the evidence came into --
7 A. I'm not aware of a log book that says that.

8 Q. Okay.
9 You're not aware -- there might be one but

10 that would be something to ask somebody from the
11 evidence room?
12 A. Yeah. You would have to ask those people.

13 Q. Okay.
14 You indicate in your report that after the
15 first buy you verified through use of picture that the
16 person that you met with was Wesley Townsend?

17 A. Yes.
18 Q. Where did you obtain that picture from?
19 A. Let me check my report. It was the DOC.
20 Q. Department of Corrections?
21 A. Yes.
22 Q. Did you ever run his information through the
23 data system?
24 A. Yes.
25 Q. Did you run it by name?

727 821-3320
1 A. I don't recall if I ran a name or social.

2 Q. Okay.
3 Did you run the tag of the car that he was in
4 or did somebody run the tag?

5 A. Yes.
6 Q. Is that something you did or something
7 someone else did?

8 A. Something I did.
9 Q. Okay.
10 And you used your data log-on for that?
11 A. Yes.
12 Q. Now, as far as the testing, forensic testing,

13 do you order that items be tested?
14 A. Yes.
15 Q. Okay.
16 And did you order that the pills be tested

17 immediately?
18 A. Immediately? I mean we don't control the
19 time frame that the lab does it. We just submit it and
20 ask for it --
21 Q. Okay.
22 A. -- and they tell us when it's done.
23 Q. What I mean by that is did you put in a
24 request for them to be tested?
25 A. Yes.

727 821-3320
1 Q. At the time that you logged them into

2 evidence --
3 A. Yes.
4 Q. -- or around this time?

5 A. Yes.
6 Q. Okay.
7 And did you request fingerprints also?

8 A. On pills? No.
9 Q. How about on the bag that they were in?

10 A. Anytime there's a bag or a container, I
11 always request latents.
12 Q. Okay.
13 So that's a standard practice of yours or is
14 it a standard --
15 A. It's a practice of me.
16 Q. Okay.
17 Is there a requirement to do that, department
18 policy-wise?
19 A. Not that I'm aware of.
20 Q. Okay.
21 Now, when you receive -- after the deal was
22 done and you looked at it, did you feel that you had
23 received the pills you had requested?
24 A. Yes.
25 Q. Okay.

727 821-3320
1 And at that time you could have arrested the

2 individual who gave them to you, correct?
3 A. Uh, no. I mean -- technically yes, for PC.
4 However, my standard practice, if I were in patrol, or

5 in that situation I would wait for lab results to
6 confirm that it was the actual drug.
7 Q. Okay.
8 Because you didn't arrest him after the first
9 buy.
10 A. Correct.
11 Q. And you didn't arrest him when you got the
12 lab results back as well.

13 A. Correct.
14 Q. Okay. Why?
15 A. I believe he had the ability to do more than
16 that after I met him.

17 Q. Okay.
18 So you were okay with -- if indeed he was a
19 drug dealer, you were okay with his continuing his drug
20 dealing activities, even though you could have arrested
21 him on the spot for dealing a substantial amount of
22 pills?
23 A. I would not consider ten pills to be
24 substantial.
25 Q. Okay.

727 821-3320
1 But it was illegal?

2 A. Correct.
3 Q. Okay.
4 But not illegal enough for you to arrest him?

5 MR. JACKSON: I'm going to object to the
6 form of the question. You can answer.
7 BY MR. DeCAILLY:
8 Q. You can answer.
9 A. There's hundreds of things I see illegal

10 every day but I'm not going to arrest people for.
11 Q. Does that include the sale of, the illegal
12 sale of ten pills?

13 MR. JACKSON: And, again, I'm going to
14 object to relevance, but you can answer.
15 THE DEPONENT: Can you say your question
16 one more time?

17 BY MR. DeCAILLY:
18 Q. You said you see hundreds of illegal things a
19 day and you look the other way, like jay-walking and
20 such.
21 Do you include the sale of prescription
22 pills?
23 A. Certain things that I don't arrest them for.
24 Q. Okay.
25 So the fact that you didn't arrest him on

727 821-3320
1 that day or the day after or the day after, uh, was
2 based on your own personal policy?
3 A. Uh --
4 MR. JACKSON: Again, I'm going to object to

5 relevancy, but you can answer.
6 THE DEPONENT: Do I have to answer? I'm
7 not sure I understand what you're asking.

8 BY MR. DeCAILLY:
9 Q. What I'm asking is you said that -- that you

10 felt -- I asked you if you arrested him. You said no
11 and you felt that he could do more. Okay?
12 A. Mm-hmm.
13 Q. And by doing more I'm gathering he would do
14 more drug dealing.
15 A. I believe he was a drug dealer that
16 customarily sold more than just ten pills.

17 Q. Okay.
18 And where did you form that belief from?
19 A. From my meeting with him.
20 Q. Okay.
21 But had you arrested him for ten pills, that
22 would have been a felony, correct?
23 A. Yes.
24 Q. Okay.
25 But you wanted to arrest him with a quantity

727 821-3320
1 higher than ten pills?

2 A. Not necessarily.
3 I believe -- if you arrest somebody after
4 dealing drugs one time, it doesn't show a pattern. It

5 could just be -- maybe they just need money that day.
6 However, in my experience drug dealers show a continued
7 behavior.
8 Q. Okay.
9 So your experience told you after not

10 arresting him after the first buy, he was going to go
11 out and sell it to somebody else?
12 A. Sell what?
13 Q. Drugs. Pills.
14 A. I would assume so. He was selling before
15 then. I don't see why he would stop afterwards.
16 Q. Okay.
17 So you knew he selling them beforehand
18 according to your sources that gave you the
19 information, correct?
20 A. Yes.
21 Q. Okay.
22 So you knew at the time this wasn't a case
23 where somebody was doing one sale of maybe their own
24 prescription because they needed money?
25 A. Well, I can't know for sure. That's the only

727 821-3320
1 reason of doing deals, is to obtain evidence.

2 Q. Okay.
3 Evidence for later to charge somebody?
4 A. Correct.
5 Q. All right.
6 I want to go over the remaining six buys.
7 Okay. There were seven in total based upon my count of

8 the information.
9 Did you -- at any of these other buys did you

10 contact the suspect on your own or did somebody help
11 facilitate those other buys?
12 A. I contacted him.
13 Q. Okay.
14 And were those contacts like the first one, a
15 combination of text and voice?
16 A. Uh, I would have to look at each specific one

17 to tell you what each one was.
18 Q. Okay.
19 Because it doesn't really say in the police
20 report I have. Is it quite possible that you have a
21 police report that's different than mine?
22 A. It shouldn't be.
23 Q. Okay.
24 Why don't you take a look and see if --
25 because I'm trying to gather how much text messages

727 821-3320
1 there should be out there that should be in evidence.

2 A. Okay.
3 Q. So go ahead and take your time and take a
4 look.
5 A. You want me to go over each one?
6 Q. Yeah.
7 A. Okay.
8 The second deal was initially started via
9 text.
10 Q. Okay.
11 A. Let me check the phone, too.
12 The third deal was initiated via text.

13 The fourth deal was initiated via text.
14 The fifth deal was initiated via text.
15 The sixth deal was like a combination at
16 least.
17 The majority of the deals are actually going
18 to have phone conversation as well.
19 Q. Right.
20 A. And once it got closer to the time of the
21 deal. I'm just talking about initiating it right now.
22 Q. Right.
23 A. The seventh deal was initiated via text.
24 And the eight deal, it looks like it was a
25 combination of as well.

727 821-3320
1 Q. Okay.
2 For each of those deals did you request a
3 specific quantity and type of drug?
4 A. Uh, as far as quantities, sometimes the deals

5 are like, you know, based on how much can I get for
6 this much money. Not specifically like I want 2.6
7 grams.
8 Q. Right.
9 A. Sometimes it's like, hey, I want a hundred

10 dollars worth or something like that.
11 Q. Okay.
12 A. But the type of drug, yes. I would normally

13 request the type of drug I want.
14 Q. While you were looking, I was just looking
15 back at something. When was the first deal? I want to
16 verify some information?

17 A. Back in January I would say.
18 Q. January 11th?
19 A. Uh, yes, January 11.
20 Q. You do realize that he's charged with
21 trafficking out of those ten pills?
22 A. He shouldn't be. Ten oxycodone is not a
23 trafficking amount.
24 Q. Oh, I'm sorry. It was the 3rd day of
25 February that was the trafficking case. Hydromorphone.

727 821-3320
1 A. Yes, hydromorphone. That should be a

2 trafficking case.
3 Q. Okay.
4 On that particular deal did you request this

5 particular type of drug?
6 A. Yes.
7 Q. And what was the name, the terminology you

8 used to --
9 A. The street slang name --

10 Q. Yeah.
11 A. -- that I used? Uh, they commonly refer to
12 it as Dees, DVDs, Dilaudids. There's a bunch of

13 different names that are interchangeable.
14 Q. Okay.
15 And on that particular day did you request a
16 certain amount or a certain amount of monies worth?

17 A. A certain amount.
18 Q. Okay.
19 So you specifically asked for a trafficking
20 quantity?
21 A. Yes.
22 Q. Okay.
23 Now, that was what, the third deal?
24 A. Yes.
25 Q. Okay.

727 821-3320
1 In that particular case, that was three out

2 the eight, correct?
3 A. Yes.
4 Q. Okay.
5 And you were shooting for a trafficking
6 amount when you requested --
7 A. Yes.
8 Q. -- those pills? Okay.
9 And did you arrest him after that?

10 A. No.
11 Q. Okay. For the same reasons that we
12 previously discussed?
13 A. No.
14 Q. Okay.
15 Well, why didn't you arrest him this time for
16 that?
17 A. Normally any case that involves a CI
18 transaction, I never make an arrest for at least six
19 months.
20 Q. And is that a personal policy --
21 A. Yes.
22 Q. -- or is that a -- is that a written policy
23 in any of your training materials?
24 A. No.
25 Q. Is this a written policy of the Pinellas

727 821-3320
1 County Sheriff?
2 A. No.
3 Q. Is that a written policy from the HIDTA task
4 force?
5 A. No.
6 Q. So for six months you do deals with knowing
7 people that you claim are known drug dealers, you buy
8 drugs from them, you test the drugs. And regardless of
9 whether or not they're what you -- whether or not

10 they're illegal substances, you just let them keep
11 doing it for six months?
12 A. Correct. For the protection of any

13 confidential informant that may or may not be working
14 with us.
15 Q. So at that time you're more concerned about
16 your confidential informant than you are of the general

17 public?
18 MR. JACKSON: I'm going to object to
19 relevance, but you can answer.
20 A. No. I'm concerned with everybody.
21 BY MR. DeCAILLY:
22 Q. Do you consider not arresting somebody for a
23 crime that you say occurred in your presence is
24 protecting and serving?
25 MR. JACKSON: Objection. Relevance.

727 821-3320
1 A. Yeah, I'm not going to answer that.

2 BY MR. DeCAILLY:
3 Q. You're not going to answer that? Is there a
4 basis of -- are you certifying it? Is it

5 attorney-client privilege?
6 A. I'm not certifying it.
7 Q. Okay.
8 And these other buys that took place, did
9 they occur in basically the same time --the nature

10 before where you just sort of agreed on a meeting
11 place?
12 A. Yes.
13 Q. Okay.
14 And a time?
15 A. Which specific buy are we talking about now?
16 Q. I'm just lumping the other six in together.

17 I mean were there any different where you didn't agree
18 on a time?
19 A. Uh, the fourth deal and thereon he suggested
20 a meeting place.
21 Q. Okay.
22 Were there any -- for the other deals, were
23 there any other -- were there electronic surveillance,
24 video-type surveillance?
25 A. Electronic -- for the fourth deal he

727 821-3320
1 suggested the meeting place until the eight deal when

2 he was arrested.
3 Q. Right.
4 And during those deals -- I'm going just from

5 deal two to deal eight, was there any electronic
6 surveillance of a video nature?
7 A. No.
8 Q. Was there audio of all those deals?
9 A. Yes.
10 Q. Were there any still photographs from any of
11 those deals?
12 A. Not that I'm aware of, no.

13 Q. You didn't take any?
14 A. No, I didn't take any.
15 Q. And if somebody did take pictures, from your
16 backup or anybody else there, uh, you would know about

17 it?
18 A. I believe I would know.
19 Q. Okay.
20 A. Any pictures that we took are going to be
21 related to search warrants --
22 Q. Okay.
23 A. -- which was served on the residence.
24 Q. All right.
25 And when you gathered for the deals two

727 821-3320
1 through eight, when you took in -- when the deal was

2 finished and you separated, did you handle each and
3 every one of those the same as far as taking the
4 evidence, the pills or the substance to the evidence

5 room and logging it in?
6 A. Yes.
7 Q. Okay.
8 For all of them did you go straight to the
9 evidence room to log it in?

10 A. No. For the ones that are cocaine we do
11 presumptive testing.
12 Q. Okay.
13 So you did presumptive testing obviously
14 after you two split up?
15 A. Yes.
16 Q. Okay.
17 And then after that would you take it to
18 evidence?
19 A. Yes.
20 Q. The presumptive testing, was that done at
21 your office or in the car?
22 A. No, at the evidence room.
23 Q. At the evidence room. So before you logged
24 it in you did a test?
25 A. Yes.

727 821-3320
1 Q. And are those tests also logged in, the

2 presumptive test, logged in with the substance?
3 A. No. Those are toxic materials and when
4 they're tested, we throw those out.

5 Q. You just throw them out immediately?
6 A. (Nodding.)
7 Q. Okay.
8 And on all of those cases, on the other buys
9 did you order the testing of the -- the forensics

10 testing on fingerprints and substance around the same
11 time that you logged them in?
12 A. Yes.
13 Q. Okay.
14 Now, at the time that the -- during this -- I
15 believe it was a six-month period -- started in January
16 and ended in May, would that be -- so about five or six

17 months, correct?
18 A. Are you asking me a question?
19 Q. Yeah.
20 I just verifying. This investigation started
21 in January and ended on arrest I believe in May?
22 A. Yes.
23 Q. Okay.
24 Did you have knowledge of where the suspect
25 in this case, where he was getting the drugs to sell to

727 821-3320
1 you?
2 A. No.
3 Q. Okay.
4 Do you know his supplier?

5 A. No.
6 Q. You didn't have any working relationship with
7 the supplier?
8 A. I didn't have a working relationship --
9 Q. I'm just making sure.

10 Do you know if anybody else in the department
11 had a working relationship with the person selling the
12 drugs to the suspect in this case?

13 A. They may have but I don't know who that
14 person is so I can't tell you whether they had a
15 relationship with him or not.
16 Q. Okay.
17 Where did you get the buy money for this?
18 A. My department.
19 Q. Okay.
20 And is that a process of requesting it in
21 writing and then it's approved and then they give you
22 the money?
23 A. Yes.
24 Q. Okay.
25 And do you copy the money or write down the

727 821-3320
1 numbers, the serial numbers involved --

2 A. No.
3 Q. -- for each buy?
4 A. No.
5 Q. Okay.
6 So you use buy money but you can't trace back
7 to a particular deal?
8 A. Say that again.
9 Q. So if you were to, let's say, buy drugs from

10 somebody and you use buy money, and then turn around
11 and twenty minutes later arrest them, okay, you would
12 have no way of telling whether the money that they had

13 in their pocket was the money that you just gave them
14 or not?
15 A. We don't really do that. We don't arrest
16 them twenty minutes later.

17 Q. I understand. But if you did, you wouldn't
18 be able to identify the money as the money you just
19 gave them, correct?
20 A. Correct.
21 Q. Owner than selling drugs to you in this
22 particular case, the suspect in this case, do you have
23 any evidence of any particular -- other people who he
24 sold drugs to?
25 A. No.

727 821-3320
1 Q. So you have no firsthand knowledge of whether

2 or not he had other customers other than you?
3 A. It would just be my assumptions.
4 Q. Okay.
5 So the question is -- the answer is no, you
6 don't have any --
7 A. I don't have any evidence, no.

8 Q. Okay.
9 I want you to take a look at in my binder,

10 which should be your report --
11 A. Okay.
12 Q. -- except they redacted it, a lot of it,

13 okay? But I have numbers, Bates numbers at the bottom
14 right. They start with WLT and then there's a number
15 there.
16 Do you see that at the bottom?

17 A. Yes.
18 Q. Okay. Why don't you go to page number 15.
19 A. Okay.
20 Q. Is that the picture you used to identify the
21 person that you claim was the seller of the drugs you
22 bought?
23 A. Yes.
24 Q. Okay.
25 And do you know how old that picture is?

727 821-3320
1 A. Uh, I do. I can look at my report. I

2 believe it has the date of his release. It actually
3 says it there.
4 Q. Has this information -- I understand that.

5 But do you know if that includes the picture?
6 A. I would have to check in my report. I wrote
7 what date I believe.

8 Q. Okay.
9 Go ahead and check.

10 A. I have that this picture was dated 10-17 of
11 2016.
12 Q. Okay.
13 That's what you have?
14 A. Yes.
15 Q. And did you gather that from the notation on
16 the document itself?

17 A. Yes.
18 Q. Okay.
19 All right, I want you to flip over to page
20 21. I'm sorry, 22. At the top it says "Subject two."
21 A. Mm-hmm.
22 Q. Do you see that?
23 A. Yes.
24 Q. And in my version everything is blanked out.
25 And there's a subject three, Kayla Marie Pratt

727 821-3320
1 (phonetic).
2 A. Yes.
3 Q. Okay.
4 Are these people who were present at the time

5 of any particular deal?
6 A. Yes. Kayla Marie Pratt (phonetic) was
7 present at the deal.

8 Q. Okay.
9 And subject two, was he or she present at the

10 deal?
11 A. No.
12 Q. Okay.
13 And Wesley Lee Townsend was subject one,
14 suspect one, correct?
15 A. What page are you looking at?
16 Q. Twenty-one. Do you see at the top of 21?

17 A. Yes.
18 Q. Okay.
19 Now, I want you to go back to number 22. Go
20 back to that page.
21 At the top it says "suspect two." Does it
22 also say "subject number two"?
23 A. At the top of 22?
24 Q. Right there.
25 A. What's your question?

727 821-3320
1 Q. See where it says "subject two"?

2 A. Mm-hmm.
3 Q. And then there's a blank?
4 A. Mm-hmm.
5 Q. Okay.
6 What's supposed to be there? Is that a
7 title? Is that a name?

8 A. Certify that.
9 Q. Okay.
10 And then it says number one dash -- and then
11 there's a couple other things. Is that also -- is that
12 a reference to another, another investigation?

13 A. That's not a reference to another
14 investigation, no.
15 Q. Okay.
16 Well, what's number one? What's after that?

17 A. Certify that.
18 Q. Okay.
19 I want you go to 24. Obviously, the, uh, the
20 first paragraph of the narrative, I believe the
21 blackouts are identifications of particular individuals
22 or groups of individuals.
23 A. That's a possibility.
24 Q. Okay.
25 What I want to talk about is, uh, the next

727 821-3320
1 paragraph. It says, "At approximately 1300 hours," and

2 then that's all blacked out.
3 A. Mm-hmm.
4 Q. Okay.
5 What I want to know is -- because I know
6 you're not going to tell what it says because they've
7 gone to great lengths to make sure that I don't see

8 it -- is that further identification of the source of
9 your information?
10 A. Further indication?
11 Q. Right. Are people's names in that blacked
12 out?
13 A. No.
14 Q. Okay.
15 Do you know what that describes?
16 A. Yes.
17 Q. Okay. What does it describe?
18 A. Certify that.
19 Q. And then down at the bottom of the page it
20 says -- I believe it says "I" and then it's blacked
21 out.
22 A. Mm-hmm.
23 Q. Is that -- is that what I'm seeing?
24 A. Mm-hmm.
25 Q. Okay.

727 821-3320
1 Now, I'm assuming "I" -- because you wrote

2 this report, correct --
3 A. Mm-hmm.
4 Q. Is that a yes?
5 A. Yes.
6 Q. In fact, your name is there that's blacked
7 out?
8 A. No.
9 Q. Okay.
10 So who else wrote this report? Who is the
11 "I"? If you wrote the report, I'm assuming "I" is you.
12 You wrote the report.

13 A. Correct.
14 Q. But you're telling me that -- that -- that
15 that -- where it says "I" and then a name, it's not
16 you?
17 A. You're making an improper assumption that
18 that's a name.
19 Q. Okay.
20 Uh, so that's not a person's name?
21 A. Correct.
22 Q. Okay. Can you tell me what it is?
23 A. Certify that.
24 Q. Well, is it -- does it include -- does it
25 make a reference to "I recorded," have a recording of

727 821-3320
1 the transaction?
2 A. Certify that.
3 Q. And it talks about a CD was placed into
4 evidence at the narcotics division evidence locker

5 number nine. Do you see that?
6 A. Mm-hmm.
7 Q. What's on the CD?

8 A. Uh, the audio.
9 Q. Just the audio?

10 A. Mm-hmm.
11 Q. Is that yes?
12 A. Yes. Sorry.
13 Q. Okay.
14 So the line before where all the blackouts
15 are, it says -- it says, "the drugs and" blank "CD were
16 placed into evidence."

17 What's before "CD"?
18 A. Certify that.
19 Q. Okay.
20 And then down further on the next page --
21 A. You're talking 25, correct?
22 Q. Yes.
23 A. Okay.
24 Q. About midway down there's a -- it says "the"
25 blank "picture used also attached to this report

727 821-3320
1 electronically in ACISS."
2 A. Mm-hmm.
3 Q. Okay.
4 What is the blank?

5 A. Certify that.
6 Q. Okay.
7 So you put into evidence ten doses of

8 OxyContin, fifteen milligrams each, and blank CD?
9 A. I put in ten doses of oxycodone, not

10 OxyContin.
11 Q. Okay.
12 Oxycodone, fifteen milligrams each and blank

13 CD.
14 A. Correct.
15 Q. That CD is in evidence now?
16 A. Correct.
17 Q. But yet you won't tell me what kind of --
18 what the word is before "CD"?
19 A. Correct.
20 Q. Okay.
21 Go to page 27. Down at the bottom where it
22 says "subject two," do you see the blackouts?
23 A. Yes.
24 Q. Is that the same information that we
25 previously discussed that you will not disclose?

727 821-3320
1 A. Yes.
2 Q. Okay.
3 Does subject two, blank, one, number one,
4 blank, remain constant throughout the report?

5 A. It should, yes.
6 Q. So once they -- because, you know, the
7 reports are supplements. This is, like I said,

8 supplement two.
9 A. Mm-hmm.
10 Q. So it's anchored to the main report, correct?
11 A. Mm-hmm.
12 Q. So any label that you gave anybody, any

13 person in the initial report carries through the entire
14 report and the supplement?
15 A. Uh, no, I don't believe that's how the
16 database works. I believe that you have to label them

17 in each supplement.
18 Q. Okay.
19 A. However, you can't label them the same in
20 each supplement.
21 Q. Okay.
22 So it doesn't automatically do it? You have
23 to give it a label?
24 A. Correct. You have to physically do it.
25 Q. Okay.

727 821-3320
1 Go to page 31. In this particular case, it

2 says "subject one, number one," blank, and then it's
3 blacked out.
4 So earlier on Wesley Townsend was subject

5 one, suspect one.
6 A. Mm-hmm.
7 Q. Is there a different subject one now?

8 A. Uh, let me see if I can help you out.
9 The way that our database system works is

10 just however you type in your report, whatever person
11 you put in chronologically, like if I were to put
12 Wesley in first, he would automatically be subject one.

13 If I were to put Kayla (phonetic) first, she would be
14 subject one. Whoever I just physically type in first
15 is how labels it.
16 Q. Okay.
17 So it's not uniform throughout?
18 A. Correct.
19 Q. Okay.
20 A. That's what I meant as far as each supplement
21 -- you have to do it for each supplement. When you put
22 in each person, it's going to give that person a label
23 in that one.
24 Q. Right. Okay.
25 A. So, correct, Wesley is not subject one

727 821-3320
1 throughout the entire report. It's just however I

2 added him to that report supplement.
3 Q. Okay.
4 Now, let's just go to page 35. Uh, at the

5 top there you have at approximately 2200 hours a blank,
6 okay, and you see all of that.
7 Now, that's similar to what we discussed

8 earlier.
9 A. Mm-hmm.
10 Q. Okay. Is that the same information as we
11 discussed earlier that you won't disclose?
12 A. Yes.
13 Q. Do you need to take a break? Do you need
14 some water or anything?
15 A. No.
16 Q. Okay.
17 And then go to page 60. Do you see that big
18 blackout there where it says "At approximately 1800 a"
19 blank?
20 A. Mm-hmm.
21 Q. Is that substantially the same type of
22 information as the other blackouts that you won't
23 disclose?
24 A. Yes.
25 Q. Okay.

727 821-3320
1 What I'm trying to do is avoid having to go

2 through the same line for every blank, blanked-out
3 area.
4 Now, all of these supplements indicate that

5 you were the author of them.
6 A. Correct.
7 Q. Are you aware of any other officer involved

8 in this case who wrote a supplement or a report
9 themselves?
10 A. There should be, yes.
11 Q. Okay.
12 And if they wrote something, would there --

13 it would be the same heading? It would be case
14 number -- supplement, case number, and then a slash.
15 Would their supplement just be part of the supplements
16 in this particular case?

17 A. Yes. Theirs would be in between my reports.
18 Like if they did a report, it would be -- I would be
19 17, they would be 18, I would 19 and so on and so
20 forth.
21 Q. Okay.
22 So I have to go back and look carefully at
23 every supplement and see who the actual author was?
24 A. Correct.
25 Q. Okay.

727 821-3320
1 So I just want to sort of make it clear.

2 There is no video surveillance of any type in this
3 particular case?
4 A. Correct.
5 Q. There is some audio?
6 A. Correct.
7 Q. Were there any phone taps involved in this

8 case?
9 A. No.
10 Q. And you indicated search warrants. You
11 obtained search warrants?
12 A. Let me ask you for further clarification of

13 the phone taps. When you say phone taps, do you mean
14 like where we listen to their phone calls?
15 Q. Correct.
16 A. No.
17 Q. Were there any phone taps where you just knew
18 who was calling in and out?
19 A. Uh, who was calling out -- yes.
20 Q. Okay.
21 And did you get a warrant for those taps or
22 that surveillance?
23 A. Yes.
24 Q. Okay.
25 A. I, uh -- let me see. When we -- I'm not a

727 821-3320
1 technical person so you've got to give me a second to

2 try and figure out how it works or how best I can
3 explain it.
4 When we were getting close to arresting him,

5 uh, we -- I don't know if it was actually a subpoena or
6 a warrant, how -- which one it was that the state
7 attorney's did, but they did the paperwork. I don't

8 how what it's called. I think it's pen register, is
9 what it's called.

10 Q. Okay.
11 A. Are you familiar with those?
12 Q. Pen register?
13 A. Pen register.
14 Q. Where you can see calls going in and calls
15 going out?
16 A. Yes. And it has his location.

17 Q. And it has his location as well.
18 A. Mm-hmm.
19 Q. So you didn't particularly fill out any
20 warrant or subpoena for that?
21 A. No.
22 Q. Okay.
23 And do you know if the -- we don't know if
24 it's a warrant or subpoena so I'll refer to it as --
25 A. Yeah. I would have to go back and look at

727 821-3320
1 the --
2 Q. Do you know if that information is in
3 evidence?
4 A. Uh, it should be. I'd have to check with the

5 state attorney's office, like how they do their
6 paperwork, and our technical people. Because we have a
7 separate unit that does all that kind of technical

8 stuff. I'd have to check on that.
9 Q. Did you ever see the results of that?

10 A. What do you mean the results? Like the
11 printed papers?
12 Q. Right.
13 A. Uh, I think so.
14 Q. Okay.
15 So the information that was derived from this
16 warrant or subpoena was reduced down to paper? It's

17 not a recording? It's not a photograph or a video of
18 any type? It's -- the information is on a piece of
19 paper?
20 A. Like his phone calls?
21 Q. Right. From the pen register.
22 A. Mm-hmm.
23 Q. Okay.
24 It says that -- like shows location?
25 A. No, they have it on a computer.

727 821-3320
1 Q. They have it on a computer?

2 A. Yeah. Like, uh -- our technical people do
3 all that. To be honest, I'm not really sure how it
4 works, but they have a computer that does it.

5 Q. Okay.
6 And does that computer like draw maps and
7 stuff to show where they're at, where they were at?

8 A. I think so, yeah.
9 Q. Okay.
10 And you indicated that you did do warrants.
11 How many warrants did you apply for?
12 A. Two warrants, one for a search warrant and

13 one for an arrest warrant.
14 Q. The arrest warrant was for Wesley Townsend?
15 A. Mm-hmm.
16 Q. Is that a yes.
17 A. Yes.
18 Q. Okay.
19 And the search warrant, what was that to
20 search?
21 A. For the residence that he was staying at.
22 Q. Okay.
23 And what was the fruits of that search? Did
24 you find any drugs?
25 A. I don't think there was anything at the

727 821-3320
1 residence, no.
2 Q. Okay.
3 And were you present when that warrant was
4 executed?
5 A. No.
6 Q. Okay.
7 Do you know if there are any police reports

8 related to that warrant execution?
9 A. There should be, yes.

10 Q. Are you aware of any -- and other than the
11 phone, any other investigative subpoenas issued or you
12 utilized in this particular case?

13 A. No.
14 Q. Okay.
15 After -- before arrest did you give any
16 testimony before either a state attorney or a judge

17 regarding this case?
18 A. Yes.
19 Q. Okay.
20 And was it the prosecutor or was it the
21 judge?
22 A. The prosecutor.
23 Q. So did you go through like an invest type of
24 situation?
25 A. Yes.

727 821-3320
1 Q. Okay.
2 Did you come here to this building and --
3 A. Yes.
4 Q. -- sit down and talk with somebody and then

5 they issued the arrest warrant after that?
6 A. Yes.
7 Q. Okay.
8 And when you gave that information did they
9 swear you in? Were you under oath?

10 A. Yes.
11 Q. Okay.
12 Are there any internal guidelines -- and when

13 I say internal guidelines, I am talking about the
14 Pinellas County Sheriff's Department or the HIDTA Task
15 Force, okay -- that you are aware of, are there any
16 internal guidelines regarding hand-to-hand buy

17 operations?
18 A. Uh, yeah. Yes.
19 Q. There are? Sheriff's Department?
20 A. Yes.
21 Q. And HIDTA?
22 A. I'm not aware --
23 Q. You're not aware of that.
24 A. No.
25 Q. Okay.

727 821-3320
1 Are there guidelines regarding buy money?

2 A. Yes.
3 Q. Internal for Pinellas County Sheriff?
4 A. Yes.
5 Q. Okay.
6 And like I -- earlier I asked you about -- so
7 you haven't seen or you're not familiar with any

8 specific guidelines from the HIDTA Task Force?
9 A. No.
10 Q. Okay.
11 Did you -- from the informants, we'll just
12 call them the informants, it could be one or it could

13 be several -- were there any text messages regarding
14 this particular case?
15 A. Uh, there may have been the initial
16 communication.
17 Q. Okay.
18 And are those preserved?
19 A. They should be.
20 Q. Okay.
21 Are those also on the same Google --
22 A. Yes.
23 Q. -- Voice, or whatever it is, account?
24 A. Yes.
25 Q. And that account is still active?

727 821-3320
1 A. Yes.
2 Q. Okay.
3 Are there any current other cases that have
4 been charged? I'm not asking about ongoing

5 investigations, just that have been charged that have
6 derived from this particular group or individual of
7 informants?
8 A. You would have to ask Detective Livernois.
9 Q. Okay.
10 During these investigations, other than your
11 reports, do you keep detailed time records? The amount
12 of time you spend working on the case.

13 A. No.
14 Q. Do you have to keep any mileage logs
15 regarding the car that you use?
16 A. No.
17 Q. Is mileage tracked per day in any way?
18 A. No.
19 Q. When you need to fuel up that car that you
20 use for the buys, do you pay for it out of your own
21 pocket or do you --
22 A. No. We have an electronic key --
23 Q. Okay.
24 A. -- we use at the gas systems.
25 Q. At the station?

727 821-3320
1 A. Mm-hmm.
2 Q. Is that a yes?
3 A. Yes.
4 Q. Okay.
5 Are there any -- now I'm talking about the
6 Google Voice, but I'm talking your internal -- the
7 Sheriff's Department phone system. Are there any

8 voicemails that you received or left on the internal
9 system regarding this case?

10 A. No.
11 Q. Are there any voicemails that might have been
12 left with the State Attorney's office regarding this

13 case?
14 A. No.
15 Q. Are there any emails that you may have
16 written or received from anybody internal in the

17 Pinellas County Sheriff's Department or to and from the
18 state attorney's office regarding this case?
19 A. Well, the state attorney's office doesn't
20 have emails.
21 Q. Actually, they do but just don't tell us.
22 A. Not that we can communicate with them with.
23 As far as internal ones, there's probably --
24 what was your predicate, emails internal --
25 Q. Internal emails from you to another officer,

727 821-3320
1 to a supervisor, to one of these technical people or to

2 the evidence room regarding this case?
3 A. Uh, probably emails regarding the technical
4 people as far as whatever they --

5 Q. Handling of evidence or the electronic
6 evidence?
7 A. Yeah. They tell us like when stuff is

8 working or not.
9 Q. Okay.
10 Has -- since Wesley has been incarcerated
11 have you accessed any of his phone calls or visitation
12 recordings?
13 A. Yes.
14 Q. Okay.
15 Have you preserved them or turned them over
16 to the state attorney?

17 A. No. I haven't used them for anything.
18 Q. Okay.
19 And so you haven't pulled any from the system
20 and then called up a state attorney and said, "You got
21 to hear this"?
22 A. No.
23 Q. Okay.
24 Let me make sure I have everything.
25 Oh, let me ask you this. If, uh -- have you

727 821-3320
1 been involved in any investigations where instead of

2 being the buyer, you're the seller?
3 A. No.
4 Q. Okay.
5 Do you know of any such operations within the
6 Pinellas County Sheriff's Office?
7 A. No.
8 Q. Okay.
9 If you needed some drugs that you know -- if

10 you needed a substance of some sort to do some sort of
11 controlled sell, buy/sell --
12 A. Mm-hmm.
13 Q. -- is there a place or a procedure you can
14 use to get them from the evidence room or from a
15 particular stockpile they may have?
16 A. I've never done it, but I believe it exists.

17 I would have to research on how to do it.
18 Q. But you haven't been involved?
19 A. No.
20 Q. But such a procedure may exist?
21 A. Correct.
22 Q. And you're not aware of whether or not some
23 other detective within your -- within your building and
24 your unit -- I'll call it the unit -- uh, had supplied
25 the drugs involved in this case to whoever supplied

727 821-3320
1 them to Wesley?
2 A. Say that again. I'm sorry.
3 Q. Are you aware -- maybe I'll do it -- here you
4 have you buying and then you have a seller.

5 A. Mm-hmm.
6 Q. Obviously, the seller doesn't make oxycodone
7 himself. So the seller has to get it them from

8 somebody else?
9 A. Okay.
10 Q. Do you agree with that statement?
11 A. I mean I don't know he wasn't making them.
12 Lots of people have pill presses nowadays.

13 Q. Okay.
14 A. My assumption is he was not making them.
15 Q. But he had a bigger buyer -- or bigger seller
16 above him?
17 A. That was my assumption.
18 Q. Okay.
19 Are you aware of any internal operations or
20 investigations where this person here -- we'll call him
21 the big guy -- was getting drugs as part of an
22 operation from the Pinellas County Sheriff's Office?
23 A. No, I'm not aware of any operation like that.
24 Q. Okay.
25 I have nothing further.

727 821-3320
80
1 MR. JACKSON: I don't have any questions.

2 Thank you.
______________________________________
3 THE DEPOSITION CONCLUDED AT 2:24 P.M.
______________________________________
4
5
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

727 821-3320
81
1 CERTIFICATE OF OATH
2 STATE OF FLORIDA )
3 COUNTY OF PINELLAS )
4 I, the undersigned authority, certify that

DETECTIVE PHILIP PIONE personally appeared before me
5 and was sworn to give truthful answers.
6 WITNESS my hand and official seal this 16th

day of April, 2018.
7
8
9
10 _______________________________
Phyllis B. Pennington, RPR, CP,
11 Court Reporter,
Notary Public,
12 State of Florida at Large.
13
14 (Depo of Det. Philip Pione on 8-23-2017,

Style: State vs. Wesley Townsend,
15 Reporter: Phyllis B. Pennington)
16
17
18
19
20
21
22
23
24
25

727 821-3320
82
1
2 DEPONENT'S SIGNATURE PAGE
3 I, DETECTIVE PHILIP PIONE, hereby declare
4 under penalty of perjury that the foregoing is my

5 deposition under oath; that these are the questions
6 asked of me and my answers thereto; that I have read my
7 deposition and have made the necessary corrections,

8 additions, or changes to my answers that I deem
9 necessary.
10 DATED this day , 2018.
11
12
13 _____________________________
DETECTIVE PHILIP PIONE
14
15
16 * * * * * * * * * * * *
17
18
19
20
21

24
25

727 821-3320
83
1 REPORTER'S DEPOSITION CERTIFICATE

2
3 STATE OF FLORIDA )
4 COUNTY OF PINELLAS )
5 I, PHYLLIS B. PENNINGTON, Registered
Professional Reporter, certify that I was authorized to
6 and did stenographically report the deposition of
DETECTIVE PHILIP PIONE; that a review of the transcript
7 was requested; and that the transcript is a true and
complete record of my stenographic notes.
8
I further certify that I am not a relative,
9 employee, attorney or counsel of any of the parties,
nor am I a relative or employee of any of the parties'
10 attorney or counsel connected with the action, nor am I
financially interested in the action.
11
DATED this 16th day of April, 2018.
12
13
14 ________________________________
Phyllis B. Pennington, RPR, CP,
15 Court Reporter,
Notary Public,
16 State of Florida at Large.
17

20
21
22
23
24
25

727 821-3320
84
1 ERRATA PAGE
2 INSTRUCTIONS:
3 Please make note of any errors in transcription on this

page. Do not mark on original transcript itself. Sign
4 and date this sheet and "Deponent's Signature Page."
Thank you.
5
6 PAGE LINE CORRECTION
7 ____ ____ _______________________________

8 ____ ____ _______________________________
9 ____ ____ _______________________________

10 ____ ____ _______________________________
11 ____ ____ _______________________________
12 ____ ____ _______________________________

13 ____ ____ _______________________________
14 ____ ____ _______________________________
15 ____ ____ _______________________________
16 ____ ____ _______________________________

17 ____ ____ _______________________________
18 ____ ____ _______________________________
19 ____ ____ _______________________________
20 ____ ____ _______________________________
21 ____ ____ _______________________________
22 ____________ __________________________
23 DATE DETECTIVE PHILIP PIONE


727 821-3320
State of Florida vs Detective Philip Pione
Wesley Townsend August 23, 2017
14:14,15;15:7 76:12,18,19 bigger (2) 21,25;33:4,7;35:1;

A alley (1) audio (8) 79:15,15 37:15;40:9;43:10;
23:14 32:15,17,21,25; binder (1) 49:7;50:15;54:17;
ability (1) altered (2) 51:8;62:8,9;68:5 56:9 55:3,6,9,10;73:16;
40:15 32:25;33:2 author (2) bit (1) 74:1
able (3) always (2) 67:5,23 11:3 buy/sell (1)
8:4,6;55:18 23:13;39:11 automatically (3) Biz (1) 78:11
above (4) amount (9) 26:8;64:22;65:12 21:15 buyer (2)
8:22;9:5,14;79:16 25:21,22;40:21; avoid (1) B-I-Z (1) 78:2;79:15
absolutely (1) 46:23;47:16,16,17; 67:1 21:16 buying (1)
30:13 48:6;75:11 aware (14) blacked (5) 79:4
academy (2) anchored (1) 9:13;37:7,9;39:19; 60:2,11,20;61:6; buys (7)
4:24;5:5 64:10 51:12;67:7;72:10; 65:3 24:9;44:6,9,11;
accessed (1) anonymous (2) 73:15,22,23;78:22; blackout (1) 50:8;53:8;75:20
77:11 11:15,17 79:3,19,23 66:18
according (1) answered (1) away (2) blackouts (4) C
43:18 25:12 33:17;34:7 59:21;62:14;63:22;
account (10) apply (1) 66:22 call (7)
27:6,9,11,24;28:1, 71:11 B blank (12) 17:23;23:2,16;
2,4;29:6;74:23,25 approved (1) 59:3;62:15,25; 25:2;74:12;78:24;
ACISS (4) 54:21 bachelor's (2) 63:4,8,12;64:3,4; 79:20
18:15,16;20:5;63:1 approximately (3) 5:6,7 65:2;66:5,19;67:2 called (4)
acquired (2) 60:1;66:5,18 back (15) blanked (1) 18:13;69:8,9;77:20
36:19,22 Area (3) 4:19;16:21;18:25; 57:24 calling (4)
active (1) 8:12;19:8;67:3 30:10;31:9;33:7; blanked-out (1) 15:23;20:16;68:18,
74:25 around (3) 34:8;40:12;46:15,17; 67:2 19
activities (10) 39:4;53:10;55:10 55:6;58:19,20;67:22; bonds (1) calls (5)
8:19;9:17;14:7,8; arranged (2) 69:25 16:22 68:14;69:14,14;
16:15;20:9;23:4,5; 26:1;28:11 backup (2) book (3) 70:20;77:11
25:1;40:20 arrest (20) 32:1;51:16 8:4;37:5,7 came (9)
activity (1) 12:25;29:15;40:8, bag (6) both (2) 11:16;14:1;15:17;
27:5 11;41:4,10,23,25; 34:6,11;35:8,25; 26:2,3 19:6,15;21:11,11;
actual (2) 42:25;43:3;48:9,15, 39:9,10 bottom (4) 28:18;37:6
40:6;67:23 18;53:21;55:11,15; based (4) 56:13,16;60:19; can (23)
Actually (6) 71:13,14;72:15;73:5 12:6;42:2;44:7; 63:21 4:12,13;11:6,10;
22:2;23:21;45:17; arrested (7) 46:5 bought (1) 14:25;17:10;19:7;
57:2;69:5;76:21 15:15,16;40:1,20; bases (2) 56:22 35:25;36:1;41:6,8,14,
added (1) 42:10,21;51:2 13:9;17:24 Bow (1) 15;42:5;46:5;49:19;
66:2 arresting (3) basically (2) 21:15 57:1;61:22;65:8;
afterwards (1) 43:10;49:22;69:4 13:20;50:9 B-O-W (1) 69:2,14;76:22;78:13
43:15 arrests (2) basis (5) 21:16 car (9)
Again (6) 8:18;24:16 13:11;14:1;17:25; bowling (1) 30:2,3,4;33:17;
19:9,14;41:13; associates (1) 19:2;50:4 23:14 34:15;38:3;52:21;
42:4;55:8;79:2 5:5 Bates (1) Bowman (1) 75:15,19
agencies (1) assume (4) 56:13 10:16 career (1)
10:2 6:11;19:7,7;43:14 Bay (1) break (1) 5:22
agency (3) assuming (3) 19:8 66:13 carefully (1)
8:24;10:9,12 12:1;61:1,11 Beach (1) bring (1) 67:22
agency's (1) assumption (3) 5:1 8:5 carrier (4)
9:9 61:17;79:14,17 beforehand (1) broad (1) 21:17,17,18;22:8
agree (2) assumptions (1) 43:17 23:22 carries (1)
50:17;79:10 56:3 beginning (1) broke (1) 64:13
agreed (1) attached (1) 5:17 34:1 case (48)
50:10 62:25 behavior (1) bug (1) 9:20,21,22,24;10:7,
ahead (2) attend (1) 43:7 32:15 8,22;12:17;13:6;
45:3;57:9 14:22 belief (1) building (2) 14:14,15;15:16;
aid (1) Attorney (4) 42:18 73:2;78:23 16:16,20;24:5;25:13;
15:5 27:22;72:16;77:16, best (1) bunch (1) 27:5;29:19,22;35:22;
alias (1) 20 69:2 47:12 36:12,14,14;43:22;
18:4 attorney-client (1) beyond (1) business (1) 46:25;47:2;48:1,17;
aliases (2) 50:5 15:5 23:13 53:25;54:12;55:22,
18:17,19 Attorney's (6) big (3) buy (20) 22;65:1;67:8,13,14,
alleged (3) 11:22;69:7;70:5; 35:15;66:17;79:21 25:10;26:1;31:15, 16;68:3,8;72:12,17;
Min-U-Script® Kanabay Court Reporters - Serving the Tampa Bay Area (1) ability - case
727 821-3320
74:14;75:12;76:9,13, 10:25;52:10 54:25 40:19;42:15 directly (1)

18;77:2;78:25 collaboration (1) Corrections (1) dealers (2) 22:7
cases (5) 8:15 37:20 43:6;49:7 disclose (3)
12:25;29:23,24; combination (3) correctly (1) Dealing (8) 63:25;66:11,23
53:8;75:3 44:15;45:15,25 13:19 14:9;23:4,5;24:12; discussed (4)
CD (8) commonly (1) cost (1) 40:20,21;42:14;43:4 48:12;63:25;66:7,
62:3,7,15,17;63:8, 47:11 27:18 dealings (2) 11
13,15,18 communicate (1) count (2) 12:17,20 division (1)
cell (10) 76:22 31:18;44:7 deals (13) 62:4
15:22;16:3,6,7,8, communication (1) County (20) 23:8;24:6,6;44:1; DOC (1)
11,15;21:6,18,22 74:16 5:1,16,23,25;6:19; 45:17;46:2,4;49:6; 37:19
central (1) compensated (1) 8:20;9:25;10:17,20; 50:22;51:4,8,11,25 document (1)
8:12 17:11 17:5;18:18;23:9,21, DeCAILLY (8) 57:16
certain (5) comprised (1) 23;49:1;73:14;74:3; 4:10;27:22;28:3; dollars (1)
25:16;41:23;47:16, 18:17 76:17;78:6;79:22 41:7,17;42:8;49:21; 46:10
16,17 computer (4) couple (5) 50:2 done (4)
certificate (1) 70:25;71:1,4,6 4:17;28:22;29:3, Dees (1) 38:22;39:22;52:20;
7:14 computers (1) 14;59:11 47:12 78:16
certify (17) 30:17 courses (1) defendant (2) doses (2)
11:7,14;12:14; concerned (2) 6:24 14:14,14 63:7,9
13:2;14:10;22:23; 49:15,20 created (1) degree (1) down (9)
31:3,6;32:20;35:7; conducted (3) 14:13 5:7 35:23;36:24;54:25;
59:8,17;60:18;61:23; 20:9,13;25:1 crime (1) degrees (1) 60:19;62:20,24;
62:2,18;63:5 confidential (12) 49:23 5:6 63:21;70:16;73:4
certifying (2) 11:20,23,25;12:13, cross-check (1) delete (1) draw (1)
50:4,6 17;13:10;14:6,17; 17:25 26:14 71:6
changed (1) 16:19,23;49:13,16 current (1) department (14) Drove (4)
6:11 confirm (1) 75:3 16:3,8;17:6;18:18; 30:2,20;31:4;33:17
charge (5) 40:6 currently (2) 34:20,21;37:20; drug (18)
8:14;10:7,8;18:22; connected (3) 8:11;16:16 39:17;54:10,18; 6:20;7:8;8:10,12;
44:3 27:6,11;29:5 customarily (1) 73:14,19;76:7,17 23:8;24:6,6;40:6,19,
charged (3) connection (1) 42:16 department-issued (1) 19;42:14,15;43:6;
46:20;75:4,5 28:5 customers (1) 16:1 46:3,12,13;47:5;49:7
charges (1) consider (2) 56:2 Deponent (6) drugs (17)
16:22 40:23;49:22 4:1,2,6;28:1;41:15; 14:9;24:12;43:4,
check (8) considered (2) D 42:6 13;49:8,8;53:25;
19:13;36:1;37:19; 10:7;12:13 derived (2) 54:12;55:9,21,24;
45:11;57:6,9;70:4,8 constant (1) dash (1) 70:15;75:6 56:21;62:15;71:24;
chronologically (1) 64:4 59:10 describe (1) 78:9,25;79:21
65:11 contact (6) data (4) 60:17 duly (1)
CI (1) 15:22;17:19;23:20; 17:24,24;37:23; describes (1) 4:6
48:17 24:16;25:14;44:10 38:10 60:15 During (5)
claim (2) contacted (3) database (6) description (1) 7:25;31:21;51:4;
49:7;56:21 15:8;25:13;44:12 22:3;25:5,7,8; 19:13 53:14;75:10
clandestine (1) contacts (1) 64:16;65:9 destroy (1) DVDs (1)
7:7 44:14 date (8) 26:7 47:12
clarification (1) container (1) 5:22;36:19;37:1,3, detailed (1)
68:12 39:10 4,6;57:2,7 75:11 E
clarity (1) continued (1) dated (1) DETECTIVE (8)
4:12 43:6 57:10 4:5,12;6:6,7,15; earlier (4)
class (1) continuing (1) day (10) 17:2;75:8;78:23 65:4;66:8,11;74:6
9:16 40:19 28:23;41:10,19; determine (1) Early (1)
clear (2) control (2) 42:1,1,1;43:5;46:24; 31:13 7:13
7:23;68:1 24:9;38:18 47:15;75:17 developing (1) earmarked (1)
Clearwater (1) controlled (2) DEA (3) 15:6 29:18
18:20 31:23;78:11 7:5,6;9:3 different (8) easier (2)
click (2) controlling (1) deal (23) 6:25;34:22,22; 14:5;25:6
19:19;29:12 10:14 28:13;39:21;45:8, 35:14;44:21;47:13; economics (1)
close (1) conversation (1) 12,13,14,15,21,23,24; 50:17;65:7 5:7
69:4 45:18 46:15;47:4,23;50:19, Dilaudids (1) education (1)
closer (1) conversations (1) 25;51:1,5,5;52:1; 47:12 4:21
45:20 26:6 55:7;58:5,7,10 DIRECT (1) eight (5)
cocaine (2) copy (1) dealer (2) 4:9 45:24;48:2;51:1,5;
Min-U-Script® Kanabay Court Reporters - Serving the Tampa Bay Area (2) cases - eight
727 821-3320
52:1 56:12 10,14;26:1;31:21; 9:16,16;11:21; Hey (2)

either (2) exchange (2) 37:15;40:8;43:10; 17:22 20:25;46:9
14:16;72:16 16:21;31:8 44:14;46:15;59:20; gives (2) HIDTA (9)
electronic (5) executed (1) 65:12,13,14 16:8;19:3 8:11;9:24;10:9,11,
50:23,25;51:5; 72:4 firsthand (1) giving (1) 14;49:3;73:14,21;
75:22;77:5 execution (1) 56:1 14:21 74:8
electronically (1) 72:8 Five (2) goes (2) High (1)
63:1 exist (1) 35:16;53:16 35:12;36:12 8:12
else (8) 78:20 flip (1) Google (11) higher (1)
5:20;11:7;38:7; exists (2) 57:19 26:18;27:3,6,12, 43:1
43:11;51:16;54:10; 36:15;78:16 Florida (4) 24;28:2,8;29:5,8; himself (1)
61:10;79:8 experience (2) 4:25;5:8;7:1;8:13 74:21;76:6 79:7
email (5) 43:6,9 follow (1) grade (1) history (1)
27:12,13,14;28:1,4 explain (1) 9:9 8:23 4:20
emails (6) 69:3 follows (1) grams (1) hit (2)
28:10;76:15,20,24, 4:7 46:7 19:12;26:14
25;77:3 F force (13) great (1) hits (1)
ended (2) 8:10,14,20,22;9:1, 60:7 18:7
53:16,21 facilitate (2) 7,11,17,22;10:14; group (7) Hold (1)
enforcement (5) 25:14;44:11 49:4;73:15;74:8 11:4,12;12:2,12, 23:21
5:11,20;6:20;7:8; facilitated (2) forensic (1) 18;16:19;75:6 holder (1)
8:10 14:16,18 38:12 groups (1) 27:9
engaged (2) facilities (1) forensics (1) 59:22 home (2)
14:7,8 6:25 53:9 guess (2) 8:5,6
enough (1) fact (4) form (2) 12:1;23:22 honest (1)
41:4 11:20;24:12;41:25; 41:6;42:18 guidelines (8) 71:3
entered (1) 61:6 forth (1) 9:7,9,12;73:12,13, hours (4)
34:9 familiar (2) 67:20 16;74:1,8 28:22;29:3;60:1;
entire (2) 69:11;74:7 forward (1) guy (1) 66:5
64:13;66:1 far (8) 8:24 79:21 hundred (1)
establish (1) 16:17;22:4;38:12; found (1) guys (1) 46:9
27:16 46:4;52:3;65:20; 23:4 28:18 hundreds (2)
established (1) 76:23;77:4 fourth (3) 41:9,18
19:18 FBI (2) 45:13;50:19,25 H Hydromorphone (2)
establishing (1) 7:4;9:3 frame (1) 46:25;47:1
27:19 February (1) 38:19 handle (1)
estimate (1) 46:25 fruits (2) 52:2 I
29:2 feel (1) 24:6;71:23 handler (2)
ethnicity (1) 39:22 fuel (1) 16:25;17:1 identification (1)
19:20 felony (1) 75:19 handling (2) 60:8
even (1) 42:22 further (5) 16:24;77:5 identifications (1)
40:20 felt (2) 60:8,10;62:20; hand-to-hand (1) 59:21
everybody (1) 42:10,11 68:12;79:25 73:16 identified (4)
49:20 few (1) handwritten (3) 22:11,20;23:1;
evidence (40) 28:22 G 25:4;33:3,13 24:11
32:22;34:4,6,8,9, fifteen (2) happened (2) identify (4)
11,18,19,22;35:2,2, 63:8,12 gas (1) 31:8;33:8 21:17;23:15;55:18;
25;36:1,19,22;37:2,6, fifth (1) 75:24 head (4) 56:20
11;39:2;44:1,3;45:1; 45:14 gather (2) 8:16;10:9,11;21:2 illegal (6)
52:4,4,9,18,22,23; figure (1) 44:25;57:15 headed (1) 41:1,4,9,11,18;
55:23;56:7;62:4,4, 69:2 gathered (2) 9:1 49:10
16;63:7,15;70:3; fill (2) 14:13;51:25 heading (1) immediately (3)
77:2,5,6;78:14 35:8;69:19 gathering (1) 67:13 38:17,18;53:5
exact (1) find (3) 42:13 hear (1) improper (1)
23:11 11:10;36:3;71:24 gave (10) 77:21 61:17
exactly (4) fingerprints (2) 11:24;14:20;31:8; height (1) incarcerated (1)
8:16;19:10;29:1; 39:7;53:10 34:11;40:2;43:18; 19:21 77:10
35:24 finished (1) 55:13,19;64:12;73:8 help (2) inches (2)
EXAMINATION (1) 52:2 general (1) 44:10;65:8 35:15,16
4:9 first (26) 49:16 helped (1) include (4)
examined (1) 4:6,16;15:16,22; geographically (1) 25:14 18:19;41:11,21;
4:7 17:19,23;22:18;23:2, 23:9 herein (1) 61:24
except (1) 16,20;24:4,10;25:2, given (4) 4:6 includes (2)
Min-U-Script® Kanabay Court Reporters - Serving the Tampa Bay Area (3) either - includes
727 821-3320
9:3;57:5 17:24;18:15;73:12, keep (4) listen (1) 71:6

indeed (3) 13,16;74:3;76:6,8,16, 8:4;49:10;75:11,14 68:14 Marie (2)
31:14;33:21;40:18 23,24,25;79:19 kept (1) little (2) 57:25;58:6
indicate (3) into (11) 26:8 4:20;11:3 marijuana (1)
30:14;37:14;67:4 5:10;32:22;34:4,6, key (1) Livernois (2) 10:25
indicated (3) 9;37:2,6;39:1;62:3, 75:22 17:2;75:8 materials (3)
22:19;68:10;71:10 16;63:7 kind (11) location (5) 8:7;48:23;53:3
indicates (1) introductions (2) 4:21;6:23;7:14; 23:3,11;69:16,17; matter (3)
10:23 14:22;15:12 15:21;17:21;24:25; 70:24 11:20;15:7;24:16
indication (1) invest (1) 26:17;28:12;30:3; locations (1) may (10)
60:10 72:23 63:17;70:7 34:22 23:8;49:13,13;
individual (11) investigated (1) knew (5) locker (1) 53:16,21;54:13;
11:11,12;12:9,12; 9:25 25:22,23;43:17,22; 62:4 74:15;76:15;78:15,
19:13;22:10,20; investigating (1) 68:17 log (4) 20
24:11;35:19;40:2; 35:19 knowing (1) 20:5;37:5,7;52:9 maybe (5)
75:6 investigation (5) 49:6 logged (7) 14:4,4;43:5,23;
individuals (7) 9:23;17:17;53:20; knowledge (6) 32:22;37:2;39:1; 79:3
11:13;12:2,12,18; 59:12,14 13:10,13;19:2; 52:23;53:1,2,11 mean (11)
14:16;59:21,22 investigations (5) 24:15;53:24;56:1 logging (1) 12:24;13:11;33:9;
informant (7) 24:21;75:5,10; known (3) 52:5 35:25;38:18,23;40:3;
11:20,25;13:9; 78:1;79:20 18:18,19;49:7 log-on (4) 50:17;68:13;70:10;
14:7;16:24;49:13,16 investigative (4) 20:6,10,14;38:10 79:11
informants (10) 17:21;21:21;22:23; L logs (1) meaning (3)
11:23;12:13,18; 72:11 75:14 12:20;14:18;23:7
14:6,7,17;16:19; involve (1) lab (3) long (8) meant (1)
74:11,12;75:7 11:22 38:19;40:5,12 5:15;6:14;26:8; 65:20
informant's (1) involved (7) label (7) 28:21;29:1;31:5; meeting (13)
13:10 27:18;55:1;67:7; 11:19,24;64:12,16, 34:25;35:6 14:22;22:19;24:2,
information (34) 68:7;78:1,18,25 19,23;65:22 look (13) 4,10;28:11,22;29:25;
11:5,21,25;12:19; involvement (2) labels (1) 14:24;20:25;22:2; 31:4;42:19;50:10,20;
13:6;14:1;16:21; 8:9;12:25 65:15 31:22;36:3;41:19; 51:1
17:13,18,22;18:1,25; involves (1) laboratory (1) 44:16,24;45:4;56:9; member (2)
21:12;22:3,7;23:23; 48:17 7:8 57:1;67:22;69:25 8:11;10:14
24:10,18;27:23; involving (1) Largo (1) looked (1) memorandum (1)
35:12;36:12;37:22; 24:21 18:20 39:22 9:8
43:19;44:8;46:16; issue (1) last (2) looking (4) messages (2)
57:4;60:9;63:24; 9:7 4:13;7:13 21:1;46:14,14; 44:25;74:13
66:10,22;70:2,15,18; issued (3) latents (1) 58:15 met (5)
73:8 21:21;72:11;73:5 39:11 looks (1) 13:21;14:9;24:19;
ingesting (1) items (1) later (3) 45:24 37:16;40:16
31:22 38:13 44:3;55:11,16 lot (3) methamphetamine (1)
initial (4) law (3) 23:12;33:12;56:12 7:7
15:22;17:24;64:13; J 5:10,14,19 Lots (1) midway (1)
74:15 learned (1) 79:12 62:24
initially (1) JACKSON (6) 23:24 lower (1) might (2)
45:8 27:25;41:5,13; least (2) 16:22 37:9;76:11
initiated (4) 42:4;49:18,25 45:16;48:18 lumping (1) mileage (2)
45:12,13,14,23 jail (2) led (1) 50:16 75:14,17
initiating (1) 6:2;19:21 12:25 milligrams (2)
45:21 January (5) Lee (1) M 63:8,12
inside (1) 46:17,18,19;53:15, 58:13 mine (1)
30:17 21 left (3) main (1) 44:21
instead (1) jay-walking (1) 35:1;76:8,12 64:10 minutes (3)
78:1 41:19 lengths (1) maintain (1) 28:23;55:11,16
Intensity (1) jerk (1) 60:7 19:9 misspelled (1)
8:12 7:22 level (1) majority (1) 4:17
interchangeable (1) judge (2) 18:24 45:17 Mm-hmm (29)
47:13 72:16,21 license (1) making (6) 7:16;11:1;12:11;
interested (1) 30:10 17:23;25:1;54:9; 15:4;19:17;21:7;
28:10 K line (3) 61:17;79:11,14 28:9;42:12;57:21;
interesting (1) 16:13;62:14;67:2 many (3) 59:2,4;60:3,22,24;
22:16 Kayla (3) list (1) 18:7;19:25;71:11 61:3;62:6,10;63:2;
internal (13) 57:25;58:6;65:13 35:13 maps (1) 64:9,11;65:6;66:9,
Min-U-Script® Kanabay Court Reporters - Serving the Tampa Bay Area (4) indeed - Mm-hmm
727 821-3320
20;69:18;70:22; 59:25;62:20 76:12,18,19;78:6; 21:11 per (1)

71:15;76:1;78:12; nickname (1) 79:22 oxycodone (4) 75:17
79:5 21:15 officer (6) 46:22;63:9,12;79:6 perform (1)
model (1) nine (1) 4:22,23;5:20;10:7; OxyContin (2) 33:20
30:4 62:5 67:7;76:25 63:8,10 period (3)
monetarily (1) Nobody (1) old (1) 17:17;22:17;53:15
17:11 25:14 56:25 P person (27)
money (14) Nodding (1) once (2) 8:16;10:9,11;11:4,
31:9;43:5,24;46:6; 53:6 45:20;64:6 page (10) 4,19,24;12:1,23;
54:17,22,25;55:6,10, normally (2) one (44) 56:18;57:19;58:15, 13:21;15:2,15;16:24;
12,13,18,18;74:1 46:12;48:17 4:16;13:2;15:1; 20;60:19;62:20; 18:21;19:15;21:15;
monies (1) notate (1) 17:10;18:3,10;19:15; 63:21;65:1;66:4,17 23:1;37:16;54:11,14;
47:16 22:13 20:2;22:15,23;25:4; paid (2) 56:21;64:13;65:10,
months (4) notated (1) 29:12,22;30:24; 6:9;17:13 22,22;69:1;79:20
48:19;49:6,11; 22:13 36:15;37:9;41:16; Palm (1) personal (6)
53:17 notation (1) 43:4,23;44:14,16,17; 5:1 27:12,13;28:10;
more (13) 57:15 45:5;52:3;58:13,14; paper (2) 30:5;42:2;48:20
6:9;15:1;18:10; notes (4) 59:10,16;64:3,3;65:2, 70:16,19 person's (2)
19:15;20:2;29:22; 24:25;25:4;33:3,13 2,5,5,7,12,14,23,25; papers (1) 19:20;61:20
40:15;41:16;42:11, nowadays (1) 69:6;71:12,13;74:12; 70:11 Petersburg (1)
13,14,16;49:15 79:12 77:1 paperwork (2) 18:19
move (2) number (35) ones (2) 69:7;70:6 PHILIP (2)
17:9,16 10:24;13:14,15; 52:10;76:23 paragraph (2) 4:5,16
much (3) 14:20,21;15:3,6,18; ongoing (1) 59:20;60:1 phone (41)
44:25;46:5,6 17:18;20:16;21:6; 75:4 parking (1) 13:14;14:20,21;
multi-jurisdictional (2) 22:18;27:2,3,16,19, only (5) 23:12 15:3,6,8,12,21,22;
8:10;9:2 19;29:5,8,15,18,23; 9:2;18:17;19:7; part (4) 16:1,3,6,7,8,11,15;
multiple (1) 36:12,14;56:14,18; 36:11;43:25 9:22;23:9;67:15; 17:18,23;20:16;21:6,
34:21 58:19,22;59:10,16; operate (1) 79:21 22;22:5,18;23:2,16;
mutual (3) 62:5;64:3;65:2; 9:8 parted (2) 25:2;26:10,17,24;
28:14,16,18 67:14,14 operated (1) 31:13;33:16 29:5;45:11,18;68:7,
numbers (6) 30:15 particular (23) 13,13,14,17;70:20;
N 26:25;29:11;55:1, operation (2) 13:6;16:20;29:19; 72:11;76:7;77:11
1;56:13,13 79:22,23 32:9,12;35:22;36:14; phonetic (3)
name (20) numerous (1) operations (3) 47:4,5,15;48:1;55:7, 58:1,6;65:13
4:13,16;10:15; 6:24 73:17;78:5;79:19 22,23;58:5;59:21; photograph (1)
11:11;15:17;19:16; opportunity (1) 65:1;67:16;68:3; 70:17
20:6,10;35:18,24; O 24:1 72:12;74:14;75:6; photographs (2)
36:10;37:25;38:1; order (3) 78:15 32:11;51:10
47:7,9;59:7;61:6,15, oath (1) 38:13,16;53:9 particularly (1) physically (2)
18,20 73:9 ordered (1) 69:19 64:24;65:14
names (2) object (4) 33:21 password (3) pick (1)
47:13;60:11 41:5,14;42:4;49:18 out (24) 20:6,10,14 32:4
narcotic (1) Objection (1) 11:10;18:25;35:9; patrol (4) picture (7)
12:20 49:25 36:1,3;43:11;45:1; 6:1,3,8;40:4 37:15,18;56:20,25;
narcotics (2) obtain (3) 46:21;48:1;53:4,5; pattern (1) 57:5,10;62:25
13:14;62:4 23:3;37:18;44:1 57:24;60:2,12,21; 43:4 pictures (2)
narrative (1) obtained (1) 61:7;65:3,8;68:18, pay (3) 51:15,20
59:20 68:11 19;69:2,15,19;75:20 8:22;9:5;75:20 piece (1)
nature (2) obviously (4) outside (1) PC (1) 70:18
50:9;51:6 30:9;52:13;59:19; 10:2 40:3 pill (1)
necessarily (1) 79:6 over (4) PD (2) 79:12
43:2 occur (1) 44:6;45:5;57:19; 18:20,20 pills (19)
need (7) 50:9 77:15 pen (4) 10:25;31:9;33:21;
8:25;19:3;20:25; occurred (1) own (7) 69:8,12,13;70:21 34:2;35:2;38:16;
43:5;66:13,13;75:19 49:23 15:8;25:14;27:13; people (14) 39:8,23;40:22,23;
needed (3) off (1) 42:2;43:23;44:10; 11:5;12:18;15:2; 41:12,22;42:16,21;
43:24;78:9,10 21:2 75:20 32:1;37:12;41:10; 43:1,13;46:21;48:8;
negotiate (1) Office (20) owned (4) 49:7;55:23;58:4; 52:4
29:2 5:16;6:19;8:20; 16:6,8;21:14;30:14 70:6;71:2;77:1,4; Pinellas (18)
negotiation (1) 10:1,20;11:22;23:13; owner (3) 79:12 5:15,23,25;6:18;
28:12 30:22;31:2,4;33:7; 20:20,22;55:21 people's (1) 8:19;9:25;10:17,20;
next (2) 34:8,18;52:21;70:5; ownership (1) 60:11 17:5;18:18;23:21,23;
Min-U-Script® Kanabay Court Reporters - Serving the Tampa Bay Area (5) model - Pinellas
727 821-3320
48:25;73:14;74:3; previous (1) quantity (5) relationship (7) 51:3,24;56:14;57:19;

76:17;78:6;79:22 24:21 25:17,20;42:25; 13:5;14:12;15:7; 58:24;60:11;65:24;
PIONE (1) previously (2) 46:3;47:20 54:6,8,11,15 70:12,21
4:5 48:12;63:25 quite (1) release (1) road (4)
P-I-O-N-E (1) printed (1) 44:20 57:2 6:1,3,8;30:24
4:14 70:11 relevance (3) room (13)
place (6) Prior (18) R 41:14;49:19,25 34:8,9,11,18,19;
31:5;50:8,11,20; 5:19;12:16,17,20, relevancy (1) 35:2;37:11;52:5,9,22,
51:1;78:13 21,24,25;13:5;17:22; ran (2) 42:5 23;77:2;78:14
placed (2) 20:16;23:15,20;24:4, 21:6;38:1 remain (1) rooms (1)
62:3,16 10,15,16,18;25:1 range (1) 64:4 34:22
plate (1) privilege (1) 23:23 remaining (1) run (7)
30:10 50:5 rate (1) 44:6 18:3;19:19;20:16;
please (1) probably (5) 9:5 remember (3) 37:22,25;38:3,4
21:5 16:25;18:11;29:3; realize (1) 36:3,7,9
pocket (6) 76:23;77:3 46:20 reminding (2) S
35:3,4,5,6;55:13; procedure (2) really (4) 7:21,22
75:21 78:13,20 33:12;44:19;55:15; Repeat (1) sake (1)
point (6) process (1) 71:3 21:5 20:24
12:2;21:24;28:11; 54:20 reason (1) report (34) sale (4)
30:1;31:21;35:1 produced (1) 44:1 10:23;11:6,9,19; 41:11,12,21;43:23
police (8) 29:8 reasons (1) 20:25;21:1,4;22:2, same (13)
4:22,23,24;24:24; produces (1) 48:11 12;23:17;24:24;25:7; 14:7;29:15;48:11;
30:15;44:19,21;72:7 25:7 recall (7) 28:24;37:14,19; 50:9;52:3;53:10;
policies (1) program (2) 18:7,9;20:1;29:1; 44:20,21;56:10;57:1, 63:24;64:19;66:10,
9:9 26:17,18 35:24;36:10;38:1 6;61:2,10,11,12; 21;67:2,13;74:21
policy (5) promotion (1) receive (1) 62:25;64:4,10,13,14; save (1)
42:2;48:20,22,25; 6:8 39:21 65:10;66:1,2;67:8,18 17:10
49:3 proper (1) received (3) reports (7) saying (1)
policy-wise (1) 6:5 39:23;76:8,16 8:18,21;36:15; 26:13
39:18 prosecutor (2) receiving (1) 64:7;67:17;72:7; search (7)
pool (1) 72:20,22 31:14 75:11 51:21;68:10,11;
29:11 protecting (1) record (3) request (8) 71:12,19,20,23
possibility (1) 49:24 4:13;7:23;20:24 25:16;38:24;39:7, searches (1)
59:23 protection (2) recorded (2) 11;46:2,13;47:4,15 20:13
possible (1) 32:2;49:12 20:10;61:25 requested (4) second (3)
44:20 provided (5) recording (2) 25:21;33:22;39:23; 21:4;45:8;69:1
post (2) 10:2,23;11:5; 61:25;70:17 48:6 seeing (1)
5:5;23:12 12:19;15:2 recordings (2) requesting (2) 60:23
practice (3) providing (2) 24:25;77:12 27:23;54:20 sell (6)
39:13,15;40:4 15:6;16:20 records (1) required (2) 10:25;13:13;43:11,
Pratt (2) public (1) 75:11 36:11,11 12;53:25;78:11
57:25;58:6 49:17 redacted (1) requirement (1) seller (6)
pre-contact (1) pull (1) 56:12 39:17 56:21;78:2;79:4,6,
17:16 35:25 reduced (2) research (1) 7,15
predicate (1) pulled (1) 16:22;70:16 78:17 selling (4)
76:24 77:19 refer (6) residence (3) 43:14,17;54:11;
pre-first (1) purchase (1) 21:4;22:12;23:17; 51:23;71:21;72:1 55:21
24:2 25:16 28:24;47:11;69:24 resources (1) separate (2)
prescription (2) purposes (3) reference (3) 9:3 16:13;70:7
41:21;43:24 16:12,13;29:20 59:12,13;61:25 restricted (1) separated (2)
presence (1) put (16) regarding (12) 16:12 34:1;52:2
49:23 18:24;19:3;33:8; 24:25;27:5;72:17; result (2) sergeant (2)
present (4) 34:4,6,11;35:8,18,23; 73:16;74:1,13;75:15; 19:4,6 10:13,16
58:4,7,9;72:3 38:23;63:7,9;65:11, 76:9,12,18;77:2,3 results (4) serial (1)
preserve (1) 11,13,21 regardless (1) 40:5,12;70:9,10 55:1
26:5 49:8 right (30) served (1)
preserved (3) Q register (4) 4:19;9:20;11:11; 51:23
16:16;74:18;77:15 69:8,12,13;70:21 13:17,22;17:8;19:1; serving (1)
presses (1) Quantico (2) registered (1) 22:6,9;23:11,11; 49:24
79:12 7:2,25 27:14 25:9;27:15;32:3; set (1)
presumptive (4) quantities (1) related (3) 33:10;34:7;44:5; 24:1
52:11,13,20;53:2 46:4 16:15;51:21;72:8 45:19,21,22;46:8; seven (1)
Min-U-Script® Kanabay Court Reporters - Serving the Tampa Bay Area (6) PIONE - seven
727 821-3320
44:7 25:12;50:10;68:1; 23:10;47:9 20:5;37:23;65:9; 8:1

seventh (1) 78:10,10 stuff (3) 76:7,9;77:19 texting (1)
45:23 source (2) 70:8;71:7;77:7 systems (1) 26:17
several (1) 13:5;60:8 Subject (14) 75:24 Theirs (1)
74:13 sources (1) 57:20,25;58:9,13, 67:17
Sheriff (3) 43:18 22;59:1;63:22;64:3; T thereon (1)
10:17;49:1;74:3 specialized (2) 65:2,4,7,12,14,25 50:19
Sheriff's (16) 6:19,24 submit (2) tag (8) thinking (1)
5:16;6:19;8:20; specific (9) 8:21;38:19 34:12,12;35:9,12, 13:18
9:25;10:20;17:6; 9:11,17;11:4;23:3; submitted (1) 15,23;38:3,4 third (2)
18:18;30:9;34:19,21; 36:21;44:16;46:3; 22:3 talk (4) 45:12;47:23
73:14,19;76:7,17; 50:15;74:8 subpoena (5) 11:3,7;59:25;73:4 though (2)
78:6;79:22 specifically (3) 22:4;69:5,20,24; talking (10) 22:16;40:20
shooting (1) 36:7;46:6;47:19 70:16 22:4,17;26:24; three (2)
48:5 spell (1) subpoenas (2) 27:2;45:21;50:15; 48:1;57:25
Short (3) 4:13 21:22;72:11 62:21;73:13;76:5,6 Throughout (4)
18:4;19:13,16 spend (1) substance (5) talks (1) 7:1;64:4;65:17;
show (3) 75:12 31:23;52:4;53:2, 62:3 66:1
43:4,6;71:7 spit (1) 10;78:10 Tampa (1) throw (2)
shows (1) 18:25 substances (1) 19:8 53:4,5
70:24 split (1) 49:10 taps (5) times (2)
similar (1) 52:14 substantial (2) 68:7,13,13,17,21 4:18;29:14
66:7 spoke (1) 40:21,24 task (13) tip (2)
sit (1) 15:15 substantially (1) 8:10,14,20,22;9:1, 11:15,17
73:4 spoken (1) 66:21 7,11,17,22;10:14; title (4)
site (1) 29:14 suggested (2) 49:3;73:14;74:8 6:5,11,14;59:7
31:12 spot (2) 50:19;51:1 tattoos (1) today (1)
sitting (2) 28:18;40:21 supervisor (1) 19:20 9:21
35:3,3 St (1) 77:1 teaching (2) together (1)
situation (2) 18:19 supplement (11) 6:25;8:7 50:16
40:5;72:24 standard (5) 64:8,14,17,20; technical (7) told (2)
six (8) 26:20;34:19;39:13, 65:20,21;66:2;67:8, 18:21;69:1;70:6,7; 9:14;43:9
35:15,16;44:6; 14;40:4 14,15,23 71:2;77:1,3 tolls (1)
48:18;49:6,11;50:16; start (4) supplements (3) technically (1) 22:5
53:16 6:1,1;30:20;56:14 64:7;67:4,15 40:3 took (5)
six-month (1) started (4) supplied (2) techniques (1) 29:1;34:25;50:8;
53:15 5:25;45:8;53:15,20 78:24,25 22:24 51:20;52:1
sixth (1) State (10) supplier (2) telephone (1) top (7)
45:15 11:22;27:22;69:6; 54:4,7 10:24 21:2;36:15;57:20;
skill (1) 70:5;72:16;76:12,18, support (1) telling (2) 58:16,21,23;66:5
18:24 19;77:16,20 10:2 55:12;61:14 total (1)
slang (1) statement (1) supposed (2) ten (9) 44:7
47:9 79:10 9:8;59:6 40:23;41:12;42:16, Townsend (7)
slash (1) station (1) sure (11) 21;43:1;46:21,22; 24:16;35:23;36:5;
67:14 75:25 8:16;13:18;16:2; 63:7,9 37:16;58:13;65:4;
social (1) statistics (1) 19:10;29:21;42:7; terminology (1) 71:14
38:1 8:21 43:25;54:9;60:7; 47:7 Townsend's (1)
sold (2) staying (1) 71:3;77:24 test (3) 9:22
42:16;55:24 71:21 surveillance (10) 49:8;52:24;53:2 toxic (1)
somebody (15) steps (1) 24:2;31:25;32:4,6, tested (4) 53:3
10:24;13:13;23:12; 17:21 8;50:23,24;51:6; 38:13,16,24;53:4 trace (1)
37:10;38:4;43:3,11, still (4) 68:2,22 testified (1) 55:6
23;44:3,10;49:22; 26:10;32:11;51:10; suspect (13) 4:7 tracked (1)
51:15;55:10;73:4; 74:25 14:13,15;15:7; testifying (1) 75:17
79:8 stipend (1) 24:5;25:13;35:23; 26:13 Trafficking (9)
someone (1) 16:9 44:10;53:24;54:12; testimony (1) 8:12;25:21,22;
38:7 stockpile (1) 55:22;58:14,21;65:5 72:16 46:21,23,25;47:2,19;
Sometimes (3) 78:15 swear (2) testing (8) 48:5
35:20;46:4,9 stop (1) 4:2;73:9 31:12;38:12,12; training (6)
sorry (4) 43:15 sworn (2) 52:11,13,20;53:9,10 6:20,23;7:6,8,25;
46:24;57:20;62:12; straight (2) 4:1,6 tests (2) 48:23
79:2 4:18;52:8 system (10) 33:20;53:1 transaction (7)
sort (5) street (2) 18:13,13,15,22; textbook (1) 32:9,12,16,17,22;
Min-U-Script® Kanabay Court Reporters - Serving the Tampa Bay Area (7) seventh - transaction
727 821-3320
48:18;62:1 upon (1) way (9) 24:25;48:22,25;

transactions (1) 44:7 14:4;15:5;25:6; 49:3;76:16 3
12:21 use (12) 27:11;33:1;41:19; wrote (9)
try (2) 15:21;17:25;28:4; 55:12;65:9;75:17 14:4;36:10;57:6; 31 (1)
22:7;69:2 29:23;34:23;37:15; ways (2) 61:1,10,11,12;67:8, 65:1
trying (4) 55:6,10;75:15,20,24; 31:13;33:17 12 35 (1)
7:22;11:10;44:25; 78:14 wearing (1) 66:4
67:1 used (10) 32:19 Y 3rd (1)
turn (4) 16:11;18:14;20:14; weight (1) 46:24
8:5;9:20;10:22; 29:15;38:10;47:8,11; 19:21 year (3)
55:10 56:20;62:25;77:17 Wesley (10) 5:2;7:10,13 6
turned (1) using (1) 35:23;36:5;37:16;
77:15 27:19 58:13;65:4,12,25; 1 60 (1)
twenty (2) usually (1) 71:14;77:10;79:1 66:17
55:11,16 25:5 what's (8) 10-17 (1)
Twenty-one (1) utilized (1) 10:15;18:13;58:25; 57:10 7
58:16 72:12 59:6,16,16;62:7,17 11 (1)
two (18) what's-closer-to-me (1) 46:19 727 (1)
26:24;28:21,23; V 28:13 11th (1) 29:7
31:13;33:16,25;51:5, What's-closer-to-you (1) 46:18
25;52:14;57:20;58:9, vehicle (5) 28:13 1300 (1)
21,22;59:1;63:22; 30:6,6,7,11,14 whatsoever (1) 60:1
64:3,8;71:12 verified (1) 10:3 15 (1)
type (13) 37:15 WHEREAS (1) 56:18
25:5;28:13;33:10; verify (5) 4:4 17 (1)
46:3,12,13;47:5; 17:22,25;19:20; Where's (1) 67:19
65:10,14;66:21;68:2; 24:10;46:16 31:2 17-10574 (1)
70:18;72:23 verifying (1) wherever (1) 36:17
53:20 8:25 18 (1)
U version (1) Who's (1) 67:19
57:24 10:11 1800 (1)
Uh (48) via (6) Wii (1) 66:18
6:9;11:6;13:2,18; 15:8;45:8,12,13,14, 21:15 19 (1)
14:15,24,25;15:16; 23 W-I-I (1) 67:19
16:23,25;18:21;20:1, video (5) 21:16
23;22:10;28:12,21, 32:6,8;51:6;68:2; wire (1) 2
24;30:4;33:17;35:24; 70:17 32:15
40:3;42:1,3;44:16; video-type (1) within (3) 2.6 (1)
46:4,19;47:11;50:19; 50:24 78:5,23,23 46:6
51:16;57:1;59:19,25; visitation (1) witnessed (1) 2001 (1)
61:20;62:8;64:15; 77:11 24:5 5:3
65:8;66:4;68:19,25; voice (10) WLT (1) 2012 (1)
69:5;70:4,13;71:2; 26:1,18;27:3,6; 56:14 5:17
73:18;74:15;77:3,25; 28:2,8;29:6;44:15; word (1) 2014 (1)
78:24 74:23;76:6 63:18 6:16
Ulmerton (1) voicemails (2) work (5) 2016 (2)
30:24 76:8,11 16:12,13;17:5; 7:11;57:11
under (2) 29:20;30:7 209-7755 (1)
36:12;73:9 W worked (1) 29:7
uniform (1) 5:19 21 (2)
65:17 wait (2) working (7) 57:20;58:16
unit (3) 34:7;40:5 13:5;49:13;54:6,8, 22 (3)
70:7;78:24,24 walk (1) 11;75:12;77:8 57:20;58:19,23
University (1) 15:10 works (6) 2200 (1)
5:8 warrant (12) 18:22;19:10;64:16; 66:5
unmarked (3) 68:21;69:6,20,24; 65:9;69:2;71:4 24 (1)
30:11,13;33:17 70:16;71:12,13,14, worth (2) 59:19
up (14) 19;72:3,8;73:5 46:10;47:16 25 (1)
9:1;15:10;19:15; warrants (6) write (2) 62:21
20:19;21:11,11;24:1; 51:21;68:10,11; 36:24;54:25 27 (1)
28:22;29:10;32:4; 71:10,11,12 writing (2) 63:21
35:25;52:14;75:19; water (1) 36:7;54:21
77:20 66:14 written (5)
Min-U-Script® Kanabay Court Reporters - Serving the Tampa Bay Area (8) transactions - 727
727 821-3320

Pinellas County Sheriff&#39;s Detective Philip Pione Deposition

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Pinellas County Sheriff&#39;s Detective Philip Pione Deposition

Uploaded by

Copyright:

Available Formats

1 IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT

IN AND FOR PINELLAS COUNTY, FLORIDA

3 CASE NO.: 17-060080 CF

12 DEPOSITION OF: DETECTIVE PHILIP PIONE.

14 DATE: August 23, 2017

15 PLACE: Victim Witness Office, Room

Kanabay Court Reporters - Serving the Tampa Bay Area

Kanabay Court Reporters - Serving the Tampa Bay Area

3 DEPONENT: DETECTIVE PHILIP PIONE

4 Direct, by Mr. DeCailly....................... 4

6 Reporter's Affidavit of Oath.................. 81

Kanabay Court Reporters - Serving the Tampa Bay Area

6 the deponent herein, being first duly sworn, was

7 examined and testified as follows:

12 Detective, can you -- for clarity of the

16 A. An my first name Philip, has one l.

18 times, but I got it straight I think.

19 All right. I want to go back. I want to get

20 a little history on you.

21 What kind of education do you have for being

23 A. For being a police officer, I went to the

25 Q. Okay. Here in Florida?

Kanabay Court Reporters - Serving the Tampa Bay Area

1 A. Yes. In Palm Beach County.

7 A. I have a bachelor's degree in economics from

14 Now, since you've been in law -- well, let me

16 County Sheriff's Office?

19 Prior to that had you worked as a law

20 enforcement officer anywhere else?

22 Q. So your career to date has been here in

25 Q. Now, when you started with Pinellas County,

Kanabay Court Reporters - Serving the Tampa Bay Area

1 did you start on road patrol or did you start in the

9 A. Uh, I get paid more.

11 A. And they changed my title so I would assume

14 And how long have you had the title of

18 Now, since you've been with the Pinellas

19 County Sheriff's Office have you had any specialized

20 training in drug enforcement?

23 What kind of training is that?

24 A. I've taken specialized courses at numerous

25 different teaching facilities.

Kanabay Court Reporters - Serving the Tampa Bay Area

1 Q. Throughout Florida or have you had --

4 So you've been to the FBI --

7 A. I did methamphetamine and clandestine

14 Q. And did you get some kind of certificate from

21 Q. So I'm just reminding you of that. I'm not

22 trying to be a jerk about it. I'm just reminding you

23 so we have a clear record.

25 Q. During that training at Quantico did you get

Kanabay Court Reporters - Serving the Tampa Bay Area

4 Is this a book that you were able to keep and

6 A. I was able to take it home with me, all the

9 Have you had any involvement in any

11 A. Yes. I'm currently a member of the HIDTA,

12 High Intensity Drug Trafficking Area for central

14 Q. And who is in charge of the task force?

15 A. I believe it's a collaboration. I'm not

16 exactly sure who the head person is.

18 Well, when you make reports about arrests or

19 about your activities, do they just go to the Pinellas

20 County Sheriff's Office or do they go to a task force?

21 A. I believe they submit statistics and reports

Pinellas County Sheriff's Detective Philip Pione Deposition

Pinellas County Sheriff's Detective Philip Pione Deposition