Case Document 11 Filed 08/09/17 Page 1 of 75 A0 9! (Rev. ll/ll) Criminal Complaint UNITED STATES DISTRICT COURT for the Eastern District of California United States of America v. William James FARBER, aka ?Bill Danzerian,? Case NoMichael Angelo PALMA, Richard Thomas MARTINSEN, Bryan Anthony LEMONS, and Michele PICKERELL Defendant(s) CREMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge andlbelief. On or about the date(s) of August 2013 through May 201? in the county of Fresno and Kern 7 in the _WEaW_s__tem District of California the defendant(s) violated: Code Section Offense Description 21 U.S.C. 841(a)(1), and Distribution of Controlled Substances and Conspiracy 846 18 U.S.C. 1956 . MOney Laundering and Conspiracy This criminal complaint is based on these facts: _(see attachment) Continued on the attached sheet. Complainant 's signature Matthew Larsen, Special Agent, HSI Printed name and title Judge '5 signature Sworn to before me and signed in my presence. Date: 7777777 9?017 Cityand state: Fresno, California _Erica P. Grosjean, U.S. Magistrate Judge Printed name and title Case Document 11 Filed 08/09/17 Page 2 Of 75 Table of Contents AFFIDAVIT OF MATTHEW LARSEN 1 INTRODUCTION 1 II. SUMMARY OF THE INVESTIGATION . 3 BACKGROUND ON DIGITAL CURRENCY '4 Iv. STATEMENT OF PROBABLE CAUSE 7 A. Overview of Individual Subjects 7 William FARBER 7 2. Michael PALMA, 8 3. Richard MARTINSEN . 9 4. Bryan LEMONS 9 5. Michele PICKERELL 10 B. Overview of the VANALDEN WAREHOUSE 10 C. Initial Investigation into FARBER 11, D. FARBER on the Silk Road 15 E. Use of the Moniker ?Purefiremeds? on the Silk Road 18 F. Border Search on Cell Phone 21 G. Email Account 25 H. Tax Return Information 28 I. Link between ?Purefiremeds? and ?Humboldtfarms?.30 J. ?Undercover Purchase from HUMBOLDTFARMS 30 K. Surveillance of Mailings Connected to - HUMBOLDTFARMS 31 N. Annie Jagler?s.involvement in the HUMBOLDTFARMS i Case Document 11 Filed 08/09/17 Page 3 of 75 DTO 44 O. The GABRIELINO RESIDENCE is identified as a location of marijuana distribution 46 P. Richard MARTINSEN is identified as mailing parcels for the HUMBOLDTFARMS DTO 50 Q.- LEMONS is associated with the marijuana company ?dabble? 58 S. Cell phone tolls for members of HUMBOLDT FARMS 62 T. Information from GPS tracker 68 U. FARBER'operates a marijuana related business named 81? Enterprises LLC 65 V. HUMBOLDTFARMS goes on vacation mode on AlphaBay 67 W. DREAM MARKET 68 X. VANALDEN WAREHOUSE 68 . Y. Blockchain analysis of bitcoin wallets 70 CONCLUSION ?.71 ii Case Document 11 Filed 08/09/17 Page 4 of 75 AFFIDAVIT OF LARSEN I, Matthew Larsen, being duly sworn, declare and state as follows: I. INTRODUCTION 1. I am a Special Agent with Homeland Security Investigations (HSI) and have been so employed for approximately eight years. As a requirement for employment as an HSI Special Agent, I successfully completed the Criminal Investigator A Training Program (CITP) located at the Federal Law Enforcement Training Center (FLETC) in Georgia. At the conclusion of CITP, I completed an-additional Immigration and 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, firearms, rules of evidence, and interview techniques. 2. As a Special Agent with HSI, part of my duties include the investigation of criminal violations as proscribed by 21 U.S.C. 841 846 (Distribution of Controlled Substances and Conspiracy) and 18 U.S.C. 1956 1957 (Money Laundering and Conspiracy). Moreover, as an HSI Special Agent, I 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. I am familiar with the formal methods of illegal narcotics investigations, including electronic surveillance, visual surveillance, general questioning of witnesses, search warrants, confidential informants, the use of undercover agents, Case Document 11 Filed 08/09/17 Page 5 of 75 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. 4. My knowledge of drug trafficking and money laundering practices, as well as my knowledge of drug transportation and distribution techniques on the ?dark web,? arise from the following: my training and experience in drug and dark web. investigations; b. the collective shared experience of other federal agents, state and local law enforcement officers I have worked and consulted with in regards to this investigation, and c. _other intelligence information provided through law_enforcement channels. 5. The information contained in this affidavit is submitted for the sole purpose of demonstrating probable cause to obtain a criminal complaint. Because this affidavit is being submitted for the sole purpose of demonstrating probable cause, it does not contain all of the information known to me and other law enforcement officers involved in this case. 6. Based on my training and experience and the facts as set forth in this affidavit, there is probable cause to believe that violations of 21 U.S.C. 841, 846 (distribution of controlled substances and conspiracy) and 18 U.S.C. 1956 (money laundering and conSpiracy) have been committed by William Case Document 11 Filed 08/09/17 Page 6 of 75 FARBER, Michael PALMA, Richard MARTINSEN, Bryan LEMDNS, and Michele PICKERELL, and others not charged in this complaint. II. SUMMARY OF THE. INVESTIGATION 7. I initiated this investigation based on the money laundering activities of William EARBER, a Los Angeles resident who was converting large amounts of bitcoin into cash through an unlicensed bitcoin exchanger in Bakersfield, California and elsewhere. As described below, over the course of my investigation I discovered that EARBER was a dark web narcotics trafficker on The Silk Road from approximately June 2013 through October 2013, operating under the name ?Purefiremeds.? After the Silk Road was shut down by law enforcement in October 2013, EARBER, with other co-conspirators, began operating on other dark web marketplaces, including AlphaBay, under the name ?Humboltharms? (hereafter, with other associates, referred to as the through which he sold thousands of pounds of marijuana to customers throughout the United States and is believed to have been the largest vendor on AlphaBay from approximately March 2015 through May 2017. I 8. As described below, members of the HUMBOLDTEARMS DTO, including PALMA, MARIINSEN, and others have used the residence of co?conspirator Michele (the located in a gated community in Altadena, California, to assemble and mail an estimated 1,000 parcels a week of marijuana. I believe that the HUMBOLDTEARMS DTO completed over 78,000 orders on the dark website AlphaBay since approximately March 2015. Further, I learned through an email Case Document 11 Filed 08/09/17 Page 7 of 75 search warrant and other evidence that FARBER, with assistance from LEMONS and others, has exchanged at least $7 million in bitcoin for cash through unlicensed bitcoin exchangers, which is believed to be the proceeds of the HUMBOLDTEARMS DTO's drug distribution. BACKGROUND 0N DIGITAL CURRENCY 9. Digital currency (also known as is generally defined as an electronic?sourced unit of value that can be used as-a substitute for fiat 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 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 financial transactions. However, digital currency is often used for conducting illegal transactions, such as the sale of controlled substances. 10. Bitcoin is a type of digital currency. Bitcoin payments are recorded on a public ledger that is maintained by peer-to?peer verification, 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. Case Document 11 Filed 08/09/17 Page 8 of 75 11. 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. ?12. Bitcoins are stored in 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 address can be analogized to an account number while the private key is like the password to access that account. 13. 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. 14. Through the dark web or dark net, 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 1 The Silk Road was a dark net website operated as a TORK hidden service. The Silk Road allowed its users to brOWSe anonymously to purchase a variety of illegal goods, including Case Document 11 Filed 08/09/17 Page 9 of 75 'accept payment through digital currencies, such as bitcoin. _Accordingly, large amounts of bitcoin sales or purchases by an individual is often an indicator that the individual is involved in narcotics trafficking 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 bitcoins as proceeds of illegal sales on Silk Road-like websites need to sell their bitcoins to convert them to fiat (government-backed) currency. Such purchases and sales are often facilitated by peer-to?peer bitcoin exchangers who are not registered with the federal or a state government and who advertise their services on websites designed to facilitate such transactions. These unregistered exchangers often charge a higher transaction fee than legitimate, registered digital currency exchangers. This higher fee is essentially a premium that the unregistered exchangers charge in return for not filing reports on the exchanges pursuant to the Bank Secrecy Act, such as Currency Transaction Reports and Suspicious Activity Reports.2 controlled substances. Bitcoin was the form of payment accepted by the site. In 2013, the FBI 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 the Southern District of New York relating to the Silk Road and was sentenced on May 29, 2015, to life in prison. His conviction and sentence was affirmed by the Second Circuit Court of Appeals. 2 In 2013, the Financial Crimes Enforcement Network determined ?persons creating, obtaining, distributing, exchanging, accepting, or transmitting virtual currencies? are subjected to the regulations contained within the Bank Secrecy Act. Case Document 11 Filed 08/09/17 Page 10 of 75 15. Dark websites (such as when the Silk Road existed) operate on ?The Onion Router? or network. 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 specific web browser software designed to access the TOR network. TV.STAIEMENT OF PROBABLE CAUSE A. Overview of Individual Subjects 1. William FARBER 16. EARBER is a resident of Los Angeles and is 37 years old. His criminal history includes: 2014 convictions for misdemeanor reckless driving and misdemeanor driving without a license; a 2006 conviction for misdemeanor possession of obscene material (minor in a sex act); and a 2006 conviction for misdemeanor driving under the influence. FARBER is currently a State of California registered sex offender. 17. EARBER was initially identified by law enforcement based on his exchanging of large sums of bitcoin for cash using unlicensed money exchangers.- After identifying EARBER as being Case Document 11 Filed 08/09/17 Page 11 of 75 involved in bitcoin-for-cash exchanges, I was able to determine that he was a vendor of marijuana, cocaine, mushrooms, ecstasy, LSD, and various prescription drugs on the Silk Road using the moniker ?Purefiremeds.? This information came from the seized servers of the Silk Road. After the Silk Road was shut down by law enforcement, EARBER and his co-conspirators began selling ?large quantities of marijuana on the dark web marketplace AlphaBay3 under the moniker ?Humboltharms.? 2.. Michael 18. PALMA is a resident of Les Angeles and is 22 years old. He was arrested in 2013 on staterurglary charges. The disposition for this arrest is unknown. 19. EAEMA was identified by case agents as one of the individuals who regularly went to residence and then to post offices in the Los Angeles area to ship parcels of marijuana to customers of the HUMBOLDTEARMS DTO. Case agents have observed PALMA in person and through surveillance footage mailing.hundreds of parcels on behalf of the HUMBOLDTFARMS DTO. Two of the parcels PALMA mailed were seized by case agents and found to contain marijuana. 3 AlphaBay is estimated to have been the world?s largest darknet marketplaces. Like the Silk Road, AlphaBay existed on the TOR network and allowed users to buy and sell all types of illegal goods, including narcotics, stolen identification and bank account records, and toxic chemicals. It began operation in December 2014 and was taken down by U.S. law enforcement on or about July 5, 2017. Its founder and administrator, Alexandre Cazes, aka ?Alpha02,? ?Admin,? is believed to have killed himself in a Thai prison where he was awaiting extradition to the United States on federal RICO, narcotics, access-device fraud, and money laundering charges. 8 Case Document 11 Filed 08/09/17 Page 12 of 75 3. Richard MARTINSEN 20. MARTINSEN is a Studio City resident and is 29 years old. He does not have a criminal history. 21. In February and March of 2017, MARTINSEN purchased. over $9,500.00 worth of a distinctive priority postage stamps that were used_by the HUMBOLDTEARMS DTO to mail marijuana parcels. Also, in March and April of 2017, case agents observed in person and through surveillance footage mailing hundreds of parcels on behalf of the HUMBOLDTEARMS DTO. Two of the parcels MARTINSEN mailed were seized by investigators and found to contain marijuana. According to social media postings, MEETINSEN is friends with EARBER and has travelled with him. MARTINSEN is also friends with LEMONS. 4. Bryan LEMONS 22. LEMDNS is a Los Angeles resident and is 29 years old. His criminal history includes: 2010 convictions for misdemeanor driving under the influence of alcohol and misdemeanor driving under the influence of drugs; and a 20l2 deferred entry of judgment for possession of a controlled substance. LEMDNS also violated his terms of probation in 2013 and 2015, for which he served time in jail. Case Document 11 Filed 08/09/17 Page 13 of 75 cartridge company called ?Dabble,? which is associated with Humboltharms parcels, William edible marijuana company, Cheef Naturals, and Richard event promotion company, ?bLAacklist.? Additionally, PALMA visited I former residence after working at the GABRIELINO RESIDENCE and mailing packages on behalf of the HUMBOLDTFARMS DTO. Michele PICKERELL 24. PICKERELL is an Altadena, California resident and is 47 years old. She does not have a criminal history. Case agents discovered that individuals mailing parcels on behalf of the DTO were meeting at residence on almost a daily basis and then travelling to post offices to send out parcels of marijuana to customers of the HUMBOLDTFARMS DTO. Case agents also discovered that PICKERELL is Facebook friends with EARBER. She is seen in one photo on Facebook wearing a ?Stix? baseball cap (as described below, ?Stix? is the name of a skateboard shop co?owned by FARBER). Phone records indicate that PICKERELL communicated with BARBER over 100 times within a three-week time period, as described below. Overview 9f the VANALDEN WAREHOUSE 25. Case agents installed a GPS tracker on vehicle in April 2017, which showed that vehicle traveled to the warehouse_in Northridge, California (the on multiple occasions. In addition, according to the Department of Water and Power (DWP), the warehouse uses an unusually large amount of power, which is indicative of indoor marijuana grow activities. The DWP account 10 Case Document 11 Filed 08/09/17 Page 14 of 75 is in the name of EARBER and a marijuana-related business, ?Marlin Management.? Further, as described below, public records indicate that ?Green Nation Cultivation, is associated with this warehouse. Green Nation Cultivation advertises itself as an investment and management company specializing in marijuana cultivation. C. Initial Investigation into EARBER 11 Case Document 11 Filed 08/09/17 Page 15 of 75 I 2 Case Document 11 Filed 08/09/17 Page 16 of 75 Case Document 11 Filed?08/09/17 Page 17 of 75 l4 Case Document 11 Filed 08/09/17 Page 18 of 75 D. EARBER on the Silk Road 38. On November 11, 2015, former DEA Task Force Officer? (TFO) Jared Gabbay provided me with the following information pertaining to a search warrant conduCted on January 23, 2014, by DEA Boston and the Cambridge Massachusetts Police Departwent, on a residence located at 115 Harvard St, 4, Cambridge, MA 02139. 15 Case Document 11 Filed 08/09/17 Page 19 of 75 I valued at approximately $8,000.00. Agents and officers recovered a clandestine narcotics laboratory, various 'pharmaceutical controlled substances, and United States Postal; Service mail shipping slips. 40. Investigators examined the mail shipping slips and noted that the labels were addressed to the following persons:' TO: William EARBER, 857 Palo Verde Ave, Pasadena, CA 91104. ITO: William EARBER, 421 South Avenue, Monrovia, CA 91016.? 41. All of the USPS Express Mail labels had the ?Waiver of Signature? indiCated. I know-from my training and experience that_this waiver is commonly utilized by persons sending controlled substances and/or U.S. currency through the USPS: As a.result of selecting this waiver, the recipient of the package will not have to provide a signature at time of delivery, whichi prevents the recipient from having to provide a signature and being caught in a potential law enforcement controlled package delivery. ?Additionally,_I know from my training'and experience that USPS Express mail is a common method of shipping utilized by drugtraffickers and money laundering groups because of its affordability and privacy as compared to commercial mailing. 42. The labels recovered cover the time period from approximately September 2013 through December 2013. Some labels 16 Case Document 11 Filed 08/09/17 Page 20 of 75 do not indicate a date. A-total of 22 USPS Express labels were recovered.' Included in shipping labels was a receipt from the Kendall Square Post Office, located in Cambridge, Massachusetts. The receipt was for a USPS Express mailing William I 43. TFO Gabbay informed me that was acting as a Bitcoin exchanger, in which he would buy bitcoin from indiViduals, including EARBER, and then send cash through the? mail to his customers. TFO Gabbay interviewed ?l matting mm cash in the mail at the time of the execution of the Search; In addition, - Istated they were. sending per day to a dark?web narcotics supplier (not FARBER) based.out of Porterville, California. ?44. eattay stated that - - The registered business address s? tto eattay believed this was Best?s attempt to operate as a ?legitimate? 17 Case Document 11 Filed 08/09/17 Page 21 of 75 Bitcoin exchanger while also providing cash to dark-web vendors, including EARBER, as detailed below. I 45. On November-18, 2015, TFO Gabbay stated he examined e? mails that Best sent and received in the days prior to mailing pack ages to EARBER, including emails sent between Best and -EARBER on October 3, 2013. TFO Gabbay noted that there were Pretty Good Privacy from ?Purefiremeds? on or about October 3,2013. E. Use of the Moniker ?Purefiremeds? on the Silk Road 46. Based on the previously mentioned email address, I searched publicly available dark- web information and discovered comments and reviews on a dark web vendor.known as I 47. On March 2, 2016, I received information from the International Organized Crime Intelligence and Operations Center pertaining to the dark web vendor ?Purefiremeds.? ?The - information came from the seized servers of the dark-web markets Silk Road and Pandora. The Pandora marketplace operated in a similar fashion to the Silk Road, which is described above. 48. I noted that according to the Silk Road data provided by on September 23, 2013, the vendor sent a private message to which stated the following. a. ?Yes that works for me. Please overnight cash for. 60 bitcoins to same address asap: William FARBER, 421 5 Pretty Good Privacy (PGP) is a pOpular program used to and email over the Internet, as well as authenticate messages With digital signatures and stored files. - 18 Case Document 11 Filed 08/09/17 Page 22 of 75 . . . Ave, Monrovia, CA, 91016 have confirmed that Father in fact resided at this address during at this time period].- This will be the address that you will continue to ship cashito. After today I will be dele_ting this address from this meSsage history so please keep for yourself sOmewhere safe (possibly an drive or device). Also I do not have access to your pub key so please sent that to me or let me know where I can access this. I will start to contact you via your email address after I get yOur pub key. I am sending the 60 bitcoins your way now. Confirm after when you have shipped the cash. Thanks!? 7 b. A I also discovered the following private message- from to sent on September 18,2013: Yes, I very much apologize for the delay. This afternoon SR seems up and running again. cool. I?ve sent yOu $3720 (sorry for overpaying a bit) and the tracking number ,is EU 92019635 US and you should have it by tomorrow morning. Here is my bitcoin address: 49. TFO Gabbay provided me with photos of USPS Express Mail labels found in Best? 5 apartment during the search warrant that was conducted on January 23, 2014, in Cambridge, MassachuSetts, as described above. 'One of the photos is of a label dated September 18, 2013, and addressed to FARBER. The tracking number is EU 926019635 US, which is the same number 'mentioned in the private message I found from to 19 Case Document .11 Filed 08/09/17 Page 23-0f'75 50. Based on this private message exchange, I believe that the vendor ?Purefiremeds? was EARBER and that the buyer of bitcoin, was Best. 51. I reviewed data from the Pandora servers pertaining to the vendor PUREFIREMEDS and noted the.following: a. On January 6, 2014, the buyer ?blackCodeDog? purchased Blue Mac Reboots Ecstasy Pill (180 mg, MDMA, XTC, Lab Tested)? from PUREFIREMEDS for a total of .1057 bitcoin, which was the eQuivalent of $97.4833. The shipping- address provided by the buyer was Ruth Xovox, PO Box 4263, Georgetown, CA 95634. I b. ?The bitcoin for this purchase was released from escrow by the buyer on January 8, 2014. 52. In addition, I reviewed the PGP key from the PUREFIREMEDS vendor accounts from the Silk Road and Pandora dark net marketplaces and noted the PGP key is the same for both accounts. I believe that this common PGP key indicates that the same person was operating both vendor accounts. 7'53.? According to an analysis I received from the DEA Document and Media Exploitation Section, PUREFIREMEDS finalized 5,486 narcotics orders between August 26, 2013, and October 28,. 2014. PUREEIREMEDS sold 10 different types of illegal narcotics, including marijuana, cocaine, norco hydrocodone, 'mushrooms, ecstasy, MDMA, LSD, Xanax, and Ketamine. The total value of these finalired orders was-estimated to be $1,183,904.60. 20_: Case Document 11 Filed 08/09/17 Page 24 of 75. Border Search on Cell Phone 54.' On-January 22, 2016, I was notified that FARBER was departing the United States from the Port of Miami on a cruise ship that was destined for Jamaica. I contacted HSI Miami and requested they conduct a border search of BARBER upon his return to the United States. HSI Miami and United States Custom and Border Protection officers conducted the border search of EARBER when he returned. Forensics Agent provided me a c0py of cell phone obtained during the search. I examined the contents of the phone, which are summarized below: a. I found numerous pictures related to narcotics, .including the following: I One small clear plastic bag of pink triangle shaped pills resembling the illegal narcotic ecstasy. ii. Dozens of green rectangular shaped pills resembling the illegal narcotic ecstasy. One small clear plastic bag of five pink triangle shaped pills resembling the illegal narcotic ecstasy. - iv. One garbage bag containing numerous clear plastic bags containing mushrooms. v. One hand holding six pink triangle shaped pills resembling the illegal narcotic ecstasy. I vi. One clear plastic bag containing mushrooms. vii. A blue powdery substance on a flat surface that appears tORbe ground down ecstasy or adderall." 'Pieces of honey oil on a flat Surface. ix. .Marijuana. 21. Case Document 11 Filed 08/09/17 Page 25 of 75 ?3 x. Jessica Laughlin, who appears to be EARBER's girlfriend, holding mushrooms in both hands. xi. EARBER on a boat in the water while doing whippets (nitrous oxide found in small metal cannisters).- xii. Vacuum sealed marijuana. Four clear_plastic bags containing round green pills, green rectangular pills, rOund orange pills, 'and round white pills, all resembling ecstasy. xiv. A soreenshot of a pillreports.net report on four ecstasy pills. I I b. I discovered the following text messages on phone: i. On November 27, 2013, at 11:13pm, ?Marlo?' texted EARBER the following message: ?Can you bring us the white girl to hang out plz.? At 11:27pm, EARBER responded ?sure.?? I_know from my training and experience that ?white girl? is a nickname for cocaine.' ii. ?On December 6, 2013, at 4:19pm, ?Marlo" texted EARBER the following message: ?Just popped a meatloaf in I should be there by 4:15.? At 4:21pm ?Marlo? sent a follow?up meSsage: ,?Also can I get 4'or 5 norcos? Whatever 20$ will buy?" At 4:35pm, EARBER responded I know from my training and experience that ?norco? is a prescribed opioid pain medication that is often abused by drug users. On June 25,,2014, at 4:49pm, ?Gee Sylvias Bff" sent EARBER the following mesSage: ?Fuck douche bag drug dealer. Fuck And sorry I?m not stupid_enough to believe 22 Case Document 11 Filed 08/09/17 Page 26 of 75 that ham took over_ur spot good plan but not that stupid. I would never rat on guysmU A DICK and ur time will come loser. Don' EVER tell someone I said _something I didn? say. 2 feet tall acting like a bad ass. Ur _Silvia so Stupid up your ass. treat people like shit. Ur day will comemu a joke.' Hey 2 ft tallmand trust memJessica will never stay with u. IShe is way to pretty and can iget a lot better than a piece of shit drug dealer like u. EVERYONE OF UR FRIENDS THINK UR AN ASSHOLE: Ur own brother thinks an asshole. Rule 101 in drug dealingmdonit be so fucking mean to peOple. That?s an idiot move. I don?t need to rat on umuve pissed off so many peoplemsomeone will get umGood luck cause will go down one day. try to kiss up to Don.. He can?t stand No Don-is a big deal rva wanna be. have 'issuesmu insecure as fuckmFUCK Go sell more drugs and ?piss people off. I?m old as dirt and I know more people than will ever know. I?m not scared of but be careful bil cause. _I'm after perSonally. Would never rat There is way worSe things. So keep eyes in the back of ur head cause just never know.? iv. On October 16. 2013. at 12;21am, ?Ham? sent EARBER the following message: Yo we should pick up a boat of these DOlph?s.? FARBER responded, ?Can get for sure??_ ?Ham? Iresponded, ?Yeah my boy paul gots bunch. We should pick a up.? responded, ?Price??' ?Hamf responded, ?550 for the dolps for a-jay.? At 1:59am. ?Ham? sent EARBER the following message: ?Hey this guy is gunna be in Pasadena area in?3 hr. should 23 Case Document 11? Filed 08/09/17 Page 27_ of 75 meet up with him he has a large variety of goods for good_ price.f EARBER responded, ?Can?t today man I?m swamped.? I- know from my training and experience-that a ?blue dolphin? iS?a common ecstasy tablet and I believe that is what ?Ham?6 is referring to in this text message. . v. On October 16, 2013, at 5:50pm, ?Josh 951? sent EARBER the folloWing messagezi ?I'm still 2.5% under bitstamp if you want me to sell for you at that rate.? EARBER responded, ?Need in person trade today if you?re down; Willing to make the trip.? ?Josh 951? responded, ?Sure. I'm about to go get cash. What time can you make it? EARBER responded, ?2-3pm.? ?Josh 951? responded, ?How much?? FARBER responded, ?Whatever you can come up with. Have over 100.? I?Josh 951V responded, ?72.5 coins for $9900 ok? That?s 136.55 each.7 responded, ?Yes.? ?Josh 951? responded, Eta?.Ignore me if you?re driving: driVe safe!" EARBER responded, ?Prob going to? be after.6-7pm is ok? I can send coins first.? ?Josh 951?? responded, ?Sure, lemme_get you the addym? EARBER responded, I can send in about 1 hour.? ?Josh 951 responded, I 0 Sounds good. See you this -evening.? FARBER responded, vi. On October 16, 2013, at 9:46pm, FARBER sent the following message to ?Josh 951:? ?Ok sent FARBER followed up with ?Please Confirm.? ?Josh 951? responded, see them. Thanks. 6 or 7pm. See you then.?" EARBER responded, 5 I believe that ?Ham? is Michael Richard Ham, an associate ?of Farber and a resident of Monrovia, California. 24? Case Document 11 Filed 08/09/17 Page 28 of 75 -?What's the addreSS for that place? And it prob wont be till ?Josh 951 responded, ?Getting itm.39540 Murrieta Hot Springs Rd, Unit 234, Murrieta, CA 92563 United States. EARBER responded, ?0k it's looking like 8:30 is ok? And I have plenty more after this." ?Josh 951 reSponded, ?Sure, I owe younecessary." I c. I believe the two previous text mes?ages show EARBER and ?Josh 951? discussing the trading of bitcoin for cash. G. Email Account 55. on July 13, 2016, Acting Eastern District of California Magistrate Judge Jonathan B. Conklin signed search warrant number which authorized a search of the email accounts and On August 12, 2016, I received the results of the search warrant from Yahooi. ?In December .2016, I completed a review of these results.' I I 56. I noted a message from ?purefirameds420@yahoo.com" sent to September 23, 2013. The message stated, ?Hello please reply to the message I sent you on sr. thanks.? I know from experience that ?sr? is'a common abbreviation for Silk, Road. I believe FARBER was_communicating with Jay Best in this. 'email, 57. I observed approximately 88 emails that were almost entirely between ?purefiremeds4200yahoo,com? and either best@mit.edu or jaycortex@gmail.com.. The name associated .25 case Document 11 Filed-08/09/17 Page 29 of'75 with the email account jaycortengmail.com is Jay BEST.7 As- such, I believe this was also BEST's email account. The emails .between EARBER and Best started on September 23, 2013, and ended. an April 24, 2014. 58. I also reviewed emails from I reviewed hundreds of emails pertaining to the trading of bitcoin for cash. The following is a typical email correspondence_between EARBER and a bitcoin trader known as a. 5/10/2016-? BITCOINMAVEN writes, QHey. Will you have coins today? Let me know. Thanks.?- b. .Later in the day, writes, ?Yes I have 195 ready now. Let me know I can send them over right away but I won?t be able to pick-Up the cash until later this afternoon like at 6. 30 pm is that ok? Thanks? I c. BITCOINMAVEN responded, ?_Did you get my email? Yahoo has been slow today!!Yes I can hand you cash later on this afternoon like 6:30. Please send coins as soon as you can. I really need them..Thanks!! I Bitstamp at 453.02 6 is 425.83195 is $83,037. 59. Based on my training and experience, I am aware of the following. Toward the end of the email referenced above, 7 According to TFO Gabbay, that jaycortex@gmail. com was Best' 5 primary means of communication. In addition, TFO Gabbay indicated that the email account best@mit. edu contained 6,169 individual email messages related to Best's program at the Massachusetts Institute of Technology, which confirmed that this account belonged to Best. 26 'Case-1217-mj-00124-EPG Document 11 Filed 08/09/17 Page 30 of 75 BITCOINMAVEN lists the ?ticket,? which is the agreed?upon priCe that pay for bitcoin, which in this case, ?Bitstamp at 453.02 6 . . . indicates that BITCOINMAVEN will pay $453.02 for eaCh bitcoin at the Bitstamp price minus six percent for he/her services.- [Bitstamp is a3 digital currency exchange company based in Luxembourg.] The total price he/she will pay for 195 bitcoin is $83,037 in cash. The last line in the email exchange above is the bitcoin wallet -address to which EARBER sends the bitcoin for the transaction. 60. I reviewed emails containing bitcoin trade information, between EARBER and others, and I was able to verify on the Blockchain each trade using the wallet addresses and date of the trades. Based on my review, I noted that EARBER conducted approximately 188 confirmed trades. ?And out of these trades, I was able to determine that EARBER received approximately - $7,018,379 from February 2014 through July 2016 from various traders, many of whom are unregistered, The large amount of bitcoin that EARBER is offloading.throughl various unregulated traders indicates that he is regularly receiving large amountsof bitcoin.and may not want to be subject to any reports that the bitcoin exchanger would file if ?registered. As noted above, narcotics vendors on the darkweb are paid in bitcoin and other digital currencies. Accordingly, the large amount of bitcoin EARBER is caShing ont,.and uSe of unregistered exchangers, corroborates other evidence indicating that he is a dark web narcotics trafficker. '27 4 Case Document 11 Filed 08/09/17 Page 31 of 75 H. EARBER's Tax Return Information 61. ?In January 2017, I reviewed the federal and California state tax returns of EARBER and his business partner, George Khoury. The following is a summary of the review: a. EARBER filed no tax returns in 2014 and 2015. b. EARBER filed a Partnership Return of Income for 2011 that includes the following information: i. ii. 91016 I iv. vi. vii. .Ride Shop. Name: Ruka Ride Shop DBA Stix Ride Shop Address: 421 Ave, Mbnrovia, CA Gross Receipts: $135,058.00- Gross Profit: $83,173:00' Total Deductions; $96,531.00' Income Loss: $13,358.00 EARBER received 50% of the profit from Stix c. personal federal and California state tax return for 2012 includes the following_information; i. ii.? 91016 iv. vi. vii. Media): $15,470.00 Name: William J. EARBER Address: '421 3 Ave, Monrovia, CA Social Security Number:. CA adjusted income: $2,028 00 Total federal Aggregate Gross Receipts: $160,696.00 Net earnings from self?employment (Spanky?s 28 Case Document 11 Filed 08/09/17 Page 32 of 75 Net earnings from self-Employment (Ruka Ride Shop DBA) $887.00 I d. EARBER filed a PartnerShip Return of Income for 2012 that includes the following infor?ation: i. . Nade: Ruka Ride Shop DBA Stix Ride Shop ii; Address: 421 Ave, Monrovia, CA 91016 Gross Receiptsz' $220,361.00 iv. Gross Profit: $77,515.00 iv. Total Deductions: $75,740.00 'vi. Total Incohe: $1,775 plvii.rFARBER received 50% of the profit from Stix Ride Shop. I - filed a Partnership Return of Income for 2013 that includes the following-information: Name: Ruka Ride Shop DBA Stix Ride shop, ii. Address: 421 Ave, Monrovia, CA 91016 - Gross Receipts: $310,471.00 iv; GroSs Profit: $69,406.00 v. Total Deductions: $96,588.00 'vi. ,Total Income: vii. FARBER received 50% of the profit from Stix Ride Shop. A. I I 62.. taereturns indicate that he was not reporting the bitcoin.income he was generating in 2014 or 2015, 29? Case Document 11 Filed 08/09/17 Page 33 of 75 . as described above. The returns also show that he_is the co- owner of Stix Ride Shop. I. Link between ?Purefiremeds? 63. On September 30, 2016, I observed a ?vendor question". on the website Reddit.com pertaining to the darkweb narcotics vendor The-following is'a summary of the information: I a. Approximately one year ago, ?NavajoHills? submitted a vendor question on the ?AgMarketplace? discussion board on Reddit. The question stated, ?Anybody ever order pot from He?s probably scamming [sic] out of $250.? b. A moderator on the discussion board stated the following in response to the question: ?There have been sporadic reports on /r/darknetmarkets to stay away from. some saying that he might be the vendor PUREFIREMEDS. 'Of course, no can verify that with certainty, but Ianywaym? 64. I noted there was a narcotics vendor on the darkweb marketplace AlphaBay named HUMBOLDTEARMS that had been on the market since March 25, 2015, with total number of finalized Sales transactions above 78,000.. I J. -Undercover Purchase from HUMBOLDTEARMS 65. On February 23, 2017, at approximately 1:22 pm, Fresno- Police Detective Daniel Vandersluis and I ordered ?7g Cali Orange Krush Grade Weed? from HUMBOLDTFARMS on Alphabay for delivery to Fresno.? The price for the order was $40.00 plus $7.00 for USPS priority shipping. The order number is 29955 and .30 Case Document 11 Filed 08/09/17 Page 34 of75 the sale number is 7975342.? The order was subsequently placed into the ?processing? mode. I 66. On February 24, 2017, the order was labeled as I?shipped.? 67. On March 3, 2017, United States Postal Inspector' Jessica Burger informed me that a parcel had arrived for purposes of distribution into Fresno. I responded to her office land took possession of-the-parcel. 68. I observed that the package?s return address is ?Touch of Class," 203 Kenwood St, Burbank, CA 91505, which appears to be a non?existent address. I observed a.malar type outer- packaging and subsequently three additional vacuum sealed bags that contained one small sandwich bag containing a leafy green substance which field tested positive for marijuana and weighed approximately 8 grams.? K. Surveillance-of Mailings Connected to HUMBOLDTEARMS 69. In March 2017, I prOvided pictures of the underCover parcel that arrived in response to the order from HUMBOLDTEAEMS on AlphaBay that contained marijuana to United States_Postal Inspector Lyndon_Versoza (InSpector Versoza). Inspector Versoza obServed that the parcel was mailed using USES small priority flat?rate box with the USPS Priority Lili'uoxalani Gardens (?Gardens?) postage stamp and a non-machine scanable eastern tailed-blue butterfly (?Butterfly?) postage stamp on it, as opposed to digitally printed stamps usually used by businesses. for'the mailing of priority packages. Inspector Versoza also noted that affixed to the parcel was a USPS tracking label, .31 Case Document 11 Filed 08/09/17 Page 35 of 75 known as label 400? and that the address labels were-- computer printed. Based on Inspectbr Versoza's review of USPS records, the parcel entered the U.S. mail at_the Verdugo Viejo Post Office in Glendale, CA (the ?Verdugo Viejo Post Inspector Versoza indicated that flat?rate priority boxes are usually not mailed using stamps and USPS 400 labels. Rather, the more common method of postage consists of digitally printed stamps that contain tracking numbers and machine scanable codes. 70. Inspector Versoza believed that USPS employees would qUickly recognize when they received_large numbers of packages bearing these unique stamps. In March 2017, Inspector Versoia visited the Verdugo Viejo Post OffiCe and requested postal employees notify him if anyone mailed'more parcels with packaging and stamps like those on the undercover parcel.? _71, On March 10, 2017, a USPS employee informed Inspector Versoza that an individual dropped ofanUmerous packages at the back dock of the Verdugo Viejo PoSt Office,. The USPS employee said that packages matched the characteristics of the undercover parcel. Inspector Versoza visited the Verdugo Viejo Post Office and examined the packages; there were approximately 221 addressed to different addresses around the United States. They: bore the same USPS priority flat-rate paCkaging, the same kind of tracking label, and the same kind of stamps as the parcel purchased undercover, described above. .The return address on these packages was ?Modern House Art,_l619 La Brea Ave, Los Angeles, CA 90028?. 32 Case Document 11 Filed 08/09/17 Page 36 of 75 72.. Inspector Versoza checked the address and learned that the building located at 1619 N. La Brea Ave, Los Angeles, CA 90028, is?a large complex, which means the address printed on the label was incomplete as it was missing a unit number. Based- on his training and experience, Inspector Versoza conveyed that ?when senders provide incomplete addresses, it is to prevent tracing of the sender (or a fictitious address) and may indicate that the parcels contain contraband. Inspector Versoza also' reviewed surveillance video from the Verdugo Viejo Post Office and observed a heavy?set Hispanic male in his 203 Or early 305 mailing the suspicious parcels. 73. On March 22, 2017, a USPS employee again informed Inspector Versoza that an unknown person left the same type of suspicious packages at the Verdugo Viejo Post Office. ,Inspector Versoza visited the Verdugo Viejo Post Office and saw four mail sacks_containing what he estimated as containing between 1004200 priority flat-rate parcels bearing the same packaging, tracking label, and stamps as the parcel purchased by undercover. Inspector Versta noted the return address for all of these- packages was ?Jewelry Hills, 4143 Toland Way, Los Angeles, CA 90041?. Inspector versoza checked the address and learned that the building located at 4143 Toland Way, Los Angeles, CA 90041, is a large complex, which_means the address printed on the label was again incomplete as it was missing a unit number. The building also did not appear to be a commercial building that, could accommodate a jewelry store. 33' Case Document 11 Filed 08/09/17 Page 37 of 75 74. _Inspector Verso;a reviewed surveillance video from March 22, 2017, and determined that the mailer was the same unknown Hispanic male as referenced above and that he wasr driving a four-door black Audi A4 with paper license plates that. included the logo of ?Delux Motors." 75. ?On March 23, 2017, along with other postal inspectors,? Inspector Versoza conducted surveillance at the Verdugo Viejo Post OffiCe. At around 2:00 pm, Inspector Versoza saw the same black Audi arrive at the back dock area of the Verdugo Viejo' Post Office. When the_driver exited his vehicle, Inspector Versoza recognized the same unknown Hispanic male. Inspector Versoza observed him leave several mail sacks, eaCh containing dozens of packages. I 76. After the unknown Hispanic male departed the post, office, Inspector Versoza requested assistance from the Glendale Police, who was aware of the ongoing surveillance. Glendale _Police Officer Ralph Garcia pulled over the vehicle (the unknown Hispanic male was driving the same black Audi) for having no license plates and tinted windows. According to Officer Garcia, the driver did not have a valid driver-license but identified himself as PALMA.- OffiCer Garcia issued a citation to ?Michael Angelo (DOB 10/05/1994, CA F4787549) for driving without a license and released him. RALMA 'provided his phone number as 323?516-9948. The vehicle license plate is 6PGB302 (Registered owner: Michael PALMA, 548 108th ?St, Los Angeles, CA 90044). 34 Case Document-11 Filed 08/09/17 Page 38 of 757 77. Inspector Versoza later examined the sacks of mail left by PALMA at the-back dock of the Verdugo Viejo Post Office; on March 23, 2017. There were four mail sacks, containing between 1004200 priority flat-rate mail parcels. Inspector Versoza randomly selected two packages, one bearing label number 9114 9014 9645 0743 5555 92 921), and one bearing label number 9114 9011 5981 5844 4556 84 (the I 78. Both of these parcels bore the same kind of stamps and. tracking labelsas the package purChased by me, undercover, described above. IThese packages also had the same printed return address of ?Jewelry Hills 4143 Toland Way, Los Angeles, CA 90041.? InSpector Versoza seized PARCEL 94_and PARCEL 84 for ?further investigationMarch 23, 2017, Inspector Versoza witnessed Los Angeles Police Officer Patrick Foreman and his trained drug?- detection dog, ?Jess,? examine the exterior of PARCEL 84 and PARCEL 92. Officer Poreman stated that Jess positively alerted to both packages, indicating the presence of drugs or other items such as the proceeds from the sale of drugs, recently contaminated by or associated with the odor of drugs. 80. On March 29, 2017, Inspector Versoza obtained a7? federal search in the Central District of California for PARCEL 84 and PARCEL 92. He executed the search? warrant and found two vacuumed sealed packages weighing - _approximately 500 mg each. One parcel contained chocolate chip cookies and the other contained brownies. Both products contained substances believed to be marijuana. 35 Case Document 11 Filed 08/09/17 Page-39 of 75 81. .I observed a Facebook page for VMichael Palma? from Los Angeles, California, and noted that it appeared to be the 'same RAEMA that was cited by Glendale Police. _The Facebook page had a list of friends for PALMA, which included Bryan LEMDNS and Darren Blatt, who are both Facebook friends with William EARBER. As previously mentioned at paragraph 33, LEMONS picked up approkimately $100,000.in cash from the CI on behalf in February 2015. This social media connection between EALMA and close associates of EARBER indicated to me that EARBER was a member of the HUMBOLDTEARMS DTO that included selling narcotics under the moniker ?Humboldtfarms? on the darkweb. 82. In summary, based on the surveillances described above, Inspector Versoza informed me that PALMA conducted the following actions that I believe were in support of HUMBOLDTFARMS-DTO: . March 10, 2017, PALMA delivered 221 parcels to. the Verdugo Viejo Post 0ffice._' . March 22, 2017, PALMA delivered four large sacks of parcels to the Verdugo Viejo Post Office. I March 23, 2017, PALMA delivered four large sacks of parcels to the Verdugo Viejo Post Office (witnessed by Inspector Versoza). . Id. March 31, 2017, PALMA delivered four large sacks of parcels to the Verdugo Viejo Post Office; April 6, 2017, PALMA delivered four large sacks ?of parcels to the Verdugo Viejo-Post Office (witnessed by LAPD). 36 - Case DocUment 11 Filed 08/09/17 Page 40 of 75 f. April 14, 2017, PALMA delivered four large sacks -of parcels to the Verdugo Viejo Post Office, - g. 'May 5, 2017, PALMA delivered five large sacks of 'parcels to the Verdugo Viejo Post Office. Case Document 11 Filed 08/09/17 Page 47 of 75 N. Annie Jagler?s involvement in the HUMBOLDTFARMS DTO 95. As described above, on March-3, an undercover parcel from the darknet narcotics vendor HUMBOLDTFARMS on AlphaBay. I provided pictures of the parcel to inspector VersoZa who observed that affixed to the parcel was a Lili'uokalani ?Gardens? Priority Mail postage stamp and the _?Butterfly? postage stamp on it. Inspector Versoza noted'thatr was an unusual method of mailing priority parcels because priority stamps are generally mailed using electronic postage. _Inspector Versoza searched USPS records and determined that an unknown person or persons were purchasing large amounts of theSe types of postage stamps at one time. Payments for these postages stampswere done in cash.? Specifically, Inspector' Versoza noted that on Feerary 9, 2017, an unknown person purchased $1,600.00 worth of ?Gardens? and ?Butterfly? postage, at the Verdugo Viejo Post Office. On February 10, an unknown person purchased $2,533.00 worth of ?Gardens" and ?Butterfly? postage at the Burbank Post Office in Burbank, California.- Further, on March 1, 2017, an unknown person purchased $2,940.00 'worth of ?Gardens? and ?Butterfly? postage stamps at the 3 Glendale Main Post Office in Glendale, CA. 96. On March 31, 2017, Inspector Versoza received a message from an employee at the Verdugo Post Office located at 44 Case Document 11 Filed 08/09/17 Page 48 of 75 101 North Verdugo Road, Glendale, CA 91206, that an unknown~ female was buying the distinct ?Gardens? and ?Butterfly? postage, stamps. The employee stated the unknown female departed in a vehicle bearing California license plate number 7JTF675 (Registered Owner: Annie Jagler, 7119 West SunsetBoulevard, Unit 905, Los Angeles, CA 90046) and described as a white Chevrolet Impala, Inspector Versoza stated the female purchased approximately $2,600 worth of ?Gardens? and ?Butterfly? stampsr 97. On April 1, 2017, Inspector Versoza obtained surveillance camera footage from the Verdugo Post Office and noted the person seen in the footage resembled the Facebook profile of ?Anne Jagler.? Inspector Versoza noted that Jagler was also friend on Facebook.' LAPD Detective Sharon Kim discovered an Instagram photo on Jagler?s publicly available account that also included FARBER. has also posted photos on Instagram indicating that he is friends with Jagler; Jagler's-California license number is Y2710901 and the addreSS' listed is 7119 West Sunset Boulevard, Unit 905, Los Angeles, CA 90046, which is also the same address listed on the registration of the white Chevrolet Impala; The photo on her driver?s license appeared to depict the same female buying.the ?Gardens? and ?Butterfly? postage stamps. I believe Jagler'was purchasing priority postage stamps on behalf of FARBER and HUMBOLDTEARMS. 45 Case Document 11 Filed 08/09/17 Page 49 of 75 The GABRIELINO RESIDENCE is identified as a location of marijuana distribution 98. -On March 29, 2017, Inspector Versoza obtained a vehicle tracker_search warrant for black Audi sedan bearing California license plate number 6268302. 99. ?On April 5, 2017, at approximately 5:00 am, Inspector Versoza installed the GPS tracker to Audi sedan at 1324 I .West 9lst Street, Los Angeles, CA 90044. 100. On April 5, 2017, at approximately 10:00 am, Inspector? Versoza noted that vehicle traveled directly_from his residence at 1324 West 915t Street, Los Angeles, CA 90044, to 805 _West Gabrielino Ct, Altadena 91001 (described above as the_ The LAPD Major Enforcement SectiOn Parcel Squad initiated surveillance on PALMA at the RESIDENCE, which is a two-story singleefamily residence located within the gated community ?La Vina.? Guests are required to check in with security located at the entrance.of the community.y 101. At approximately 10:20 am, LAPD observed a Honda ?Accord at the GABRIELINO RESIDENCE bearing California license plate 6EAW893 (Registered Owner: Michele PICKERELL, 805 W. Gabrielino Ct,_Altadena, CA 91001). LAPD noted that'PALMA's vehicle was not visible outside of the At approximately 11:30 am, LARD observed vehicle exiting the garage at the GABRIELINO RESIDENCE, which now had its. vehicle license plates visible (6PGB3021. .At approximately 11:46 am, EALMA arrived at a Chickefil-A drive-thru and then drove back to the GABRIELINO RESIDENCE. 46 CaSe Document 11 Filed 08/09/17 Page 50 of 75 I- 102. I Checked public-records for the GABRIELINO RESIDENCE and noted a record from February 2016 pertaining to person named (Camilla Kapustina. I also observed that EARBER is Facebook friends with a female named Camilla Kapustina. -103. During the surveillance, LAPD observed a gray MerCedes 'in front of the GABRIELIND RESIDENCE bearing California license plate number 7DTB386 (Registered Owner: Carolina Edlin, 1045 West 104 Street, Los Angeles, CA 90044). 104. LAPD Det. Kim discovered a Facebook profile for a male ,named ?Anthony Fiacco" (later identified as Anthony Edlin) who is Facebook friends with PALMA. Det. Kim noted that Edlin ?posted a photo of himself on his Facebook account in front of a similar gray Mercedes that appeared to be parked in front of the RESIDENCE.. I i 105. On April 6, 2017, LAPD Det. Kim made contact with a security guard for the communitythat includes the GABRIELINO The security guard stated there are approximately .four or five vehicles that regularly visit the GABRIELINO RESIDENCE, including PALMA, who drives a black Audi, a male known as ?Sebastian Gates" (later identified as Richard who drives a black BMW, a male known as ?Tony 'Viacco,7 (identified as Anthony Edlin) who drives a gray Mercedes, and ?Hector Contrasf (later identified as Jose Palma), -who drives a white Mini Cooper. Det. Kim showed pictures of -EALMA, MARTINSEN, Anthony Edlin, and Jose Palma, to the security guard who visually identified them. The security guard stated Edlin?s phone number was Subscriber information 47 Case Document 11 Filed 08/09/17 Page 51 of 75 for this phone number indicates the account was in the name of Carolina Edlin, 1045 west 104U?Street, LOS Angeles, CA 90044. 106. The security guard stated that the owner of the RESIDENCE is Michele PICKEREEL (phone number is 626?- 379?7185) and thathhe lives alone. has two children, and is in college and is rarely home. I 'primarily stays with his father, who is divorced from PICKERELL. The security guard stated that PICKERELL has a history of causing problems within the community and used to have large parties that angered her neighbors. The security guard also stated that refers to the group of males that regularly come to her house as her ?boys.? 107. Also on April-6, 2017, LAPD established surveillancer positions at the GABRIELINC RESIDENCE. At approximately 11:13 am, LAPD obserVed PALMA depart the GABRIELINO RESIDENCE in his black Audi. At approximately 11:20 am, LAPD observed EALMA Iarrive at the Post Office located at 600 Lincoln Avenue, Pasadena, CA 91109, and unload parcels from his vehicle. At. approximately 11:20 am, LAPD Det. Kim confirmed with USPS employees that PAEMA dropped off four sacks of parcels that had the ?Gardens? and ?Butterfly? priority postage stamps affixed to them. A USPS employee stated that an additional white male in a black Mercedes drop of large sacks of parCels several times a week. LAPD followed PALMA back to the GABRIELINO RESIDENCE. . 108. on April 6, 2017, LAPD noted the presence.of a white Mini Cooper at the GABRIELINO RESIDENCE bearing California 48 Case Document 11 Filed 08/09/17 Page 52 of 75 license plate number 7VKK239 (Registered Owner: Jose Palma, 631 8 West 120 Street, Los Angeles, CA 90044)?. Jose Palma appears to be Michael brother. 109. On April 6, 2017, at approximately 2:20 pm, LAPD observed vehicle depart the GABRIELINO RESIDENCE and drive to the Post Office located at 7435 North Figueroa Street, Los Angeles, CA 90041. picked up USPS trays and departed Ithe location. At approximately 2:50 pm, the_GPS tracker I indicated PALMA returned to the ?110. On April 12, 2017, Det. Kim found a picture on Facebook from 2015 that inCluded PICKERELL in a photo with three other women wearing a Stix Ride Shop hat (as noted above, Stix Ride Shop is a skateboarding business owned by FARBER). EARBER '?liked? this photo on Facebook. .111. On April 18, 2017, Inspector Versoza noted that according to the GPS tracker, black Audi traveled from the GABRIELINO RESIDENCE to the Highland Park, Eagle Rock, and. Glendale main Post Offices. -'112. On May 17, 2017, the security guard at the GABRIELINO RESIDENCE informed Det. Kim that PICKERELL had told him, the Isecurity guard, that her ?boys? were no longer coding by her home_and that she was planning to sell it. 113. on May 22, 2017, the security guard at the GABRIELINO RESIDENCE texted Inspector Versoza and said she saw EAEMA arrive at the GABRIELINO RESIDENCE. This is the last-time any of the -suspects associated with HUMBOLDTFARMS were seen at the 49' Case Document 11 Filed 08/09/17 Page 53 of 75 114. On July 18, 2017, Det; Kim stated-the security guard at the GABRIELINO RESIDENCE informed her that PICKERELL was 'Vstill living there.. P. Richard MARTINSEN is identified as mailing parcels for the HUMBOLDTEARMS DTO . 115. On March 14, 2017, a USPS employee alerted Inspector- Versoza that an unknown male dropped off numerous packages at the back dock of the Verdugo Viejo Post Office located at 101 North Verdugo Road, Glendale, CA 91206. The USPS employee said that packages had ?Gardens? and ?Butterfly? priority postage stamps on them. I 116. On_March 15, 2017, LAPD Det. Kim and Inspector Versoza went to the Verdugo Viejo Post Office and reviewed video from the previous day. From this review, Inspector Versoza_saw a tall, slender, white male estimated to be in his twenties or thirties, drop off four mail sacks containing parcels. The .suspect was driving a late model, black, two?door BMW With paper . plates that say ?Pacific (the LAPD later I identified Richard Thomas MARIINSEN as the driver of the BMW. 117. On March 15,.2017, a USPS employee again nOtified Inspectdr Versora that someone left the same type of suspicious parcels at the Verdugo Viejo Post Office. Det. Kim responded to the Post Office and saw four mail sacks containing what she estimated to as between 1007200 priority flat?rate parcels bearing the same packaging, USPS 400 labels, and ?Gardens? and ?Butterfly? stamps, as previous parcels involvedin this investigation. Inspector Versoza examined photos Det. Kim took 50- Case 7 Document 11 Filed 08/09/17 Page 54 of 75 of the parcels and saw that.the'return address was ?Modern House Art 1619 N. La Brea Ave, Los Angeles, CA 90028.? Inspector Versoza later checked the addreSs on a mapping website and a Ilearned that the building located at 1619 N. La Brea Ave, Los Angeles, CA 90028, is a large residential complex, which means the address printed on the label was incomplete, as it was missing a unit number. Although the building was residential, there appeared to be a few businesses at the ground level of the ,building. Inspector Versoza did not find any businesses named ?Modern Art House.? Inspector-Versoza also conducted an online search for ?Modern House Art? and did not find the business associated with the 1619 N. La Brea Ave address.? Inspector Versoza reviewed surveillance video and noted that MARTINSEN delivered these parcels to the Post Office. 118. On April 5, 2017, a USPS employee again notified Inspector Versoza that an individual dropped off four sacks of parcels at the Verdugo Viejo Post Office. The employee sent Inspector Versoza images of the parcels left by the suspect. From the photos, Inspector Versoza recognized the characteristics and that these packages met the profile of the. packages in this investigation. The USPS employee told' Inspector Versoza that it appeared to be MARTINSEN, again driving the BMW, who dropped off the parcels. The USPS employee said that MARTINSEN asked for boxes and the employee provided him 60 flat rate priority boxes. said that he wanted' more boxes because he ships out approximately 1000 packages per week. Inspector VersoZa also observed from the photos sent by 51 Case Document 11 Filed 08/09/17 Page 55 of 75 the USPS employee that the return addresSes on_the packages was ?FantaStic Studio 505 Adams St., Glendale, CA 91206.? inspector Versoza verified the address onVa mapping website and learned that the building located at 505 Adams St., Glendale, CA 91206, is-a large residential complex, which means the addreSs printed on the label was incomplete as it was missing a unit number. This building does not appear to house any -business or commercial units. 119. Inspector Versoza reviewed video from this.mailing and 4f observed the parcels and driving the black_ BMW. - I I _120. On April 12, 2017, the LAPD Major Enforcement Section Parcel Squad established surveillance positions around the GABRIELINO RESIDENCE. -121. At approximately 3:10 pm, LAPD observed a black two door new model BMW with.gray ?Pacific paper plates arrive at the GABRIELINO RESIDENCE. The driver used a garage door remote to access the garage and drive in. At approximately 4:10 .pm, LAPD observed the black BMW depart the GABRIELINO RESIDENCE. LAPD followed the vehicle and requested a Los Angeles Sherriff?s Department (LASD) Deputy conduct a traffic stop on the vehicle. The traffic stop was executed by LASD and the driver was iSsued a citation for front tinted windows. The LASD Deputy recorded thefollowing information on the driver.and vehicle: a. Richard Thomas MAREINSEN b. 11023 Fruitland Dr. #104 Studio City, CA 91604 52 Case Document 11 Filed 08/09/17 Page 56 of 75 d. Phone: (541) 499?8393 e. CA Driver?s License F3404643 . f. 2015 BMW 235i, black coupe, CA license plate 7NEH444 (Registered Cwner:.Richard MARTINSEN, 6732 West Hepburn Way, Los Angeles, CA 90038.) .122. The LASD Deputy stated to LAPD that he saw backseat filled with bulky items but that they were covered with fabric. I believe these bulky items were parcels that contained? marijuana that MARTINSEN was transporting to be mailed, as I detailed below. - A . 123.After the vehicle stop, LAPD followed MARTINSEN to the Post Office located at 101 North Verdugo Road, Glendale,-CA 91208, and observed him drop off four sacks of parcels at the .back dock. Det. Kim later.examined the sacks of mail he left at the back dock. There were four mail sacks, containing between 100-200 priority flat?rate mail parcels. .Det. Kim randomly selected two packages 63? and Both of these parcels have the same kind of stamps and tracking labels seen in other parcels. These packages had the printed_return address of ?Printastic Studio, 505 Adams St., Glendale,-CA 91206?, which is a.different buSiness name but the same address 'as the prior mailing. Det. Kim took possession of PARCEL 63 andl PARCEL 38 for further investigation. 124. At approximately 5:30 pm, LAPD was contacted by a USPS temployee at the Pasadena main Post Office-located at 600 Lincoln Avenue, Pasadena, CA 91109, that MARTINSEN dropped off another four sacks of parcels at the back dock.k 53 Case Document 11 Filed 08/09/17 Page 57 of 75 125. On April 12, 2017, Inspector Versoza found a Facebook post from March 29, 2017, on account indicating he was traveling with EARBER from Miami, FlOrida, to Los Angeles, California. - - 126. On April 14,2017, Postal InSpector Noah Thompson informed Inspector Versoza that on April 13, 2017, he observed, LAPD Officer Vanessa Keortge and her trained drug?detection dog, ?Cobra,? examine the exterior of PARCEL 63 and PARCEL 38. I Officer Keortge told Inspector Thompson that Cobra positively alerted to both packages, indicating the presence of drugs or other items such as the proceeds from the sale of drugs, recently contaminated by or associated with the odor of drugs. 127. On April 19, 2017, Inspector Versoza obtained federal search warrant for PARCEL 63 38. 128. On April 19, 2017, Postal InspeCtor Joseph Weidenkopf and Inspector Versoza executed the search-warrant and opened PARCEL 63, which contained approximately 22_ grams of what appeared to be marijuana. The contents of PARCEL 63 were sealed and entered into evidence. 129. Postal Inspector Joseph Weidenkopf and Inspector 'Versoza also opened PARCEL 38, which Contained two packages of substance that appeared to be marijuana.' The first package weighed approximately 254 grams and the second package weighed 267 grams. Also inside PARCEL 38 were three packages of marijuana vape cartridges. I The first vape package weighed 356 gross grams, the second weighed 315 gross grams, and the third weighed 420 gross grams. A closer look at the vape cartridges 54' Case Document 11' ?Filed 08/09/17 Page 58 of 75 show that the products have been tested by Labs? and had an Instagram account, ?@justdabble?, associated with marijuana vape products. ?@justdabble? was imprinted on the packaging. \Ehe contents of PARCEL 38 were sealed and entered into evidence. 130. On April 19, 2017, InSpector VerSoza obtained a GPS tracker warrant for vehicle bearing CA license plate 7NEH444. . i I 131. On April 26, 2017, LAPD installed the GPS tracker-on- m'rmsm's vehicle, which was located at 11023 Fruitland Dr. #104, Studio City, CA 91604. 132. On April 26, 2017, Inspector Versoza noted that. black Audi traveled from the GABRIELINO RESIDENCE to residence at 11023 Fruitland Dr. #104, StUdio Cityr CA 91604.- 133. In summary, InSpector Versoza informed me that conducted the following actions that I believe were in- support of HUMBOLDTFARMS-DTO marijuana distribution operations: a. {'February 9, 2017, purchased $1,600 worth of the AGardens? and ?Butterfly? stamps at the Verdugo Viejo Post Office. I I - b. February-10, 2017,.purchased $2,533 worth of the ?Gardens? and ?Butterfly? stamps at the Burbank Post Office c. March 1, 2017, purchased $2,940 worth of the ?Gardens? and ?Butterfly? stamps at the Glendale Main Office March 10, 2017, purchased $2,500 worth of the' ?Gardens? and stamps at the Verdugo Viejo Post Office. 55 Case Document 11 Filed 08/09/17 Page 59 of 75 e. March 14, 2017, mailed four large sacks of parcels at the Verdugo Viejo Post Office I f. . March 15, 2017, mailed four large sacks of parcels at the Verdugo Viejo Post Office I April 5, 2017, mailed four large sacks of parcels at the Verdugo Viejo Post Office I 1h. April 7, 2017, mailed four large sacks of parcels at the Pasadena Main Post Office I I . i. April 12, 2017, mailed four large sacks of' parcels at the Pasadena Main Post Office April 12, 2017, mailed four large sacks of parcels at the Verdugo Viejo Post Office (witnessed by LAPD) 134. On May 1, 2017, Inspector Versoza observed on Facebook account that hewas traveling with EARBER to Las Vegas. On the same day, Inspector Versoza noted that according to GPS data, PALMA was at residence, located at 11023 Fruitland Dr, Studio City, CA 91604. i '135. It?s apparent to me that MARTINSEN was heavily involved with HUMBOLDTEARMS logistical operation. MARTINSEN used his own vehicle to transport hundreds of parcels a week to the numerous Post Offices and well as buying.stamps that I believe were used to mail the parcels. I I 136. On May 23, 2017, IRS Task Force Officer and Bakersfield folice Detective Paul Yoon provided me with the following information concerning MARTINSEN: 56 Document 11 Filed 08/09/17 Page 60 of 75? 0 I a. Financial records pertaining to reveal funnel account12 activities which took place between May, 2015 and April, 2016. EARIINSEN had opened his accounts at Wells. personal checking accounts #2272122504, a personal savings account #8791267423, and a business checking account.#2757752007. HEREINSEN is the sole owner of these accounts and is listed as an owner of an event promotion business named Martinsen Enterprises, LLC. I b. A number of things are notable about this pattern 'of cash deposits and cash withdrawals. Wells Fargo bank reported that the currency deposited into accounts had an odor of marijuana and that multiple cash deposits were conducted at branches located in California, Illinois, Nevada,' Florida, and Oregon by unknown subjects.- The cash deposits were then immediately followed by caSh withdrawals in or near Hollywood, CA. The cash deposits were often in amounts just under the Currency Transaction Report (CTR) filing threshold of $10,000, and conducted on or near consecutive days aggregating over the CTR filing threshold indicating intent to evade the CTR filing requirement. c. - Between May 22, 2015'and August 21, 2015, MARTINSEN conducted seven (7) cash withdrawals in amounts 'ranging from $1,468 to $9,600 totaling $50,768 after reCeiving 12 describes a funnel account as an individual or business account in one geographic area that receives multiple cash deposits, often in amounts below the cash reporting threshold, and from which the funds are withdrawn in a different geographic area with little time elapsing between the deposits and withdrawals. 57 Case Document 11 Filed 08/09/17 Page 61 of 75 .ten (10) cash deposits in amounts ranging from $1,500 to $9,800 Itotaling $54,431. Between October 5, 2015 and January 7, 2016, there were thirteen (13) cash withdrawals conducted by MARIINSEN in amounts ranging from $103 to $12,240 totaling $45,751 after receiving eleven (11) cash deposits in amounts ranging from $810 to $9,700 totaling $46,710. Furthermore, Wells Fargo bank I reported that On February 18, 2016,_a cash deposit of $9,800 was made at a branch in Altamonte, Florida which consisted of_$20 bills. The bank teller reported that the currency had an odor of marijuana emitting from it. The next day on February 19, 2016, MARTINSEN withdrew $8,300 from a branchin Studio City, _California. I i LEMDNS is associated with the marijuana company '?dabble? I 137. As noted aboVe, marijuana vape products with the name- ?Justdabble? were co?mingled with parcels sent on behalf of the HUMBOLDTFARMS DTO. I reviewed the Instagram account ?@justdabble,? and observed dozens of pictures of marijuana vape cartridges with the name on them and the company logo, which looked like the same as the one found in the parcels._ I _also noted pictures Of CHEEF NATURALS Bars (made by which I know to be a marijuana edible company that is associated with FARBER (see below for additional details on BIF ENTERPRISES and CHEEF NATURALSS. I 138. I reviewed the public1y_avai1ab1e Facebook account for LEMDNS and observed that on June.24, 2016, a person named Sarah. Erskine posted a pieture of a marijuana vape cartridge 758 Case Document 11 Filed 08/09/17 Page 62 of 75 and made the following comment (the cartridge looked like the same type of cartridge Instagram page): a. had no idea this was urs. I?ve been smoking dabble for a minute now. Love it.? b. I noted that MARTINSEN posted an emoji on the picture that indicated he liked it. I c. According to subscriber information from I phone, Bryan the account holder and the addreSs was 3883 Fredonia 9r, Apt D, Los Angeles,'CA 90068, ?139. On April 19, 2016, LEMDNS posted on his Instagram account an advertisement for the launch party of DABBLE, which also has a logo of CHEEF NATURALS and a logo fOr ?bLAcklist,? a company owned and/or Operated by MERIINSEN. In the post, LEMDNS states, ?Excited to launch my company tomorrow on 420)? 59 Case Document 11 Filed 08/09/17 Page 65 of 75 s. - Cell phone tolls for members of FARMS DTO 155. I reviewed toll records regarding common calls? between phone number and his associates' phones. I determined Verizon cell phone number was in his name as of April 20, 2017., The following is a summary of.the report: I a, EARBER had 107 communications with PICKERELL from March 13, 2017, through March 31, 2017'1 I b. EARBER had 63 communications-with MBRIINSEN from April 5, 2017, through May 1, 2017.' c. FARBER had 61 communications with LEMDNS from _March 19, 2017, through April 30, 2017. 62 Case Document 11 Filed 08/09/17 Page 66 of 75 d. . PICKERELL had 30 communications with Anthony Edlin from March 13,-2017, through April 28, 2017. Edlin had 170 communications with Michael EALMA from February 25, 2017, through May 4, 2017. 156. I believe the common communication between PALMA, PICKERELL, LEMDNS, MARTINSEN, EARBER, and others, indicate they know each and are conspiring to distribute marijuana via the dark web. T.- Information from GPS tracker 157. According to GPS tracker data from vehicle, (April 4? May 7, 2017), on April 11, 2017, EALMA went to_the~ GABRIELINO RESIDENCE, then to a Post Office, then back to the GABRIELINO RESIDENCE. PALMA then goes to MARTINSENKS residenCe located at 11023 Fruitland Drive, Studio City, CA 91604, and -stays in the area for approximately 22 minutes. After leaving residence, PALMA travels to LEMous} former residence, located at 3882 Fredonia Drive, Los Angeles, CA 90068, and stays in the area for approximately 31 minutes. Finally, back home to his residence. 158. According to the GPS tracker data, on April 20, 2017, PALMA spent over eight hours at the GABRIELINO RESIDENCE before going home. PALMA then went-to Gardena, CA, before coming back home. EALMA then traveledto residence, stayed in the area for_approximately 28 minutes, and then returned home.- 159. According to the GPS tracker data, on April 24, 2017, EALMA traveled to the GABRIELINO RESIDENCE in the mid-afternoon. PALMA then went to Gardena, CA, before arriving at Edlinrs 63 Case-1:17-mj-00124-EPG Document 11 Filed 08/09/17 Page 67 of 75 residence, located at 1045 West 104th St, Los Angeles, CA 90044. RALMA stayed in the area for approximately 11 minutes before going back home. .150. According to the GPS tracker data, on April 27, 2017,. left his residence and arrived at the GABRIELINO RESIDENCE in Ithe mid?morning. BALMA spent approximately eight hours at the GABRIELINO RESIDENCE before traveling to Reseda, CA. RAEMA then - arrived at residence in the evening. EALMA is in the area for approximately three hours.and 22 minutes before returning home. The next morning PALMA appears to go directly back to the GABRIELINO RESIDENCE. . 161. According to the GPS tracker data, on May 4, 2017, PAEMA departed his residence and went to the GABRIELINO RESIDENCE. PALMA then visited the Post Office, 5930 Figueroa St, Los Angeles, CA, and then went back to the GABRIELINO . RESIDENCE. PALMA then traveled to residence and stayed in the area for approximately 51 minutes. Subsequently, traveled to Edlin?s residence and stayed in the area for approximately 41 minutes before going home. 162. I observed numerous instances uhen RALMA arrived home for the evening and then the next morning traveled back to the GABRIELINQ RESIDENCE (sometimes with short stops to the gas station or clothing stores in between home and the GABRIELINORESIDENCE). This includes April 5-6, April 6?7, April 9?10, April 10~11, April 12, April 13?14, April 18, April .18?19, April 19?20, April_20e21, April 23-24, April 24e25, April 64 Case 1i17?amj-00124-EPG Document 11 Filed 08/09/17 Page 68 of_ 75 25?26, April 26-27, April 30 May 1, May 1~2, May 3, May 3-4, and May 4-5. I 1 I 163. In addition, the GPS data indicates EALMA spent time at MARTINSEN and residences on various occasions. U. EARBER operates a marijuana related business named BIF Enterprises LLC - A 164, I reviewed bank records that indicate EARBER is a part owner of Stir Ride Shop and has been a Customer of Wells Fargo since April 2011. EARBER is also a part owner BIF ENTERPRISES, ?a limited liability company doing business in Rancho Santa Fe, California, as a purported wholesaler of vegan products and has been a cuStomer of Wells Fargo since May 17, 2016. 165. Bank records indicate that BIF ENTERPRISES has, transactional activity with purported medical marijuana dispensaries, and a check deposited into BIF ?business checking account references the purchase of CHEEF NATURALS, which is a supplier of cannabis infused foods. 'Based on the transactional activity, it appears that BIF ENTERPRISES imay be selling CHEEF NATURALS products and other marijuana related products, and thus deriving its income from the sale of marijuana. Wells Fargo identified suspicious activity in solely owned personal checking account which was opened in Nevember 2013, and BIF solely owned business checking account which was opened' May 2016. A and an attorney named Ryan Mitchell are joint signers on BIF business checking account. 65 Case Document 11 Filed 08/09/17 Page 69 of 75 According to the State Bar of California, ?Ryan Seth Mitchell? is a licensed attorney in Rancho Santa Fe, California and is .associated with the Law Offices of Mitchell Heim LLP. Between June 28, 2016 and December 7, 2016, personal checking account #7337728948 and BIF business checking' account #7134666549 received a combined 29 cash deposits totaling $93,496 in amounts ranging from $690 to $6,170. The castheposits were conducted at branches in Coral Springs, FL, Culver City, CA, Glendale, CA, Los Angeles, CA, and Santa Ana, CA. I 167. Between July 14, 2016 and August 8, 2016, BIF checking account #7134666549 received athree check deposits totaling $1,649 in the amounts of $400, A $486, and $763. _The checks were deposited at branches in Culver City, CA and Los Angeles, CA and drawn on accounts held by Hitbox Solutions, which is a distributor of cannabis and cannabis related products for other vendors, and CA Alternative Caregivers, which is a medical marijuana dispensary business in Venice, California. The credits funded six debit card transactions totaling $3,032 that appear to have been uSed to supply and facilitate the operation of a medicalmarijuana dispensary. The debit card transactions were conducted between _August 15, 2016 and November 14, 2016 in amounts ranging from $3 to $1,500 with SC Laboratories, which is a marijuana?testing laboratory, CHEEF NATURALS, Edibles List, and iHerb, which are suppliers of marijuana and marijuana?related products. '66 'Case1217-mj-00124-EPG Documen?tll Filed 08/09/17 Page 70.0f 75 168. Between December 27, 2016 and March 10, 2017, personal checking account #7337728948 and BIF business checking account #7134666549 received a combined 11 cash deposits totaling $46,711 in amounts ranging from $2,170 to '36,440. The cash deposits were conducted at branches in the Los Angeles area. V. HUMBOLDTEARMS goes on vacation mode on AlphaBay 169. On May'll, 2017, I became aware that the vendor HUMBOLDHEARMS on Alphabay went into ?vacation mode.?1l3 The vendor stated they were behind on orders and needed time to catch up. . 170. On May 22, 2017, I became aware that HUMBOLDTEARMS was messaging other vendors on AlphaBay and offering to sell the vendor account_for the amount of $100,000 to $400,000. Further, it appears that HUMBOLDTEARMS has since then been banned by the AlphaBay marketplace and is no longer selling any products on that site. As noted above, AlphaBay was taken down by U.S. law enforcement on July 5, 2017 and is no longer in operation. 171. AlSo, on June 29, 2017, at approximately 10:00 am, HSI Special Agent (SA) Chris Hicks, while conducting surveillance at the VANALDEN WAREHOUSE, observed a silver Dodge_Challenger arrive at the location with paper dealer plates. Hicks identified the driver as MARIINSEN. Vacation mode.is utilized by vendors who do not'want to accept any new orders because they are away on vacation, out of product, or other miscellaneous reasons.? The can return to normal business operations at any time. 67 Case Document 11 Filed 08/09/17 Page-71 of 75 w. DREAM MARKET 172. On July 19, 2017, I reviewed the HUMBOLDTEARMS vendOr I aCcount on the dark web market Dream}4 I noted that the PGP key was the same as the vendor operating on Alphabay. I alSo-observed that the account had 8,200 finalized orders with a 4:93 rating out of 5. The account was listed as being on ?vacation" mode. - . I X. WAREHOUSE 173. On'April 26, 2017, and May 9, 2017, the vehicle tracker on vehicle indicated it was located at 8765 Vanalden Avenue,_Northridge, CA 91324 (described above as the 174. Det. Kim contacted the Department of Water and Power (DWP) regarding the utilities at the VANALDEN WAREHOUSE. DWP indicated that the bill has typically been approximately $3,500 to $4,000 per month. However, in the past several months, power consumption has increased. In April the bill was approximately $6,500 and the month before was $5,800. 175. On June 7, 2017, I spoke with David Sanchez, a DWP employee. He stated that the VANALDEN WAREHOUSE account is associated with Marlin Management, LLC. The account was opened in September 2015. In addition, name is on the account. Sanchez stated FABBER provided $15,000 in cash on May 31, 2017, to pay down the balance owed on the account. Based on Sanchez' experience,-he estimates-the VANALDEN WAREHOUSE has Like the Silk Road and AlphaBay, Dream Market is a darkweb marketplace that has been in operation since approximately November 2013. 68 Case Document 11 Filed 08/09/17 Page 72 of 75 approXimately 55 one-thousand?watt lights Operatinginside. The VANALDEN WAREHOUSE is using approximately 50-60 kilowatt hours of power per month. By comparison, Sanchez stated an average 'Costco building uses approximately 35?38 kilowatt hours of power per month.? I I 176. High electrical bills are associated with marijuana grows due to the amount of artificial sunlight that needs to be generated to grow marijuana plants. 177. The company Green Nation Cultivation states on its website that it ?collaborates with Marline Management and Investments, Specializing in MMJ [medical marijuana] properties, as our [Marline Management?s] sole real estate broker.?15 1 reviewed a public record on the California Secretary of State website pertaining to entity number 201522410368, Green Nation_ Cultivation, LLC. 'The record indicates the registration date is August 11, 2015, the Agent for Service of Process is Martin Eruchtman, and the address is 8725 Vanalden Avenue, Northridge, CA 91324 (the VANALDEN WAREHOUSE). Green Nation Cultivation?sA website which states that it invests in marijuana cultivation and also assists investors in establishing and managing medical marijuana Operations. 178. On May 31, 2017, LAPD conducted surveillance at the VANALDEN WAREHOUSE. Det. Kim observed EARBER arrive at the location as a passenger in a vehicle bearing California license plate number 7LLY594 (Registered owneri Ryan Mitchell, 27031 5 Located at Last viewed On July 25, 2017. . A 69 Docurnent 11 Filed 08/09/17 Page'73 of 75 Island Rd, ValenCia, CA 91355). As describing above, bank records pertaining to Bif Enterprises, LLC, Mitchell show that Mitchel employed as an attorney and is a joint signer on the account along with EARBER. 179. LAPD officers walkeanear the VANALDEN WAREHOUSE and detected the smell of marijuana coming from the building. 180. On June 28, 2017, agents obtained a picture of a dark covered Mini Cooper in the VANALDEN WAREHOUSE parking lot. The last four characters of the license plate (J435) are visible in the photograph. I know this to be Mini Cooper. 181. I believe that EARBER is using this grow house location to supply his marijuana related businesses and were used to supply, at least in part, the HUMBOLDTEARMS I Y. Blockchain analysis of bitcoin wallets 182. On June 2, 2017, I provided a list of all the bitcoin? wallet addresses I found in email account, to a contracted employee with the IRS who is trained to conduct bitcoin transactional analysis. He reviewed these addresses and found that from October 29, 2014, through May 27, 2017, approximately 20,000 bitcoin worth approximately $6.2 million came from suspicious sources, including directly from dark web markets Evolution (1,500 bitcoin), Agora (988 bitcoin), Nucleus (330 bitcoin), Abraxas (236 bitcoin),AlphaBay (139 bitcoin), and Middle Earth (166 bitcoin). I 183.ApprOXimately 11,360 bitcoin came from a dark web market to a private wallet, then through a bitcoin mixing 7O Case Document 11 Filed 08/09/17 Page 74 of 75' service,16 then back to another private wallet, and then to an unlicensed bitcoin exchanger?s wallet, such as the one held by the DEA CS. 184. Approximately 4,345 bitcoin came from a dark web market and then was moved through multiple private wallets either before or after going through a miwing service and then into an unlicensed bitcoin exchanger's wallet. 185. The data associated with these Bitcon wallet addresses indicates that handling Bitcoin traceable to numerous darkweb marketplaces. CONCLUSION 186. Based upon my training and experience, and on the facts set forth in this affidavit, I believe there is probable that defendants by Wiliiam EARBER, Michael PALMA, Richard MARTINSEN, Bryan muons, and Michele PICKERELL, have violated- Title 21, United States Code, Sections 846 and 841(a)(1) (Distribution of Controlled Substances and Conspiracy) and Title 18, United States Code, Sections 1956 1957 (Money Laundering and Conspiracy). I therefore request that the Court authorize the attached complaints and arrest warrants. Bitcoin ?mixing? refers to the process of using a third party service to break the connection between a bitcoin address sending coins and the address they are sent-to. 71 Case Document 11 Filed 08/09/17 Page 75 of 75 Approved as to Form: Grant B. Rabenn Grant B. Rabenn Assistant 0.8. Attorney_ Matthew LarSen Special Agent Homeland Security Investigations Subscribed to and sworn before me this gf-day of August, 2017 HON. ERICAWE. GROSJEAN UNITED STATES MAGISTRATE JUDGE 72