Case 1:20-mj-04170-DHH Document 1-1 Filed 06/29/20 Page 1 of 5

AFFIDAVIT IN SUPPORT OF AN APPLICATION FOR
A CRIMINAL COMPLAINT AND ARREST WARRANT
I, Sean P. Sullivan, having been duly sworn, hereby depose and state as follows:
Introduction and Agent Background
1.

I make this affidavit in support of an application for a criminal complaint and arrest

warrant charging LAMONT BOSWELL (DOB xx/xx/1985) with knowing possession of a
firearm connected with interstate commerce after having been convicted of a crime punishable
by imprisonment for a term exceeding one year, in violation of 18 U.S.C. § 922(g)(1).
2.

I am employed as a Special Agent with the United States Bureau of Alcohol, Tobacco,

Firearms and Explosives (“ATF”). I joined ATF in 2014 and received formal training at The
Federal Law Enforcement Training Center in Glynco, Georgia. My training included, among
other things, instruction on the investigation of firearms offenses under 18 U.S.C. §§ 922 and
924. I am currently assigned to a joint task force comprised of ATF agents and detectives from
Southeastern Massachusetts. I have participated in numerous investigations focusing on
Controlled Dangerous Substance (“CDS”) trafficking, gangs, and illegal firearms. I have
conducted covert surveillance of suspected CDS traffickers; interviewed numerous individuals
involved in gangs and the CDS trafficking trade; participated in several Title III wiretap
investigations as a monitor and member of surveillance teams; participated in the execution of
numerous state and federal search and arrest warrants involving CDS traffickers and violent
offenders; and participated in the seizure of numerous firearms and controlled dangerous
substances.
3.

Based on my training and experience, I am familiar with the means by which individuals

unlawfully obtain, use, and possess firearms, and how firearms move in or affect interstate
commerce.

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4.

The information set forth in this affidavit is based on information provided to me by

members of the Hanover Police Department (“HPD”) and other federal and state law
enforcement officers, and from my review of records and reports relating to the case. Because
this affidavit is intended to show merely that there is probable cause to issue a criminal
complaint and arrest warrant, it does not set contain all of my knowledge about this matter.
Probable Cause
5.

On March 5, 2020, at about 4:59 A.M., Hanover Police Officer Dana Hansen was

dispatched to 2103 Washington Street in the Town of Hanover, Plymouth County,
Massachusetts, following a report of a person seated inside a parked car with their sweatshirt
pulled up over their head. The description of the car from the report included the Massachusetts
vehicle registration number, xxxR64.
6.

When P.O. Hansen arrived at the location, he observed a car bearing Massachusetts

license plate xxxR64 parked in front of a convenience store. He immediately noticed the sound
of the car’s engine revving. A male with a sweatshirt partially covering his head was seated in
the driver’s seat. No one else was in the car. The occupant appeared to be sleeping. Plainly
visible on his lap was an object that appeared to be a black revolver handgun.
7.

With the assistance of another HPD officer, P.O. Hansen alerted the occupant and

secured the object on his lap without incident. The officers confirmed that it was indeed a loaded
firearm. The occupant could not produce any documentation for the firearm or a license to carry
one. P.O. Hansen arrested the occupant of the car, who was later identified during booking at the
Hanover Police Department as LAMONT BOSWELL (DOB xx/xx/1985). BOSWELL also
revealed during booking that he is a member of a gang, the Latin Kings.

2

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8.

In addition to the firearm, P.O. Hansen recovered 10 small, clear plastic bags of

suspected drugs from BOSWELL. Four bags contained a white and brown powder that P.O.
Hansen believed, based on his training and experience, was likely to be heroin. The other six
bags contained a white powder and rock-like substance that P.O. Hansen believed was likely to
be cocaine. The bags were submitted to the Massachusetts State Police Crime Laboratory for
testing. 1
9.

The firearm recovered from BOSWELL is a .38 Special caliber Smith & Wesson model

442-2 revolver, bearing serial number xxxx925. It was loaded with five rounds of .38 caliber
special ammunition in the cylinder. The firearm and ammunition were tested by a Trooper in the
Massachusetts State Police, Firearms Identification Section. I have reviewed the results of the
testing, which demonstrate that the ammunition was live and the firearm was operable and
capable of firing said ammunition.
10.

ATF used serial number xxx925 to conduct a trace of the firearm recovered from

BOSWELL. According to records kept and maintained by ATF, the firearm was originally sold
by a licensed firearms dealer in the State of North Carolina in 2008. The recorded purchaser was
not BOSWELL.
11.

I conducted an electronic search of records in the Massachusetts Department of Criminal

Justice Information System and confirmed that BOSWELL was not licensed to carry a firearm
on March 5, 2020, or at any other time.

1

Due to a backlog in Massachusetts testing facilities caused by the COVID-19 pandemic,
the contents of the plastic bags recovered from BOSWELL have not yet been tested to confirm
P.O. Hansen’s suspicions that they are, in fact, controlled substances.
3

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12.

I also obtained and reviewed BOSWELL’s criminal history, certain police reports

detailing law enforcement interactions with BOSWELL, and certain certified records of
conviction from Massachusetts courts. Specifically, I have reviewed Norfolk County Superior
Court docket number 1282CR01065, captioned “Commonwealth of Massachusetts vs. Lamont
Miguel Boswell.” These records indicate that BOSWELL pleaded guilty on October 28, 2013 to
multiple criminal violations of the Massachusetts General Law, including Chapter 94C, Section
32(a) (possession of a Class A controlled substance with intent to manufacture, distribute or
dispense) and Chapter 269, Section 10 (possession of a firearm without a license). As a result of
his convictions, BOSWELL was sentenced to a period of incarceration of not less than 4 years
and not more than 4 years and one day. Based on my understanding of Massachusetts law, a
violation of M.G.L. c 94C § 32(a) is a crime constituting a felony, and requires a sentence of
imprisonment for a term in excess of one year. 2

Conclusion
13.

Based on the foregoing information and on my training and experience, I submit that

there is probable cause to believe that on March 5, 2020, LAMONT BOSWELL (DOB
xx/xx/1985) violated 18 U.S.C. § 922(g)(1) by knowingly possessing a firearm despite being
prohibited from doing so as a person having been previously convicted of a crime punishable by

2

The text of the statute reads, in pertinent part, “Any person who knowingly or
intentionally manufactures, distributes, dispense or possesses with intent to manufacture,
distribute or dispense a controlled substance in Class A . . . shall be punished by imprisonment in
the state prison for not more than ten years or in a jail or house of correction for not more than
two and one-half years . . . .” See M.G.L. c 94C § 32(a) and M.G.L. c 274 § 1 (“A crime
punishable by death or imprisonment in the state prison is a felony.”).
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imprisonment for a term exceeding one year, and that said firearm had travelled in or affected
interstate commerce.

Respectfully submitted,

Sean P. Sullivan
Special Agent
U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives

Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1
4:55 p.m.
by telephone on June ___,
29 , 2020.

_________________________________________
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Honorable David H. Hennessy
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UNITED STATES MAGISTRATE
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