Rev - Complaint and Affidavit - Jason Siplin Et Al - MDH
Rev - Complaint and Affidavit - Jason Siplin Et Al - MDH
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about and between the month of August 2020 and May 19, 2021 in the Western District of New York,
and elsewhere, JASON SIPLIN, JASON SIPLIN, JR., ERNEST GAMBLE, LYTRICE JACKSON, TIMOTHY
GRANISON, DKEIDRON DUBLIN, and others known and unknown, did combine, conspire and agree to possess
with intent to distribute, and to distribute, at least 280 grams of cocaine base, a Schedule II controlled substance, and
at least 500 grams of cocaine, a Schedule II controlled substance, in violation of Title 21, United States Code, Sections
84l(a)(l ) , 841(b)(l )(A), 84l(b)(l )(B) and 84l(b)(l )(C), all in violation of Title 21, United States Code, Section 846;
AND further, that on or about May 19, 2021, in the Western District of New York, DKEIDRON DUBLIN,
in furtherance of a drug trafficking crime for which he may be prosecuted in a court of the United States, that is,
conspiracy to possess with intent to distribute, and to distribute, controlled substances, as alleged above, did
knowingly and unlawfully possess a firearm, in violation of Title 18, United States Code, Section 924(c)(l)(A)(i).
v. 21-MJ-512
Defendants.
___________________________________________
Homeland Security Investigations (HSI), and have been so employed since November 2019.
I am currently assigned to the HSI Buffalo Border Enforcement Security Task Force (BEST)
and attached to the Greater Rochester Area Narcotics Enforcement Team (GRANET). My
responsibilities include investigating violations of federal and state criminal laws, including
enforcement officer" within the meaning of Title 18, United States Code, Section 2510(7),
that is, an officer of the United States who is empowered by law to conduct investigations and
to make arrests for offenses enumerated in Title 18, United States Code, Section 2516, and
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Title 21 of the United States Code.
SIPLIN a/k/a J, Jason SIPLIN, JR. a/k/a Mush, Ernest GAMBLE a/k/a Dred, Lytrice
JACKSON a/k/a Storm, Timothy GRANISON, and Dkeidron DUBLIN with a violation
of Title 21, United States Code, Section 846 (conspiracy to possess with intent to distribute,
and distribute, at least 280 grams or more of cocaine base, a Schedule II controlled substance;
and at least 500 grams or more of cocaine, a Schedule II controlled substance), and that
Dkeidron DUBLIN also committed a violation of Title 18, United States Code, Section
3. As more fully described below, the facts in this affidavit are based on a
filed in connection with this investigation, conversations with other law enforcement officers
involved in this investigation, and my review of conversations that have been intercepted
are based on my training and experience as well as the advice of other experienced federal,
state and local narcotics investigators. Since this affidavit is being submitted for a limited
purpose, I have not included every fact that I know concerning this investigation. Rather, I
have set forth only those facts that relate to the issue of whether probable cause exists to
believe that the above-named defendants committed the above-described offenses. In support
AFFIANT’S BACKGROUND
4. I have been employed as an HSI Special Agent since November 2019. During
my tenure with HSI, I have participated in numerous narcotics investigations during which I
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have conducted physical and wire surveillance, executed search warrants, and reviewed and
education, and experience, I have become familiar with the manner in which illegal drugs
(including cocaine, cocaine base, and others) are imported, stored, transported, and
distributed, as well as methods of payment for such drugs. I am also familiar with the manner
in which proceeds from narcotics trafficking are laundered, and the efforts and strategies drug
traffickers will employ to avoid detection by law enforcement. I am aware of the fact that
those who distribute controlled substances often use cryptic, coded or otherwise indirect
language when discussing their illegal activities over the telephone. I am also aware of the
fact that drug traffickers will often add adulterants or other additives to their controlled
substances to increase the quantity of their distributable product, thereby increasing their
profits. I know that drug traffickers often use firearms in order to protect themselves, their
narcotics and drug proceeds from rival drug traffickers and/or potential robbers. Therefore,
BACKGROUND OF INVESTIGATION
“GRANET”) and other cooperating law enforcement agencies have been investigating a drug
trafficking organization led by Jason SIPLIN (hereafter the “SIPLIN DTO”). The
audio recorded purchases of cocaine base 1, surveillance (by both plain clothes officers as well
1
Cocaine base is more commonly known as “crack” or “crack cocaine.” Whenever I use those terms throughout
this affidavit I am referring to cocaine base.
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as covert cameras), search warrants and state eavesdropping warrants that were used to
6. The members of the SIPLIN DTO were using cellular phones to conduct their
drug business. Over the course of this investigation numerous eavesdropping warrants were
obtained for telephone numbers used by members of the SIPLIN DTO. All of the intercepted
telephone calls, text messages, and corresponding location/ping data referred to in this
affidavit were obtained through lawful eavesdropping warrants, issued by the Honorable
Michael Dollinger, Monroe County Court Judge, on various dates over the course of this
investigation.
frequently use multiple cellular phones and will regularly drop or change telephone numbers
in an effort to evade law enforcement. For example, Jason SIPLIN used at least seven
different telephone numbers over the course of this investigation. Often drug dealers will use
telephone numbers that have services subscribed to in the name of another individual, fake
names, or have no user information at all. The users of the telephone numbers described
throughout this affidavit have been identified by various means, including but not limited to
reliable confidential sources, vehicle stops of targets, video footage, Department of Motor
Vehicle driver’s license and automobile registration records, and the names and nicknames
this was a long-term investigation, members of the investigative team also became
increasingly familiar with the sound of each target’s voice as the case proceeded.
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OVERVIEW OF CONSPIRACY
8. The investigation has revealed that since at least August 2020, the SIPLIN
DTO has been distributing large quantities of cocaine and cocaine base in the City of
Rochester and the surrounding areas. Based upon the evidence discovered during the course
of the investigation, it was revealed that Jason SIPLIN, who resides at 14 Elwood Drive,
Rochester, New York, is the leader of this organization. Jason SIPLIN regularly obtains large
quantities of cocaine that he in turn uses to supply a drug house located at 230 Glenwood
Avenue, Rochester, New York, where cocaine and cocaine base is sold to individual drug
users. It is believed that SIPLIN may have multiple storage locations for narcotics and United
States currency. At least one of SIPLIN’s storage locations for narcotics is the premises known
as 62 Clifton Street, Rochester, New York. The investigation has revealed that SIPLIN
regularly supplies or “re-ups” 230 Glenwood Avenue with cocaine base stored at 62 Clifton
Street. SIPLIN’s DTO is composed of a number of individuals who fulfill various roles in
furtherance of his narcotics trafficking operation. SIPLIN would obtain bulk quantities of
cocaine, which would then be cooked or transformed into cocaine base (crack cocaine) by a
member of the SIPLIN DTO. The cocaine base was then broken down into individual units
and bagged for street sale. Members of the SIPLIN DTO also staffed the drug house at 230
Glenwood Avenue, where the cocaine base was sold to individual drug users who traveled to
the location on foot or in vehicles. SIPLIN’s upper level workers are believed to include his
son, Jason SIPLIN, JR. a/k/a Mush, who resides at 2013 Norton Street, Rochester, New
York, among others. Ernest GAMBLE a/k/a Dred and Lytrice JACKSON a/k/a Storm are
among a number of individuals who packaged drugs for street sale and conducted hand-to-
hand drug transactions out of 230 Glenwood Avenue on behalf of the SIPLIN DTO. For
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approximately six months leading up to the arrest of Jason SIPLIN law enforcement has
utilized covert cameras directed at various locations pertinent to the investigation, including
the rear of 230 Glenwood Avenue. Based on my training and experience and conversations
with other experienced narcotics investigators, your affiant has observed foot traffic and
vehicle traffic to the location that is consistent with roughly forty to fifty drug transactions
each day. I also believe SIPLIN supplies bulk quantities of cocaine and cocaine base to other
drug dealers who then further distribute these substances. Based on my training, experience
and knowledge of the investigation, I believe SIPLIN supplied bulk quantities of cocaine to
9. As an aid to the Court, the following locations are relevant to the Court’s
consideration:
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f. 5 Birch Crescent, Apartment 3, Rochester, New York: The
residence of Dkeidron DUBLIN.
CONTROLLED BUYS
10. Between August 2020 and the last week in April 2021, numerous controlled-buy
operations were conducted by the investigative team utilizing one of two confidential informants
(hereafter “CI-1” and “CI-2”)2. Prior to each controlled-buy the CI would be searched for drugs,
money and contraband always with negative results. Further, prior to each operation the CI
would be fitted with an audio recording and transmitting device. This device would record the
CI’s conversations with the individuals encountered by the CI during the controlled-buy
operation. The device also allowed law enforcement to monitor for the CI’s safety while inside
of a target location. For each controlled-buy, visual surveillance was conducted by officers who
could observe the CI walking to and from target locations. The CI was provided with official
law enforcement funds to purchase narcotics during each controlled-buy operation. After each
controlled-buy, members of the law enforcement team would follow the CI from the target
location to a predetermined meeting location where the CI would turn over the purchased
cocaine base, the recording device, and thereafter be debriefed. After each controlled-buy, the
cocaine base was field tested by a properly trained law enforcement officer. The field tests
conducted in each of the controlled-buy operations enumerated below all returned positive
results for the presence of cocaine. What follows is a brief description of the numerous operations
in which cocaine or cocaine base was successfully purchased from a member of the SIPLIN
2
CI-1 and CI-2 are paid confidential informants who have assisted law enforcement in this investigation as well
as other past investigations that have led to successful search warrants, arrests and seizures of evidence. Their
information has proven to be truthful, reliable and accurate in this and other investigations. The information
provided by CI-1 and CI-2 over the course of this investigation has also been corroborated where possible by
other investigative techniques.
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DTO out of 230 Glenwood Avenue, Rochester, New York, over the course of this investigation:
11. During the 4th full week of August 2020, at the direction of law enforcement
CI-1 called SIPLIN at (585) 259-8246 and arranged to purchase a quantity of cocaine base.
SIPLIN told CI-1 to go to the house at 230 Glenwood Avenue. Following that conversation,
CI-1 went to the back door of 230 Glenwood Avenue. A black male that the CI-1 knew as
“Red” answered the door. CI-1 described “Red” as a male in his 50’s, with light skin and
freckles. CI-1 had a brief conversation with Red about purchasing crack cocaine and handed
Red a quantity of U.S. currency. In exchange Red handed CI-1 a quantity of white, rock-like
substance that appeared to be crack cocaine. A short time later, CI-1 left the location, and
came back to the undercover vehicle. CI-1 then turned over a quantity of white, rock-like
substance to the undercover officers monitoring the operation, that appeared to be crack
cocaine. The substance later field tested positive for the presence of cocaine.
12. During the 4th week of September 2020, at the direction of law enforcement,
CI-1 called (585)530-7705 and arranged to purchase a quantity of crack cocaine. This
number was obtained prior to the operation and was believed to be used by one of SIPLIN’s
associates by the name of Ernest GAMBLE. The male on the phone told CI-1 to go to the
house at 230 Glenwood Avenue. While under surveillance by members of GRANET, CI-1
went to the back door of 230 Glenwood Avenue. A black male that the CI-1 knew as “Dred”
answered the door. Dred was described by CI-1 as a black male in his 20’s with dreadlocks.
Through further investigation, Dred was later identified to be Ernest GAMBLE. CI-1 had
a brief conversation about purchasing crack cocaine from Dred and handed him a quantity
of U.S. currency. In exchange Dred handed CI-1 a quantity of white, rock-like substance
that appeared to be crack cocaine. A short time later, CI-1 left the location, and came back
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to the undercover vehicle. CI-1 then provided the investigators with the white, rock-like
substance purchased from the SIPLIN DTO on this date, that appeared to be crack cocaine.
The substance later field tested positive for the presence of cocaine.
13. During the first week of October 2020, at the direction of law enforcement
CI-1 called Ernest GAMBLE at (585) 530-7705, and heard a recording stating that phone
number was unable to accept calls at that time. A plan was then formulated for CI-1 to go
directly to 230 Glenwood Avenue. Law enforcement provided CI-1 with a quantity of U.S.
currency. While under surveillance by members of GRANET, CI-1 went to the back door
of 230 Glenwood Avenue. A short time later, CI-1 left the location, and returned to the
undercover vehicle. CI-1 then handed the investigators a quantity of white, rock-like
substance purchased from the SIPLIN DTO, that appeared to be crack cocaine. The
substance later field tested positive for the presence of cocaine. During the debriefing CI-1
advised that he/she walked to the enclosed porch at the rear of 230 Glenwood Avenue,
knocked on the door, and was greeted by Ernest GAMBLE. CI-1 had a brief conversation
with GAMBLE about purchasing crack cocaine and handed GAMBLE an amount of U.S.
currency. In exchange GAMBLE handed CI-1 a quantity of white, rock-like substance that
14. During the second week of October 2020, at the direction of law enforcement,
CI-1 attempted to reach Ernest GAMBLE at (585) 530-7705 several times. Each time a
recording stated that the number was unable to take phone calls. Thereafter, a plan was
formulated for CI-1 to go directly to 230 Glenwood Avenue in an effort to make contact with
GAMBLE. CI-1 walked directly to 230 Glenwood Avenue, Rear Apartment, and knocked on
the door. Ernest GAMBLE answered the door, at which time CI-1 had a conversation with
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GAMBLE about his phone number. GAMBLE provided CI-1 with his new telephone number
which was (585) 820-7677, for CI-1 to use for future drug transactions. Shortly thereafter CI-1
15. During the second full week of October 2020, at the direction of law
enforcement CI-1 called Ernest GAMBLE at (585) 820-7677. A male answered the phone
and CI-1 recognized the voice as Ernest GAMBLE’s. CI-1 had a conversation with
GAMBLE over the phone about purchasing crack cocaine at 230 Glenwood Avenue. While
under surveillance by law enforcement, CI-1 went to the back door of 230 Glenwood Avenue
and knocked on the door. Ernest GAMBLE opened the door and allowed CI-1 into the
location. CI-1 had a brief conversation about purchasing crack cocaine and gave GAMBLE
a quantity of U.S. currency. In exchange GAMBLE handed CI-1 a quantity of white, rock-
like substance that appeared to be crack cocaine. CI-1 left the location and returned to the
undercover vehicle. CI-1 then handed law enforcement the white, rock-like substance
purchased from GAMBLE, that appeared to be crack cocaine. The substance later field tested
16. During the third week of February 2021, at the direction of law enforcement,
CI-2 attempted to purchase cocaine base from members of the SIPLIN DTO at 230
Glenwood Avenue. While under surveillance by members of the investigative team, CI-2
went to the back door of 230 Glenwood Avenue. A short time later, CI-2 left the location,
and returned to the undercover vehicle. CI-2 then handed the investigators a quantity of
white, rock-like substance that appeared to be crack cocaine, which later field tested positive
for the presence of cocaine. During the debriefing CI-2 advised that he/she walked to the
enclosed porch at the rear of 230 Glenwood Avenue, and knocked on the door. An
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unknown male greeted CI-2 through the door and CI-2 had a brief conversation with this
person about purchasing crack cocaine. A price and quantity were agreed upon at which
point CI-2 handed the unknown male an amount of U.S. currency. In exchange, the
unknown male handed CI-2 a quantity of white, rock-like substance that appeared to be
crack cocaine.
17. A second controlled buy was conducted during the third week of February
2021. While under surveillance by law enforcement, CI-2 went to the back door of 230
Glenwood Avenue. A short time later, CI-2 left the location, and returned to the undercover
vehicle. CI-2 handed law enforcement a quantity of white, rock-like substance that
appeared to be crack cocaine, and later field tested positive for the presence of cocaine.
During the debriefing CI-2 advised that he/she walked to the enclosed porch at the rear of
230 Glenwood Avenue, and knocked on the door. CI-2 had a brief conversation about
purchasing crack cocaine with an unknown female, who directed an unknown male to get
the product for CI-2 in exchange for U.S. currency. CI-2 handed the unknown male an
amount of U.S. currency and in exchange the unknown male handed CI-2 a quantity of
white, rock-like substance that appeared to be crack cocaine. CI-2 obtained a phone number
for the unknown female to use for future drug transactions: (585) 285-3463.
18. During the fourth week of February 2021, law enforcement formulated a
plan to purchase crack cocaine from 230 Glenwood Avenue using telephone number (585)
285-3463 obtained during the previous operation. At the direction of law enforcement, a
controlled call was made to that number and CI-2 arranged to purchase drugs from 230
Glenwood Avenue. While under surveillance by undercover investigators, CI-2 went to the
back door of 230 Glenwood Avenue. A short time later, CI-2 left the location and returned
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to the undercover vehicle. CI-2 handed law enforcement the white, rock-like substance
purchased on this date that appeared to be crack cocaine. The substance later field tested
positive for the presence of cocaine. During the debriefing, CI-2 advised that he/she had
walked to the enclosed porch at the rear of 230 Glenwood Avenue, and knocked on the
door. An unknown male greeted CI-2 through the door and after a brief conversation about
purchasing crack cocaine, CI-2 was allowed into the house. CI-2 handed the unknown male
an amount of U.S. currency and in exchange the unknown male handed CI-2 a quantity of
19. A second controlled buy was conducted during the fourth week of February
2021. At the direction of law enforcement, CI-2 called telephone number (585) 285-3463 and
made arrangements to purchase crack cocaine. Shortly thereafter, CI-2 traveled to the
location while under surveillance and went to the back door of 230 Glenwood Avenue. A
short time later, CI-2 left the location, and returned to the undercover vehicle. CI-2 then
turned provided the investigators with a quantity of white, rock-like substance that appeared
to be crack cocaine, purchased from the SIPLIN DTO that day. The substance later field
tested positive for the presence of cocaine. During the debriefing, CI-2 advised that he/she
walked to the enclosed porch at the rear of 230 Glenwood Avenue and knocked on the door.
CI-2 was met by a black female and a young black male with dreadlocks. CI-2 had a brief
conversation about purchasing crack cocaine and a price and quantity were agreed upon.
CI-2 handed the unknown male an amount of U.S. currency and in exchange the unknown
male handed CI-2 a quantity of white, rock-like substance that appeared to be crack cocaine.
20. During the first week of March 2021, CI-2 called telephone number (585)
285-3463 at the direction of law enforcement. During the controlled call CI-1 arranged to
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purchase a quantity of crack cocaine from 230 Glenwood Avenue. Later that day, CI-2 went
to the back door of 230 Glenwood Avenue. A short time later, CI-2 left the location and
returned to the undercover vehicle. At that time CI-2 handed law enforcement a white,
rock-like substance that appeared to be crack cocaine, purchased that day from 230
Glenwood Avenue. The substance later field tested positive for the presence of cocaine.
During the debriefing, CI-2 advised that he/she walked to the enclosed porch at the rear of
230 Glenwood Avenue and knocked on the door. CI-2 was met by a black female known
as “Storm.” CI-2 had a brief conversation about purchasing crack cocaine from Storm in
exchange for U.S. currency. Shortly thereafter, CI-2 purchased a quantity of crack cocaine
from Storm in exchange for U.S. currency. Storm was later identified as the defendant
Lytrice JACKSON.
21. During the second week of March 2021, CI-2 called (585) 285-3463 at the
direction of law enforcement, and an arranged to purchase crack cocaine from 230
Glenwood Avenue. Shortly thereafter, CI-2 went to the back door of 230 Glenwood Avenue
while under surveillance. A short time later, CI-2 left the location, and returned to the
undercover vehicle. At that time CI-2 provided law enforcement with the white, rock-like
substance purchased that day, which appeared to be crack cocaine. The substance later field
tested positive for the presence of cocaine. During the debriefing, CI-2 advised that he/she
walked to the enclosed porch at the rear of 230 Glenwood Avenue and knocked on the door.
CI-2 was met by a male black who identified himself as “J.” CI-2 had a brief conversation
about purchasing crack cocaine from J, and a price and quantity was agreed upon. CI-2
handed J an amount of U.S. currency and in exchange, J handed CI-2 a quantity of white,
rock-like substance that appeared to be crack cocaine. CI-2 later identified the male “J” as
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the defendant Jason SIPLIN. Additionally, CI-2 was given the phone number (585) 867-
3073 to call in order to reach Jason SIPLIN in the future. It should also be noted that during
this controlled buy, law enforcement was conducting in person and pole camera
surveillance. Members of the investigative team observed that SIPLIN’S rental vehicle (a grey
Subaru with PA license plate LKM6294) was parked in front of 230 Glenwood Avenue during
the above transaction. Prior to the transaction, surveillance shows that the same vehicle was
22. During the third week of March 2021, at the direction of law enforcement
CI-2 called telephone number (585) 867-3073 and arranged to purchase narcotics from 230
Glenwood Avenue. Shortly thereafter, CI-2 traveled to the location while under surveillance
and went to the back door of 230 Glenwood Avenue. A short time later, CI-2 left the
location, and returned to the undercover vehicle. At that time CI-2 provided law
enforcement with the white, rock-like substance purchased from the SIPLIN DTO that day,
which appeared to be crack cocaine. The substance later field tested positive for the presence
of cocaine. During the debriefing CI-2 advised that he/she walked to the enclosed porch at
the rear of 230 Glenwood Avenue and knocked on the door, where CI-2 was met by a male
black whom CI-2 knew as “J.” CI-2 had a brief conversation about purchasing crack cocaine
from J. CI-2 handed the male an amount of U.S. currency and in exchange, J handed CI-2
a quantity of white, rock-like substance that appeared to be crack cocaine. CI-2 then left the
location and returned to the undercover vehicle. CI-2 identified the male “J” as Jason
23. During the 4th week of March 2021, at the direction of law enforcement CI-2
called telephone number (585) 867-3073 and arranged to purchase narcotics from the
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SIPLIN DTO at 230 Glenwood Avenue. Shortly thereafter, CI-2 traveled to the location
while under surveillance and went to the back door of 230 Glenwood Avenue. A short time
later, CI-2 left the location and returned to the undercover vehicle. At that time CI-2
provided law enforcement with the white, rock-like substance purchased from the SIPLIN
DTO that day, which appeared to be crack cocaine. The substance later field tested positive
for the presence of cocaine. During a debriefing CI-2 advised that he/she walked to the
enclosed porch at the rear of 230 Glenwood Avenue and knocked on the door. CI-2 was
met by SIPLIN who had arrived from outside of the house. CI-2 had a brief conversation
about purchasing crack cocaine from SIPLIN. Thereafter, CI-2 handed SIPLIN U.S.
currency and in exchange, SIPLIN handed CI-2 a quantity of white, rock-like substance that
appeared to be crack cocaine, directly from his pocket. After the transaction CI-2 returned
to the undercover vehicle and turned over the white, rock-like substance purchased from
SIPLIN. CI-2 identified SIPLIN as the person who had sold the crack cocaine to CI-2.
24. During the last week of March 2021, at the direction of law enforcement CI-
2 called telephone number (585) 867-3073 and arranged to purchase narcotics from 230
Glenwood Avenue. Shortly thereafter, CI-2 traveled to the location while under surveillance
and went to the back door of 230 Glenwood Avenue. A short time later, CI-2 left the
location, and returned to the undercover vehicle. At that time CI-2 provided investigators
with the white, rock-like substance purchased from the SIPLIN DTO that day, which
appeared to be crack cocaine. The substance later field tested positive for the presence of
cocaine. During the debriefing, CI-2 advised that he/she walked to the enclosed porch at
the rear of 230 Glenwood Avenue, and knocked on the door. CI-2 was allowed inside and
observed SIPLIN in the house. CI-2 had a brief conversation with SIPLIN about
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purchasing crack cocaine and a price and quantity were agreed upon. SIPLIN said he would
be right back and then left 230 Glenwood Avenue before returning a short time later with a
quantity of crack cocaine. CI-2 handed SIPLIN an amount of U.S. currency and in
exchange, SIPLIN handed CI-2 a quantity of white, rock-like substance that appeared to be
crack cocaine, directly from his pocket. CI-2 then left the location and returned to the
undercover vehicle where CI-2 turned over the white, rock-like substance to investigators.
During the same time frame in which this transaction took place, law enforcement observed
SIPLIN exit the rear of 230 Glenwood Avenue and enter the rear of 8 Rainier Street. After
a short while SIPLIN was observed exiting 8 Rainier and returning to 230 Glenwood
Avenue.
25. During the second full week of April, 2021, law enforcement formulated a
plan to have CI-2 attempt to purchase narcotics from the SIPLIN DTO at 230 Glenwood
Avenue. At the direction of law enforcement, CI-2 traveled to the location while under
surveillance and went to the back door of 230 Glenwood Avenue. A short time later CI-2
left the location and returned to the undercover vehicle. At that time CI-2 provided
investigators with the white, rock-like substance purchased from the SIPLIN DTO that day,
which appeared to be crack cocaine. The substance later field tested positive for the presence
of cocaine. During the debriefing, CI-2 advised that he/she walked to the enclosed porch at
the rear of 230 Glenwood Avenue, and knocked on the door. CI-2 was let inside and spoke
to a male who went by the name “Mush.” CI-2 had a brief conversation with Mush about
purchasing crack cocaine, and a price and quantity were agreed upon. CI-2 handed Mush
an amount of U.S. currency and in exchange Mush handed CI-2 a quantity of white, rock-
like substance that appeared to be crack cocaine. CI-2 later identified Jason SIPLIN, JR. as
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the man named Mush who completed this transaction.
26. During the last week of April 2021, law enforcement formulated a plan to
have CI-2 purchase narcotics from the SIPLIN DTO at 230 Glenwood Avenue. At the
direction of law enforcement, CI-2 traveled to the location while under surveillance and
went to the rear of 230 Glenwood Avenue. CI-2 went into the location and after a short
time, SIPLIN was observed entering as well. Shortly thereafter CI-2 left the location and
returned to the undercover vehicle. CI-2 then provided investigators with the white, rock-
like substance purchased from the SIPLIN DTO that day, which appeared to be crack
cocaine. The substance later field tested positive for the presence of cocaine. During the
debriefing CI-2 advised that he/she walked to the enclosed porch at the rear of 230
Glenwood Avenue, and was let inside. After a short time SIPLIN entered the location. CI-
2 had a brief conversation with SIPLIN about purchasing crack cocaine, and a price and
quantity were agreed upon. CI-2 then handed SIPLIN an amount of U.S. currency and in
exchange, SIPLIN handed CI-2 a quantity of white, rock-like substance that appeared to be
crack cocaine.
warrants were issued by the Hon. Michael Dollinger, Monroe County Court Judge, for
telephone numbers associated with the SIPLIN DTO. The following paragraphs are
interpretation of these communications. This affidavit does not present each and every call
intercepted between parties, but merely provides relevant examples that are intended to
demonstrate the involvement of each party. Where pertinent, this affidavit also provides a
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description of surveillance activity performed in connection with a particular communication.
Throughout this investigation, surveillance has been conducted either “in person” by law
enforcement agents on the ground or through video surveillance feeds from cameras located
28. On October 29, 2020, at approximately 10:50 p.m. an incoming call (Ref.# 671)
was lawfully intercepted over target telephone number (585) 820-7677 utilized by GAMBLE.
In this call, an unknown male asks GAMBLE if he is still there, to which GAMBLE replies
yes. The male tells GAMBLE that he wants the same thing and asked him if he remembers
what it was, to which GAMBLE replies, “yea you had 250 right.” The unknown male says
“no, 200.” The unknown male goes on to say that he will be right there and for GAMBLE to
“bag and get him ready.” Based on my training and experience, the unknown male called
GAMBLE and ordered a quantity of narcotics. Cocaine, cocaine base and other controlled
1133) was lawfully intercepted over target telephone number (585) 820-7677 used by
GAMBLE, in which SIPLIN calls GAMBLE. During this call GAMBLE asks SIPLIN if he
grabbed the “G” (based on my training and experience GAMBLE is referring to $1,000).
SIPLIN says yes and then starts to ask if Ernest GAMBLE gave it right back to [a third party].
SIPLIN then asks GAMBLE if he bagged it up to which GAMBLE replies that he did.
GAMBLE tells SIPLIN that “there was 15 here and my $800.00 and 40, and I had got two
cards.” Based on my training and experience, I believe SIPLIN and GAMBLE are discussing
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30. On November 7, 2020, at approximately 3:03 p.m., an outgoing call (Ref.# 187)
was lawfully intercepted during the execution of an eavesdropping warrant over telephone
number (585) 355-1994 used by SIPLIN. In this call, SIPLIN asks what GAMBLE is doing.
GAMBLE tells SIPLIN that he is bagging. SIPLIN comments on the fact that GAMBLE is
still bagging and tells GAMBLE that he will be right there. Based on my training, experience
and knowledge of this investigation, I believe GAMBLE is advising SIPLIN that he is in the
280) was lawfully intercepted over telephone number (585) 355-1994 used by SIPLIN, from
(585) 260-4929 used by GRANISON. The contents of this call are transcribed below. It should
be noted that New Cingular / AT&T records indicate that the services provided to cellular
telephone number (585) 260-4929 are subscribed to in the name of Timothy Granison.
[Start]
JS: What’s good wit you, where you at, you still at the house?
TG: Alright
[End]
Timothy GRANISON called SIPLIN to arrange a meeting that took place at 230 Glenwood
19
Avenue. At the time of this phone call, cellular location data placed SIPLIN’s (585) 355-1994
phone in the area of 230 Glenwood Avenue, Rochester, New York. The investigation has
revealed that the location is solely used to sell illegal narcotics, though it appears that members
of the DTO may occasionally sleep at the house after the conclusion of their shift. Through
covert camera surveillance and physical surveillance, members of the investigative team have
observed customer foot traffic and vehicle traffic to this location at all hours of the day and
night. SIPLIN had previously stated during an intercepted call (Ref.# 4297) that it is not out
of the ordinary for the drug house at 230 Glenwood Avenue to sell approximately two
33. On November 21, 2020, at approximately 9:53 a.m. an incoming call (Ref.#
1983) was lawfully intercepted over telephone number (585) 820-7677 used by GAMBLE.
During the call, an unknown male asks Gamble where SIPLIN is. GAMBLE tells the male
that SIPLIN is in the house. The unknown male tells GAMBLE “This Mush I’m over here.”
GAMBLE tells Mush that SIPLIN probably wanted him to “bag that up.” Based on my
training, experience, and knowledge of the investigation, I believe “bag that up” refers to
packaging a quantity of narcotics for distribution. Mush then replied, in sum and substance,
that that is what he thought too. “Mush” has been identified as Jason SIPLIN, JR.
34. On November 21, 2020, at approximately 11:34 a.m., an outgoing call (Ref.#
1987) was lawfully intercepted over telephone number (585) 820-7677 utilized by GAMBLE.
In this call, GAMBLE calls SIPLIN and says, “we need something, you want me to come get
some.” SIPLIN tells GAMBLE to meet him at the hotel. Based on my training, experience and
knowledge of this investigation, I believe GAMBLE called SIPLIN to advise him that 230
Glenwood Avenue was either out of drugs, or low on drugs, and was asking SIPLIN if he
20
wanted GAMBLE to resupply the house. SIPLIN then tells GAMBLE to meet him at a hotel.
The investigation has revealed that the SIPLIN DTO would utilize hotel rooms to prepare and
35. On November 23, 2020, at approximately 11:18 a.m., an outgoing call (Ref.#
3053) was lawfully intercepted over telephone number (585) 355-1994 used by SIPLIN to (585)
260-4929 used by GRANISON. The contents of this call are transcribed below:
[Start]
TG: Alright.
TG: Alright
[End]
asks GRANISON to come to 230 Glenwood Avenue. SIPLIN then says something
unintelligible about having to give GRANISON what sounds like “a coat” or “coke.” Based
upon my training, experience, and knowledge of this investigation, it is very common for drug
dealers to use code words over the phone, and I believe this exchange to be a reference to the
21
37. On November 27, 2020, at approximately 7:45 p.m., an incoming call (Ref.#
3929) was lawfully intercepted over telephone number (585) 355-1994 used by SIPLIN from
(585) 260-4929 used by GRANISON, the contents of which are transcribed below:
[Start]
JS: Cousin
UM: Alright.
[End]
call GRANISON arranged another meeting with SIPLIN at the drug house located at 230
Glenwood Avenue. At the time of this call SIPLIN’s cellular location data associated with
telephone number (585) 355-1994 places him in the area of 230 Glenwood Avenue.
39. On November 27, 2020, at approximately 7:54 p.m., an incoming call (Ref.#
3936) was lawfully intercepted over telephone number (585) 355-1994 used by SIPLIN from
(585) 260-4929 used by GRANISON, the contents of which are described below:
[Start]
22
JS: You outside cousin?
[End]
GRANISON calls SIPLIN to let him know that he is outside of 230 Glenwood. This call
took place shortly after the previously described call (Ref.# 3929). Just after this call (Ref.#
3936) is placed, surveillance footage from 230 Glenwood Avenue shows a large SUV pull into
view on Rainier Street. The SUV then stops on Rainier Street, which is the street on the west
side of 230 Glenwood Avenue. Within seconds, a male exits the rear door of 230 Glenwood
Avenue and walks over to the SUV. The interior lights of the SUV briefly turn on while the
male who exited 230 Glenwood Avenue stands at the driver’s side door. Within 30 seconds,
the male who exited 230 Glenwood Avenue walks away from the large SUV and goes back
into 230 Glenwood Avenue from the rear door. The large SUV then resumes driving down
Rainier Street. During this encounter, the individual who arrived in the large SUV never exits
the vehicle. Due to the time of night, the quality of the surveillance video makes it difficult to
clearly identify these individuals. However, I believe that the male that exited 230 Glenwood
Avenue and went up to the large SUV was Jason SIPLIN. Timothy GRANISON is the
registered owner of a Toyota Sequoia, which is a large SUV that has the same physical
characteristics as the vehicle observed through the covert surveillance camera. Moments
before this large SUV pulled into the camera frame, GRANISON told SIPLIN that he had
arrived at 230 Glenwood Avenue. As such, I believe the individual in the large SUV was
Timothy GRANISON. Aside from the male believed to be SIPLIN, no one else is observed
entering or exiting 230 Glenwood Avenue during this time frame. Based on my knowledge
23
of this investigation, and the brevity of this meeting, I believe that Timothy GRANISON
went to 230 Glenwood Avenue to conduct a narcotics transaction with Jason SIPLIN.
41. On November 29, 2020, at approximately 10:07 a.m., an incoming call (Ref.#
2586) was lawfully intercepted over telephone number (585) 820-7677 used by GAMBLE. In
this call SIPLIN asks GAMBLE who is at the house. GAMBLE tells him that ‘Smooth” and
“Rar” are at the location. GAMBLE then tells SIPLIN that something they had was “done.”
SIPLIN asks if they still have something there, to which GAMBLE replies yes, “hard.” Crack
cocaine or cocaine base is commonly referred to as “hard” in drug jargon. SIPLIN ends the
42. On December 11, 2020, at approximately 1:25 p.m., an outgoing call (Ref.#
1200) was lawfully intercepted over telephone number (585) 451-4342 used by SIPLIN to
(585) 287-4361 used by Jason SIPLIN, JR., the contents of which are transcribed below:
[Start]
MU: Yo.
MU: Umm, nah, I mean I can call. I can… I can get [unintelligible]. I’m on my way over
there. I just don’t feel like rushin’ and baggin’ it up.
JS: Um. I’m… I’m… I’ll… I’ll… I’ll call her right now
[End]
this call Jason SIPLIN is asking his son, Jason SIPLIN, JR., if his regular quantity of narcotics
is packaged and ready to be distributed. Jason SIPLIN, JR. informs Jason SIPLIN that that
24
he can make a call, but he does not feel like rushing over to the stash house to bag up the
product. Jason SIPLIN then says, “I’ll call her right now.” I believe Jason SIPLIN is referring
to Lytrice JACKSON a/k/a “Storm” when he mentions calling “her.” The investigation has
revealed that one of SIPLIN’s workers by the name of Lytrice JACKSON will oversee day to
44. On December 12, 2020, at approximately 3:29 p.m., an outgoing call (Ref.#
1417) was lawfully intercepted over telephone number (585) 451-4342 used by SIPLIN, to
(585) 287-4361 used by SIPLIN, JR., the contents of which are transcribed below:
[Start]
MU: Yo.
JS: Yo. Go to, um, Get Litty and grab the 34’s.
MU: Aight.
JS: Alright.
[End]
this call Jason SIPLIN is telling Jason SIPLIN, JR. to go to “Get Litty” and grab the “34’s.”
I believe “Get Litty” refers to Get Litty Smoke Shop located at 515 Dewey Avenue in
Rochester, New York, which sells various bags and supplies that are commonly then used by
drug dealers to package narcotics. One bag size that Get Litty Smoke Shop carries is Apple
Brand 3434 bags, which are 3/4” by 3/4” in size. I believe Jason SIPLIN was instructing
Jason SIPLIN, JR. to purchase 3/4” sized bags from Get Litty Smoke Shop, which the
SIPLIN DTO will then use to package narcotics for street sale.
25
46. On December 17, 2020, at approximately 12:25 p.m., an outgoing call (Ref.#
2312) was lawfully intercepted over telephone number (585) 451-4342 used by Jason SIPLIN
to telephone number (585) 287-4361 used by Jason SIPLIN JR., transcribed below:
[Start]
MU: Yo.
JS: I know. I was but, you know, I’m runnin’ around. I’m about to get them now, son. I
mean you gotta… you gotta be there, bro. As a matter of fact, I got… I got… I gotta
take this jewelry to the mall right quick.
MU: Alright.
[End]
believe that in this call, Jason SIPLIN and Jason SIPLIN, JR. are discussing the need to
48. On December 19, 2020, at approximately 8:33 a.m., an incoming call (Ref.#
4592) was lawfully intercepted over telephone number (585) 820-7677 used by GAMBLE, from
SIPLIN. In this call, SIPLIN asks GAMBLE “what’s it look like.” GAMBLE tells SIPLIN
that the first G-pack is almost gone but that they have another one. Based on my training,
experience and knowledge of this investigation, I believe that GAMBLE and SIPLIN are
discussing the available drugs at 230 Glenwood Avenue. GAMBLE tells SIPLIN that the first
26
“G pack” is almost gone, but they have another one. I believe GAMBLE is referring to a
package containing $1,000.00 worth of cocaine base when uses the phrase “G-pack.”
49. On December 23, 2020, at approximately 3:25 p.m., an outgoing call (Ref.#
4543) was lawfully intercepted over telephone number (585) 451-4342 used by Jason SIPLIN
to telephone number (585) 287-4361 used by Jason SIPLIN, JR., transcribed below:
[Start]
MU: Yo.
JS: Mush. Where you got them bags? Get Litty got some?
MU: Nah.
MU: Yeah, the uh, yeah. 38’s. 34’s first then I have 58’s.
[End]
believe Jason SIPLIN and Jason SIPLIN, JR. are discussing the drug packaging baggies they
have at their disposal. When Jason SIPLIN, JR. tells Jason SIPLIN, “They don’t got no more
slims,” I believe that he means that they do not have any more 3/4” bags left. Another bag
size that Get Litty Smoke Shop carries is Apple Brand 5858 bags, which are 5/8” by 5/8” in
27
size. I believe Jason SIPLIN is referring to these bags when he references “58’s” in this
conversation.
51. On December 23, 2020, at approximately 3:26 p.m., an incoming call (Ref.#
4545) was lawfully intercepted over telephone number (585) 451-4342 used by SIPLIN from
(585) 260-4929 used by GRANISON, the contents of which are transcribed below:
[Start]
JS: Hello
TG: Cousin
JS: What’s up
JS: Alright
[End]
23, 2020, at approximately 3:45 p.m., an incoming call (Ref.# 4561) was lawfully intercepted
over telephone number (585) 451-4342 used by SIPLIN from (585) 260-4929 used by
28
JS: Jason Siplin
TG: Timothy Granison
[Start]
JS: Yo
JS: Yo um, when, um, come to Comfort Inn on West Ridge Road, grab me a black and
mild too.
[End]
GRANISON called SIPLIN regarding a meeting at the Comfort Inn by the Red Lobster on
West Ridge Road. Throughout this investigation, surveillance, intercepted phone calls, and
interviews of targets have established that the SIPLIN DTO used hotel rooms to break down,
package, and prepare his cocaine base for street sale. One minute prior to the first phone call
with GRANISON on this date (Ref.# 4545), SIPLIN called his son Jason SIPLIN, JR. (Ref.#
4543), to discuss the what baggies they have available to package narcotics. Based upon this
series of conversations, I believe SIPLIN went to the Comfort Inn this afternoon to prepare
54. On December 23, 2020, at approximately 3:54 p.m., an outgoing call (Ref.#
4564) was lawfully intercepted over telephone number (585) 451-4342 used by SIPLIN to (585)
29
JS: Jason Siplin
TG: Timothy Granison
[Start]
JS: Yep
TG: Alright
[End]
SIPLIN called Timothy GRANISON to check on his status. GRANISON complains that he
56. On December 23, 2020, at approximately 4:02 p.m., an incoming call (Ref.#
4566) was lawfully intercepted over telephone number (585) 451-4342 used by SIPLIN from
[Start]
30
JS: Alright
[End]
GRANISON calls Jason SIPLIN to tell him that he has arrived at the hotel. SIPLIN directs
GRANISON to come to room 209. Based on SIPLIN’s previous conversation with Jason
SIPLIN, JR. inquiring about packaging materials (Ref. # 4543), I believe that SIPLIN is at
the hotel packaging cocaine base for street sale when GRANISON arrives.
58. On January 7, 2021, at approximately 1:39 p.m., an outgoing call (Ref.# 1542)
was lawfully intercepted pursuant to an eavesdropping warrant for target telephone number
(585) 287-4361 used by Jason SIPLIN, JR., to telephone number (585) 284-3775 used by
[Start]
MU: Yo.
MU: Ain’t nothin’ I… I… I had called, uh, Heem. He said they was good like a hour ago.
JS: [yelling at someone in the background] Yo, nigga! Go downstairs and smoke that
shit! I do not want my house smelling like that! Please, bro, I’m just sayin’! Hello?
MU: Yeah yeah yeah, I’m gonna come by and bring that bread.
31
JS: Yeah, I know. You finished that though, right?
MU: Alright.
[End]
believe Jason SIPLIN, JR. is telling Jason SIPLIN that the house at 230 Glenwood Avenue
has enough product for the time being. I believe this because the individual they refer to as
“Heem” is an individual with initials R.G. that is known to work for Jason SIPLIN at 230
Glenwood Avenue selling crack cocaine. When Jason SIPLIN, JR. tells Jason SIPLIN that
he’s going to “come by and bring that bread” I believe Jason SIPLIN, JR. means that he will
be dropping off money to Jason SIPLIN. The term “bread” is commonly used by drug dealers
was lawfully intercepted pursuant to an eavesdropping warrant for telephone number (585)
287-4361 used by Jason SIPLIN, JR. to telephone number (585) 284-3775 used by Jason
[Start]
MU: Yo.
MU: Nah, I was calling to see, uh, when I had talked to Heem, he had said that it was, uh,
a…a… a pack left.
32
JS: Huh?
MU: I said I had called Heem to make sure there was a pack left. I was gonna…
MU: Alright.
JS: Alright.
[End]
believe that Jason SIPLIN, JR. is discussing the quantity of narcotics remaining at 230
62. On March 4, 2021 at approximately 9:58 a.m. an incoming call (Ref.# 146)
was lawfully intercepted over telephone number (585) 867-3073 used by SIPLIN from
telephone number (585) 285-3463 used by JACKSON. In this call JACKSON tells SIPLIN
“I’m done.” At the time of this call SIPLIN is in the area of 62 Clifton Street. At
approximately 10:10 a.m. he is observed via surveillance to be in the area of 230 Glenwood
Avenue.
as my conversations with the investigative team, I believe that JACKSON called SIPLIN to
let him know that she was “done” with her shift selling drugs out of 230 Glenwood Avenue.
Soon after, surveillance officers observed that SIPLIN traveled to 230 Glenwood Avenue
from 62 Clifton Street. The investigation has revealed that JACKSON will occasionally sleep
64. On March 4, 2021 at approximately 7:25 p.m. an incoming call (Ref.# 204)
was lawfully intercepted over target telephone number (585) 867-3073 used by SIPLIN from
33
telephone number (585) 285-3463 used by JACKSON. In this call JACKSON tells SIPLIN
JACKSON is telling SIPLIN that 230 Glenwood Avenue is out of drugs to sell and that she
66. On March 7, 2021 at approximately 11:40 a.m. an outgoing call (Ref.# 265)
was lawfully intercepted over telephone number (585) 285-3463 used by Lytrice JACKSON
to target number (585) 867-3073 used by SIPLIN. In this call JACKSON tells SIPLIN that
there is a line forming “out here” and that “they coming.” SIPLIN says he will “call them.”
After this call (at approximately 11:40 a.m.) surveillance officers observed a white Ford
Taurus (NY registration JJW3772) leaving 62 Clifton Street. At approximately 11:46 a.m.
the same Ford Taurus pulls up to 230 Glenwood Avenue. A black female is observed getting
out of the passenger seat and motions to the customers waiting outside of the house as she
that JACKSON called SIPLIN because 230 Glenwood Avenue was out of drugs to sell and
a line was forming outside of the location. I believe that shortly after this call with JACKSON,
SIPLIN sent the white Taurus from 62 Clifton Street to resupply 230 Glenwood Avenue with
drugs.
68. On March 8, 2021, at approximately 6:33 p.m. an incoming call (Ref.# 450) was
lawfully intercepted over telephone number (585) 867-3073 used by SIPLIN from (585) 260-
4929 used by GRANISON. The contents of the call are transcribed below:
34
JS: Jason Siplin
TG: Timothy Granison
[Start]
JS: Yo
JS: Whhaaawaa
[End]
69. In this call GRANISON calls SIPLIN and says, “wild line, cousin.” Jason
SIPLIN responds briefly, and the call disconnects. The duration of this call was 14 seconds
in its entirety. Following this phone call, GRANISON was observed arriving at 62 Clifton
Street at 6:51 p.m. in a large SUV, and then entering the location. N.B., another drug
trafficking associate of the SIPLIN DTO, arrived at 62 Clifton Street at 7:07 p.m. and entered
the location. Shortly thereafter Jason SIPLIN arrived at 62 Clifton Street and entered the
location at 7:16 p.m., after parking his vehicle on the street. Based on my training, experience,
and knowledge of this investigation, I believe 62 Clifton Street is the stash house where
SIPLIN stores bulk quantities of narcotics. 60/62 Clifton Street is a multi-family dwelling
located in the City of Rochester. 62 Clifton Street is located in the rear of this multi-family
dwelling and is accessed through the northern-most porch on the east side of the dwelling.
Jason SIPLIN, Jason SIPLIN, JR., GRANISON, N.B., and several others have been
observed accessing this location over the course of the investigation, but no customer foot
traffic has been observed here. On several occasions, calls have been intercepted to or from
one of SIPLIN’s phones indicating that 230 Glenwood Avenue is running low on narcotics,
at which time SIPLIN or SIPLIN, JR. have then made a brief stop inside 62 Clifton Street
35
70. On this date, four minutes after Jason SIPLIN arrived at 62 Clifton Street,
Timothy GRANISON was observed leaving the location in a large SUV, identified through
camera surveillance as a Toyota Sequoia. Plain clothes officers observed the license plate for
this vehicle to read GYB 1199. Records for GYB 1199 indicate that the Toyota Sequoia is
1199’s registration records show this registration has subsequently been replaced by KKV
6346. A surveillance team followed GRANISON from 62 Clifton Street. GRANISON made
two short stops at convenience stores, and then traveled back to 93 Woodman Park. Based
on my training, experience, and knowledge of this investigation, I believe “wild line” is a code
word used to meet at SIPLIN’s stash house at 62 Clifton Street. N.B. was observed leaving
62 Clifton Street at 7:55 p.m. and returning at 8:17 p.m. At 8:30 p.m., N.B. left the location
once again.
71. On March 9, 2021, at approximately 6:01 p.m., an outgoing call (Ref.# 492) was
lawfully intercepted over telephone number (585) 867-3073 used by SIPLIN to (585) 690-6209
used by an associate of the SIPLIN DTO with the initials J.S. The contents of this call are
transcribed below:
[Start]
UM: Yo.
UM: Yea, I’m still at the house right now, I’m about to leave though.
36
JS: Oh umm, Tim brung you my sneakers?
UM: Yea.
JS: Oh. Alright, how long you about to leave cause I’m about to have ca, Cam come get
um.
UM: Angel.
UM: In my studio.
JS: Alright.
[End]
72. In this call SIPLIN asks J.S. if Tim (meaning GRANISON) dropped off his
“sneakers,” which J.S. confirms. J.S. is one of SIPLIN’s children and resides with SIPLIN at
14 Elwood Drive. Based on the contents of this call and surveillance operations, I believe 14
Elwood Drive is the location being discussed throughout this call. SIPLIN tells J.S. that he
wants to send someone by the house to get “them,” but J.S. tells SIPLIN that he is planning
on leaving soon. SIPLIN then asks if anyone else was at the house. When J.S. tells SIPLIN
37
that an individual named “Angel” was in the house, SIPLIN asks “where did you put it” no
longer referring to the delivery as “sneakers.” J.S. tells SIPLIN that he put the delivery in his
Nike bag, which is in his studio. During SIPLIN’s conversation with J.S. he appeared to be
concerned about leaving the delivery unattended while “Angel” was at 14 Elwood Drive
alone. Based on my training and experience, it is common for drug dealers to use code words
to describe narcotics or other illegal activities in an effort to evade prosecution. I believe that
when SIPLIN asks J.S. where he put “it” SIPLIN is referring to a quantity of narcotics or
73. Prior to the above described call between SIPLIN and J.S., surveillance officers
GRANISON exited his vehicle without anything in his hands and entered 14 Elwood Drive.
Based on my training and experience, it is common for narcotics traffickers to carry and
conceal narcotics or U.S. currency on their person. Twenty minutes after the above described
call, at approximately 6:22 p.m., Timothy GRANISON’s vehicle was observed as it returned
to 14 Elwood Drive and pulled into the driveway. Four minutes later, GRANISON’s vehicle
was observed leaving the location. Based on my training, experience, and knowledge of this
narcotics or U.S. currency he had dropped off earlier, due to SIPLIN’s concern about leaving
74. On March 15, 2021, at approximately 4:50 p.m., an outgoing call (Ref.# 1153)
was lawfully intercepted over telephone number (585) 867-3073 used by SIPLIN to (585) 260-
38
JS: Jason Siplin
TG: Tim Granison
[Start]
TG: Hello?
TG: Nah, I’m in Greece. I’m taking her to the Mall to get her hair done.
TG: Alright
[End]
75. On March 15, 2021, at approximately 5:30 p.m., an outgoing call (Ref.# 1159)
was lawfully intercepted over telephone number (585) 867-3073 used by SIPLIN to (585) 260-
[Start]
TG: Yeah
JS: Oh, I’m bout to um, buy my thing out there. I’m bout to come out there right quick
to you anyways so I can give you the [inaudible]. Damn.
TG: Alright, I’m, I’m on the, I’m on the Long Pond side.
39
JS: Alright
TG: Alright
JS: [apparently talking to someone in the background] Which one you want to take?
[End]
76. Twenty minutes later, on March 15, 2021, at approximately 5:52 p.m., an
outgoing call (Ref.# 1164) was lawfully intercepted over telephone number (585) 867-3073 used
by SIPLIN to (585) 260-4929 used by GRANISON. The contents of this call are transcribed
below:
[Start]
TG: Yo
TG: I’m right on the part of Long Pond by Macy’s. I’m sitting out, way out in the parking
lot. You’ll see me.
TG: Alright
JS: Yeah
[End]
77. Surveillance was conducted in connection with the three calls described above
that took place on March 15, 2021, between 4:50 p.m. and 5:52 p.m. (Ref.#s 1153, 1159 and
1164). In sum and substance, GRANISON and SIPLIN make arrangements to meet up at
the Greece Ridge Mall. At 5:52 p.m., SIPLIN calls GRANISON to try to figure out where
40
exactly GRANISON is at the mall. GRANISON tells SIPLIN that he is by Macy’s “way out
in the parking lot.” SIPLIN was then observed by plain clothes officers pulling up to
GRANISON’s vehicle in his new Mercedes. At 5:53 p.m., SIPLIN was observed getting into
GRANISON’s vehicle. At 5:56 p.m., SIPLIN exited GRANISON’s vehicle, returned to his
Mercedes, and proceeded to drive away. At 6:00 p.m., GRANISON drove away from his
parking spot in the Macy’s parking lot onto West Ridge Road, and then reentered the Mall
parking lot on the other side by the Target entrance. At 6:30 p.m., GRANISON returned to
the Macy’s parking lot. At no point did GRANISON exit his vehicle. Based on my training,
experience, and knowledge of this investigation, I believe that SIPLIN met up with
SIPLIN and GRANISON met in a remote area of the parking lot near Macy’s for
approximately three minutes. I believe that GRANISON then moved his vehicle between
parking lots in an effort to reveal law enforcement surveillance or to discreetly assess what
SIPLIN had just brought him. It is a common practice for drug dealers to “clean themselves
off” after a drug transaction by driving around a block or by making several right hand or left
hand turns in a row. These evasive tactics are used to reveal or evade police surveillance.
Cellular location data places SIPLIN’s phone in the area of 14 Elwood Drive during the
second call that he makes to GRANISON (Ref.# 1159) prior to their meeting at the mall.
From Elwood Drive, SIPLIN’s cellular location data then places him in the area of Greece
78. On March 31, 2021, at approximately 8:48 p.m. an outgoing text message
(Ref.# 780) was lawfully intercepted over telephone number (585) 260-4929 used by
41
TG: Timothy Granison
DD: Dkeidron Dublin
[Start]
[End]
GRANISON sent Dkeidron DUBLIN the text message “Uber is in route” to let DUBLIN
know that GRANISON would be arriving shortly with a delivery of narcotics. Drug dealers
will frequently use coded, cryptic and guarded jargon to discuss narcotics transactions and to
arrange meetings. At 8:50 p.m., GRANISON received an incoming text message (Ref.# 782)
from (585) 360-6846 used by DUBLIN that simply read “ok.” On March 31, 2021 at
pulling into the driveway of 5 Birch Crescent. At 8:58 p.m., an incoming text message (Ref.#
787) to GRANISON from DUBLIN at (585) 360-6846 read “pulling up.” Shortly thereafter,
a short black male was observed entering the passenger side of GRANISON’s Toyota
Sequoia. At approximately 9:10 p.m. members of the surveillance team observed this same
person exiting the passenger side of GRANISON’s vehicle and then entering 5 Birch
Crescent. Based on the positioning of the surveillance units it is unclear if the individual came
from the house or some other location prior to entering GRANISON’s vehicle. The Toyota
Sequoia then drove away from 5 Birch Crescent. Over the course of the investigation your
affiant has learned that Dkeidron DUBLIN resides at 5 Birch Crescent. DUBLIN is a black
male that is 5’2” and approximately 110 pounds. Based on the foregoing text messages and
42
80. On April 1, 2021, at approximately 1:10 p.m. an incoming call (Ref.# 826) was
lawfully intercepted over telephone number (585) 867-3073 used by SIPLIN to telephone
number (585) 260-4929 used by GRANISON. The contents of this call are transcribed below:
[Start]
TG: Hello
JS: Damn
TG: Hello
JS: Oh word
TG: Yea
JS: Oh, what you doing over there? I’m right here on Jefferson, I’m near the umm, right
over here.
TG: Alright
JS: Alright
[End]
brief conversation indicates an already planned meeting. Over the course of this investigation,
SIPLIN and GRANISON have kept telephone conversations brief, instead repeatedly
43
arranging for face to face meetings. I believe they avoid speaking over the phone due to
concern over the possibility that their conversations will be intercepted by law enforcement.
82. On April 1, 2021, at approximately 1:26 p.m. an outgoing call (Ref.# 827) was
intercepted over telephone number (585) 260-4929 used by GRANISON to (585) 867-3073
used by SIPLIN.
[Start]
JS: I’m, Cousin, I’m in um at in the fish market at the um um beauty salon, hairdo store
TG: Oh
TG: Alright
JS: mm
[End]
called GRANISON to meet him at the fish market and beauty salon located at 626 West Main
Street in Rochester, New York. Shortly after this call, a surveillance team observed SIPLIN
and GRANISON park next to each other in the rear parking lot of this location. The
surveillance team further observed SIPLIN enter the passenger side door of GRANISON’s
vehicle. After approximately five minutes, SIPLIN returned to his vehicle, and both parties
drove away in opposite directions. The surveillance team was unable to follow GRANISON
due to his erratic driving. Based on my training and experience, I believe SIPLIN and
GRANISON met up in order to conduct a narcotics transaction. I also believe that the erratic
44
driving patten engaged in by GRANISON was designed to either reveal or evade law
enforcement surveillance.
84. On April 5, 2021, at approximately 3:55 p.m. an incoming call (Ref.# 1225)
from (585) 360-6846 used by DUBLIN to (585) 260-4929 used by GRANISON was lawfully
below:
[Start]
TG: Hello
DD: You make it hard out here for a pimp don’t you
TG: You know, so my number be the same for twenty years you know
DD: Nah, if I aint just think about it I probably wouldn’t of called now
TG: Nah it wasn’t that I was just waiting on you, I was going to kill two birds with one
stone, ha ha
TG: Yeah, yeah, yeah yeah, yup sure enough, you um, you want me to slide by it
TG: Alright
45
TG: Oh word
TG: Nah, nah, nah, nah, nah, tonight, the morning it don’t matter
DD: Yeah, I’ll probably hit you before it gets too late
DD: oh shoot, yeah so, I’ll try and hit you before it gets too late
TG: Alright
DD: Alright
TG: Peace
[End]
85. In this call GRANISON and DUBLIN speak about possibly meeting up. At
one-point DUBLIN tells GRANISON to “just put it with my next order.” DUBLIN tells
GRANISON that he will probably call him before the night is over. DUBLIN asks
GRANISON if he needs more time. Based on my training, experience, and knowledge of this
GRANISON is not known to sell legitimate, legal products. DUBLIN asks GRANISON if
he needs more time to complete the order. I believe this to mean that DUBLIN is questioning
whether or not GRANISON has enough product on hand, or if he needs more time to acquire
86. On April 5, 2021 at approximately 6:40 p.m. an incoming call (Ref.# 1245)
from (585) 360-6846 used by DUBLIN, to target telephone number (585) 260-4929 used by
46
TG: Timothy Granison
DD: Dkeidron Dublin
[Start]
TG: Hello
DD: Yea yo
TG: Yo
DD: I will a
TG: Alright
TG: Alright
[End]
Timothy GRANISON and DUBLIN are discussing a narcotics transaction. DUBLIN tells
GRANISON “I need two of them” which I believe is a coded request for twice the amount
this date, a surveillance team observed GRANISON operating his Toyota Sequoia and
pulling into the driveway of 5 Birch Crescent. A few seconds later, GRANISON moved his
vehicle to allow a small SUV bearing New York registration GBL2378, with an unknown
female driver, to pull in. At approximately 7:16 p.m., the surveillance team observed a male
with a very small build exit 5 Birch Crescent and enter the front seat of GRANISON’s vehicle.
At approximately 7:19 p.m., the surveillance team observed GRANISON drive around the
block with the unknown male. GRANISON drove from Birch Crescent, to Main Street, to
47
Circle Street, to Goodman Street, and back to 5 Birch Crescent. The unknown male then
exited the front seat of Timothy GRANISON’s Toyota Sequoia, removed an infant out of the
backseat of the small SUV bearing NY GBL2378, and then walked into 5 Birch Crescent.
Thereafter GRANISON left the location, traveling east bound on Main Street. At 8:14 p.m.
Birch Crescent on this date. DUBLIN’s physical appearance is consistent with the male seen
meeting with GRANISON outside of 5 Birch Crescent, and DUBLIN is known to reside at
this location.
88. On April 14, 2021, at approximately 4:32 p.m., an outgoing call (Ref.# 5) from
(585) 857-8489 used by SIPLIN to telephone number (585) 867-1292 used by Jason SIPLIN,
JR., was lawfully intercepted pursuant to an eavesdropping warrant. The contents of the call
[Start]
MU: Yo.
MU: Yeah.
JS: Man. Aight. What time is it? Just, um, just go over there with the scale and shit and,
umm…
48
MU: Yeah. That’s what I’m gonna do. But, um, also, uh, I went to Home Depot a couple
of times with Max. I didn’t know if you wanted… I wanted to tell you how much.
(unintelligible)… or whatever. Imma go over there. Imma hit ‘em.
JS: Yeah just, um, just weigh out 4… all 4 should be 60 and we’ll figure out the rest for
now.
MU: Ok.
JS: Aight.
MU: Aight.
[End]
believe Jason SIPLIN is telling Jason SIPLIN, JR. to take a scale and then measure out four
(4) “62’s” of cocaine. A “62” in drug jargon is a commonly used term to describe
approximately 62 grams of cocaine. The investigative team has learned over the course of this
investigation that Jason SIPLIN is known to shortchange customers, so when he says that
“all 4 should be 60,” I believe he is instructing Jason SIPLIN, JR. to fill each “62” bag with
only 60 grams of cocaine. For context, a $10 bag of cocaine base that would be sold to an
individual drug user would typically contain approximately 0.1 grams of cocaine.
90. In connection with this call (Ref.# 5) intercepted on April 14, 2021, involving
Jason SIPLIN and Jason SIPLIN, JR., members of the investigative team conducted
matching the description of a vehicle driven by Jason SIPLIN, JR. pulled into the driveway
of 62 Clifton Street. A male that fits the physical description of Jason SIPLIN, JR. was then
observed exiting the front driver’s side of this vehicle and entering the residence at 62 Clifton
Street. This took place approximately 20 minutes after Jason SIPLIN instructed Jason
SIPLIN, JR. to go “weigh out 4.” I believe Jason SIPLIN, JR. went to 62 Clifton Street to
49
weigh out four (4) “62s” of cocaine in response to SIPLIN’s instructions.
91. On April 14, 2021, at approximately 9:44 p.m., an outgoing call (Ref.# 1009)
from telephone number (585) 867-7445 used by Jason SIPLIN, JR. to Get Litty Smoke Shop
[Start]
GL: Yeah.
[End]
believe Jason SIPLIN, JR. was calling “Get Litty Smoke Shop” looking for beakers. Beakers
are commonly used by crack cocaine dealers to transform powder cocaine into cocaine base.
93. On April 14, 2021, at approximately 9:44 p.m. an outgoing call (Ref.# 1010)
over telephone number (585) 867-7445 used by Jason SIPLIN, JR., to telephone number (585)
635-2039 used by an individual known to have the initials F.R. was lawfully intercepted
pursuant to an eavesdropping warrant. The contents of this call are transcribed below:
50
MU: Jason SIPLIN JR. a/k/a “Mush”
FR: Associate of the SIPLIN DTO with initials F.R.
[Start]
FR: Yo.
FR: I’m all done, bro. I did it. I found mine, yeah.
MU: [laughs] Aight. Whatchu gonna come get it? Or you gonna drop it off to me?
MU: Shit. I’m still… I’m still… I was just about to leave Glen.
FR: Yeah, it doesn’t matter. Call me when you get there. I’m not even 2 minutes away.
MU: Aight.
FR: Aight.
[End]
believe Jason SIPLIN, JR. was asking F.R. if he would be able to cook crack cocaine using a
1,000-milliliter beaker. This coincides with an earlier call by Jason SIPLIN, JR. to “Get Litty
Smoke Shop” (Ref.# 1009) when Jason SIPLIN, JR. inquired about the sizes of glass beakers
the shop had in stock. In this call (Ref.# 1010) F.R. tells Jason SIPLIN, JR. that he no longer
needs one as he had found his own glass beaker. Jason SIPLIN, JR. tells F.R. that he is about
to leave “Glen.” I believe “Glen” is short for 230 Glenwood Avenue, Jason SIPLIN’s main
51
crack cocaine distribution location.
95. On April 24, 2021, at approximately 5:21 p.m., an incoming text message
(Ref.# 2902) was lawfully intercepted over telephone number (585) 260-4929 used by
GRANISON to telephone number (585) 360-6846 used by DUBLIN. In this text message,
GRANISON asks DUBLIN “Did you want an Uber today or tomorrow?” During a follow
up text message (Ref.# 2904) moments later, DUBLIN tells GRANISON “Tomorrow to be
“Tomorrow to be safe.”
96. On May 3, 2021, at approximately 9:41 a.m., a series of calls and text messages
(Ref.#s 353, 355, 357, 359, 363, 365, 367, 369, 371, 373, 375, 377, 379, 381, 383, 385, 387,
389, 391, 393, 395, 401, 403, 405, 415, 419, 420) were lawfully intercepted during the
DUBLIN, from an unknown male who was later identified as a person with initials R.B.,
using telephone number (585) 443-9109. In sum and substance, R.B. text messages DUBLIN
and writes that he’s coming up and needs “hard, soft and boy.” These terms are commonly
used drug jargon that refer to crack cocaine, powder cocaine and heroin or fentanyl,
knowledge of this investigation, I believe DUBLIN was telling R.B. to come to 5 Birch
97. On the same date, at approximately 10:30 a.m. members of the New York State
Police were conducting surveillance in the area of 5 Birch Crescent. The troopers observed an
individual later identified as R.B. exit the passenger side of a vehicle parked near 5 Birch
52
Crescent and then enter the location. Shortly thereafter, R.B. left 5 Birch Crescent and got
back into the same vehicle, which began to drive away. A vehicle and traffic stop was
conducted by NYSP Troopers who identified R.B. and recovered small baggies containing
98. On May 7, 2021, at approximately 12:08 p.m., an outgoing text message (Ref.#
3808) was intercepted over telephone number (585) 260-4929 used by GRANISON to (585)
360-6846 used by DUBLIN. The contents of this text message are transcribed below:
TG: Yes, I have your lawn more [sic] that I borrow let me know when you
want me to bring it
(Ref.# 3810) was intercepted over telephone number (585) 260-4929 used by GRANISON
DD: Kool
100. On May 7, 2021, at approximately 12:13 p.m., an outgoing text message (Ref.#
3812) was intercepted over telephone number (585) 360-6846 used by DUBLIN from (585)
(Ref.# 3860) was lawfully intercepted over telephone number (585) 360-6846 used by
DUBLIN from (585) 260-4929 used by GRANISON. The contents of this call are described
below:
53
TG: Timothy Granison
DD: Dkeidron Dublin
[Start]
TG: Alright, you tell me…. I can come there… it’s up to you.
TG: Alright
TG: Yea…Yea…Yea…Yea
TG: Right
[End]
102. On May 7, 2021, at approximately 8:23 p.m. video surveillance obtained from
the Delta Sonic located on 718 East Ridge Road shows GRANISON’s vehicle parked near
pump number one. At the same time a dark colored Dodge Durango pulls up to pump number
two. DUBLIN can be seen exiting the back seat of the Dodge Durango and entering
GRANISON’s vehicle. A few seconds later DUBLIN exits GRANISON’s vehicle and
returns to the Dodge Durango, which then pulls away. Based on my training, experience and
knowledge of this investigation, I believe that GRANISON met with DUBLIN at the Delta
Sonic to resupply him with a quantity of narcotics. No lawn mower was observed during the
brief meeting at Delta Sonic described above. I believe that lawn mower was a coded phrase
54
meaning a quantity of narcotics, most likely cocaine.
103. On May 14, 2021, at approximately 2:34 p.m., an incoming telephone call
(Ref.# 4353) was lawfully intercepted over telephone number (585) 260-4929 used by
[Start]
TG: [unintelligible]
DD: Shit I need an Uber you gotta go get an oil change first?
TG: Ahh not really I’m just waiting for my daughter to get here on the bus.
DD: Oh alright.
TG: Alright.
DD: Alright.
TG: I’ll hit you as soon as she get here she be here by like 3:05, 3:10.
TG: Alright.
[End]
104. On May 14, 2021, at approximately 2:34 p.m., an incoming telephone call
(Ref.# 4358) was lawfully intercepted over telephone number (585) 260-4929 used by
55
The contents of this call are transcribed below:
[Start]
DD: Yo
TG: Oh yeah
DD: Yeah
TG: Oh, okay, I’m about to drop this uuhmm, this ahh sticker off
DD: Alright
TG: Cause I got my daughter with me but I don’t got, I got to get some tape, oh I do got
tape, alright.
DD: Alright
TG: Alright
[End]
105. On May 14, 2021, at approximately 3:19 p.m. Investigator Tom Walton and
Senior Investigator Scott Shepard observed Timothy GRANISON leave 93 Woodman Park,
Rochester, New York, operating his Toyota Sequoia, with his young daughter in the front
passenger seat of the vehicle. The troopers continued surveillance and observed GRANISON
drive directly to 5 Birch Crescent. Surveillance officers observed GRANISON park in front
of 5 Birch Crescent and retrieve a box from the back seat of his vehicle. The surveillance team
observed DUBLIN walk towards GRANISON’s vehicle at which point both GRANISON
and DUBLIN entered the back seat of the vehicle, out of sight of the officers. Shortly
thereafter, the surveillance team observed DUBLIN get out of GRANISON’s vehicle and
56
walk back to 5 Birch Crescent while holding a bag. GRANISON drove away from the
location a few moments later. Based on my training, experience and knowledge of this
date when they met up in front of 5 Birch Crescent. Prior to this meeting DUBLIN called
GRANISON and asked for an “Uber.” As described in other portions of this affidavit, I
believe that “Uber” is a code word used by GRANISON and DUBLIN meaning a quantity
of narcotics.
106. On May 16, 2021, beginning at approximately 10:21 a.m. a series of text
messages and calls, (Ref.#s 5904, 5912, 5916, 5918, 5963) were lawfully intercepted pursuant
to an eavesdropping warrant over telephone number (585) 360-6846 used by DUBLIN and
telephone number (585) 260-4929 used by GRANISON. In sum and substance DUBLIN asks
GRANISON if he is “up and at it yet” to which GRANISON responds “10 min.” A related
telephone call (Ref.# 5993) was intercepted in which GRANISON told DUBLIN to come
out, to which DUBLIN responds, “I’m out here let me back up.” Shortly thereafter,
GRANISON was observed via surveillance as he arrived at 5 Birch Crescent in a black, 2013
Lincoln MKS bearing New York Registration JRE 6888. A records check revealed that this
vehicle is registered to an individual with the initials L.W. at 93 Woodman Park, Rochester,
107. Shortly after GRANISON arrived at 5 Birch Crescent, the surveillance team
observed DUBLIN exit a Dodge Durango and approach the driver’s side of the Lincoln MKS.
GRANISON and DUBLIN had a short exchange and then GRANISON left the location,
while DUBLIN returned to the Dodge Durango. At approximately 11:45 a.m. the
57
108. Based on my training, experience and knowledge of this investigation, I believe
DUBLIN and GRANISON met in front of 5 Birch Crescent on this date in order to conduct
a narcotics transaction.
109. On May 19, 2021, at approximately 3:15 p.m., a telephone call (Ref.# 4784)
was intercepted over telephone number (585) 260-4929 used by GRANISON from (585) 360-
6846 used by DUBLIN, pursuant to an eavesdropping warrant. The contents of this call are
transcribed below:
[Start]
DD: Yoooo
TG: Alright
[End]
58
SEARCH WARRANTS
111. On or about May 17, 2021 and May 18, 2021, the Hon. Michael Dollinger,
Monroe County Court Judge, issued search warrants for a number of locations relating to this
investigation including: 230 Glenwood Avenue, Rochester, New York; 14 Elwood Drive,
Rochester, New York; 62 Clifton Street, Rochester, New York; 2013 Norton Street,
Rochester, New York; and 5 Birch Crescent, Apartment 3, Rochester, New York, among
other locations. These search warrants were executed throughout the afternoon and evening
of May 19, 2021. The results from these search warrant executions are described below.
5 BIRCH CRESCENT
112. A search warrant for 5 Birch Crescent (Apartment No. 3), Rochester, New
York, was executed on May 19, 2021 in conjunction with surveillance operations. More
specifically, after the 3:15 p.m. telephone call (Ref.# 4784) between GRANISON and
DUBLIN described above, the New York State Police were anticipating an imminent
narcotics transaction between the targets at 5 Birch Crescent. At approximately 3:23 p.m.
Timothy GRANISON’s Toyota Sequoia was observed pulling up to 5 Birch Crescent. Shortly
GRANISON’s vehicle and entered through the front passenger side door. At this point law
enforcement moved in quickly and detained both GRANISON and DUBLIN. A “31” or a
bag of cocaine equaling approximately 31 grams was found wrapped in a paper towel on the
floor of GRANISON’s vehicle, in the backseat behind the center armrest area. DUBLIN was
experience and knowledge of the investigation, I believe DUBLIN was in the process of
59
purchasing the “31” from GRANISON, when both men were taken into custody.
113. After GRANISON and DUBLIN were secured, a thorough search of the
premises was conducted. 5 Birch Crescent is broken into three apartments. The third
apartment is the residence of DUBLIN. Among other items recovered during this operation
was DUBLIN’s driver’s license, which listed 5 Birch Crescent, Apartment 3, Rochester, New
York as his residence. In the kitchen of 5 Birch Crescent, Apartment 3, to the right of the stove
in an upper drawer, the State Police located a quantity of cocaine base, a razor blade, a scale
and numerous new and unused plastic baggies commonly used to package narcotics.
Approximately $400.00 in U.S. currency was found on a wine rack in the kitchen. In the
kitchen closet, multiple new and unused glassine baggies were located on the fourth shelf. On
the top shelf of the same closet, the State Police located a Walther P22, .22 caliber
semiautomatic pistol bearing serial No. WA017726. The firearm was unloaded but next to
the gun was an appropriate magazine that was loaded with one round of .22 caliber
ammunition. Based on my training and experience, I am aware of the fact that drug traffickers
or dealers will often unlawfully carry or possess firearms in order to protect themselves, their
narcotics, and/or proceeds from narcotics sales from being forcibly taken by others. Drug
dealers are frequently the target of robberies, as they are known to be in possession of valuable
narcotics or large amounts of U.S. currency due to the nature of their business. As such, I
believe DUBLIN possessed this firearm in the furtherance of a drug trafficking crime for
which he could be prosecuted in a Court of the United States, namely, violations of Title 21,
60
62 CLIFTON STREET
114. On May 19, 2021 at approximately 6:25 p.m., members of the investigative
team executed a search warrant for 62 Clifton Street, Rochester, New York. No individuals
were encountered in the premises. After the location was secured a thorough search of the
premises was conducted, during which law enforcement located the following property of an
evidentiary nature: approximately 877.22 grams of bulk cocaine were located on the floor of
cocaine base were recovered on the floor in one of the location’s bedrooms. These substances
were later field tested by properly trained members of the investigative team, and each field
test returned a positive result for the presence of cocaine. Additional materials indicative of
drug trafficking were also recovered from 62 Clifton Street including: four boxes of baking
soda, commonly used as a cutting agent; three digital scales, commonly used by drug dealers
to weigh out various quantities of narcotics; new and unused small plastic baggies, frequently
used to package individual quantities of narcotics, including cocaine and cocaine base.
Beakers and other paraphernalia associated with cooking cocaine base were found in the
kitchen with noticeable amounts of what appeared to be cocaine residue. The location was
equipped with a security camera system I believe to be capable of recording and displaying
video in real time, as well as the hard drive the device was connected to. The security cameras
were connected to a television mounted to a wall in the living room. Still images of Jason
SIPLIN could be observed on the security camera display. Based on my training, experience
and knowledge of this investigation, the quantities of cocaine and cocaine base recovered
from 62 Clifton Street clearly demonstrate an intent to distribute controlled substances. Jason
SIPLIN was not at the location at the time the search warrant was executed. SIPLIN was
61
taken into custody at 26 North Clinton Avenue, Rochester, New York, by supporting officers.
115. Members of the investigative team also executed a search warrant for 230
Glenwood Avenue on May 19, 2021, at approximately 6:19 p.m. Upon breaching the
location, law enforcement made contact with a number of individuals including Ernest
GAMBLE and Lytrice JACKSON, among others. Everyone inside of the house was called
down from the upstairs portion of the premises, and this process took several minutes to safely
complete. It appears that individuals within the location were in the process of flushing
narcotics down an upstairs toilet, as 81 small plastic baggies containing cocaine base were
recovered from an upstairs bathroom toilet bowl. Once 230 Glenwood Avenue was secured,
law enforcement conducted a thorough search of the premises. Eight (8) baggies of cocaine
base were found spread around the floor of the living room. Five (5) baggies of cocaine base
were located on a kitchen counter. Walkie-talkies were recovered on the kitchen floor and
living room floor. A closed-circuit television system and DVR were recovered. The system’s
cameras were mounted throughout the premises, facing out to areas surrounding 230
Glenwood Avenue. Three (3) digital scales were located in the living room on top of a table.
Two (2) digital scales were located in the upstairs master bedroom. Mail and other personal
paperwork were recovered from the upstairs master bedroom addressed to Lytrice
JACKSON. At least one piece of bank mail was addressed to Lytrice JACKSON at 230
Glenwood Avenue. A sample of the cocaine base recovered from this location was field tested
and returned a positive result for the presence of cocaine. In total, approximately $10,888.00
in U.S. currency was recovered from the premises or individuals within the premises. Ernest
GAMBLE had approximately $5,470.00 in U.S. currency on his person when taken into
62
custody. Investigators found approximately $1,078.00 in U.S. currency on the kitchen floor
and $1,407.00 in U.S currency on the living room floor. This large amount of U.S. currency
is consistent with narcotics trafficking, particularly for a drug house that services numerous
traffickers that manage drug houses such as 230 Glenwood Avenue will routinely pick up
money from the drug house as it accumulates each day, and bring that money to another,
116. On May 19, 2021 at approximately 8:39 p.m. a search warrant was executed at
the premises known as 2013 Norton Street, Rochester, New York, the residence of Jason
SIPLIN, JR. As agents were preparing to execute the search warrant for this location,
SIPLIN, JR. left the premises, entered a Nissan Sentra, and began driving away. The search
warrant also authorized the search of Jason SIPLIN, JR., the Nissan Sentra he was traveling
in, and a Subaru Outback that was parked at the location. Law enforcement stopped SIPLIN,
JR. as he drove away from the location in the Nissan Sentra and located approximately
$62,581.00 in U.S. currency inside of the vehicle, bundled with rubber bands. Approximately
$300.00 U.S. currency was recovered from SIPLIN, JR.’s person, along with individually
packaged baggies of cocaine. Another 8.5 grams of cocaine were found within the center
armrest of the other vehicle (that is, the parked Subaru Outback). Paperwork in SIPLIN, JR.’s
117. A thorough search of 2013 Norton Street was conducted, and the following
property of an evidentiary nature was recovered: approximately 250 grams of cocaine was
63
found throughout house, the bulk of which was located in the basement; numerous new and
unused plastic Ziploc style baggies commonly used to package narcotics for individual sale;
paperwork in the name of both Jason SIPLIN and Jason SIPLIN, JR.; City of Rochester
records for 8 Rainier Street; and numerous cellular phones. Samples from the cocaine
recovered from this location, the vehicles, and SIPLIN, JR.’s person were field tested, all of
which returned a positive result for the presence of cocaine. Based on my training and
experience, the large quantities of cocaine, packaging materials, and U.S. currency are all
14 ELWOOD DRIVE
118. On May 19, 2021 at approximately 6:39 p.m. members of the investigative team
executed a search warrant for 14 Elwood Drive, Rochester, New York. Over the course of
this long-term investigation, this location has been identified as Jason SIPLIN’S residence,
along with his wife N.F. However, there was no one inside of the house when officers
executed the warrant. After 14 Elwood Drive was secured a thorough search was conducted
and law enforcement recovered the following property of an evidentiary nature: a digital scale
with white residue along with small Ziploc style baggies were located in the kitchen; a small
amount of cocaine base was located in the basement; numerous documents in the name of
Jason SIPLIN evidencing his dominion and control over the residence were recovered, and a
total of $62,593.00 in U.S. currency was recovered. The bulk of the U.S. currency was
64
INTERVIEW OF JASON SIPLIN
119. After being taken into custody, SIPLIN was transported to RPD’s Public Safety
Building where he was placed in an interview room. The defendant was advised of his
Miranda rights, which he voluntarily waived. Thereafter the defendant was interviewed
regarding his involvement in the drug trafficking activities at the various locations described
in this affidavit. The defendant admitted that he is in fact a drug dealer and that he sells drugs
out of the Glenwood location (that is, 230 Glenwood Avenue). The defendant also confirmed
that he stores and prepares crack cocaine for street sale at the Clifton Street location. He
estimated that he sells approximately one kilogram of cocaine each week. He denied being
part of a narcotics conspiracy. He admitted that the U.S. currency recovered from the 14
120. After being taken into custody at 2013 Norton Street, SIPLIN, JR. was
transported to RPD’s Public Safety Building. Prior to being interviewed, Jason SIPLIN, JR.
was advised of his Miranda rights, which he voluntarily waived. The defendant was then
interviewed in connection with the drug trafficking activities described throughout this
affidavit. SIPLIN, JR. admitted that the cocaine recovered from his person, vehicle and house
currency recovered from his vehicle. He acknowledge being part of a group of individuals that
sold narcotics out of 230 Glenwood, and that the group utilized 62 Clifton Street as a storage
and preparation location. SIPLIN, JR. indicated that he had approximately four 62s of
cocaine in his residence that were ultimately supposed to have been sold out of 230 Glenwood
65
Avenue. When asked why the group stopped utilizing hotel rooms to prepare and package
cocaine base, SIPLIN, JR., stated that he did not know why they had stopped doing so.
SIPLIN, JR. advised law enforcement that he personally sells multiple 62s of crack cocaine
on a daily basis.
121. After Earnest GAMBLE was taken into custody at 230 Glenwood Avenue,
GAMBLE was transported to RPD’s Public Safety Building where he was placed in an
interview room. The defendant was advised of his Miranda rights, which he voluntarily
waived. The defendant was then interviewed in connection with the drug trafficking activities
described throughout this affidavit. The defendant admitted to being one of a number of
individuals that sold crack cocaine out of 230 Glenwood Avenue. GAMBLE did not wish to
identify these other individuals but did explain his business model and profit margin. He
indicated that he would purchase 62s of cocaine base from an individual who was in charge.
The price he paid for each 62 was essentially a retail price, but GAMBLE indicated that he
still profited approximately “two bands” (that is, $2,000.00 U.S. currency) per 62. GAMBLE
said that he sold approximately two 62s every day for the last six to seven months. GAMBLE
acknowledged that he believed he had sold roughly ten (10) kilograms of cocaine base over
CONCLUSION
122. Based on the foregoing information, your affiant submits that probable cause
exists to believe that on or about and between the month of August 2020, and May 19, 2021,
in the Western District of New York, Jason SIPLIN a/k/a J, Jason SIPLIN, JR. a/k/a Mush,
66
Ernest GAMBLE a/k/a Dred, Lytrice JACKSON a/k/a Storm, Timothy GRANISON, and
Dkeidron DUBLIN, committed violations of Title 21, United States Code, Sections 841(a)(l ),
841(b)(l)(A), 841(b)(l )(B), and 84 l (b)(l )(C) all in violation of Title 21, United States Code,
Section 846 (conspiracy to possess, with intent to distribute, and to distribute: at least 280
grams of cocaine base, a Schedule II controlled substance; and at least 500 grams of cocaine,
that on or about May 19, 2021, in the Western District of New York, Dkeidron DUBLIN
committed a violation of Title 18, United States Code, Section 924(c)(l)(A)(i) (possession
Special Agent
Homeland Security Investigations
67