Case Document 1 Filed 03/24/16 Page 1 of 28 UNITED STATES COURT E: A0 91 (Rev. llil 1) Criminal Complaint . . for the . Eastern District of California United States ofAmerica I CLERK I I I v. 3 Case No m, 3T David RYan BURCHARD Defeirdanr(s) . .1 1 a are: BAH 9:3 CRIMINAL COMPLAINT l, 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 March 2013 - March 2016 in the county of Fresno and elsewhere in the Eastern District of California the defendant(s) violated: Code Section foerise Description 21 U.S.C. 841(a)(1) Distribution of Marijuana and Cocaine. Controlled Substances 21 U.S.C. 846 and 841 Conspiracy to Distribute Marijuana and Cocaine, Controlled Substances This criminal complaint is based on these facts: Set forth in attached Complaint and Af?davit of Matthew Larsen attached hereto and fully incorporated herein, RI Continued on the attached sheet. I . Compiaiirairt 's signature Matthew Larsen, Special Agent, HSI Primed name and ri?e Sworn to before me and si nedin my presence. Judge ?5 City and State; Fresno, California Hon. Barbara A. McAuliffe, U.S. Magistrate Judge Primed nan-re and titie Date: LUJN Case Document 1 Filed 03/24/16 Page 2 of 28 BENJAMIN B. WAGNER United States Attorney GRANT B. RABENN Assistant United States Attorneys 2500 Tulare Street, Suite 4401 Fresno, CA 93721 Telephone: (559) 497-4000 Facsimile: (559) 497-4099 Attorneys for Plaintiff United States of America IN THE UNITED STATES DISTRICT COURT EASTERN OF STATES OF AMERICA, CASE NO. Plaintiff, AFFIDAVIT OF MATTHEW LARSEN v. Violations: I RYAN BURCHARD, 21 U.S.C. 841(a)(1) (Distribution of Marijuana and Cocaine, Controlled Substances); 21 U.S.C. 846 and 841(a)(1) Defendants. (Conspiracy to Distribute Marijuana and Cocaine, Controlled Substances). I, Mathew Larsen, being duly sworn, hereby depose and state as follows: I. INTRODUCTION AND AGENT BACKGROUND 1. I am a Special Agent with Homeland Security Investigations (HSI) and have been so employed since November 2008. My duties include the investigation of criminal violations involving narcotics traf?cking and money laundering. Moreover, as an HSI Special Agent, 1 am generally authorized to investigate violations of the laws of the United States and to execute search and seizure warrants issued under the authority of the United States. 2. I As a requirement for employment as an HSI Special Agent, I successfully completed the Criminal Investigator Training Program (CITP) located at the Federal Law Enforcement Training Center (FLETC) in Georgia. At the conclusion of CITP, I completed an additional lmmigration and AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT C'ase Document 1 Filed 03/24/16 Page 3 of 28 Customs Enforcement Special Agent Training Academy. As part of the training at FLETC, I received extensive instruction in the areas of immigration. law, customs law, illegal narcotics, ?rearms, rules of evidence, and interview techniques. 3. I am familiar with the formal methods of illegal narcotics and money laundering investigations, including electronic surveillance, visual surveillance, general questioning of witnesses, search warrants, con?dential informants, the use of undercover agents, and analysis of financial records. I have participated in investigations of organizations involved in the manufacture, distribution, and possession with intent to distribute controlled substances. I am also familiar with the use of digital currency to launder money and have participated in trainings on this subject. 4. The information in this Affidavit is based on my personal knowledge, information provided to me by others, including other law enforcement of?cials and civilian witnesses, as well as my review of documents associated with the case. I am fully aware of the facts and circumstances concerning this investigation and have participated in significant aspects of this investigation. 5. The information contained in this Af?davit is submitted for the sole purpose of demonstrating probable cause to obtain a criminal complaint charging David Ryan BURCHARD with violations of Title 21; United States Code, Sections and 846 (Distribution and Possession with Intent to Distribute Marijuana and Cocaine, and Conspiracy). Because this Af?davit is being'submitted . for the limited purpose of demonstrating probable cause, it does not contain all of the information known to me and/or other law enforcement of?cers involved in this case. 11. BACKGROUND ON DIGITAL CURRENCY- 6. 'Digital currency (also known as is generally defined as an electronic- sourced unit of value that can be used as a substitute for ?at currency currency created and regulated by a government). Digital currency exists entirely on the Internet and is not stored in any physical form. Digital currency is not issued by any government, bank, or company and is instead AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 2 Case Document 1 Filed 03/24/16 Page 4 of 28 generated and controlled through computer software operating on a decentralized peer-to-peer network. Digital currency is not illegal in the United States and may be used for legitimate ?nancial transactions. However, digital currency is often used for conducting illegal transactions, such as the sale of controlled substances. 7. Bitcoin is a type of digital currency. Bitcoin payments are recorded in a public ledger that is maintained by peer-to-peer veri?cation, and is thus not maintained by a single administrator or entity. Individuals can acquire bitcoins either by ?mining? or by purchasing bitcoins from other individuals. An individual can ?mine? for bitcoins by allowing his/her computing power to verify and record the Bitcoin payments into a public ledger. Individuals are rewarded for this by being given newly created bitcoins. I 8. An individual can send and receive bitcoins through peer-to-peer digital transactions or by using a third-party broker. Such transactions can be done on any type of computer, including laptop computers and smart phones. 9. Bitcoins are stored on digital ?wallets.? A digital wallet essentially stores the access code that allows an individual to conduct bitcoin transactions on the public ledger. To access bitcoins on the public ledger, an individual must use a public address (or ?public key?) and a private address (or ?private key?). The public addressican be analogized to an account number while the private key is like the password to access that account. 10. Even though the public addresses of those engaging in bitcoin transactions are recorded on the public ledger, the true identities of the individuals or entities behind the public addresses are not recorded. If, however, a real individual or entity is linked to a public address, it would be possible to determine what transactions were conducted by that individual or entity. Bitcoin transactions are, therefore, described as ?pseudonymous,? meaning they are partially anonymous. 11. Dark websites, such as Silk Road, operated on ?The Onion .Router? or network. AFFIDAVIT IN SUPPORT OF CRIMINAL COMPIAINT Case Document 1 Filed 03/24/16 Page 5 of 28 The TOR network is a special network of computers on the Internet, distributed around the world, that is designed to conceal the true Internet Protocol addresses of the computers accessing the network, and, thereby, the locations and identities of the network?s users. TOR likewise enables websites to operate on the network in a way that conceals the true IP addresses of the computer servers hosting the websites, which are referred to as ?hidden services? on the TOR network. Such ?hidden services? operating on TOR have complex web addresses, generated by a computer algorithm, ending in ?.onion? and can only be accessed through speci?c web browser software designed to access the TOR network. 12. Through the dark-web or dark-net, i.e. websites accessible only through means, individuals have established online marketplaces, such as the Silk Road, for narcotics and other illegal items.1 These markets often only accept payment through digital currencies, such as bitcoin. Accordingly, a large amount of bitcoin sales or purchases by an individual is often an indicator that the individual is involved in narcotics traf?cking or the distribution of other illegal items. Individuals intending to purchase illegal items on Silk Road-like websites need to purchase or barter for bitcoins. Further, individuals who have received bitcoin as proceeds of illegal sales on Silk Road-like websites need to sell their bitcoin to convert them to ?at (government-backed) currency. Such purchases and sales are often facilitated by peer-to-peer bitcoin exchangers ?who advertise their services on websites designed to facilitate such transactions. The Silk Road was a dark website operated as a TOR hidden service. The Silk Road allowed its users to browse anonymously to purchase a variety of illegal goods, including controlled substances. Bitcoin was the form of payment accepted by the site. A further description of Silk Road is included below. - AFFIDAVIT IN SUPPORT CRIMINAL COMPLAINT Case Document 1 Filed 03/24/16 Page 6 of 28 FACTS ESTABLISHING PROBABLE CAUSE A. Homeland Security Identifies David BURCHARD as a Marijuana Distributor 13. I am part of a digital currency task force focused on identifying the use of digital currency to launder the proceeds of criminal activity. As part of this task force, I have been involved in several investigations into unlicensed digital currency exchangers and narcotics distributors on the dark- web who use digital currency to receive payment for the sale of narcotics. These investigations have brought my attention to numerous individuals who have been cycling through large amounts of Bitcoin. One of those individuals is David Ryan BURCHARD. I 14. . Speci?cally, in or around March, 2015, I began investigating BURCHARD based, in part, on his sale of millions of dollars of Bitcoins to an unlicensed digital currency exchanger. I was, and continue to be, unable to identify a legitimate source of large amount of Bitcoins. Using surveillance and public records, I learned that primary residence was located at Gabriel Drive, Merced, California 95340 (the GABRIEL RESIDENCE). I also discovered that BURCHARD drove a white Chevrolet Tahoe bearing California license plate 6BOK924 (the CHEVY TAHOE). 15. On March 12, 2015, at approximately 9:00 am, HSI Special Agent?s initiated surveillance at the GABRIEL RESIDENCE and noted the presence of the CHEVY TAHOE parked near the residence in close proximity to the intersection of Via Moraga and Gabriel Drive. 16. On March 12, 2015, at approximately 11:26 am, I telephonically swore out a search warrant with US Magistrate Judge Barbara A. McAuliffe to install a Global Positioning System (GPS) tracker onto the CHEVY TAHOE and subsequently installed the tracker at approximately 12:00 pm. At approximately 12:15 pm, departed the area. 17. On March 18, 2015, other case agents and I conducted surveillance on BURCHARD. I observed BURCHARD in the CHEVY TAHOE near an address at Duke Ct, Merced, California 95340 (the DUKE CT ADDRESS). Public records associate BURCHARD with this residence as recently as July 2014. GPS records from a tracking device installed on the CHEVY TAHOE also showed BURCHARD at the GABRIEL RESIDENCE. At approximately 3:23 pm, the CHEVY AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT Case Document 1 Filed 03/24/16 Page 7 of 28 TAHOE drove from Merced, California to the United States Post Of?ce (USPO) located at 755 East Nees Ave, Clovis, California 93720, arriving at approximately 4:42 pm. 18. Subsequently, United States Postal Inspector Jessica Burger obtained surveillance video, which shows a white male resembling BURCHARD with three medium sized parcels in his arms inside the USPO at approximately 4:48 pm. According to GPS data, at approximately 5505 pm, the CHEVY TAHOE arrived at the USPO located at 655 Minnewawa Ave, Clovis, California 93612. Then, according to GPS data, at approximately 6:24 pm, the CHEVY TAHOE returned to the area of IMerced, California. I 19. On March 20, 2015, I provided the Inspector Burger with a booking photo of BURCHARD obtained from a recent Driving While Intoxicated arrest on March 9, 2015. Based on this photo, Inspector Burger recognized BURCHARD from prior video footage of him mailing three packages from the USPO located at 655 Minnewawa Ave, Clovis, California 93612, on March 18, 2015. 20. In addition, Inspector Burger recognized BURCHARD from a previous investigation she was involved in. Specifically, in June 2014, the Postal Service could not deliver a parcel mailed to ?Car Audio Refurbishment, Fernando Garcia, Pharr, TX 78577? because the address was vacant; the parcel was then sent back to the return address at 14681 Huntington Road, Madera, California 93636. Postal Inspectors searched the package and found marijuana inside it. Inspector Burger determined that the parcel was mailed from the USPO located at 755 E. Nees Ave, Fresno, California 93 720, and retrieved video from that USPO that shows an individual resembling BURCHARD mailing the parcel. 21. Inspector Burger had investigated the previously unidenti?ed sender (now identi?ed as BURCHARD) and noted the payment card used to mail the package in June 2014 was also used to send approximately 55 packages from Automated Processing Centers at USPOs located in or around Fresno and Modesto, California. 22. On March 20, 2015, as described below, BURCHARD mailed a parcel containing marijuana from a USPO located in Clovis, California. . I On March 20, 2015, at approximately 11:32 pm, GPS data indicated that the CHEVY TAHOE had arrived at the USPO located at 655 Minnewawa Ave, Clovis, California 93612. At approximately 1 1:44 pm, the CHEVY TAHOE arrived at the USPO located at AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 6 Case Document 1 Filed 03/24/16 Page 8 of 28 23. 755 East Nees Ave, Clovis, California 93720. The CHEVY TAHOE then departed the area. The following day, on March 21, 2015, Inspector Burger informed me that she reviewed video and observed BURCHARD mail a parcel on March 20, 2015 at the USPO located at 655 Minnewawa Ave, Clovis, California 93612. Inspector Burger seized parcel, which was addressed to ?James Good, 3556 Briarthorne Drive, Charlotte, North Carolina 28269.? On March 27, 2015, Inspector Burger obtained a federal search warrant to search this parcel. On March 31, 2015, Postal Inspector Jessica Burger arrived at the HSI Fresno of?ce with the parcel that was mailed by BURCHARD on March 20, 2015 from the USPO located at 655 Minnewawa Ave, Clovis, Califomia 93612. The return address for the parcel was ?Central California Auto Refuer 4949 N. Wishon'Ct., Fresno, California 93704.? I conducted a public records check on this business with negative results. In addition, the address appeared to be a residence that was listed for sale. At approximately 9:30 am, InSpector Burger and I executed the warrant on the parcel and discovered six vacuum sealed packages that contained a green leafy substance. I conducted a ?eld test on the substance which tested positive for marijuana. The combined weight of the six packages was approximately 48.5 ounces. Subsequently, I sent the marijuana and the packaging to the Drug Enforcement Administration laboratory located in Pleasanton, California for further analysis, which is pending. I On March 25, 2015, as described below, BURCHARD mailed a parcel containing marijuana from a USPO located in Clovis, California. On March 25, 2015, GPS data indicated that the CHEVY TAHOE was moving south from Merced, California, and heading towards Clovis, California. Subsequently, HSI Fresno case agents established surveillance positions near USPO locations in Clovis, Califomia. At approximately 2:25 pm, the case agents observed the CHEVY TAHOE arrive at the USPO located at 755 East Nees Ave, Clovis, California 93720. Case agents obtained AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 7 Case Document 1 Filed 03/24/16 Page 9 of 28 photos of BURCHARD exiting the CHEVY TAHOE and carrying two packages, one white and one brown, into the USPO. One of the case agents went into the USPO and observed BURCHARD place the packages into a mail bin._ The case agent then prevented other customers from placing packages into the bin until packages were retrieved. Inspector Burger arrived and took control of the two packages BURCHARD mailed. The case agent who observed BURCHARD place the packages into the mail bin recognized the packages retrieved by Inspector Burger and me. The case agents observed no other packages in the mail bin with the same physical characteristics of the BURCHARD packages. In addition, both packages were addressed to the same person and address, which was ?Jordan Hall, 4427 Brandie Glen Rd, Charlotte, North Carolina 28269,? with a return address of ?Central California Auto Refurb, 4949 N. Wishon Ct, Fresno, California 93704.? Inspector Burger subsequently forwarded the two parcels to Postal Inspectors based in Charlotte, North Carolina. Upon review of the GPS data, I discovered that on March 25, 2015, at approximately 2: 12 am, the CHEVY TAHOE was located at -the DUKE CT ADDRESS, before it arrived at the GABRIEL RESIDENCE, at approximately-3:34 am. At approximately 1:24 pm, GPS data indicated the CHEVY TAHOE departed the GABRIEL RESIDENCE and drove directly to the USPO located at 755 East Nees Ave, Clovis, California 93720, arriving at approximately 2:25 pm. At this point HSI case agents observed BURCHARD mail the parcels as detailed above. I On May 1, 2015, I received reports and images from a Charlotte, North Carolina-based Postal Inspector pertaining to the two parcels BURCHARD mailed from Clovis, California on March 25, 2015. The reports indicate that on March 30, 2015, Postal Inspectors attempted to verify on law enforcement databases information associated with the parcels mailed by BURCHARD on March 25, 2015 but could not identify any known persons associated with the listed sender and addressee. On March 30, 2015, Drug K-9 Handler Of?cer V.W. Woodlief, from the Charlotte Mecklenburg Police Department, AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 8 Case Document 1 Filed 03/24/16 Page 10 of 28 conducted a narcotics detection examination with his K-9 ?Indy? on the parcels. Both parcels were placed separately into a lineup along with four similar control parcels. Inspector Crooks observed as Indy walked among the parcels and noted that Indy alerted to the suspect packages by snif?ng the seams and responding passively by sitting next to the parcels, which is his signal to indicate the scent of a controlled substance. 0 On April 3, 2015, the Postal Inspector obtained federal search warrants for the two parcels and found that one of the parcels contained seven vacuum sealed packages containing approximately 4.16 pounds of marijuana. The other parcel contained two vacuum sealed bags that contained approximately 1.18 pounds of marijuana. On May 1, 2015, I reviewed pictures of the contents of parcels and noted that the marijuana was sealed with a gray outer packaging and a clear vacuum sealed inner packaging. This packaging appeared similar in color and consistency to the packaging used in the parcel BURCHARD mailed from Clovis, California, on March 20, 2015, and examined by HSI case agents. On May 5, 2015, I spoke with the Postal Inspector, who con?rmed that he obtained positive ?eld tests for the parcels and that he subsequently had the marijuana destroyed on April 17, 2015. B. David URCHARD Sells Marijuana and Cocaine 0n the Silk Road 24. On June 3, 2015, I learned that publicly available information indicated David BURCHARD, Duke Ct, Merced, California 95340, had registered or attempted to register and trademark the phrase ?caliconnect.? After obtaining this information, HSI Fresno investigators began to I search Reddit and other publicly available websites for the username ?caliconnect? and discovered comments and reviews from individuals claiming to have ordered marijuana from a dark-web vendor going by the online username?ca1iconnect.? ?Caliconnect? appeared to operate on ?dark-web? websites that specialize in selling contraband, utilizing and Internet Protocol ?anonymizers? to protect buyer and seller identities, as described below. 25. On the same day, June 3, 2015, 1 reviewed a document entitled ?Silk Road NTC Vendor List,? which was provided to me in March 2015 by Headquarters. As background, Silk Road was a dark-web market, best known as a platform for selling illegal drugs and other illegal items. The illegal AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 9 Case Document 1 Filed 03/24/16 Page 11 of '28 nature of the commerce hosted on the Silk Road was readily apparent to anyone visiting the site. The vast majority of the goods for sale consisted of illegal drugs of nearly every variety, openly advertised on the site as such and prominently visible on the home page'. The only form of payment on Silk Road was Bitcoin. 26. In October 2013, federal law enforcement shut down the website and arrested Ross William Ulbricht under charges of being the site's pseudonymous founder "Dread Pirate Roberts." In February 2015, Ulbricht was convicted on conSpiracy, narcotics, and money laundering charges in U.S. Federal Court in Manhattan relating to the Silk Road and was sentenced on May 29, 2015 to life in prison. As part of the investigation, the FBI was able to seize information about vendors on the Silk Road, which has since?been made available to law enforcement. 27. The Silk Road NTC Vendor List, referenced above, contained a list of vendors on Silk Road with over $100,000.00 in sales, compiled from information on computing servers that were seized by law enforcement during the investigation into Silk Road. Included in this document was the vendor name ?caliconnect.? ?Caliconnect? was described as a marijuana traf?cker with a sales volume at approximately $1,250,248.65. ?Caliconnect? is listed on the NTC Vendor List as the one of the largest vendors on the Silk Road. The FBI estimates that ?caliconnect? was the eighteenth largest vendor worldwide out of the approximately 4,000 vendors who sold goods on the Silk Road. As such, this information indicated that BURCHARD was likely a large-scale vendor on the Silk Road utilizing the vendor name ?Caliconnectfe I requested additional data from the seized Silk Road servers pertaining to. ?Caliconnect.? I received this information on June 11, 2015 and began to review it (as described below). 28. On July 20, 2015, I sent United States Postal Inspector Trevor Covert a list of postal tracking numbers obtained from the Silk Road ?caliconnect? data. The tracking numbers were found in private-messages between ?caliconnect? and his customers. These tracking numbers were assigned to parcels containing marijuana that were sent by ?caliconnect?ito customers. 29. On July 21, 2015, I reviewed the ?ndings of InSpector Covert, which are summarized below: a. 9505 5213 8331 3087 0000 96 mailed from Merced, CA post of?ce zip code AFFIDAVIT IN SUPPORT OF CRIMINAL. COMPLAINT I Case Document 1 Filed 03/24/16 Page 12 of 28 95340 going to Ithaca, NY zip code 14853--Ap1i1 1, 2013; b. 9505 5213 8331 3130 0005 23 mailed from Merced, CA post of?ce zip code 95340 going to Ridge?eld, NJ zip code 07657--May 14, 2013; c. 9505 5109 8173 3207 5153 69 mailed from Winton, CA post of?ce zip code 95388 going to Marion, OH zip code 43302--July 31, 2013; d. 9505 5106 2632 3105 5732 93 mailed from Chowchilla, CA post of?ce zip code 93610 going to Boston, MA zip code 02116--Apri1 15, 2013; e. 9505 51054336 3113 4373 38 mailed from Atwater, CA post of?ce zip code 95301 going to?Hays, KS zip code 67601--April 25, 2013; f. 9505 5108 8804 3 137 4795 51 - mailed from Fresno, CA post of?ce zip code 93720 going to Wilmington, DE zip code 19804--May 23, 2013; g. 9505 5106 7980 3210 5773 90 - mailed from Merced, CA post of?ce zip code 95340 going to Marion, OH zip code 43302--Ju1y 30, 2013; h. 9505 5109 8173 3210 5343 64 mailed from Winton, CA post of?ce zip code 95388 going to Marion, OH zip code 43302?QJu1y 30, 2013; i. 9505 5109 8173 3210 5341 35 - mailed from Winton, CA post of?ce zip code 95388 going to Pompano Beach, FL zip code 33066--August 04, 2013; j. 9505 5000 2928 3218 0002 12 mailed from Clovis, CA post office zip code 93612 going to Centre Hall, PA zip code 16828--August 08, 2013; k. 9505 5213 8332 3218 0002 77 - mailed from?Merced, CA post of?ce zip code 95340 going to Baltimore, MD zip code 21218--August 08, 2013; 1. 9505 5000 1250 3219 0001 97 - mailed from Fresno, CA post of?ce zip code 93720 going to Bronx, NY zip code 10457--August 09, 2013; m. 9505 5000 2650 3249 0001 15 - mailed from Fresno, CA post of?ce zip code 93720 going to Danville, PA zip code 17821--September 06, 2013; 1 n. 9505 5000 2650 3256 0002 69 - mailed from Fresno, CA post office zip code 93720 going to Oxford, OH zip code 45056--September 17, 2013; o. 9505 5000 2928 3257 0000 51 - mailed from Clovis, CA post office zip code AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 1 1 Case Document 1 Filed 03/24/16 Page 13 of 28 93612 going to Binghamton, NY zip code 13905--September 21, 2013; and p. 9505 5000 2928 3256 0002 05 - mailed from Clovis, CA post of?ce zip code 93612 going to Roxbury Crossing, MA zip code 02120--September 21, 2013. 30. 1 observed that all the post offices utilized to send the parcels are located within the Central Valley of California, near the home of BURCHARD, who resides in Merced, California. 31. In October, 2015, I reviewed Silk Road private messages between ?caliconnect? and a customer named ??shingOl.? The following is a summary of contact between ?caliconnect? and ??shingOl?: a. On August 7, 2013, ?fishingO sent ?caliconnect? a private message that stated AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT the following: i. ?Dear Cali, I am currently looking for a new vendor. I hope that you and I can do some business together. It?s seems you have exactly what I?m looking 3) for. ii. have been using this ?money pak? with great success for the last couple of months. faster, easier, and no so up and down. Do you know about these And if so, would this be something that I could pay with? I get these CC thru Walmart. I pay cash, and it cant be tracked. . .I just send you a 16 digit code that you can add to you CC balance. It works for me bc I?m on the road a lot and can buy one within minutes." ?1 will be looking at buying 3-5 depending on the month..and the if the products move like I think it will. If so, I?m Thank you for your time, pp.? b. On August 8, 2013, ?caliconnect? responded to ?fishing01?: i. ?yea yea I know about green dot packs. . .yea that works. . .lets do this first. . .buy a hp from me. . .if all goes well on both ends we can talk. . .safeguards both us to start cut small right? c. -On August 8, 2013, ??shingO responded to ?caliconnect? i. ?thank you very much..this is a big help! I?ll go buy a money pak today 12 AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT Case Document 1 Filed 03/24/16 Page 14 of 28 for hp. I?ll send you the numbers so you add to your card. I do appreciate the help with this payment. I?ll be in touch. ps. This new warning on this site (tonnail) does this affect us emailing each other? Thanks again.? d. On August 14, 2013, ??shing01? sent ?caliconnect? the following private message: i. ?Son?y my bad, I bought a money pak for $865 today. This is before the I got the last email. Please take out a half oz if you need to complete this transaction. Thank you.? ii. 29532942490876 S.J., 15 partridge lane, gray me 04039 [full name redacted] iv. Please con?rm..i do not want to sign for anything if that is possible? Please let me know when this will be going out and if there is a tracking number with this. Thanks again.? e. On August 17, 2015, ?caliconnect? sent ??shingOl? the following private message: i. ?all good the. money pack went through. . .I am shipping out your stuff Monday and will use priority express for the delay..you will have it on wed? f. On August 22, 2015, ??shing01? sent ?caliconnect? the following private message: g. got it today around 3 pm. Thank you. Looks good. I?ll do a full one this time. I?ll have the numbers for you by the end of the day. If you can get it today that would help me out, if not, tomorrow works too. Thank you.? h. On August 23, 2013, ??shingOl? sent ?caliconnect? the following private message: 1. ?I?ll take a whole one this time..2 money packs with 925 on each one. ii. 60904459068324 05272755073653 iv. S.B., 15 partridge lane, gray me 04039? [full name redacted] l3 28' C'ase Document 1 Filed 03/24/16 Page 15 of 28 i. On August 28, 2015, ??shingOl? sent ?caliconnect? the following private message: i. ?Sounds good. I?ll be looking at doing a bigger package in the next 2 weeks..need to get some funds for it all. I?m sending over $1700 as agreed upon. ii. 79925605273324 59382846730844 iv. 38 running brook rd, windham, me 04062? [full name redacted] 32. On October 18, 2015, I submitted a subpoena to Green Dot Corporation for information related to the previously referenced Money Pak codes involving ??shingOl? and ?caliconnect.? On October 30, 2015, I received an email response from Green Dot containing the following informationMoney Pak codes contained within the subpoena, Green Dot indicated they did not have records to provide. However, for Money Pak code 29532942490876, Green Dot indicated that on August 17, 2013, $865.00 was transferred from this code to a Green Dot Network partner AccountNow Prepaid Visa card, number ending in 1881, in the name of DAVID BURCHARD, with a zip code of 95348. This particular Money Pak was obtained from the private message dated August 14, 2013 (as mentioned above). b. In addition, according to Green Dot, Money Pak codes 29532942490876 and 60904459068324 were also redeemed to AccountNow Prepaid Visa card. These Money Pak codes were also mentioned in private messages between ??shingOl? and ?caliconnect? on August 23, 2013, and August 14, 2013, respectively. c. Green Dot also indicated that AccountNow prepaid Visa card was blocked because it was receiving funds related to what they deemed to be possible fraudulent activity. 33. On December 15, 2015, I reviewed a subpoena response from AccountNow pertaining to PrePaid Visa card, number ending in 1881. The following is a summary of the information: i a. Card number ending in 1881 was opened on March 30, 2013 under the name AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT Case Document 1 Filed 03/24/16 Page 16 of 28 DAVID BURCHARD. The applicant?s addresses was Duke Ct, Merced, California 95348; the phone number was the email addresses was ms_1 128@yahoo.com; the social security number was and the date of birth was This information matches personal identifying information I have obtained on BURCHARD. b. AccountNow records indicate that from August 12, 2013, until September 25, 2014, $6,540 in cash was uploaded to the card, which was used to conduct purchases from various businesses and retailers, including Amazon, CCBill.com, Target, Costco, Forever 21, and Chevron. c. I therefore concluded that BURCHARD was on the receiving end of the money Money Pak codes provided to him from ??shingOl? as payment for the sale of marijuana over the Silk Road. - 34. On September 11, 2015, I received information from the DEA indicating that the usemame ?caliconnect2? ordered ?ve 37.5 milligram tablets of phenterrnine for $99.77 from a Silk Road vendor on August 2, 2013. 35. On November 18, 2015, I received further Silk Road data from the FBI on the usemame ?caliconnect2.? The following is a Summary of the information: a. On April 26, 2013, ?caliconnect2? sent a private message to ?asianvixen,? which stated the following: b. Hey asian vixen. . .I understand. I made two transactions on this account. I am a vendor also just thought I was not supposed to use my vendor account to make purchases. My vendor name is caliconnect. Is it ok if I order shirt now?" i 36. Further, on-July 18, 2013, ?caliconnect2? sent a private message to ?TedDanzigSR,? which contained information that would typically appear on an identi?cation card, such as name, address, license number, birthdate, height, weight, and sex. This information appears to have been chosen by BURCHARD for a fraudulent identi?cation document and does not contain his real name, date of birth, or address. The message also stated: a. ?Please enter your address below EXACTLY as you?d like it to appear on the AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 15 C'ase Document 1 Filed 03/24/16 Page 17 of 28 37. the following: 38. mailing label: David Burchard, Duke Ct, Merced CA 95348.? It should be noted that BURCHARD has since moved from this residence. On August 2, 2013, ?caliconnect2? sent a private message to ?BenzoKing,? which stated a. ?0k bro. ..sent you two trans one for 5.3 and another for .15 for the change in and to add express shipping. Here is my drop info f0r shipping. David Burchard, Duke Ct, Merced, CA 95348?. I believe BURCHARD was ?caliconnect2? due to his message to ?asianvixen? in which he states he is the vendor ?caliconnect.? In addition, ?caliconnect2? provided name and address for shipping information to ?BenzoKing.? 39. 40. 41. 42. 43. AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT I also reviewed transactions involving ?Caliconnect? selling cocaine on the Silk Road. In April 2013, ?Caliconnect? posted the following messages: a. ?3.5 grams strait off da brick ?sh scale coke. Straight off the brick and pure as you will ?nd coke. Wish the pics were better because this coke is that real ?sh scale that shines in the light.? b. ?1 am fairly new here on SR but if you check my reviews for the mj I also sale you will see that I am very fair and I don?t scarn people. Stealth in my shipping is beyond good and I am quick to ship and communicate with my buyers. Thanks, Cali.? On April 11, 2013, ?Caliconnect? sent the following message to ?kazim63z? a. ?Hey bro thanks for your order. you are the ?rst on to pick up the white from me so please leave feedback. Yea I will do largerjust let me know after you get package we can custom one up for you. will get in mail no later than Friday but maybe today if time allows. Thanks.? On April 15, 2013., ?Caliconnect? sent the following message to ?tomwallischI? a. ?yea had two order that shipped on Saturday. Those are my ?rst. Honestly my is better deal and quality them the ?owers. No lie. Thanks. Cali.? On April 16, 2013, ?tomwallisch? send ?Caliconnect? the following message: a. ?Hey man, Super excited to be one of the ?rst testers of this. I took your advice 16 Case Document 1 Filed 03/24/16 Page 18 of 28 44. 45. cocaine: 46. and gotjust a ball for now. I h0pe this goes well and product/weight/stealth (had some vendors with sketchy harnd-written labels, and several shorting me ha). ..I may belcrazy but I feel like the longer a vendor is around the shittier the product gets [01, so I am hoping you are straight up and here to stay! [like going back to the same vendors over and over! Looking forward to working more in the future assuming all is legit and product is ?re. Take it easy man! I appreciate! Tom? On August 17, 2013, ?Caliconnect? sent the following message to ?jjgreen57:? a. can get you really cheap coke at really cheap prices or really good coke at really good prices. . .you want coke to party with or coke that comes back point for point. . .sold it for a while on here but some were like trippin bout buying bud from me cuz I was selling coke too so I-pulled the ads. . .I have coke 1500 an 02 on the pure stuff. . .shit goes up in down in price on a daily basis but shit is great. . .straight ?sh scale?. A review of purchase orders for ?Caliconnect? revealed the following sales related to a. On April 11, 2013, the Silk Road buyer ?kazim63? bought 3.5 grams of cocaine from ?Caliconnect? for 1.81 bitcoin (approximately $309.05). b. On April 12, 2013, the Silk Road buyer bought 3.5 grams of cocaine from ?Caliconnect? for 2.22 bitcoin (approximately $31 1.39). c. On April 15, 2015, the Silk Road buyer ?tomwallisch? bought 3.5 grams of cocaine from ?Caliconnect? for 3.27 bitcoin (approximately $310.52). A review of feedback for ?Caliconnect? from the cocaine buyers posted on the Silk Road revealed the following: a. On April 18, 2013, posted this message: i. If you pass on this you are seriously slippingl! This is ABOVE AND BEYOND the quality of the highest price on SR and cost less. This is that Real Deal HOIy?eld FISHSCALEII 10/5 Quality AMAZING. 10/5 Shipping - Only 3 days. 10/5 Stealth - !(Best I've seen yet, very secure). AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT ?nk-C?ase Document 1 Filed 03/24/16 Page 19 of 28 Good vendor to work with and I'll only use him for my future orders, keep this shit on deck Cali! I b. On April 20, 2013, ?tomwallisch? posted this message: i. ?Caliconnect is the man, plus his coke is Had a great experience, and this guy is very eager to keep everyone happy! I will be around again and again, no doubt!!? ?5/5 easily.? 47. Other HSI investigators and I reviewed approximately 977 transactions involving ?Caliconnect? on the Silk Road and determined that approximately 704 pounds of marijuana and approximately 10.5 grams of cocaine were sold to customers located throughout the United States. The total dollar amount of these transactions involving ?Caliconnect? was approximately $1.43 million from approximately March 2013 through September 2013. Among the data provided to me by the FBI on this list, ?Caliconnect? was the third largest U.S.-based vendor on the Silk Road in terms of total sales. C. David BUR CHARD Sells Marijuana on the Dark-web Site A gora 48. In June 2015, I learned that a vendor on the Agora dark-web marketplace going by the name of ?the_rea1_caliconnect? was advertising to sell marijuana.2 The Agora website indicated that this vendor registered on the site one year and ?ve months ago. ?The_real_caliconnect? stated it was the same' vendor from the Silk Road, Black Market Reloaded, and the Silk Road Two dark web marketplaces and that on all those sites it was ranked in the top one percent of vendors. ?The_rea1_caliconnect? also stated it had over 1000 transactions between those sites and continued to build their customer base on Agora. Information on ?the_rea1_caliconnect?s? vendor page indicated they were in ?vacation? mode since approximately May 23, 2015. 49. On July 13, 2015, I learned that ?the_real_caliconnect? had returned to Agora from ?vacation mode.? ?The_rea1_caliconnect? stated ?Hey AG Fam. . .Iam back! And for good now! Listings now up so let?s get this money!? Also, the vendor indicated that it was willing to conduct. orders using an Agora escrow account (Agora, like other dark-web marketplaces, allows for purchases to 2 Agora was a dark-web illegal marketplace that launched in 2013. As with Silk Road, all transactions on Agora were conducted in Bitcoin. The administrators of Agora took it offline in August 2015 to address purported security vulnerabilities. The site has remained of?ine since that time. 18 AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT OOH-.Case Document 1 Filed 03/24/16 Page 20 of 28 put their funds into an escrow account that are not released until the order is received by the purchaser). 50. Based on my review of records on the Agora marketplace, from approximately January 2014 until approximately July 2015, ?the_rea1_caliconnect? sold approximately 470 pounds of marijuana through approximately 1000 transactions. These totals are based on 50 pages of reviews that customers posted to ?the_real_caliconnect?s? vendor account. - D. David BURCHARD Sends Mail Parcels from a Raley?s Supermarket 51. On September 29, 2015, at approximately 12:00 pm, another HSI investigator and I arrived at the Raley?s store located at 3550 Street, Merced, California 95340 (the and contacted an employee (hereafter the ?Employee?). I showed him/her a picture of BURCHARD, who he/she immediately recognized as a frequent customer who usually ships medium sized flat-rate parcels. 52. On September 29, 2015, at approximately 1:02 pm, the Employee contacted me and stated BURCHARD had dropped off three parcels for delivery at the STORE. Intern Mann and I responded to the store and obtained information related to the packages. Speci?cally, the packages were sent to South Carolina, Florida, and Virginia.' The sender on all three packages was: Automotion LLC, 3721 Ithaca Ct, Merced, CA 95340. I conducted a public records check on ?Automotion with negative results. I also learned that 3721 Ithaca Ct is a residential home located one street east of former residence, the DUKE CT ADDRESS. 53. On October 5, 2015, at approximately 12:47 pm, the Employee informed me that BURCHARD sent three parcels from the STORE at approximately 12:30 pm. I did not obtain pictures of these parcels and did not seize them. 54. On October 6, 2015, Raley?s provided me with surveillance camera photos from the STORE. The photos depict a white male resembling BURCHARD mailing three parcels on September 29, 2015, at approximately 12:40 pm, and three parcels on October 5, 2015, at approximately 12:23 pm. 55. On November 25, 2015, at approximately 1:15 pm, I observed BURCHARD driving the CHEVY TAHOE westbound on East Yosemite Avenue, near North Parsons Avenue, in Merced, California. I followed BURCHARD to the STORE. AFFIDAVIT IN SUPPORT OF CRIMINAL COM PLAINT 19 Case Document 1 Filed 03/24/16 Page 21 of 28 56. I observed BURCHARD enter the STORE carrying one-large parcel. Intern Mann observed BURCHARD mail this parcel at the U.S. Postal counter located within the Raley?s. BURCHARD then departed the area at approximately 1:25 pm. I 57. I subsequently viewed pictures of the parcel BURCHARD mailed, which contained the following information: a. Addressee: M.G., Ruritan Lake Rd, Palmyra, Virginia, 22963 [full name and address redacted]; b. Return Address: CC Automotive, 1235 Stevens Ct, Merced, California 95340 c. Tracking Number: 9505 5213 3331 5329 0001 23 d. I did not seize this package. I E. David URCHARD Sells Marijuana on the Dark-web Marketplace AIphaBay 58. On November 13, 2015, Intern Mann took the Pretty Good Privacy (PGP) key utilized by BURCHARD on the darkweb marketplace Agora and searched the dark-web search engine I?Grams? for other vendors utilizing this PGP key. The search indicated that a vendor named ?caliconnect4life? was operating on the dark Web site AIphaBay.3 The web address is ?pwoah7foa6au2pul.onionf user/ php?id=250523 &tab=1 59. According to the AIphaBay website, ?caliconnect4life? began Operating as a vendor on November 10, 2015. 60. On November 13, 2015, ?caliconnect4life? vendor page included the following messages: a. Hey Fam. . .Blue nightmares are Blue Dream Tahoe ?re I had listed on AB bef0re we all got scammed super fucking work. ..shit is like indoor no sleep.? Hey AB Fam. . . guess we are here now too Opening shop here now after Abraxas drama. . .will have work posted I 1.12. 12noon pst.?4 3 AIphaBay is a dark?web marketplace that came to prominence after the takedown of the Silk Road. It is estimated to currently be the largest dark-web marketplace. 4 Abraxas was another illegal dark-web marketplace that came to prominence after the takedown of the Silk Road. In November 2015, Abraxas went of?ine and _is no longer a functioning dark-web marketplace. AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT Case Document 1 Filed 03/24/16 Page 22 of 28 61. On December 29, 2015, Fresno Police Department Detective Daniel VandersIuis, in conjunction with Intern Mann and conducted a controlled purchase of a half-pound of marijuana from the AlphaBay vendor known as ?caliconnect41ife.? Investigators utilized the AlphaBay buyer account ?Megiddo? to purchase the marijuana strain Crack? for approximately $900.00, or 2.0955 Bitcoin. Investigators requested that the parcel be addressed to ?Adam Smith, 701 Washington Street, PO Box 4, Buffalo, New York 14203.? 62. I On December 31, 2015, AphaBay buyer ?Megiddo? sent the following message to the AlphaBay vendor ?Caliconnect4life:? I a. ?hey bro hope all is good. imk ifu shipped that ifu get a chance. Otherwise i?ll check back next week after the new year. i got enough green to get my people thru the weekend.? b. On December 31, 2015, at approximately 2:05 pm, Intern Mann and I observed BURCHARD driving a white Jaguar sedan westbound on East Yosemite Avenue, near North Parsons Avenue, in Merced, California. Intern Mann and I followed Jaguar parked at the Raley?s Store located at 3550 Street, Merced, California 95340. 63. At approximately 2:20 pm, Intern Mann and I?arrived at the Raley?s store and contacted the Employee, who informed me that BURCHARD had mailed four parcels moments earlier. 64. At approximately 4:53 pm, Postal Inspector Trevor Covert informed me ?that a parcel mailed by BURCHARD from Raley?s was addressed to Adam Smith, 701 Washingt0n Street, PO Box 4, Buffalo, New York 14203. The tracking number was 9505 5213 8331 5365 0005 21, it was a medium ?at rate box, and was bearing $12.65 in postage. 65. On January 1, 2016, the vendor ?caliconnect4life? sent ?megiddo? the following messages: a. ?your out and look for Saturday bro or Monday because of the holiday friday.? b. ?sup bro. . .hey order went out but outta shirts. . .sorry. . .yea putting up 02 listings now. ..btw i gave you free upgrade to blue cookies. . .they are more expensive but i have been fucking with you for a while so its all good.? AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 2 1 ?Case Document 1 Filed 03/24/16 Page 23 of 28 66. On January 4, 2016, I retrieved the tracking information for the parcel BURCHARD mailed and noted that the parcel was accepted on December 31, 2015, at 2: 10 pm, in Merced, California 95340, and was delivered to a PO Box at 2:09 pm on January 4, 2016, in Buffalo, New York 14205. 67. On January 5, 2016, I received the parcel BURCHARD sent to Buffalo, New York, from HSI SA Brad Brechler. SA Brechler stated the suspected marijuana weighed approximately 289 grams. I examined the parcel and determined the method of packaging was similar to the parcels sent by BURCHARD and previously seized by HSI Fresno. The suspected marijuana was vacuum sealed in a food saver bag which was then sealed in a moisture barrier bag. 68. I turned the parcel and its contents over to Detective Vandersluis. A chemical analysis of the sUspected marijuana is pending with the Fresno Police Department. Homeland Security and the Internal Revenue Service Search BURCHARD ?5 Residence I 69. On January 20, 2016, I obtained a federal search warrant for the GABRIEL RESIDENCE. 70. On January 21, 2016, HSI agents, along with investigators and of?cers from the IRS, USPIS, Merced Police Department, and California Highway Patrol, executed the search warrant at the GABRIEL RESIDENCE. 71. At approximately 7:10 am, HSI conducted a knock and notice on the front door of the residence, and subsequently encountered BURCHARD, MONICA SAUCEDO spouse), and three minor children. HSI made entry into the residence and secured it without incident. 72. and investigators conducted a search of the residence as authorized by the search warrant and seized numerous computers and other electronic storage devices. I also seized numerous items associated with the distribution of narcotics, including anti-static bags, a digital scale, food saver vacuum sealing bags; Amazon boxes with plastic storage bags; a trash bag containing marijuana, a box containing a sealed bag of marijuana. I also found pieces of clothing apparel with the label ?caliconnect.? In addition to this evidence, case agents seized a 2010 Jaguar XF sedan; a Mercedes S63 a 2013 Mercedes and a 2007 Chevy Tahoe 22 AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT Clase Document 1 Filed 03/24/16 Page 24 of 28 73. BURCHARD signed a Department of Homeland Security ?Consent to Search? form for two storage units under his control, which included Central Self Storage Merced, 3 23rd Street, Merced, Califomia 95340, Unit 228, and Darrell?s Mini-Storage, 2425 Santa Fe Dr, Merced, California 95343, PAC 4, Unit 2459. I 74. At approximately 10:40 am, HSI case agents searched storage unit located at Central Self Storage Merced, 3 23rd Street, Merced, California 95340, Unit 228, and seized a credit card machine with blank cards and other items indicating that BURCHARD was involved in the production of- stolen or fraudulent access devices: 75. I conducted an interview of BURCHARD at his residence with lntemal Revenue Service, Criminal Investigations (IRS) SA Kulbir Mand and Intern Mann. The following is a summary of the interview: a. At approximately 8:05 am, I identi?ed myself to BURCHARD and informed BURCHARD of the purpose of the search warrant and interview. I read BURCHARD his Miranda Rights at 8:10 am and asked BURCHARD if he understood his rights. BURCHARD stated, ?Yes sir.? I informed BURCHARD he was not under arrest and not in custody. BURCHARD stated he was willing to answer questions, but would decline or take the ??fth? for questions he did not feel comfortable answering. During the interview BURCHARD provided the following information: b. BURCHARD stated that since 2012 he traded Bitcoin to make money _on the website LocalBitcoins.com. He would buy Bitcoin at or below market prices and then sell above the market price to make a pro?t. He began trading bitcoin in 2012 when the pricerose from $41 to over $1,200 per bitcoin. He stated many of his clients conduct Bitcoin exchanges with him because they do not want to give up their personal information, which would be required with a legitimate digital currency exchange company. BURCHARD does not know his Bitcoin wallet address and indicated it was on a computer hard drive that he discarded. From 2010 to 2012, he was unemployed and has not sold Bitcoins since his daughter died in June 2015. BURCHARD and his family have been using his deceased daughter?s $100,000 life insurance payment to cover their AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT . Case Document 1 ?led 03/24/16 Page 25 of 28 living expenses. BURCHARD stated his wife, Monica SAUCEDO, have lived together for 18 years and she is employed as a cosmetic dentist. However, they never ?led for a marriage license. c. BURCHARD stated ?Caliconnect? is the name of his clothing brand, which he ?led paperworkvto trademark. d. BURCHARD stated he does not sell marijuana through the dark web. He stated he has never mailed marijuana to anyone. He?acknowledged that he used to sell marijuana when he was 17 or 18 years old and last grew marijuana in 2011 in the Porterville area. 76. At approximately 8:12 am, HSI Andres Varela and Tim Kotman interviewed SAUCEDO. SAUCEDO was informed that she was not under arrest and was read her Miranda rights by SA Kotman. SAUCEDO waived her Miranda rights verbally and in writing at approximately 8:13am. The following is a summary of statement: a. SAUCEDO stated she had lived at Gabriel Drive, Merced, California 95340 (identi?ed above as the GABRIEL RESIDENCE), for approximately two years. SAUCEDO stated prior to living at the Gabriel address she lived at Duke Ct, Merced, California 95340 (identi?ed above as the DUKE CT RESIDENCE), for approximately four years. Prior to the Duke Ct address, she lived at Shafer Ave, Merced, California 95348, for three years. b. SAUCEDO stated her ?ance, BURCHARD, had not been working for the last six or seven years. SAUCEDO stated she was a stay-at-home mom. SAUCEDO stated the rent was $1350.00 a month at the Gabriel address. G. Evidence on BURCHARD ?5 Computer Reveals He Is ?Caliconnect? 97. In February, 2016, IHSI Computer Forensic Agent (CFA) Ulises Solorio provided me with information he obtained from an Acer lapt0p and attached thumb drive that was seized in the dining room of residence. The following is a summary of the information: a. CFA Solorio discovered the black and gold ?Caliconnect? logo (currently being used by BURCHARD on the dark-web market AlphaBay) in an image ?le on the laptop. AFFIDAVIT IN SUPPORT OF CRIMINAL, COMPLAINT Case Document 1 Filed 03/24/16 Page 26 of 28 b. The Onion Router (TOR) browser was found on the laptop, which is used to access the dark-web and anonymize a user?s Internet Protocol (I.P.) address. c. CFA Solorio found an image ?le of 2014 Supra boat that he sold in August 2015. (1. CF A Solorio provided me with messages found on thumb drive. BURCHARD used a program called GPG4USB, which automatically used Burchard?s Pretty Good Privacy (PGP) private key to messages sent to him from customers. The GPG4USB program required a password to messages. CFA Solorio discovered that ?asshole209? was the password, which was a password utilized by BURCHARD based on subpoenaed records obtained by me. e. - I reviewed the following message found on laptop: i. ?Adam Smith, 701 Washington Street, PO Box 4, Buffalo, New York 14203? ii. ?hey bro I sent a message about the ounces but I?m going to pick up your last HP anyhow. Let me know if are going to add more. If still have those old cali shirts throw one in for me if don?t mind, size large. Thanks bro, have a happy new year.? 77. This address and message are identical to the information provided by who conducted the undercover controlled buy of a half-pound of marijuana from ?caliconnect4life? on the dark-web market AIphaBay. 78. I noted approximately 49 orders within the messages from customers who were buying marijuana from BURCHARD. The following is an example of one of those orders: a. ?Hey CC, here to order another 2.5 LBS of your STRAWBERRY 1 have two addresses for you. Would you kindly send 2 LBs to: J.N., Broad Oaks Dr, Hemdon, VA 20170. 1 HP to: T.B., Kristin PL, Hemdon, VA 20171. Thank you so much! [full names and addresses redacted] 79. CF A Solorio found a-Bitcoin wallet and provided thetransaction history to me. I noted that on January 4, 2016, the wallet received a 6.154 bitcoin payment and that same day sent out 6.15 AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT C'ase Document 1 Filed 03/24/16 Page 27 of 28 bitcoin. According to walletexplorer.com (a website that allows you to search for details on bitcoin transactions), the 6.154 payment came from the dark-web market AlphaBay. As previously noted, HSI Fresno conducted a controlled buy with BURCHARD for a half pound of marijuana on December 29, 2015, and released the bitcoin payment from an AlphaBay escrow account on January 4, 2016. 80. 1 therefore believe that part of the 6.154 bitcoin transfered to wallet consisted of the payment made by investigators as part of the purchase of a half-pound of marijuana from ?caliconnect4life.? I 81. In addition, it is evident to me that BURCHARD had control of the AlphaBay vendor account ?caliconnect4life? and was processing and sending out the parcels from the GABRIEL RESIDENCE. IV. CONCLUSION 97. Based upon my training and experience, and on the facts set forth in this Af?davit, there is probable cause to believe that David BURCHARD has violated Title 21, United States Code, Sections 841(a)(1) (Distribution of a Marijuana and Cocaine, Controlled Substances), and 21 U.S.C. 846 and 841(a)(1) (Conspiracy to Distribute Marijuana and Cocaine, Controlled Substances). I therefore request that you issue the attached arrest warrant and criminal complaint. Approved as to form: Grant B. Rabenn Grant B. Rabenn Assistant United States Attorney Mathew Larsen Special Agent - Homeland Security Investigations to before me this ay of March 2015 MM BARBARA A. MC United States Magistrate I 'e Eastern District of California Swo AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT Case Document 1 Filed 03/24/16 Page 28 of 28 fs/ GBR AUSA PENALTY SLIP DEFENDANT: David Ryan BURCHARD COUNT ONE: VIOLATION: 21 U.S.C. 841(a) S: (C) Distribution of Marijuana and Cocaine, Controlled Substances PENALTY: 20 years imprisonment $1,000,000 criminal fine Mandatory 3 years supervised release VIOLATION: 21 U.S.C. 846 and 84l(a)(l) - Conspiracy to Distribute Marijuana and Cocaine, Controlled Substances PENALTY: 20 years imprisonment $1,000,000 criminal fine Mandatory 3 years supervised release I