POLICE CRIMINAL COMPLAINT [Egret Number Date Filed I OTN[LiveScan Number Complaint/incident Number 04/ 16/ 2013 O2-09-334 First Middle Last "am STANLEY CHARLES BROOKS AFFIDAVIT of PROBABLE CAUSE Affiant is a police officer employed by the New Hanover Township Police Department located in Montgomery County, and is also a member of the Montgomery County Municipal Drug Task Force. Throughout my employment as a police officer and as a member of the Drug Task Force, have been involved in many cases in which i have participated in the application and execution of drug related search warrants, interviewed drug law violators, and cultivated and utilized confidential informants in such matters. Affiant has also received many hours of instruction on the topic of and relating to narcotics investigation and illegal drug activity. I have received instruction from numerous sources including but not limited to, the Montgomery County Narcotics Enforcement Team, State Police, Traffic institute for Police Services, Montgomery County District Attorney.iEUREs Office, Pinellas County Sheriffs Office-Florida, Greensboro Police Department, North Carolina, Metropolitan PD, Nashville, Tennessee, PA Narcotics Officer/5Es Association, Allentown, PA Police Department, Pottstown, PA Police Department, Bucks County, PA Emergency Training Center, US Drug Enforcement Administration, MAGLOCLEN, Maryland State Police, Northumberland District Attorney/EUREs Office, Arlington County, Virginia Police Department, Johnson County, Kansas Sheriffs Office, Philadelphia, PA Police Department, Albequerque, New Mexico Police Department, E|Paso, Texas Police Department, Camden County, New Jersey Prosecutor/Es Office, Attorney General;EUREs Office, Lancaster County, District Attorney/IE3 Office, National Guard Counter Drug Training Center (NCTC), and the Homeland Security Division of Immigration and Customs Enforcement. This affiant received information from Douglass Township Police reporting that an anonymous subject had contacted that agency and advised that Stanley BROOKS, who resides on Hoffmansville Road in New Hanover Township had been growing marijuana in a barn next to his house at that location. The confidential source also explained that there are osecret roomso that BROOKS secrets large amounts of marijuana and that he has in the past made purchases of marijuana from BROOKS. The source also indicated that there is a large pile of dirt next to the barn and that the dirt is discarded from planting pots that BROOKS utilizes in his marijuana grow operation. Information provided also indicated that BROOKS has equipped the barn with climate control measures to allow for indoor growing of marijuana plants. Affiant is familiar with Stanley BROOKS and knows his address to be 2301 Hoffmansville Road, New Hanover Township, Montgomery County, PA. This agency has had numerous contacts with BROOKS on prior occasions and his property matches the description provided by the confidential source including a large obarno type building that has electrical service as evidenced by spot/flood lights that are visible on all sides of the buiiding. I was also able to locate a large pile of dirt immediately next to the barn as described on the east side of the building. The pile looks to include compacted dirt or material that appears to be in the shape of pots used for plant cultivation. ING TO THE LAW, TRUE AND I, CPL. ROBERT JONES (20) . BEING DULY SWORN ACC DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING DAVI CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION, AND BEL 2 mant) Sworn to me and subscribed before me this . --0 I Date I .Mag_is_teriaI_ My commission expires first Monday of JanuaryAOPC 411C - Rev 09/12 Page 1 of 3 POLICE CRIMINAL COMPLAINT Docket Number Date Filed OTN/Livescan Number Complaint/Incident Number 04/16/2013 02-09-334 First Middle Last STANLEY CHARLES BROOKS AFFIDAVIT of PROBABLE CAUSE CONTINUATION Further observation of the property from the roadway shows that a white PVC pipe is visible on the east side of the building. I was able to see what appeared to be steam being expelled from the pipe in a manner consistent with the interior of the building being heated. In addition a hose reel on a cart was located just outside the building which would be in a location suitable to provided water to support vegetation in the building if needed . Two other, unconnected, white PVC pipes are visible on the west side of the building but do not appear to be connected to anything outside of the building. Several windows are open on the second floor of the barn as well despite cold temperatures which could indicate attempts at ventilation. Affiant has in the past made arrests for and assisted on cases in which buildings were modified or adapted for marijuana growth and cultivation and based on prior experience, training and knowledge believes that the "barn" in question appears to have charachteristics consistent with that use. It is also common for other buildings. and vehicles on or around the property to be utilized for further processing, packaging or storage of illegal drugs monetary procedes and documents associated with drug manufacturing and sales. On February 9th, 2009 affiant applied for and was granted a Search Warrant which allowed the electric company (MetEd) to provide the electricity use records for 2301 Hoffmansville Road, Frederick, PA 19435, located in New Hanover Township, Montgomery County, PA. The record showed the resident's name at that address as Stanley Brooks and also showed that the address is served by two separate meters. One meter is identified as for the "house" and a second meter is listed as service to the "barn" on the documents provided by MetEd. The average cost for electricity use for Brooks' house is listed at $203.00 per month with a peak use cost of $435.28 which occurred during the summer of 2008. The kw hours used show consistent use of between 800 to an extreme high of 4283 in JuliAug, 2008. The electricity consumption for the "barn" is drastically higher with an average cost of $557.00. Peak cost listed is $818.00 at 8922 kw hours in Aug/Sep, 2008. The barn shows consistent electricity use in excess of 4100kwrh for the past 18 months. The Search Warrant also provided comparable information from residences in the vicinity of 2301 Hotfmansville Road. Those homes listed showed substantially less electrical usage. One address had a electric bill that averaged $83.00 and a second area residence had an average bill of $155.00. Both compared addresses were serviced by one meter each and had the same billing rate as the Brooks residence. I also contacted the New Hanover Township Fire Company which is located on Swamp Pike in New Hanover Township for the purpose of providing a source of electricity use comparison. The Fire House is in constant use including but not limited to lighting, staff operations, maintenance, special events and kitchen use. The Fire Department also has computer equipment, emergency equipment on chargers and a large. lighted display sign in front of the building. The information provided by the Fire Department indicates that average KwiH use is roughly 3100kwlh. Affiant confirmed that there is no business listed at the address of 2301 Hoffmansville Road, New Hanover Township and that no special use permits have been issued that would account for the unusually high amount of electricity used at that address. Affiant requested investigative assistance from Detective Sergeant John Becker of Horsham PD for the purpose of conducting a "Thermal lmage" scan of the property. Through my training and experience, lam aware individuals engaged in Marijuana cultivation utilize high--intensity grown lights which provide sufficient light, in lieu of sunlight, to grow Marijuana plants indoors. These lights are used because Marijuana growers utilize indoor facilities, like the barn, to keep their illegal plants from public view. These high--intensity lights are what cause higher than normal electric usage as indicated by the records described herein. These high--intensity lights give off an enormous amount of heat. Indoor Marijuana growers normally attempt to vent this heat from the grow rooms because too much heat will burn the leaves of the plants and damage the roots. in a structure being used for Marijuana cultivation, the Thermal Imaging will show a high pattern emanating from various areas of the structure in buildings used for such illegal activity. On February 27, 2009, between 4:00 a.m. and 5:00 am, I accompanied Sgt. Becker as he conducted an examination AOPC 411C -- Rev 09/12 Page 2 of 3 POLICE CRIMINAL COMPLAINT Docket Number Date Filed OTN/Livescan Number Lcomplaint/Incident Number 04/16/2013 ?2'09'-334 First Middle Last STANLEY CHARLES BROOKS AFFIDAVIT of PROBABLE CAUSE CONTINUATION of 2301 Hoflmansville Road, New Hanover Township, Montgomery County, PA., using a Thermal Imager, also known as a Forward Looking infrared (FLIR). Sgt.Becker reported that the "barn" like structure exhibited an unusually high amount of heat and energy in a manner Consistent with structures adapted for marijuana growth and cultivation. On February 27, 2009 affiant applied for and was granted a Search Warrant for the property located at 2301 Hoffmansviile Road which is listed as the property of Tiffany RUSSIN and as the residence of Stanley C. BROOKS. Upon approach of the oBarno on the property, a very strong odor of fresh marijuana was present and upon entry to the structure, the odor became even stronger. At that time police located several rooms that were located behind false walls in an apparent effort to hide their existence, which was Consistent with the reports made by the initial confidential informant. Inside of the hidden rooms, marijuana plants of at least two stages of growth were located as well as chemicals, soil and equipment commonly used in the indoor growth, cultivation, and processing of marijuana. Specifically, the following items were located, photographed, and seized: 1) Twenty-three (23) dried marijuana plants 2) One hundred three (103) live marijuana plants in various stages of growth. 3) Six large, high intensity lamps 4) Electric outlet timer 5) Ten (10) transformers 1 power supplies There were also water hoses, buckets, potting materials, shovels and hand tools commonly used in the cultivation of plants. Several items of mail confirmed that both Tiffany RUSSIN and Stanley BROOKS were the occupants of the home. The marijuana plants were subsequently transported to NMS Labs and it was confirmed that they were in fact marijuana and weighed approximately 200 ounces approximately 12 pounds. ssessed marijuana Based on the above information affiant believes that Stanley BROOKS produced, cultivated and for the purpose of sales and distribution. TD AOPC 411C -- Rev 09/12 Page 3 of 3