Free Redacted Document - District Court of Delaware - Delaware

Case 1 :06-mj—OO1 1 2-M PT Document 3 Filed O9/20/2006 Page 1 of 4 I
AO ?lv(Rev. l2/93) Criminal Complaint O
~ United States District Court 1 g
DISTRICT OF DELAWARE
UNITED STATES OF AMERICA
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· Criminal Complaint 06- HRM
BRIAN KEITH MYERS __:,
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I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my
knowledge and belief. On or about May 22, 2006, in New Castle County, in the District of Delaware defendant,
Brian Keith Myers (Track Statutory Language of Offense)
did knowingly distribute 50 grams or more of a mixture and substance containing a detectable amount of cocaine base
in violation of Title 21 United States Code, Section(s) 841{a)g 1 L and b{1l(Al .
I further state that I am a(n) Special Agent, DEA and that this complaint is based on the following facts:
Official Title
SEE ATTACHED AF F IDAVIT
Continued on the attached sheet and made a part hereof: YES
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Signature of Complai t
F l L E D David Hughes
Special Agent
SEP Z O 2006 Drug Enforcement Administration
I T COURT I
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Sworn to before me and subscribed in my presence, in

Case 1 :06-mj—OO112—MPT Document 3 Filed O9/20/2006 Page 2 of 4
AO _91r(Rev. l2/93) Criminal Complaint E ‘
September 20, 2006 ,_ at Wilmington, DE
Date City and State
Honorable Mary Pat Thynge. /
United States Magistrate Judge _ ,..**.1...; ,•&....(, ; _
Name & Title of Judicial Officer e 0 udicial Of r I `

p Case 1 :06-mj—OO112—MPT Document 3 Filed O9/20/2006 Page 3 of 4
AFFIDAVIT
DAVID B. HUGHES, being duly sworn, states as follows;
I. I am a Special Agent (S/A) with the Drug Enforcement Administration (DEA) and
have been so employed for approximately five years and one half years. Prior to my employment
with the DEA, I was employed as a Trooper with the Maryland State Police for approximately six
years. During my law enforcement tenure, I have participated in numerous investigations into the
unlawful distribution of narcotics in violation of federal and state laws. In the course of my
duties, I have conducted or participated in physical and electronic surveillance, undercover
transactions, the execution of search warrants, debriefing of informants, interviews of witnesses,
reviews of tape-recorded conversations involving drug trafficking activities, and analyses of
telephone toll records and other records kept by or relating to drug traffickers. Through my
training, education and experience, I have become familiar with methods in which illegal drugs
are imported, manufactured and distributed; methods of payment for such drugs; and methods
used by drug traffickers to avoid law enforcement detection, including methods used to disguise
the source and illegal nature of drug proceeds. I have also testified as an expert witness in
federal and/or state courts regarding the distribution, transportation and concealment of illegal
drugs.
2. This Affidavit is in support of a criminal complaint against and arrest warrant for
i Brian Keith MYERS, dfofb 'l972. I am the case agent responsible for the investigation in
I aid of which this application is being made, This Affidavit is based on my personal knowledge
and observations as well as information provided to me by other law enforcement officers.
Because this Affidavit is solely for the purpose of establishing probable cause, not all facts
relating to the investigation are included herein.
3. On or about May 22, 2006, a DEA Confidential Source (hereinafter referred to as the "CS"),
rmder the direction and control of agents/officers, initiated a series of consensually monitored tape-
recorded telephone calls to MYERS regarding the purchase and delivery of four ounces of crack cocaine.
During the telephone calls, the CS and MYERS made arrangements to meet in Newark, Delaware for the
purchase and delivery of four ounces of crack cocaine. Pursuant to the telephone calls, members of the
DEA Wilmington, Delaware Resident Office, the Newark Police Department Special Investigations Unit,
the Delaware State Police Special Investigations Unit, and the New Castle County Police Department
Drug Control Unit established surveillance in and around the area of the meet location in Newark,
Delaware awaiting MYERS’ arrival. Shortly thereafter, agents/officers observed MYERS meet with the
CS. During the meeting, the CS purchased four ounces of crack cocaine from MYERS with $3,400.00 in
United States Currency (Official Advanced Government Funds). The CS and the CS’s vehicle were
searched for contraband (money and/or drugs) prior to and after the purchase of the four ounces of crack
cocaine with negative results. The CS was equipped with an electronic monitoring and recording device
during the transaction allowing agents/ofliicers to conternporaneously monitor the transaction between the
CS and MYERS.
4. On September 18, 2006, agents/officers officers ofthe Wilmington, Delaware Resident
Office executed the arrest of MYERS at the Bluffs Apartment Complex adjacent to building 400

Case 1 :06-mj—OO112—MPT Document 3 Filed O9/20/2006 Page 4 of 4
I in Newark, Delaware. Immediately thereafter, MYERS was verbally advised of his rights
pursuant to Miranda v. Arizona but was not questioned at that time.
5. Upon arrival to the DEA Wilmington Resident Office on September 19, 2006, MYERS
was again advised of his Miranda Rights and signed a written waiver of those rights. Post
Miranda, MYERS admitted to distributing the aforementioned four ounces of crack cocaine as
well as quarter pound quantities of cocaine on a regular basis.
6. The suspected crack cocaine purchased on or about May 22, 2006 from MYERS by the CS
field-tested positive and was later analyzed by the DEA Northeastern Regional Laboratory and determined
to be 109.9 net grams of cocaine base.
7. Based on the foregoing facts and my training, knowledge and experience, your Affiant
submits that there is probable cause to believe that MYERS has violated Title 21, United States
Code, Section 84l(a)(l) and (b)(l)(A), by distributing more than fifty grams of a substance
r containing a detectable amount of cocaine base, and therefore respectfully requests that the Court
issue a criminal complaint and arrest warrant for MYERS.
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Special Agent D i ughes
Sworn to and subscribed before "
me this ji-fday of September 2006.
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[ I V Aff “ l
1 The H nora le M hynge p
S nite ‘ tates Magis te Judge for the District of Delaware
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