Florida Federal Drug Defense Attorney Publishes Typical Federal Criminal Complaint for Drug Charges

Federal Criminal Complaint for Drug Charges

Sample Federal Criminal Complaint

Florida Federal Drug Defense Attorney, W.F. ''Casey'' Ebsary, Jr. has published a Typical Federal Criminal Complaint for Drug Charges. The names and identities have been edited. The Criminal Complaint was used by Federal Agents in a recent drug investigation.

Typical Federal Criminal Complaint for Drug Charges

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 26, 2009, in Polk County, in the Middle District of Florida, an individual did, possess with intent to distribute anabolic steroids, a Schedule Ill controlled substance, in violation of Title 21, United States Code, Section 841. I further state that I am a Special Agent with United States Immigration and Customs Enforcement, and that this Complaint is based on the following facts:

SEE ATTACHED AFFIDAVIT

I, Special Agent, being duly sworn, hereby depose and state as follows:

I am a Special Agent with United States Immigration and Customs Enforcement (ICE), and have been so employed since May 5, 2008. I was previously employed as a Special Agent with the United States Secret Service for eight years. I am currently assigned to the ICE Special Agent in Charge (SAC), Tampa, Florida. The ICE/SAC Tampa has investigative responsibilities for crimes within the jurisdiction of Immigration and Customs Enforcement, including those that relate to the importation, smuggling and distribution of narcotics that occur in the Middle District of Florida, Since being assigned to the ICE/SAC Tampa I have been trained and involved in numerous types of investigations involving importation, smuggling and distribution of narcotics.

I am submitting this affidavit in support of a criminal complaint charging an individual with knowingly or intentionally manufacturing, distributing, or dispensing, or possessing with intent to manufacture, distribute, or dispense, a controlled substance in violation of Title 21, United States Code, Section 841(a) (1). The following information is based upon my personal knowledge, as well as information provided to me and other law enforcement officers, agents, and by individuals cooperating with this investigation. Because the affidavit is submitted for the limited purpose of establishing probable cause for an arrest, not all of the facts and information known to me and other law enforcement agents are included herein.

On May 21, 2006, I received information from Special Agent, ICE/SAC Philadelphia that a package intercepted by the Customs and Border Protection Inspectors at the Philadelphia Airport, UPS Package Hub that contained items listed as liothyronine (200 tablets) and 37 vials with labels for drostanolone propionate, nandrolone decanoate, testosterone cypionate, and testosterone enanthate, which are all listed as anabolic steroids. Anabolic steroids are a schedule III controlled substance. 21 C.F.R. Section 1300.01(b)(4) defines anabolic steroids as “any drug or hormonal substance, chemically or pharmacologically related to testosterone)”, and lists the specific chemical names of numerous steroids. The package originated from Bratislava, Slovakia and the listed consignee was Name, Address. S/A inquired whether the ICE/SAC was interested in attempting a controlled delivery of the steroids to the listed consignee. I agreed to attempt a controlled delivery of the steroids.

I contacted the Sheriff’s Office and they agreed to participate in a controlled delivery to the listed consignee located within their jurisdiction. Sheriff’s Office Detective applied for and received a judicially authorized anticipatory search warrant for the above address signed from a Florida state court judge. Database checks revealed that the listed owner of Address is Name. Name had been arrested three (3) times in, including arrest for possession with intent to sell steroids,

On May 26, 2009, the steroid package was wired with an electronic beacon which emitted an alert indicating whether or not the steroid package had been opened by the consignee. At approximately 3:00 pm, an undercover Sheriff’s detective delivered the steroid package to Address. The Sheriff’s Detectives and ICE Agents monitored the electronic beacon which alerted approximately 5 minutes later, indicating that the package had been opened. Sheriff’s Office detectives gained entry into the residence pursuant to the judicially authorized search warrant. This individual was the only occupant and was observed in possession of the opened steroid package.

Sheriff’s Office search warrant was then executed. The search warrant was read to the individual and the individual was read his Miranda warnings/rights. The individual stated he wished to obtain a lawyer to represent him before questioning. During the search warrant, the individual made numerous spontaneous utterances concerning the distribution/sale/ importation of steroids. I personally heard the individual state, while being asked biographical information by Sheriff’s Office detectives, that he “would beat any charges like he had in the past,” and that “the only thing he knows is selling steroids.” The individual was then arrested and transported by the Sheriff’s Office.

Found during the search of the individual’s residence were numerous items, including five (5) firearms, three (3) of which were loaded handguns, one (1) loaded shotgun, and one (1) AR-15 assault rifle and ammunition for several caliber weapons; three (3) large containers containing numerous types of anabolic steroids with the labeled names boldenone, methenolone, nandrolone, oxandrolone, oxymetholone, testosterone, testosterone cypionate, testosterone enanthate, testosterone propionate (all listed in 21 C.F.R 1300.01(b) (4)); numerous blister packs with the printed substance diazepam (the Schedule IV controlled substance in the brand name valium); a digital scale; UPS packaging labels; anabolic steroids books; body building trophies and photos; three (3) computer towers; one (1) laptop; numerous filled syringes; and miscellaneous paperwork relating to steroids. Also found were many yet unidentified tablets and vials of substances suspected to be steroids and/or prescription medicines.

Based on the foregoing information, I believe that probable cause exists to conclude that this individual did knowingly or intentionally manufacture, distribute, or dispense, or possess with intent to manufacture, distribute, or dispense, a controlled substance, that is anabolic steroid, in violation of Title 21, United States Code, Section 841 (a) (1).

W.F. ''Casey'' Ebsary, Jr. is available Toll Free to help with these types of allegations. 1-877-793-9290.

Tampa Federal Criminal Defense