Case 2:16-cr-00138-MSG Document 1 Filed 03/10/16 Page 1 of 8

AO 91(Rev.11/11) Criminal Complaint

~1

UNITED STATES DISTRICT COURT

for the
Eastern District of Pennsylvania
United States of America

v.

)
)

ANGEL CATALINO IVOSTRAZA-TORRES

Case No.

)
)
)
)

MAR ! O 2016

Defendant(s)

CRIMINAL COMPLAINT

MICHAEL r:. !\UNZ, Clerk

Dep. Clerk

By

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of
Eastern

District of

March 9, 2016
Pennsylvania

Code Section

in the county of

Philadelphia

in the

, the defendant(s) violated:

Offense Description

Knowingly and intentionally possessing with intent to distrbute 500 grams or

more of cocaine

21U.S.C.841(a)(1), (b)(1)(B)

This criminal complaint is based on these facts:

On or about March 9, 2016, in Philadelphia, in the Eastern District of Pennsylvania, defendant ANGEL CATALINO
IVOSTRAZA-TORRES, knowingly and intentionally possessed with intent to distribute 500 grams or more of cocaine, a
Schedule II controlled substance, in violation of21U.S.C.841(a)(1),(b)(1)(A),(b)(1)(B).

~ Continued on the attached sheet.

mmmmmmQmm:~
U.S. Postal Inspector Cotelia Bond-Young
Printed name and title

Sworn to before me and signed in my presence.

Date:

ff/rAAliA /0 t 2/JJ{,

City and state:

Philadelphia, PA

RICHARD A. LLORET, U.S. Magistrate Judge

Printed name and title

r=~lEU

/&-)Oi

Case 2:16-cr-00138-MSG Document 1 Filed 03/10/16 Page 2 of 8

MAR~ O 2016'

AFFIDAVIT
I, COTELIA BOND-YOUNG, being duly sworn, depose and say:
1.

I am a United States Postal Inspector. I am currently assigned to the United States

Postal Inspection Service, Philadelphia Division. I have been employed as a Postal

Inspector since June 2013. As part of my duties as a United States Postal Inspector, I
investigate the use of the U.S. Mails to illegally transport controlled substances and drug
trafficking in instrumentalities, in violation of Title 21, United States Code, Sections
841(a)(l), 843(b), and 846. I have been trained in various aspects oflaw enforcement,
including the investigation of narcotics offenses. Through my education and experience
and that of other agents assisting in this investigation, I have become familiar with the
methods that individuals use to traffic narcotics through the U.S. Mail.
2.

As part of my duties as a United States Postal Inspector, I investigate the use of

the U.S. Mails and private carriers to illegally transport controlled substances and drug
trafficking instrumentalities, in violation of Title 21, United States Code, Sections
841(a)(l), 843(b), and 846. I have been trained in various aspects oflaw enforcement,
including the investigation of narcotics offenses. Through my education and experience,
and that of other agents, I have become familiar with the methods that individuals use to
traffic narcotics through the U.S. Mails.
3.

This affidavit is based upon my personal knowledge, experience and training, and

other information developed during the course of this investigation. This affidavit is also
based upon information and experience imparted to me by other law enforcement
officers. Because this affidavit is being submitted for the limited purpose of establishing
probable cause for an arrest, I have not included each and every fact known to me

Case 2:16-cr-00138-MSG Document 1 Filed 03/10/16 Page 3 of 8

concerning this investigation. I have set forth only the facts that I believe are necessary
to establish probable cause to believe that Angel Catalino Ivostraza-Torres has attempted
to possess with intent to distribute 500 grams or more of cocaine, in violation of 21

u.s.c. 846.
FACTS ESTABLISHING PROBABLE CAUSE
1.

On March 8, 2016, the Philadelphia Division of the U.S. Postal Inspection Service

identified a suspect Express Mail package, Express Mail number EK42795 l 694US (the
"Subject Parcel"). The Subject Parcel was mailed from Pue110 Rico, an area known to
law enforcement as a source for narcotics and has the following characteristics: Express
Mail No. EK427951694US, and measuring approx. 18" x 18" x 18", bearing the return
address "Hector Diaz, Playa Azul II Apt 18, Luquillo, PR 00773," and the delivery
address "Jesus M. Soto Rivera, 4151 0 St. Philadelphia, PA 19124."
2.

The Subject Parcel was mailed on March 7, 2016, from Luquillo, Puerto Rico.

The parcel was a brown box which measured 18" x 18" x 18" and weighed
approximately 17 pounds .2 ounces. Investigation of the return address of the Subject
Parcel, through the Law enforcement Database "CLEAR", showed that the name "Hector
Diaz" does not associate with the return address itself. Investigation of the addressee
information of the Subject Parcel, through "CLEAR," a law enforcement database,
showed that "Jesus M. Soto Rivera" is not listed at that address. From my training and
experience, and the experience of other agents, I know that drug dealers who are sending
controlled substances by the mail or other package delivery services will often use a
fictitious delivery addressee name when they are shipping parcels containing controlled
substances. They use this subterfuge in order to prevent the mailer of the package from

Case 2:16-cr-00138-MSG Document 1 Filed 03/10/16 Page 4 of 8

being located. From my training and experience, and the experience of other agents, I
know that drug dealers who are sending controlled substances by the mail or other
package delivery services will often use a company or business as the delivery address as
a method to mask their identity when they are shipping parcels containing controlled
substances. I am further aware, based upon my training and experience, that Puerto Rico
is a known source state for controlled substances.
3.

On March 8, 2016, the subject parcel express mail# EK427951694US was

exposed to a drug detection canine named "Diesel." Diesel is handled by Officer Gordon
Schaffer Badge# 627 with the Camden County Sheriff Police Department and has been
working as a canine officer with since January of 2009. Officer Schaffer started his Law
Enforcement career in August 2005 with the Clementon Police Department and in April
2013, he transferred to the Camden County Sheriff's Office. The Camden County
Sheriff's Office certifies Officer Schaffer and K9 Diesel on a yearly basis, and Officer
Schaffer and K9 Diesel have ongoing maintenance training every month during the year.
In January 2016, Officer Schaffer and K9 Diesel participated in the United States Police
K9 Association Drug Detector Dog Certification. Officer Schaffer and K9 Diesel
successfully completed the certification and are certified in the detection of the smell of
the following substances: marijuana/hashish, cocaine hydrochloride/cocaine base, and
heroin hydrochloride. Officer Schaffer advised Postal Inspectors that "Diesel" alerted
positive to the odor of the presence of illegal narcotics inside the Subject Parcel. The
Subject Parcel is presently located at the United States Postal Inspection Service
Narcotics Office within the Eastern District of Pennsylvania.

Case 2:16-cr-00138-MSG Document 1 Filed 03/10/16 Page 5 of 8

4.

On March 8, 2016, the Honorable Richard A. Lloret, U.S. Magistrate Judge for

the Eastern District of Pennsylvania, issued a federal search warrant (Magistrate Number
16-290) to search the Subject Parcel. Postal Inspectors opened the parcel and found
inside green foam packing peanuts surrounding an "Epson XP-320" printer box. Inside
the printer box was a black printer. Inside the black printer was a vacuum sealed bag and
inside the vacuum sealed bag was a white powdery substance. The white powdery
substance field tested positive for the presence of cocaine with an approximate total
weight of one kilogram. The estimated street value of one kilogram of cocaine is
$100,000 US Dollars, if broken down for distribution in user quantities.
5.

On March 8, 2016, after postal inspectors recovered cocaine from the Subject

Parcel, the Honorable Richard A. Lloret issued an anticipatory search warrant for 4151 0
Street, Philadelphia, PA 19133 ("the Subject Location") the delivery address on the
Subject Parcel. Magistrate Judge Lloret also issued a warrant to have a GPS tracking
device placed on the Subject Parcel. After receiving these warrants, postal inspectors
removed the majority of the cocaine from the Subject Parcel, leaving a representative
amount. An alarm was installed in the Subject Parcel that was triggered to go off if the
parcel was opened.
6.

On March 9, 2016, at approximately 10:35 AM, postal inspectors conducted a

controlled delivery of the Subject Parcel to the Subject Location.

7.

At approximately 10:45 AM as the Undercover (UC) inspector approached the

delivery location when a Hispanic male wearing black jeans and a black hoodie
approached the UC showing his identification stating his name was Jesus M. Soto Rivera,
and the Subject Parcel was for him.

Case 2:16-cr-00138-MSG Document 1 Filed 03/10/16 Page 6 of 8

8.

Shortly thereafter, the Hispanic male walked towards Castor Avenue,

Philadelphia, PA and placed the Subject Parcel in the back passenger side of a maroon
Chevrolet SUV bearing Pennsylvania license plate JTV8550 ("the Subject Vehicle). The
SUV was occupied with two individuals.
9.

Postal Inspectors continued surveillance on the maroon Chevrolet where it

ultimately parked on the 3300 block of Lawrence Street, Philadelphia, PA. There were no
individuals inside of the vehicle.
10.

Inspectors continue to observe the vehicle, along with the Subject Parcel in the

back passenger side of the car.

11:

At approximately 6: 14 PM, a Hispanic male wearing blue jeans and black t-shirt,

later identified as Angel Catalino Jvostraza-Torres, approached the Subject Vehicle. He

removed the "Epson" printer box from the Subject Vehicle, leaving the Subject Parcel
behind, and walked to "Finishline Auto Detailing" located at 3301 N 5th Street,
Philadelphia, PA 19140 and entered the business establishment.
12.

While law enforcement was conducting surveillance on the Westmoreland Street

garage entrance of "Finishline Auto Detailing" business (this business has another
entrance at 3301 N 5th Street), law enforcement saw a Hispanic male, later identified as
Angel Catalino lvostraza-Torres, walking on Westmoreland Street coming from the
direction of the 3300 N. 5th Street. Ivostraza-Torres walked toward the driver's side of the
maroon Chevrolet SUV. Law enforcement was unable to see Ivostraza-Torres at that
time, however, law enforcement saw the rear parking lights of the maroon Chevrolet
SUV turn on for approximately twenty to thirty seconds. Once the lights of the vehicle
are off, law enforcement saw lvostraza-Torres walk back towards the 3300 N. 5th Street

Case 2:16-cr-00138-MSG Document 1 Filed 03/10/16 Page 7 of 8

with the printer box under his arm. Law enforcement saw Ivostraza-Torres enter the first
available garage door of the Finishline Auto Detailing business located at 3301 N

5th

Street. The door was partially opened at the time and Ivostraza-Torres was seen ducking
under the garage door and then the garage door immediately closed.
13.

At approximately 6:16 the first alarm sounded indicating that the "Epson" Printer

box had been opened. Shortly thereafter, the second alarm sounded indicating that the
actual printer had been opened.
14.

Once the alarms sounded law enforcement converged on business and maintained

surveillance on both garage door entrances/exits of the business. Law enforcement saw
Ivostraza-Torres exit the N. 5th Street garage entrance and he was stopped. Law
enforcement checked Ivostraza-Torres hands and body for the presence of thief detection
powder which was found on his hands and shirt.
15.

Law enforcement continued surveillance on all entrances/exits to the business

while obtaining the help of the Philadelphia Fire Department in order to open the steel
gate to make entry into the business. Approximately thirty minutes later, law
enforcement entered the business and during a security sweep saw the open printer box
with the printer sitting on the tool case. The printer was unscrewed and the vacuum
sealed bag sitting next to the printer. 1
16.

At approximately 6:55 PM, Ivostraza-Torres waived his Miranda rights and stated

in summary and in part that a Hispanic male, who he did not know, approached him
saying he would give him 100 US currency2 to get the printer out of the maroon

The vacuum sealed bag was black on one side and clear on the other side making the cocaine visible.

Although I vostraza-Torres did not indicate whether he had been paid, a search incident to arrest revealed
that he only nine dollars.

Case 2:16-cr-00138-MSG Document 1 Filed 03/10/16 Page 8 of 8

Chevrolet and take it out of the box and put in on the tool case inside of "Finishline Auto
Detailing." Your affiant asked how did the drugs get beside the printer, and IvostrazaTorres responded that he had been told to remove it from the printer and place it on the
tool case. Ivostraza-Torres stated this was the first time (10 minutes ago) that he has ever
met the Hispanic male. He said the Hispanic male said his name was "Nick." When
Ivostraza-Torres was asked how he got into the car, he replied "it was opened." When
Ivostraza-Torres was asked how he got into the detailing shop, he replied "I went around
the back and the door was closed, I went in the front and it was opened."
17.

Ivostraza-Torres declined answering anymore questions until his lawyer was

present.
18.

Based on the above facts, your affiant believes there is probable cause to believe that on

March 9, 2016, Angel Catalino lvostraza-Torres possessed with intent to distribute 500 grams or
more of cocaine, a Schedule II controlled substance in the Eastern District of Pennsylvania, in
violation of Title 21, United States Code, Section 84l(a)(l), (b)(l)(B), and as such a warrant
should be issued for his arrest.

G~
COTELIA~~

United States Postal Inspector

Swornjp before me this day

of Jt''iVcarch, 2016

HONORABLE RICHARD A. LLORET

United States Magistrate Judge