Free Complaint (Sealed) - District Court of Delaware - Delaware

Case 1 :06-cr—00050-GIVIS Document 2 Filed 04/26/2006 Page 1 of 3
A0 91 (Rev. 12/93,) Criminal Complaint ll
` i _ A I United States District Court
DISTRICT OF DELAWARE
UNITED STATES OF AMERICA i
v.
Crim` al Complaint 06- 5QH - M•°’T“`
WILLIE BROWN op,/(IU
0/`S (Name and Address of Defendant) 4 ppg/J
I, the undersigned complainant, being duly swom, state the following is tme and correct to the best of my
knowledge and belief On or about November 30, 2005 and March 16, 2006, in Kent County, in the District of _
Delaware defendant, Willie Brown (Track Statutory Language of Offense)
did on November 30, 2005, distribute 50 grams or more of a mixture and substance containing a detectable amotmt of cocaine in violation of 21
U.S.C. § 841(a)(l) and (b)(l)(A), and on March 16, 2006, did aid and abet the distribution of 50 grams or more ofa mixture and substance
containing a detectable amount of cocaine in violation of2l U.S.C. § 84l(a)(l) and (b)(l)(A) and 18 U.S.C. § 2
in violation of Title United States Code, Section(s) see above .
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 AFFHDAVIT
Continued on the attached sheet and made a part hereof: YES
/
Sign lainant
Jeffr urm
Spec1al Agent
Drug Enforcement Administration
Swom to before me and subscribed in my presence,
April 26,2006 at Wilmington, DE
Date City . • e - tes,
Honorable Mary Pat Thynge -/ /`
United States Ma istrate Jud e A ·L-
Name & Title ofJudicial Officer ture of Iudicia fic r

Case 1:06-cr-00050-GIVIS Document 2 Filed 04/26/2006 Page 2 of 3
I AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
Your Affiant Jeffrey Dunn, being duly swom and deposed, states as follows: e
1. Your Affiant is a Special Agent with the United States Drug Enforcement Administration
(hereinafter "DEA"). As such, I am an investigative or law enforcement officer ofthe United
States within the meaning of Title 18, United States Code, Section 2510(7) and empowered by
law to conduct investigations and to make arrests for offenses enumerated in Title 18, United
States Code, Section 2516. I have been a Special Agent with DEA for approximately nine years,
currently assigned to the Dover, Delaware, Resident Office. Among other duties, I am now
responsible for the instant investigation.
2. During my nearly nine years with the DEA, I have participated in numerous drug and
money laundering investigations during the course of which I have conducted physical and wire
surveillance, executions of search warrants, reviews and analyses of taped conversations and
records of drug traffickers. Therefore, I am familiar with the manner in which illegal drugs are
imported and distributed, the method of payment for such drugs, and the efforts of persons
involved in such activity to avoid detection by law enforcement, as well as methods used to
finance drug transactions and launder drug proceeds.
3. On November 30, 2005, DEA formulated plans to have an undercover agent ("UC1")
purchase crack cocaine from Willie Brown. Acting on instructions from DEA, a confidential
source placed a call to 302—270—9165 to arrange a meeting between Brown and UC1. At or
around 6:15 p.m., UC1 traveled to a Laundromat in the 1100 block of South Bay Road in Dover
to meet with Brown. At about 6:16 p.m., a light colored Buick Rendezvous anived at the
Laundromat and parked next to a blue Nissan Quest. Brown got out of the Rendezvous and
walked to the driver's side door of the Nissan. At the same time, UCI got out of UCl's vehicle
and also approached the blue Nissan Quest. Brown opened the driver side door of the blue
Nissan Quest door and reached under the driver's seat. UC1 opened the passenger side door and
placed $1,800 under the passenger seat. UC1 then approached Brown, shook his hand, and
walked to the driver's side of the blue Nissan Quest. UC1 reached under the driver's seat and
retrieved two small clear plastic baggies containing an off—white chunky substance. UCl then
went up to Brown and told Brown that if the crack cocainewas "right", then UC1 would "step it
up." Brown responded "alright." ' A 4
4. The substance in the two plastic baggies was subsequently sent to the North East
Regional Lab for analysis. The lab indicated that substance was cocaine base with a net weight
of 55.6 grams.
5. On March 16, 2006, at approximately 4:44 p.m., UC1 telephoned Willie Brown at (302)
270-9165. During the conversation, UCI made arrangements with Brown to purchase
approximately 169 grams (6 ounces) of crack cocaine (cocaine base) from Brown at a
Laundromat in Dover, Delaware.
6. On March 16, 2006, at approximately 8:40 p.m., Brown telephoned UC 1 and directed

Case 1:06-cr-00050-GIVIS Document 2 Filed 04/26/2006 Page 3 of 3
UCI to the Target department store in Dover. Brown also told UCI that he (Brown) would be
arriving in a black car. As instructed, UCI drove to Target, where UCI observed an unknown
male (subsequently identified as "AUK") walk from a dark colored car and motion to UCI. UCI
then drove the undercover vehicle (hereafter "UCV") towards AUK. AUK then entered the front
passenger seat of the UCV and retrieved a clear plastic bag containing an off-white rock-like
substance from his (AUK’S) jacket pocket. UCI then asked, "six for forty—eight?' (meaning six _
ounces of crack cocaine for forty-eight hundred dollars)" AUK replied, "yeah, that is the price
you agreed on." AUK then handed the clear plastic bag with the off-white rock-like substance to
UCI, who in tum gave AUK $4,800 in Official Authorized Funds. AUK then exited the UCV
and UCI departed the area.
7. Following the undercover purchase, UCI retumed to the DEA Dover Resident Office.
After retuming, the off-white rock like substance was field tested. The substance tested positive
for the presence of cocaine. The substance was also weighed and found to weigh approximately
II3 grams (four ounces), and not the agreed upon I69 grams (six ounces). The substance was
subsequently sent to the DEA North East Laboratory where is was confirmed to be cocaine base
with a net weight ofI06.5 grams.
8. Due to the discrepancy of the weight of the crack cocaine, UCI telephone Brown at (302)
270-9165. UCI and Brown agreed to meet at a later date where Brown would give UCI the
approximately 56 grams (two ounces) of crack cocaine that was owed to UCI by Brown.
Based on the above information, Ibelieve that there is probable cause that on or about
November 30, 2005, Willie Brown violated Title 2I United States Code § 84I(a)(I) and (b)(I)(a)
by distributing 50 grams or more of a mixture and substance containing a detectable amount of
cocaine base, and that on March I6, 2006, Willie Brown violated Title 2I United States Code §
84I(a)(I) and (b)(l)(a) and Title I8, United States Code Section 2 by aiding and abetting the
distribution of 50 grams or more of a mixture and substance containing a detectable amount of
cocaine base.
N4" AL / 4 .
pecial Agent
.• »• ; Enf » ent Administration
Subscribed and swom to before me on
th' · » - .; ofApril 2006.
I luv M 41
e agistra J ge Mary Pat Thynge _
'Not all portions ofthe undercover consensual recordings are described herein. To the
extent that quotations are used, the quoted segments are based on summaries of the recordings
and not final transcripts. All dates and times are approximate.
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