AO 91 (Rev. 08/09) Criminal Complaint 

AUSA: Christopher Rawsthorne 

Special Agent: Scott Nedoff, DEA 

UNITED STATES DISTRICT COURT 

United States of America, 

v. 

for the 

Eastern District of Michigan 

Case: 4: 14-mj-30563 

Sergio Collins Assigned To : Hluchaniuk, Michael J. 

Assign. Date: 11/4/2014 

Description: SEALED MATTER (TH) 

CRIMINAL COMPLAINT 

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

On or about the date(s) of June 1 l, 2013 & October 2, 2014 , in the county of Genesee 

Eastern District of Michigan , the defendant(s) violated: 

Code Section 

21 U.S.C. §84 l(a) 

21 U.S.C. §841(a) 

This criminal complaint is based on these facts: 

Please See Attachment. 

X Continued on the attached sheet. 

Sworn to before me and signed in my presence. 

Date: 11/4/2014 

Offense Description 

Delivery of Heroin 

Possession with Intent to Distribute Heroin 

Scott Nedoff, Special Agent, DEA 

Printed name and title 

Judicial Officer signature 

, in the 

City and state: Flint, Ml Michael Hluchaniuk, Magistrate Judge 

Printed name and title 

Case 4:15-cr-20154-MFL-MJH ECF No. 1, PageID.1 Filed 11/04/14 Page 1 of 5
AFFIDAVIT 

I, SCOTT NEDOFF, being duly sworn state the following is true and accurate to 

the best of my knowledge and belief: 

1. I am a Special Agent with the United States Department of Justice, 

Drug Enforcement Administration (DEA), having been so designated since 

December 1999. I am a graduate of Michigan State University where I received 

my B.A. in Criminal Justice. During my career as a DEA Special Agent, I have 

been involved in numerous investigations concerning the identification and 

distribution of controlled substances and I have received training in these areas. I 

have authored numerous affidavits in support of search and seizure warrants, arrest 

warrants, and Title III wire intercept orders, leading to the seizure of controlled 

substances and the arrests of drug traffickers. The following is based on my 

investigation as well as statements from other law enforcement officers and 

individuals. 

2. This affidavit is intended to show only that there is sufficient probable 

cause for the requested warrant and does not set forth all of my knowledge about 

this matter. Additionally, unless otherwise noted, wherever in this affidavit I assert 

that an individual made a statement, that statement is described in substance 

herein, and is not intended to be a verbatim recitation of such statement. 

Case 4:15-cr-20154-MFL-MJH ECF No. 1, PageID.2 Filed 11/04/14 Page 2 of 5
3. I make this affidavit in support of the arrest of Sergio COLLINS for 

violations of 21 U.S.C. §841(a), Possession with Intent to Distribute Heroin and 

Delivery of Heroin. 

4. On June 11, 2013, law enforcement officers from the Michigan State 

Police Flint Area Narcotics Group observed Sergio COLLINS and another 

individual meet up at the Rite Aid parking lot at Ballenger and Flushing in the city 

of Flint in the Eastern District of Michigan. 

5. They observed an apparent drug transaction between the individual 

and COLLINS. The other individual was stopped by law enforcement and admitted 

that he had purchased heroin from COLLINS. This individual handed law 

enforcement a comer cut tie containing approximately .1 gram of suspected heroin. 

The Michigan State Crime laboratory would later test and confirm that the 

substance was heroin. 

6. Law enforcement stopped COLLINS on that and recovered $2157.00 

from COLLINS. COLLINS drove a 2007 Dodge Challenger registered to his 

mother at 1213 Eldorado A venue in Flint, Michigan. 

7. On October 2, 2014, Drug Enforcement Administration agents, who 

had obtained a search warrant for COLLINS' residence at 1213 Eldorado, 

conducted surveillance and observed COLLINS leaving 1213 Eldorado in the city 

of Flint. After observing him enter a car with another individual, law enforcement 

Case 4:15-cr-20154-MFL-MJH ECF No. 1, PageID.3 Filed 11/04/14 Page 3 of 5
approached. Approximately 50 grams of heroin were recovered from the vehicle, 

and COLLINS threw a large amount of United States currency while fleeing from 

agents. COLLINS was arrested following that foot chase. 

8. A search warrant on 1213 Eldorado on that same date resulted in the 

recovery of approximately 20 grams cocaine base, approximately3 grams heroin, 

and approximately $11,000 United States currency from a room that appeared to be 

COLLINS' room. Both of the aforementioned items tested positive in field tests for 

the presence of cocaine base and heroin, respectively. The room contained male 

clothing and photographs of COLLINS. Moreover, other bedrooms appeared to 

belong to the other two residents of the home, COLLINS' brother and mother. I 

believe that those substances were possessed with intent to distribute based on 

COLLINS' previous behavior and the lack of items in the residence or on 

COLLINS' person to engage in use of such substances. COLLINS' brother also 

identified the room as Sergio COLLINS room as well. 

Case 4:15-cr-20154-MFL-MJH ECF No. 1, PageID.4 Filed 11/04/14 Page 4 of 5
9. Based on the above referenced statements, I believe that there is 

probable cause to issue a complaint against Sergio COLLINS for Delivery of 

Heroin on June 11, 2013 and Possession with Intent to Distribute Heroin on 

October 2, 2014. 

Dated this 4th day ofNovember, 2014 

Scott Nedoff, Special A ent 

Drug Enforcement Administration 

Sworn to before me this 4th day of November, 2014. 

Hon. Michael Hluchaniuk 

United States Magistrate Judge 

Case 4:15-cr-20154-MFL-MJH ECF No. 1, PageID.5 Filed 11/04/14 Page 5 of 5