UNITED STATES DISTRICT COURT

DISTRICT OF MARYLAND

UNITED STATES OF AMERICA

v.

FrankAIDOO CRIMINAL COMPLAINT

CASE NUMBER: 00/ -I /~ rsKC-
I, Richard Federico, the undersigned complainant being duly sworn state the following is true and
correct to the best of my knowledge and belief. On or about March 30, 2009 in the District of Maryland,
defendant did, (Track Statutory Language Offense)

Knowingly and intentionally import into the United States of America, from a place outside
thereof, 1.2 kilograms or more of a mixture or substance containing a detectable amount of
heroin, a Schedule I controlled substance, and did knowingly and intentionally possess with the
intent said quantity of heroin,

in violation of Title .lL United States Code, Section(s) 952(a), 960 (a) and 841.

I further state that I am a Special Agent of the U.S. Immigration and Customs Enforcement, and that this
complaint is based on the following facts: Official Title

SEE ATTACHED AFFIDAVIT

CdJhtinuedon the attached sheet and made ~ part hereof: ~ No

Sworn to before me and subscribed in my presence,

March 30, 2009 at

Date

United States Magistrate Judge

AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT

I. Purpose of the Affidavit

1. This affidavit is submitted in support of a criminal complaint charging

Frank AIDOO with conspiracy to import 1.2 kilograms or more of a quantity of a

mixture or substance containing heroin, a Schedule I controlled substance, into

the United States from a place outside the United States, to wit, Ghana and

elsewhere, in violation of21 U.S.C. sections 952(a) and 960(a).

II. Your Affiant

2. Your affiant, Richard Federico, is a Special Agent of the United States

Department of Homeland Security, Immigration and Customs Enforcement (ICE),

in Baltimore, Maryland. As such, your affiant is a law enforcement officer of the

United States within the meaning of Section 2510(7) of Title 18 of the United

States Code, that is, an officer empowered by law to conduct investigations of,

and make arrests for, offenses enumerated in Section2516 of Title 18.

3. Your affiant is a Special Agent with United States Immigration and

Customs Enforcement (ICE), under the Department of Homeland Security and is

presently assigned to the Smuggling/Narcotics Group, at the Baltimore

Washington International (BWI) Airport. During his tenure as a Federal Criminal

Investigator, your affiant has participated in numerous investigations involving

smuggling, narcotics, and other unlawful activities. These investigations have

included the use of surveillance techniques and the execution of search, seizure,

and arrest warrants. Your affiant has attended the Criminal Investigator Training
 ()r - /( b i' 5)ee;,
Program and Customs Basic Law Enforcement Academy at the Federal Law

Enforcement Training Center. Your affiant is familiar with the facts and

circumstances of the investigation that is the subject of this search warrant

application. Your affiant has been employed with u.s Customs Service /ICE

since January 1998.

III. Probable Cause

4. On Friday, March 27, 2009, at approximately 1801 hours, Frank AIDOO,

Citizen of Netherlands (Ghana born) (DOB 12-02-54) arrived at Baltimore

Washington International Airport, Baltimore, Maryland aboard a British Airways

Flight Number 229 from London Heathrow International Airport, London, Great

Britain England. Customs and Border Protection (CBP) Officer obtained

information regarding AIDOO's airfare and prior activities. AIDOO's ticket was

purchased (cash) three days prior to flight. Intelligence obtained alleged that

AIDOO had been involved in heroin smuggling activities. AIDOO had traveled to

an address in New York utilized by Nigerian heroin smugglers, who were

apprehended at John F. Kennedy Airport and in Boston. Upon questioning by

CBP Officers, AIDOO became very nervous and did not know where he was

staying. AIDOO indicated that his purpose for travel was that he was visiting his

nephew for a couple of weeks. CBP Officers contacted the alleged nephew, and

the stories told by AIDOO and alleged nephew were different. Upon further

questioning, AIDOO informed the CBP inspectors that he had ingested pellets of

heroin. AIDOO was taken to Baltimore Washington Medical where he passed 100

_~~'Jf. __ ~ •.••• t
 pellets of heroin; total weight of 1.2 kilograms of heroin. A field test.on a sample

of the pellets was positive for heroin.

5. On Saturday, March 28, 2009, Immigration and Customs Enforcement, Special

Agents (SA) Rick Federico and Irina Kuvykina identified themselves and

explained to AIDOO that he under arrest for the smuggling of heroin. At

approximately 1301' hours, SA Federico advised AIDOO of his Miranda Rights in

the English language witnessed by SA Kuvykina. AIDOO indicated that he

understood his rights and requested to speak with an attorney before answering

any question. At this time, the interview was terminate~.

IV. Conclusion

Based on the foregoing, I submit that there is probable cause to believe

that Frank AIDOO did knowingly and intentionally import 1.2 kilograms or more

of a quantity of a mixture or substance containing heroin, a Schedule I controlled

substance into the United States from a place outside the United States, and did

possess heroin with the Intent to distribute it, in violation of21 U.S.C. 952, 960

and 841(a).

Richard Federico ~ f~
Special Agent, U.S. Immigration and ~s~
J--
Enforcement

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