Case 7:19-cr-00225 Document 1 Filed on 01/24/19 in TXSD Page 1 of 3 A0 91 (Rev. 11/11) Criminal Complaint - . . . em I I ctCourt UNITED STATES DISTRICT COURT 2019 Southern District of Texas 1 David J. Bradley. Clerk . United States of America I v. I Chelsea Nichole voe; 1989, use 3 Case My 3 I De?ndant?s) CRIMINAL COMPLAINT . I, the complainant in this case, state that the following is true to the best of my knowledge and belief. i . On or about the diate(s) of May 25, 2018 in the county Of Hidalgo in the Southern District of Texas the defendant(s) violated: Code Section . . Oj?nse Description Title 21 U.S.C. Section 841(3) Possession with the intent to distribute In excess of 28 5 kilograms of Title 21 U.S.C. Section 846 cocaine a Schedule ll Controlled Substance. I i Conspiracy to possess with the intent to distribute' In excess of 5 kilograms of cocaine a Schedule ll Controlled Substance. This criminal complaint is based on these facts: See Attachment A El Continued on the attached sheet. AUSA JL St? . I I UComplainant?s signature . - Special Agent Matthew deSaracho, DEA Printed name and title Sworn to before me and signed in my presence. bate: My 25/7 g/ 67/" City and State: Texas -. Peter E. Printed name and title Case 7:19-cr-00225 Document 1 Filed on 01/24/19 in TXSID Page 2 of 3_ ATTACHMENT A In April 2008, agents with the Drug Enforcement Administration (DEA) and the Texas Department of Public Safety. (DPS) initiated an investigation into a Drug Trafficking Organization (hereinafter referred to as the operating in the Rio Grande Valley of South Texas, Guadalajara, Mexico, Merida, Mexico, and other cities located' In the northern part of the United States. Said investigation has revealed that members ofthe including Chelsea MADILL, have operated and traveled through the SouthernDiStrict of Texas in furtherance of their drug trafficking activities. Based on the investigation, agents have determined that MADILL used. companies to coordinate the transportation of cocaine loads Concealed in cover loads from-the Southern District of Texas to other destinations In the United States. On or about May 25,2018, agents conducted surveillance at a warehouse, located at 1305 5 East Pecan Boulevard, warehouse units and Texas During surveillance, agents Observed a red Nissan sedan, with Missouri registration, registered to Hertz Car Rental in . McAllen, Texas. Agents contacted a source of information (hereinafter referred to as and learned that the red Nissan was currently rented to MADILL. Agents later observed MADILL exit the aforementioned warehouse and meet withthe driver of a tractor/trailer that had arrived at said location. Agents observed MADILL direct the driver of the tractor/trailer to back up to the . loading clock of warehouse After the tractor/trailer parked at the loading dock and while said trailer was loaded with a cover load, MADILL stayed with the driver just outside the tractor/trailer? 5 driver side door. Agents followed the tractor/trailer after it departed the warehouse. I I During a traffic stop, the driver-of the tractor/trailer consented to a search of the tractor/trailer. With the assistance of a DPS canine and a United States Customs and Border . Protection (CBP) x? ray scanning device, agents discovered twenty?two (22) vacuum sealed bundles of cocaine, Weighing approximately twenty-eight and a half (28.5) kilograms. After a post? ?arrest interview, the driver was released. Subsequent investigation and telephone to" records revealed that MADILL utilized a cellular telephone to communicate with other members ofthe DTO while she was in the McAllen, Texas area. Agents also?learned from another SOI that obtained the aforementioned warehouse in March 2018 to use for her company, MONSTERS INC. LOGISTICS. Subsequent I investigation also revealed that MADILL had obtained the coVer load used to conceal the cocaine, as evidenced by saveral bills of lading bearing company, MONSTERS INC. LOGISTICS as?; - the shipper, and an additional company owned by MADILL, TITANIUM WHOLESALE AND RETAIL, as the received in Lombard, Illinois. On the day the. seizure occurred telephone toll analySIs.._ . revealed that MADILL was in cOntIact with a Mexican telephone number utilized by. the leader of . the DTO, who agents have identified during the investigation. Telephone toll analysis also revealed that MADILL had contracted GPS- tracking services through Brickhouse Security, a New York based company that provides GPS tracking devices and Case 7:19-cr900225 Document 1 Filed on 01/24/19 in TXSD Page 3 of?3 services to customers. An administrative subpoena issued by agents to Brickhouse Security showed that purchased multiple GPS devices that were used to track the Cover load that was found to contain the cocaine seized on May 25, 2018, as?well as other cover loads that I are believed to have been utilized to transport narcotics and bulk United States currency. Following the seizure on or about May 31,2018, MADILL traveled to Merida, Yucatan, Mexico. DEA agents conducted surveillance on MADILL upon arrival in Merida, and observed MADILL meet with the leader of the DTO, who' IS based' In Mexico. On June 3, 2018', DEA agents conducted additional surveillance and observed MADILL board a flight in Merida, Mexico, and travel to'Atlanta, Georgia. Mexican?Federal authorities conducted an exit interview of and learned that MADILL had stayed with an unidentified friend at an unidentified location. Upon. entry into the United States via an international airport in Atlanta, Georgia, CBP inspectors verified that MADILL was in possession ofthe telephone she had used to communicate with other members of the DTO. On or about August 8, 2018, agents obtained a consent to search the aforementioned I warehouse from the owner, who had been previously notified of intent to vacate- the" property and terminate the lease between herself and the owner. During thesearch, agents discovered multiple bills of lading for MONSTERS INC. LOGISTICS and TITANIUM WHOLESALE AND RETAIL indicating the transportation of cover loads from the aforementioned warehouse to another warehouse in Lombard, Illinois. Both the aforementioned warehouse, as well as the Warehouse in Lombard, Illinois, were listed on all of the bills of lading. Additionally, agents" discovered a'vacuum sealer commonly used to vacuum pack narcotics, as well as discarded plastic wrapping-s consistent with the type and shape 'of wrappings used to conceal the narcotics seized on May 25,2018. Subsequent tothe aforementioned cocaine seizure, a cooperating defendant advised agents that MADILL works for the aforementioned DTO as-a drug trafficker.? The cooperating defendant told agents that the drugs originated in McAllen, Texas. Said cooperating defendantadmitted that he/she had worked fer MADILL as a money courier and purchaser of cocaine, andidentified other members of the DTO working with MADILL as well.