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UNITED STATES DISTRICT COURT

DISTRICT OF MARYLAND - NORTHERN DIVISION

UNITED STATES OF AMERICA CRIMINAL COMPLAINT


v.
CASE NUMBER:
SAVINO BRAXTON
110 9- 317 lI"SF
I, the undersigned complainant, being duly sworn state the following is true and correct to the best of my knowledge
and belief. On or about September 2,2009, in Baltimore City, in the District of Maryland, defendant(s) (Track Statutory Language
Offense)

SAVINO BRAXTON did knowingly, wilfully, and unlawfully possess with the intent to distribute
one kilogram or more of a mixture or substance containing a detectable amount of heroin, a schedule
I narcotic controlled substance, in violation of21 U.S.C. s841(a)(1). •

I further state that I am a Task Force Officer with DEA and that this complaint is based on the following facts:

SEE ATTACHED AFFIDAVIT

Continued on the attached sheet and made a part hereof: X Yes No

.;:;:.
Michael Collins
Task Force Officer, DEA

Sworn to before me and subscribed in my presence,

/.'II: ~t Baltimore, Maryland.


I
AFFIDAVIT

This affidavit is submitted in support of a criminal complaint charging Savino BRAXTON

with possession with the intent to distribute one kilogram or more of a mixture or substance

containing a detectable amount of heroin in violation of21 U.S.C. Section 841(a)(l).

The name of your affiant is Task Force Office Michael Collins of the Baltimore City Police

Department who is detailed to HIDTA, as a Task Force Officer (TFO) for the Drug Enforcement

Administration (DEA).

Your Affiant has been employed with the Baltimore Police Department since 1999. Your

Affiant is currently assigned as a Task Force Officer of the Drug Enforcement Administration

(DEA) HIDT A Group 51. Your Affiant has received over 80 hours of formalized training with

the Baltimore Police Department, Multi-jurisdictional Counter-drug Training Task Force, and

ODV Incorporated. During this training, your Affiant received detailed training, both aocademic

and practical application, in the areas of informant handling/debriefing, drug packaging, pricing,

importation, and trafficking methods. In addition, your Affiant received both academic and

practical application training in surveillance and counter surveillance techniques/methods. Your

Affiant received legal instruction in drug conspiracy laws, preparing drug affidavits, the

Controlled Substances Act, Fourth Amendment Searches and Seizures, Rules of Evidence, and

the execution of search warrants.

Your Affiant has participated in numerous investigations that has targeted violators of

Federal and State controlled dangerous substance laws, and have made over 250 purchases in

controlled dangerous substance investigations acting in an undercover capacity. In addition, your

Affiant has participated in investigations involving wiretaps and has reviewed taped

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conversations, conducted numerous debriefings of CDS traffick~rs~ Cooperating Individuals, and

Sources of Information and examined drug records pertaining to controlled dangerous substance

trafficking. Your Affiant is familiar with the actions, traits, habits, and terminology utilized by

traffickers of CDS. Finally, your Affiant has been acknowledged as an expert in the field of

controlled dangerous substance in the Circuit Court for Baltimore City and the Maryland District

Court for Baltimore City.

All information contained in this affidavit, from whatever source derived, is either

personally known to me or has been related to me by other swohllaw enforcement officials. I

submit this affidavit in support of a criminal complaint charging Savino BRAXTON with the

crime of possession with intent to distribute one kilogram or more of a mixture or substance

containing a detectable amount of heroin in violation of21 U.S.C. Section 841(a)(1). The

following facts and circumstances establish probable cause to believe that Savino BRAXTON

has committed the aforementioned crime. Said circumstances are:

FACTS AND CIRCUMSTANCES: On September 1,2009, your affiant obtained a federal search

and seizure warrant for the residence of Savino BRAXTON, 5312 Goodnow Road, Apartment I,

Baltimore, Maryland. On September 2, 2009, pre raid surveillance was established at BRAXTON's

residence, 5312 Goodnow Road Apt I, Baltimore, Maryland. While conducting pre raid surveillance,

agents observed Savino BRAXTON exit 5312 Goodnow Road and enter a vehicle associated with

BRAXTON. This vehicle is identified as a purple Honda Accord with Maryland temporary

registration. BRAXTON was followed away from the 5300 block of Goodnow Road and eventually
,

returned to the 5000 block of Sinclair Lane, located in Baltimore City, Maryland. Members of

HIDTA Group 51 then took BRAXTON into custody in the 5000 block of Sinclair Lane. At the time

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of his arrest, agents seized approximately 35 grams of suspected heroin from the center console of

the above listed vehicle. Later onthis date, the suspected heroin was tested by your affiant and gave

a positive'reaction for presence for heroin.

After BRAXTON was arrested, agents/officers went to the BRAXTON's residence and

executed the search warrant at 5312 Goodnow Road Apt I, Baltimore, Maryland. Agents/officers

obtained the key for 5312 Goodnow Road, Apt I, Baltimore, Maryland from BRAXTON's key ring

to execute said warrant.

During a search of the dwelling, agents recovered approximately 1 kilogram of suspected

heroin fr<;,mthe kitchen. In the pantry area of the kitchen, there was one gym style duffle bag that

contained approximately 500 grams of 1?uspectedheroin in pellet form. This suspected heroin was

also field tested and gave a positive reaction for the presence of heroin. Recovered fr0f!l inside of

the stove was approximately 500 grams of suspected heroin. In the cabinet above the stove agents

seized one timberland box that contained numerous empty gel caps, one black digital scale, three

sifters, one pipe, one screw driver and one Greyhound bus ticket in thename of Savino BRAXTON.

In addition, agents seized four bottles of mannitol, a bottle of caffeine and a bottle of quinine which

are agents used to dilute heroin for street level distribution. Based on your affiant's training and

experience, all of the above listed property is used in the manufacturing of heroin for street

distribution. Agents also seized a large sum of U.S. currency from the kitchen pantry which your

affiant believes was bundled in thousand dollar stacks.

Based on the aforementioned facts, the undersigned submits that there is probable cause to

believe that Savino BRAXTON did possess with the intent to distribute one kilogram or more ofa

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mixture or substance containing a detectable amount of heroin, a Schedule
.
coj;l8Gsubstance in

violation of21 U.S.C. s841(a)(l).

I, Task Force Michael Collins, affirm under penalties of perjury that the ...facts and

circumstances recounted in the foregoing affidavit are true and accurate to the best of my knowledge

~~
Michael Collins
Task Force Officer

Drug Enforcement Administration

Subscribed and sworn before me on September ,2009.