savino braxton complaint
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UNITED STATES DISTRICT COURT
DISTRICT OF MARYLAND - NORTHERN DIVISION
UNITED STATES OF AMERICA
v .
CRIMINAL COMPLAINT
SAVINO BRAXTONCASE NUMBER:
110 9- 317
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: XYes No
.;:;:.
Michael Collins
Task Force Officer, DEA
Sworn to before me and subscribed in my presence,
/.'II: ~t Baltimore, Maryland.I
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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
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. ..14- 31 '7 J L . .mixture or substance containing a detectable amount of heroin, a Schedule1coj;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
4
,2009.