COMMERFORD Bradley Affidavit

8/20/2019 COMMERFORD Bradley Affidavit

1/17

UNITED

STATES

DISTRICT

COURT

DISTRICT

OF

CONNECTICUT

UNITED

STATES

OF

AMERICA

:

ss:New

Haven,

Connecticut

COUNTY

OF NEW

HAVEN

AFFIDAVIT

I,

Dana

R'

Mofenson,

Special

Agent

with

the Drug

Enforcement

dministration,

eing

duly

sworn,

eposes

nd

states:

l.

I am

employed

s

a Special

Agent

with

the Drug

Enforcement

dministration

("DEA")

and

have

been

o

employed

ince

August

2004.

2.

I am

currently

assigned

o

the DEA

New

Haven

District

Office

("NHDO")

Tactical

Diversion

Squad "TDS"),

which

investigates

hose

drug

traffickers

and

organizations

responsible

or

diverting

and

distributing

pharmaceuticals

nd

other

drugs within

the

States

of

Connecticut'

Due

to

the

abuse

and

trafficking

of opioid

based

pharmaceutical

ills

and

the

correlated buse nd raffickingof heroin, he DEA NHDO TDS is alsoactively nvestigating

investigations

nvolving

individuals

and

organizations

nvolved

with

the

distribution

of heroin.

During

my

assignment

o

the

DEA

NHDO

TDS,

and

previous

ssignment

o

theDEA

Bridgeport

Resident

ffice

High

Intensity

Drug

Task

Force,

haveprepared

umerous

ffidavits

n

support

of

applications

or

federal

search

warrants

and

arrest

warrants,

as well

as in

support

of

authorizations

o

conduct

electronic

surveillance.

As a

case

agent,

I

have

directed

and

coordinated

lectronic

surveillance,

ontrolled

purchases

f drugs, physical

surveillance,

undercover

ctivities

as well

as

debriefed

nd

managed

onfidential

sources.

am

familiar

with

the

manner

n

which

individuals

obtain,

inance,

tore,manufacture,

ransport,

nd

distribute

their

llegal

drugs.

have

a Bachelor

f

Arts

and

a

Bachelor

f Business

dministration

rom he


2/17

University

of Massachusetts

t Amherstanda Master

of Science

rom Northeastern

niversity.

havecompletedhe sixteen-weekong DEA

BasicAgent

Trainee cademy

n

Quantico,

A. I

have also attended umerousaw enforcementraining courses

elated o the

field

of drug

law

enfbrcement ndhold

a

Police nstructor

Certification

on the opic

of

drug

aw

enforcement ith

the State f Connecticut

olice

Officer

Standards nd

TrainingCouncil.

3. I am

an investigative r law

enforcementfficer of the United

Stateswithin the

meaning f

Title 18,

United

States

Code,Section2510(7)

n

that

I

am

empowered y

law

to

conductnvestigations

f

and o

makearrestsor offenses numerated

n Title

18,

United

States

Code,Section 516. Currently, am involved n an investigation f several eroinoverdoses

that occurredn

Shelton

and Derby,Connecticut

uring he

week of February

15, 2016. In

particular,

am investigating

iolationsof

2l

U.S.C.

$

8a1(aX1)

possession

ith intent

o

distribute, nddistribution

f, heroin)and2l

U.S.C.

$

846

conspiracy

o distribute

eroin).

4.

This

affrdavit is submitted

in support of

a complaint

charging

Bradley

COMMEMORD

(with

a dateof birth

(xxlxx/1995)

hat s

known

o

me) with

possession

ith

intent o distributeand

distributionof,

a mixtureandsubstance

ontaining detectable

mountof

heroin, a

Schedule

controlled ubstance,

n violation of

2l

U.S.C.

$$

8al(a)(l) and

841(bxlxc).

5. In

addition,

hisaffidavit

s submittedn support

f

an application

or a search

warrant irected t Verizon

Wireless

ecause

robable

ause xists o believe,

nd do believe,

asmore ully set orthherein,haton thecustomer atastorageystem f VerizonWireless,

thereexists vidence,

ruits,

and

nstrumentalitiesf violations

l

U.S.C.

$

8al(aXl)

(possession

with

intent o distribute,

nd

distribution

f, heroin)and2l U.S.C.

$

846

conspiracy

o distribute


3/17

heroin).

Specifically,

he

warrant

eeks

ecords

elated

o

COMERFORD's

seof

cellular

telephone

umber 203)

892-8592,

hich

s

a cellular

elephone

erviced

y Verizon

Wireless.

6.

This

affidavit

doesnot set orth all of the factsandevidencehat I havegathered

during

the

course

of the

investigation

f this

matter.

Rather,

his

affidavit

sets orth

facts

and

evidence

hat

are

relevant

o the

requested

omplaint

and

search

warrant.

The

statements

contained

n

this

affidavit

are

based,

n

part,

on information

provided

by

Special

Agents

and

Task

Force

Officers

of

the

DEA,

as well

as

the

Derby

Police

Department

nd

Shelton

police

Department

s

well

as

officers

from

other

aw

enforcement

gencies,

nd

on law

enforcement

officers' review

of

seized

electronic

vidence including

stored

ext

messages),

nd

on

the

experience

nd

raining

of

the

affiant.

BACKGROUND

7.

This

investigation

y the

DEA

NHDO

TDS

involves

he investigation

nto

a

series

f

heroin

overdoses

hat

share

common

eroin

source

f supply.

Theheroin

ource

f

the

supply

has

been

dentified

asBradley

COMMERFORD.

Two of these eroinoverdosesccurred

in

Shelton,

Connecticut

n

or

about

02-16-2016

nd

one

of the

heroin

overdoses

ccurred

n

Derby,

Connecticut

n

or

about

02-17-2016.

he

two

heroin

overdoses

ccurring

n

Shelton,

Connecticut

id

not

result

n

death

identified

hroughout

his

affidavit

as Victim

#l

andVictim

#2),

however,

he

one

heroin

overdose

ccurring

n

Derby,

Connecticut

id

result

n the

death

f

thevictim (identified

hroughout

his

affidavit

as

victim

#3).

8. Thus far in the investigation,

nvestigators

were

able

to

analyze

elephone

ext

messages

ecovered

rom

the

cellular

elephone

f Victim

#3,

analyze

elephone

oll

records

associated

ith

the

source

of

supply,

eview

medical

ecords

and

speak

with

victims

and

witnesses

nvolved

with

the

nvestigation.

nvestigators

ave

alsohad

he opportunity

o speak


4/17

with

COMMERFORD

when

he

was

arrested

n

February

8,20l6on

a

Connecticut

iolation

of

Probation

VOp)

warrant.

THE

DEFENDANT

9'

Bradley

COMMERFoRD

s

a resident

f

Sixth

Street

n

Derby,

Connecticut.

s

referenced

bove,

COMMERFORD

was

identified

as

the

heroin

source

of

supply

for

at

least

three

heroin

elated

overdoes,

ne

of which

resulted

n

a

death,

occurring

on

or

abou

02-16-2016

and

on

or

about

02-17-2016.

l0'

On

08-16-2014,

OMMERFORD

was

arrested

y

the

Derby

police

Department

and chargedwith Sale of a ControlledSubstance.oMMERFoRD receiveda three-year

suspended

entence

nd

was

ordered

o serve

hree

years

ofprobation

or

this

charge.

I

l'

On

10-23'2014,

OMMERFORD

was

arrested

y

the

Derby

Police

Department

and

charged

with

Sale

of

a

Controlled

Substance.

COMMERFORD

received

a

three-year

suspended

entence

nd

was

ordered

o

serve

hreeyears

of

probation

to

run

concurrent)

or

this

charge.

12'

On

0l-15-2016,

OMMERFORD

as

arrested

y the

Derby

Police

Department

and

charged

with

Possession

f a

Controlled

Substance

nd

Interfering

and

Resisting.

hese

charges

repending.

13'

On

02-18-2016,

members

f

the

Derby

Police

Department

btained

an

arrest

warrant

or

CoMMERFORD

charging

him

with violation

of probation.

Subsequent

o

obtaining

the

arest

warrantomembersof law enforcementconducteda motor vehicle stop of

coMMERFoRD

and

his

associate,

rooke

BIZEWSKI.

CoMMERFoRD

had

a

cellular

telephone

n

his possession

nd

$765

n

United

States

urrency.

ubsequent

o

the

motor

vehicle

stop,

DEA

Task

Force

officer

Brian

McPadden

laced

a

telephone

all

from

a DEA

telephone

o


5/17

telephone

umber

203-892-8592,

hich, during

the course

of the investigation nd

articulated

within

this

affidavit,

has

been dentified

as belonging

o COMMERFORD.Moments

after he

telephone

all,

TFO

McPadden

bserved

COMMERFORD's

elephone lert

to an incoming

telephone

all. DEA

spoke

with BIZEWSKI,

who

stated hat she

and COMMERFORD

were

traveling

o waterbury,

cT

to meetwith

their heroinsource

f supply Duke."

PROBABLE

CAUSE

INVESTIGATION

OF VICTIM

#1,VICTIM

#2

14.

On 02-16-2016,

members f

the Shelton

Police Department

esponded

o

a

reported eroinoverdosef an eighteenearold male,hereinaftereferredo asVictim #1,at a

residence

ocated n

Center

Streetn Shelton, T.

15.

Medical

assistanceas

endered

o

Victim

#1, who was

subsequently

ransported

to the

Griffin Hospital

n

Derby,

Connecticutor

evaluation

nd reatment. ictim #l

was

reated

and

was

subsequently

eleased

rom

the hospital.While

at

the

residence,

juvenile

witness,

hereinafter

eferred

o

as

Witness#1,

stated

o law enforcement

hat

Victim #1

does n

fact

"snort" heroin.

While

at

the hospital, aw

enforcement

ttempted

o

speakwith

Victim #1,

however,

ictim

#l

initially

refusedo

answer

uestions

f law enforcement.

16.

On the

evening

of the overdose

f

Victim #1,

members

f

the SheltonPolice

Department

poke

with

a

Sourceof Information,

who provided

a telephone

umber

of 203-892-

8592 as

the telephone

umber

belonging

o the heroin

source

of

supply or

Victim

#1.

The

Source f Information lsostatedhat Brad"soldheroin o victim #1.

17.

On

02-17-2016,

EA TFO

McPadden

nd

SheltonPolice Detective

Nugent

attempted

o speak

gain

with

Victim

#l and

Witness 1.

Witness

l

and

Victim

#l

discussed

the overdose

hat

occurred

on

the

previous

day

and stated

hat

"Brad" was the heroin

source

of


6/17

supply

or

the

supplied

eroin.

Witness

l

andVictim

#l

observed

ocial

media hotographs

nd

law

enforcement

hotographs

f

COMMERFORD

nd

dentified

he

photographs

s

.Brad,o,

the

source

f

supply

or

the

heroin

of

Victim

#

. Victim

#

stated

o

law

enforcement

hat

Victim

#

purchased

ive

(5)

"bagso'

f heroin,

sniffed

one

(l)

bag

of

heroin

and

that

,.within

seconds,,

Victim

#l

stated

hat

he,.knew',

e

was

overdosing.

l8'

While

speaking

with

law

enforcement,

itness

#l

stated

hat,

on

02-16-2016,

there

was

a

heroin

overdose

f a

second

ndividual,

hereinafter

eferred

o

as

Victim

#2,

and

hat

COMMERFORD

was

the

heroin

source

of

supply

or

Victim

#2.

Witness

#l provided

he

identityof Victim #2, whohassincebeen dentified sa twenty-two earold male,andstated

that

Victim

#2

had

also

been

ransported

o Griffin

Hospital

y

a second

uvenile

witness,

erein

referred

to

as Witness

#2,

on 02-16-2016.

aw

enforcement

was

not

aware

of

the

heroin

overdose

f

Victim

#2

at

the

time

as

reported

by

Witness

#1.

Subsequent

o

receiving

information

elated

o

Victim

#2,

detectives

ith

the

Shelton

police

Department

ttempted

o

speak

with

Victim

#2.

Victim

#2

acknowledged

he

heroin

overdose

hat

Victim

#2

had,

experienced,

owever,

ictim

#2

would

not

continue

o answer uestions

f law

enforcement.

19'

On

02-18-2016,

members

of

the

DEA

NHDO provided

an

administrative

subpoena

o

Griffin

Hospital

for

patient

records

of Victim

#2.

The

DEA

NHDO

did

in

fact

receive

ospital

ecords

elated

o the

admittance

f Victim

#2,

for

a heroin

overdose

n 02-16-

2016'

Members

f the

DEA

and

Shelton

olice

Department

ave

attempted

o

contact

ictim#2.

howevero

t is

believedhatVictim#2 does otwish o speakwith awenforcement.

IIWESTIGATION

OF

VICTIM

#3

20'

On

02-17-2016'

at

approximately

:43AM,

members

of the

Derby

police

Department

esponded

o

a medical

emergency,

hich

was

determined

o

be

a heroin

overdose


7/17

of

a twenty-three

ear

old

male,

hereinafter

eferred

o as Victim

#3,

at a

residence

ocated

on

Hawthorne

ve in

Derb ,

CT. Medical

assistance

as

endered

o

Victim

#3,

however,

ictim

#3

expired

after

being

ransported

o Griffin

Hospital

n

Derby,

Connecticut.

21.

DEA

TFO

McPadden

as

able

o speak

riefly

with

the

mother

f Victim

#3.

The

mother

of

Victim

#3

reported

hat,

approximately

ne

week

prior,

Victim #3

confided

hat

Victim

#3

was

using

heroin

and hat

he

heroin

source

f supply

or

Victim

#3

was

an ndividual

with

the

first

name

of "Brad."

Following

an interview

of the

mother

of Victim #3,

and

at the

request

f

law

enforcement,

he mother

of

"Victim #3" provided

cellular

elephone

elonging

to Victim #3 to law enforcement.he elephone umberutilizedby Victim #3 was ound o be n

frequent

ontact

with

telephone

umber

203-g92-g592.

TELEPHONE

ANALYSIS

22.

On

02-17-2016,

members

of

the

Monroe

Police

Department

onducted

an

electronic

nalysis

f

the

above

eferenced

elephone

elonging

o Victim

#3.

Members

f

the

DEA

conducted

n

analysis

f

the elephone

ext

messages

ecovered

s

a result

of

the

electronic

analysis.

23.

A search

of

the telephone

contact

ist"

of Victim

#3

revealed

hat

telephone

number

203-892-8592

s

associated

ith

"Brad."

The

elephone

umber

f Victim

3 was

ound

to

be n

frequent

ontact

with

203-892-g1g2.

TEXT

MESSAGES

COMMERFORD,

VICTIM

#3

24. on 07-30- 015,at approxim tely3:24PM hrough3:30PM, he following ext

message

onversation

ook

place

between

ictim

#3

and

COMMERFoRD:

coMMERFoRD

stateso

o'Yo

nigger,"

"I'm

back

home."

Victim

#

3 states, who's

this."

coMMERFoRD

states'

lts brad

u

don't got

my num

saved

ol."

Victim

#3

states,

Nah got

a new

phone

dude.,,


8/17

COMMERFORD

tates.

Ok

call

mewhenu can."

25. Based

upon my

training

and experience,

believe

that

during the

above

referencedext message

onversation,

ictim

#3

and

COMMERFORD

have a

conversationn

whichVictim

#3

states

hat

he hasa

new elephone nd

does

not have he elephone

umber

or

COMMERFORD avedn his elephone

dentifying

COMMERFORD's

elephone

umber.

26. On02-14-2016

t approximately

0:29PM hrough

l:49PM,

he

ollowing

ext

message onversationook

place

between

Victim

#3 and COMMERFORD:

Victim

3 states,

"Address??"

OMERFORD

tates, 19

dusty ane,"

"Newtowncr."

Victim

#3

states,

lght,"

"Outsidenigga," Yoo," "Yo go nearur phonenigga."COMMERFORD tates, Can u check

the car andsee f I

dropped

moneydude," Please

ude 'll throw u a bag

f u find it in

looking

everywhere."

27. Based

upon

my training

and

experience,

believe that

during

the

above

referenced

ext message

onversation, ictim

#3

and COMMERFORD

have a conversationn

which

Victim #3 is provided

with

an address nd meets

with COMMERFORD or the

purchases

of Victim

#3 purchasing

eroin rom

COMMERFORD.

alsobelieve hat after

Victim

#3

and

COMMERFORD

meet,

COMMERFORD sksVictim

#3

to

see

f Victim

#3

can

ocate

money

that

COMMERFORD

may have nadvertentlyeft in

the

vehicle

of

Victim

#3.

I

additionally

believe,

hatCOMMERFORD

tateshathe will

provide

heroin

"bag")

o

Victim #3

above nd

beyond

which

Victim

#3

paid

or

if Victim #3

is able o locate he money hat

was

nadvertently

left by COMMERFORDn thevehicle f Victim #3.

28.

On 02-16-2016"

at approximately

1l:02PM,

the following text message

conversation

ook

place

betweenVictim #3

and COMMERFORD:Victim

#3

states,

'At

the

door."

COMMERFORD

tates.Comin."

Victim

#3

statesisht."


9/17

29. Based

upon my training and experience,

believe that

during

the

above

referenced

ext message

onversation, ictim

#3

and COMMERFORD

are completinga

heroin

transaction.believe

hat

at the ime

of

the

ext messages,

ictim

#3

is outsidehe

residence

f

where

COMMERFORDs

at and

s alertingCOMMERFORD

s o

whereVictim

#3

is

("At

the

door"). believe hat,

at the ime of the ext

messages,OMMERFORD

nstructs ictim #3

to

enter he residence

"Comin")

and hat

Victim

#3 accepts

he nvitation o

enter he residence,

attemptingo state All right"

which wasentered

nto the elephone

ncorrectly

"ight").

INTERVIEW

OF COMMERFORD

30. On02-18-2016, embers f DEA and he Shelton oliceDepartmentnterviewed

COMMERFORD.COMMERFORDwas not forthcoming

during

the interview

with respect o

distributingheroin o others.

COMMERFORD

did

state hat

he used

heroin,

had knowledgeof

significant eroindistributors.

OMMERFORD

tated

hat he had

beennotified

of two heroin

overdoses,

ncluding

hat

of

Victim

#3.

COMMERFORD

ecame

isibly upset

when speaking

about the death

Victim

#3. COMMERFORD

stated hat

he

had known

Victim #3 for

COMMERFORD's

ntire ife.

ADMINISTRATIVE

SUBPOENA

31.

On

02-17-2016,members f

the DEA issued

an administrative

ubpoenao

Verizon equesting

ubscribernfbrmation nd oll

recordselatedo telephone

umber 03-892-

8592. According to

Verizon, this telephone

number is currently

subscribed o

Sean

COMMERFORD, elievedo be the fatherof BradleyCOMMERFORD.Also, accordingo

Verizon,

this telephone

s currently n the

"account" name of Bradley

COMMERFORD,

effective 0l-18-2016

through 02-16-2016and

was in the

"account" name of Sean

COIMMERFORDrom l2-l

6-201 throush

01 1

8-20

6.


10/17

SOCIAL MEDIA

32.

On 02-17-2016,

embers

f the DEA

conducted search f

telephone

umber

203-892-8592

ithin

a

query

unction

available

n the socialmediawebsiteFacebook.

he

result

of the

query

showed

hat elephone umber

203-892-8592s

associated

ith

a Facebook

"profile"

of "Brad

Commerford."

BACKGROUND

TO

STORED COMMUNICATIONS

33. In

my

training

and experienceo have earned

hat Verizon Wireless s

a

company

that

provides

cellular

telephone

access to the

general

public,

and

that stored

electronic

communications, ncluding retrievedand unretrievedvoicemail, text, and multimedia messages

fbr Verizon Wireless

subscribers

may

be

located

on the computers

of Verizon

Wireless.

Further,

I

am aware that

computers

located at Verizon

Wireless contain information and

other stored

electronic communications

belonging to unrelated hird

parties.

34. Among

the

services commonly offered

by

wireless

phone providers

is

the

capacity to

send

short

text

or

multimedia

messages

photos,

audio,

or

video)

from

one

subscriber's

phone

or wireless

device

to

another

phone

or

wireless

device

via

one or more

wireless

providers.

This

service

s

often referred o as

"Short

MessageService"

("SMS")

or

"Multimedia

Messaging

Service"

("MMS"),

and is often referred

to

generically

as "text

messaging"

or

"wireless messaging."

Based on my knowledge

and

experience,

believe

that

stored

electronic

communications,

ncluding

SMS and MMS messageshat have

been sent

or

receivedby subscribers,may be stored by Verizon Wireless for short periods ncident to and

following

their

transmission.

In addition,

providers

occasionally

etain

printouts

from

original

storage

of text

messages

or

a

particular

subscriber's

ccount.

35. Wirelessphone

providers

ypically retain

certain ransactional nformation

about


11/17

the

use

of

each

telephone,

voicemail,

and

text-messaging

account

on

their systems.

This

infbrmation

can

nclude

og

files

and

messaging

ogs

showing

all activity

on

the account,

such

as

local

and

long

distance

elephone

connection

ecords,

ecords

of

session

imes

and

durations,

lists

of

all

incoming

and

outgoing

telephone

numbers

or

e-mail

addresses

ssociated

with

particular

elephone

alls,

voicemail

messages,

nd

text

or

multimedia

messages.

providers

may

also

have

nformation

about

the

dates,

imes,

and

methods

of

connecting

associated

with

every

communication

n

which

a

particular

cellular

device

was

nvolved.

36.

Many

wireless

providers

retain

information

about

the location

in

which

a

particular communicationwas transmittedor received. This information can include dataabout

which

"cell

towers" (i.e.,

antenna

owers

covering

specific

geographic

areas) eceived

a radio

signal

from

the

cellular

device

and

thereby

transmitted

or received

the

communication

in

question.

37

Wireless

providers

may

also

retain

text

messaging

ogs

that include

specific

information

about

text

and

multimedia

messages

ent or

received

rom

the

account,

such

as

the

dates

and

times

of

the

messages.

A provider

may

also

retain

information

about

which

cellular

handset

or

device

was

associated

with

the

account

when

the

messages

were

sent

or

received.

The

provider

could

have

this

information

because

ach

cellular

device

has

one

or

more

unique

identifiers

embedded

inside

it.

Depending

upon

the

cellular

network

and the

device,

the

embedded

nique

dentifiers

or

a cellular

device

could

take

several

different

forms,

ncluding

an

Electronic

Serial

Number

("ESN"), a Mobile Electronic Identity Number (,.ME1N,'),a Mobile

Identification

Number

("MIN"),

a

Subscriber

dentity

Module

("SIM"),

an

International

Mobile

Subscriber

dentifier

("IMS["),

or

an International

Mobile

Station

Equipment

dentity (..IMEI").

When

a cellular

device

connects

o

a cellular

antenna

or

tower,

it

reveals

ts

embedded

unique


12/17

identifiers

to the

cellular

antenna

or tower

in

order

to

obtain

service,

and

the cellular

antenna

or

tower

records

hose

dentifiers

as

a

matter

of course.

38'

Wireless

providers

also

maintain

business

ecords

and

subscriber

nformation

for

particular

accounts.

This

information

could

include

the

subscribers'

ull

names

and

addresses,

the

address

o

which

any

equipment

was

shipped,

he

date

on which

the

account

was

opened,

he

length

of

service.

he

types

of

service

utilized,

the

ESN

or

other

unique

dentifier

for

the

cellular

device

associated

ith

the

account,

he

subscribers'

Social

Security

Numbers

and

dates

of

birth,

all

telephone

numbers

and

other

dentifiers

associated

with

the account,

and a

description

of the

servicesavailable o the accountsubscribers. n addition,wirelessproviders ypically generate

and

retain

billing

records

or

each

account,which

may

show all

billable

calls

(including

outgoing

digits

dialed).

The providers

may

also have

payment

nformation

for

the account,

ncluding

the

dates

and

times of payments

and the

means

and

source

of

payment (including

any

credit

card

or

bank

account

number).

39-

In some

cases,

wireless

subscribers

may

communicate

directly with

a wireless

provider

about issues

elating

to the

account,

such

as technical problems,

billing inquiries,

or

complaints

flom

other

users.

Wireless providers

typically

retain

records

about

such

communications,

ncluding

records

of

contacts

between

the

user

and the

provider's

support

services,

as

well

records

of any

actions

taken

by the

provider

or user

as a result

of

the

communications.

40- On 02-17-2016,members f the DEA NHDO TDS issued preservation rder o

Verizon

Wireless.

The

order

requested

hat

Verizon preserve

all text

message

ommunications

occurring

over

telephone

number

203-892'8592

hrough

02-17-2016.

have

sincecommunicated

with

Verizon

that the preservation

equest

was

received

and

processed.

Through

my

training

and


13/17

experience,

understand

hat

text message

ommunications

t

Verizon

exist or

periods

of time,

typically

not

exceed

en

(10)

days,and

hat hese

ext

messages

ay

be

preserved

nd

provided

to

law

enforcement

ith

legal

process.

Based

ponmy

training

and

experience,eview

of text

messages

xchanged

etween

Victim

#3

and

COMMERFORD,

and other

aspects

f this

investigation,

believe

hat

the above

eferenced

ext

messages

reserved

y Verizon

will

provide

additional

evidence

with

respect

o

the illegal

drug sales

of COMMERFORD

o

Victim#3

and

others.

INFORMATION

TO

BE

SEARCHED

AND THINGS

TO

BB

SEIZED

41. I anticipate xecutinghe searchwarrantunder he ElectronicCommunications

Privacy

Act,

n

particular

8 U.S.C.

$

2703(a).2703(b)(l)(A)

nd

2703(cXl)(A),

y

using

he

warrant

o require

Verizon

Wireless

o disclose

o

the

government

opies

of the records

ndother

information including

he

content

of communications)

articularly

escribedn

Section

of

Attachment

B.

Upon

receipt

of

the infonnation

described

n

Section

of Attachment

B,

government-authorized

ersons

will

review

that

infbrmation

o locate

he items

described

n

Section

I

of Attachment

.

CONCLUSION

42.

I submit

hat

this affidavit

supports robable

ause

o

believe hat,

n

February

2016,

Bradley

COMMERFORD

DOB

xx/xx/I995)possessed

ith

the ntent

o

distribute

nd

distributed

mixture

and

substance

ontaining

detectable

mount

of

heroin,

a

Schedule

controlled ubstance,n violation f 2l U.S.C.$$ 8a1(a)(l)and841(b)(lXC).As a result,

request

hat

he

attached

omplaint

ssue.

43.

In

addition,

request

hat

he

Court ssue

he

proposed

earch

arrant.

his

Court

has

urisdiction

o issue

he

requested

arrant

ecause

t is

"a court

of competent

urisdiction"

as


14/17


15/17

ATTACHMENT A

Property

o Be Searched

This warrant

applies

o infbrmation

associated ith the

account or telephone

umber

(203) 892-8592,which is stored at premisesowned, maintained, ontrolled,or operatedby

Verizon

Wireless,

wireless

rovider

eadquarteredt Basking

Ridge,

New Jersey.


16/17


17/17

associated

ith

the

account,

ocial

Security

number,

date

of

binh,

telephone

umbers,

nd

other

identifiers

ssociated

ith

the

account;

f'

oeqit3o

billing

records,

howing

ll

billable

alls

ncluding

utgoing

igits,

rom

bQ//

January

6,

20

$

to

fresent;

g'

AII payment

nformation,

ncluding

dates

and

imes

of

payments

nd

means

f)$27

source

of

payment

including

any

credit

or

bank

account

umber),

rom

January

26,

20tX;

present;

lI.

Information

o

be

seized

y

the

government

All informationdescribed bove n Section that constitutesruits, evidenceand

instrumentalities

f

violations

f

2l

U.S.c.

$

sal(a)(l)

(possession

ith

intent

o

distribute,

nd

distribution

of,

heroin)

and,

21

U.S.C.

$

846

(conspiracy

o

distribute

heroin)

involving

BRADLEY

COMERFORD

ince

August

1,

2015,

ncluding,

or

each

ccount

r

identifier

isted

on

Attachment

,

information

ertaining

o the

ollowing

matters:

a'

the

illegal

procurement,

ossession

r

distribution

of

controlled

substances.

including

ut

not

imited

o

heroin;

b'

Records

elating

to

who

created,

used,

or communicated

with

the

account

or

identifier,

ncluding

ecords

bout

heir

dentities

nd

whereabouts.

Documents

COMMERFORD Bradley Affidavit