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Richard Shaw case xo. l .. ) q /u ) 67

CRIM INAL COM PLAINT

ls the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the datets) of January 2009 to date in the county of in the

Western District of Virginia , the defendantts) violated:

Code Section

21 U.S.C. j 846

Offense DescriptionConspiracy to Possess with the Intent to Distribute Methamphetamine

This criminal complaint is based on these facts:

See Attached.

D Continued on the attached sheet.

/Complainant 's signature

Jonathan Tabor, Special Agent, Bureau of ATFPrinted name and title

Judge 's signature

Pamela Meade Sargent, U.S. Magistrate JudgePrinted name and title

Sworn to before me and signed in my presence.

Date: 04/14/2014

city and state'. Abingdon, Virginia

Case 1:14-mj-00087-PMS Document 3 Filed 04/14/14 of 1 Pageid#: 3

per gram of crystal methamphetamine).could not afford to let it go at that price.

I believe that Rusty CASSELL advised REECE that he

On April 1 1, 2013 Angela SURBER was interviewed in Bristol, Virginia. SURBERstated around 2009-2010 she moved in with Danny REECE. After living with REECE for twomonths REECE asked SURBER to take him to M ountain City to obtain meth from Rick SHAW .SURBER stated she and REECE went to SHAW 'S to plzrchase meth approximately once a weekfor approximately eight weeks. SURBER stated REECE obtained a tsfistful'' size of meth eachtime from SHAW . SURBER advised most of the deals with SHAW occurred at his house butone deal occurred at a property SHAW owned in Butler, TN.

On April 23, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text m essages stored in the accounts of several cellular telephone numbers,including those of Danny REECE and Rick SHAW . In response to the execution of this searchwarrant on Verizon W ireless, agents received text messages stored in those accounts from April9 to April 23, 2013. The following is an excerpt from the search warrant results.

April 10, 2013

Roger LAWSON to Danny REECE, kilts Roger myph is screwfup. Did u try to text me?New no. 276 206 3398,,REECE to LAW SON, Q*No still haven 't heard nothin''LAW SON to REECE, iivb'o ur not Iikely to be over too soon. Just let me kntpw''REECE to LAW SON, içïkrell im over here but no parts''LAW SON to REECE, *GOk thanks.''

Rick SHAW to REECE, %*1 'm home''REECE to SHA W , 6110-4 leavin Dlnown ntpw''REECE to ûtBubba'' BUCHANAN LiDidyou an Rodger want to come tonight/t'7

Based on my training and experience, and m y knowledge of this investigation, 1 believethat Danny REECE utilized the text messaging service on his cellular telephone to arrange tomeet with Rick SHAW for the purpose of obtaining methamphetamine. 1 believe that REECE inturn sold the methamphetamine to Roger LAW SON and Bubba BUCHANAN.

A pril 14 - 15, 2013

Bubba BUCHANAN to Danny REECE, i;U n D r Mtn CjKenny Nstef,REECE to BUCHAN AN , ççout haven 't seen him yet',BUCHANAN to REECE, Gilkx when u dopleez bhknny N stef'

REECE to Rick SHAW , ç6I gotta haul thisparts truck to Stony Creek an I 'll be up fyraround/''REECE to SHAW , i%on wJy atlw to yr house''SHAW to REECE, çç1 'm in Boone back soon',REECE to SHAW , *i1'l1 have to go tm ''

9

Case 1:14-mj-00087-PMS Document 3-1 Filed 04/14/14 Page 9 of 106 Pageid#: 12

SHAW to REECE, inok c u later text when u get back''

REECE to BUCHANAN , 2*10-4 good to goo''Roger LAW SON to REECE, ççls it ok to stop by. lm in c//y''REECE to LAW SON , çi10-4''

Based on my training and experience, and my knowledge of this investigation, 1 believethat Danny REECE utilized the text messaging service on his cellular telephone to obtainmethamphetamine from Rick SHAW and distribute it to Bubba BUCHANAN and RogerLAW SON.

April 17, 2013

Rick SHAW to Danny REECE, inbleaded home''REECE to SHAW , **On wJy do u need nethingh'om /own?''SHAW to REECE, Qnllrink't

Roger LA W SON to REECE, dûadre u n D Fow?7 tonight''REECE to LAW SON , $iC/ry''REECE to LAW SON , iiGotparts't

Based on my training and experience, and my knowledge of this investigation, 1 believethat Danny REECE utilized the text messaging service on his cellular telephone to obtainmethamphetamine from Rick SHAW and distribute it to Roger LAW SON.

April 19, 2013

Dalmy REECE to Rick SHAW , G*Willyou be around tonight.?''SHA W to REECE, iiàhïo sorry''

Bubba BUCHANAN to REECE, GiEver hear n e thing LKenny Nstef'REECE to BUCHANAN, **He went to the Rodrun nothinftBUCHANAN to REECE, dt.. .l0-4bNKenny Nstef'

April 20 - 21, 2013

REECE to SHAW , çiblave you got any ideal what time you will be home/''(423) 707-5321 to REECE, nLlfandwhenpossible can you double my regparts order//2/C.V''REECE to (423) 707-5321, iiDude is gone to Rodrun//''(423) 707-5321 to REECE, içsheeeotl''

(423) 534-7673 to REECE, i;& t@''REECE to (423) 534-7673, iiDude is gone to the Rod Run. Don 't know when he will behome''

10


BUCHANAN to REECE, GiNow wvî//.v up WKenny N Stef'REECE to BUCHANAN, Gx othin he still aint home?''BUCHANAN to REECE, ;'Fex me when WKenny Nstef'

Roger LAW SON to REECE, Lizqre u gonna be in D Town today/''REECE to LAW SON, 1iFw#.' Dude is gone to the Rod Run don 't no when he will behome/''

LAW SON to REECE, ççAll 1 need is a 50 lb. bag ofdogfool'

REECE to SHAW , Giklave you got any ideal what time you will be /?t??ne?''BUCHANAN to REECE, iilkhat 's the word WKenny N Stef'REECE to BUCHANAN , iiNothin/',SHA W to REECE, Qo3oml.n''REECE to SHAW , içlkeenfourrrr on wayfrom Dlbwn''

REECE to BUCHANAN, içllow much cash u got on hand/'tBUCHANAN to REECE, **160 WKenny Nstef'REECE to BUCHANAN , idf-fow quik can u get to river bridge/''BUCHANAN to REECE, 6120 n route now WKenny N stef'

LAW SON to REECE, iiok fl come over ntlwy''REECE to LAW SON, GnYeahfor a lil,,LAW SON to REECE, içok Im leavin Saltville n(?w.''LAW SON to REECE, çiBe there in 20 mfns'''REECE to LAW SON, Qil0-4''

The affiant believes Rick SHAW utilized the aforementioned text messages to distributemethamphetamine to Danny REECE who in turn distributed methamphetamine to RogerLAW SON and Kenneth BUCHANAN.

On M ay 2, 2013, CS-IO was interviewed in Charlotte, NC. CS-IO stated that RickSHAW was a methamphetamine distributor in M ountain City, TN. CS-IO stated that SHAWlived on T Greer Rd. and was currently on federal probation.

On August 16, 20 13, a search warrant was executed at 190 12 Lake Rd., Abingdon, VA,the residence of Nathan HALL, Brandi DUNFORD, W illiam HUNT, Jr. and others. Seized fromthe apartment of HALL and DUNFORD was a m ethamphetam ine lab.

Subsequent to the search warrant, HALL, DUNFORD and HUNT w ere interviewedseparately. HALL stated that the liquids seized during the search wanunt did not containmethnmphetamine, as they were left over from previous tccooks''. HALL stated that he obtainedhis m etham phetam ine primarily from CtBUDDHA'' aka Tim GERACE. HALL stated that RickSHAW was a big m ethamphetam ine supplier from TN .

On October 31, 2013 CS-9 was interviewed in Abingdon, VA . CS-9 stated he/she m etRick SHAW three to fotlr years ago through Angela SURBER and Danny REECE. CS-9 statedthat he/she had witnessed SHAW distribute m ethamphetamine on num erous occasions. CS-9

11


stated SHAW told him/her to never speak openly about meth but to speak in code whentalking/texting on the phone. CS-9 stated SHAW sold methamphetamine out of his garage.

(On November 19, 2013, CS-7 was interviewed in Coeburn, VA. CS-7 stated that in

September 20l 3, he/she was present at the residence of Rick SHAW in M ountain City, TN whenthe person he/she was with received methamphetamine from Rick SHAW .

On M arch 7, 2014 the affiant traveled to the Carter County, Tennessee Courthouse in anattempt to speak with a Haley Herd believed to the ex-girlfriend of Rick SHAW . W hile presentin the courtroom the afsant observed Herd sitting behind M elvin CAM PBELL and Rick SHAW(CAMPBELL and SHAW were arrested in Carter Cotmty, Tennessee on December 7, 2013 aftera domestic incident with the Herd). The affiant identified himself to Herd and asked to speak toher about her relationship with SHAW . Herd then provided her cell phone and agreed to speakwith the aftiant on later date.

On M arch 12, 2014 CS-8 contacted the affiant after attempting to order 1 .0 grams ofmethamphetamine from Jim GRINDSTAFF at the direction of 1aw enforcement. CS-8 stated JimGRW DSTAFF had contacted hinfher about ptlrchasing methamphetamine. GRINDSTAFFstated a DEA agent had contacted SHAW 'S girlfriend at the Carter County Courthouse and wasasking questions about SHAW . GRW DSTAFF stated SHAW had moved a11 of his drugs to hisresidence until things cooled down. GRINDSTAFF stated SHAW may not make a rtm to pick upmethamphetamine this month so if CS-8 wanted methamphetamine he/she should come soon.GRINDSTAFF added that SHAW was making approximately $50,000.00 a month from illegaldrug transactions.

On M arch 25, 2014 Carter Cotmty, Tennessee Sheriff s Deputy M yles Cook advised thathe arrested SHAW and M elvin CAM PBELL on December 7, 2013 near the intersection ofW haley Town Road in Butler, TN. During the arrest SHAW stated to COOK that the tw o storyresidence located at the intersection of Highway 159 and W haley Town Road was his residence.Cook stated that he had recently arrested Herd for tiling a false police report after she hadrecanted her prior statements made during SHAW 'S arrest on December 7, 2013. Cook advisedduring her arrest Herd stated that she and SHAW were arguing over methamphetnmine dtlringthe December 7, 2013 incident.

M elvin Glen CAM PBELL

On December 22, 2009, a traftic stop was executed on a vehicle operated by RichardSHAW in Anderson County, SC. Pursuant to a search of the vehicle, approximately one (l)pound of methamphetamine was seized. SHAW and his passenger, M elvin Glen Campbell, werearrested and charged with trafficking metham phetam ine. As a result of the investigation SHAWand CAM PBELL were convicted of Attempt and Conspiracy Provisions Dnzg Law and receiveda five year suspended sentence and five years probation.

According to the records of Verizon Wireless, telephone number (423) 557-2246 wassubscribed to by Robin Ensor at 1 195 Dry Creek Rd., Elizabethton, 'FN. As a result of this

12


investigation, your affiant believes that the primary user of the telephone was M elvin GlenCAM PBELL.

(1n November 2013, 1aw enforcement executed a search warrant on the cellular telephoneof a known methamphetamine distributor in Abingdon, VA. Contained within the Contacts Listof this cellular telephone was the name Glen CAMPBELL with telephone number (423) 557-2246.)

On April 23, 20l 3, a seazch warrant was applied for and obtained in the W estern District

of Virginia for text messages stored in the accounts of several cellular telephone numbers,including those of Danny REECE and Rick SHAW . ln response to the execution of this search

warrant on Verizon W ireless, agents received text messages stored in those accounts from April9 to April 23, 2013. The following is an except from the search warrant results.

April 10, 2013

Danny REECE to Itick SHAW , GGlkxt me when u get upplease need to see ya andl'llbringyr culvertpipe /05'SHAW to REECE, Gi1 'm at Courtney''REECE to SHAW , inïkhen be in.?''SHAW to REECE, iil-onight''REECE to SHAW , 1210-4 text me as soon as you... thanks r/tzn''

REECE to Glen CAM PBELL, Giliey man this is Danny can you text me Big Jims no Idon 't àtwé' it in my new phone.''CAM PBELL to SHAW , GQl-ley call me when ya get up n goin''

REECE to James GRINDSTAFF, iGliey man this is Danny. Is this Big Jims no. ?''GRINDSTAFF to REECE, SIFEJ this is Big Jim'tREECE to GRW D STAFF, iillog not home can you /lc/#?''GRINDSTAFF to REECE, LGyeah Iam goodlam getting out in about an hour or so uwtzn/ me to run by''REECE to GRINDSTAFF, ikf 'm up here on the ?7pw bypass wtu headed to Dtownpullin atrailor can u meet me at Doc Talors Vet Of/ic: Iv already turnd rtltfntf'GRW DSTAFF to REECE, LGok give me 10 min what do u ncptf'REECE to GRINDSTAFF, ççcouple''GRINDSTAFF to REECE, çiok 1 will split the dfference with u it will be 220 be there inafew min t?/c''

CAM PBELL to SHA W , Gçïkrhat time ya thinkya be home/''SHAW to CAM PBELL, *%5 or &'

Based on m y training and experience, and my knowledge of this investigation, l believethat Dnnny REECE utilized the text messaging service on his cellular telephone to ascertain thelocation of Rick SHAW in an effort to obtain methamphetam ine. l believe that SHAW advisedREECE that he was at his sister Courtney's house, and REECE contacted Glen CAM PBELL to

13


get in touch with Jnmes GRINDSTAFF to ptlrchase the methamphetamine. 1 believe thatCAM PBELL eontacted SHAW directly to ascertain a time for his return.

April 17, 2013

(423) 440-5203 to Rick SHAW , *Q1 know 1 ()w: u money 4 the tires and Im sorry, 1 willpay u soon as 1 can. 1ts not my intention that Glen wtpr/c it off.ok? Its not him who tpwps',only me. Sorry t?/c''SHAW to (423) 440-5203, i*l'm cool dose he no u tlwc''(423) 440-5203 to Rick SHAW , CIFCJ, cuz I went to his house that night straight J/cr 1got the tires 2 share....ofcourse then 1 gotfuknhred n thats where my money cameh'omlol''SHAW to (423) 440-5203, tûA'''

Based on my training and experience, and my knowledge of this investigation, I believethat the user of telephone number (423) 440-5203 (believed to be Heather Rae Ranck) utilizedthe text messaging service on her cellular telephone to discuss a drug debt owed to Rick SHAW .I believe that SHAW and Heather Ranck discussed Glen CAM PBELL'S knowledge of the debtand his use of the methamphetamine (tttires'').

April 19 - 20, 2013

Glen CAMPBELL to Rick SHAW, GiGona stop n holler at ya fok? Wont stay long. 1know ya got companyttCAMPBELL to SHAW, içNever heardfrom ya. Iprob head back home''CAMPBELL to SHAW , %Guqre ya home? I'fzrtz.ç gona tryya one more time b4 1 went to Eliz.Me n boys got busy schedule next 2 days''CAMPBELL to SHAW , çiReally could use ya /7c#7. Holler f/'ytz get down this wly''SHAW to CAMPBELL, %ilhis is Torainna Ricksphone kept going offljust ntpw Iookedat it sorry ..but tzn

-vwtzy.ç seen it wash'om u do ya need me to get Rick up or something',CAM PBELL to SHA W , i*No 1* holles later but thanks''SHAW to CAM PBELL, i;K lol this is Glen right?''

Based on m y training and experience, and my knowledge of this investigation, l believethat Glen CAM PBELL utilized the text messaging service on his cellular telephone in an attemptto contact lkick SHAW . 1 believe that CAM PBELL was attem pting to obtain m ethamphetam inefor himself and others with whom he worked. l believe that SHAW 'S girlfriend, TorrainaAschenback, responded to CAM PBELL on SHAW 'S phone.

On M arch 25, 2014 Carter County, Tennessee Sheriff s Deputy M yles Cookadvised that he arrested SHAW and M elvin CAM PBELL on December 7, 2013. During thearrest SHAW stated to Deputy Cook that the two story residence located at the intersection ofHighway 32 1 and W haley Tow'n Road was his residence. Cook stated that he had recentlyarrested Herd for tiling a false police report after she had recanted her prior statem ents m adeduring SHAW 'S arrest on Decem ber 7, 2013. Cook advised during her arrest Herd adm itted thatshe and SHAW were arguing over methamphetamine during the December 7, 2013 incident.

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Jam es Carl GRINDSTAFF

ln 2005 GRIND STAFF plead guilty to the offense of sim ple possession of schedule 11substance aher being arrested for drunkenness, simple possession of a schedule 11 substance, andillegal possession of a weapon. GRINDSTAFF also have prior an-ests for driving under the

St d 2nd ffense and aggravated dom estic assault.influence 1 an o

According to the records of TracFone, telephone number (423) 431-8498 was subscribedto by Tim Grindstaff at 1022 Justus Dr., Johnson City, TN with a date of birth of 10/31/1976.According to the records of Thomas Reuters (credit database), James Carl GRINDSTAFF hasutilized this address between 2002 and 2013. As a result of this investigation, your affiantbelieves that the prim ary user of this telephone was James GRINDSTAFF.

According to the records of TracFone, telephone number (423) 483-813 1 was subscribedto by Brenda Gaither at 1022 Justus Dr., Johnson City, TN with a date of birth of 10/31/1976.As a result of this investigation, your affiant believes that the prim ary user of this telephone wasJam es GRINDSTAFF.

(On December 5, 2013, CS-8 positively identified a photograph of James CarlGRINDSTAFF as his/her methamphetamine source of supply known as iiBig Jim''. CS-8 statedthat çtBig Jim's'' cellular telephone number was (423) 483-8131.)

On April 23, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text m essages stored in the accotmts of several cellular telephone numbers,

including those of Danny REECE and Rick SHAW . ln response to the execution of this searchwarrant on Verizon W ireless, agents received text messages stored in those accounts from April

9 to April 23, 2013. The following is an excerpt from the search warrant results.

April 10, 2013

Danny REECE to Rick SHAW , iilnext me when u get up please need to see ya and 111bringyr culvert pipe to''SHAW to REECE, Qil'm at Courtnef'REECE to SHAW , GGïkhen be in/''SHAW to REECE, â*l-onightt,REECE to SHAW , 1610-4 text me as soon as you...thanks man''

REECE to Glen CAM PBELL, içbley man this is Danny can you text me Big Jims no 1don 't have it in my new phone.''CAM PBELL to REECE, G*liey call me when ya get up n gt?f?7''

REECE to Jam es GRINDSTAFF, iiHey man this is Danny. Is this Big Jims no. ?''

15


GRW DSTAFF to REECE, (CJ'C,& this is Big Jim''REECE to GRINDSTAFF, Gillog not home canyou Jle/#?''GRINDSTAFF to REECE, G*kkah 1 am good I am getting out in about an hour or so uwant me to run by''REECE to GRINDSTAFF, çnl'm up here on the ncw bypass wtu headed to Dtownpullin atrailor can u meet me at Doc Talors Vet O//icc iv already turnd rtpt/ntf'GRINDSTAFF to REECE, çnokgive me 10 min what do u acctf'REECE to GRINDSTAFF, içcouplet'GRINDSTAFF to REECE, içok 1 will split the dp rence with u it will be 220 be there inafew min tp/c''

Based on my training and experience, and my knowledge of this investigation, I believethat Danny REECE utilized the text messaging service on his cellular telephone to ascertain thelocation of Rick SHAW in an effort to obtain methamphetamine. l believe that SHAW advisedREECE that he was at his sister Courtney's house, and REECE contacted James GRINDSTAFFto purchase the methamphetamine.

On October 31, 2013, CS-9 was interviewed in Abingdon, VA. CS-9 stated he/she metRick SHAW tllree to four years ago. CS-9 stated that Jim GRINDSTAFF aka Sûllig Jim'', RustyCASSELL, Danny REECE, and his girlfriend Linda W ALTERS distributed methnmphetaminefor SHAW . CS-9 stated he/she had seen GRW DSTAFF with an 8 inch x 4 inch brick ofm ethamphetam ine on two separate occasions in the past.

On December 5, 2013, CS-8 was interviewed in Abingdon, VA. CS-8 stated that he/shehad purchased one (1) gram of methamphetamine from lkBig Jim'' on at least five (5) occasionsin the last year. CS-8 stated that ûiBig Jim'' took him /her to his m etham phetam ine supplier'sresidence. CS-8 positively identified Rick SHAW 'S residence of 382 T-Greer Road, M ountainCity, Tennessee as the location. CS-8 positively identified a photograph of James GRINDSTAFFas SûBig Jimv'' CS-8 stated that CtBig Jim's'' cellular telephone number was (423) 483-8131.

On January 17, 2014, CS-8 purchased one (1) gram of crystal methamphetamine fromGRINDSTAFF from his residence located at 233 Pedro Shouns Lane M ountain City, TN locatedin Doe Valley Trailer Park. During the transaction CS-8 stated he/she had trouble finding them eth so GRW DSTAFF entered the bedroom and pulled out a box containing between 25-50

individual clear baggies containing what appeared to be crystal methamphetamine. CS-8 advised

each bag looked just like the bag she purchased and provided to the affiant. CS-8 stated he/sheobserved two guns on the bed, one of which appeared to be an AK-47 style ritle. There were two

gun safes in the bedroom, a tall one that contained rifles and shotguns and a smaller one thatcontained handguns. According to CS-8 each safe contained approximately five long guns andfive handguns. An assortment of am mo was also observed in the bedroom . CS-8 statedGRINDSTAFF also had a Beretta pistol visible in his back lef4 pocket during the transaction.

16


On March 7, 2014 the affiant traveled to the Carter County, Termessee Courthouse in anattempt to speak with Haley Herd believed to the ex-girlfriend of Rick SHAW . W hile present inthe courtroom the affiant observed Herd sitting behind M elvin CAM PBELL and Rick SHAW(CAMPBELL and SHAW were arrested in Carter County, Tennessee on December 7, 2013 aftera domestic incident with Herd). The affiant identified himself to Herd and asked to speak to herabout her relationship with SHAW . The female then provided her cell phone and agreed to speakwith the affiant on a later date.

On M arch 12, 2014 CS-8 contacted the affiant after attem pting to order l .0 gram s ofmethamphetamine from GRW DSTAFF at the direction of law enforcement. CS-8 stated JimGRINDSTAFF had contacted him/her about purchasing methamphetamine. GRINDSTAFFstated a DEA Agent had contacted SHAW 'S girlfriend at the Carter County Courthouse and wasasking questions about SHAW . GRINDSTAFF stated SHAW had moved a11 of his drugs toGRINDSTAFF'S residence until things cooled down. GRINDSTAFF stated SHAW may notm ake a nm to pick up m ethamphetam ine this m onth so if CS-8 wanted m ethamphetam ine he/sheshould come soon. GRINDSTAFF added that SHAW was making approximately $50,000.00 am onth from illegal drug transactions.

D aniel Shane REECE

Dnnny REECE has two prior felony convictions for possession of a controlled substance.

On September 24, 2007, Daniel Shane REECE was arrested in possession of over four (4)grams of methamphetam ine.

On January 13, 2008, Daniel REECE was arrested in possession of $2,552.00 U.S.Currency and methamphetamine residue.

On M arch 30, 2009, a search warrant was executed at the residence of Christy DeniseAdams in Marion, VA. Seized pursuant to the search warrant was over one (1) ounce ofmethamphetamine, packaged for distribution. Adams was arrested for possession with the intentto distribute methamphetamine. Seized f'rom Adams' vehicle was over $ 12,000.00 U.S.Currency. The sole occupant of the vehicle at the tim e of seizure was Daniel Shane REECE.

According to the records of Verizon W ireless, telephone number (423) 297-5395 wassubscribed to by Dwayne Pruitt at 31529 O1d Stage Rd., Glade Spring, VA. This phone wasactive from October, 2012 tmtil M arch 17, 2013. As a result of this investigation, your affiantbelieves that the prim ary user of this phone num ber was Danny REECE, a distributor of crystalm etham phetam ine for Rick SHAW in M ountain City, TN and Dnm ascus, VA.

According to the records of Verizon W ireless, telephone number (423) 895-5732 wassubscribed to by Dwayne Pruitt at 31529 Old Stage Rd., Glade Spring, VA. This phone wasactive from M arch 20, 2013 until at least July, 2013. As a result of this investigation, youraffiant believes that the prim ary user of this phone number was Dnnny REECE.

According to text m essages received via search warrants, a m ale nam ed isDanny'' was theuser of both listed telephones. According to the text m essages, çsDnnny'' lived in M otmtain City,

17


TN, but spent tim e on property also occupied by Rusty CA SSELL and dated a fem ale nam edSslvinda''. Agents were aware that Rusty CASSELL lived on property owned by Danny REECEat 21504 Fisher Hollow Rd., Dam ascus, VA and that Danny REECE and Linda W ALTERS wereinvolved in a romantic relationship.

On April 10, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text messages stored in the accounts of several cellular telephone num bers,including that of Roger LAW SON. ln response to the execution of this search warrant onVerizon W ireless, agents received text messages stored in that account from April 1 to April 10,2013. The following is an excep t from the search warrant results.

April 2, 2013

Toby MOCK to Roger LAW SON, iiDid u ever decide fu wcr: gona go to themkt/jntoby (.W'LAW SON to MOCK, QiNot sure. J/'f do 111 call ?z.5'

LAW SON to Dnnny REECE, GQGonna be in D Ftpwa today/''REECE to LAW SON , çGHere now''LAW SON to REECE, iican I ask how long u will be there/t'REECE to LAW SON, i%4 or 5 hrs but I don 't katlw fthparts will last that long/''LAW SON to REECE, içcan u hang on to at least 3. 111 be there shortly''REECE to LAW SON , SsT'ry my best''LAW SON to REECE, *LOk.''

LAW SON to M OCK, çnGetting ready to go to the market. Be ur wJy unless u can meetme in Glade.t'

LAW SON to REECE, iisave me at least 3.'%

Based on my training and experience, and my knowledge of this investigation, I believethat Roger LAW SON utilized the text messaging service on his cellular telephone to obtainmetham phetamine from Danny REECE for resale to Toby M OCK.

April 5, 2013

Toby M OCK to Roger LAW SON, iLïk-en u goin to the mkt? Eddie here and wanted to

sendfor somepaintintobyO 'tLAW SON to MOCK, Q%can go anytime but wait couple ofhrs. Callyal.''M OCK to LAW SON, *i1 got somebody else bringing me sum $ over to I ned to send withyaàntobyk '

Danny REECE to LAW SON , GiETA/''LAW SON to REECE, iils 11:30 to late/''REECE to LAW SON, iiBe (7/c''LAW SON to REECE, çilhanks''

18


IN THE UN ITED STATES DISTRICT COURT FOR THEW ESTERN DISTRICT OF VIRGFNIA

Abingdon Division

IN THE MATTER OF THE ARRESTSOF RICHARD SHAW ET AL

UNDER SEAL

Case N o.

AFFIDAVIT IN SUPPORT OFCRIM INAL COM PLAINTS. ARREST AN D SEARCH W ARRANTS

1, Jonathan A. Tabor, Special Agent, United States Department of Justice, Bureau of Alcohol,Tobacco, Firearms, and Explosives, being duly sworn, do depose and state as follows:

INTRODUCTION

I am a Special Agent (SA) with the Bureau of Alcohol, Tobacco, Firearms andExplosives (ATF) and have been employed for approximately four years. Prior tobecoming an ATF Agent l served as a State Trooper with the W est Virginia State Policefrom 2003-2009. l have received training at the W est Virginia State Police Academy,Federal Law Enforcement Training Center (FLETC), and the ATF National Academy.During my training at FLETC and the ATF National Academy I received specializedtraining in the Controlled Substances Act, Title 21, United States Code, including, but not

limited to Sections 841 (a)(1) and 846 (Conspiracy and Controlled Substance Violations),criminal organizations engaged in conspiracies to manufacture and/or possess with intentto distribute cocaine, methamphetamine, marijuana and other dangerous drugs prohibitedby law, search and seizure law , and many other facets of drug law enforcement.

During my tenure in law enforcement, 1 have become familiar with the methods andtechniques associated with the distribution of narcotics, the latmdering of drug proceedsand the organization of drug conspiracies. In the course of conducting theseinvestigations, yotlr affiant has been involved in the use of the following investigativeteclmiques: interviewing confidential sources and cooperating witnesses; conductingphysical surveillance, controlled buys; consensual monitoring and recording of bothtelephonic and non-telephonic com munications', conducting court-authorized electronicsurveillance. Further, I have participated in the preparation, presentation and execution ofnum erous search and arrest warrants which have resulted in the recovery of weapons,narcotics, m oney and docum entary evidence indicative of firearm and narcotic traffickingorganizations. Additionally, l have assisted in investigations and arrests leading toconvictions for violations of federal and state firearm and narcotics laws.

1


MOCK to LAW SON, çiWherya at/àntoby @ 'LAW SON to MOCK, iuust kiddin on our wtzy.''MOCK to LAW SON, Giokey dokey...yal b carefuljntoby @'LA W SON to M OCK, ççft'''

M OCK to LAW SON, %iR yal close? qntoby f7'LAW SON to M OCK, CtF:.C at Bub '.ç''M OCK to LAW SON, iiHave yal /c

.# Bub 's yetjntoby tkp'LAW SON to M OCK, *iI 'm down at Kenny 's. Bub 's got t/r5'.''

Based on my training and experience, and my knowledge of this investigation, I believethat Roger LAW SON utilized the text messaging service on his cellular telephone to obtainmethamphetamine from Danny REECE. l believe LAW SON in turn sold the methamphetamineto Toby M OCK after stopping at Bubba BUCHANAN'S and Kenny Forrester's residences.

On April 1 1, 2013 M gela SURBER was interviewed in Bristol, Virginia. SURBERstated she smoked metham phetam ine with Roger LAW SON at his house when he lived in GladeSpring, Virginia. LAW SON also gave m ethamphetam ine to SURBER to deliver to his daughter.

SURBER stated around 2009-2010 she m oved in with Danny REECE. SURBER advisedafter living with REECE for two months, REECE asked if SURBER would give him a ride toM ountain City, TN to obtain meth from Rick SHAW . SURBER stated she and REECE went toSHAW 'S to purchase meth approximately once a week for eight w eeks. SURBER stated REECEobtained a Sktistful'' size of meth each time from SHAW . SURBER advised most of the dealswith SHAW occurred at this house but one deal occurred at a property SHAW owned in Butler,TN.

On April 23, 2013, a search warrant was applied for and obtained in the W estern District

of Virginia for text messages stored in the accotmts of several cellular telephone num bers,including those of Danny REECE and Rick SHAW . In response to the execution of this searchwarrant on Verizon W ireless, agents received text m essages stored in those accounts from April

9 to April 23, 20 13. The following is an excerpt from the search warrant results.

April 10, 2013

Danny REECE to Rick SHA W , iilkxt me when u get upplease need to see ya andl 'llbringyr culvertpipe to''SHAW to REECE, QL1 'm at Courtney',REECE to SHAW , çâïk-hen be in/''SHAW to REECE, iiTonight''REECE to SHAW , 1610-4 text me as soon as you... thanks ?A)la''

REECE to Christy Adams, çiWhtz upfeel like meetin me in Fisher Hollor in couple hrs. ?''

REECE to Johnny Osborne, incan u spare any cofpp?''Osborne to REECE, iillon 't have lzl7b/lnzky''

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REECE to Osborne, iiliate to bother u again but do have elains no she gave it to me butL inda must have erased it or Big Jims no''

REECE to Glen CAM PBELL, iiHey man this is Danny can you text me Big Jims no 1don 't have it in my ncw phone.t,CAM PBELL to REECE, GGl-ley call me when ya get up n gtpfn''

REECE to Jam es GRINDSTAFF, Q*l-ley man this is Danny. Is this Big Jims no. ?''GRINDSTAFF to REECE, CtFCJ this is Big Jim''REECE to GRIND STAFF, i%ltog not home can you help/t'GRINDSTAFF to REECE, iik-eah 1 am good 1 am getting out in about an hour or so uwant me to run by''REECE to GRW DSTAFF, i*1 'm up here on the ncw bypass wtzs' headed to Dtownpullin atrailor can u meet me at Doc Talors Vet O//cc iv already turnd rounl'GRINDSTAFF to REECE, ç*Ok give me 10 min what do u ncetf'REECE to GRIND STAFF, incouple''GRINDSTAFF to REECE, ;(Ok 1 will split the dfference with u it will be 220 be there inafew min ta/c''

LAW SON to REECE, ç*vjre u gonna be in D lbwn today ''

REECE to LAW SON, çilfl can get some tires I will be. 111 letyou no asap''LAW SON to REECE, iiok //2J?7/o'''

REECE to Adams, 6iI 'd sure like to try that Folgers :rJn#/''Admns to REECE, içï'vhat.l''

Adams to REECE, Gil'm @ work''REECE to Adams, iGDamm till when/''

Admns to REECE, ç*probably wonf be offtill 12..30'%REECE to Adams, 1*10-4 1 'll hollor back f/7 canfnd aph charger its bout Jc1tf'Adams to REECE, $;0/6'7

LAW SON to REECE, GGlts Roger myph is screwfup. Did u try to text me? New no. 276206 3398''REECE to LAW SON, ioNo still haven 't heard nothin''LAW SON to REECE, ççvb'o ur not Iikely to be over too soon. Just Iet me krtpw''REECE to LAW SON, içWell im over here but no partf'LAW SON to REECE, Giok thanks.''

SHAW to REECE, **1 'm home''REECE to SHAW , $*10-4 leavin Dlhwn atpw''REECE to kdBubba'' BU CHAN AN, inD idyou an Rodger want to come tonight/''

Based on my training and experience, and m y knowledge of this investigation, 1 believethat Danny REECE utilized the text m essaging service on his cellular telephone to comm unicatewith Rick SHAW , Christy Adam s, Jolmny Osborne, Glen CAM PBELL, and JamesGRINDSTAFF in an effort to obtain m ethamphetam ine. 1 believe that REECE communicated

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with Roger LAW SON who wanted to purchase methamphetamine. 1 believe that REECEeventually purchased methamphetamine from SHAW and sold to LAW SON and BubbaBUCHANAN .

April 11, 2013

Roger LAW SON to Danny REECE, Lilhis is my new no. 276 206 6462 r u gonna in DFtpwn today/''REECE to LAW SON, nckkah in a couple hrs''LA W SON to REECE, iGok thanks''

LAW SON to REECE, çQzqre u in Damascus? Atpgcr''REECE to LAW SON, 1110-4 ETA.?''LAW SON to REECE, çiHow long have 1 got to get there/t'

REECE to LAW SON, içprob be late late before 1 leave'tLAW SON to REECE, Qiok be there about /lr.''REECE to LAW SON, *il0-4,'

April 11 - 12, 2013

Bubba BUCHANAN to REECE, iiliey r u up tex r call me Lcraig N stef'REECE to BUCHANAN, CiETAB''BUCHANAN to REECE, Gi3o/Ncraig N stef'REECE to BUCHANAN , **10-4,'BUCHAN AN to REECE, ènupstairejNcraig N & c

./''REECE to BUCHAN AN , i610/5,tREECE to Christy Adams, iiTalkin to Bub hejus got here 111 text whn he gone''

Based on m y training and experience, and my knowledge of this investigation, I believethat Dnnny REECE utilized the text messaging service on his cellular telephone to sellmethamphetamine to Roger LAW SON and Bubba BUCHANAN.

April 14 - 15, 2013

Bubba BUCHANAN to Danny REECE, ç*U n D r Mtn CàKenny Nstef,REECE to BUCHAN AN , iiout haven 't seen him yett'BUCHANAN to REECE, Lilkx when u do pleez bKenny Nstef'

REECE to Rick SHAW , ç*1 gotta haul this parts truck to Stony Creek an 1 'll be up fyraround?''REECE to SHAW , iion wtz-p nrlw to yr house''SHAW to REECE, i$f 'm in Boone back soon''REECE to SHAW , LiI 'lI have to go tpn''SHAW to REECE, **Ok c u later text when u get #tzck''

REECE to BUCHANAN , iGl0-4 good to goo''

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Roger LAW SON to REECE, çnls it ok to stop by. Im in cïry''REECE to LAW SON, GGl0-4''

Based on m y training and experience, and m y knowledge of this investigation, 1 believethat Danny REECE utilized the text m essaging service on his cellular telephone to obtainmethamphetamine from Rick SHAW . 1 believe that REECE sold the methamphetamine toRoger LAW SON and Bubba BUCHANAN.

April 16, 2013

Roger LAW SON to Danny REECE, ûi# u in D lnown today/''REECE to LAW SON, GQWhile it lastl Yeah DTown''

LAW SON to REECE, iGuqre you still there fso I 'll b there in 20 mins''REECE to LAW SON, iilreahb'LAW SON to REECE, iiok''

LAW SON to REECE, %iR u still there? I need 1 more tirefor my trailer''

Based on my training and experience, and my knowledge of this investigation, l believethat Roger LAW SON utilized the text messaging service on his cellular telephone to purchasemetham phetam ine from Danny REECE on two separate occasions on the snme date.

April 17, 2013

Rick SHAW to Danny REECE, inlieaded home''REECE to SHAW, içon wJy do u need nethingfrom town/''SHAW to REECE, QiDrink''

Roger LAW SON to REECE, çëvjre u n D Ftpwn tonight''REECE to LAW SON, iûcj/y''REECE to LAW SON, içGotparts''

Based on my training and experience, and m y knowledge of this investigation, 1 believethat Danny REECE utilized the text m essaging service on his cellular telephone to obtainm ethamphetam ine from Rick SHAW and sell it to Roger LAW SON .

April 19, 2013

Rick REECE to Danny SHAW , LGWillyou be around tonight/'tSHAW to REECE, CQNO sorry''

Bubba BUCHANAN to REECE, iiEver hear n e thing Xenny N Stef'REECE to BUCHANAN , ççl'le went to the Rodrun nothing''BUCHANAN to REECE, Ck. . .l0-4$NKenny Nstef,

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April 20 - 21, 2013

REECE to SHAW , iGliave you got any ideal what time you will be /lo-e?''(423) 707-5321 to REECE, inlfand whenpossible can you double my regparts order//7/c-&''REECE to (423) 707-532 l , *iDude is gone to Rodrun?/''(423) 707-5321 to REECE, iisheeeotl''

(423) 534-7673 to REECE, tûU'z@''REECE to (423) 534-7673, GGltude is gone to the Rod Run.home''

Don 't know when he will be

BUCHANAN to REECE, LiNow wvî//: up WKenny N Stef,REECE to BUCHANAN , GQNothin he still aint /lo?>le?''BUCHANAN to REECE, inlkx me when NKenny Nstef'

LA W SON to REECE, çGvlre u gonna be in D lhwn today.J''REECE to LAW SON, içFwd.. Dude is gone to the Rod Run don 't no when he will behome.J''

LAWSON to REECE, çiAll 1 need is a 50 lb. bag ofdogfool,

REECE to SHAW , içl-lave you got any ideal what time you will be home/''

BUCHANAN to REECE, çiWhat 's the word WKenny Nstef'REECE to BUCHANAN, iiNothin/'t

SHAW to BU CHANAN, i%30min,t

REECE to SHAW, GiTeeenfourrrr on wayj'om Dl-own''

REECE to BUCHANAN, iiHow much cash u got on hand/''BUCHANAN to REECE, *2160 XKenny Nstef,REECE to BUCHANAN, içblow quik can u get to river bridge/''BUCHANAN to REECE, *120 n route ntpw XKenny Nstef'

LAWSON to REECE, %iOk fl come over nt?w?''REECE to LAW SON, nnjmeahfor a lilt'LA W SON to REECE, Gnok Im Ieavin Saltville nöw.''LAW SON to REECE, çiBe there in 20 mins''REECE to LA W SON, ';7p-#''

Based on m y training and experience, and m y knowledge of this investigation, I believethat Danny REECE utilized the text m essaging service on his cellular telephone to obtainm ethamphetam ine from Rick SHAW and sell it to Roger LAW SON and Bubba BUCHANAN.

23


On M ay 8, 20l 3, a search warrant was applied for and obtained in the W estern District of

Virginia for text messages stored in the accounts of several cellular telephone numbers, includingthose of Danny REECE, Rick SHAW and Roger LAW SON. ln response to the execution of thissearch warrant on Verizon W ireless, agents received text messages stored in those accounts fromApril 26 to M ay 8, 2013. The following is an excerpt from the search warrant results.

M ay 1, 2013

Toby M OCK to Roger LAW SON, GiHave u heard anything?jntoby @ 'LA W SON to M OCK, GnNotyet''M OCK to LAW SON, çx bntoby (.W'

LAW SON to Dalm y REECE, çGu gonna be in D F/wn today/''REECE to LAW SON, içlétn c@ ''LAW SON to REECE, iiok thanks.t'LAW SON to REECE, iiok to stop by later/''REECE to LAW SON, iç10-4,'LAW SON to REECE, çiOk''

Based on my training and experience, and my knowledge of this investigation, I believethat Roger LAW SON utilized the text messaging service on his cellular telephone to obtainmethamphetamine from Darmy REECE and sell it to Toby M OCK.

On August 21, 20l 3, the affiant, while conducting surveillance of the REECE residence,observed REECE exit his residence and walk towards a GM C Yukon bearing TennesseeRegistration E70 31F. A Department M otor Vehicles query reveals Termessee Registration E7031F to be registered to Daniel S. REECE of 1025 W est M ain Street, M ountain City, TN on a1996 GM C Yukon.

On September 19, 2013 the affiant installed a GPS tracking device on the subject vehiclepttrsuant to a federal search warrant obtained through the Eastem District of Tennessee which

authorized the installation of a GPS monitoring device on the subject vehicle for a period of 45days.

Between September and December 2013, surveillance was conducted on the vehicleutilized by Danny REECE (white GMC Ytlkon, TN Registration E70 31F). REECE'S vehiclefrequented the residence of Rick SHAW (382 T Greer Rd., Mountain City, TN) approximatelyevery two (2) to three (3) days during this time period, thirty-one (31) times total in two months.

Linda Louise W ALTERS, aka Linda SLEM P

Linda W alters has prior arrests for assault, worthless checks, thet-t of property over$500.00, leaving the scene of an accident, and driving under the influence of alcohol.

24


On April 1 1, 2013, Angela SURBER w as interviewed in Bristol, Virginia. SURBERstated that she had sold methamphetamine over the years for Danny REECE and others.SURBER stated that REECE'S current girlfriend was Linda LNU (last name unknown) inM ountain City, TN.

According to the records of Verizon Wireless, telephone number (423) 218-7469 wassubscribed to by Nancy Slemp at 1444 Crossroads Dr., M ountain City, TN. According to thefollowing text messages, a female named dslvinda'' was the user of this telephone. According tothe records of Thomas Reuters (credit database), Linda W ALTERS also resided at 1444Crossroads Dr., M otmtain City, TN, Apt. F-2. Based on the results of this investigation, agentsbelieve that this phone was utilized by Linda W ALTERS, the girlfriend and partner of DannyREECE in the distribution of methamphetamine.

On M arch 22, 2013, a search wanunt was applied for and obtained in the W esternDistrict of Virginia for text messages stored in the accounts of several cellular telephones,including that utilized by Roger LAW SON . ln response to the execution of this search wanunton Verizon W ireless, agents received text messages stored in those accounts from February 23 toM arch 22, 2013. The following is an excerpt from the search warrant results.

February 25, 2013

Toby MOCK to Roger LAW SON, Gilt-you go meet Rachael will u holla at me Eddie wnetsomewhere an he may not make it bak n time to go meet herjnlhby''

LAW SON to MOCK, *i1 'vc not heardh'om her.''

MOCK to LAW SON, iiL indajus text me bak and she good ànToby''MOCK to LAW SON, Cirzr: can holla at L inda (/'N want toànlhby''MOCK to LAW SON, iiHow many ofthose rugs did u ned an I can text herbnToby''

LAW SON to M OCK, iibley is L inda gonna be there this evening/''MOCK to LAW SON, içI 'm not sure I haven 't talkd to her anymore since earlier she

probably will lrekonjnlbby'MOCK to LAW SON, *i1 think she is ready ntpw fu were wantin to yell at herjnToby''

LAWSON to Danny REECE, içWill it be ok to stop by @ 6 or 7.?,'REECE to LAW SON, *il0-4 that 'lI 1?:/nc''LAW SON to REECE, Gion tha wtzy, that t?/c3''REECE to LA W SON, L*l0-4''

M OCK to LAW SON, iicall L inda an she saidshe could tellya wher to come /t?lz7F(?:y.',)''LAW SON to M OCK, Giliejust text me.''MOCK to LAW SON, içokbnlhby .')''

M arch 1, 2013

25


LAW SON to Linda WALTERS, inDo u knt?w where Danny is? Jfnof, can u help me?WO#Cr''W ALTERS to LAW SON , Gil'le 'w in th bedl believe. A1l 1 hav is one xtra''W ALTERS to LAW SON , ç*No my apt r u n mc''W ALTERS to LAW SON , iiK Food Lion''LAW SON to W ALTERS, CSFeJ Foodlion ok be right fàcrc''LAW SON to Danny REECE, ioBe there shortly''

Based on my training and experience, and my knowledge of this investigation, 1 believethat Roger LAW SON utilized the text messaging senice on his cellular telephone tocommunicate with Linda W ALTERS in an effort to obtain methamphetamine. l believe thatLAW SON and W ALTERS agreed to meet at the Food Lion to consummate the transaction, thenLAW SON notified Dalmy REECE to 1et him know.

M arch 11 - 20, 2013

Danny REECE to Roger LAW SON, içTe1l her these are .5s. They gofor 2''LAW SON to REECE, iGok. r'lrc 'll take care ofli''

LAW SON to Linda W ALTERS, iiliave u seen Danny/''

LAW SON to REECE, LGzlre u in D ftpwn.''LAW SON to REECE, Gâlley man are u in D fown?''LAW SON to REECE, Qivjre u at home? Need to c z/.''

LAW SON to W ALTERS, ççcan u call me/'tW ALTERS to LAW SON, Qçlfyou need tell me ntaw cause 1 am tlking to him right nt?w an1 will getfor you too''LAWSON to WALTERS, iç1 need at least 1. Is it ok (/'f give TG urph. No. ?''WALTERS to LAW SON, içK 1 canpick one upforyou. FcJ thtshne''LA W SON to W ALTERS, içvjrc yal comin to D town or u already there.?''W ALTERS to LAW SON, **No 1 am not but Dannyprobably will shortly do you want meto tell him so you canjst meet up with him ovr there/''LAW SON to W ALTERS, içYespleaset'W ALTERS to LAW SON , Qil'le ne dwn there in bout 2 hours. A'''

LAWSON to WALTERS, â*1 will need @ 3 I/'/le can bring them. L et me kntpw.''WALTERS to LAW SON, iil-l'e should b ther netime (fyt?z/ hurry an grab him b4 nebdyelse gets ther lol''

Based on my training and experience, and m y knowledge of this investigation, l believethat Roger LAW SON utilized the text messaging service on his cellular telephone tocommunicate with Danny REECE about selling % grams of methamphetamine for $100.00. Ibelieve that REECE stopped using that particular cellular telephone, so LAW SON had to arrangea m etham phetam ine transadion thzough Linda W ALTERS. 1 believe that LAW SON orderedtlzree (3) grams of methamphetamine and arranged to pick it up from REECE in Dnmascus, VA(referred to as $iD Town'').

26


On April 10, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text messages stored in the accounts of several cellular telephone numbers,including those of Danny REECE and Linda W ALTERS. In response to the execution of thissearch warrant on Verizon W ireless, agents received text messages stored in those accounts fromMarch 18 to M arch 27, 2013. The following is an excerpt from the search warrant results.

M arch 20, 2013

Linda W ALTERS to Rick SHAW , GGliey is Danny still there/''SHAW to W ALTERS, tûFc5'''W ALTERS to SHAW , iiWillyouplz hav him to call me b4 he heads back thisaway?t,SHAW to W ALTERS, Cil'c,ç 1 will how r u doing'b

Danny REECE to W ALTERS, 124238955732',REECE to WALTERS, ûkAèw no 1 love you come see me fu wln/. 1 'm bout out Ifyoucould run by hollor l will call an get th t?#.?''

Based on my training and experience, and my knowledge of this investigation, I believethat Linda W ALTERS utilized the text messaging service on her cellular telephone tocomm unicate with Rick SHAW about the whereabouts of Danny REECE. l believe that REECEobtained a new phone number and shared it with W ALTERS. 1 believe that REECE ran out ofmethamphetamine and asked W ALTERS to go to Rick SHAW 'S residence (ishollor'') and pickup some m ore.

M arch 21, 2013

Linda WALTERS to Danny REECE, GGNeed l whole an l J?JI/''REECE to W ALTERS, âLcome Jlcrc''W ALTERS to REECE, iione an qtr all in one #Jg''W ALTERS to REECE, ($.. .hav u tlked to #ïc/c''

W ALTERS to REECE, Lill'e saidhe would he% me out especially (J'f wJl sick an I i'zlt?Joe is lookinfor him ljst thot u might hav tlked to him a could maybe grab a couple b4''REECE to W ALTERS, **No notyet't

REECE to Rick SHAW , :(?''SHAW to REECE, Ckf im home ?zilp''

REECE to W ALTERS, içGota run up th road. Be rt /7/c''

Based on my training and experience, and m y knowledge of this investigation, I believethat Linda W ALTERS utilized the text messaging service on her cellular telephone to order onewhole ounce and one % ounce of m ethamphetam ine for her custom ers. I believe thatW ALTERS asked REECE to m ake contact with Rick SHAW to obtain additionalmethamphetam ine. l believe that REECE contacted SHAW then told W ALTERS that he wasgoing to pick up.

2 7


M arch 27, 2013

Linda W ALTERS to Dalmy REECE, iollid u work at Ricks today''REECE to W ALTERS, iiI got a couple hrs fz7''WALTERS to REECE, iiWht did u do th rest fth /f?nc''REECE to W ALTERS, ççWait on him to go to the garage''WALTERS to REECE, iivqn you didn 't hav enuffmoney to buy me somthin to eat todaybutyou had enuffto get grn?.!''REECE to WALTERS, Lntmuck this goddam shityou supplyh'om now t?n.''WALTERS to REECE, Qiuqndyou are rightfuck this dumb shitjust because you enjoyliving /44 waiting on th r?x/ deal I don 't andl cannot handle lies an bullshitt'REECE to WALTERS, iGWhat gd lies im expecting a texth'om Rodger and I cant get afuckin thg done while thph keeps. . .''REECE to WALTERS, *iI need that 60 before I go to wör/c in th am''W ALTERS to REECE, *GHa1 Perfect example ... u said u gave him to 1:00',REECE to WALTERS, **Well Buba askfor more time and fyr not callin me a lier thentell me qwil wbatyr sayin',W ALTERS to REECE, tW tpw its Buba''

Based on my training and experience, and my knowledge of this investigation, l believethat Linda W ALTERS utilized the text messaging service on her cellular telephone to ascertain ifDarmy REECE went to see Rick SHAW . I believe that REECE was fed up with W ALTERS andtold her to be the metham phetam ine supplier to their customers from now on. I believe thatREECE m entioned two of their custom ers, Roger LAW SON and Bubba BUCHANAN .

Russell W ayne CASSELL, aka ddRustyM CA SSELL

Rusty Cassell has a prior conviction for the m anufacture, sale, possession of a controlledsubstance.

On January 30, 2013 CS-4 was interviewed in Bristol, Virginia. CS-4 stated from 2004-2006 Rusty CASSELL was selling methnmphetnmine at a garage in Glade Spring, Virginia.Through interview s and surveillance CASSELL'S personal residence was identified as 21504Fisher Hollow Road, Damascus, Virginia.

CS-4 stated in the fall/winter of 201 1 he/she and Jason M ULLINAX were gettingapproximately four (4) ounces of meth per week from CASSELL. CS-4 stated this continued forapproximately tive to six months. CS-4 stated he/she was at CASSELL'S every day for fivemonths. CS-4 stated the m ost m eth he/she had ever seen at one tim e at CA SSELL'S residencewas a one gallon zip lock baggy full of meth Ciice''. CS-4 added the m eth was not individuallywrapped. CS-4 stated he/she saw hand to hand deals while present at CASSELL'S residence.

CS-4 stated he/she always paid CASSELL in cash and had seen approximately $7,000.00in his wallet on one occasion. CS-4 stated he/she paid CASSELL $200.00 for an eight ball (3.5

28


Through instruction and pm icipation in investigations, your affant has becomefamiliar with the manner and methods by which narcotics traffickers conduct their illegalbusiness and the language and tenus that are used to disguise conversations about theirnarcotics activities. From experience and training, your affiant has learned, among otherthings, that in conversations narcotics traffickers believe susceptible to interception, theyvirtually never expressly refer to methamphetamine or other illegal drugs by name;instead to conceal the true nattzre of their illegal activities and to thwart detection by lawenforcement, they refer to the drugs and drug quantities using seemingly innocent terms.Further, based upon your aftiant's knowledge, training, experience and participation infirearm and narcotic trafficking investigations, yotzr afEant knows that: lndividuals whodeal in illegal controlled substances maintain books, records, receipts, notes, ledgers, bankrecords, money orders, electronic files/data, computers and papers relating to theimportation, manufacture, transportation, ordering, sale and distribution of illegalcontrolled substances. These books, records, receipts, notes, ledgers, bank records, moneyorders, electronic tiles, computers, etc., are maintained in locations to which the dealers inillegal controlled substances have ready access, such as within their residences and thesunounding curtilage; their vehicles', the residences of fam ily members, friends andassociates', the places in which they conduct their drug distribution activities, such as stashhouses or safe houses; in business locations with which the trafficker is associated', or instorage areas.

4 . lndividuals who deal in illegal controlled substances routinely conceal large quantitiesof currency, financial instruments, precious metals, jewelry, and other items of value,typically proceeds of illegal controlled substance transactions. lndeed, when drugtraftickers am ass large proceeds from the sale of drugs, they often attem pt to legitim ize or''launder'' these protks. To aceomplish this, drug traffickers may utilize domestic andforeign banks and/or financial institutions and their attendant services, such as sectuities,cashier's checks, money drafts, letters of credit and safe deposit boxes. A11 of these itemsare generally found within their residences and the surrounding curtilage; their vehicles;the residences of family members, friends and associates; the places in which theyconduct their drug distribution activities, such as stash houses or safe houses; in businesslocations with which the trafscker is associated; or in storage areas.

lt is common for individuals who deal in the sale of illegal controlled substances, tosecrete contraband related to the trafficking activity, such as scales, razors, packagingmaterials, eutling agents, cooking utensils, microwave ovens, hair dryers, blenders, pots,dishes and other containers for preparing methamphetamine and other controlledsubstances for distribution, within their residences and the surrounding curtilage; theirvehicles; the residences of family mem bers, friends and associates; the places in whichthey conduct their drug distribution activities, such as stash houses or safe houses', inbusiness locations with which the trafticker is associated', or in storage areas.

lndividuals who deal in the sale and distribution of controlled substances com m onlym aintain telephone numbers and address books or papers which reflect nam es, addressesancl/or telephone numbers for their associates. These individuals often utilize cellulartelephones, pagers and telephone system s to maintain contact with their associates in their

2


gms) of meth. He/she stated most other people paid $350.00. CS-4 stated in February 2012he/she was present at CASSELL'S when GERACE brought meth to CASSELL. CS-4 stated hej saw GERACE hand CASSELL a quantity of meth.

According to CS-4, CASSELL was providing approximately one (l) ounce of meth perweek to Bubba BUCHANAN for approximately five to six months.

Between February 4, 2013 and February 7, 2013 CS-4 met with Timothy GERACE.W ords to the effect of the following were stated:

GERACE said he has not talked to Rusty (CASSELL) lately because he owes him over$1000 so CASSELL is dodging him. CASSELL is getting his meth from Devanna(BOARDWINE). GERACE said he thinks he can get away with not paying him. GERACE saidhe gave CASSELL the chance to make the money back hundreds of times and he could not dothat.

According to the records of Verizon Wireless, telephone number (276) 698-4109 wassubscribed to by Cardinal Travel Center, Nick Lambert, P.O. Box 340, Glade Spring, VA.According to text messages obtained via search warrant, the user of this telephone was a malenamed idRusty'' who had property in common with Danny REECE. According to theW ashington County Sheriff s Office database, Russell ttRusty'' CASSELL resided in a secondhome located on the property of Danny REECE at 21504 Fisher Hollow Rd., Damascus, VA. Asa result of this investigation, your aftiant believes that the primary user of this phone number wasRussell CdRusty'' CASSELL.

On Septem ber 19, 2013 SCSO lnvestigator Prater and W CSO Detective Hazelwood werepresent at the Petro Truck Stop in Glade Spring, Virginia when, at their direction, ATF SA Dukecalled CASSELL'S aforementioned cell phone number. Inv. Prater and Det. Hazelwood observedCASSELL answer the phone call and then put the phone back in his pocket once SA Duke ended

1 the call.

On April 10, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text messages stored in the accounts of several cellular telephone numbers,including those of Danny REECE and Linda W ALTERS. ln response to the execution of thissearch warrant on Verizon W ireless, agents received text messages stored in those accotmts fromM arch 18 to M arch 27, 2013. The following is an excerpt from the search warrant results.

M arch 21, 2013

Danny REECE to Rick SHAW, iilnhis is Danny rlew no. Are you at homefor Jxwp''SHAW to REECE, *GNo b back 4 or J''REECE to SHAW , **10-4 throw me a text w//E'a on wtz-r thanks man''REECE to SHAW, çiNeed l whole an l /7fz#''

REECE to Rusty CASSELL, çil-le aint home yet''CASSELL to REECE, çèWhere is he J/?''

29


REECE to CASSELL, çilie said he would call when he got in bout J or 6probt'CASSELL to REECE, %6He1l. Ok''

REECE to SHAW , t'?''SHAW to REECE, iil'm home mant'

REECE to CASSELL, GnGot help but not ctpznï yr wly till morn.'t

M arch 23, 2013

REECE to SHAW , ktlbrf be home in bout an hour''SHAW to REECE, inl'm home an 1 will b here... ''

REECE to SHAW , ççl'm on my wayh'om D town zmw''

REECE to CASSELL, QLl-l'ey 1 can get rid of4 but theyjust got $110.00 apeace instead of120.00 can ya do j/?''CASSELL to REECE, iisorry man but im in th hole again cant do it''REECE to CASSELL, Gnok told them 1 would ask u no Afgp/ brother''REECE to CASSELL, LCETA J5''

Based on my training and experience, and my knowledge of this investigation, 1 believethat Dalmy REECE utilized the text messaging service on his cellular telephone to communicatewith Rick SHAW and Rusty CASSELL concerning the distribution of methnmphetamine. lbelieve that REECE asked CASSELL if he could afford to 1et the grams of methamphetaminesell for $1 10.00 instead of $120.00 per gram (the current price for one gram of crystalmethamphetamine).

On April 23, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text messages stored in the accounts of several cellular telephone numbers,including those of Danny REECE, Rick SHAW and Rusty CASSELL. ln response to theexecution of this search wan'ant on Verizon W ireless, agents received text messages stored inthose accounts from April 9 to April 23, 2013. The following is an excerpt from the searchwanunt results.

April 14, 2013

Rusty CASSELL to Danny REECE, nuust making sure it wl.& u up there''CASSELL to REECE, i*zqny help''REECE to CA SSELL, iûa4 Iil I wtzs' gettin ready to leave do you wlnf me to come by/''CASSELL to REECE, inlhe ol man Tom needs some help wls' w:y I wJ: asking. l'bz/ canhave my big screen f/'zf want it also.''REECE to CA SSELL, GD on 't need it. Can you cover him cause 1 need to gtp.?''CA SSELL to REECE, $*1 can 't brother. He b tp/c''REECE to CASSELL, iiR u out/''CASSELL to REECE, i*llellya. 1 b ok brother. TTYL ''REECE to CA SSELL, ç*Do you want me to com e down/''

30


CASSELL to REECE, GGhrot fu need to go man. Unless ujust want to... tu(.P'IIEECE to CASSELL, **1 b there in 2 rzl//7''

Based on my training and experience, and my knowledge of this investigation, l believethat Rusty CASSELL utilized the text messaging service on his cellular telephone tocommunicate with Danny REECE. l believe that CASSELL asked REECE if he had anymethamphetamine (1the1p'') because CASSELL had run out and was trying to provide it to Ciolm an Tom ''

April 15, 2013

Rusty CASSELL to Danny REECE, çiU coming over''REECE to CASSELL, iilm am overl''CASSELL to REECE, **U is here',REECE to CA SSELL, d$f is Jz'r''CASSELL to REECE, iils it break time''REECE to CASSELL, Gsends on what u bring me to cJ/''

CASSELL to (772) 225-2484, çGliey olpal u still needing',CASSELL to (772) 225-2484, inl-lello''CASSELL to (772) 225-2484, iiugoing to miss out olpaI...''

Based on m y training and experience, and m y knowledge of this investigation, 1 believethat Rusty CASSELL utilized the text messaging service on his cellular telephone tocommunicate with Danny REECE for the purpose of obtaining methamphetamine. 1 believe thatafter CASSELL obtained the methamphetamine from REECE, CASSELL attem pted to contactone of his drug custom ers.

April 17, 2013

Frankie M adrie to CASSELL, i%bley brother can u help me out tonightpossibly on break@ 9..302 111 make it well worth your while...lhankv manll''CASSELL to Madrie, i*Not unless my buddie comes by brother. 1 been sick man. Guessthat bug goin around...''

Based on my training and experience, and my knowledge of this investigation, 1 believethat Rusty CASSELL utilized the text m essaging service on his cellular telephone tocommunicate with Frankie M adrie. 1 believe that M adrie attempted to obtain methamphetaminefrom CASSELL on his break from work.

As a result of this investigation, agents have learned that Frankie M adrie was involved inthe m anufacturing of metham phetamine with co-conspirator Brady LESTER.

April 19, 2013

Rusty CA SSELL to Danny REECE, içU up',REECE to CA SSELL, ii-lus wo/ce up''

31


CASSELL to REECE, GiBub up there',CASSELL to REECE, Guust pulled z7''CASSELL to REECE, **No whos comin in/',CASSELL to REECE, iGBubba went up hill't

Based on my training and expericnce, and my knowledge of this investigation, I believethat Rusty CASSELL utilized the text messaging service on his cellular telephone toeommunicate with Danny REECE regarding the arrival of Bubba BUCHANAN. 1 know thatCASSELL resides on a multi-home property owned by REECE in Damascus, VA, and believethat CASSELL acts as a lookout for REECE when REECE is there.

April 21, 2013

Danny REECE to Rick SHAW , iil-lave you got any ideal what time you will be home/''SHAW to REECE, çG3ominb'

REECE to SHAW , Qilkeenfourrrr on wayj-om D/bwa''

REECE to Bubba BUCHANAN , iiHow much cash u got on J2Jn#?''BUCHANAN to REECE, 21160 WKenny N Stef,

REECE to Rusty CASSELL, **He is home. U got any cash to go on/''CASSELL to REECE, iildon 't brothert,

Based on my training and experience, and my knowledge of this investigation, 1 believethat Danny REECE utilized the text messaging service on his cellular telephone to communicatewith Bubba BUCHANAN and Rusty CASSELL regarding the purchase of methamphetaminefrom Rick SHA W .

April 22, 2013

Frankie Madrie to Rusty CASSELL, Gâll'ey ole buddy hope u have gotten rid oftht bugyahad last time i talked zujust thought id chek and c fi could come cu mayb bring u sumcash on break n bout 15min i dnt care Ifits afew days or so b4 u can get me tht v6for myold beater ,' can wait (/'z/ dnt mind 2/7:17 me out k thanks ?/kJn''

CASSELL to M adrie, CSFJ itprob b tomorrow b4 i couldget it. You can leave it n the ashtray ofmy suzuki f/'1/ want to. ''

Madrie to CASSELL, $*K sounds good illput it out there shortly then. What would a 3.5runfor my car?''

CA SSELL to M adrie, 1*420,'

Madrie to CASSELL, çilput 240 out there couldn'tjlnd ast tray so iput between seats ncupolder. Thanks van''

32


CASSELL to M adrie, CCA'''

Based on m y training and experience, and m y ltnowledge of this investigation, I believethat Rusty CASSELL utilized the text m essaging service on his cellular telephone tocommunicate with Frankie M adrie. 1 believe that M adrie utilized code to inquire about the priceof an 1/8 ounce of methamphetamine (3.5 grams), to which CASSELL responded $420.00. 1believe that M adrie could not afford the 3.5 grams, so instead lef4 $240.00 for CASSELL toobtain 2 grams of methamphetamine. (Based on my involvement in this case and others, l knowthat the çtstreet value'' of one gram of crystal methamphetamine is $120.00).

On Septem ber 2, 2013 Stephanie PATRICK was arrested with Craig l'Bubba''BUCHANAN in Johnson County, TN for drug related offense after being found in possession ofapproximately 1 1.4 grams of methamphetamine. Following her arrest PATRICK stated toJohnson County, TN Sheriff s Investigators that she picked the methamphetamine up fromsomeone in Virginia earlier and had already sold an eight-ball (3.5 gms) earlier in the evening.PATRICK stated she and BUCHANAN were ttfronted'' the m etham phetam ine and wereattempting to sell it. PATRICK stated she and BUCHANAN went to Cçlkusty' s'Youse. Based onthe affiant's participation in the investigation it's believed that çtlkusty'' is Russell CA SSELL.While at k'Rusty's'' BUCHANAN and PATRICK weighed out an' eight-ball (3.5 gms) of methFand sold it to 'kRusty''. PATRICK stated Stlkusty'' paid her $ 154.00 for the meth.

Kenneth Craig BUCHANAN, aka ddBubba'' BUCHANAN

Craig Buchanan has a prior conviction for the manufacture, sale, possession of acontrolled substance.

On April 3, 2013, CS-4 was interviewed in Bristol, Virginia. CS-4 stated that in latewinter 2009 until April 2010 he/she made and sold 3.5 grams of methamphetamine per week toBubba BUCHANNAN for $350.00.

CS-4 stated that from Septem ber to Novem ber 2012, he/she observed Tim othy GERACE

meet with Bubba BUCHANNAN at his garage in Glade Springs, Virginia and get an 8-bal1 (3.5grams) of methnmphetamine no less than seven times.

On April 1 1, 2013 Angela SURBER was interviewed in Bdstol, Virginia. SURBERstated that she had used methamphetamine with Bubba BUCHANAN and Stephanie PATRICK.According to SURBER, she, PATRICK and BUCHANAN traded methamphetamine with eachother when one another would run out.

According to the records of Verizon Wireless, telephone number (276) 206-0244 wasresold to TracFone with no subscriber inform ation available. According to the following textm essages, the user of this phone was a m ale named iûBubba'' tlKenny'' and dûcraig'' As a result5 *of this investigation, your affiant believes that the primary user of this phone number wasKenneth Craig GtBubba'' BUCHANAN.


On April 23, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text messages stored in the accounts of several cellular telephone num bers,including those of Danny REECE and Rick SHAW . In response to the execution of this searchwarrant on Verizon W ireless, agents received text messages stored in those accounts from April9 to April 23, 2013. The following is an excerpt from the search warrant results.

April 10, 2013

Roger LAWSON to Danny REECE, inlts Roger myph is screwfup. Did u try to text me?New no. 276 206 3398''REECE to LAW SON, *îNo still haven 't heard nothint'LAW SON to REECE, içvb'o ur not likely to be over too soon. Just let me kn/w''REECE to LAW SON , i*WelI im over here but noparts''LAW SON to REECE, içok f/cl?7/o,.''

Rick SHAW to REECE, ânl'm home''REECE to SHAW , ii10-4 leavin D Town nöw''

REECE to Bubba BUCHANAN, GiDidyou an Rodger want to come tonight/''

April 11 - 12, 2013

BUCHANAN to REECE, çiliey r u up tex r call me Lcraig N & c./''

REECE to BUCHANAN , iCETA/''BUCHANAN to REECE, iç3o/Ncraig N steftREECE to BUCHANAN, Qil0-4',BUCHANAN to REECE, GiupstairebNcraig Nstef'REECE to BUCHANAN, *il0/5''

REECE to Christy Adams, iGlnalkin to Bub hejus got here 111 text whn he gtpêlc''

April 14 - 15, 2013

BUCHANAN to REECE, iiU n D r Mtn Cxenny Nstef'REECE to BUCHANAN , içout haven 't seen him yet''BUCHANAN to REECE, içlnex when u dopleez âKenny Nstef'

REECE to SHAW, **I gotta haul thisparts truck to Stony Creek an I 'll be up fyraround/''REECE to SHAW , ç*on wJy ntpw to yr house''SHAW to REECE, iil'm in Boone back soont'REECE to SHAW , iç1'll have to go t?:7'5SHAW to REECE, isok c u later text when u get Atzc/c''

REECE to BUCHANAN , *Q10-4 good to goo''LAW SON to REECE, iGls it ok to stop by. lm in cï/y''

34


REECE to LAW SON, ii10-4''

Based on my training and experience, and my ltnowledge of this investigation, I believethat Danny REECE utilized the text messaging service on his cellular telephone to obtainmethamphetamine from Rick SHAW and distribute it to Bubba BUCHANAN and RogerLA W SON .

April 19, 2013

Danny REECE to Rick SHAW , LiWillyou be around tonight?',SHAW to REECE, iiNo sorry''

Bubba BUCHANAN to REECE, çiEver hear n e thing LKenny Nstef,REECE to BUCHANAN, Lil-le wcnf to the Rodrun nothing''BUCHANAN to REECE, ;(. . .10-4WKenny Nstef'

April 20 - 21, 2013

BUCHANAN to REECE, ttAbw wvzf/: up Wlkknny Nstef'REECE to BUCHANAN, iW othin he still aint home/t'BUCHANAN to REECE, iilkx me when WKenny N Steft

REECE to SHAW , iâliave you got any ideal what time you will be home.?''

BUCHANAN to REECE, iLWhat 's the word WKenny Nstef'REECE to BU CHAN AN , GçNothin/''

SHAW to BUCHANAN , ii-îomin',

REECE to SHAW , Gilkeenfourrrr on wayh'om DTown',

REECE to BUCHANAN, Gillow much cash u got on /Jtz/7#?''BUCHANAN to REECE, **160 WKenny Nstef'REECE to BUCHANAN, içblow quik can u get to river bridge/t'BUCHANAN to REECE, 6120 n route ntaw WKenny Nstef,

Roger LAW SON to REECE, Giok fl come over ntlw?''REECE to LAW SON, QiYeahfor a /ï/''LAW SON to REECE, iGok lm leavin Saltville nt?w.''LAW SON to REECE, ççBe there in 20 mins''REECE to LAW SON , çi10-4't

On M ay 8, 2013, a search wanunt was applied for and obtained in the W estern District ofVirginia for text messages stored in the accounts of several cellular telephone num bers, includingthose of Dalmy REECE, Rick SHAW , Roger LAW SON and Bubba BU CHANAN. In responseto the execution of this search warrant on Verizon W ireless, agents received text m essages stored

35


in those accounts from April 26 to M ay 8, 2013. The following is an excerpt from the searchwarrant results.

April 30, 2013

Bubba BUCHANAN to Danny REECE, Guus wtlkc up have 2 go 2 dmv n the am b ok 2come over then'tREECE to BUCHANAN, içl0-4',

Toby M OCK to BUCHANAN, **R u gona come by A.A u go to work/jntoby .',)''Lauren Allison to BUCHANAN, iiliey (/Z/ still got my 3odollars i got enough to make itl20 fyoudjust txt me or something id like to know whats goin on''Jason M ULLINAX to BUCHANAN, çil-ley w:r u at nt)w.?''

Allison to BUCHANAN, Gilm in emory on wJy to Daisy. J/'zf got that Id like to get it. J/-not 1 canjust get money back it dont matter. Please let me kptpw.''BU CHANAN to Allison, içB there shortly''

M ULLIN AX to BUCHANAN, ççlam atyur hous',

MULLW AX to BUCHANAN, GGRoger here said dont have to gofarl''BUCHANAN to MULLINAX, iiB there Jp''

Based on m y training and experience, and m y knowledge of this investigation, I believethat Bubba BUCHANAN utilized the text messaging service on his cellular telephone to obtainmethamphetamine from Danny REECE. l believe that BUCHANAN then engaged in drugconversations with Toby M OCK, Lauren Allison, and Jason MULLINAX. l believe thatMULLINAX advised BUCHANAN that they could get additional methamphetamine from RogerLAW SON .

M ay 2, 2013

Toby M OCK to Roger LAW SON, çiWill u text Bubba an ask him to call me plez/jntoby1 ,LAW SON to MOCK, ièl'l'e 's been asleepfor hrs.',M OCK to LAW SON, i6Well hell...1 saved mine so 1 could do it with him...1 been tryingto get ahold ofhim all evening... Thankya anm aysjntoby ('i7'

On May 21, 2013, CS-6 was interviewed in W ashington County, VA. CS-6 stated thaton M ay 16 and 1 7, he/she was with Sam ROBBINS while he was attempting to obtainmethamphetamine. CS-6 stated that he/she and ROBBINS received a ride from Tony DELP tothe residence of Bubba BU CHAN AN and Stephanie PATRICK to purchase m ethamphetam ine.CS-6 stated that DELP provided the ride in anticipation of receiving metham phetam ine fromROBBINS.

CS-6 stated that upon arriving at the residence of BUCHANAN and PATRICK , no onewas hom e. CS-6 stated that DELP provided a ride to the residence of Toby M OCK in CountryLiving Estates in Glade Spring, VA . CS-6 stated that eventually, BUCHAN AN and PATRICK

36


anived and gave M OCK a ride to obtain the methamphetamine. CS-6 stated that upon theirreturn, MOCK sold 2 grams of methamphetamine to ROBBINS for $300.00. CS-6 stated thatROBBINS gave % gram of methamphetamine to M OCK for obtaining it, and another % gram ofmetham phetamine to DELP for the transportation.

On September 2, 2013 Stephanie PATRICK was arrested with Craig çsBubba''BUCHANAN in Johnson County, TN for drug related offense after being found in possession ofapproximately 1 1.4 gram s of of methamphetam ine. Following her arrest PATRICK stated toJohnson County, TN Sheriff s Investigators she picked the metham phetam ine up from someonein Virginia earlier and had already sold an eight-ball (3.5 gms) earlier in the evening. PATRICKstated that she and BUCHANAN were tdfronted'' the m ethamphetam ine and they were attemptingto sell the m eth. PATRICK stated she and BU CHANAN went to idlkusty's'' house. Based on theaffiant's participation in the investigation it's believed that Sklkusty'' is Russell CASSELL. W hileat iilkusty's'' BUCHANAN and PATRICK weighed out an eight-ball (3.5 gms) of meth and soldit to Skllusty'', PATRICK stated diRusty'' paid her $ 154.00 for the meth.

Stephanie M arie PATRICK

On April l0, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text messages stored in the accounts of several cellular telephone numbers,including those of Danny REECE, Roger LAW SON and Linda W ALTERS. In response to theexecution of this search warrant on Verizon W ireless, agents received text messages stored inthose accounts from March 20 to M arch 27, 2013. The following is an excerpt from the search

warrant results.

On M arch 23, 2013, Linda W ALTERS received the following text m essage from

telephone number (276) 706-2193:

çGlley Stefherejust thought we would let u guys know why you haven 't heardh'om us someonecalled social service on us gotta give them 3 clean ones and wc will drop the investigationalready gave them 2 so wont be long let D know so you have no worries it suxs but wont b tomuch longer take care $& c

.f& ''

Based on m y training and experience, and m y knowledge of this investigation, l believethat Stephanie PATRICK advised Linda W ALTERS to let Danny REECE know that she andBubba BUCHANAN had to give three (3) clean urines to social services and then they would bereturning as metham phetam ine customers. ln M arch of 2013, W ashington County, VADepartm ent of Social Services opened an investigation in to alleged drug use by PATRICK andBUCHANAN . During the investigation social workers conducted interviews of PATRICK andBUCHANAN, as well as their children. A safety plan was created that required PATRICK andBUCHANAN to provide three clean lzrine samples. The following are the results of the dnzgSCCCCHS:

March 18, 2013-Craig BUCHANAN (Refusal)

37


March 18s zol3-stephanie PATRlCK-(Refusal) Stated she did not want patemalrandmother to 'ûwin.''g

M arch 28, zol3-stephanie PATR-ICK (Negative)

April 15. 2013- Craig BUCHANAN l egative)

April 15. 2013- Stephanie PATRICK @ ot given, PATRICK left before being screenedagainst social workers direction)

May 29. 2013- Stephanie PATRICK (Negative)

According to the records of Verizon W irelesss telephone number (276) 274-3867 wasresold to TracFone with no subscriber inform ation available. According to the following textmessages, a fem ale named (tstef ' w as the user of this phone. As a result of this investigation,your affiant believes that the primary user of this phone number was Stephanie PATRICK.

On April 23, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text messages stored in the accounts of several cellular telephone numbers,including those of Danny REECE and Rick SHAW . ln response to the execution of this searchwarrant on Verizon W ireless, agents received text m essages stored in those accotmts from April9 to April 23, 2013. The following is an excerpt from the search warrant results.

April 10, 2013

Stephanie PATRICK to Danny REECE, Goll'ey Stefhere where t/5'REECE to PATRICK, çGln the apt',PATRICK to REECE, iiu going 2 Dtown'tREECE to PATRICK, iiI wtz.ç but canthnd nethg to go on/',REECE to PATRICK, Gçl-l'e wtan/ be home till tonight''PATRICK to REECE, âGFuck that J';/.u''REECE to PATRICK, içBeen tryin... im ready to head to Dtown ?yt?w an iv gotprob .25 inthe glass that ill do withyafor one ofthose specialfavors yr so good atl'tPATRICK to REECE, iccyanide shortly''

Based on my training and experience, and my knowledge of this investigation, I believethat Stephanie PATRICK contacted Danny REECE to determ ine if he had methamphetamine andif he was going to Damascus, VA CdDtown''). I believe that REECE advised PATRICK that themethamphetamine source of supply (Rick SHAW ) wasn't home, but REECE would share whatlittle he had lef4 for a sexual favor.

On April 13, 2013 Angela SURBER was interviewed in Bristol, Virginia. SURBERstated she had used m ethamphetam ine w ith Bubba BUCHANAN and Stephanie PATRICK .

38


illegal businesses. These electronic devices, telephone records, bills and paper are oftenfound within their residences and the surrounding curtilage; their vehicles; the residencesof fam ily m em bers, friends and associates; the places in which they conduct their dnlgdistribution activities, such as stash houses or safe houses; in business locations withwhich the trafficker is associated; or in storage areas.

Individuals who deal in illegal controlled substances often take photographs ofthemselves, their associates, their property and illegal contraband. These photographs areusually maintained within their residences and the surrounding curtilage; their vehicles',the residences of family members, friends and associates; the places in which theyconduct their dnzg distribution activities, such as stash houses or safe houses; in businesslocations with which the trafficker is associated', or in storage areas.

8. Persons who traffic in controlled substances maintain documents, letters and recordsrelating to their illegal activities for long periods of time. This documentary evidence isusually secreted within their residences and the surrounding curtilage; their vehicles; theresidences of family members, friends and associates; the places in which they conducttheir dnzg distribution activities, such as stash houses or safe houses; in business locationswith which the trafficker is associated', or in storage areas.

lndividuals involved in narcotics trafficking often own, possess and/or use fireanns asa means of facilitating their illegal drug activities. Said firearms are used to protect andsecure a drug traftickers property and narcotics from law enforcement and from theft byother crim inals. Drug traffickers also possess firearm s as a means of enforcing drugtransactions, i.e., as a m eans of ensuring paym ent for the drugs they are selling. Suchweapons are most often secreted within their residences and the surrounding curtilage;their vehicles', the residences of family mem bers, friends and associates', the places inwhich they conduct their dnzg distribution activities', such as stash houses or safe houses;in business locations with which the trafticker is associated', or in storage areas. Personswho possess or collect tirearms also keep other firearm related equipment, to includeam munition, amm unition m agazines, holsters, bullet proof vests, pistol grips, pistol boxes,cleaning kits and paperwork relating to the acquisition and disposition of tireanns.

10. lndividuals who are m embers of active drug organizations stay in regular contact withone another. This contact does not terminate once an individual is incarcerated.lncarcerated mem bers of drug organizations routinely send letters to and receive lettersfrom other members of the organization in which they discuss ongoing criminal activitiesand request various form s of assistance, from financial help to help in engaging in witnessintimidation or elimination. ln addition, incarcerated members often keep photographs ofthemselves and other m embers of their organization in order to obtain respect from otherinm ates.

1 l . Based on my training and experience I have becom e fam iliar with methods used bytraffickers to smuggle and safeguard narcotics, to distribute narcotics, and to collect andlaunder proceeds. The aftiant is aware of the sophisticated tactics they routinely use toattem pt to thwart detection by law enforcement which include the utilization of ntzm erous

3


SURBER stated she, PATRICK and BUCHANAN traded methamphetamine with each otherwhen one another would run out.

On M ay 21, 2013, CS-6 was interviewed in W ashington County, VA. CS-6 stated thaton M ay 16 and 1 7, he/she was with Sam ROBBINS while he was attempting to obtainmethamphetamine. CS-6 stated that he/she and ROBBINS received a ride from Tony DELP tothe residence of Bubba BUCHANAN and Stephanie PATRICK to purchase methnmphetamine.CS-6 stated that DELP provided the ride in anticipation of receiving methamphetamine fromROBBINS.

CS-6 stated that upon aniving at the residence of BUCHANAN and PATRICK, no onewas home. CS-6 stated that DELP provided a ride to the residence of Toby M OCK in CountryLiving Estates in Glade Spring, VA. CS-6 stated that eventually, BUCHANAN and PATRICKarrived and gave M OCK a ride to obtain the methamphetamine. CS-6 stated that upon theirreturn, M OCK sold 2 grams of methamphetamine to ROBBINS for $300.00. CS-6 stated thatROBBINS gave % gram of methnmphetamine to M OCK for obtaining it, and another % grnm ofmethamphetamine to DELP for the transportation.

On September 2, 2013 Stephanie PATRICK was arrested with Craig EsBubba''BUCHANAN in Johnson County, TN for dnlg related offense after being found in possession ofapproximately 1 1.4 grams of methamphetamine. Following her arrest PATRICK stated toJohnson County, TN Sheriff s Investigators she picked the m ethamphetam ine up from som eonein Virginia earlier and had already sold an eight-ball (3.5 gms) earlier in the evening. PATRICKstated she and BUCHANAN were Ctfronted'' the m ethamphetam ine and they were attempting tosell the meth. PATRICK stated she and BUCHANAN went to Siltusty's'' house. Based on theafliant's participation in the investigation it's believed that çûlkusty'' is Russell CASSELL. W hileat StRusty's'', BUCHANAN and PATRICK weighed out an eight-ball (3.5 gms) of meth and soldit to k'Rustf'. PATRICK stated StRusty'' paid her $154.00 for the meth.

Roger Dale LAW SON8282 O Id M ill Road, Glade Spring, Virginia 24340

Roger Lawson has prior convictions for distribution of marijuana % ounce to 5 pounds,dnzgs: sell/provide for resale schedule l or 1l, possession of schedule l or l1.

On September 20, 2012 CS-I purchased one (1) gram of methamphetamine from RogerLAW SON at his residence of 8282 Old M ill Road, Glade Spring, Virginia located in the W esternDistrict of Virginia. During the transaction LAW SON explained to CS-I he weighed the methout on paper and provided a little for good measure. LAW SON advised CS-I not to idfuck withit, it weighs right, taste right, and that's why it cost $120.00''.

On September 20, 2012 CS- 1 purchased two (2) grams of methamphetamine from RogerLA W SON at his residence of 8282 Old M ill Road Glade Spring, Virginia located in the W esternDistrict of Virginia.

39


On September 26, 2012 CS-I purchased two (2) grams of methamphetamine from RogerLAW SON in the W estern District of Virginia.

On December 14, 2012 Gary HOW ELL was arrested following a motor vehicle accidentin Glade Spring, Virginia. During the accident investigations HOW ELL was discovered to be inpossession of approximately ten (10) pounds of marijuana, twelve (12) ounces ofmethamphetamine and $2, 192.00 U.S. Currency. HOW ELL stated he sold meth for $2,400.00 anounce and $100.00 per gram. HOW ELL stated he sold drugs (meth) to Roger LAW SON (anounce a week).

On January 7, 2013 CS-2 was interviewed in Charlottesville, Virginia. CS-2 stated thatRoger LAW SON purchased methamphetamine from Gary HOW ELL. LAW SON wasHOW ELL'S m ost frequent custom er purchasing ounces of m ethamphetnm ine at a time.

On January 25, 2013 HOW ELL was interviewed pursuant to a proffer agreement.HOW ELL stated from August 2012 until December 2012 he supplied LAW SON with one (1) totwo (2) ounces of methamphetamine per week. HOW ELL stated LAW SON owed him $2400.00for methamphetamine.

On Thursday, January 31, 2013 CS-3 was interviewed in Roanoke, Virginia. CS-3 statedHOW ELL was dealing one-half (%) ounces of methamphetamine to LAW SON every five toseven days. CS-3 stated he had observed LAW SON on over thirty (30) separate occasions obtaindrugs from HOW ELL.

According to the records of Verizon W ireless, telephone number (276) 206-3833 wasresold to TracFone W ireless with no subscriber infozm ation available. This phone was activefrom February, 2013 until at least April 10, 2013. According to text messages received via courtorder, the user of this phone was 'A oger''. As a result of this investigation, your affiant believesthat the prim ary user of this phone number was Roger LAW SON .

According to the records of Verizon W ireless, telephone number (276) 206-6462 wasresold to TracFone W ireless with no subscriber information available, This phone was activefrom approxim ately April 26, 2013 until at least November, 2013. According to text m essagesreceived via court order, the user of this phone was StRoger''. As a result'of this investigation,your affiant believes that the primary user of this phone number was Roger LAW SON.

(On May 14, 20 13, CS-6 was interviewed in Bristol, VA and stated that RogerLAW SON'S cellular telephone numbers were (276) 206-3833 and (276) 206-6462.)

On February 27, 2013, a search warrant was applied for and obtained in the W estern

District of Virginia for text messages stored in the account of telephone number (423) 471-1541,the cellular telephone of Timothy GERACE. In response to the execution of this search warranton Verizon W ireless, agents received text m essages stored in that account from January 26 toFebruary 27, 20 13. The following is an excerpt from the search warrant results.

January 28,2013

Roger LAW SON to Tim othy GERACE, Gil'im how close r u? I can meet u''

40


LAW SON to GERACE, %çliey. Tried to call need to no wJ/ tm tell my buddy. She 's beenwaiten 4me to /x/ her/''

January 31, 2013

LAW SON to GERACE, iiliey the girl that bough thefurniture wants to buy the 3matchinpieces''

February 1,2013

LAW SON to GERACE, inl-ley that girl wtzs' wanting thapictures that went wl that ,çc/?''LAW SON to GERACE, ççl'im call meplease''

February 2,2013

LAWSON to GERACE, ççbl'ey im sitten hear with tha girl who bought urfurniture @ shewants tha 6 chairsfor tha table so call me A.S.A.P. ?''GERACE to LAW SON, iicall me Jmr''

Based on my training and experience, and my knowledge of this investigation, 1 believethat Roger LAW SON utilized the text messaging service on his cellular telephone tocom municate with Tim othy GERACE about the distribution of metham phetam ine to anunknown fem ale custom er.

February 24,2013

Roger LAWSON to Danny REECE, içls it ok to come over /t)#t# @ J or 4''REECE to LAW SON, **10-4''LA W SON to REECE, Qosee ya /& z7''REECE to LAW SON, çL1 gotta run up the road ill textya when I Ieave there an we canmeet at myplace'tLAW SON to REECE, (ûO/c''REECE to LAW SON, isFtlz/ can come on n/w''

Based on my training and experience, and my knowledge of this investigation, l believethat Roger LAW SON utilized the text messaging service on his cellular telephone tocom municate with Darmy REECE to purchase m ethamphetam ine. I believe that REECE m ade atrip to Rick SHAW 'S to obtain the methamphetamine, then notitied LAW SON that he had it.

February 26,2013

Roger LAW SON to Danny REECE, Qook to visit tonight @ 11?',REECE to LAW SON, çolts gonna be a lil while 1 'm tryin to get up with thatfeller rt ntlw.1 'll let ya no asap''LA W SON to REECE, *QOk.''

41


Based on my training and expelience, and my knowledge of this investigation, 1 believethat Roger LAW SON utilized the text messaging service on his cellular telephone tocom municate with Danny REECE to pick up m ethamphetam ine. 1 believe that REECE notifiedLAW SON that he had to see Rick SHAW before he could sell methamphetamine to LAW SON.

On M arch 22, 2013, a search warrant was applied for and obtained in the W esternDistrict of Virginia for text m essages stored in the accounts of several cellular telephonenumbers, including that of Roger LAW SON. In response to the execution of this search warrant

on Verizon W ireless, agents received text messages stored in that account from February 23 toM arch 22, 2013. The following is an excerpt from the search warrant results.

M arch 1, 2013

Roger LAW SON to Linda W ALTERS, L*Do u know where Danny is? J/'nö/, can u helpme? Wt?.jrcr''W ALTERS to LAW SON, çil'le 's in th bed I believe. All 1 hav is one xtra''W ALTERS to LAW SON, çiNo my apt r u n mc''W ALTERS to LAW SON, GX FoodL ion''LAW SON to W ALTERS, CEJ'CJ Foodlion ok be right there',

Based on my training and experience, and my knowledge of this investigation, 1 believethat Roger LAW SON utilized the text messaging service on his cellular telephone to purchasemethamphetamine from Linda W ALTERS.

M arch 4, 2013

Danny REECE to Roger LAW SON, çill'ow much wJy you wantin to spendon thoseDA/.5- -?''P

LAWSON to REECE, çnWouldyou take @ 200.',REECE to LAW SON, iiBe 180. 1 geuss is what you mean/'tLAW SON to REECE, ççYeal. Not sure 1'm coming.',LAWSON to REECE, içls before 12 t?/c?''REECE to LAW SON, LGl0-4. Ijust wanted to make sure 1 had enufparts''LAW SON to REECE, $tt?F'

Based on my training and experience, and my knowledge of this investigation, l believethat Roger LAW SON utilized the text messaging service on his cellular telephone to purchasem ethamphetam ine from Danny REECE.

M arch 5, 2013

Roger LAW SON to Danny REECE, içcould 1 come c u today/t,LA W SON to REECE, Giok to come over to get those parts tonight?''

LAW SON to Linda W ALTERS, iiHave u seen Danny? M aybe u can help me. Let meknow please.''

42


REECE to LAW SON, içMans not at home 111 text ya asap''LAW SON to REECE, iGOk''

REECE to LAW SON, iiok to come on''

Based on my training and experience, and my knowledge of this investigation, 1 believethat Roger LAW SON utilized the text messaging service on his cellular telephone to purchasemetham phetam ine from Danny REECE.

M arch 7 - 9, 2013

Roger LAW SON to Jason M ULLINAX, ènc'an u help me /t?nflc''M ULLINAX to LAW SON, LiGina 's',LAW SON to M ULLINAX, ç*Be there shortlyt'

Based on my training and experience, and my knowledge of this investigation, 1 believethat Roger LAW SON utilized the text messaging service on his cellular telephone to purchasemetham phetam ine from Jason M ULLINAX and Gina Lopez.

M arch 11 - 20, 2013

Danny REECE to Roger LAWSON, iâTeIl her these are .5s. They gofor l''LAW SON to REECE, Giok. l)'é? 'll take care o./'/ï''

LAW SON to Linda W ALTERS, iiHave u seen Danny/''

LAW SON to REECE, iivjre u in D ftlwn.''LAW SON to REECE, Liliey man are u in D town/b'LA W SON to REECE, inzqre u at home? Need to c u.''

LAW SON to W ALTERS, Lican u call me/'tWALTERS to LAW SON, Qilfyou need tell me now cause 1 am tlking to him right now an1 will getfor you too''LAW SON to WALTERS, Q%1 need at least 1. Is it ok fl give TG urph. No. ?''WALTERS to LAW SON, $;A7 I canpick one upforyou. Yea thtshne''LAW SON to W ALTERS, Gçvqre yal comin to D town or u already there/''W ALTERS to LAW SON, GiNo 1 am not but Dannyprobably will shortly do you want meto tell him so you canjst meet up with him tlvr there/''LAW SON to W ALTERS, iQYesplease''W ALTERS to LAW SON, çilie ne dwn there in bout 2 hours. X''LAW SON to WALTERS, t$f will need @ J Ifhe can bring them. L et me /c?7ow.''W ALTERS to LAW SON, *%He should b ther netime ffyt?z/ hurry an grab him b4 nebdyelse gets ther 101''

43


Based on my training and experience, and my knowledge of this investigation, l believethat Roger LAW SON utilized the text messaging service on his cellular telephone tocommunicate with Linda W ALTERS about purchasing methamphetamine from Dnnny REECE.

On April 10, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text messages stored in the accounts of several cellular telephone numbers,including those of Danny REECE, Roger LAW SON and Linda W ALTERS. ln response to theexecution of this search warrant on Verizon W ireless, agents received text m essages stored inthose accounts from March 20 to March 27, 2013. The following is an excerpt from the searchwarrant results.

M arch 21, 2013

Dazm y REECE to Roger LAW SON , çGlnhis is my no Dan'tLA W SON to REECE, iik-ou gonna work in D town today?''REECE to LAW SON, Gik-eah but it will be 5 or 6 before that guy gets home. Then 111com e on

LAW SON to REECE, iiok can u text me when ur .:4)4)t/?''REECE to LAW SON, *Gl0-4 will (1''

LAW SON to REECE, ççlley r u in D town/''REECE to LAW SON, GiM anjus text me 111 hollor atya when in hand.''LAW SON to REECE, iook''

REECE to LAW SON , GQGot them truckparts but not comin that wly till morning. Come

up (/FONJ like t0''

Based on my training and experience, and my knowledge of this investigation, l believethat Roger LAW SON utilized the text messaging service on his cellular telephone tocommunicate with Danny REECE about ptlrchasing methamphetamine. l believe that REECEobtained the methamphetamine from Rick SHAW and notified LAW SON that it was available.

M arch 22, 2013

Roger LAW SON to Danny REECE, LQWhen u head this wtzy, will u give me a callIease?t'#REECE to LAW SON , iil0-4prob be hr or J''

REECE to LA W SON , çGln D town ntaw''LAW SON to REECE, **C u shortly''REECE to LA W SON, Gçl0-4''

LAW SON to REECE, Gnlkrould 12 be too late to come over/''REECE to LA W SON, içBe

-flne',LAW SON to REECE, GQok thankv''LAW SON to R-EECE, iiNeed 2 cans ofgreese when 1 c u at 12,'

44


REECE to LAW SON, çi10-4,,

Based on m y training and experience, and m y knowledge of this investigation, I believethat Roger LAW SON utilized the text messaging service on his cellular telephone to purchasem ethamphetam ine from Danny REECE.

April 2, 2013

Toby MOCK to Roger LAW SON, iDid u ever decide fu were gona go to themkt/jntoby (.75LAWSON to MOCK, iiNot sure. Y'f do I 'll call zf.''

LAW SON to Danny REECE, G%Gonna be in D Fown today/',REECE to LAW SON , Gillere now''LAW SON to REECE, iGcan 1 ask J/t?w long u will be there.J''REECE to LAWSON, çt4 or 5 hrs but I don 't know Ifthparts will last that long?',LAW SON to REECE, Gncan u hang on to at least 3. 111 be there shortly. ''REECE to LAW SON, ''Fry my best''LAW SON to REECE, %iOk.''

LAW SON to M OCK , inGetting ready to go to the market. Be ur wly unless u can meetme in Glade. ''

LAW SON to REECE, insave me at least J.''

Based on my training and experience, and my knowledge of this investigation, l believethat Roger LAW SON utilized the text messaging service on his cellular telephone to purchasemethamphetamine from Darmy REECE for Toby MOCK.

April 5, 2013

Toby M OCK to Roger LAW SON, tûll'cn u goin to the mkt? Eddie here and wanted tosendfor somepaintjntoby @ 'LAW SON to MOCK, iscan go anytime but wait couple ofhrs. Callyal.''MOCK to LAW SON, GGlgot somebody else brining me sum $ over to 1 ned to sendwithyabntoby @ '

Danny REECE to LAW SON , iQETA?''LAW SON to REECE, Gils 11:30 to late/',REECE to LAW SON , $*Be tl/(''LAW SON to REECE, iilhanks''

M OCK to LAW SON, GGWher ya at?bntoby (v(.P'LAW SON to M OCK, iilust kiddin on our wtzy.''MOCK to LAW SON, iiokey dokey...yal b carefulintoby (.25LAW SON to M OCK, *K '

45


M OCK to LAW SON, G*R yal close? intoby @ 'LAW SON to M OCK, iûFc.$ at Bub 'J''M OCK to LAW SON, çGblave yal /:.# Bub 's yetjntoby @ 'LAW SON to M OCK , iil'm down at Kenny 's. Bub 's got z/r,ç.''

Based on my training and experience, and my knowledge of this investigation, 1 believethat Roger LAW SON utilized the text m essaging service on his cellular telephone to purchasemethamphetamine from Danny REECE for Toby M OCK and Bubba BUCHANAN.

On April 11, 2013 Angela SURBER was interviewed in Bristol, Virginia. SURBERstated she smoked methamphetamine with Roger LAW SON at his house when he lived in GladeSpring, Virginia. SURBER advised that LAW SON had given her m ethamphetam ine to deliver tohis daughter in the past.

On April 23, 20 13, a search warrant was applied for and obtained in the W estern Districtof Virginia for text messages stored in the accounts of several cellulr telephone numbers,including those of D anny REECE and Rick SHAW . ln response to the execution of this searchwarrant on Verizon W ireless, agents received text m essages stored in those accounts from April9 to April 23, 2013. The following is an excerpt from the search warrant results.

April 10, 2013

Roger LAWSON to Danny REECE, nnlts Roger myph is screwfup. Did u try to text me?New no. 276 206 3398''REECE to LAW SON, iiNo still haven 't heard nothin''LAW SON to REECE, **So ur not likely to be over too soon. Just let me iwtpw''REECE to LAW SON, **Well im over here but no pJr/5,''LAW SON to REECE, çiok //ltzn/c5'.''

Rick SHAW to REECE, çnl'm home''REECE to SHAW , i*l0-4 leavin D lhwn n/w''

REECE to ttBubba'' BUCHANAN , çcllidyou an Rodger want to come tonight/''

A pril 11, 2013

LAW SON to REECE, LGl-his is my zyew no. 276 206 6462 r u gonna in D Ftlwa today/''REECE to LAW SON, ânk-eah in a couple hrs''LAW SON to REECE, Giok f/tl?y#.ç''

LAW SON to REECE, St-drc u in Damascus? Roger''REECE to LAW SON, *il0-4 fFa4?''LAW SON to REECE, S*ll'ow long have 1 got to get there/t'REECE to LAWSON, ioprob be Iate Iate before I Ieave''LAW SON to REECE, Giok be there about hn''

46


REECE to LAW SON , iGl0-4,'

April 16, 2013

LAW SON to REECE, iiR u in Dlmown today/''REECE to LAW SON , GGWhile it last! Yeah Dl-own't

LAW SON to REECE, iizqre you still there f/'cçtp f 'lI b there in 20 mins''REECE to LAW SON, Gçkreah',LAW SON to REECE, iiok''

LAW SON to REECE, çiR u still there? 1 need l more tirefor my trailer',

Based on my training and experience, and my knowledge of this investigation, l believethat Roger LAW SON utilized the text messaging service on his cellular telephone to purchasemetham phetamine from Danny REECE in Damascus, VA.

April 17, 2013

Rick SHAW to Danny REECE, iiHeaded home',REECE to SHAW , $1On wJy do u need nethingjbom town?''SHAW to REECE, çiDrink''

Roger LAW SON to REECE, Lizqre u n D Ftawn tonight''REECE to LAW SON, i$C7/.p''REECE to LAW SON, nnGotpartst'

April 20 - 21, 2013

LAW SON to REECE, Lnzqre u gonna be in Dl-own today/''REECE to LAW SON, iâFwd.. Dude is gone to the RodRun don 't no when he will behome?''

LAW SON to REECE, GiAll I need is a 50 lb. bag o/lt?g/otl(f'

REECE to SHAW , içblave you got any ideal what time you will be home/',SHAW to BU CHANAN, iç30min,tREECE to SHAW , Qilneeenfourrrr on wayjkom DTbwp''

LAW SON to REECE, çiok f/'f come over nt?w?''REECE to LAW SON, GiYeahfor a lil,'LAW SON to REECE, çnok lm leavin Saltville nt?w.''LAW SON to REECE, GëBe there in 20 minf'REECE to LAW SON , iil0-4''

47


Based on my training and experience, and my knowledge of this investigation, I believethat Roger LAW SON utilized the text messaging service on his cellular telephone to purchasemethamphetamine from Danny REECE, who was supplied by Rick SHAW .

On M ay 8, 2013, a search warrant was applied for and obtained in the W estern District ofVirginia for text messages stored in the accounts of several cellular telephone numbers, includingthose of Danny REECE, Rick SHAW and Roger LAW SON. ln response to the execution of thissearch wanunt on Verizon W ireless, agents received text messages stored in those accounts fromApril 26 to M ay 8, 2013. The following is an excerpt from the search warrant results.

M ay 1, 2013

Toby M OCK to Roger LAW SON, Giliave u heard anything/bntoby (.W5LAW SON to M OCK, iiNot yet.''M OCK to LAW SON, çx jntoby tu!.7'

LAW SON to Danny REECE, Giugonna be in D Ftpwn today/ttREECE to LAW SON, ëçlitn cf/y''LAW SON to REECE, (iok /J2tzn/o'.''LAW SON to REECE, **Ok to stop by D/er?''IkEECE to LAW SON, ç*l0-4''LAW SON to REECE, çiok''

Based on my training and experience, and my knowledge of this investigation, l believethat Roger LAW SON utilized the text m essaging service on his cellular telephone tocomm unicate with Toby M OCK and Dalm y REECE about obtaining m ethamphetam ine.

On August 13, 2013 CS-I 1 purchased one-half (%) grams of methamphetamine fromRoger LAW SON in the W estern District of Virginia.

On September 5, 2013 CS-I 1 purchased one-half (%) grams of methamphetamine fromRoger LAW SON at his residence of 8282 Old M ill Road Glade Spring, Virginia located in the

Western District of Virginia. During the transaction CS-3 asked LAWSON what yossessed himto bond Craig (kBubba'' BUCHANAN and Stephanie PATRICK out of jail followlng their arrestin Mountain City, TN. LAW SON stated he wrote the bondsmen a $13,000.00 check andmentioned the bondsman was holding the check for two weeks. LAW SON stated he would be inreal trouble if he didn't come up with the m oney. lt is known to the affiant that BUCHANANand PATRICK were arrested in Johnson County, TN on September 2, 2013 for possession ofm ethnmphetam ine.

Toby Anne M O CK13341 Country Living Lane, Glade Spring, VA 24340

Toby M ock has prior arrests/convictions for contempt of court.

48


different cellular telephones, counter surveillance, false or fictitious identities, and codedcommunications and conversations. The affiant knows that individuals involved innarcotics traftkking often use (çcode'' words when facilitating illegal drug transactions.Based on the affiant's knowledge and participation of this investigation tenus such astttruck parts ttcoffee'' ttrtz s'' ûûfurniture'' tdlug nuts'' or $$ o to the market'' were used, , g , , gwhen conducting methamphetamine transactions in order to avoid detection from 1awenforcement.

12. The inform ation contained in this affidavit is based on my personal observations,observations of other law enforcement officers, observations of Contidential lnformants(CI's) and Cooperating Sources (CS) as related to me, my review of official police andgovernment reports, and consultation with other agents/offcer involved in theinvestigation and is provided for the limited purpose of establishing probable cause. Theinformation is not a complete statement of a1l the facts related to this case.

13. This aftidavit is submitted in support of a request that a complaint, arrest warrantts)and search warrantts) be issued for the following personts) and placetslfor violations ofTitle 21, United States Code, Section 846, Conspiracy to Possess with the lntent toDistribute M etham phetamine:

Persons

1. Richard Shaw2. M elvin Campbell3. Jim Grindstaff4. Daniel Reece5. Linda W alters6. Russell Cassell7. Kenneth Craig Buchanan8. Stephanie Patrick9. Roger Lawson10. Toby M ock1 l . Rachael Peake12. Jason M ullinax13. Roger Austin Jr.14. Timothy Gerace15. Angela Surber16. Patricia Lealm Halll 7. M ichael Brady Lester18. Joseph Nathan Hall19. W illinm Hunt, Jr.20. Brandi M arie Dtmford21 . Tim othy Nickolas Rabara22. Albert Hague23. Kim berly Ann Bradley


On April 3, 2013, CS-5 was interviewed in Bristol, Virginia. CS-5 stated in October of2012 GERACE got called by Toby M OCK who wanted to sell a .22 pistol. GERACE and CS-5went to meet M OCK at Bubba BUCHANNAN'S garage. On the way GERACE told CS-5 to getthe silver 9m m pistol and get out in the woods in case anything goes wrong. CS-5 did as he wastold. Five to ten m inutes later GERACE called up and asked CS-5 if he/she w anted to buy this.22 caliber revolver for $500 that MOCK was selling. M OCK said it belonged to her boyfriendat the time. CS-5 and GERACE declined buying the pistol.

According to the records of Verizon Wireless, telephone number (276) 492-7023 wasresold to TracFone with the following information available: no name at 13341 Country Living

Ln., Glade Spring, VA, email [email protected]. As a result of this investigation, youraffiant believes that the primary user of this phone number was Toby M OCK.

(On April 1 1, 2013, Angela SURBER was interviewed in Bristol, VA and stated thatToby MOCK'S cellular telephone number was (276) 492-7023.)

(On May 14, 2013, CS-6 was interviewed in Bristol, VA and stated that Toby MOCK'Scellular telephone number was (276) 492-7023.)

On M arch 22, 2013, a search warrant was applied for and obtained in the W esternDistrict of Virginia for text messages stored in the accounts of several cellular telephones,including that utilized by Roger LAW SON. ln response to the execution of this search warrant

on Verizon W ireless, agents received text messages stored in those accounts from February 23 toM arch 22, 2013. The following is an excerpt from the search warrant results.

February 25,2013

Toby MOCK to Roger LAW SON, iX you go meet Rachael will u holla at me Eddie wnetsomewhere an he may not make it bak n time to go meet Jlprï#zFt):.p''

LAW SON to MOCK, Gil've not heardh'om her.',

MOCK to LAWSON, iiL indajus text me bak and she good bnToby''MOCK to LAWSON, kûr'p-c can holla at L inda fu want tojnlbby',MOCK to LAWSON, çiliow many ofthose rugs did u ned an l can text /?drlaFt?:.y''

LAW SON to M OCK, niliey is L inda gonna be there this evening/''M OCK to LAW SON , itf 'm not sure 1 haven 't talkd to her anymore since earlier sheprobably will 1 rekonjnlnoby''MOCK to LAWSON, $i1 think she is ready ntpw fu were wantin to yell at herjnlnoby''

LAW SON to M OCK , GiWere u wantin to go, or send/''MOCK to LAW SON, GGsend fthat ok with ujnToby ..,)''MOCK to LAW SON, LGc'an Isend with u wen u go over? LnToby :)''LAW SON to M OCK, içsure can.b'

LAW SON to Danny REECE, iiïkrill it be ok to stop by @ 6 or 737,'

49


Based on m y training and experience, and m y knowledge of this investigation, I believethat Toby M OCK utilized the text messaging service on her cellular telephone to eommunicatewith Roger LAW SON in an attempt to obtain m etham phetam ine for a custom er, Eddie LNU . lbelieve that M OCK suggested Rachael PEAKE and Linda W ALTERS as suppliers, butLAW SON eventually went to Danny REECE for the m etham phetamine.

February 28,2013

Toby MOCK to Roger LAW SON, tiFbtf goin to thejlea mkt. this eveningànlbby :)''LAW SON to MOCK, iik-eal flget moneyttMOCK to LAW SON, iiK 1 ned 2 and halfgallons ofpaint ànToby .',)''LAW SON to M OCK, LLBe byt'MOCK to LAWSON, çiK Eddie bringing the money down so it b bout an hour bfore hegets herebnToby :)''LAW SON to M OCK, L*Ok''MOCK to LAW SON, çîl'le said he would b here (/?z didn 't mind to swing by an get /I& $plezbnlnoby .*7''LAW SON to M OCK , **Ok''

LAW SON to Danny R-EECE, inBe ok to head ur wlA about an hr. .?''REECE to LAW SON , 6*10-4''

Based on my training and experience, and my knowledge of this investigation, 1 believethat Toby M OCK utilized the text messaging service on her cellular telephone to communicatewith Roger LAW SON in an attempt to obtain methamphetamine for a customer, Eddie LNU. lbelieve that LAW SON eventually obtained the methamphetamine from Danny REECE.

On April 1O, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text m essages stored in the accounts of several cellular telephone num bers,including that of Roger LAW SON. In response to the execution of this search wanunt on

Verizon W ireless, agents received text messages stored in that account from April 1 to April 10,2013. The following is an excerpt from the search w arrant results.

April 2, 2013

Toby MOCK to Roger LAW SON, iDid u ever decide f/'lf were gona go to themkt?bntoby @ 'LAW SON to MOCK, S*Not sure. J/V do 111 call ?z''

LAW SON to Danny REECE, iiGonna be in D Town today.J''REECE to LA W SON, Giliere atpw''LAW SON to REECE, çncan 1 ask how long u will be there/''REECE to LAWSON, 1;# or 5 hrs but 1 don 't kptlw fthparts will last that long/''LAW SON to REECE, içcan u hang on to at least 3. 111 be there shortly''REECE to LAW SON , tIF/-.V my llp-çf''LAW SON to REECE, ;tOk''

50


LAW SON to M OCK, GGGetting ready to go to the market. Be ur wJy unless u can meetme in Glade.t'

LA W SON to REECE, Qçsave me at least 3.'t

Based on my training and experience, and my knowledge of this investigation, l believethat Toby M OCK utilized the text m essaging service on her cellular telephone to comm unicatewith Roger LAW SON in an attempt to obtain m ethamphetam ine. l believe that LAW SONeventually obtained the methamphetamine from Danny REECE.

April 5, 2013

Toby MOCK to Roger LAW SON, içWen u goin to the mkt? Eddie here and wanted tosendfor some paintjntoby t:7'LAW SON to MOCK, iican go anytime but wait couple ofhrs. Callyal.''M OCK to LAW SON, ii1 got somebody else brining me sum $ over to 1 ned to send withyabntoby @ 5

Danny REECE to LAW SON, iiETA/''LAW SON to REECE, Gnls 11..30 to late?',REECE to LAW SON, içBe ok''

'LAW SON to REECE, iil-hanks',

M OCK to LAW SON, Gnlkher ya at/bntoby t.W'LAW SON to M OCK, iuust kiddin on our wly.''MOCK to LAW SON, içokey dokey...yal b carefuljntoby @'LAW SON to M OCK, ESA'''

M OCK to LAW SON, GiR yal close? Lntoby ('W'LAW SON to M OCK, Ctl'c,N at Bub 's''MOCK to LAW SON, içblave ya1 Ieh Bub 's yetbntoby t'W'LAW SON to M OCK, ii1 'm down at Kenny 's. Bub 's got urs.''

Based on my training and experience, and m y knowledge of this investigation, 1 believethat Toby M OCK utilized the text messaging service on her cellular telephone to communicatewith Roger LAW SON in an attempt to obtain m ethamphetam ine for several customers. 1 believethat LAW SON eventually obtained the methamphetamine from Danny REECE and leflM OCK'S share at the residence of Bubba BUCHANAN .

April 1 1, 2013 Angela SURBER was interviewed in Bristol, Virginia. According toSURBER, GERACE cam e to her and M OCK'S apartm ent everyday with twO to four grams ofmeth for each of them to distribute. SURBER stated she sold every bit of meth she could just toeat.

51


On M ay 8, 2013, a search wanunt was applied for and obtained in the W estern District ofVirginia for text messages stored in the accotmts of several cellular telephone numbers, includingthose of Dnnny REECE, Rick SHAW and Roger LAW SON. ln response to the execution of thissearch warrant on Verizon W ireless, agents received text m essages stored in those accounts fromApril 26 to M ay 8, 2013. The following is an excerpt from the search warrant results.

M ay 1, 2013

Toby M OCK to Roger LAW SON, iiHave u heard anything/bntoby (W'LAW SON to M OCK, GQNotyett,M OCK to LAW SON, ix jntoby @ '

LAW SON to Danny REECE, iiugonna be in D Ttlwn today/',REECE to LAW SON, QGkftn cjfy''LAW SON to REECE, ièok thanks.''LAW SON to REECE, çiok to stop by Iater?''REECE to LAW SON, iil0-4''LAW SON to REECE, çûO/c''

Based on m y training and experience, and m y knowledge of this investigation, l believethat Toby M OCK utilized the text messaging service on her cellular telephone to communicatewith Roger LAW SON in an attempt to obtain methamphetamine. 1 believe that LAW SONeventually obtained the methamphetamine from Danny REECE.

M ay 2, 2013

Toby M OCK to Roger LAW SON , çiWill u text Bubba an ask him to call me plez/bntoby(.j.p,LAWSON to MOCK, âibl'e 's been asleepfor hrs.''MOCK to LAW SON, ççWell hell...I saved mine so I could do it with him...I been tryingto get ahold ofhim all evening... Thankya anm aysjntoby (J7'

On M ay 21, 2013, CS-6 was interviewed in W ashington County, VA. CS-6 stated thaton M ay 16 and 17, he/she was with Sam ROBBINS while he was attempting to obtainmethamphetamine. CS-6 stated that he/she and ROBBW S received a ride from Tony DELP tothe residence of Bubba BUCHANAN and Stephanie PATRICK to ptlrchase methamphetamine.CS-6 stated that DELP provided the ride in anticipation of receiving methamphetamine fromROBBINS. CS-6 stated that upon arriving at the residence of BU CHANAN and PATRICK , noone was home. CS-6 stated that DELP provided a ride to the residence of Toby M OCK inCountry Living Estates in Glade Spring, VA. CS-6 stated that eventually, BUCHANAN andPATRICK anived and gave M OCK a ride to obtain the m ethamphetam ine. CS-6 stated upontheir return, M OCK sold 2 grams of methamphetamine to ROBBINS for $300.00. CS-6 statedROBBINS gave % gram of methamphetam ine to M OCK for obtaining it, and another % gram ofm ethamphetam ine to DELP for the transportation.

52


On June 1, 2013 CS-6 purchased one (1) gram of methamphetamine from Toby MOCKin the W estern District of Virginia. CS-6 had previously paid $120.00 to M OCK on M ay 31,2013 for methamphetamine but did not receive the one (1) gram of methamphetamine until June1, 2013.

On June 7, 2013 CS-6 purchased one (1) gram of methnmphetamine from Toby MOCKat 13341 Countl'y Living Lane, Glade Spring, Virginia located in the W estern District ofVirginia. CS-5 had previously paid $120.00 to M OCK on June 3, 2013 for methamphetnmine butdid not receive the one (1) grnm of methamphetamine until June 7, 2013.

On June 10, 2013 CS-6 purchased one (1) gram of methamphetamine from Toby MOCKat 13341 Countl'y Living Lane, Glade Spring, Virginia located in the W estern District ofVirginia.

On June 12, 2013 CS-6 purchased one and one-half (1.5) grams of methamphetnminefrom Toby M OCK at 13341 Country Living Lane, Glade Spring, Virginia located in the W esternDistrict of Virginia.

On June 25, 2013 CS-6 purchased one (1) gram of methamphetamine from Toby M OCKat 13341 Country Living Lane, Glade Spring, Virginia located in the W estern District ofV irginia.

On July 2, 2013 CS-6 purchased 3.5 gram s of m ethnmphetamine from Toby M OCK at13341 Country Living Lane, Glade Spring, Virginia located in the W estern District of Virginia.

On July 15, 2013 CS-6 purchased three (3) grams of methnmphetamine from TobyM OCK at the entrance to Countl'y Living Estates which is located approximately one-half milesfrom M OCK'S residence located at 13341 Country Living Lane, Glade Spring, Virginia in theW estern District of Virginia.

Rachael Renee PEAKE

On April 1 1, 2013 Angela SURBER was interviewed in Bristol, Virginia. SURBERstated that she had sold methamphetamine over the years for Tim GERACE, Rick SHAW ,Danny REECE and others. SURBER stated that one of her methamphetamine customers wasRachael PEAKE.

According to the records of Tracfone Wireless, telephone number (276) 243-7583 wassubscribed to by Rachael R. PEAKE at 61 1 Freedom Tabemacle, Atkins, VA. According to therecords of Sprint, telephone number (276) 685-3 199 was subscribed to by Rachael PEAKE at6 l 1 Freedom Tabernacle Ln., Atkins, VA. According to the records of Tracfone W ireless,telephone number (276) 378-4585 was subscribed to by Crystal Peake at 2508 Avery Ln.,Marion, VA. According to the records of Sprint, telephone number (276) 685-6638 wassubscribed to by Betty Peake at 573 Freedom Tabem acle Ln., Atkins, VA.

53


For the purposes of this affidavit, your aftiant believes that Rachael PEAKE was the userof these telephones to send and receive the text messages contained herein.

On M arch 22, 2013, a search warrant was applied for and obtained in the W esternDistrict of Virginia for text messages stored in the accounts of several cellular telephones,including that utilized by Roger LAW SON . In response to the execution of this seareh warrant

on Verizon W ireless, agents received text m essages stored in those accounts from Febnzary 23 toM arch 22, 2013. The following is an excerpt from the search warrant results.

February 25,2013

Toby MOCK to Roger LAW SON, i*1 couldn 't get ahold ofher...Rachael checkin on sumfor mejnToby''LAW SON to M OCK , i6Tell her to call or text me please.''

M OCK to LAW SON , çGilid she textya? ïaTbby''LAW SON to M OCK, GiNotyet''MOCK to LAW SON, iilt-you go meet Rachael will u holla at me Eddie went somewherean he may not make it bak n time to go meet herbnl-oby''

M OCK to LAW SON, GoText RachaelbnToby'tMOCK to LAW SON, â*she calling them at 1..00 so let me no fu want me to ask herforajnlhby''A'

LAW SON to Rachael PEAKE, içbley are u gonna take a trip/''PEAKE to LAW SON, iGNo cuz 1 can 't get anythingfor myselfbut I can here real close.Same thing. 1 went Fri. they went wit ?pe.''

PEAKE to LAW SON, Q*Need to know what u need asap fu do''LAW SON to PEAKE, çilust go with what u gt)/.''PEAKE to LAWSON, ii1 don 't got anything to go with 1 wasjust gonna go here in townfor u to Toby''

Based on my training and experience, and m y knowledge of this organization, I believethat Roger LAW SON inquired of PEAKE if she was going to go to see her m ethamphetam inesource of supply, possibly in Mountain City, TN. I believe that PEAKE advised LAW SON thatshe had made a trip with others on Friday, and that she could get methamphetamine from theothers for LAW SON and Toby M OCK.

February 26,2013

Rachael PEAKE to Roger LAW SON, tçllrcn do u think u will be able to do that again fueven do cuz 1 want to but don 't have close to his rules''LAW SON to PEAKE, nQblow much do u need/t'PEAKE to LAW SON , %L1 only have 200''LAW SON to PEAKE, ii1 'vp got 5 or more. Can u go tonight/',

54


PEAKE to LAW SON, ççllon 't look like 111 be able to do anything until I can see Christyto let me borrow. 1 really don 't wanna go (/'f can 't get me something. So hopefully wcz? 1can go u will still be able to.''LAW SON to PEAKE, içU can go tonight/''PEAKE to LAWSON, â*1 don 't knt?w cuz even fshe Iets me borrow $ she don 't get offtill11 tonight. Don 't knt?w fdude lets anyone come aher certain /ï?nc.''LAW SON to PEAKE, iiok 1 understand ''

Based on my training and experience, and my knowledge of this organization, I believethat Rachael PEAKE inquired of Roger LAW SON if he was going to go see themethamphetamine source of supply. l believe that PEAKE told LAW SON that she only had$200.00 and did not believe that the source would sell that small of a quantity. l believe thatLAW SON told PEAKE that he had $500.00 or more and wanted PEAKE to go with him .

M arch 2, 2013

Rachael PEAKE to Roger LAW SON, i%1 guess I aint going cuz 1 don 't have but 500unless u can come up with anything in next 30 min l triedgetting rent early even told her

id take tp/fzpp fshe 'dpay early Roger W wtan '/ help he suck balls''

Samuel ROBBINS to LAW SON, 6*U coming by''LAW SON to ROBBINS, isff will be late fnot early morning. Will try my best.t'

Angeline Delp to LAW SON , iiHave u heard anything/''LAW SON to Delp, Gx otyet.tt

LAW SON to PEAKE, çGWhat's goin on. Are u t?/c.?''

Toby MOCK to LAW SON, inll'as she made it backyet? 3nToby.')''LAWSON to MOCK, iil've not heard#om /):r.''M OCK to LAW SON, iCK. 111 try an call her to c wher she 9h?7Ft?:.p.'a)''M OCK to LAW SON, LiHerphone is turned tp

.J/'ïnrt?by.',)''LAW SON to M OCK , iLGood luck''MOCK to LAWSON, ièWell #-yl hearh'om herjus holla at me an 1 will do the sameLnToby.'l''

A. Delp to LAW SON, çistill waiting/''LAW SON to A. Delp, G*1 am to.''

LAW SON to PEAKE, GnRachael, what 's goin on? Gotpeople yelling at me.''

PEAKE to LAW SON, çLok how much ofthat wasyour $''LAW SON to PEAKE, iilhought we came up with 5. I've got to give Toby some.''

tt0/c uhrst gave me 300for u then 50for meds. Then u met me 2ndPEAKE to LAW SON,time gave me 150 total of500. 1 'm gonna give u 4 and 50$ cash a/w. Then aroundlunch time 1'm gonna give you 50 more cash cuz im getting rent today cuzyesterday 1wtzy desperate to get cash I told her Y'-ç/;c 'dgive me rent early 111 take l00 /7./'.:/ she

55


paying me today. Will that be ok so all 111 tpwc u J-//er I give u yours tfr 50$ will be 50 atIunch time is that cool''LAW SON to PEAKE, *%R u coming on ntpw?''PEAKE to LAW SON, CtFCJ can u meet me at shellplz about outta gas again 1 'll text wcn1 leave here getting ready to leave in 15''LAW SON to PEAKE, çiok butplease hurry. 1 'm leavin now. Put it down and come on.''

Based on my training and experience, and my knowledge of this organization, l believethat Rachael PEAKE and Roger LAW SON discussed $500.00 that LAW SON gave to PEAKEfor drugs for himself, Sam ROBBINS, Angeline DELP and Toby M OCK. I believe that PEAKEagreed to give LAW SON four (4) grams of methamphetamine and $50.00 cash now, and anadditional $50.00 cash when PEAKE collected rent from a tenant.

M arch 8 - 9, 2013

Roger LAW SON to Rachael PEAKE, inbley woman, katpw anything g/t)#?''PEAKE to LAW SON, iiGoing to go here in about 30 min.'tLAW SON to PEAKE, iil-hink u couldpicksomething upfor me.''PEAKE to LAW SON, iilfu will meet me.''LAW SON to PEAKE, Gisure will where and what time?''

PEAKE to LAW SON, CiIJJJ.C u happy with that'tLAW SON to PEAKE, Lçsure wJJ''

Based on my training and experience, and my knowledge of this organization, l believethat Rachael PEAKE agreed to pick up m ethamphetam ine for Roger LA W SON . 1 believe thatafter PEAKE supplied LAW SON , she inquired as to the quality of the m etham phetamine,

M arch 11, 2013

Roger LAWSON to Rachael PEAKE, QçDid u everhrure the deal on the money triangle''PEAKE to LAW SON, içWhat r u talking about? The message 1 sent u explained

everything. lpaid Toby her 50 that u give mefor the meds. She saidyou took care ofherwith the other 50.''LAW SON to PEAKE, içok, come me next time ur down.b'PEAKE to LAW SON, içokay u gave me 300 the 1't time. The second time u gave me150. Totaling 450. I gave u 4 and 50 cash. Ipaid Toby her 50 but that wasn 't evenincluded. What is it u r thinking 1 'm confused''LAW SON to PEAKE, i%1 'm satished Do uplan to go again. ''PEAKE to LAW SON , çiFri't

Based on m y training and experience, and my lcnowledge of this organization, I believethat Rachael PEAKE and Roger LAW SON discussed the prior drug transaction totaling $500.00.I believe that PEAKE told LAW SON that she was m aking another trip to purchasemethamphetamine on Friday (possibly to Mountain City, TN).

56


On April 23, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text messages stored in the accounts of several cellular telephone numbers,including those of Danny REECE and Rick SHAW . ln response to the execution of this searchwarrant on Verizon W ireless, agents received text messages stored in those accounts from April9 to April 23, 2013. The following is an excep t from the search warrant results.

April 10, 2013

Rachael PEAKE to Rick SHAW, *i1 got shitload ofrugs zitlw. f c/ me /czyt?w when u wantme tt I 'll bring e-''SHAW to PEAKE, G6ok tomar b 4 12:00 is gotaï'PEAKE to SHAW, ikol ifsomething happens 1 can 't get there before then l'llyell. Hell 1got all time in world now old man wtp?7 '/ be homefor several days.''SHAW to PEAKE, GQOIC''

April 11, 2013

PEAKE to SHAW , GQstill oklcomettSHA W to PEAKE, 1'Fc5'''PEAKE to SHAW , çiok 1 'm in Glade c u shortly''SHA W to PEAKE, %*Ok,'

April 20 - 21, 2013

PEAKE to SHAW , Qiblello hun. Hope u enjoying sunshine. AIl kins ofgoodies. Shoprags & shop towels. M ore rugs and industrial trash bags.''PEAKE to SHAW , ççsfeant to say 1 got u alI kinds ofgoodies''SHA W to PEAKE, iiYeap goodl need them''PEAKE to SHAW , GiWhen is a good timefor me to come over? Id like to talk to Dannyabout Iast time I m w him.',PEAIQE to SHAW , GQzjlso got u big roll ofbarbwirefor u to startfence with. Got boxfullfindustrial glovest,SHAW to PEAKE, iiGood csll me tomar eveningt,

PEAKE to SHAW , Gil-lello hope u doing well this awesome sunny spring dayll Wantingto c fwe can come your wtl? Christy riding with me.''SHAW to PEAKE, inon wJy b 2 :r-ç''PEAKE to SHAW , çiok so around 430 ok''SHAW to PEAKE, Gikkah u can but remind me what u sail'

Based on my training and experience, and m y knowledge of this organization, l believethat Rachael PEAKE communicated with Rick SHAW regarding m iscellaneous item s in herpossession that she wished to trade for metham phetamine. l believe that PEAKE advised SHAWthat she needed to speak with Danny REECE, a distributor for SHAW . l believe that SHAWagreed to trade with her the following day.

57


Locations

8282 Old M ill Road, Glade Spring, Virginia 2434013341 Country Living Lane, M eadowview, Virginia 24340

INITIAL SUM M ARY

Beginning in April 201 1 law enforcem ent began to obtain inform ation regarding themanufacturing and distribution of quantities of methamphetamine in the community of Saltvillelocated in W ashington Colmty, Virginia. Through arrests, interviews, and the cultivation ofcontidential inform ants, 1aw enforcement was able to identify a network of individuals involvedin the possession and distribution of crystal m ethamphetam ine comm only referred to as tçlce'' inSouthwest Virginia and Northeast Tennessee. The investigation shows that commencing on orabout January 1, 2009 and continuing to date, that in the W estern District of Virginia andelsewhere, the defendants lmowingly and unlawfully combined, conspired and agrted togetherand with each other, and with other persons, both known and unknown to distzibute and possesswith intent to distribute methamphetamine; to manufacture, distribute and possess with intent to

distribute methamphetamine: a1l in violation of Title 21, United States Code, Sections 841(a)(1),(b)(1)(A)(viii); maintaining drug involved premises in violation of Title 2 1, United States Code,Sedion 856 and Title 18, United States Code, Section 2. All in violation of Title 21, UnitedStates Code, Section 846.

From Jtme 2012 until the present, federal, state, and local law enforcement haveconducted interviews and executed controlled purchases of methamphetamine from membersengaged in both the manufacturing and trafficking of methamphetamine.

Timothy GERACE aka BUDDHA was identified as a distributor of methamphetamine inM ountain City, TN. In February 2013 undercover recordings of Timothy GERACE capturedaudio in which GERACE stated he was being supplied methamphetamine from a M exicanCartel. GERACE stated he had over seventy (70) tirearms and his methamphetamine rulmerswere armed. Through interviews and phone records it is known to law enforcement thatGERACE supplies m ethamphetamine to a network of individuals to include, Roger LAW SON ,Angela SURBER, Jason M ULLINAX, Brady LESTER, Joseph CcN athan HALL, W illiamHUNT, Jr., Rusty CASSELL, Toby M OCK and others in the W estern District of Virginia andthe Eastern District of Tennessee.

During the past several years GERACE and Richard itRick'' SHAW , also of M ountainCity, TN, have conspired to distribute quantities of m ethamphetam ine. Through interviews andphone records it is known to 1aw enforcem ent that SHAW supplies metham phetamine toGEM CE, Dalm y REECE, Roger LAW SON , Jim GRIND STAFF, M elvin CA M PBELL andothers.

5


Throughout the course of this investigation, numerous subpoenas and court orders wereissued for GPS tracking devices, telephone subscriber information, telephone toll records, andtext message content cm cellular telephones. Text messages were obtained via court order on thecell phones of Tim GERACE, Brady LESTER, Jason MULLINAX, Nathan HALL, RickSHAW , Danny REECE, Rusty CASSELL, Roger LAW SON, Linda W ALTERS, Toby M OCK,and others. Any cellular telephone subscriber information and all text m essages referred towithin this aftidavit, unless otherwise stated, are a result of these subpoenas and court orders.

PROBABLE CAUSE

SUBJECTS

Richard Charles SH AW

On February 25, 2009, M ichael Todd Layton was interviewed in Ashe County, NC.Layton stated that in December 2008, he purchased approximately $2,000.00 worth ofmethamphetamine from Rick SHAW in M ountain City, TN.

On July 14, 2009, Christy Adams was interviewed pursuant to a proffer agreement withthe United States Attorney's Office. Adams stated that in 2008, she traveled with RiehardSHAW from M ountain City, 'IN to Georgia to meet with Todd Layton. Adams stated thatSHAW was a methamphetamine distributor for the same source of supply as her (iûchip'' inGeorgia).

On December 22, 2009, a traffic stop was executed on a vehicle operated by RichardSHAW in Anderson County, South Carolina. Pursuant to a search of the vehicle, approximatelyone (1) pound of methamphetamine was seized. SHAW and his passenger, Melvin GlenCampbell, were arrested and charged with trafticking methamphetamine, As a result of theinvestigation SHAW and CAM PBELL were convicted of Attempt and Conspiracy ProvisionsDrug Law and received a five year suspended sentence and tive years probation.

On January 30, 2013 CS-4 was interviewed in Bristol, Virginia. CS-4 stated he/she,GERACE, and SHAW would sit and do meth at SHAW 'S residence. Through interviews andsurveillance SHAW 'S residence was identified as 382 T-Greer Road M ountain City, TN. CS-4stated in early to mid April 2012 until arotmd July 4, 2012, he/she and GERACE would go toSHA W 'S house approximately three tim es a week. W hile present with SHAW , SHAW wouldprovide meth to use. CS-4 advised SHAW called people to come to his house to pick up meth.CS-4 advised he/she and GERACE would go out and sell meth for SHAW . CS-4 stated therewas usually two to three zip lock bags full of methamphetnmine (ice) at SHAW 'S house. CS-4stated the meth had the appearance of shattered glass and was not packaged in individual baggiesbut was packaged a1l together in the bags. CS-4 stated the m ost he/she had seen at one tim e wasthree zip lock bags full with the least amount being one sm all bag. CS-4 stated SHAW launderedm oney through a fake business. CS-4 stated during personal conversations with SHAW , SHAWbragged about not having ajob and laundering money for ten years through his fake businessûtshaw Industries.'' CS-4 stated on one occasion he/she witnessed GERACE take $10,000.00cash to SHAW and observed GERACE personally hand the cash to SHAW .

6


Between February 4, 2013 and February 7, 2013, CS-4 met with GERACE. W ords to theeffect of the following were stated:

CS-4 asked GERACE about SHAW laundering m oney and how he does it. GERACEexplained: SHAW tinds people, you know you can't put that money in your bank account, youcan only put so m uch away and save som e stuff. W hat you do is buy land, find som eone whohas good collateral, they buy the land, you give them the money and pay it off a little at the time,nothing more than $4,800.00, anything more than that sends up a flag. Or you buy' a businesswith another person and put the money into the business and then get it back clean. GERACEsays he knows a guy up north who has over 20 businesses and moves his coke and pot m oneythrough them. You can go out and buy vehicles, the older ones with no loans. Buy and sell, justnot show it, that is how you get caught. When l work a realjob l make good money, $80,000-100,000 a year. That way I can make extra money and hide it like that. I bought this and that

and prove it when I have a real job. 1 had a lot of extra money in the box but being off the lastl two years Ssfucked me''. lt was fun but 1 am going to have to go back to work.

CS-4 asked what Rick SHAW is doing. GERACE says: SHAW is laying 1ow and acouple of his people have called him . Buddha says: he is leaving well enough alone right now,trying to watch himself right now, not taking on anyone new. Just take it slow and wait, seewhat happens. Don't get greedy because that's when you get sloppy. 1 don't need to be greedy.The CS-4 asked GERACE if he likes dealing with the other people (Mexicans) better. GERACEsays yes, when it is done there is no fucking around, no playing gnmes. Dealing with Rick(SHAW ) he made you feel like you owed him something. 1 always paid him cash on time and hestarted jerking me around. l called him on it and then 1 went and took what 1 thought was mineand then some (GERACE previously admitted to CS-4 he had broken into a residence owned by1 SHAW near Watauga Lake).

A search of real estate records through the Johnson County, Tennesssee assessor's officereveals property owned by SHAW located at 623 W haley Town Road, Butler, TN 37640. Theproperty was purchased on 10/13/2009 by Richard C. SHAW and Gary M arcus SHAW 11 for$35,000.00 with a $17,500.00 mortgage through Farmers State Bank. On 10/19/2009 bnnkrecords show Richard and Gary SHAW 11 paid off the balance of the loan ($18,342.35) with eachbrother paying approximately half of the remaining balance with cash, a11 in $20.00 bills. TheI residence is located approximately .5 miles from Watauga Lake.

According to the records of Verizon W ireless, telephone number (423) 302-9299 wassubscribed to by Richard C. SHAW at 382 T Greer Rd., M ountain City, TN . As a result of thisinvestigation, your affiant believes that the primary user of this phone number was Rick SHAW .

On April 10, 2013, a search warrant was applied for and obtained in the W estern Districtof Virginia for text messages stored in the accounts of several cellular telephone numbers,including that of Danny REECE. In response to the execution of this search warrant on VerizonW ireless, agents received text messages stored in that account from M arch 20 to M arch 27, 2013.The following is an excerpt from the search warrant results.


M arch 21, 2013

Danny REECE to Rick SHAW , iGlhis is Danny ncw no. Are you at homefor ajèw?''SHAW to REECE, iih?o b back 4 or 5''REECE to SHAW , *i10-4 throw me a text when on wJy thanka man''REECE to SHAW , çnNeed l whole an 1 J?J//''

Roger LAW SON to REECE, ;t1't)?: gonna wor/c in D town today?''REECE to LAWSON, çLYeah but it will be 5 or 6 before that guy gets home. Then 1'11Com e (?/Z

REECE to Rusty CASSELL, LQHe aint home ye/''CASSELL to REECE, çGlkhere 9 he at?''REECE to CASSELL, iilie said he would call when he got in /7tpz// J or 6prob''CASSELL to REECE, 6*Hell. Ok''

REECE to SHAW , $$?''SHAW to REECE, iiI 'm home man',REECE to LAWSON, GQManjus text me i1l hollor atya when in hand ''LAW SON to REECE, i*Ok''

REECE to LAW SON , inGot them truckparts but not com in thay wJy till morning. Come

up fyoud Iike to. ''REECE to CASSELL, çLGot help but not comi yr wJy till morn.''

Based on my training and experience, and my knowledge of this investigation, 1 believethat Danny REECE utilized the text messaging service on his cellular telephone to obtainmethamphetamine from Rick SHAW for the purpose of distributing it to Roger LAW SON andRusty CASSELL.

slarch 23,2013

Danny REECE to Rick SHAW , I<Ft??g be home in bout an hour''SHAW to REECE, içl'm home an 1 will b here... ''

REECE to SHAW , Gnl'm on my wayh'om D ftpwn now''

REECE to Rusty CASSELL, Gil-l'ey 1 can get rid of4 but theyjust got $110.00 apeaceinstead ofl20.00 can ya do l't?''CASSELL to REECE, LLsorry man but im in th hole again cant do it''REECE to CASSELL, *QOk told them 1 would ask u no àlïg,gy brother''REECE to CASSELL, LLETA Jj''7

Based on m y training and experience, and my knowledge of this investigation, l believethat Dnnny REECE utilized the text messaging service on his cellular telephone to attem pt to sellfour (4) grams of methamphetnmine for $1 10.00 per gram (instead of the going rate of $120.00

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richard shaw case xo.l . ) q /u )...

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