Case 1:14-cr-10088-PBS Document 56-1 Filed 01/22/15 Page 1 of 22 AFFIDAVIT OF POSTAL INSPECTOR STEPiffiN P. DOWD I, Stephen P. Dowd, being duly swom, state the following: Personal Background 1. I have been employed as a Postal Inspector by the United States Postal Inspection Service for the past 18 years. 1 have been assigned to and have specialized in narcotics investigations for the past twelve years and have participated in munerous investigations involving the transportation of controlled substances or proceeds/payments through the United States Postal Service during that time. During this time, I have intercepted in excess of 500 Express Mail and/or Priority Mail packages which were found to have contained controlled substances or the proceeds of controlled substance sales. I have received training by the Drug Enforcement Administration in the investigation of controlled substances. I have received training by the U. S. Postal Inspection Service ("USPIS") in the investigation of controlled SlJbstances and proceeds/payments for controlled substances being transported through the United States mails. Purnose of Affidavit 2. This affidavit is made in support of an application for three search warrants: two for individual United States Postal Service Intemational Express Mail parcels as described below and one for a residence as described below: a. Subject Parcel #I, bearing tracking number EA148154278HK is addressed to "Ju1ie Carlozzi, 51 Maple St., Unit 3115, Rockland MA 02370 USA," and bearing a return address of"RM 25-26, BLK, B, 2/F, FOCAL IND, CTR, 21 MAN LOK ST, HUNG HOM, KOWLOON, I-IONGKONG." A detailed description of Subject Parcel #1 appears in Attachment A-1, which is attached hereto and incorporated herein by reference. b. Subject Parcel #2, bearing tracking number EA148154304HK is addressed to "Julie Carlozzi, 51 Maple St., Unit 3115, Rockland MA 02370 USA," and bears a return address of"RM 25-26, BLK, B, 2/F, FOCAL IND, 000032 Case 1:14-cr-10088-PBS Document 56-1 Filed 01/22/15 Page 2 of 22 CTR, 21 MAN LOK ST, HUNG HOM, KOWLOON, HONGKONG." A detailed description of Subject Parcel #2 appears in Attachment Ac2, which is attached hereto and incorporated herein by reference. c. 3. RESIDENCE OF HAROLD BATES, 32 E Water St., Apt. C, Rockland, Massachusetts, which is located in Plymouth County, Massachusetts. This location is an apartment in a multi-unit apartment building situated on the north side of East Water Street in Rockland, Massachusetts. The building is three stories tall with very light colored siding. There are 12 apartments within the building. The main entry door to the building is white in color with the number "32" clearly visible above the door. There are multiple parking spots directly in front and to the left of the building. The roof is comprised oflight colored shingles. Apartment C is located on the second floor. The white colored door to the apartroent is clearly labeled with the letter "C" which is located in the middle of the door at eye level above a peep hole. A detailed description appears in Attachment A-3, which is attached hereto and incorporated herein by reference. Collectively, Subject Parcel #1 and Subject Parcel #2 will be referred to as the "Subject Parcels." The Subject Parcels are currently in the possession of the United States Postal Inspection Service, 495 Summer Street, Suite 600, Boston, Massachusetts 02210. 4. The Subject Parcels are both the same size and shape: each parcel is approximately four inches long, four inches wide and four and one-half inches deep, and each weighs approximately one pound five ounces. The retmn address on the label of each of the Subject Parcels is typewritten, and the addressee information on each label is handwritten. A handwritten notation on each of the Subject Parcels lists the contents as "cosmetic samples." 5. As will be discussed below, I am involved in a criminal investigation involving the illegal distribution ofMethylone, a Schedule I controlled substance more commonly known as "Molly," by Harold Bates (hereafter "Bates"), Julie Carlozzi (hereafter "Carlozzi") and others. Bates is 31 years old and has numerous state felony convictions. In 2010, Bates was convicted of at111ed robbery in Norfolk Superior Com! for the robbery of a car wash. In 2009, Bates was convicted of possession with intent to distribute heroin in Quincy District Comt. In2007, Bates 2 000033 Case 1:14-cr-10088-PBS Document 56-1 Filed 01/22/15 Page 3 of 22 was convicted of possession of a Class B substance in Brighton District Court. In 2006, Bates was convicted of knowingly receiving stolen property in Westborough District Court. 6. As will be discussed below, evidence developed during the investigation provides probable cause to believe that Bates, Carolozzi, and others have been involved in the receipt of packages containing methylone, a Schedule 1 controlled substance, from China and then distributing the drugs in southeastern Massachusetts and elsewhere. Evidence developed during the course of this investigation as set forth in this Affidavit further provides me with probable cause to believe that the Subject Parcels each contain controlled substances and/or other evidence of dmg trafficking activities. Additionally, evidence developed during the investigation as set forth in this affidavit provides me with probable cause to believe that 32 E Water Street, Apartment C, Rockland, Massachusetts is Bates's residence, and that evidence of Bates's drug trafficking activities will be found at this address. (Hereafter, I will refer to 32 E Water Street, Apartment C, Rockland, Massachusetts as "the Bates Residence"). 7. For the reasons set forth in this affidavit, probable cause exists to believe that the Subject Parcels and the Bates Residence each contains evidence ofihe following offenses: (a) possession with intent to distribute and/or distribution of controlled substances, in violation of 21 U.S.C. § 841 (a)(l ); (b) use of a communications facility in the commission of narcotics trafficldng offenses, in violation of21 U.S.C. § 843(b); and (c) conspiracy to possess with intent to distribute and/or to distribute controlled substances, in violation of21 U.S.C. § 846. (Hereafter, these offenses are collectively referred to as "the Target Offenses.") More specifically, as will be discUBsed below, I submit that there is probable cause to believe that the Subject Parcels contain items listed in Attachment B-1, and that the Bates Residence contains items listed in Attachment B-2, that is, evidence of the commission of a criminal offense or 3 000034 Case 1:14-cr-10088-PBS Document 56-1 Filed 01/22/15 Page 4 of 22 which is contraband, the fruits of crime, or things otherwise criminally possessed, or which is designed or intended for use or which is or has been used as the means of committing an offense in violation of the Target Offenses. 8. I have personally participated in this investigation since November 12, 2013. The facts stated herein are based upon my personal involvement in this investigation, my training and experience, my review of documents, and infonnation provided to me by other law enforcement agents. This affidavit does not contain each and every fact that I know about tllis investigation. This affidavit only sets forth sufficient facts to demonstrate probable cause for the requested search warrants. The Current Investigation 9. On November 12, 2013, the U.S. Postallnspection Service in Boston learned of an incoming international E:\.''j)ress Mail parcel mailed from China bearing tracking number EE604360456CN that was addressed to "Harold Bates, 32 East Water Street, Apt C, Rockland, MA." (Hereafter, this package will be refened to as "Bates Parcel #1.") Bates Parcel #1 weighed approximately one pound four ounces and bore a return address of"Shanghni Keeps Trading Co., Ltd., No 504123 Lane Kangqiao Road Pudong, New Shanghai 200124 China." 10. Postal Inspectors discovered a connection between Bates Parcel #1 and another Express Mail parcel from Hong Kong that was delivered to an individual in Hollywood, Florida, on October 17, 2013. (Hereafter, this second parcel will be referred to as the "Florida Parcel"). Thereafter, law enforcement officers obtained consent to search the Florida parcel, and the package was found to contain approximately 500 grams of white crystal-like substance that fieldtested positive for methylone. 4 000035 Case 1:14-cr-10088-PBS Document 56-1 Filed 01/22/15 Page 5 of 22 II. Postal Inspectors established a connection between the Florida Parcel and Bates Parcel #1 through data maintained by the Track 'n Confirm website operated by the United States Post Oftice ("USPS"). The Track 'n Coniirm website was created by the USPS to allow individuals to monitor via the intemet the progress of packages sent via Express Mail. This is done by accessing the USPS's Track 'n Confirm website and entering a package's unique tracking number. When the website is accesse