AO I 06 (Rev. 04/10) Application for a Search Warrant 

UNITED STATES DISTRICT COURT 

In the Matter of the Search of 

(Briefly describe the property to be searched or identify the person by name and address) 

for the 

Southern District of Ohio 

Case No. 

(614) 615-4220, with international mobile subscriber 

identity number 355987083045940 

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APPLICATION FOR A SEARCH WARRANT 

I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under 

penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the 

property to be searched and give its location): 

See Attachment A to the Affidavit in Support of this Application, all of which is incoporated herein. 

located in the ___ S_o_u_th_e_rn ___ District of ______ O_h_io _____ , there is now concealed (identify the 

person or describe the property lo be seized): 

See Attachment B to the Affidavit in Support of this Application, all of which is incoporated herein. 

The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more): 

r'lf evidence of a crime; 

0 contraband, fruits of crime, or other items illegally possessed; 

0 property designed for use, intended for use, or used in committing a crime; 

0 a person to be arrested or a person who is unlawfully restrained. 

The search is related to a violation of: 

Code Section Offense Description 

21 U.S.C. 846 Conspiracy to possess with intent to distribute a controlled substance 

The application is based on these facts: 

See attached Affidavit. 

r'lf Continued on the attached sheet. 

0 Delayed notice of __ days (give exact ending date if more than 30 days: _____ ) is requested 

under 18 U.S.C. § 3103a, the basis ofwhich is set forth on the attached sheet. 

Printed name and title 

Sworn to before me and signed in my presence. 

Date: 

'CJ Judge 's signature 

City and state: Columbus, Ohio Hon. Chelsey M. Vascura, U.S. Mag. Judge 

Printed name and title 

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IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO 

IN THE MATTER OF THE SEARCH OF 

THE CELLULAR TELEPHONE 

ASSIGNED CALL NUMBER (614) 615-

4220, WITH INTERNATIONAL MOBILE 

SUBSCRIBER IDENTITY NUMBER 

355987083045940 

2: 18 mj6 0 6 

Filed Under Seal 

AFFIDAVIT IN SUPPORT OF 

AN APPLICATION FOR A SEARCH WARRANT 

I, James Rose, 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 41and18 U.S.C. §§ 2703(c)(l)(A) for information about the 

location of the cellular telephone assigned call number (614) 615-4220, with International 

Mobile Subscriber Identity Number 355987083045940 (the "Target Cell Phone"), whose service 

provider is Metro PCS/T-Mobile, a wireless telephone service provider headquartered at 4 

Sylvan Way, Parsippany, New Jersey. The Target 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 Special Agent with the United States Drug Enforcement Administration 

(DEA) since September 2017. I am assigned to the Detroit Field Division, Columbus District 

Office. As such, I am an "investigative or law enforcement officer" of the United States within 

the meaning of Title 18 U.S.C. § 2510(7), that is, an officer of the United States empowered by 

law to conduct criminal investigations and make arrests for offenses enumerated in 18 U.S.C. § 

2516. I am empowered to investigate, to make arrests with or without warrants, and to execute 

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search warrants under the authority of21 U.S.C. § 878. Before becoming a Special Agent, I was 

an active duty U.S. Army Officer for 4 years and worked in Corporate Loss Prevention and 

Investigations for a total of 7 years. Your Affiant has accumulated the following training and 

experience: 

Completed the DEA Basic Agent Training Academy in Quantico, VA where 

I have received specialized narcotics-related training includes drug identification, 

interview and interrogation, managing informants, undercover operations, conspiracy 

investigations, surveillance and electronic monitoring techniques, tactical application 

of narcotics enforcement, search and seizure law, pharmaceutical diversion, 

clandestine drug labs, marijuana cultivation and money laundering investigations. I 

continue to receive training on a daily basis by conducting criminal narcotics 

investigations with, and drawing on the expertise of agents more experienced than 

myself. 

3. 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. 

PROBABLE CAUSE 

4. On or about early April, 2018, investigators with the Columbus, Ohio DEA office 

made contact with a Source of Information (SOI) claiming to have information regarding the 

distribution of illegal narcotics in the Central Ohio area. Through follow-on investigations, 

investigators were able to develop an SOI with direct, first-hand knowledge of a cell from 

Nayarit, Mexico affiliated to the Cartel Jalisco Nueva Generacion (CJNG). 

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5. Investigators were provided with information that an individual known as Ivan 

LOMELI was present in the Columbus, Ohio, and was in possession or control of a large amount 

of cocaine. Additionally, investigators were provided with phone number 614-446-3757 as a 

means to contact LOMELI. 

6. Subsequent toll analysis revealed that phone number 614-446-3757 was 

previously in contact with telephones that were involved in federal narcotics investigations as of 

April and May, 2018. On April 19, 2018, investigators were able to get a state court order 

authorizing geolocation data services of 614-446-3757. Through court ordered geo-location data 

investigators were able to place phone number 614-446-3757 in the presence oflvan LOMELI 

who was identified through photographs obtained from the SOI and through open sources. 

7. As of June, 2018, investigators were further informed by the SOI that ROBERT 

LOMELI was also currently in Columbus, Ohio, working in narcotics trafficking operations with 

IV AN LOMELI. Specifically, as of June, 2018, the SOI informed law enforcement that IV AN 

LOMELI was working for ROBERT LOMELI, and that ROBERT LOMELI was expecting a 

large shipment of illegal narcotics into Columbus, Ohio, for drug trafficking operations. 

8. Furthermore, the SOI informed investigators that Robert LOMELI had recently 

been arrested in California for narcotics violations. Through searches of law enforcement 

databases, investigators learned that an individual named Roberto Fabian LOMELI-BANUELOS 

had been arrested in California during May, 2017, and charged with Conspiracy to Possess with 

Intent to Distribute Cocaine. Furthermore, Roberto Fabian LOMELI-BANUELOS had been 

investigated in connection with money laundering and firearms violations. Investigators 

contacted members of the DEA Orange County (California) Office and were informed that, to 

their knowledge, Roberto Fabian LOMELI-BANUELOS was not incarcerated. Furthermore, 

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based on the investigation, the LOMELI-BANUELOS OTO, the Drug Trafficking Organization 

(OTO) with which ROBERT LOMELI is associated, has known ties to Ohio. 

9. Based on the foregoing, and upon the investigation to date, investigators believe 

ROBERT LOMELI is in fact Roberto Fabian LOMELI-BANUELOS. 

10. Investigators were able to identify Robert LOMELI through surveillance 

photographs taken by Columbus Police Department's Narcoti~s Unit from a related 

investigation. These photographs placed Robert LOMELI in Columbus, Ohio in the month of 

June 2018. 

11. Through tolls analysis investigators learned that the provided number for Robert 

LOMLEI of (614) 972-3944 was in contact with phone numbers from multiple current federal 

narcotics investigations. In July of2018 investigators were able to obtain a federal search 

warrant for the geo-location data for (614) 972-3944 but the account had been closed before the 

geo-location data could be initiated. Subsequently investigators do not have a current address or 

vehicle for Robert LOMELI. 

12. An administrative subpoena for phone account subscriber data for Ivan 

LOMELI's phone (614) 446-3757 revealed a billing address of 4748 Bay Run Dr. in Columbus, 

Ohio. Through open source data, investigators were able to locate a phone number of (614) 772-

9191 that was being used with utility accounts in the name of Ivan LOMELI at the address of 

4037 Meadowleigh Way, Columbus, Ohio. 4037 Meadowleigh Way, Columbus, Ohio, is the 

address where investigators observed Ivan LOMELI through surveillance and prior phone 

geolocation data for (614) 446-3757 in the months of April through June of2018. An 

administrative subpoena for the account subscriber data for (614) 772-9191 revealed a subscriber 

oflvan Omar Lomeli Hernandez and an address of 4748 Bay Run Dr. in Columbus, Ohio, which 

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was the same billing address for (614) 446-3757. Toll analysis for (614) 772-9191 revealed that 

the phone was in contact with phone numbers associated with more than 12 current federal 

narcotics investigations. 

13. Investigators have not been able to locate a valid address, additional vehicle 

registrations, or any other documentation associated to members of the LOMELI-BANUELOS 

DTO through open source searches. 

14. The most frequently contacted telephone number of (614) 772-9191 is (614) 615-

4220. An administrative subpoena of subscriber data for (614) 615-4220 revealed that the 

subscriber was Ivan Omar LOMELI Hernandez with a billing address of 4748 Bay Run Dr. in 

Columbus, Ohio. Tolls analysis revealed that (614) 615-4220 is in contact with phone numbers 

from 5 current federal narcotics investigations as well as phone numbers used from multiple 

prior Title III investigations. Further analysis revealed that (614) 615-4220 is in contact with 

multiple phone numbers from Mexico and Canada as well as a phone number from Brownsville, 

Texas, which was directly related to narcotics trafficking from a previous DEA Tiii investigation 

in Columbus, Ohio. 

15. Investigators have not been able to locate a valid address, additional vehicle 

registrations, or any other documentation associated to members of the LOMELI-BANUELOS 

DTO through open source searches. 

16. In summary, investigators have been able to repeatedly and independently verify 

information that has been obtained through the SOI. Investigators have verified this information 

on multiple occasions through database searches, records checks, surveillance, and speaking with 

other law enforcement officers. Investigators have not been able to make contact with the SOI 

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for more than 6 weeks. Previous phone numbers that were provided have since had the accounts 

closed. 

17. Investigators have placed Robert LOMELI and Ivan LOMELI in Columbus, 

Ohio. Investigators believe that Robert and Ivan LOMELI's presence in the Columbus, Ohio 

area, in connection with the DTO's known connections to Ohio indicate strongly to their 

involvement in the distribution of the DTO's illegal narcotics, and remittance of the proceeds of 

their sales. 

18. Investigators believe a phone ping/E-911 court order, for phone number (614) 

615-4220, with International Mobile Subscriber Identity Number 355987083045940 is a 

reasonable and necessary step in furtherance of this investigation for the identification of 

persons, vehicles, and locations involved in the DTO's narcotics trafficking operation. 

19. In my training and experience, I have learned that T-Mobile/Metro PCS is a 

company that provides cellular telephone access to the general public. I also know 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 cellular telephones to which they 

provide service: (1) E-911 Phase II data, also known as OPS data or latitude-longitude data, and 

(2) cell-site data, also known 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 OPS 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 data 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 connected. These towers are often a half-mile or more apart, even in urban areas, and 

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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 T-Mobile can collect E-911 

Phase II data about the location of the Target Cell Phone, including by initiating a signal to 

determine the location of the Target Cell Phone on T-Mobile's network or with such other 

reference points as may be reasonably available. 

21. Based on my training and experience, I know that T-Mobile can collect cell-site 

data about the Target Cell Phone. 

AUTHORIZATION REQUEST 

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

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

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

Procedure 4l(f)(3), that the Court authorize the officer executing the warrant to delay notice until 

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

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 Cell Phone 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 

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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 T-Mobile/Metro PCS to disclose to the 

government any information described in Attachment B that is within the possession, custody, or 

control ofT-Mobile/Metro PCS. I also request that the Court direct T-Mobile/Metro PCS 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 T-Mobile/Metro PCS's services, including by initiating a signal to 

determine the location of the Target Cell Phone on T-Mobile/Metro PCS's 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 T-Mobile/Metro PCS for 

reasonable expenses incurred in furnishing such facilities or assistance. 

25. I further request that the Court authorize execution of the warrant at any time of 

day or night, owing to the potential need to locate the Target Cell Phone outside of daytime 

hours. 

26. 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 good cause to seal these documents 

because their premature disclosure may seriously jeopardize that investigation. 

Respectfully submitted, 

~s; ~ 

8 

Special Agent 

DEA 

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Subscribed and sworn to before me on q ~ u S \-- l V , 2018 

CHELSEY M"'.7V ASCURA 

ST A TES MAGISTRATE JUDGE 

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ATTACHMENT A 

Property to Be Searched 

1. The cellular telephone assigned call number (614-615-4220) whose wireless 

service provider is T-Mobile/Metro PCS a company headquartered at 4 Sylvan Way, 

Parsippany, New Jersey. 

2. Information about the location of the Target Cell Phone that is within the 

possession, custody, or control ofT-Mobile/Metro PCS. 

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ATTACHMENT B 

Particular Things to be Seized 

All information about the location of the Target Cell Phone 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 ofT-Mobile/Metro PCS, 

T-Mobile/Metro PCS is required to disclose the Location Information to the government. In 

addition, T-Mobile/Metro PCS 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 T-Mobile/Metro PCS' s services, 

including by initiating a signal to determine the location of the Target Cell Phone on TMobile/Metro PCS's 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 T-Mobile/Metro PCS for reasonable expenses incurred in furnishing such facilities 

or assistance. 

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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