Nyesom Ibeh Affidavit

8/3/2019 Nyesom Ibeh Affidavit

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IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRG INIA

Alexandria Division

UN ITED STATES OF AMERICA

NYESOM COLLINS IBEH,

Defendant.

Case No. 1:1 i-j 41

AMENDED AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

1, Jason McGraw, 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 theWashington Dulles InternationalAirport. My duties as a Special Agent with ICE 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 theUnited StatesCode. I am a graduate of the Federal Law Enforcement Training Center atGlynco, Georgia.

2. I am an "investigative or law enforcement officer" of the United States withinthemeaning ofTitle 18, United States Code, Section 2510(7), that is,an officer of theUnited 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 October 7, 2011, in Loudoun County, Virginia, within the Eastern District of Virginia,NYESOM COLLINS IBEH imported 100grams or more of a mixture or substance containing a

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detectable amount of heroin, a Schedule I controlled substance, into the United States, inviolation ofTitle 21, United States Code, Section 952.

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 tothe government. I have set forth only those facts necessary to support a finding of probablec a u s e .

Probable Cause

6. On or about October 7, 2011, IBEH arrived at Dulles International Airport, inLoudoun County, Virginia, within the Eastern District ofVirginia, on a flight that originated inRome.

7. Officers with Customs and Border Protection (CBP) referred IBEH to a secondaryinspection area. IBEH told CBP officers that he intended to travel on to Orlando, Florida for avacation at Disney World. However, documents in IBEH's possession indicated that he wasinstead traveling to Baltimore, Maryland.

8. CBP officers also noted that IBEH's abdomen was abnormally rigid. IBEHagreed to have his abdominal area x-rayed.

9. IBEH's x-rays indicated the presence of foreign bodies in his abdomen. CBPofficers then observed IBEH expel pellets from his rectum. CBP officers field-tested thecontents ofone of the expelled pellets, which tested positive for the presence of heroin. The totalgross weight of all of the pellets expelled by IBEH was 404.4 grams.

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10. IBEH acknowledged that he swallowed the pellets, which he understoodcontained drugs.

Conclus ion

11. Based upon the above information and my training and experience, I submit thatthere is probable cause to believe that on or about October 7,2011, in Loudoun County, Virginia,within the Eastern District ofVirginia, NYESOM COLLINS IBEH imported 100 grams or moreof a mixture or substance containing a detectable amount of heroin, a Schedule I controlledsubstance, into the United States, in violation ofTitle 21, United States Code, Section 952.

Documents

Nyesom Ibeh Affidavit