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kwalitygear pleaded guilty
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  I.KEKlNM lJSA0#2016R00215 JOSEPH ANDREW TULLY  A091  (Rev. 08/09)  Criminal Complaint  Ell E UNITED  STATti~.~~I~~1~~t1URT for theDi5tric?tybtv4~JYI~  A /I: 5  I United States of America v.  Dt?jt!lIdam(s) CRIMINAL COMPLAINT 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 March 16,2016 in the county of Montgomery County in theDistrict of Maryland . the defendant(s) violated: Code Section 18 U.S.C.  S S  841(a)(1) and (b)(1) (C) Offellse Descripfioll Possession with intent to distribute a Schedule I controlled substanceThis criminal complaint is based on these facts:See Attached Affidavit i 'f   Continued on the attached sheet. Complainant's signature  __ D.ojJ9La.sJ:j.ellil9'!LE9J5! llnspector USPIS Pr;nff!d name and title Sworn to before me and signed in my presence.Date:City and state: Greenbelt, Maryland  - ....--~I: -'-  JUl   ge  S  signature Timothy J.  Sullivan, U.S. Magistrate Judge  Prin1e..d name and lil/e   Case 8:16-mj-01042-TJS Document 1 Filed 04/25/16 Page 1 of 1  16-1042TJS FILED AFFIDAVIT IN ~~~~~~L  COMI)LAINT I, Douglas Henegar (your '~i~~R'~? PAsW ~rpector for the United States PostalInspection Scrvice, being first duly swoEL,t!nteg~J1~~2~e and state as follows: A T  GRfENF~t  T ~JNTROJ)UCrtON. [l' _  I. Your Affiant is an investigative or law enforcement officer of the United Stateswithin the meaning of Section 2510(7) of Title 18, Unitcd Statcs Codc, that is, an officer of theUnited States who is empowered by law to conduct investigations of and to make arrests for otTenses enumerated in section 2516 of Title 18.2. I have been a Postal Inspector for the United States Postal Inspection Servicesince April 2012 and have completed 12 weeks of basic investigative training, which incl~lded the investigation of narcotics related offenses. I routinely investigate the use of the United StatesMail to ship narcotics and narcotics proceeds to and from the Baltimore/Washington area fromthe known narcotic source areas of Florida, Georgia, Califomia, Arizona, Texas, and Colorado(among others). As a result of my training and experience, I am trained to identil;,' vr'riollsmethods that are regularly used by narcotics traffickers to facilitate the shipment of controlled substances and bulk cash through the United States Mail.3. Based on your Affiant's training, experience, and participation in investigating bank robberies, and the training and experience of other detectives and agents with whom I amworking closely in this investigation, I submit this Aftldavit in support of the attached Complaint. This Affidavit does not contain every fact gathered during the investigation.Additionally, unless otherwise noted, wherever in this Aftldavit I assert that an individual made astatement, that statement is described in substance, and in part, and is not intended to he averbatim recitation of the entire statement.   Case 8:16-mj-01042-TJS Document 1-1 Filed 04/25/16 Page 1 of 5  16-1042TJS 4. This Affidavit is made in support of an application for a complaint cha:ging thedefendant JOSEPH ANDREW TULLY with one coun; of knowingly and intentionally possessing with intent to distribute 3,4-Methylenedioxymethamphetamin  ( :vJ~I,IA ), commonly known as Ecstasy, a Schedule I controlled su~stance, in viole-tion of 21 U.S.c. S  841(a)(I) and (b)(I)(C).FACTS  AND  CIRCUMSTANCES OF  THE INVESTIGATIOi'i 5. On March 16, 2016, Postal Inspectors received infornlation that Internatiol111Express Parcel  #  CC052071173NL (the Subject Parcel ) l~ad been identified by Customs and Border Protection ( 'CBp ) and had been interdicted at the International Sen'ice Ccnt~r inJamaica, New York. The Subject Parcel was addres:,ed to Jcey Tully, at 15 Bethayres Ct.,Derwood, MD 20855. CBp agents, pursuant to their protocols and procl.GUre;, o::cnec! theSubject Parcel and found it to contain approximately 2,500 pills that field-tested positive for the presence of MDMA. The evidence was fonvarded to the High Intensity Drug Tlatlicking AreaTask Force ( HIDTA ) and Montgomery County Police Narcotics Detectives.6. On March 21, 2016, at approximately 9:30 a.m., Postal Inspectors, HI~TA, mid Montgomery County Police Detectives conducted a con'.niiled delivery of the Subject Parcelcontaining the MDMA to the residence identified on the Subject Parcel, namely 15 lklhayrcsCt., Derwood, MD 20855 (the Subject Residence ). The d~livery  'Vas  made, and'a white mall',later identified as defendant JOSEPH ANDREW TULLY ( TULL.Y ), took thc Subjeci :'arcelinto the Subject Residence.7. On March 21, 2016, at approximately  9:<10  a.m., TULLY and a fC:llale( 'Coconspirator 1 ), exited the Subject Residence and L'lIten:da silver Toyota Prius. TULLY,who had the Subject Parcel in his possession, entered the ~'rontpassenger sidc llf the' ve~ick, m:d Coconspirator I entered the driver side of the vehicle. The vehicle left the area of the residence2   Case 8:16-mj-01042-TJS Document 1-1 Filed 04/25/16 Page 2 of 5  16-1042TJS and began heading toward Shady Grove Road. Montgomery County Detectives activated their emergency lights and sirens in an attempt to stop the vehicle. Coconspirator 1 began to drive inan erratic manner, at one point driving through the yard of a residence in an attempt to elude police. During the attempt to nee from police, Coconspirator I struck a Montgomery CountyPolice vehicle causing damage to that policc vehicle. Coconspirator I was finally stopped in thearea of the 16000 block of Shady Grove Road, Dei Wood, MD 20855. TULLY and Coconspirator 1were in possession of the Subjcct Parcel containing the MDI\IA, and wcre takeninto custody.8. During the arrest, TULLY was in posses~ion of a black cellular phone. TULLYattempted to throw the cellular phone onto the street in an apparent attempt to destroy it.Additionally, while being handcuffed, TULLY attempted to kick the cellular phone into a stornldrain located near the arrest location.9. On March 21, 2016, Montgomcry County Circuit Court Judge David Boyntonissued a search warrant for the Subject Residence, locatcd   l'.l  15 BClhayrcs Ct.. Derwood. MD20855.10. Pursuant to the search warrant, members oflaw enforcement senrched the SubjectResidence and found, among other items, large quantities of various controlled substances, drugtraftieking paraphernalia, packaging materials, cleclronk devices, and U.S. currency. Thecontrolled substances recovered from the Subject Residence include MDMA, methamphctamine,cocaine, marijuana, and Xanax, all of which field-tested positive for CDS. The drug traftieking paraphernalia include but are not limited to a pill prcss, a glass container with suspected CDSresidue, measuring tools with suspected CDS residue. a PH test indicator, plastic bags, heatsealers, a canning system, digital scales, packaging materials. and glass pipes.3   Case 8:16-mj-01042-TJS Document 1-1 Filed 04/25/16 Page 3 of 5
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