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:
.;:;:.
Michael Collins
Task Force Officer, DEA
with possession with the intent to distribute one kilogram or more of a mixture or substance
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
Affiant received legal instruction in drug conspiracy laws, preparing drug affidavits, the
Controlled Substances Act, Fourth Amendment Searches and Seizures, Rules of Evidence, and
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
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
All information contained in this affidavit, from whatever source derived, is either
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
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
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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
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
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
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
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
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Michael Collins
Task Force Officer