Michigan Meth Ring
Michigan Meth Ring
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Continuation of Application
I, Michael W. Tighe, being duly sworn, hereby depose and state as follows:
information associated with a certain cellular telephone assigned call (470) 955-0097 (the
“Target Cellular Device”), that is stored at premises controlled by Verizon Wireless, a wireless
telephone service provider headquartered at One Verizon Way, Basking Ridge, NJ 07920. The
United States Department of Justice. I am currently assigned to the Kalamazoo Post of Duty in
the DEA’s Detroit Field Division. I have been employed with the DEA since January 2005.
During my time as a Special Agent, I have led and/or participated in multiple investigations of
unlawful drug trafficking and money laundering and, among other things, have conducted or
of taped conversations and drug records, and investigations that included the interception of wire
and electronic communications. Through my training, education and experience, I have become
familiar with the manner in which illegal drugs are transported, stored, and distributed, the
methods of payment for such drugs, the laundering of narcotics proceeds, and the dialect, lingo,
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and coded language used by narcotics traffickers. As part of my duties as a DEA Special Agent,
violations of the federal controlled substance laws, including, but not limited to 21 U.S.C.
§§ 841, 843, 846, 848, 952, and 963, as well as money laundering, in violation of 18 U.S.C.
§§ 1956 and 1957. I have experience with various electronic surveillance methods, the
debriefing of defendants, informants, and witnesses, as well as others who have knowledge of
3. I also know from training and experience that drug traffickers frequently utilize
mobile telephones and other electronic devices, such as tablets and laptop and desktop
computers, to facilitate drug trafficking. Mobile telephones are portable, and some mobile
telecommunications service providers do not require purchasers of the devices to provide their
names and/or addresses, so drug traffickers often use the devices in an effort to avoid detection
by law enforcement. Mobile phones often contain evidence indicative of drug trafficking,
including records of incoming and outgoing calls and text messages with suppliers of drugs;
“smart phones,” Global Positioning System (“GPS”) data indicating the location of the device at
given points in time, providing evidence that the device was in high drug-trafficking areas or
evidencing the route used in trafficking controlled substances. Additionally, drug traffickers
typically maintain and use multiple mobile phones to facilitate sales, and frequently switch
experience, and information obtained from other agents and witnesses. This continuation is
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intended to show merely that there is sufficient probable cause for the requested warrant and
5. Based on the facts set forth in this continuation, there is probable cause to believe
that Richard FARMER used the Target Cellular Device at least between May and August 2018.
Further, there is probable cause to believe that the historical cell site location information
associated with the Target Cellular Device, more fully described in the attachments, will
initiated an investigation into Raymond Demetruis STOVALL, a/k/a “OG”, and Richard Lee
JAMES Jr., a/k/a “Lopez”, and their involvement in the distribution of large quantities of
STOVALL and JAMES are believed to the leaders of a drug-trafficking organization (“DTO”)
multiple packages sent via the United States Postal Service (“USPS”), which contained pounds
of methamphetamine and were owned by the DTO. Investigators conducted wire and electronic
surveillance of the cellular devices of both STOVALL and JAMES pursuant to orders issued by
Chief Judge Robert J. Jonker under Title III. See Case No. 18-mc-59.
8. The wire and electronic surveillance has yielded evidence against STOVALL and
JAMES, as well as against their co-conspirators. One of these co-conspirators was identified as
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Richard FARMER, who used the Target Cellular Device. 1 Investigators intercepted numerous
pertinent communications involving FARMER while he was using the Target Cellular Device.
For instance, on August 24, 2018, at approximately 7:34 p.m., FARMER used the Target
FARMER: You get, did, did you get tight on the joints you was waitin’
on?
STOVALL: Shit, bitch. Shit, bitch. Let me get one ‘em bitches man.
FARMER was asking STOVALL if he had received his multi pound crystal methamphetamine
shipment when he said, “Did you get tight on the joints, you was waitin’ on?” The word “joint”
has been utilized by the DTO as coded speech meaning a pound of crystal methamphetamine.
STOVALL then said, “Hell nah, bitch still ain’t here man.” I believe STOVALL meant the
shipment of crystal methamphetamine had not yet arrived. I further believe that when FARMER
said, “Man I’m straight on them bitches,” he was indicating to STOVALL that he had pounds of
crystal methamphetamine. STOVALL’s response was, “Let me get one ‘em bitches man.” I
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FARMER was identified as the user of the Target Cellular Device as follows. The
subscriber’s address is 4300 Flat Shoals Road, Apartment 3301, Union City, Georgia. The
Accurint commercial database indicates that FARMER is associated with that address. During
intercepted communications, STOVALL refers to the user of the phone as “Rick” and the user’s
voice is male. Finally, during interaction with FBI special agents during the July 31, 2018, arrest
of Antwan MIMS, FARMER provided the number of the Target Cellular Device to the agents
as his telephone number.
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believe STOVALL meant he wanted FARMER to provide one of the pounds of crystal
methamphetamine to him.
10. Also on August 24, 2018, at approximately 8:27 p.m., FARMER again used the
conversation:
STOVALL: Them bitches is hit, man. At least bring one of them bitches [U/I]
to do with that bitch.
FARMER: Listen bro. I just told you, talking he had two of em coming there
nigga. [U/I] I’m coming. I told them people I’m coming. Do what
you said nigga.
STOVALL: Alright.
11. Based on my training, experience, and familiarity with the investigation, I believe
STOVALL and FARMER were discussing the distribution of two pounds of methamphetamine.
STOVALL said, “them bitches is hit, man. At least bring one of them bitches.” I believe
STOVALL was telling FARMER that he could quickly sell the methamphetamine. FARMER
responded that he is coming to STOVALL with two pounds and it will be up to STOVALL to
12. On July 31, 2018, the FBI and the Clayton County Police Department executed a
search warrant at an apartment located at 1507 Pine Drive, College Park, Georgia. Inside, they
found FARMER and MIMS, a loaded firearm, about a pound of methamphetamine in pill form
(that appeared to be ecstasy), heroin, and an assortment of other suspected controlled substances
that were not tested due to the policy of the Georgia Bureau of Investigation laboratory. The
apartment was leased to a Demetrius Jackson, who was not present at the time of the search.
13. On August 29, 2018, FARMER was charged with conspiring to distribute
controlled substances by criminal complaint. See 18-mj-307. He was arrested the next day. A
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grand jury indicted him with the same offense in November 2018. See 18-cr-249. The Court has
14. As part of the investigation, I applied for, and this Court issued, a warrant to
search for location information associated with the Target Cellular Device. See Case No. 18-
mj-322. That warrant only sought historical location information for the Target Cellular Device
dating back to July 28, 2018. The information produced by Verizon Wireless in response to the
warrant indicates that between July 28 and August 4, 2018, the Target Cellular Device was
utilizing towers and sectors near the 1507 Pine Drive address. The information also indicated
that the Target Cellular Device travelled between Georgia and Benton Harbor in late August
2018. I respectfully submit that there is probable cause to believe that additional historical cell
site location information associated with the Target Cellular Device prior to July 28, 2018,
15. In my training and experience, I have learned that Verizon Wireless is a company
that provides cellular telephone access to the general public. I also know that providers of
cellular telephone service have technical capabilities that allow them to collect and generate
information about the locations of the cellular telephones to which they provide service,
including cell-site data, also known as “tower/face information” or “cell tower/sector records.”
Cell-site data identifies the “cell towers” (i.e., antenna towers covering specific geographic
areas) that received a radio signal from the cellular telephone and, in some cases, the “sector”
(i.e., faces of the towers) to which the telephone connected. These towers are often a half-mile
or more apart, even in urban areas, and can be 10 or more miles apart in rural areas.
Furthermore, the tower closest to a wireless device does not necessarily serve every call made to
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or from that device. Accordingly, cell-site data provides an approximate location of the cellular
telephone but is typically less precise than other types of location information, such as E-911
16. Based on my training and experience, I know that Verizon Wireless can collect
cell-site data about the Target Cellular Device. I also know that wireless providers such as
Verizon Wireless typically collect and retain cell-site data pertaining to cellular phones to which
they provide service in their normal course of business in order to use this information for
17. Based on my training and experience, I know that Verizon also collects per-call
measurement data, which Verizon also refers to as the “real-time tool” (“RTT”). RTT data
estimates the approximate distance of the cellular device from a cellular tower based on the
speed with which signals travel between the device and the tower. This information can be used
to estimate an approximate location range that is more precise than typical cell-site data.
18. Based on my training and experience, I know that wireless providers such as
Verizon Wireless typically collect and retain information about their subscribers in their normal
course of business. This information can include basic personal information about the
subscriber, such as name and address, and the method(s) of payment (such as credit card account
number) provided by the subscriber to pay for wireless telephone service. I also know that
wireless providers such as Verizon Wireless typically collect and retain information about their
subscribers’ use of the wireless service, such as records about calls or other communications sent
or received by a particular phone and other transactional records, in their normal course of
business. In my training and experience, this information may constitute evidence of the crimes
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under investigation because the information can be used to identify the Target Cellular
AUTHORIZATION REQUEST
19. Based on the foregoing, I request that the Court issue the proposed search
respectfully submit that there is probable cause to believe FARMER has engaged in a conspiracy
to distribute controlled substances, in violation of 21 U.S.C. § 846, and further that there is
probable cause to believe the information sought by the warrant will constitute evidence of that
crime.
20. I further request that the Court direct Verizon Wireless to disclose to the
government any information described in Section I of Attachment B that is within its possession,
custody, or control. Because the warrant will be served on Verizon Wireless, who will then
compile the requested records at a time convenient to it, reasonable cause exists to permit the
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ATTACHMENT A
Property to Be Searched
This warrant applies to records and information associated with the cellular telephone
assigned call number (470) 955-0097 (“the Account”), that are stored at premises controlled by
Verizon Wireless (“the Provider”), headquartered at One Verizon Way, Basking Ridge, NJ
07920.
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ATTACHMENT B
To the extent that the information described in Attachment A is within the possession,
custody, or control of the Provider, including any information that has been deleted but is still
available to the Provider or that has been preserved pursuant to a request made under 18 U.S.C.
§ 2703(f), the Provider is required to disclose to the government the following information
pertaining to the Account listed in Attachment A for the time period May 1, 2018, to August 31,
2018:
iv. Records of session times and durations, and the temporarily assigned
network addresses (such as Internet Protocol (“IP”) addresses) associated
with those sessions;
viii. Means and source of payment for such service (including any credit card
or bank account number) and billing records.
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b. All records and other information (not including the contents of communications)
including:
ii. information regarding the cell tower and antenna face (also known as
“sectors”) through which the communications were sent and received as
well as per-call measurement data (also known as the “real-time tool” or
“RTT” data).
U.S.C. § 846 involving Richard FARMER or his co-conspirators during the period May 1, 2018,
Law enforcement personnel (who may include, in addition to law enforcement officers
and agents, attorneys for the government, attorney support staff, agency personnel assisting the
government in this investigation, and outside technical experts under government control) are
authorized to review the records produced by the Provider in order to locate the things