Case Document 1 Filed 07/14/10 Page 1 of 14 A0 9] (Rev. 08/09) Criminal Complaint U.S. DISIRICT COURT ND. 0F N.Y. I- I: UNITED STATES DISTRICT COUR for the JUL 1 4 2010 Northern District of New York AT United States of America Lawrence K. Baerman. Clerk - Syraruso v. . Case No. "7 3% (GHL) i ,7 Sondra :Sgia?i Prince 7 7 WW Defendamm 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 the date(s) of May 2998 to June 20l0 in the county of in the Northern District of Nexy_?ork the defendant(s) violated: Code Section . Oj?nse Description Conspiracy to Possess with the Intent to Distribute and Distribute 50 grams or Title 21, United States Code, more of Cocaine Base Sections 841 and 846 This criminal complaint is based on these facts: Continued on the attached sheet. 6 I omptainant 's signature Shelly Matthes, Senior Patroergent, USBP Printed name and title Sworn to before me and signed in my presence. Date: 7 if" Jul 14,20197iw Zw?f/ Judge '3 signature City and state: Syracuse, New York 7 77 George Lowe, U.S. Magistrate Judge Printed name and title Case Document 1 Filed 07/14/10 Page 2 of 14 AFFIDAVIT OF SHELLY MATTHES I, Shelly C. Matthes, being duly sworn, hereby state: 1. I am a Senior Patrol Agent of the Department of Homeland Security, United States Border Patrol (USBP) and I have been so employed since August of 2000. I have been assigned to my current position with the Ogdensburg Border Patrol Station since 2007 and detailed to the Saint Lawrence County Drug Task Force since July of 2009. My previous assignment with the USBP consisted of 6.5 years at the Carrizo Springs Border Patrol Station in. Carrizo Springs, Texas. I have received extensive training in Immigration Law and Nationality Law. I also have experience making drug arrests in the field with the Border Patrol and I am cross designated and given the authority to enforce laws under Title 19 and Title 21. I am a US. Border Patrol trained and certified canine handler. My canine partner is certified to detect the odors of concealed humans as well as the following illegal drugs: marijuana, cocaine, methamphetamine and heroin. I have made hundreds of arrests and have experience in debriefing of defendants, informants, and witnesses who have personal knowledge of various types of law violations, including drug offenses. 2. This affidavit is offered in support of a criminal complaint based upon probable cause that Sondra ?Sosa? ARQUIETT PRINCE has violated Title 21, United States Code, Section 846, Case Document 1 Filed 07/14/10 Page 3 of 14 Conspiracy to Possess with Intent to Distribute and Distribute 50 grams or more of cocaine base. 3. Because this affidavit is provided for the limited purpose of showing probable cause for the arrest of the person listed above, I have not included each and every fact known to me regarding this investigation. I have only included information sufficient to establish probable cause for the arrest. 4. The information contained in this affidavit has been made known to me through my personal investigation in this matter or has been relayed to me by other agents/officers of the Drug Enforcement Administration, US Border Patrol and the St. Lawrence County Sheriff?s Department Drug Task Force. PROBABLE CAUSE 5. Based upon information learned by law enforcement officers during the course of an approximately year long investigation, it is believed that Jermaine BRANFORD is the head of the Jermaine BRANFORD Drug Trafficking cuganization (DTO) based le New Yerk City. The BRANFORD DTO consists of over 30 members and distributes illegal drugs such as cocaine, cocaine base, and MDMA in Watertown, New York and Ogdensburg, New York. To date, thirteen (13) federal and three (3) state arrests have been made involving members of this organization. BRANFORD, along with seven (7) others, was indicted by the grand jury for the Northern District of New York for conspiracy to distribute and distribution of 50 Case Document 1 Filed 07/14/10 Page 4 of 14 grams or more of cocaine base. BRANFORD was arrested pursuant to an arrest warrant in connection with his indictment on 4-20?2010. 6. I know from my investigation into the BRANFORD DTO that Travis BATTICE is aa trusted member of the cuganization and has also been charged le the aforementioned indictment. BATTICE is currently in federal custody after having been arrested in connection with the indictment on 4-20-2010. 7. Based upon my investigation, I believe that Sondra ?Sosa? Arguiett PRINCE is girlfriend and is known to the leadership of the organization as ?the secretary.? 8. Det. Ronald Gatch of the Watertown, NY Police Department has met both PRINCE and BRANFORD and has seen PRINCE together with BRANFORD :hi the Watertown, NY area. Det. Gatch reported that PRINCE is girlfriend and she was involved in ?three incidents that involve members of the BRANFORD DTO: a. On 5?11?2008, the Watertown PD stopped BRANFORD and cited him for driving without a valid license. PRINCE arrived at the scene to pick up BRANFORD and she was also detained and cited for driving without a license. b. On 6?8-2009, the Watertown PD responded to apartment in the City of Watertown and arrested Jermaine in front of the building for menacing. PRINCE gave permission for her apartment to be searched by police. Case Document 1 Filed 07/14/10 Page 5 of 14 c. On, 8-24?2008, the Watertown PD responded 133 a domestic incident between Travis BATTICE and Everda BARON (also charged in the BRANFORD, et a1 indictment). The Watertown PD also encountered PRINCE at the scene. 9. On 10-31?2009, Watertown Police and t?ua DEA executed a search warrant at a residence in Watertown, NY and arrested BATTICE and BARON at this location. During the execution of the search warrant, agents seized 51.1 net grams cm? crack cocaine, over 900 dosage units of MDMA and a cellular telephone believed to belong' to BRANFORD. A federal search warrant was subsequently obtained to examine this phone; pursuant to that warrant, I examined the phone and observed two video clips that show BRANFORD and PRINCE together in bed. 10. On 3?18?2010, a cooperating source of information (hereafter referred to as told police that he/she worked as a ?runner? for the BRANFORD DTO. made the following statements: a. BRANFORD goes by the nicknames of ?Hovie,? ?Bricks,? or ?Jack.? BRANFORD is the boss with the following individuals working under him: Enal LAROSE, Travis ?Trav? BATTICE and Tyrone ?T-Bone? FELDER. b. first met BRANFORD in 2003. first began selling drugs for BRANFORD in March 2008. started Case Document 1 Filed 07/14/10 Page 6 of 14 out by selling ounces of marijuana for BRANFORD but later worked selling crack cocaine for BRANFORD. c. On multiple occasions, Spoke directly to BRANFORD and received instructions from BRANFORD on what to sell, the price to fix, and how much he would be paid. was also frequently present when BRANFORD would direct the drug sales activities of Enal LAROSE, Travis BATTICE and Tyrone FELDER. d. In June 2009 a girl by the name of ?Melissa? stole a quantity of MDMA, crack cocaine, powder cocaine, and a TV set from BRANFORD which BRANFORD had kept at an apartment that was rented by a girl called Sondra ?Sosa? PRINCE. BRANFORD personally gave $6,000 in cash as payment for trying to ?lure out? Melissa. attempted to bring Melissa to BRANFORD by bringing Melissa to a parking lot where BRANFORD was waiting but Melissa fled the parking lot in a vehicle. A short car chase followed and Melissa escaped. These events led to arrest by the Watertown Police shortly thereafter. 11. On multiple occasions from late 2009 to mid-2010, a cooperating source of information, (hereafter referred to as told police the following information about the BRANFORD DTO and PRINCE's relationship to Jermaine BRANFORD: Case Document 1 Filed 07/14/10 Page 7 of 14 a. worked as a runner for the BRANFORD DTO. His/her job was to take drugs (cocaine, crack, MDMA, and Molly) to customers on the street. b. identified Caleb LNU (last name unknown), Pat Gillman, and ?Grills? as BRANFORD DTO cocaine customers to whom has personally delivered drugs to and from whom he/she has picked up drug proceeds. c. knows from his/her personal experience that PRINCE is girlfriend. d. was physically present on numerous occasions while Travis BATTICE was 5J1 PRINCE's apartment j11 the summer of 2009 cooking crack cocaine. was waiting for the cooking process to be completed so he/she could take the crack cocaine and distribute it to the BRANFORD DTO customers. e. PRINCE was present on multiple occasions while crack cocaine was manufactured in her apartment. During the summer of 2009, PRINCE helped process 2-3 ounces (56?84 grams) of crack cocaine and PRINCE personally handed baggies of finished crack cocaine that were ready for sale. 12. Following Travis arrest on 10-31-2009 (following the execution of the search warrant described in paragraph 9), BATTICE was held in federal custody from November 1, 2009, until December 21, 2009. During his incarceration, BATTICE made dozens of recorded jailhouse telephone calls to PRINCE. Case 5:117cr700033rGTS Document 1 Fned 07/14/10 Page 8 of 14 PRINCE talked with BATTICE for hours on the phone and during many of these calls, PRINCE would 3-way connect BATTICE to other members of the conspiracy including Jermaine BRANFORD and Enal LAROSE (also charged in the ERANFORD, el: al indictment). The following phone call extracts were made from monitored jailhouse Calls between BATTICE and PRINCE while BATTICE was incarcerated at the Onondaga County Jail in Jamesville, NY: a. 11--7--2009, 2023 hrs: PRINCE told BATTICE that she does not need them (Tyrone "T--Bone" FELDER) to cut certain things to make sure she makes the quotes 11-8-2009, 1054 hrs: brought -- into a 3--way discussion with BATTICE. BATTICE stated to -: "lheveryone should be scared because I'm off the scene. I move flawless. 'Shine' is gonna touch everybody else." BATTICE told - that he will "msend everything to Sondra (PRINCE) and title it to BATTICE told -that she could move like "Sondra moved for Hovie . c. 11--8--2009, 1357 hrs: BATTICE called PRINCE and PRINCE 3- way called Enal LAROSE. BATTICE told LAROSE to get the people that he needs from CARVELLE. BATTICE told LAROSE to keep "Sunshine" mobilel BATTICE told LAROSE: "If you don't gotta do something, don't do its Send other people to do itl" Case 5 Document 1 Fned 07/14/10 Page 9 of 14 11-3-2009, 1653 hrs: BATTICE called PRINCE and she initiated a 3-way call with Jermaine EATTICE told BRANFORD that he had bad news for BRANFORD and to think about everything that BRANFORD left on phone' (Agent's note: This call referred to the phone that was seized from apartment when he was arrested on 10-31-2009 in Wacertown, NY and referred to in paragraph 9, above. Agents discovered phone a: the apartment which had incriminating video evidence on it showing BRANFORD with $50,000 cash and cavotting with Sondra PRINCE.) 11-8-2009, 1717 hrs: called PRINCE and she initiated a 3-way call with Jermaine BRANFORD. BATTICE referred to PRINCE as that they should make -- a secretary. tal ked "the secretary." stated BRANFORD co BATTICE about PRINCE and Meme (Seamethea LEAKE) making money. 11-9-2009, 1934 hrs: BATTICE. called PRINCE and they talked about _"moving stuff." PRINCE stated that. she gave list to BRANFORD. BATTICE stated: "When I get out, you, me and Rev (BRANFORD) are going to do it, The plan I got is very big." BATTICE stated that he was going to write PRINCE about the plan and he wanted her to look into it. BATTICE told PRINCE to tell LAROSE: Case Document 1 Filed 07/14/10 Page 10 of 14 ?Pat, Grills, Steve, Calebm tell him ice cream ASAPW even 50. That?s how everything going to get paid.? BATTICE told PRINCE to tell LAROSE to ?get them on the phone and wise up.? PRINCE stated that she told. Tony that she wanted. to ?play' basketball.? Further stating, ?My' aunt wants two baskets.? BATTICE told PRINCE to tell LAROSE that ?City is a gem NOTE: It is believed that the references to basketball are code for drug transactions. Additionally, a cooperating source of information told agents that he personally delivered cocaine to Pat Gillman, ?Grills,? and ?Caleb? for BATTICE.) 11-9-2009, 1805 hrs: BATTICE called PRINCE and she 3?way called Seamethea ?Meme? or ?Sandy? LEAKE. BATTICE told LEAKE how LAROSE isn't doing his part. LEAKE stated 'that it (the situation) must be hart! on Sondra PRINCE because it?s all on her shoulders. 11?9-2009, 1841 hrs: BATTICE called PRINCE. PRINCE told BATTICE that she hates being the middle man with him (referring to LAROSE). PRINCE told BATTICE that T-Bone (FELDER) wouldn't answer his phone so she had to go to his ?crib? (house). PRINCE told BATTICE that she wants EZ (LAROSE) to send the money tonight so that she can pick it up first thing in the morning before she goes to see Hovie Case Document 1 Filed 07/14/10 Page 11 of 14 (BRANFORD) so she can bring it to him. PRINCE told BATTICE that T-bone (FELDER) asked her about ?Molly.? BATTICE told PRINCE that the ?docs? (arrest report) doesn?t say anything about ?Molly.? PRINCE told BATTICE that was a nice little setup she did to us (still referring to ?Molly.?) (agent?s note: is the street name for a new type of MDMA capsule of the same type that were seized from apartment on 10?31? 2009.) 11-10-09, 1151 hrs: PRINCE told BATTICE that T-Bone (FELDER) called her and said that ?Tam? got locked up by the same people he did and that they are trying to put Hovie (BRANFORD) in the middle of everything. PRINCE told BATTICE that she got ?John? and ?City?s? numbers. 11?10-2009, 1404 hrs. BATTICE called PRINCE who 3-way called LAROSE. told LAROSE, got a lot of shit across what?s his name. I gave him the go with my homeboy Mark. He don?t play the phone shit.? LAROSE told BATTICE that that is what Sosa (PRINCE) is there for. BATTICE told PRINCE to make sure that she is able to listen in. 11-10-2009, 1721 hrs: BATTICE called PRINCE. PRINCE 3? way called ?City;? BATTICE told ?City? that anytime Sondra (PRINCE) calls it?s just like him calling. 10 Case Document 1 Filed 07/14/10 Page 12 of 14 11?11?2009, 1931 hrs: BATTICE called PRINCE. PRINCE told BATTICE that she was mad at LAROSE. PRINCE said that she told LAROSE that she has never told them 1K) when they asked her to do anything. PRINCE told BATTICE: ?Why can't do it? She lives for free. You are all doin? the same thing for her that you are doin for me. Why can?t you ask her for anything?? BATTICE told PRINCE ?That is T?Bone?s (FELDER's) girl, that?s through. him.? PRINCE told BATTICE: ?But I?m Hovie?s (BRANFORD), not his.? BATTICE told PRINCE ?You're on the team, you feel me?? PRINCE told BATTICE that she received a text message from Meme (LEAKE) telling her to tell ?Trav? (BATTICE) that she loves him but she can't write him because it would interfere with both of their cases. 11-11?2009, 2229 hrs: BATTICE called PRINCE. PRINCE told BATTICE that she talked to Meme (LEAKE) and asked her what she meant by ?her case.? PRINCE said LEAKE told her that she had told them (Feds) that she didn?t know Trav (BATTICE) so she was just gonna leave it at that. PRINCE told BATTICE that EZ (LAROSE) didn?t send her the money. BATTICE told PRINCE to make sure she ?presses Jack? (LAROSE). 11?12-2009, 1833 hrs: BATTICI: called PRINCE. BATTICE told PRINCE tn) tell Hovie (BRANFORD) that ?Wma is gonna ll Case Document 1 Filed 07/14/10 Page 13 of 14 have to take care of Adrian himself because Jack (LAROSE) don?t have what it takes.? PRINCE told BATTICE, ?He was sayin' to only buy ice cream.? BATTICE: ?Oh, Sunshine?? PRINCE: ?No, I?m talking about basketball.? BATTICE: ?Watch what you say.? PRINCE told BATTICE, ?You know how I made dinner and he was gonna come visit me? He brought dessert and he brought like ice cream and shit. You know what I'm sayin? And I was mad because I didn?t want ice cream.? BATTICE: ?Oh, you wanted other?? PRINCE: ?Yeah and (UNINTELLIBLE) is upset ?cuz he wanted something else too. He asked Jack (LAROSE), what the fuck?? BATTICE: ?Like it?s better to have that with the cake than chocolate chip cookies.? [Agent?s note: It is believed that this is coded language for drug transactions.] 11-12-09, 2131 hrs: BATTICE called PRINCE. PRINCE told BATTICE that she ?would send the letter' he wrote Hovie (BRANFORD). BATTICE asked PRINCE if everything was functional. BATTICE told PRINCE that he would be sending her a letter that would help her ?move smooth.? 11?13?09, 2102 hrs: BATTICE called PRINCE. Leigh HOLLENBECK half?sister) and BATTICE spoke on the phone. BATTICE told HOLLENBECK to tell PRINCE, not to go out ?cuz if she go out and they snatch her up who is gonna hold me and Hovie (BRANFORD) down? Sosa (PRINCE) is 12 Case Document 1 Filed 07/14/10 Page 14 of 14 real fucking important and we can't lose her. She holds it down.? q. 11?14?09, 1918 hrs: BATTICE called PRINCE. PRINCE told BATTICE that she asked ?City? for some money and he said that he is the boss and he is not giving PRINCE any money. r. 11-14-09, 2055 hrs: PRINCE tried to connect BATTICE, BRANFORD and ?City? using a conference call. 5. 11?22-09, 2225 hrs: BATTICE called PRINCE. PRINCE told BATTICE that she doesn't know' how Inany apartments for Hovie (BRANFORD) she has in her name. 13. Based upon the information provided herein, I believe that probable cause exists to believe that Sondra ?Sosa? ARQUIETT PRINCE has violated Title 21, United States Code, Section 846, Conspiracy to Possess with Intent to Distribute and Distribution of 50 grams or more of cocaine base. Senior,P trol Agent, USBP Subscribed and sworn to before me on this day of July 2010. GEORGE H. LOWE UNITED STATES MAGISTRATE JUDGE 13