Case Document 1 Filed 02/28/18 Page 1 of 7 PagelD 1 UNITEDISMIBESIDIISTRICT COURT 9' We]: MAINE 3: FILED UNITED STATES OF AMEWFEB 78 2, 38 - Docket No. 211'? 9" . V1 DEPUTY CLEP 0? BRIAN J. BILODEAU CRIMINAL COMPLAINT I, Michael Gagnon, being duly sworn, state that the following is true and correct to the best of my knowledge and belief: mu (Possession of a Firearm in Furtherance of Drug Traf?cking) On about February 27, 2018, within the District of Maine, defendant BRIAN J. BILODEAU knowingly and intentionally possessed a Beretta, model BU9 Nano, 9mm pistol, bearing serial number 1403, in furtherance of a drug traf?cking crime for which he may be prosecuted in a court of the United States, namely the offense described in Count 2 of this Complaint. In violation of Title 18, United States Code, Section (Possession with Intent to Distribute Marijuana) On about February 27, 2018, within the District of Maine, defendant BRIAN J. BILODEAU knowingly and intentionally possessed with intent to distribute more than 50 kilograms of marijuana, in violation of Title 21, United States Code, Section 841(a)(1). Case Document 1 Filed 02/28/18 Page 2 of 7 PagelD 2 It is further alleged that the penalty provisions of Title 21, United States Code, Section 841(b)(l)(C) apply to the conduct described herein. This Complaint is based on those facts which are set forth in my af?davit of February Sit/?Gd? 2018, which is attached hereto and incorporated herein by reference. yr} ..- Michael fiagtion Special Agent U.S. Drug Enforcement Administration Sworn to before me and subscribed in my presence this 28th day of February, 2018. John H. Eich 111 US. ,agistrate Judge Case Document 1 Filed 02/28/18 Page 3 of 7 PagelD 3 UNITED STATES DISTRICT COURT DISTRICT OF MAINE UNITED STATES OF AMERICA Docket No. _2 I%o V. BRIAN J. BILODEAU AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT 1, Michael Gagnon, being ?rst duly sworn, hereby depose and state as follows: INTRODUCTION AND AGENT BACKGROUND l. I am a Special Agent with the Drug Enforcement Administration (DEA), United States Department of Justice, with federal law enforcement jurisdiction, and have been in this position since January 2012. I joined the DEA Portland Resident Of?ce in 2018. I was assigned to the Los Angeles Division from 2012 until I moved to Portland. Prior to attaining sworn status as a Special Agent, I was employed by DEA and received specialized training in narcotics traf?cking investigations and related legal matters at the DEA Training Academy in Quantico, Virginia. Before joining DEA, I was employed by the Newton Police Department in Newton, New Hampshire, from June 2009 to January 2012. During my employment with the Newton Police Department, I was a certi?ed Peace Of?cer in the State of New Hampshire. I have received law enforcement training through the Police Standards and Training Counsel. 2. In the course of my employment with DEA, I have received approximately 17 weeks of training at the DEA Academy in Quantico, Virginia about techniques used by major narcotics traf?ckers. I have specialized training involving the use, possession, packaging, manufacturing, sales, concealment, and transportation of various controlled substances, money Case Document 1 Filed 02/28/18 Page 4 of 7 PagelD 4 laundering techniques, and conspiracy investigations. Additionally, I have attended specialized training in wire and electronic interceptions and the use of wire and electronic interception equipment. 3. During my employment with DEA, I have participated in narcotics investigations both as a case agent and in a supportive role. I have participated in the arrests of multiple drug traf?ckers and in interviewing informants and suspects concerning the methods and means of drug traf?ckers. I have also participated in countless static and mobile surveillance activities and assisted in the execution of multiple search warrants and arrest warrants. I have conducted investigations regarding these unlawful activities, violations of Sections 841(a)(1), 843(b), 846, 952(a), and 963 of Title 21 of the United States Code, and Sections 2, 1952, 1956, and 1957 of Title 18 of the United States Code. As a DEA agent, I primarily investigate large?scale narcotics traf?ckers and money laundering organizations. 4. Based on my training and experience as a DEA Special Agent and Police Of?cer, I have become familiar with the criminal activities of individuals involved in drug traf?cking organizations, including drug manufacture and distribution, money laundering, and unlawful usefpossession of ?rearms. I have also become familiar with the methods used by such individuals to avoid detection by law enforcement, including the use of: multiple cellular telephones, including those subscribed to in the names of other persons; prepaid cellular telephones; counter-surveillance techniques; coded and ambiguous language; multiple vehicles; vehicles equipped with concealed compartments; and false identities. 5. The facts in this af?davit come from my personal observations, my training and experience, and information obtained from other agents and witnesses. Case Document 1 Filed 02/28/18 Page 5 of 7 PagelD 5 6. DEA and other law enforcement agencies are conducting an investigation into the unlawful distribution of marijuana and the unlawful manufacture of marijuana concentrates, commonly known as Butane Hash Oil, or ?Shatter? or ?Dabs.? The investigation targeted a drug traf?cking organization located in the Lewiston-Aubum area that is alleged to have grown and distributed large quantities of marijuana in violation of federal law, and under the cover of, but in violation of, Maine?s Medical Marijuana program. The organization cultivated marijuana at numerous warehouses in Androscoggin County and distributed marijuana to people who were not participants in Maine?s Medical Marijuana program, including out-of-state customers. This organization also grew marijuana as a precursor for the illegal manufacture of Butane Hash Oil. 7. On February 27, 2018, federal, state and local agents executed over 20 search warrants in the Lewiston-Auburn area associated with the organization. One location searched was Defendant Brian J. Bilodeau?s residence located at 72 Danville Corner Road, Auburn, Maine. 8. During execution of this search warrant, agents discovered a secure room in the basement. This room was approximately eight feet by ten feet in size, was constructed out of foundation concrete, and contained a metal vault door. Upon gaining access to this room, agents located and seized approximately 183 pounds (more than 50 kilograms) of a substance that a trained and experienced DEA agent on site told me is consistent in appearance with marijuana. 9. Also, within the secure room, agents discovered a large gun safe. Within this safe was a loaded Walther, Model PK 380, .380 caliber pistol, bearing serial number 060696. The safe also contained distributable quantities of suspected Butane Hash Oil. 10. In the master bedroom, agents located and seized a Beretta, model BU9 Nano, 9mm pistol, bearing serial number NU111403. This ?rearm was on top of the There Case Document 1 Filed 02/28/18 Page 6 of 7 PagelD 6 was a round in the chamber and additional rounds in the magazine. Agents also seized a Kimber, model Ultra II, .45 caliber pistol, bearing serial number KAU1188, from a case within the master bedroom. This ?rearm was not loaded. Bilodeau advised agents of the presence of the Beretta and acknowledged this was his bedroom. 11. In a second bedroom, agents located and seized a Mossberg, model 702 Plinkster, .22 caliber ri?e, bearing serial number EGB263043. This ?rearm was not loaded. 12. In the garage of this residence, agents located a blue 2016 Lamborghini Huracan (valued at approximately $190,000). According to a sales contract dated March 15, 2017, Bilodeau made a $95,500 cash down payment on this vehicle at a dealer in North Miami Beach, Florida. His payment on this vehicle is $2671.61. Agents also seized a black 2014 Nissan (valued at approximately $60,000). The Lamborghini and the Nissan were seized pursuant to seizure warrants issued by this Court on the basis that they were forfeitable as proceeds of drug traf?cking, facilitated drug traf?cking, or were involved in money laundering offenses. 13. Based upon my training and experience, I know that drug traf?ckers often possess and store ?rearms in their residences in order to protect themselves, their supplies of drugs, and/or drug proceeds. I believe based on the items seized from Bilodeau?s residence and the location of the loaded Beretta on the of the bed, that this weapon was in fact possessed in furtherance of Bilodeau?s drug traf?cking. 14. Based on my training and experience, I believe the quantities of suspected marijuana and marijuana concentrate seized are consistent with further distribution and inconsistent with personal use. Case Document 1 Filed 02/28/18 Page 7 of 7 PagelD 7 CONCLUSION 15. I respectfully submit, based on the facts set forth above, that probable cause exists to charge Brian J. Bilodeau by Criminal Complaint with the offenses of possession of a ?rearm in furtherance of a drug traf?cking offense, in violation of Title 18, United States Code, Section 924(c)(1)(A) (Count 1), and possession with intent to distribute marijuana, in violation of Title 21, United States Code, Section 84l(a)(l) (Count 2), and request that the accompanying Criminal Complaint be issued. Michael Gagno?? Special Agent U.S. Drug Enforcement Administration Sworn to before me and subscribed in my presence this 28th day of February, 2018.