7/ Complainant's signature

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1 Case 3:13-mj Document 1 Filed 12/23/13 Page 1 of 9 Page ID#: 1 AO 91 (Rev. 11/11 Criminal Complaint UNITED STATES DISTRICT COURT for the United States of America v. RAUL REYES RAMIREZ Defendant(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 December 19, 2013 in the county of Multnomah in the District of O...:..._re'-"g'-'-o_n' , the defendant(s violated: Code Section Title 21, United States Code, Section (b(2(b Distribution of Heroin Offense Description This criminal complaint is based on these facts: See Affidavit of FBI Special Agent Yaqub Prowell attached hereto and incorporated herein by this reference. 0 Continued on the attached sheet. 7/ Complainant's signature Special Agent Yaqub Prowell, FBI Printed name and title Sworn to before me and signed in my presence. Date: City and state: Portland, Oregon Judge 's signature v U.S. Magistrate Judge John V. Acosta Printed name and title

2 Case 3:13-mj Document 1 Filed 12/23/13 Page 2 of 9 Page ID#: 2 STATE OF OREGON AFFIDAVIT OF Y AQUB PROWELL DISTRICT OF OREGON I, Yaqub Prowell, being duly sworn, depose and state the following: INTRODUCTION I am a Special Agent with the Federal Bureau oflnvestigation (FBI and have been so employed for three years and four months. As a Special Agent of the FBI, my duties and responsibilities have included conducting criminal investigations for possible violations of federal law. My current assignment is investigating cases involving Organized Crime and Criminal Enterprises. I have received five months of training at the FBI Academy in Quantico, Virginia, which included interviewing and interrogation techniques, arrest procedures, search warrant applications, criminal case management, informant development, and various other criminal law and procedures. I have also received specialized training to include the Department of Justice Asset Forfeiture and Money Laundering Section (AFMLS Financial Investigations Seminar, as well as the AFMLS Basic Organized Crime Drug Enforcement Task Force Financial Investigations Seminar. This training focused on methods of unlawful drug trafficking; the means by which drug traffickers derive, launder, and conceal their profits from drug trafficking; the use of assets to facilitate unlawful drug trafficking activity; the law permitting the forfeiture to the United States of assets purchased with drug proceeds or assets used or intended to be used to facilitate the drug violations; as well as money laundering investigations. I am also working as a member of the Washington County Sheriffs Office (WCSO Westside Interagency Narcotics (WIN Task Force, and have been so assigned for approximately Affidavit of Y aqub Prowell Page 1 of8

3 Case 3:13-mj Document 1 Filed 12/23/13 Page 3 of 9 Page ID#: 3 six months. As a deputized member of this task force, my duties include, but are not limited to, investigating violations of state and federal laws concerning the unlawful importation of controlled substances, distribution of controlled substances, and possession with intent to distribute controlled substances, including but not limited to, cocaine, methamphetamine, marijuana, and heroin. During my law enforcement career, I have participated in numerous drug and criminal enterprise related investigations and search warrants. I have personally utilized and been involved with the utilization of various means available to law enforcement during the course of an investigation which includes: surveillance, informants, undercover officers, video surveillance, photography, pen registers, vehicle trackers, wire taps, search warrants, body wires and other physical and technological investigative means. This affidavit is made in support of a criminal complaint and arrest warrant against RAUL REYES RAMIREZ (hereinafter RAMIREZ, date of birth 06/12/78, also known as "VICKY," for the unlawful distribution of heroin, in violation of Title 21, United States Code, Section 841 (b(2(b. This affidavit is intended to show that there is sufficient probable cause for the requested complaint and arrest warrant, and does not set forth all of my knowledge of, or investigation into, this matter. Based upon my training, education and experience, and my participation in investigations involving quantities of controlled substances, I believe there is probable cause to arrest RAUL REYES RAMIREZ, date of birth 06/12/78, (AKA "VICKY", for the unlawful distribution of heroin. Affidavit of Yaqub Prowell Page 2 of8

4 Case 3:13-mj Document 1 Filed 12/23/13 Page 4 of 9 Page ID#: 4 BACKGROUND OF INVESTIGATION The following was relayed to me by Beaverton Police Department Detective Charles Wujcik, a member of the WIN Task Force between December 21,2013 and December 23,2013: On December 18, 2013, at approximately 03:28a.m., Detective Wujcik was advised that a narcotics overdose had occurred at 7709 SW Pfaffle Street, Apartment 14, Tigard, Oregon Detective Wujcik subsequently arrived on scene, where he learned that one BRYAN JOSEPH CONKLIN (CONKLIN, date ofbirth 01/07/71, had reported via 911 on December 17, 2013, at approximately 11:53 p.m., that his wife, MICHELLE LEE CONKLIN (MICHELLE, date ofbirth 07/30/70, was unconscious and unresponsive. Detective Wujcik also learned that MICHELLE was declared deceased by responding authorities at 12:08 a.m. on December 18, The medical examiner on scene told Detective Wujcik that MICHELLE's death appeared to be an opiate overdose, but could not be absolutely sure until he conducted a toxicology examination. Detective Wujcik then interviewed CONKLIN with WCSO Detective Justin Pelleteri. CONKLIN divulged to Detectives Wujcik and Pelleteri that he and his wife MICHELLE had been using heroin and/or methadone for over 20 years, but that MICHELLE had been clean from opiates and opiate derivatives for the past four to five months. On December 17,2013, however, CONKLIN purchased a half gram of heroin from an individual CONKLIN knew as "Kevin," for $ CONKLIN then prepared this heroin to be injected. He injected himself with approximately 70% of this heroin, and gave MICHELLE the remaining 30% to inject herself with. CONKLIN gave the smaller amount to MICHELLE because she had not used heroin in a while. He was concerned that the more heroin she used in Affidavit ofyaqub Prowell Page 3 of8

5 Case 3:13-mj Document 1 Filed 12/23/13 Page 5 of 9 Page ID#: 5 one injection, the more dangerous it would be. After CONKLIN and MICHELLE injected themselves with their respective portions of the half gram of heroin, CONKLIN passed out. When he awoke, he found MICHELLE lying face down in their hallway. He then called 911 to report her unconscious and unresponsive. WIN Task Force investigators, with CONKLIN's cooperation, identified CONKLIN's source of heroin supply, "Kevin," as one KEVIN LYNN PIERCE (PIERCE, date of birth 03/04/77, residing at 4228 SE 15th Avenue, Number 1, Portland, OR, On December 18,2013, at approximately 5:15p.m., CONKLIN, under the direction of WIN Task Force investigators, contacted PIERCE, and then conducted a law enforcement controlled narcotics buy at 4228 SE 15th A venue Number 1, Portland, OR, 97202, in which CONKLIN purchased a half gram of a substance, which later field tested positive for heroin. Afterwards, CONKLIN stated he purchased this suspected heroin from PIERCE. Later, at approximately 7:30p.m., members of the WIN Task Force, WCSO, and the Portland Police Bureau (PPB, served a search warrant at 4228 SE 15th Avenue, Number 1, Portland, OR, During the execution of this warrant, officers seized several items to include 8.6 grams net of a brown substance, which later field tested positive for heroin. Detective Wujcik also interviewed PIERCE, after advising him of his Miranda rights, and receiving confirmation from PIERCE that he understood these rights. PIERCE admitted to Detective Wujcik that he did sell a lh gram of heroin for $50.00 to CONKLIN on December 17, PIERCE also admitted he sold CONKLIN the ~ gram of heroin for $50.00 on December 18, 2013, which was the result ofthe aforementioned controlled buy. Affidavit of Y aqub Prowell Page 4 of8

6 Case 3:13-mj Document 1 Filed 12/23/13 Page 6 of 9 Page ID#: 6 PIERCE told Detective Wujcik that his source of heroin supply was a Hispanic male posing as a female he knew only as "Vicky." Detective Wujcik showed Kevin a photograph of RAUL REYES RAMIREZ (RAMIREZ, date of birth 06/12/78. PIERCE positively identified the individual in this photograph as "Vicky." Detective Wujcik knew RAMIREZ to be the focus of several heroin investigations within the Portland and Washington County, Oregon areas. One of these investigations pertains to another heroin overdose death, which occurred in Tigard, Oregon on November 18, PIERCE told Detective Wujcik he usually purchases a Y:! ounce of heroin for $ per day from RAMIREZ. Detective Wujcik made no promises to PIERCE, nor did he threaten him with anything in exchange for information. PIERCE told Detective Wujcik he wanted to cooperate in the hopes of receiving consideration toward his charges that will result from this investigation. On December 19,2013, at approximately 12:30 p.m., Detective Wujcik met with PIERCE and directed him to contact RAMIREZ telephonically. Detective Wujcik listened to this call, in which PIERCE and RAMIREZ agreed to meet later that day. Later, at approximately 4:00 p.m., Detective Wujcik met with PIERCE again for the sole purpose of conducting a narcotics purchase, to be controlled by members of the WIN Task Force and other law enforcement officers present, of Y:z ounce of heroin for $ from RAMIREZ. Detective Wujcik searched PIERCE for drugs, cash, and any other illegal items, finding none. Detective Wujcik directed PIERCE to place another call to RAMIREZ, during which PIERCE and RAMIREZ agreed to meet at PIERCE's residence, 4228 SE 15th Avenue Number 1, Portland, OR, 97202, to conduct the aforementioned narcotics buy. Detective Wujcik gave PIERCE Affidavit of Yaqub Prowell Page 5 of8

7 Case 3:13-mj Document 1 Filed 12/23/13 Page 7 of 9 Page ID#: 7 $ cash for the sole purpose of purchasing this heroin. Detective Wujcik then directed PIERCE to walk from Detective Wujcik's department vehicle to the parking lot of PIERCE's apartment. Detective Wujcik directed PIERCE not to go inside his residence or meet with anyone other than RAMIREZ, as that would compromise Detective Wujcik's control of this purchase. On December 19,2013, at approximately 4:20p.m., WCSO Detective Timothy Miller observed PIERCE walk from Detective Wujcik's department vehicle to the parking lot of 4228 SE 15th, Portland, OR, 97202, and wait there. Detective Miller observed that PIERCE did exactly as directed by staying out of his residence, and not having any physical contact with anyone. Approximately five to ten minutes later, Detective Miller observed a white, four-door Cadillac sedan arrive in the parking lot where PIERCE was waiting. This vehicle did not have license plates. Detective Miller observed PIERCE enter the passenger's side of this vehicle, stay there for several minutes, then exit. After Detective Miller observed the white Cadillac leave the deal location, investigators followed this vehicle away. Tigard Police Department Officer Jeff Hering pulled alongside this vehicle and positively identified the driver as RAMIREZ. The driver of the vehicle had not made any stops, nor had the driver picked anyone up since PIERCE had exited, when this identification was made. Once PIERCE exited the white Cadillac, Detective Miller observed him walk south and around the comer to where Detective Wujcik was waiting. Detective Wujcik recovered PIERCE and collected from him approximately lh ounce of a brown substance, which later field tested positive for heroin. Detective Wujcik placed the suspected heroin into a clean evidence bag and Affidavit ofyaqub Prowell Page 6 of8

8 Case 3:13-mj Document 1 Filed 12/23/13 Page 8 of 9 Page ID#: 8 maintained control of it. Detective Wujcik searched PIERCE for other drugs, cash or any other illegal items and found none. Investigators continued following the Cadillac. At approximately 5:40p.m., the Cadillac arrived at the Mountain View Terrace Apartments, 5700 NE 34th Street Vancouver, Washington, WCSO Detective Albert Roque observed RAMIREZ exit the Cadillac and walk toward an alcove in the nearest apartment building. This alcove led to four separate apartments numbered 5, 6, 7, and 8. Detective Roque lost sight of Ramirez in this area. Beaverton Police Detective Pat McNair later walked by these apartments and observed movement through the blinds of a window attached to apartment number 5. At approximately 5:30p.m., Detective McNair walked by this same window and observed RAMIREZ inside apartment 5. On December 19,2013, at approximately 8:25p.m., RAMIREZ entered the Cadillac and left 5700 NE 34th Street, Vancouver, Washington, WIN investigators followed RAMIREZ as he drove directly to 2815 SE 129th Ave, Portland, Oregon, WIN team investigators had observed RAMIREZ at this residence on November 20, 2013 when investigating the aforementioned heroin overdose death that occurred in Tigard, Oregon on November 18,2013. RAMIREZ arrived at this address at approximately 8:43p.m., then left about three minutes later. Investigators observed the Cadillac return to 5700 NE 34th Street, Vancouver, Washington, 98661, at approximately 9:04p.m. on December 19,2013, upon which RAMIREZ exited the Cadillac and entered apartment 5. Investigators concluded surveillance that night at approximately 9:45 p.m. Affidavit of Yaqub Prowell Page 7 of8

9 Case 3:13-mj Document 1 Filed 12/23/13 Page 9 of 9 Page ID#: 9 Due to the probable cause established for RAMIREZ' violation of stateside statutes pertaining to the unlawful possession and distribution of heroin, law enforcement officers in Clark County, Washington obtained from District Court Judge Sonya L. Langsdorf ofthe Clark County District Court a search warrant that was executed at 5700 NE 34th Street, apartment 5, Vancouver, Washington, at approximately 6:20p.m. on December 20, During this search these officers seized a narcotics scale, packaging, and between six and ten ounces of suspected heroin. While this search was being conducted, WIN Task Force investigators conducted a traffic stop of RAMIREZ at approximately 6:41 p.m. in Hillsboro, Oregon, based on the probable cause for RAMIREZ' Unlawful Delivery of Heroin developed during the controlled narcotics buy with PIERCE. RAMIREZ was detained by WIN investigators and Detective Wujcik interviewed RAMIREZ, after RAMIREZ was informed of his Miranda rights and stated that he understood these rights. During this interview, RAMIREZ admitted to Detective Wujcik that he sells heroin, and that he specifically sells a 'li ounce of heroin per day to PIERCE. Based on the information set forth in this affidavit, I submit that there is probable cause to arrest RAUL REYES RAMIREZ for the distribution of heroin, in violation of Title 21, United States Code, Section 841(b(2(B. HonorableJohn V. Acosta United Sfates Magistrate Judge Affidavit of Y aqub Prowell Page 8 of8