AFFIDAVIT
Michael
J. Kreizenbeck, Special Agent, Federal Bureau of Investigation
(“FBI”), being duly sworn states:
1.
I have been a Special Agent of the FBI for eighteen months and have
been assigned to the Public Corruption Squad of the Boston
office of the FBI since July 2005. Prior to that, I worked for a brief
period in a consulting firm, and served for four years as an officer
in the United States Marine Corps. I am currently a Captain in the
United States Marine Corps inactive ready reserves. In my current
assignment, I have been involved in the investigation of public corruption
and other offenses which are violations of federal statutes within
the jurisdiction of the FBI. Additionally, I have worked with, and
under the direction of, other Special Agents and law enforcement personnel
experienced in the investigation of public corruption offenses. I
personally participated in the investigation of violations of federal
law by ROBERTO E. PULIDO, CARLOS A. PIZARRO, NELSON CARRASQUILLO (“defendants”),
and others in the course of the investigation.
2.
This affidavit is submitted in support of a criminal complaint charging
Boston Police Officers ROBERTO E. PULIDO, CARLOS A. PIZARRO, and NELSON
CARRASQUILLO with knowingly and intentionally combining, conspiring,
confederating and agreeing with each other and with other persons,
known and unknown, to distribute, and to possess with intent to distribute,
a quantity or mixture of a substance containing cocaine, a Schedule
II controlled substance, that quantity being in excess of 5 kilograms
(to wit: 100 kilograms) in violation of Title 21, United States Code,
Section 841 (a)(1), all in violation of Title 21, United States Code,
Section 846.
3.
This affidavit is the product of a larger investigation into the criminal
activities of PULIDO, PIZARRO, CARRASQUILLO, and others which has
spanned a period of two and one-half years. The investigation extended
over this period of time in order to uncover the full extent of these
officers’ criminal activities, and because PULIDO unwittingly provided
extensive information about the illegal conduct of other Boston police
officers, other public officials, and private citizens. Since this
affidavit is being submitted for a limited purpose of establishing
probable cause to believe that PULIDO, PIZARRO and CARRASQUILLO have
committed a violation of 21 U.S.C. 846, I have not included each and
every fact known to me concerning this investigation.
The foregoing facts are based on my personal participation
in this investigation, as well as reports made to me by other agents
of the FBI (including those working in an undercover capacity), reports
provided to me by members of the Boston Police Department, and from
a review of information provided to FBI agents and other law enforcement
by individuals associated with this investigation. A substantial portion
of the evidence in this affidavit is based on information from FBI
undercover agents and employees (UCEs) who
met directly with PULIDO, PIZARRO< and CARRASQUILLO in the course
of this crime, consensually recorded conversations with one or more
of the defendants by a cooperating witness, and information obtained
from Court-authorized interceptions of PULIDO’s
telephone over a five month period.
BACKGROUND OF DEFENDANTS
4.
ROBERTO E. PULIDO, a.k.a. ROBERT PULIDO, “KIKO”, and ANTHONY WILLIAMS
(“PULIDO”) (YOB 1965) has a residence at 57 Leighton Road in the Hyde
Park section of Boston, Massachusetts.
PULIDO has been an officer with the Boston Police Department
(“BPD”) since 1996. He is currently assigned to the Special Operations
Division, Mobile Operations Patrol. Prior to this assignment, he was
a patrol officer assigned to Area E-13 (Jamaica Plain). Prior to joining
BPD, PULIDO served as an officer with the Massachusetts Bay Transportation
Authority Police and the Boston Municipal Police Department.
5.
CARLOS A. PIZARRO (“PIZARRO”) (YOB 1969) has a residence at 8
Lenoxdale Avenue
in Boston, Massachusetts. PIZARRO has been an officer with the BPD since
1996. PIZARRO and PULIDO attended the Boston
Police Academy
at the same time. PIZARRO is currently assigned to Area D-4 (South
End), where he is assigned to patrol duties.
6.
NELSON CARRASQUILLO a/k/a “NELLY”, and JOHN
SCANDONE (“CARRASQUILLO”) (YOB 1971) has a residence at 101
Gallivan Blvd.
In the Dorchester section of Boston,
Massachusetts. CARRASQUILLO has
been an officer with the BPD since 1999. CARRASQUILLO is currently
assigned to the Special Operations Division, Mobile Operations Patrol;
he transferred to that assignment on the same day as PULIDO, and the
men often work together on assignments. Prior to this assignment,
he was a patrol officer assigned to Area B-2 (Roxbury). Prior to becoming
a police officer with the BPD, CARRASQUILLO worked as a police cadet
at the BPD from 1996 to 1999. While a cadet, CARRASQUILLO served in
Area E-13 at the same time as PULIDO.
ELECTRONIC
INTERCEPTIONS
7.
As noted above, a portion of the evidence cited in this affidavit
is from conversations of PULIDO, PIZARRO, CARRASQUILLO, and others
which were intercepted over PULIDO’s mobile
telephone between December 2005 and June 2006. On December
1, 2005, Special Agents of the Federal Bureau of Investigation
obtained authorization from the United States District Judge Reginald
C. Lindsay to intercept wire communications over a mobile telephone
used by PULIDO and assigned telephone number (617) 212-1969. The first
order authorized the interception of calls between
December 5, 2005, through January 3, 2006. Four subsequent orders were issued
by Judge Lindsay upon the application of the United
States. The second order was issued
February 2, 2006, for calls intercepted
between February 4, 2006
and March 3, 2006.
The third order was issued on March
10, 2006, for calls intercepted between March
11, 2006, and April
8, 2006. The fourth order was issued on April
8, 2006, for calls intercepted between April 10, 2006, and May 7, 2006. The fifth order was issued on May 15, 2006, for calls intercepted
between May 16, 2006
and June 16, 2006.
DEFENDANTS’ CRIMINAL CONDUCT LEADING UP TO THE
DRUG PROTECTION OPERATIONS
8.
PULIDO’s criminal conduct first came to
the attention of the FBI in the course of an investigation into an
identity theft ring operation along the eastern seaboard of the United
States. A cooperating witness (CW)
had been acting as a runner for the identity theft ring, selling fraudulently
obtained retail store gift cards to regular buyers. Shortly after
beginning this work, the CW met with PULIDO and PULIDO expressed an
interest in purchasing the fraudulently obtained gift cards from him.
The CW had known PULIDO a number of years before this contact and
renewed his relationship with PULIDO when PULIDO sought to purchase
these cards. As that relationship developed, PULIDO began to disclose,
and to request the CW’s participation in,
as wide range of criminal activities. PIZARRO and CARRASQUILLO were
involved in a portion of these criminal activities. Set forth below
is a brief outline of the nature and scope of the criminal activities
in which the defendants engaged between November 2003 and the present
date.
9.
Identity Theft: At the outset of the investigation PULIDO was
purchasing fraudulently obtained retail store gift cards from an identity
theft ring operating along the eastern seaboard including Eastern
Massachusetts. The members of the identity theft ring,
using identifying information, such as name, address, date of birth
and social security number (“identifiers”), of innocent victims obtained
false identification documents in the names of the innocent victims,
but containing the photographs of members of the identity theft ring.
They then used these documents to open instant lines of credit at
retail outlets such as Lowe’s, Home Depot, BestBuy
and others. With these fraudulent credit lines, the members of the
ring obtained gift cards (or store credit cards) and merchandise.
Some of the gift cards were sold for half their face value to individuals
who knew that the cards had been fraudulently obtained. PULIDO was
one such purchaser. Early in their renewed relationship - during the
fall of 2004 – the CW explained to PULIDO that the cards were obtained
in a fraudulent manner; PULIDO acknowledged this but continued to
order them. Between November 2003 and March 2006, the CW delivered
over $148,000 in gift cards to PULIDO, of which PULIDO purchased approximately
$108,000 worth of cards at fifty percent of their face value. Approximately
$40,000 in cards were furnished to PULIDO
by the CW in payment for related illegal activities. The first approximately
$18,000 worth of cards sold by the CW to PULIDO were received by CW
from the identity theft ring. Subsequently, unknown to PULIDO, the
CW severed his ties with the identity theft ring, the FBI purchased
the gift cards, and the CW continued to represent to PULIDO that they
were obtained through fraudulent means. PULIDO would use these cards
himself to purchase items such as a plasma television set, expensive
gifts for his friends, family and a girlfriend. He also used the cards
to purchase building supplies for his part-time construction business.
In addition, from time to time, PULDIO would further distribute these
fraudulently obtained cards, sometimes selling them at a profit.
10.
PULIDO’s involvement in the identity theft
operation was not limited to buying and selling fraudulently obtained
gift cards. In December 2004, PULIDO agreed to provide “identifiers”
to the CW to be used by the identity theft ring to obtain fraudulent
lines of credit. Between December 2004 and March 2006, PULIDO provided
the names, dates of birth, social security numbers and other information
to the CW of over 160 separate individuals. The CW paid PULIDO over
$35,000 for the identifiers. Some of the identifiers belonged to individuals
PULIDO had arrested or stopped while working as a Boston Police officer.
PULIDO obtained other identifiers by running the Registry of Motor
Vehicles information for expensive vehicles PULIDO saw while working
or that were provided by the CW to PULIDO.
PULIDO used BPD computers to access and obtain this Registry information.
For instance, in one recorded conversation on June 2, 2005, PULIDO boasted, “it’s easy for me,
I just run people’s plates, you know. I go look for fucking fancy
ass cars and fucking run ‘em in like Brookline
and Cambridge…” In another
recorded conversation on June 27, 2005, during which he provided identifiers
for two persons, PULIDO said that he pulled one of them over for running
a red light and that he was driving a “$165,00 car”; PULIDO boasted,
“that mother fucker right there is gold.” In addition, on occasion
PULIDO would have an associate who worked at a local bank check the
credit histories of the individuals whose identifiers he provided
to the CW, and would indicate to the CW which ones of the persons
had high credit scores. From November 2003 until May 2006, PULIDO
was recorded more than 80 times discussing or participating in this
identity theft scheme.
11.
Dealing Narcotics: During the course of the investigation PULIDO
regularly imported from a foreign source, and distributed in the Boston
area, steroids (such as stanozolol, also
known as Winstrol, methandrostenolone,
nandrolone decanoate,
and testosterone), Schedule III controlled
substances. In addition to importing and selling steroids, PULIDO
used them himself. (For example, in one recorded conversation on October 14, 2005, PULIDO admitted to
grabbing a man by the hair and smashing his face on the rear of his
car, just after PULIDO had “done a shot of Winstral”
and was “hyped.”) One of PULIDO’s regular
customers for these illegal steroids was PIZARRO. PULIDO’s
principal source of steroids was an individual residing in Greece,
who, according to PULIDO, had fled from the United
States to avoid prosecution for distributing
ecstacy. PULIDO obtained steroids from this
source by ordering them over the telephone, and then making a deposit
into the source’s bank account in the United
States. PULIDO subsequently received
shipments of steroids via common carriers; PULIDO directed the packages
to at least five separate locations – including private homes and
businesses – to avoid detection. In one recorded conversation on May 5, 2005, PULIDO boasted, “the key
to mailing shit (steroids) here in this country is you gotta
mail it in photo paper. You know the paper, that fucking carbon paper…you
buy that paper, you wrap it in that and that’s it. There’s nothing
that can get an x-ray through that, and dogs can’t sniff through that.”
PULIDO also sold steroids to the CW on six occasions for a total of
approximately $4,500 in cash and gift cards. PULIDO’s
primary partner in this steroid distribution operation, referred to
herein as “Associate A,” is an individual who has been convicted of
a crime of violence and incarcerated on a narcotics offense. In the
one year period between May 2005 and May 2006, PULIDO was recorded
on more than 20 occasions discussing his importation, use, and distribution
of steroids and/or human growth hormone.
12.
PULIDO also agreed to assist the CW obtain ecstacy and Oxycontin. As described
below, in a recorded conversation on January 27, 2005, PULIDO discussed with the CW the possibility
that the CW sponsor illegal parties at which ecstacy
would be sold. PULIDO advised the CW that he should purchase “white
dove” ecstacy from Greece
at $50 a tab rather than lower quality ecstacy
from California. In
subsequent recorded conversations on March 1, September 6, and September 16, 2005, PULIDO agreed to
put the CW in contact with a source of ecstacy
and agreed to assist the CW in purchasing ecstacy.
In a recorded conversation March
1, 2005, PULIDO said to the CW, “I could do time or go
to jail” for this conduct. In a recorded conversation on October
24, 2005, PULIDO indicated that he was attempting to obtain
Oxycontin for the CW.
13.
The investigation has also revealed that Pizarro has been involved
in possession with intent to distribute heroin, and that when questioned
about his relationship with a well-known drug dealer by law enforcement
agents, he withheld information and/or provided
false information. An individual referred to herein as “Associate
D” admitted to the CW on June 28, 2006 that he used to sell 500-1000
“bricks” of heroin a month for PIZARRO> In addition, PULIDO told
the UCEs in a recorded conversation on May
24, 2006 that Pizarro had worked for a drug dealer in the past.
14.
After-hours Parties/Prostitution Protection: During the course
of the investigation, PULIDO was also regularly engaged in providing
protection for illegal unlicensed after-hours parties at a building
located at 24 Factory Street
in the Hyde Park section of Boston,
Massachusetts. The unlicensed parties
involved the illegal sale of alcohol and narcotics, nude dancers/prostitutes
and the sale of sexual favors by the dancers/prostitutes. PULIDO provided
protection from police intrusion into the parties, and was paid $600
for each party by the party operators for his service. According to
POLIDO, he said that he in turn made payments to one or more superior
officers in the Boston Police Department. PULIDO’s
primary partner in this after-hours party operation, referred to herein
as “Associate B,” is an individual who has been convicted on narcotics
distribution offenses, and has served a substantial period of incarceration
for narcotics crimes. On several occasions between November 2003 and
March 2006, at PULIDO’s invitation, the
CW attended these illegal after-hours parties. The CW attended illegal
after-hours parties on October 15, November 12 and December 18, 2004, and March 11, September 16,
November 25, and December
17, 2005. An entrance fee of $20-40 was charged. The dancers/prostitutes
would provide lap dances in a “boom-boom room” for which there was
an additional charge of $20-40. On occasion, the dancers/prostitutes
would provide oral sex for $35 and sexual intercourse for $100. On
several occasions the CW observed narcotics being consumed and distributed
in connection with these parties. According to recorded conversations
with PULIDO, the parties have taken place approximately once a month
for approximately five years. The parties were attended by as many
as 100 persons on a given evening, and included a combination of well-known
felons, including drug dealers, and law enforcement officers (some
who attended in uniform) including officers from the BPD and other
departments. PIZARRO was a regular attendee of these illegal after-hours
parties. In addition, at an illegal after-hours party on December
17, 2005, PULIDO introduced CW to CARRASQUILLO. POLIDO
told the CW that CARRASQUILLO is “a hustler, just like me.” In late
2004 and early 2005, the CW and PULIDO discussed the CW starting his
own after-hours parties, including parties which would include gambling.
PULIDO told him that he would assist him, and suggested that CARRASQUILLO
would provide protection for such parties. During the course of their
discussions, PULIDO suggested that CW hold the ecstacy
parties (also known as “water parties” because bottles of water are
sold with the ecstacy), and later agreed
to introduce the CW to an individual who could sell him ecstacy. Between November 2003 and May 2006, PULIDO was recorded
on approximately 20 occasions discussing his involvement in the protection
of these illegal after-hours parties.
15.
Obstruction of Justice/Robbery/Threats/Assault and Battery:
On or about March 29, 2005,
PULIDO retaliated against a former business partner, referred to herein
as “AssociateC,” by having a firearm and a distribution quantity
of heroin planted in his car. PULIDO then had an individual referred
to herein as “Associate D” anonymously call the BPD and report the
presence of a person with a gun and narcotics in a specific location.
Associate C was subsequently arrested and charged with firearm and
narcotics offenses. While Associate C was being held in custody, PULIDO
had Associate D enter Associate C’s home and rob Associate C of $40,000.
PULIDO admitted to these crimes in a recorded conversation on May
18, 2006. Associate C independently claimed during an interview
with Boston Police Department officers that he had been framed with
respect to this crime.
16.
In a separate incident on May 7,2006, PULIDO threatened another
business partner, referred to herein as “Associate E,” over a dispute
regarding the lease of the building at 24
Factory Street where the illegal after-hours
parties have been held. When Associate E told PULIDO that he was going
to lock him out of the business PULIDO responded, “…if the dog is
out and he tries to attack us, half of the dog is gonna
be hung on the front door and the other half is gonna
be hung on the rear door…Don’t let it go personal. If you want to
make it personal, after the dog it will be your wife, then it’ll be
your mother, then it’ll be your brother, and it’ll be your unborn
child.”
17.
In a separate incident, PULIDO reported to the CW in a recorded conversation
on July 20, 2005,
that an individual known to PULIDO had stolen a stereo out of PULIDO’s truck. First, PULIDO sought the CW’s assistance in harming the thief. Then PULIDO told the
CW that, “he knows I’m a cop so he knows I can’t touch him. If I touch
him I have to hit him from behind late at night , and I got to fuck
his ass up…I want to fuck him up and let him know why he is getting
fucked up.” PULIDO also admitted in a recorded conversation on October
14, 2005, that he had grabbed the man by the hair and beaten
him against his automobile. “I grabbed him right by the fucking hair.
BOOM! Right in front of my fucking tread.”
PULIDO told the CW to look at the back wheel of his car: “See something
missing, that was his face.” PULIDO went
on to explain, “I had my military gear on too. I had just came from
training…I had just done a shot of fucking Winstral (steroids). I was ready. Boy, I was hyped.”
18.
Money Laundering: In a recorded conversation on January 27, 2005, PULIDO said that he
was in the construction business with an illegal alien. PULIDO admitted
that he laundered money for that illegal alien and charged ten percent
for doing so. This conversation confirmed earlier conversations with
the CW in which PULIDO admitted to “washing” the illegal alien’s checks
for a fee.
19.
Insurance Fraud: During the course of this investigation both
PULIDO and Pizarro conspired to commit insurance fraud. On the first
occasion in March 2006, PULIDO told the CW that he was going to sell
a truck which PULIDO regularly drove bur which he had registered in
his girlfriend’s name to a “chop-shop” and then report to an insurance
company that it had been stolen. Rather than allow that to happen,
the CW told PULIDO that he would find a “chop-shop” for the vehicle.
Through this mechanism, unknown to PULIDO, the FBI provided funds
to purchase the truck, and it was not sold to a “Chop-shop.” On April
4, 2006, PULIDO had his girlfriend file a false police
report, claiming that the truck had been stolen. A subsequent recorded
call on June 13, 2005 between PULIDO and his girlfriend revealed
that they had also filed a false claim with an insurance company claiming
that the truck had been stolen.
20.
In May and June 2006, PIZARRO sought to undertake a similar insurance
fraud scheme with PULIDO’s and the CW’s assistance. On several occasions, PIZARRO was recorded
arranging for the CW to sell his truck so that he could subsequently
report the vehicle stolen. On June
28, 2006 the CW took possession of the vehicle at PIZARRO’s
direction.
21.
Other Crimes: During the course of the investigation, in other
recorded conversations PULIDO admitted to smuggling illegal aliens
into the United States
for $5,000 per person, providing sensitive Boston Police Department
information to one or more persons other than law enforcement officers,
fixing tickets, trafficking in stolen electronics, and aiding and
abetting loan sharking.
FIRST DRUG PROTECTION OPERATION (40 KILOGRAMS)
22.
In early December 2005, after the FBI had learned the breadth of PULIDO’s
criminal activities, and after learning that PULIDO would engage in
criminal activities with other Boston
police officers, such as CARRASQUILLO and PIZARRO, the CW, at the
FBI’s direction informed PULIDO that his “cousin” was seeking to bring
contraband into Boston.
The CW indicated that his cousin needed protection to insure that
the contraband was not intercepted by the police, and was seeking
a location at which the contraband could be loaded from one truck
to another. PULIDO readily agreed. For instance, in one recorded conversation
on December 28, 2005,
the CW and the PULIDO met for the CW to deliver a fraudulent gift
card, to obtain identifiers from PULIDO, and to pay for growth hormones
he had ordered from PULIDO. In the course of that conversation the
CW told PULIDO that he was soon to meet with his “cousin” and that
he was counting on PULIDO for security when the truckload of contraband
arrived. PULIDO agreed and said he would listen on the police radio
for the CW. They discussed “safety” issues including the best location
for the truck to be unloaded. In another recorded conversation the
same day, PULIDO asked the CW if he has to worry about the “Feds.”
PULIDO told the CW that he (PULIDO) can look out for the BPD.
23.
On December 30, 2005, immediately after expressing interest in the
protection operation to the CW, PULIDO called CARRASQUILLO (to a telephone
subscribed in the name of John Scandone
but which CARRASQUILLO routinely used) and told him that he wanted
to talk to him about a business proposition that had just come up.
PULIDO told CARRASQUILLO that they would need people “that I can trust”
to watch what is going to happen. PULIDO told CARRASQUILLO that they
might be able to make some change (money) out of it.
24.
In a recorded meeting on January 16, 2006, scheduled so that the CW could give PULIDO
$7,000 in gift cards as payment for PULIDO’s
delivery of a list of twenty (20) identifiers, the two men talked
again about the scheme to have PULIDO protect a truck containing contraband.
They initially agreed that the best place to bring the truck was the
building at 24 Factory Street
where PULIDO provided protection for after-hours parties; PULIDO said
that there were “no houses in the vicinity” and the area was “full
of trucks.” PULIDO told CW he had already talked to “my man…my partner”
(believed to be CARRASQUILLO) and said that he can run “(Boston Police)
Area A and Area E” while PULIDO does “(Boston Police) Area B.” “We
got [radio] channel 12 and 13, which is the detectives and ‘secret
squirrels,’ so we can hear if they got something coming along.” (“Secret
squirrels” refers to the BPD drug unit). PULIDO told the CW they “can
put somebody upstairs up in the apartment (at 24
Factory Street)” to surveil
the area. PULIDO told the CW he will bring “only two of us,…I’m
not bringing anybody else.”
25.
In or about late January 2006, in another discussion between the CW
and PULIDO about the protection operation, the CW told PULIDO that
the shipment might also contain cocaine. The CW explained that the
cocaine would be concealed inside appliances to avoid detection. PULIDO
indicated that he did not want to personally handle the cocaine but
he would provide protection for its transfer from seller to buyer.
26.
On February 16, 2006,
in two recorded conversations, PULIDO told the CW that he thought
that his garage at 3162 Washington Street
would be a better location o store the contraband than at the garage
at 24 Factory Street.
They also discussed a trip to Atlantic City,
New Jersey to meet the CW’s “Cousins” whose contraband PULIDO was to protect. Unbeknownst
to PULIDO, the CW’s “cousins” were FBI undercover
agents (UCEs). In subsequent recorded conversations,
PULIDO and the CW finalized plans to meet with the “cousins” on February 27, 2006, at a casino In Atlantic
City.
27.
On February 27, 2006,
PULIDO, accompanied by the CW, met with the UCEs posing as the CW’s “cousins”
at the Borgata Hotel, Atlantic
City, New Jersey. After
a “meet and greet” the UCEs invited PULIDO
to Miami, Florida
to discuss future business deals.
28.
On Marrch 15, 2006, PULIDO met with the
UCEs in Miami,
Florida. The meeting was video
and audio recorded. PULIDO advised the UCEs
that he (PULIDO) would be willing to provide security for the contraband
but didn’t feel comfortable with transporting it. PULIDO offered a
commercial garage he operated at 3162 Washington
Street, in the Jamaica Plain section of
Boston under the name
of J and P Auto for the transaction. PULIDO described his garage and
discussed how difficult it would be for law enforcement to conduct
surveillance. PULIDO described how he could monitor radio frequencies
to alert the UCEs if the operation was discovered.
PULIDO offered to run criminal checks on individuals. During the meeting,
PULIDO received a call from CARRASQUILLO. PULIDO told the UCEs
that CARRASQUILLO was his boy and that CARRASQUILLO is “like me, a
hustler.” The UCEs and PULIDO agreed on
$500 per “unit” (kilogram) for protection. The UCEs
told PULIDO that if the deal goes bad the only way they would be caught
is if PULIDO identified them. PULIDO replied, “That won’t happen.”
29.
On March 30, 2006,
PULIDO met with the UCEs in Boston
to show them the possible locations for the unloading of the truck.
On the same day in a recorded telephone conversation, PULIDO told
the UCE he was looking forward to establishing a long term business
relationship with the UCEs.
30.
On April 12, 2006,
PULIDO received a call from one of the UCEs.
They discussed the schedule for the drug protection detail and confirmed
the plan for it to take place in the early morning on Sunday April
23. PULIDO said he already talked to his partner (CARRASQUILLO). In
a second recorded telephone call on April
12, 2006, the CW and PULIDO spoke about the planned drug
protection detail. In that call, PULIDO identified the officer he
had recruited for the operation as “NELLY” (NELSON CARRASQUILLO).
On April 21, 2006,
PULIDO called CARRASQUILLO and told him that the plan was on for Sunday
morning (April 23), and that he would be meeting with the UCEs on Saturday (April 22).
31.
On April 22, 2006,
PULIDO met with the UCEs at a restaurant
in the North End section of Boston
to further plan the operation scheduled for the next day, and for
PULIDO to obtain a “throw-away” telephone for him to use during the
operation. During the meeting a UCE told PULIDO that there were only
going to be “40 pieces” (kilograms) and that they would be hidden
in a white conversion van.
32.
In the early morning hours of April 23, 2006, as planned, PULIDO and CARRASQUILLO
provided protection for the transfer of 40 kilograms of cocaine from
FBI UCEs posing as sellers to other FBI
UCEs posing as buyers. At approximately 7:54 a.m., PULIDO
met the UCE/sellers’ vehicle which contained 40 kilograms of cocaine
at a Bickford’s Restaurant at 75 Boston Street in Boston, Massachusetts
and guided the vehicle to his garage at 3162 Washington Street. PULIDO
then met the UCE/buyers’ vehicle at a McDonald’s restaurant at the
corner of Massachusetts Avenue
and Southampton Street
in Boston, and guided
that vehicle to the same garage. The transfer took place inside PULIDO’s garage.
33.
CARRASQUILLO, who was in regular contact with PULIDO during the operation,
provided perimeter security during the transfer of cocaine. Intercepted calls between PULIDO and CARRASQUILLO
that morning revealed that just before 7 a.m. that morning, PULIDO
and CARRASQUILLO discussed meeting at the Washington Street garage
in Jamaica Plain; just prior to and during the protection detail,
PULIDO and CARRASQUILLO ran license plates of cars they saw in the
area; at about 7:15 a.m. PULIDO called the police station and asked
an officer to run some plates for him, claiming that his police radio
was dying; CARRASQUILLO called and sought information about PULIDO’s
location and PULIDO told CARRASQUILLO that he was having someone run
plates; the UCE called PULIDO at about 7:30 a.m., before the trucks
arrived at the garage, to check on how things were going and PULIDO
told him that “we’re in front watching everything”; just before 8
a.m., CARRASQUILLO called PULIDO and told him that a black male was
using a pay phone near the garage – PULIDO told him to take note of
the car in case it came back; PULIDO received other calls from CARRASQUILLO
reporting persons observed in the vicinity of the garage; just before
9 a.m., PULIDO spoke with CARRASQUILLO, while CARRASQUILLO was with
the CW returning the throw-away telephone he had been provided by
the UCEs; at about 9:30 a.m. PULIDO called
CARRASQUILLO and the two agreed to meet at Dunkin’ Donuts on American
Legion Highway.
34.
PULIDO did not confine his activities to surveillance outside the
garage on April 23, 2006.
While the UCE/sellers were unpacking the cocaine from the van, PULIDO
entered the garage and observed their operation. The UCE/sellers showed
PULIDO the sophisticated concealment system in the van; PULIDO had
to step over approximately 20 kilograms of cocaine on the floor of
the van to make observations of the “hide” system. PULIDO was impressed
with the system and noted that it was “nice.” The UCE/sellers told
PULIDO that the vehicle needed to be aired out before and after each
transfer to avoid detection by dogs.
35.
At approximately 8:36 a.m.,
after the cocaine had been moved from one truck to the other by the
UCEs, PULIDO guided the UCE/buyers to Interstate
93 north bound from the Washington Street
garage. PULIDO then returned to the garage and got in the UCE/cousin
car to discuss the transaction and receive an initial payment. The
UCE/cousin said that there were “40 keys” (kilograms) in the load
and that they owed PULIDO $500 for each one. They paid him a down-payment
of $5,000 with the remaining $15,000 to come at a later date. During
the course of this meeting, PULIDO was visibly excited and exclaimed,
“I love that adrenaline.” PULIDO also asked the UCE/cousin whether
the customers were happy.
36.
On April 26, 2006,
during a telephone call, one of the UCEs
and PULIDO discussed arrangements for PULIDO to travel to Atlantic
City on Monday,
May 1, 2006, to meet with the main UCE to get the rest
of his money and plan the next deal.
37.
On May 1, 2006,
PULIDO met in Atlantic City
with two of the UCEs to obtain payment for
the first operation and to discuss the next protection detail. The
meeting was video and audio recorded. During the meeting the UCEs
paid PULIDO $15,000 in cash owed from the April operation. The participants
also discussed PULIDO’s ability and willingness
to provide protection for substantially larger quantities that would
be transported via New York
to Boston. PULIDO stated
that to do it properly he would need six officers, including himself.
He was not sure he could get that many, but would think about it and
discuss it with his partner (CARRASQUILLO). PULIDO acknowledged that
his role was to protect the shipment from other drug dealers who may
seek to steal the narcotics and from law enforcement officers. The
participants discussed future deals involving 500 “pieces” (code for
kilograms of cocaine) as part of an ongoing relationship. PULIDO assured
the UCEs that he was up front with those
he brought into the conspiracy about the possible consequences of
what they were doing and that they would know going into the deal
that they were dealing with millions of dollars worth of product.
With respect to payment and the product to be protected, the UCEs
told PULIDO, “you got 20 G’s ($20,000) for
40 keys (kilograms of cocaine). You do the math for 250 and think
about 500,”
38.
On May 2, 2006,
PULIDO returned to Boston
from Atlantic City after
having been paid $15,000 in cash for the drug protection operation.
PULIDO called CARRASQUILLO that day and told him the he would come
by to see CARRASQUILLO in 30 minutes. (Based on this investigaton, this appeared to be a meeting for PULIDO to
pay CARRASQUILLO his share of the $15,000 he received from the UCEs, and discuss with him the plans for the next deal.)
39.
On May 3, 2006,
PULIDO called PIZARRO and told him that PIZARRO needed to make time
for PULIDO to talk to him about a business proposition. (Since PIZARRO
was included in the second drug protection detail in June, it can
be inferred that PULIDO sought to meet with PIZARRO to recruit him
in this effort.)
SECOND DRUG PROTECTION OPERATION (100 KILOGRAMS)
40.
On May 18, 2006,
the CW and PULIDO met to discuss the next drug protection detail and
other matters. In that recorded conversation, PULIDO told the CW that
he had CARRASQUILLO, PIZARRO, and two other non-law enforcement associates
(Associate A and Associate D) lined up to help on the next deal. The
two men discussed whether it was appropriate to use the non-law enforcement
associates. PULIDO told the CW that he and CARRASQUILLO had discussed
the fact that they were more comfortable using “uniforms,” that is,
police officers. PULIDO told the CW that hew and CARRASQUILLO had
agreed with respect to Associate A, that, “if it (the operation) goes
dirty, the only thing we can do is fucking take out his (Associate
A’s) children.” PULIDO indicated that neither he nor CARRASQUILLO
wanted to do that, but that “its gonna have to get done” if Associate A joined the conspiracy
and something went wrong. During the conversation, PULIDO and the
CW agreed that they should not use Associate A, but would discuss
with the UCEs the use of Associate D. PULIDO told the CW that he would
speak with CARRASQUILLO about other police officers CARRASQUILLO could
trust and who could be brought in to help. If they couldn’t get enough
officers, they agreed that they might have to protect a load smaller
than 250 kilograms.
41.
On or about May 17, 2006, the UCEs invited
PULIDO, CARRASQUILLO, and PIZARRO to Atlantic
City to discuss the next operation. In a series
of telephone calls leading up to May 24, 2006, the UCEs
and PULIDO decided on a date and location to meet.
42.
On May 22, 2006,
PULIDO spoke with NELSON CARRASQUILLO twice about their planned trip
to Atlantic City to meet
with the UCEs. CARRASQUILLO would not be
able to leave until the last minute and said he would fly down. In
a subsequent conversation, CARRASQUILLO told PULIDO he was having
trouble finding a flight to Atlantic City,
and might have to drive down. CARRASQUILLO told PULIDO he “definitely
would like to go out, but I’d have to leave Thursday.”
43.
On May 24, 2006,
PULIDO met with the UCEs in a hotel in Atlantic
City which was recorded. PULIDO told them that
he had two other “uniforms” to help with the next deal; one he identified
as his partner who helped with the first deal (CARRASQUILLO). The
men discussed how the drugs would be transported. PULIDO suggested
using a second empty truck as a decoy vehicle. Ultimately, they agreed
that they would have to handle a smaller load because only three officers
would be involved. One of the UCEs told
PULIDO that they would ship the 250 kilos in two deals; the first
shipment would be 100 kilos and a second shipment would be 150. The
UCEs also told PULIDO that their New
York protection crew would deliver the truck
to the Massachusetts
border so that PULIDO and his crew would not have to travel to New
York. PULIDO was pleased with the new arrangement.
They talked about what would happen if the truck was stopped by the
police. PULIDO said that if it appeared to be a routine traffic stop,
he would approach the officer and tell him that the truck was following
him, and PULIDO would get the driver out of there so that there was
no one who could be “bringing anything back” (cooperate against them);
in that case they would have to abandon the product (cocaine). PULIDO
further said that they had discussed the possibility of then abandoning
the rental car and switching to another car to make their escape.
PULIDO stated they would utilize fake identification documents to
rent cars. Therefore, if they had to abandon the rental cars the cars
would not be traced back to them. They also talked about using other
PULIDO associates for protection who were not “uniforms.” PULIDO told
them he had some people who have done things with him for years that
have never talked. PULIDO said that they are loyal to him PULIDO said
that anytime they want to talk, he’ll send them to “Rikers
Island.” One UCE stated
that he prefers people in PULIDO’s profession
(law enforcement) because they have as much to lose as people in the
UCEs’ profession (drug dealers). PULIDO responded that he
doesn’t trust people in his profession and is concerned that once
they get the money in their pockets, they might get “Christian on
me.” PULIDO also told them that the second “uniform” (PIZARRO) is
tied up with someone who just got indicted, and was interviewed, but
would never say anything. They talked about possibly using Associate
D. They ultimately agreed that they would not use him now, but might
on a later deal.
44.
During the meeting on May 24, 2006, the CW, who was also present, said that everyone
involved in the transaction needed to know the details of the operation.
PULIDO stated that his garage workers on Washington
Street would be told that the trucks are
carrying stereos or appliances, and the workers would not question
him. They all agreed that everyone
recruited to participate in the protection operation needed to know
the risks involved in the operation and the contents of the truck.
PULIDO told the UCEs that he already explained to his associates involved
in the protection operation (PIZARRO and CARRASQUILLO) what they had
to lose. PULIDO said that in recruiting people he told them that if
something goes bad, and they are at fault, that they would pay with their
lives or their children’s lives. He said that those who stepped forward
were the ones he could trust. PULIDO told the UCEs,
“these two (PIZARRO and CARRASQUILLO) stepped forward. The other one
(Associate A) was like, ‘oh, wait a minute, my children?’ That was
all I needed to hear. If you don’t want to put up your children then
you have to go.”
45.
During the meeting on May 24, 2006, PULIDO and the UCEs
also talked about using the same location as the last deal and whether
the trucks they wanted to use would fit in the garage. PULIDO suggested
that in future deals, the UCEs should think
of buying a car transporter and using the gas tanks of the transporter
to hide their product; PULIDO said the dogs can’t smell through the
gas, which overpowers everything. Because of the location of the tanks
on the transporters, it’s hard for the agents to check the tanks for
product (drugs). He said they could also add extra tanks. PULIDO also
told the UCEs that he has a relative who
is doing over 30 years federal time for drug dealing; he noted some
of the mistakes the relative made which resulted in his arrest.
46.
The next day, May 25, PULIDO again met with some of the UCEs
at the hotel in Atlantic City.
The purpose of the meeting was for the UCEs to meet PIZARRO., who had driven
down separately from Boston
in a rental car. Before PIZARRO
came in, one of the UCEs told PULIDO that
they did not want to come across like they were telling PIZARRO what
to do; they wanted PULIDO to make certain that PIZARRO was comfortable
with the criminal activity in which they are engaged. When PIZARRO
came in, PULIDO told him that the UCEs wanted to make sure he understood the risk, that he has
had time to reflect, and is not planning on backing out. PIZARRO told
them he felt comfortable once he heard that the UCEs
had been doing this (dealing drugs) for a long time. He also said
he trusted PULIDO’s judgment and they had known each other for over ten
years. PIZARRO stated PULIDO, “if you are willing to take a chance,
I am here with you, bro.” The UCEs told
PIZARRO that he needs to take it easy when the money comes in. PIZARRO
told them that PULIDO had stressed that to him. They also discussed
using real estate to hide PIZARRO’s earnings from the operation. When PIZARRO left the
room, PULIDO told the UCEs that PIZARRO
had greater experience in assisting drug dealers than he.
47.
Late in the afternoon on May 25, 2006, CARRASQUILLO contacted PULIDO and told him
that he was starting the drive down to Atlantic
City to meet with the UCEs.
The UCEs, realizing that CARRASQUILLO would
not arrive until late at night, told PULIDO to cancel the meeting
and turn CARRASQUILLO back to Boston.
48.
On May 30, 2006,
one of the UCEs called PULIDO and told him
the drug shipment would be next week. The UCE would come up Tuesday
(June 6) and would meet with PULIDO’s “boys”
to tell them what was needed. The UCE would also be able to meet CARRASQUILLO.
49.
Between May 30, 2006
and June 6, 2006,
there were a series of recorded telephone calls between PULIDO and
one of the UCEs to set up a meeting between the UCEs
and CARRASQUILLO, and the subsequent shipment of what the UCEs
represented would be 100 kilograms from New
York to Boston.
There were also a series of calls and meetings between PULIDO and
CW confirming the arrival of the UCEs.
50.
On the evening of June 6, 2006, the UCEs arranged
a meeting with PULIDO and CARRASQUILLO at a hotel on Commonwealth
Avenue in Boston.
PIZARRO was invited to the meeting by PUDILO, but did not join them.
As arranged by PULIDO and the UCEs, PULIDO
arrived first. At that meeting, which commenced at approximately 9:15 p.m., the UCEs and PULIDO
discussed the mechanics of the operation to take place the next day,
and one UCE noted, “we can’t have any problems.
There’s a lot of money riding on this.” They also discussed the mechanics
of a future 500 unit load. CARRASQUILLO arrived
at the meeting approximately 25 minutes after PULIDO. The UCEs
discussed the operation with CARRASQUILLO, telling him that the shipment
was of “dope,” and asking if he understood the risks involved, and
if he was committed to the plan. The UCE told CARRASQUILLO, “if you’re
in, you’re in, if you’re out, you’re out. And if you are out, we are
still friends.” The men discussed that the next one will be about
500 (kilograms), and discussed finding additional officers to participate.
PULIDO indicated that to test the officers he would want to do other
illegal things with them, “get dirty with them…to see if they are
real dirty” before bringing them in.
51.
On June 21, 2006,
PULIDO contacted PIZARRO and told him to be ready for the shipment
the next day. PULIDO also had a series of telephone calls with Associate
D, instructing him to obtain seven “Boost Mobile” telephones with
a “group talk” feature. (“Boost Mobile”
phones provide pay-as-you-go, long-range digital walkie-talkie service
that allows instant communication among subscribers.) Once Associate
D obtained the telephones, PULIDO instructed him to program the telephones
to work together, and to label the telephones with numbers one through
seven. He also instructed Associate D to keep one phone for himself.
52.
On the evening of June 7, 2006, PULIDO spoke with a UCE. They agreed that PULIDO,
CARRASQUILLO, and PIZARRO would meet the UCEs
at their hotel on Commonwealth Avenue
in Boston at 2 p.m. on the following day. Once at the hotel, PULIDO would
hand out the telephones, and the group would travel in several cars
out to the Lee rest stop on the Massachusetts Turnpike in western
Massachusetts. They
planned to meet the truck carrying the cocaine at approximately 4:30 p.m. at the Lee rest stop. In that call,
PULIDO told the UCE that the phones were prepaid and not in anyone’s
name; he also described how they worked. PULIDO and a UCE also discussed
future business; the UCE invited PULIDO and the others down (to Florida)
to celebrate “our big first one, a real big one.”
53.
On the morning of June 8, 2006, PULIDO left messages for both CARRASQUILLO
and PIZARRO providing them the meeting time and location. At approximately
2:15 p.m. PULIDO and PIZARRO met with the UCEs in front of their hotel on Commonwealth
Avenue. PULIDO kept one of the Boost Mobile
telephones and distributed one to the UCE, and advised that he provided
one to PIZARRO. The group subsequently met CARRASQUILLO, who was running
late, at the Natick rest
area on the westbound side of the Massachusetts Turnpike. One of the
Boost Mobile phones was provided to CARRASQUILLO. The cars then proceeded
together approximately 2 hours to western Massachusetts
to meet the truck they understood to be carrying 100 kilograms of
cocaine. PULIDO, who was driving his own black Cadillac SLS, bearing
Massachusetts registration
US 70ZA, drove in the lead. He was followed by UCEs.
Behind the UCEs PIZARRO was driving a gold/brown
2005 Nissan Altima, Massachusetts registration
64T Z41, which had been rented from Enterprise Rental Car and CARRASQUILLO,
who was driving a blue 2006 Dodge Stratus, Massachusetts registration
34Z Z54, which also had been rented from Enterprise Rental Car,
54.
After PULIDO took the wrong exit on the Massachusetts Turnpike, the
rendezvous point with the truck carrying the cocaine was charged to
the rest area in Blanford,
Massachusetts on the eastbound
side of the Massachusetts Turnpike. Once they met with the truck at
approximately 5:30 p.m., PULIDO and one UCE met with the UCE/driver
in the restroom, introduced PULIDO to him, and provided him with one
of the Boost Mobile telephones. In addition, PIZARRO and CARRASQUILLO
made eye contact with the UCE/driver in the parking lot to insure
that they could recognize each other in the event that something went
wrong and emergency action needed to be taken.
55.
The cars and truck, in convoy fashion, then drove east towards Boston.
PULIDO was in the lead, followed by the UCE, in turn followed by the
truck. CARRASQUILLO and PIZARRO took turns following the truck, and
speeding ahead to surveil activities on the Turnpike. Near Natick,
Massachusetts, PULIDO, at the request
of CARRASQUILLO, contacted the UCE/driver to have him pull over because
his license plate was dirty. The driver did so and cleaned the plate.
The convoy then proceeded into Boston
to PULIDO’s garage at 3162 Washington
Street.
56.
Just prior to reaching the garage, CARRASQUILLO was instructed to
meet the UCE/buyers’ truck which was scheduled to pick up the cocaine
at PULIDO’s garage. CARRASQUILLO was observed
meeting that truck in a McDonald’s parking lot at 870
Massachusetts Avenue in Boston,
and guiding that truck back to the garage on Washington
Street.
57.
At the Washington Street
garage both of the trucks backed up to the bay doors. The contents
of the truck delivering the cocaine (which actually included 40 kilograms
of cocaine even though it had been represented to be carrying 100
kilograms) were transferred to the UCE/buyers’ truck. While the UCE/sellers’
truck was unloading the cocaine, PULIDO entered the garage. PULIDO
was monitoring the Boston Police Department radio traffic with his
handheld BPD issue radio during this period. PULIDO mistakenly pushed
the officer emergency button on his BPD radio. The BPD dispatcher
broadcast his name and unit and asked if he was in trouble. PULIDO
replied that he pushed the button in error. While the transfer was
taking place CARRASQUILLO and PIZARRO were waiting in the area to
escort the trucks from the garage, and conducting perimeter surveillance.
58.
After the transfer of the cocaine was complete, CARRASQUILLO escorted
the UCE/buyer truck with the cocaine out of Boston.
PIZARRO escorted the UCE/seller truck to the Massachusetts Turnpike
westbound. PULIDO met with a UCE in his car. The UCE paid PULIDO a
down payment of $15,000 in cash, with the balance of $35,000 to be
paid at a future date. He invited PULIDO, PIZARRO, and CARRASQUILLO
to meet with him and others in Miami
to celebrate the successful delivery of the cocaine and to discuss
future transactions. The UCE also expressed concerns about problems
with the protection provided by PULIDO, CARRASQUILLO, and PIZARRO.
In particular, he criticized the fact that everyone as inside talking
at the Blanford rest area when they met
the truck (containing the cocaine). PULIDO defended his actions saying,
“I had CARLOS (PIZARRO) take down the plate numbers – because he was
the second one to come in – of the cars that were parked. Then I had
NELSON (CARRASQUILLO) sit back and watch the cars taking off with
us to see if I could match the numbers.” The UCE further criticized
the fact that there were people inside PULIDO’s
garage when the transfer took place. Later in the conversation, the
UCE asked PULIDO if this deal was as good a rush as the other deal
(40 kilogram deal in April). PULIDO responded, “no, the other one was a good rush. This one was a bad rush…an
out-of-control rush.”
59.
In one recorded call on the evening of June 8, 2006, PULIDO (speaking in Spanish)
told his girlfriend that the operation had gone “completely horrible.”
He explained that the garage had not been properly prepared before
he arrives, and that there were people uninvolved in the operation
present when the transfer of the cocaine took place, He also told
her that he accidentally pushed his emergency call button on his police
radio and that the BPD dispatcher broadcast his name and his division.
60.
On June 10, 2006,
PIZARRO called PULIDO to discuss the drug protection detail on June
8. The men agreed that it did not go well and that it was dangerous
the way it played out. PULIDO told PIZARRO that he planned to go down
to Miami in the near future
(implying that he was going down to straighten things out with the
UCEs). PIZARRO said that he had ideas about
how it should be done in the future. The men agreed that they needed
a new location to transfer the product from one truck to another.
PIZARRO also expressed concern about how many times they got out of
their cars during the operation: “There’s too much meeting and too
much getting out of the car, man.” PIZARRO was concerned as well that
the plates on the truck were from Florida
(implying that it was too conspicuous).
61.
Between June 10, 2006,
and June 13, 2006,
there were a series of recorded conversations between the CW and PULIDO
discussing the problems with the operation on June 8, 2006, and ways to make it better.
62.
On June 27, 2006,
one of the UCEs called PULIDO to invite
him, CARRASQUILLO, and PIZARRO to Miami,
Florida to discuss the operation
on June 8, 2006, to plan for future operations,
to get paid the remainder of the money owed to them, and to celebrate
their first big transaction.
63.
On July 19, 2006,
PULIDO and PIZARRO traveled to Miami,
Florida to meet with the UCEs. PULIDO flew from Boston.. PIZARRO flew from Puerto Rico. CARRASQUILLO
was scheduled to attend the meeting as well, but he reported to PULIDO
that a family obligation required his presence in Boston.
PULIDO told the UCEs that CARRASQUILLO agreed
to take an early morning flight to Miami
on July 20, 2006
to meet with the UCEs and receive payment
for the June drug protection operation.
64.
ON the evening of July 19, 2006, PULIDO and PIZARRO met with the UCEs in Miami.
The meeting was audio taped and videotaped. At the meeting, one UCE
said, “our first deal we did the 40 keys of coke. Then we did 100
keys of coke. We’re looking to do big numbers. How much can you handle?”
PULIDO replied, “what could be brought down?” The UCE said, “we can do 500 keys of coke.” PULIDO replied, “that’s what I want to see.” PULIDO and PIZARRO then agreed
with the UCEs that the first 500 kilogram
shipment would take place next week; to be followed by a second shipment
of 500 kilograms soon after. One UCE also asked if they would “move
some heroin” at the same time. PULIDO and PIZARRO agreed to that as
well. The men also discussed one to two shipments per month for the
indefinite future. PULIDO suggested that they change the sale location
in Boston to the garage
at 24 Factory Street
and suggested several other operational changes. PIZARRO indicated
his agreement with PULIDO’s suggestions.
A UCE also said that they had already been paid $15,000 for the last
operation, and that the balance of $35,000 would be paid the next
day. After the meeting concluded, PULIDO and PIZARRO went out to dinner
with one of the UCEs.
65.
Early on the morning of July 20, 2006, as agreed, CARRASQUILLO flew from Boston
to Miami. PULIDO, PIZARRO,
and CARRASQUILLO are scheduled to meet with the UCEs
in the early afternoon on July
20, 2006, to receive the $35,000 payment owed from the
June 8, 2006 transaction.
66.
Based on the information set out above, I believe probable cause exists
to conclude that from at least on or about May 1, 2006, through on
or about July 20, 2006, ROBERTO E> PULIDO, CARLOS A> PIZARRO,
and NELSON CARRASQUILLO knowingly and intentionally combined, conspired,
confederated and agreed with each other and with other persons, known
and unknown, to distribute, and to possess with intent to distribute,
a quantity or mixture of a substance containing cocaine, a Schedule
II controlled substance, that quantity being in excess of 5 kilograms
(to wit: 100 kilograms) in violation of Title 21, United States Code,
Section 841 (a)(1), all in violation of Title 21, United States Code,
Section 846.
SA Michael
J. Kreizenbeck
Special Agent
Federal Bureau of Investigation
Boston, Massachusetts
Subscribed
and sworn to before me this 20 day of July, 2006
.gif)