Abiodun Adebanjo Complaint

8/3/2019 Abiodun Adebanjo Complaint

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IN THE UNITED STATES DISTRICT COURT FOR ffiHE EASTERN DISTRICT OF VIRGINIA .' prn __

Alexandria Division

UNITED STATES O F A M ER IC A

Case No. l:12-mj-60ABIODUN ADENIYIADEBANJO,

Defendant.

AFF IDAV IT IN SUPPORT OF CR IM INAL COMPLA INT

1,Christopher Hall, being duly sworn, depose and state as follows:In troduct ion

1. I am a Special Agent of the United States Department of Homeland Security,Homeland Security Investigations (HSI). I am assigned to the Washington Dulles InternationalAirport. My duties as a Special Agent with HSI include, but are not limited to, the investigationof federal laws governing the importation and exportation of controlled substances. I havereceived training in general law enforcement, including training in Title 21 of the United StatesCode. I am a graduate of the Federal Law Enforcement Training Center at Glynco, Georgia.

2. I am an "investigative or law enforcement officer" of the United States within themeaning of Title 18, United States Code, Section 2510(7), that is, an officer of the United Stateswho is empowered by law to conduct investigations of and to make arrests for offensesenumerated in Title 18, United States Code, Section 2516(1).

3. This affidavit is submitted in support of a criminal complaint charging that on orabout January 29, 2012, in Loudoun County, Virginia, within the Eastern District of Virginia,ABIODUN ADENIYI ADEBANJO knowingly or intentionally imported or attempted to import

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into the customs territory of the United States from any place outside thereof, or attempted toimport into the United States from any place outside thereof, 100 grams or more of a mixture orsubstance containing a detectable amount of heroin, a Schedule I controlled substance, inviolation of 21 U.S.C. 952 and 963.

4. The facts set forth in this affidavit are based on my personal knowledge andreview of records, documents, and other physical evidence obtained during this investigation, aswell as information conveyed to me by other law enforcement officials.

5. This affidavit does not include each and every fact observed by me or known to

the government. I have set forth only those facts necessary to support a finding of probablecause.

Probable Cause

6. On or about January 29, 2012, ADEBANJO arrived at Dulles InternationalAirport, in Loudoun County, Virginia, within the Eastern District ofVirginia, on a direct flightf ro m R om e .

7. ADEBANJO told Customs and Border Protection ("CBP") Officers that heintended to travel to Atlanta, Georgia to visit friends and purchase cars. ADEBANJOrepresented himself as an employee ofLufthansaAirlines and presented an employee badge thatCBP Officers believed to be counterfeit.

8. CBP Officers referred ADEBANJO to a secondary inspection area. A narcoticsdetection canine picked up a scent from ADEBANJO's luggage. A search of ADEBANJO'sluggage by CBP Officers revealed several condoms and a net. I know from my training andexperience that internal drug smugglers use condoms to aid in ingesting pellets and use nets tocatch the pellets once expelled.



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9. CBP officers also noted that ADEBANJO's abdomen was abnormally rigid.ADEBANJO agreed to have his abdominal area x-rayed and ADEBANJO was transported toReston Hospital Center within the Eastern District of Virginia. ADEBANJO's x-rays indicatedthe presence of foreign bodies in his abdomen. CBP officers then observedADEBANJO expelpellets from his rectum. CBP officers field-tested the contents of one of the expelled pellets,which tested positive for the presence of heroin. The total gross weight of all of the pelletsexpelled by ADEBANJO was 557.2 grams.

10. ADEBANJO acknowledged that he swallowed the pellets, which he understood to

contain drugs.11. During the interview ofADEBANJO, he admitted to law enforcement that he lied

on his visa application. ADEBANJO indicated on his visa application he was an employee ofLufthansa Airlines, but ADEBANJO stated to law enforcement that he has never been anemployee ofLufthansa Airlines.

Conclusion

12. Based upon the above information and my training and experience, I submit thatthere is probable cause to believe that on or about January 29, 2012, in Loudoun County,Virginia, within the Eastern District ofVirginia, ABIODUN ADENIYI ADEBANJO knowinglyor intentionally imported or attempted to import into the customs territory of the United Statesfrom any place outside thereof, or attempted to import into the United States from any placeoutsidethereof, 100grams or more of a mixture or substance containing a detectable amountofheroin, a Schedule I controlled substance, in violationof21U.S.C. 952and 963.



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Christopher H/llSpecial AgentU.S. Department ofHomeland Security

Sworn to and subscribed before me this 1st day ofFebruary, 2012./s/

heresa Carroll BuchananUai'.rJ Stales Magistrate JudgeThe "Honorable Theresa C. BuchananUnited States Magistrate JudgeAlexandria, Virginia


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Abiodun Adebanjo Complaint