Free Complaint - District Court of Delaware - Delaware

Case 1:06-mj-00088—lV|PT Document 1 Filed 07/21/2006 Page 1 of 3
A0 91 (Rev. 12/93) Criminal Complaint E
United States District Court
DISTRICT OF DELAWARE
UNITED STATES OE AMERICA
v.
Criminal Complaint
ANTHONY MARK BRISCOE
CASE NUMBER: 06- $:%..1
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 July 20, 2006 in New Castle County, in the District of Delaware, defendant did
knowingly possess with intent to distribute more than fifty grams of cocaine base, a/k/a crack cocaine,
in violation of Title 21 United States Code, Section(s) 84lga)[l Q & gb); l MA) .
I further state that I am a(n) Special Agent and that this complaint is based
Official Title
on the following facts:
See attached Affidavit
Continued on the attached sheet and made a part hereof: Yes
Signature of Complaiiant
David Hughes
Special Agent
Sworn to before me and subscribed in my presence,
July 2l, 2006 at Wilmington, DE
Date City and State
Honorable Joseph J. Earnan, Jr. QQ- x rl. Pi?
United States District Judge \»<” '-·“"°’~»#°—·‘a -·f/' f “1,·A..
Name & Title of Judicial Officer Sigiflat re ofJu-dicia Officer
F I L E D
J JUL 2 1 EGE15 '
as

Case 1 :06-mj-00088—lV|PT Document 1 Filed 07/21/2006 Page 2 of 3
AFFIDAVIT
DAVID B. HUGHES, being duly sworn, states as follows:
1. 1 am a Special Agent with the Drug Enforcement Administration (DEA) and have
been so employed for approximately five 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 state courts regarding the distribution, transportation and concealment of illegal
drugs.
2. This Affidavit is in support of a criminal complaint against Anthony Mark
BRISCOE. I am the case agent responsible for the investigation in 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 July 19 and July 20, 2006, Agents/Officers of the DEA Wilmington,
Delaware, Resident Office conducted an investigation, during the course of which a Confidential
Source (hereinafter referred to as the "CS"), acting under the direction and control of the DEA,
initiated a series of consensually monitored and tape-recorded telephone calls to BRISCOE
regarding the purchase and delivery of two ounces of crack cocaine. During these calls,
BRISCOE agreed to meet with and deliver two ounces crack cocaine to the CS at 11:00 a.m., in
the 1200 block Claymont Street, Wilmington, Delaware.
4. Subsequently, at approximately 10:30 a.m., Agents/Officers established
surveillance in and around the area of the 1200 block of Claymont Street, Wilmington, Delaware,
awaiting the arrival of BRISCOE. At approximately 11:02 a.m., Agents/Officers observed
BRISCOE arrive in the 1200 block of Claymont Street, Wilmington, Delaware and park
southbound on Claymont Street, Wilmington, Delaware adjacent to the CS. BRISCOE was the
driver and lone occupant of a blue Chevrolet Impala. At approximately 11:03 a.m.,
Agents/Officers observed the CS meet with BRISCOE. At that time, Agents/Officers placed
BRISCOE under arrest. A search of the Chevrolet Impala incident to arrest revealed
approximately two ounces of crack cocaine (56.4 net grams) and approximately a quarter ounce
of powder cocaine (7.6 net grams) inside the vehicle.

Case 1 :06-mj-00088—IV|PT Document 1 Filed 07/21/2006 Page 3 of 3
5. All of the suspected crack cocaine and powder cocaine noted above field—tested
positive for the presence of cocaine. Based upon my training, knowledge and experience, I
believe that the seized substances noted above are crack cocaine and powder cocaine. This
conclusion is based on factors including the color, texture, smell, and appearance of the
substances.
6. Based on the foregoing facts, I submit that there is probable cause to believe that
Anthony Mark BRISCOE has committed violation of Title 21, United States Code, Sections
84l(a)(1) and (b)(I)(A), possession with intent to distribute more than fifty grams of a mixture
and substance containing a detectable amount of cocaine base.
a »"
·€_ .-1 A I
Special Agent David B. Hughes
Drug Enforcement Administration
Sworn to and subscribed before
me this 21st day of July 2006.
A"/;,.·—`i\.;'*‘.;]_,la°;.-·p_," J/""· J L_ Q.--·v— i
HG;N?{ABL J0s‘éph J. Farnan Jr.
Unite States District Court
District of Delaware
2