UNJTED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF omo 

WESTERN DIVISION 

FILED 

RICHARD W. HAGEL 

CLERK OF COURT 

2018 AUG 17 AH IQ: 08 

U 3 DISTRICT COURT 

SOUTHi::RN DIST OHIO 

WEST DIV Cl~lC NNAT I 

IN THE MATTER OF THE SEARCH OF 

THE CELLULAR TELEPHONE 

ASSIGNED CALL NUMBER 513-578-4046 

(SPRINT CORP.) 

CASE NO. t ; 18 M J -4 9 2 

UNDER SEAL 

AFFIDAVIT IN SUPPORT OF 

AN APPLICATION FOR A SEARCH WARRANT 

I, Anthony D. Peters, being first duly sworn, hereby depose and state as follows: 

INTRODUCTION AND AGENT BACKGROUND 

1. I make this affidavit in support of an application for a search warrant under Federal 

Rule of Criminal Procedure 41 and 18 U.S.C. §§ 2703(c)(l)(A) for information about the location 

of the cellular telephone assigned call number 513-578-4046 ("Target Telephone"), whose 

service provider is Sprint Corp., a wireless telephone service provider headquartered at 6480 Sprint 

Parkway, Overland Park, KS 66251. The targeted cell phone is described herein and in Attachment 

A, and the location information to be seized is described herein and in Attachment B. 

2. I am a Task Force Officer with the Federal Bureau of Investigation (FBI), and 

have been since May 2014. I am also a Cincinnati Police Officer and have been since March 

2004. I have conducted investigations into criminal enterprises, narcotics investigations, 

organized crime, and violent crimes to include the unlawful possession, possession with the 

intent to distribute, and actual distribution of controlled substances, as well as the associated 

conspiracies in violation of Title 21, United States Code, Sections 841(a)(l) and 846. 

3. Your affiant has also participated in the execution of federal search warrants and 

federal arrest warrants in relation to these investigations. Additionally, your affiant has 

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participated in the installation and monitoring of tracking devices for v.ehicles in order to 

determine the whereabouts of believed drug traffickers and their illicit merchandise. Your affiant. 

has also been involved with the monitoring responsibilities of Title III Wire intercepts, and 

analysis of pen registers related to narcotics and gang investigations. Your affiant is familiar with 

their methods of concealing the whereabouts of their illegal drugs, the methods they use to keep 

law enforcement officers from finding evidence of drug trafficking operations as well as the 

methods they use to prevent others unfamiliar with their criminal conduct from observing things 

indicative of drug trafficking. Your affiant is also familiar with the evasive nature surrounding 

most drug traffickers and the common ways in which wholesale drug distributors attempt to 

conceal their assets, their purchases, and other financial dealings that could be traced to them. 

4. Through my training and experience I am aware that drug traffickers often 

communicate with their customers, couriers, and/or associates through the use of standard hardline telephones, cellular telephones and digital display paging devices, or use of multiple 

telephones or other devices, to avoid detection by law enforcement. 

5. The facts in this affidavit come from my personal observations, my training and 

experience, and information obtained from other agents and witnesses. This affidavit is intended 

to show merely that there is sufficient probable cause for the requested warrant and does not set 

forth all of my knowledge about this matter. 

6. Based on the facts set forth in this affidavit, there is probable cause to believe that 

violations of 18 United States Code, Sections 1071, Concealing Person from Arrest, have been 

committed, are. being committed, and will be committed by AMANDA KlRICHUK, and other asyet unknown individuals. There is also probable cause to believe that the location of Target 

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Telephone will constitute evidence of this criminal violation, and will lead to the identification of 

individuals who are engaged in the commission of this offense. 

PROBABLE CAUSE 

7. The Cincinnati FBI has been investigating the JOHN MOORE Drug Trafficking 

Organization (JMDTO) since June of201 l. As well, the JMDTO has been identified as a source 

of supply for multiple other DTO's involving drug and gang investigations by the Cincinnati FBI 

since that time. Throughout the course of the investigation, RICARDO CAMPBELL ha~ been 

identified as MOORE's "right hand man" and primary fentanyl, cocaine, and heroin distributor 

forthe DTO. 

8. In February of2017, Title III interceptions were authorized in regards to voice . 

communications taking place on the phone being utilized by CAMPBELL. During interceptions 

Agents overheard numerous conversations related to the sale of narcotics. 

9. During the course of the Title III intercepts, Agents heard multiple narcotics 

related phone calls with RONNIE PARROTT who was utilizing 513-903-3 760. On March 8, 

2017, the Honorable Stephanie K. Bowman, United States Magistrate Judge, authorized the 

collection of precise location data pertaining to P ARROTI's cellular telephone, 513-903-3 760. 

Based on toll analysis, Agents believe PARROT stopped utilizing 513-903-3760 in April of 

2017. 

10. On February 7, 2018, P ~OTT was charged in a multiple count indictment 

against the JMDTO for Conspiracy to Possess with intent to distribute fentanyl, cocaine, and 

heroi~ and a subsequent arrest warrant was issued for PARROTT on that date. 

11. On July 2, 2018, through open source data base checks and investigative analysis, 

Agents identified telephone phone number 513-578-4046, (Target Telephone), to be utilized by 

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PARROTT's fiance, AMANDA K.IRICHUK.. This was confirmed through telephone 

conversations between Agents and K.IRICHUK who verified her identity after be~ng contacted 

on the Target Telephone. KIRICHUK also stated that she was PARROTT's fiance and that 

PARROTT was not guilty of the charges that he is currently wanted on, admitting to her 

knowledge of both the warrants and that he was actively evading law enforcement. 

12. On July 13, 2018, a Greater Cincinnati Northern Kentucky Crime Stoppers tip 

(Tip ID: 208-H58135) was forwarded to the FBI regarding PARROTT's whereabouts. The 

anonymous tipster stated that PARROTT was residing at the CROSSLAND HOTEL (11457 

Chester Rd. Sharonville, OH 45246) in Sharonville, OH, possibly Rm. 243, and had been staying 

at that location with the help of K.IRICHUK.. 

13. On August 9, 2018, an anonymous tip was provided through the Federal Bureau 

of Investigation's (FBI) Public Access Line (PAL) stating that PARROTT was staying in 

multiple rooms at the CROSSLAND EXTENDED STAY HOTEL (11457 Chester Rd. 

Sharonville, OH 45246) with KIRTCHUK. The tipster stated that PARROTT and KIRICHUK 

were staying under assumed names in order to remain anonymous, due to PARROTT' s wanted 

status, when booking multiple rooms and switching them regularly. The phone number provided 

by the PAL tipster for KIRICHUK was the Target Telephone. 

14. Since February 2018, Agents attempted to locate PARROTT without success. 

Multiple surveillances were conducted at PARROTT's permanent and temporary residences and 

interviews of previous neighbors and family members were also conducted in an attempt to 

locate PARROTT. Through investigative correspondence with KIRICHUK, both PARROTT 

and K.IRICHUK are aware that PARROTT is wanted by the FBI. 

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15. Based on the foregoing, the investigative team believes KIRICHUK. has used, and 

continues to use, the Target Telephone to assist PARROTT in evading law enforcement. 

KIRICHUK. is fully aware of P ARROTT's fugitive status and is taking deliberate steps to harbor 

PARROTT from the authorities. As detailed herein, investigators believe KlRICHUK uses the 

Target Telephone to misdirect law enforcement's effort to locate and arrest PARROTT. 

16. The requested information will assist law enforcement in identifying the location 

of Target Telephone, which will i.dentify the location of KIRICHUK., who has been staying 

with, traveling with, and harboring PARROTT, and ultimately assist Agents in effecting the 

arrest of RONNIE PARROTT. 

17. Since this affidavit is being submitted for the lμnited purpose of securing 

authority for obtaining precise location information of a specific phone being used by the 

targeted, I have not included each and every fact known to me concerning this investigation. I 

have set forth only the facts that I believe are required to establish the necessary foundation for 

an order authorizing the collection of precise location information pertaining the Target 

Telephone. 

18. Based on the aforementioned facts and reporting, I believe there is probable cause 

to show that Amanda Kirichuk is using Target Telephone to commit a federal offense and that 

the information requested will assist the Federal Bureau of Investigation in locating Ronnie Parrott 

and Amanda Kirichuk. 

19. In my training and experience, I have learned that providers of cellular telephone 

service have technical capabilities that allow them to collect and generate at least two kinds of 

information about the locations of the ceilular telephones to which they provide service: (1) E-911 

Phase II data, also known as GPS data or latitude-longitude data, and (2) cell-site data, also known 

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as "tower/face information" or cell tower/sector records. E-911 Phase II data provides relatively 

precise location information about the cellular telephone itself, either via GPS tracking technology 

built into the phone or by triangulating on the device's signal using data from several of the . . 

provider's cell towers. Cell-site d~ta identifies the "cell towers" (i.e., antenna towers covering 

specific geographic areas) that received a radio signal from the cellular telephone and, in some 

cases, the "sector" (i.e., faces of the towers) to which·the telephone com1ected. These towers are 

often a half-mile or more apart, even in urban areas, and can be 10 or more miles apart in rural 

areas. Furthermore, the tower closest to a wireless device does not necessarily serve every call 

made to or from that device. Accordingly, cell~site data is typically less precise that E-911 Phase 

II data. 

20. Based on my training and experience, I know that wireless phone companies can 

collect E-911 Phase II data about the location of the Target Telephone, including by initiating a 

signal to determine the location of the Target Telephone on Sprint Corp. network or with such 

. other reference points a~ may be reasonably available. 

21 . Based on niy training and experience, I know that wireless phone companies can 

also collect cell-site data about the Target Telephone. 

AUTHORIZATION REQUEST 

22. Based on the foregoing, I request that the Court issue the proposed search warrant, 

pursuant to Federal Rule of Criminal Proced_ure 41and18 U.S.C. § 2703(c). 

23. I further request, pursuant to 18 U.S.C. § 3103a(b) and Federal Rule of Criminal 

Procedure 41 (f)(3), that the Court authorize the officer executing the warrant to delay notice lintil 

30 days after the collection authorized by the warrant has been completed. There is reasonable 

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cause to believe that providing immediate notification of the warrant may have an adverse result, 

as defined in 18 U.S.C. § 2705. Providing immediate notice to the subscriber or user of the Target 

Telephone would seriously jeopardize the ongoing investigation, as such a disclosure would give 

that person an opportunity to destroy evidence, change patterns of behavior, notify confederates, 

and flee from prosecution. See 18 U.S.C. § 3103a(b)(l). As further specified in Attachment B, 

which is incorporated into the warrant, the proposed search warrant does not authorize the seizure 

of any tangible property. See 18 U.S.C. § "3103a(b )(2). Moreover, to the extent that the warrant 

authorizes the seizure of any wire or electronic communication (as defined in 18 U.S. C. § 2510) 

or any stored wire or electronic information, there is reasonable necessity for the seizure for the · 

reasons set forth above. See 18 U.S.C. § 3103a(b)(2). 

24. I further request that the Court direct the Sprint Corp. to disclose to the government 

any information described in Attachment B that is within the possession, custody, or· control of 

Sprint Corp .. I also request that the Court direct Sprint Corp. to furnish the government all 

information, facilities, and technical assistance necessary to accomplish the collection of the 

information described in Attachment B unobtrusively and with a minimum of interference with 

Sprint Corp. services, including by initiating a signal to detemline the location of the Target 

Telephone on Sprint Corp. network or with such other reference points as may be reasonably 

-

available, and at such intervals and times directed by the government. The government shall 

reasonably compensate Sprint Corp. for reasonable expenses incurred in furnishing such facilities 

or assistance. 

25. I further request that the Court authorize the government to install and operate a 

ce11-site simulator to obtairi dialing, routing, addressing, and signaling information from the t 

Target Telephone to determine the location of the Target Telephone. 

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26. I further request th!it the Court authorize execution of the warrant at any time of 

day or night, owing to the potential need to locate the Target Telephone outside of daytime hours. 

I further request that the Court order that all papers in support of this application, including the 

affidavit and search warrant, be sealed until further order of the Court. These documents discuss 

an ongoing criminal investigation that is neither public nor known to all of the targets of the 

investigation. Accordingly, there is probable cause to seal these documents because their 

premature disclosure may seriously jeopardize that investigation. 

Respectfully submitted, 

5:> Task Force Officer · 

Federal Bureau of Investigation 

Subscribed and sworn to before me on this J 7 day of August, 2018. 

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ATTACHMENT A 

Property to Be Searched 

1. The cellular telephone assigned call number 513-578-4046, (Target Telephone), whose 

wireless service provider is Sprint Corp., a wireless telephone service provider 

headquartered at 6480 Sprint Parkway, Overland Park, KS 66251. 

2. Information about the location of the ·cellular telephone assigned call number 513-578-

4046, (Target Telephone), that .is within the possession, custody, or control of Sprint 

Corp., including · information about the location of the cellular telephone if it is 

subsequently assigned a different call number. 

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ATIACHMENTB 

Particular Things to be Seized 

All information about the location of the Target Telephone described in Attachment A for 

a period of thirty days, during all times of day and night. "Information about the location of the 

target cell phone" includes all available E-911 Phase II data, OPS data, latitude-longitude data, 

and other precise location information, as well as all data about which "cell towers" (i.e., antenna 

towers covering specific geographic areas) and "sectors" (i.e., faces of the towers) received a radio 

signal from the cellular telephone described in Attachment A. 

To the extent that the information described in the previous paragraph (hereinafter, 

"Location Information") is within the possession, custody, or control of Sprint Corp., is required 

to disclose the Location Information to the government. In addition, Sprint Corp. must furnish the 

government all information, facilities, and technical assistance necessary to accomplish the 

collection of the Location Information unobtrusively and with a minimum of interference with 

Sprint Corp. services, including by initiating a signal to determine the location of the target cell 

phone on Sprint Corp. network or with such other reference points as may be reasonably available, 

and at such intervals and times directed by the government. The government shall compensate 

Sprint Corp. for reasonable expenses incurred in furnishing such facilities or assistance. In 

addition the government may initiate a signal to determine the location of the target cell phone. 

This warrant does not authorize the seizure of any tangible property. In approving this 

warrant, the Court finds reasonable necessity for the seizure of the Location Information. See 18 

U.S.C. § 3103a(b)(2). 

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