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AO 91 (Rev. 11/11) Criminal Complaint AUSAs Richard M. Rothblatt (312) 353-4558 and Jason Julien (312) 886-4156

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA

v. 

SAM HOWARD; 

WILLIE TATE; 

 also known as “Junebug”;

KELVIN FRANKLIN, 

also known as “Kevo” or “Nico”; 

STEVEN DYER; 

MORRIO BONDS; 

ANTONIO LEE; 

BRYANT BARNES; 

DWAYNE PETERSON;

ANTHONY DAVIS; 

FLOYD STEWART; 

WILL HOWARD;

TORIAN JOHNSON; 

JAMES HUGHES;

KAMRON GARRAWAY;

SAVAN WARD; 

JEREMY HAMPTON; 

JOHNNIE DANIELS; and

ROBERT STUCKEY,

also known as “Ant”

CASE NUMBER: 

UNDER SEAL

CRIMINAL COMPLAINT 

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

and belief. 

From no later than in or about February 2019 to in or about November 2019, in the Northern 

District of Illinois, Eastern Division, and elsewhere, the defendants violated:

Code Section Offense Description

Title 21, United States Code, Section 

846

did conspire with each other, and with others 

known and unknown, to knowingly and 

intentionally possess with intent to distribute 

and distribute a controlled substance, namely, 

400 grams or more of a mixture and substance 

containing a detectable amount of fentanyl (N20CR353

FILED 7/14/2020

THOMAS G. BRUTON CLERK, U.S. DISTRICT COURT

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phenyl-N-[1-(2-phenylethyl)-4-piperindinyl] 

propanamide), a Schedule II Controlled 

Substance, one kilogram or more of a mixture and 

substance containing a detectable amount of 

heroin, a Schedule I Controlled Substance, and a 

quantity of a mixture and substance containing a 

detectable amount of acetyl fentanyl, valeryl 

fentanyl, and furanyl fentanyl, Schedule I 

Controlled Substances and analogues of fentanyl 

(N-phenyl-N-[1-(2-phenylethyl)-4-piperidinyl] 

propanamide), a Schedule II Controlled 

Substance, in violation of Title 21, United States 

Code, Section 841(a)(1).

This criminal complaint is based upon these facts:

 X Continued on the attached sheet.

JAMES J. LEE

Special Agent, Drug Enforcement Administration 

(DEA)

Sworn to before me and signed prior to submission. 

Date: July 14, 2020

Judge’s signature

City and state: Chicago, Illinois HEATHER K. MCSHAIN, U.S. Magistrate Judge

Printed name and Title

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

 ss:

AFFIDAVIT

I, JAMES J. LEE, being duly sworn, state as follows:

1. I am a Special Agent with the Drug Enforcement Administration (DEA),

and have been so employed for eight years.1 My current responsibilities include the 

1 On September 1, 2016, Special Agent James J. Lee appeared before a Magistrate Judge in 

the Northern District of Illinois as the affiant on an application for a search warrant to search 

the first floor unit at 4601 South Albany, Chicago, Illinois. The Magistrate Judge issued the 

warrant and the DEA executed it the same day. During the evening of September 1, 2016, 

based on information regarding the execution of the warrant, SA Lee and an AUSA who had 

assisted with the warrant realized that the search warrant affidavit contained inaccurate 

information. The government notified the Magistrate Judge about the inaccurate information 

in the search warrant application, stating:

[P]aragraph 19 of the Affidavit submitted in support of the search warrant stated that

“Agents saw De La TORRE exit his vehicle, enter through a gate door on 46th Street, and

then enter the back door leading into the first floor of the Subject Premises.” However, in

fact, agents saw De La TORRE exit his vehicle, enter through a gate door on 46th Street

[which was the courtyard gate door], and then disappear into the courtyard. Agents had

surveillance on two visible doors to 4601 South Albany Ave. and believed that De La Torre

went into the back door of 4601 South Albany Ave. that was not visible. In other words, the

affidavit should have provided that agents believed that De La TORRE went into the back

door based on the facts set forth above, rather than stating that they saw him enter that back

door.

Paragraph 20 of the Affidavit further stated that: “At approximately 5:54 p.m., surveillance 

agents observed De La TORRE exit the back door of the Subject Premises, walk to the 

alleyway behind the Subject Premises ....” That paragraph should have provided that agents 

observed De La TORRE exit the back gate door of the Subject Premises, not the back door of 

the Subject Premises.

After receiving this information, the Magistrate Judge told the government she would not 

have signed the warrant if the surveillance had been accurately described by the agent, and 

that she expected the U.S. Attorney’s Office to make a disclosure regarding SA Lee if he were 

going to testify or be an affiant on future complaints or warrants. 

Later in the investigation, agents observed the same subject enter and exit the back door that 

was described in the original affidavit, and the subject admitted that he did in fact reside in 

the unit described in the affidavit. A DEA Office of Professional Responsibility investigation 

did not conclude that SA Lee knowingly and intentionally provided false information, and he 

was issued a non-disciplinary letter of caution for inattention to duty.

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investigation of narcotics trafficking offenses. I am currently assigned to the office of 

the Chicago Field Division located in Chicago, Illinois. I have received training in 

and have experience investigating violations of federal narcotics and money 

laundering laws including, but not limited to, Title 21, United States Code, Sections 

841, 843, and 846 and Title 18, United States Code, Section 1956, 1957, and 1960. I 

have participated in numerous investigations involving a variety of investigative 

techniques, including physical and electronic surveillance methods, controlled 

purchases and deliveries of narcotics, the analysis of a wide variety of records and 

data, including pen register and trap and trace data as well as cell phone location 

data, and the debriefing of defendants, informants, and witnesses, as well as others 

who have knowledge of the distribution, transportation, storage, and importation of 

controlled substances. 

2. This affidavit is submitted in support of a criminal complaint alleging

that, beginning no later than in or about February 2019 and continuing to in or about 

November 2019, in the Northern District of Illinois and elsewhere, defendants SAM 

HOWARD, WILLIE TATE, also known as “Junebug,” KELVIN FRANKLIN, also 

known as “Kevo” or “Nico,” STEVEN DYER, MORRIO BONDS, ANTONIO LEE, 

BRYANT BARNES, DWAYNE PETERSON, ANTHONY DAVIS, FLOYD STEWART, 

WILL HOWARD, JEREMY HAMPTON, JOHNNIE DANIELS, TORIAN JOHNSON, 

JAMES HUGHES, KAMRON GARRAWAY, SAVAN WARD, and ROBERT 

STUCKEY, also known as “Ant,” did conspire with each other, and with others known 

and unknown, to knowingly and intentionally possess with intent to distribute and 

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distribute a controlled substance, namely, 400 grams or more of a mixture and 

substance containing a detectable amount of fentanyl (N-phenyl-N-[1-(2-

phenylethyl)-4-piperindinyl] propanamide), a Schedule II Controlled Substance, one

kilogram or more of a mixture and substance containing a detectable amount of 

heroin, a Schedule I Controlled Substance, and a quantity of a mixture and substance 

containing a detectable amount of acetyl fentanyl, valeryl fentanyl, and furanyl 

fentanyl, Schedule I Controlled Substances and analogues of fentanyl (N-phenyl-N-

[1-(2-phenylethyl)-4-piperidinyl] propanamide), a Schedule II Controlled Substance,

all in violation of Title 21, United States Code, Section 846.

3. The information in this affidavit is based on my participation in this

investigation, information provided by other local and federal law enforcement 

officers (“LEOs”), the results of physical surveillance, review of consensually recorded 

conversations, review of wire and electronic communications intercepted pursuant to 

court orders, law enforcement reports, my training and experience, and the training 

and experience of other law enforcement officers with whom I have consulted.

4. Because this affidavit is being submitted for the limited purpose of

establishing probable cause in support of a criminal complaint charging SAM 

HOWARD, TATE, FRANKLIN, DYER, BONDS, LEE, BARNES, PETERSON, 

DAVIS, STEWART, WILL HOWARD, HAMPTON, DANIELS, JOHNSON,

HUGHES, GARRAWAY, WARD, and STUCKEY with conspiracy to possess with 

intent to distribute and distribute heroin, fentanyl-laced heroin, and fentanylanalogue laced heroin, I have not included each and every fact known to me 

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concerning this investigation. I have set forth only the facts that I believe are 

necessary to establish probable cause to believe that the defendants committed the 

offense alleged in the complaint.

FACTS SUPPORTING PROBABLE CAUSE

I. BACKGROUND OF THE MONTICELLO DTO

5. Since approximately February 2019, the DEA and the Chicago Police 

Department (the “CPD”) have conducted a criminal investigation into a drug 

trafficking organization (the “Monticello DTO”) responsible for distributing 

approximately 12.6 kilograms of heroin, 16.2 kilograms of fentanyl-laced heroin, 7.4 

kilograms of fentanyl-analogue laced heroin, and 2.56 kilograms of heroin laced with 

both fentanyl and fentanyl analogue at an illicit retail drug market on the 1000 block 

of N. Monticello Avenue in the Humboldt Park neighborhood of Chicago (the 

“Monticello Avenue Drug Spot”). As part of that investigation, the DEA and CPD 

introduced multiple undercover agents who have made approximately eighty

purchases of heroin, fentanyl-laced heroin, and fentanyl-analogue laced heroin from 

various members of the Monticello DTO. 

A. Roles of the Defendants

6. Throughout the course of the investigation, the DEA and CPD have 

identified numerous drug traffickers involved in the sale of narcotics at this illicit 

market. Based on the investigation, including approximately eighty undercover 

purchases, surveillance of the Monticello Avenue Drug Spot, review of CPD Pole 

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Camera video, and intercepted phone calls and text messages, the investigation has 

revealed that:

a. SAM HOWARD and KELVIN FRANKLIN, also known as “Kevo”

or “Nico,” were street-bosses or street managers for the Monticello DTO, working with 

WILLIE TATE, MORRIO BONDS, and ANTONIO LEE to ensure that the Monticello 

DTO had sufficient quantities of heroin, fentanyl-laced heroin, and fentanyl-analogue 

laced heroin to distribute to customers. SAM HOWARD and FRANKLIN also 

coordinated the distribution of narcotics to customers while on Monticello Avenue by 

directing customers to particular street-level distributors. Over the course of the 

investigation, SAM HOWARD and FRANKLIN personally distributed narcotics to 

undercover officers on 15 and 19 occasions, respectively.

b. WILLIE TATE, MORRIO BONDS, and ANTONIO LEE had

access to sources of supply of heroin, fentanyl-laced heroin, and fentanyl-analogue 

laced heroin, obtained and cut the narcotics with additives and dilutants, re-packaged 

the narcotics in aluminum foil and/or baggies, and provided the narcotics to SAM 

HOWARD and FRANKLIN and other members of the Monticello DTO in order to 

provide those narcotics to street-level traffickers of the Monticello DTO who would, 

in turn, distribute the narcotics to customers. 

c. STEVEN DYER, BRYANT BARNES, DWAYNE PETERSON,

ANTHONY DAVIS, FLOYD STEWART, WILL HOWARD, JEREMY HAMPTON, 

JOHNNIE DANIELS, TORRIAN JOHNSON, JAMES HUGHES, KAMRON 

GARRAWAY, SAVAN WARD, and ROBERT STUCKEY, and others were street-level 

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traffickers who sold narcotics to customers on Monticello Avenue at SAM HOWARD 

and FRANKLIN’s direction. Following these sales, the street-level traffickers 

provided SAM HOWARD and FRANKLIN with the proceeds of the sales. As 

discussed above and below, SAM HOWARD and FRANKLIN personally sold 

narcotics to customers as well. 

B. Summary of Probable Cause

7. Between on or about February 19, 2019 and in or about November 2019,

the Monticello DTO distributed at least 12.6 kilograms of heroin, 16.2 kilograms of 

fentanyl-laced heroin, 7.4 kilograms of fentanyl-analogue laced heroin, and 2.56 

kilograms of substances containing a fentanyl analogue, fentanyl, and heroin to 

individual customers at the Monticello Avenue Drug Spot. Specifically, and as 

discussed in greater detail below: 

a. Between February 19, 2019 and November 2019, law enforcement

participated in approximately 80 hand-to-hand exchanges of heroin, fentanyl-laced 

heroin, and fentanyl-analogue laced heroin at the Monticello Avenue Drug Spot.

b. Between February 19, 2019 and October 2019, undercover law

enforcement officers purchased approximately 188.937 grams of heroin, 244.39 grams 

of fentanyl-laced heroin, and 112.859 grams of substances containing a fentanyl 

analogue, over the course of approximately 80 separate purchases at the Monticello 

Avenue Drug Spot from various members of the Monticello DTO. These transactions 

included:

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i. On March 6, 2019, BARNES and JOHNSON sold 

approximately 1.76 grams of heroin to UC-2.

ii. On March 22, 2019, TATE delivered a supply of heroin to 

the Monticello Avenue Drug Spot, a portion of which DWAYNE PETERSON sold to 

UC-1. 

iii. On April 2, 2019, SAM HOWARD, JAMES HUGHES, and 

Individual A sold approximately 2.194 grams of heroin to undercover officers. 

iv. On April 9, 2019, TATE delivered a resupply of heroin to 

the Monticello Avenue Drug Spot, a portion of which (approximately 18.095 grams) 

STEVEN DYER sold to UC-2.

v. On April 19, 2019, SAM HOWARD and KAMRON 

GARRAWAY sold approximately 4.072 grams of heroin to undercover officers, while 

BARNES looked out for police. 

vi. On May 3, 2019, DYER sold approximately 21.013 grams 

of heroin laced with fentanyl and a fentanyl analogue (acetyl fentanyl) to UC-2.

vii. On May 3, 2019, ANTHONY DAVIS and FLOYD 

STEWART sold approximately 7.302 grams of heroin to undercover officers. 

viii. On May 30, 2019, DYER sold approximately 33.345 grams 

of heroin laced with and a fentanyl analogue (furanyl fentanyl) to UC-2. 

ix. On June 13, 2019, FRANKLIN, JEREMY HAMPTON and 

JOHNNIE DANIELS sold approximately 5.29 grams of heroin to undercover agents. 

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x. On June 14, 2019, DYER sold approximately 31.249 grams

of heroin to UC-2. 

xi. On June 18, 2019, SAM HOWARD and FRANKLIN sold

approximately 25.575 grams of fentanyl-laced heroin to undercover agents. 

xii. On June 28, 2019, DYER sold approximately 31.926 grams

of fentanyl-laced heroin to UC-2. 

xiii. On July 18, 2019, FRANKLIN sold approximately 40.338

grams of heroin to undercover officers. 

xiv. On October 1, 2019, SAM HOWARD, STUCKEY and

SAVAN WARD sold approximately 6.294 grams of heroin to undercover agents. 

c. Throughout the conspiracy, LEE, BONDS, SAM HOWARD, and

FRANKLIN managed the narcotics supply at the Monticello Avenue Drug Spot, 

monitoring inventory on the block and keeping the block supplied for street-level 

sales. Among other things:

i. SAM HOWARD and FRANKLIN arranged to resupply the

Monticello Avenue Drug Spot following DYER’s sale of narcotics to UC-2 on August 

16, 2019. 

ii. On September 3, 2019, FRANKLIN provided DYER a

quantity of heroin laced with a fentanyl analogue, a portion of which (approximately 

22.7 grams) DYER sold to UC-2.

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iii. On September 4, 2019, FRANKLIN supplied WILL

HOWARD with narcotics, a portion of which (approximately 3.6 grams of heroin and 

1.2 grams of cocaine) was seized by LEOs.

iv. In September 2019, LEE and BONDS discussed narcotics

that they previously cut on behalf of the DTO prior to giving them to SAM HOWARD 

and FRANKLIN for distribution at the Monticello Avenue Drug Spot.

v. On September 23, 2019, BONDS arranged the collections

of narcotics proceeds from FRANKLIN.

vi. On September 29, 2019, LEE instructed FRANKLIN to

distribute narcotics to BONDS.

vii. On September 29, 2019, LEE and BONDS arranged to

provide FRANKLIN with narcotics for the Monticello Avenue Drug Spot.

d. Throughout the conspiracy, members of the Monticello DTO

discussed the management and operation of the Monticello Avenue Drug Spot, 

including: (i) the coordinated efforts of all street-level traffickers selling narcotics on 

the block; (ii) the sale of narcotics packaged by and obtained from the same source; 

(iii) street-level managers directing customers to street-level traffickers to complete

hand-to-hand exchanges; (iv) DTO leaders directing DTO block managers to 

distribute free samples of narcotics to increase sales at the drug spot; (v) DTO 

members coordinating efforts to monitor and avoid detection by law enforcement; (vi) 

the possession of firearms to protect the drug spot; (vii) the staffing and hiring of 

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street-level traffickers on the block; and (viii) the monitoring of the narcotics supply 

and street-level traffickers at the Monticello Avenue Drug Spot.

e. Based on the quantity of narcotics purchased by undercover

officers throughout the course of the investigation, intercepted phone calls reflecting 

thousands of dollars of narcotics proceeds generated on a daily basis during the course 

of the interception periods alone, surveillance, and CPD Pod camera video reflecting 

street-level traffickers on Monticello Avenue transacting business, agents believe 

that, between February 2019 and October 2019, members of the Monticello DTO 

possessed with intent to distribute and distributed at least 12.6 kilograms of heroin, 

16.2 kilograms of fentanyl-laced heroin, 7.4 kilograms of fentanyl-analogue laced 

heroin, and 2.56 kilograms of substances containing a fentanyl analogue, fentanyl, 

and heroin. 

II. SURVEILLANCE OBSERVES NUMEROUS AND COORDINATED

HAND-TO-HAND EXCHANGES AT THE MONTICELLO AVENUE

DRUG SPOT

8. As discussed below, SAM HOWARD, FRANKLIN, TATE, BONDS, and

LEE and other members of the Monticello DTO used numerous individuals to traffic 

hundreds of grams of fentanyl-laced heroin to numerous customers, including 

undercover agents, at the Monticello Avenue Drug Spot.

A. Background on the Creation and Use of “Drug Spots” by Drug

Trafficking Organizations

9. Through training, experience, law enforcement training publications

about narcotics distribution, and from my conversations with confidential sources 

and other law enforcement officers who have expertise in such matters, I am familiar 

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with various characteristics of street-level drug trafficking organizations and their 

use of the use of designated locations as “drug spots.” For example, I am aware that: 

a. Drug spots are organized street-level retail narcotics markets 

that operate on a permanent or semi-permanent basis. Drug spots often consist of a 

group of people working in “shifts” to run the spot, and drug spot workers often work 

at one or more jobs, such as recruiting buyers on the street, providing security, 

looking out for law enforcement, collecting money, mixing and packaging narcotics 

for resale, distributing narcotics to street-level dealers and users, and maintaining 

stash houses to store narcotics and narcotics proceeds.

b. DTOs operating on the street-level are typically hierarchical 

organizations with individuals who have connections to narcotics suppliers, liaise 

with the suppliers, obtain bulk narcotics, and cut and re-package the narcotics to 

increase the quantity of narcotics available for distribution and adjust the potency of 

the narcotics. DTOs operating on the street-level often have street-level bosses or 

managers, who supervise street-level traffickers, assist in serving customers, and 

obtain narcotics proceeds, which are later provided to the individuals with 

connections to the suppliers to obtain additional quantities of narcotics. Street-level 

traffickers distribute narcotics to customers in hand-to-hand transactions in 

exchange for cash. Often times, DTOs store narcotics and/or narcotics proceeds in 

homes, vacant lots, and vehicles, which serve as stash locations. Street-level bosses 

and street-level traffickers typically deal in smaller quantities because they are 

serving end-use customers and because they seek to minimize losses in case of a 

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seizure or robbery and legal exposure by possessing and distributing smaller amounts 

of narcotics, which are associated with lower penalties.

c. Narcotics traffickers, including drug spot workers, use a number

of methods to evade detection by law enforcement, including, for example: using 

cellular phones or messaging applications registered to fictitious or false names or 

nicknames; using coded language to identify themselves and to discuss and conduct 

their illegal activities; frequently changing cellular phone numbers or messaging 

application accounts, or using multiple phone and messaging accounts 

simultaneously. 

d. DTOs typically package 13 individual doses of heroin (called

“blows” or “bags”), together, which is referred to as a “jab.” Each “bag” in the “jab” 

contains less than one gram of mixed heroin, fentanyl-laced heroin, or fentanylanalogue laced heroin. Six “jabs” are packaged together to make a “bundle.” After 

packaging the heroin in this manner, DTO members deliver the “bundle” to the drug 

spots, where the individual jabs are distributed between the street-level traffickers

for resale to individual customers. Typically, street-level traffickers receive 13 bags 

in a jab, and return the proceeds for some smaller number of bags (11 or 12), keeping 

the price of the remaining bags (1 or 2) as their share of the profit off each jab.

B. Surveillance Observes Numerous and Coordinated Hand-toHand Exchanges at the Monticello Avenue Drug Spot

10. Between February 2019 and November 2019, law enforcement officers

conducted regular surveillance near the Monticello Avenue Drug Spot. Throughout 

this period, surveillance regularly observed patterns of behavior that, in my 

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experience and based on my familiarity with this investigation, show that the area 

functioned as an open-air drug spot. Among other things:

a. On numerous occasions, surveillance observed various people, 

including SAM HOWARD, FRANKLIN, DYER, and others, standing or sitting near 

the intersection of Monticello Avenue and Augusta Boulevard, while various other 

people walked up and down the sidewalks around that area before returning to the 

intersection where others remained in place. Based on my training, experience, and 

familiarity with this investigation – including the movements of these individuals, 

subsequent controlled purchases from various individuals on that block, and a 

subsequent seizure of narcotics from a location on that block – I believe that some of 

the people whom agents observed on those occasions were working on the Monticello 

Avenue Drug Spot as lookouts, security, street-level narcotics dealers, runners, 

money collectors, or marketers (commonly known as “hypes” or “touts,” who advertise 

the sale of narcotics to customers on the street). 

b. On numerous occasions, surveillance observed individuals 

approach the area around the Monticello Avenue Drug Spot, both on foot and by car, 

speak briefly with individuals situated on the block, and then conduct a quick handto-hand exchange with people in nearby vacant lots. Based on my training, 

experience, and familiarity with this investigation – including the movements of 

these individuals, subsequent controlled purchases from various individuals on that 

block, and a subsequent seizure of narcotics from a location on that block – I believe 

that many of the individuals whom agents observed engage in hand-to-hand 

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transactions were drug customers who paid money for narcotics during these 

exchanges.

11. According to Chicago police reports, between January 1, 2017 and May

13, 2020, there have been approximately 2,424 arrests for narcotics related offenses,

approximately 227 arrests for weapons-related offenses, and 19,241 narcotic calls for 

service in the area around the Monticello Avenue Drug Spot. 

12. Based on my training and experience, familiarity with the investigation,

a review of police reports, controlled purchases of narcotics (discussed below), and 

surveillance of numerous, coordinated hand to hand transactions, I believe the 1000 

block of N. Monticello Avenue is a drug spot operated by the Monticello DTO.

III. CONTROLLED PURCHASES OF NARCOTICS AT THE MONTICELLO

AVENUE DRUG SPOT

13. Between February 19, 2019 and October 2019, undercover law

enforcement officers purchased approximately 188.937 grams of heroin, 244.39 grams 

of fentanyl-laced heroin, and 112.859 grams of substances containing a fentanyl 

analogue, over the course of approximately 80 separate purchases at the Monticello 

Avenue Drug Spot from various members of the Monticello DTO, including SAM 

HOWARD, FRANKLIN, and DYER. Among many other controlled purchases of 

narcotics2: 

2 Unless otherwise noted, each of the undercover purchases of narcotics discussed below, and 

each undercover purchase that occurred throughout the course of the investigation, was 

recorded by body-worn cameras operated by the undercover officer making the purchase 

and/or CPD Pod cameras setup on Monticello Avenue, and observed by surveillance agents. 

Immediately following each undercover purchase from the Monticello DTO, the suspected 

narcotics were turned over to the DEA and later tested by the DEA North Central Laboratory. 

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• KELVIN FRANKLIN sold approximately 43.261 grams of heroin, 

66.451 grams of fentanyl-laced heroin, 8.81 grams of fentanyl-analogue 

laced heroin, and 14.34 grams of fentanyl-analogue laced heroin and 

cocaine as part of approximately 19 sales to undercover officers.

• SAM HOWARD sold approximately 17.227 grams of heroin and 33.468

grams of fentanyl-laced heroin as part of approximately 15 sales to 

undercover officers.

• STEVEN DYER sold approximately 102.573 grams of heroin, 160.749

grams of fentanyl-laced heroin, and 95.248 grams of fentanyl-analogue 

laced heroin as part of approximately 21 sales to undercover officers.

• BRYANT BARNES sold approximately 11.387 grams of heroin and

6.929 grams of fentanyl-laced heroin as part of approximately 11 sales 

to undercover officers.

• DWAYNE PETERSON sold approximately 4.611 grams of heroin and

8.506 grams of fentanyl-laced heroin as part of approximately 8 sales to 

undercover officers.

• ANTHONY DAVIS sold approximately 7.303 grams of fentanyl-laced 

heroin as part of approximately 3 sales to undercover officers. 

• FLOYD STEWART sold approximately 9.33 grams of fentanyl-laced 

heroin as part of approximately 4 sales to undercover officers.

• JEREMY HAMPTON sold approximately 5.29 grams of fentanyl-laced 

heroin as part of approximately 2 sales to undercover officers. 

• JOHNNIE DANIELS sold approximately 3.289 grams of heroin and 

6.526 grams of fentanyl-laced heroin as part of approximately 5 sales to 

undercover officers. 

• JAMES HUGHES sold approximately 3.338 grams of heroin as part of 

approximately 3 sales to undercover officers.

• TORIAN JOHNSON sold approximately 4.139 grams of heroin as part 

of 3 sales to undercover officers.

• KAMRON GARRAWAY sold approximately 4.072 grams of heroin as 

part of 2 sales to undercover officers.

 

Each drug exhibit tested positive for heroin and/or fentanyl-laced heroin, including fentanyl 

analogues.

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• SAVAN WARD sold approximately 6.294 grams of heroin as part of 2

sales to undercover officers.

• WILL HOWARD sold approximately 4.1 grams of heroin as part of

approximately 2 sales to undercover officers

• ROBERT STUCKEY sold approximately 6.294 grams of heroin as part

of approximately 2 sales to undercover officers.

The following details some of the aforementioned controlled purchases.

A. UC-2 Purchases 1.76 Grams of Heroin from BARNES and JOHNSON

on March 6, 2019.

14. On or about March 6, 2019, at approximately 11:30 a.m., law

enforcement officials established surveillance in the area of Monticello Avenue in 

anticipation of an undercover officer (UC-2) attempting to purchase narcotics from 

members of the Monticello DTO. UC-2 was equipped with an audio and video 

recording device prior to the transaction.

15. At approximately 11:47 a.m., surveillance observed UC-2 arrive on

Monticello Avenue and walk southbound down the street. While UC-2 walked down 

the street, BRYANT BARNES3 and TORIAN JOHNSON4 approached and engaged 

3 Law enforcement officials identified BRYANT BARNES as follows: on February 19, 2019, 

UC-2 purchased four tin foil packets of heroin from an individual (later determined to be 

BARNES). Following the distribution on February 19, 2019, law enforcement officials 

approached the individual to identify him and completed an ISR. During that stop, the 

individual identified himself as BRYANT BARNES. Officers then pulled a photograph of 

BRYANT BARNES from a law enforcement database. UC-2 reviewed the photograph and 

identified BRYANT BARNES as the individual who facilitated the sale of heroin on February 

19, 2019.

4 Law enforcement officials identified TORIAN JOHNSON as follows: following the 

distribution on March 6, 2019 discussed below, law enforcement officials approached the 

individuals whom UC-2 had encountered in order to identify them and completed an ISR. 

During that stop, one individual identified himself as TORIAN JOHNSON. Officers then 

pulled a photograph of TORIAN JOHNSON from a law enforcement database. UC-2 

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in a recorded conversation with him. During the conversation,5 UC-2 stated: “Hey, 

bro, could I get four [blows of heroin]?” JOHNSON replied: “What you want?” UC-2 

responded: “Blow [heroin].” UC-2 asked JOHNSON: “How you’ve been, man? You’ve 

taken care [sold narcotics to] of me before.” BARNES replied: “I know who you is, 

I’ve seen you around here. Keep walking, that way.” JOHNSON asked: “How much 

you need?” UC-2 responded: “Four [blows of heroin].” BARNES said: “He’s 

[JOHNSON] going to hit [serve] you.” UC-2 responded: “Yeah.” JOHNSON replied: 

“Stay right here, I got you.” UC-2 responded: “Alright, man.” JOHNSON replied: 

“Keep your head up. Four [blows of heroin]?” UC-2 responded: “Yeah.”

16. According to UC-2 and body cam video, shortly after this exchange,

JOHNSON handed UC-2 four tin foil packets containing a white powdery substance 

and UC-2 gave JOHNSON $40 in government funds.

17. UC-2 provided the four tin foil packets containing the white powdery

substance distributed by BARNES and JOHNSON to the DEA North Central 

reviewed the photograph and identified TORIAN JOHNSON as the individual who provided 

the narcotics to him on March 6, 2019.

5 Some of the lawfully intercepted conversations (“recorded conversations”) have been 

summarized in this Affidavit. The language that is quoted from the recorded conversations 

throughout this Affidavit is based draft, not final, transcripts of the recorded conversations.

The times listed for the recorded conversations are approximate and, unless otherwise 

indicated, reflect the time in the North American Central Time Zone. The summaries do not 

include all statements or topics covered during the course of the recorded conversations. At 

various points in the Affidavit I have included in brackets my interpretation of words and 

phrases used in the recorded conversations. My interpretations are based on information 

received from the contents and context of the recorded conversations, events that took place 

before and after the conversations, my knowledge of the investigation as a whole, my 

experience and training, and the experience and training of other law enforcement agents in 

this investigation

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Laboratory. According to the laboratory, the substance weighed approximately 1.76 

grams and tested positive for the presence of heroin.

B. TATE Delivers a Supply of Heroin to the Monticello Avenue Drug Spot, 

a Portion of Which DWAYNE PETERSON Sells to UC-1 on March 22, 

2019.

18. On or about March 22, 2019, at approximately 9:30 a.m., law 

enforcement officials established surveillance in the area of Monticello Avenue in 

anticipation of an undercover officer (UC-1) attempting to purchase narcotics from 

members of the Monticello DTO. UC-1 was equipped with an audio and video 

recording device prior to the transaction.

19. At approximately 9:19 a.m., surveillance observed UC-1 arrive on 

Monticello Avenue and walk southbound towards Augusta Blvd. where UC-1 

observed three individuals at the northwest corner of Augusta Boulevard and 

Monticello Avenue. UC-1 recognized one of the three individuals as DWAYNE 

PETERSON.6

20. According to UC-1 and body cam video, at approximately 9:25 a.m., UC1 approached a narcotics customer (Individual H) to discuss the sale of heroin. 

 

6 Law enforcement officials identified DWAYNE PETERSON as follows: on February 22, 

2019, an undercover officer purchased a small quantity of heroin from an individual on 

Monticello Avenue. After the purchase, law enforcement officials stopped the individual who 

had sold the undercover officer the heroin. The individual supplied his name (DWAYNE 

PETERSON) and date of birth. Officers pulled a booking photograph of “Dwayne Peterson” 

and confirmed that the individual depicted in the photograph was the same person that had 

sold heroin to the undercover officer on February 22, 2019. In addition, during the course of 

the investigation, law enforcement officials (UC-1, UC-2, UC-3) purchased heroin from an 

individual on February 22, March 8, and March 15, 2019 and took photographs of that 

individuals. Law enforcement officials compared the surveillance photographs and video 

recordings from the purchases to photographs from law enforcement databases and 

determined that the individual who had sold heroin to the UCs was PETERSON.

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During that recorded encounter, UC-1 asked: “They’re not up [selling heroin] right 

now?” Individual H responded: “Nah.” UC-1 replied: “What they [the street-level 

traffickers] say?” Individual H answered: “They say about five to ten minutes.” 

32. According to UC-1 and body cam video, UC-1 then walked towards the

middle of Monticello Avenue and approached PETERSON and the other two 

individuals. UC-1 asked the three individuals for some “D [heroin].” PETERSON 

stated to UC-1: “Go wait by the lot down there,” and directed UC-1 to go wait in an 

empty lot in the middle of the block. Before UC-1 walked to the vacant lot, UC-1 

asked: “How long [before the street-level traffickers could distribute more heroin]?” 

PETERSON responded: “10 minutes.” UC-1 then walked to the vacant lot located in 

the middle of Monticello Avenue. 

33. At approximately 9:38 a.m., law enforcement officers conducting

surveillance observed a Chevy Impala drive north bound on Monticello Avenue and 

park in the area of a residence on Monticello Avenue. Law enforcement officials 

observed that the vehicle was only occupied by one individual, the driver, TATE.7 

Upon TATE’s arrival in the Chevy Impala, agents observed the following:

7 Law enforcement officials identified WILLIE TATE as follows: first, law enforcement 

officials pulled a Chicago Police booking photograph of WILLIE TATE and showed the 

photograph to a source of information (“SOI-1”) who confirmed that WILLIE TATE is the 

same individual he knew as Junebug. Second, after the April 9, 2019 distribution by DYER 

and TATE, law enforcement officials who conducted surveillance confirmed that the 

individual who arrived during the encounter to supply DYER was the same person depicted 

in the booking photograph of WILLIE TATE.

On or about May 24, 2019, the Honorable Rubén Castillo, then Chief Judge for the Northern 

District of Illinois, entered an order authorizing the initial interception of wire 

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a. PETERSON immediately approached the passenger window of 

the Chevy Impala and reached into the vehicle through the window. PETERSON 

retrieved a small-unidentified object from the Chevy Impala and placed it into his 

right jacket pocket. The encounter took only a few seconds.

b. After retrieving the item from the Chevy Impala, PETERSON 

walked at a fast pace to the gangway of a residence on Monticello Avenue.

c. Less than a minute later, PETERSON emerged from the gangway 

of the residence on Monticello Avenue and called UC-1 to approach him. 

34. Based on my training, experience, and familiarity with this case – 

including prior and subsequent surveillance and recorded conversations with 

PETERSON, the timing of TATE’s arrival, and PETERSON’s subsequent sale of 

heroin to UC-1 – I believe that the workers at the Monticello Avenue Drug Spot, 

including PETERSON, had temporarily run out of narcotics to sell and TATE 

delivered a resupply of heroin for the block.

 

communications to and from Target Phone 1 (the “May 24, 2019 Order”). Interception began 

on May 24, 2019 and terminated on June 13, 2019.

Law enforcement officials identified TATE as the driver of the Chevy Impala as follows: after 

arriving on Monticello Avenue and meeting with PETERSON, who obtained items from the 

Chevy Impala and sold two packets of heroin to UC-1, the driver of the Chevy Impala exited 

and reentered the Chevy Impala on multiple occasions. During one occasion, law 

enforcement officials conducting surveillance approached the driver of the Chevy Impala and 

asked his name and date of birth. The driver identified himself as “Willie Tate” and provided 

his date of birth. Officers later pulled booking photographs for TATE from the Chicago Police 

Department database and confirmed that the individual depicted in the photographs was the 

same individual whom they had stopped driving the Chevy Impala. Agents conducting 

surveillance on March 22, 2019 identified the driver of the Chevy Impala as TATE. 

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35. According to UC-1 and body camera video, UC-1 approached 

PETERSON and gave PETERSON $20 in government funds and PETERSON gave 

UC-1 one bag containing a white powdery substance. PETERSON stated to UC-1:

“You want one [blow of heroin]?” UC-1 told PETERSON: “I want two [blows of 

heroin]. Give me another one, dog, let me get one more, baby.” PETERSON then 

directed UC-1 to go back where he was standing on the sidewalk. PETERSON 

immediately returned to the gangway of the residence on Monticello Avenue and reapproached UC-1. PETERSON then gave UC-1 another bag containing a white 

powdery substance.

36. UC-1 provided the bags containing a white powdery substance supplied 

by PETERSON to the DEA North Central Laboratory. According to the laboratory, 

the two bags weighed approximately .904 grams and tested positive for the presence 

of heroin.

C. UCs Purchases 2.194 Grams of Heroin from SAM HOWARD, JAMES 

HUGHES, and Individual A on April 2, 2019.

37. On or about April 2, 2019, at approximately 9:30 a.m., law enforcement 

officials established surveillance in the area of Monticello Avenue in anticipation of 

UC-3 and UC-10 attempting to purchase narcotics from members of the Monticello 

DTO. UC-3 and UC-10 were equipped with audio and video recording devices prior 

to the transaction. Based on a review of the UCs audio and video recordings, and 

according to the UCs:

a. At approximately 3:51 p.m., surveillance observed UC-3 and UC10 enter Monticello Ave and walk southbound towards W. Augusta Blvd. While 

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walking through Monticello Ave., SAM HOWARD8 and JAMES HUGHES9

approached UC-3 and UC-10 and engaged in a recorded conversation with them. 

During the conversation, UC-10 asked: “You got that D [heroin]?” SAM HOWARD 

replied: “Next block,” while pointing southbound down Monticello Avenue.

b. While continuing to walk southbound, UC-3 and UC-10 observed 

Individual A. Individual A yelled to UC-10: “How many [blows of heroin]?” UC-10 

responded: “Three [blows of heroin]. Five [blows of heroin]. Five [blows of heroin]. I 

got fifty dollars [$50].” 

c. SAM HOWARD then joined Individual A, UC-3, and UC-10 and 

asked: “You ain’t the police, you all?” UC-10 responded: “We come here last week.” 

SAM HOWARD replied: “What kind of blows [heroin] we got?” UC-3 responded: “Tin 

foil.” SAM HOWARD replied: “Yeah you know [what kind of narcotics the Monticello 

DTO distributed]. How many [blows of heroin] you all want?” UC-3 responded: 

“Three [blows of heroin].” SAM HOWARD then stated to UC-10: “Aight, Aight, how 

many you want?” UC-3 responded: “Three [blows of heroin]. Three [blows of heroin].” 

 

8 Law enforcement officials were able to identify SAM HOWARD as follows: on February 22, 

2019, UC-7 purchased 0.946 grams of heroin and fentanyl from an unknown male and 

another individual (later identified as SAM HOWARD). Subsequent to that buy, officers 

approached SAM HOWARD to identify him and completed an ISR. Officers then compiled a 

photo array and UC-7 was able to positively identify SAM HOWARD as the individual who 

sold him narcotics on February 22, 2019.

9 Law enforcement officials identified JAMES HUGHES as follows: on April 2, 2019, UC-7 

purchased 1.144 grams of heroin from an individual (later identified as JAMES HUGHES). 

Following the distribution on April 2, 2019, law enforcement officials approached that 

individual and completed an ISR. During that stop, the individual identified himself as 

JAMES HUGHES. Officers then pulled a photograph of JAMES HUGHES from a law 

enforcement database. UC-7 reviewed the photographs and identified JAMES HUGHES as 

the individual who facilitated the sale of heroin on April 2, 2019.

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d. UC-10 asked: “You got that D [heroin], man?” SAM HOWARD 

stated to Individual A: “No, he [UC-10] want D [heroin], man! Individual A

responded: “I said C [crack cocaine].” UC-3 responded: “No, he [UC-10] said D

[heroin].” UC-10 added: “No. I want D [heroin].” UC-3 responded: “The soft [heroin].” 

SAM HOWARD pointed at UC-3 and asked: “How many [blows of heroin] you want? 

How many, how many?” UC-3 responded: “Three [blows of heroin].” UC-10 

responded: “I got fifty [$50].” HOWARD replied: “How many you want, five [blows of 

heroin]?” UC-10 responded: “Fifty [$50 worth of heroin].” UC-3 responded: “Three 

[blows of heroin]. Three [blows of heroin].” SAM HOWARD replied: “Aight.” 

e. At this point, HUGHES approached UC-3 and UC-10 and stated: 

“I got you.” SAM HOWARD replied: “They [the blows of heroin] all together, right?” 

HUGHES said: “Oops [HUGHES realized that he did not have enough blows of heroin 

readily available to fill the UCs’ order]. I’ll give you what I got.” UC-3 responded: 

“How many you got?” HUGHES replied: “I got three [blows of heroin].” UC-10 

responded: “Oh. Fuck [UC-10 saw that HUGHES did not have three blows of heroin 

readily available].” HUGHES replied: “Thirty bucks [$30]. Thirty bucks [$30], come 

on [hurry up].”

f. UC-10 then gave HUGHES $30 in government funds and 

HUGHES gave UC-10 three tin foil packets containing a white powdery substance. 

UC-3 asked: “You don’t got any more [blows of heroin]?” HUGHES replied: “It’s gonna 

be . . . it’s gonna be like five minutes [until he obtained more heroin to distribute]. 

Not even like five minutes. Two. Three minutes.” UC-3 responded: “Alright.”

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g. At that point, UC-3 and UC-10 began to depart the area with the

plan of returning to purchase additional heroin from SAM HOWARD, HUGHES, and 

Individual A once they had been resupplied. Before the UCs departed, Individual A

whistled at UC-3 and UC-10 to get their attention to come back to him. UC-3 and 

UC-10 walked back to the vacant lot where HUGHES had distributed the tin foil 

packets containing a white powdery substance. HUGHES asked: “How much [heroin 

did the UCs want to purchase]? How many [blows of heroin]?” UC-10 responded: 

“two [blows of heroin], two [blows of heroin], two [blows of heroin].” HUGHES gave 

UC-10 two more tin foil packets containing a white powdery substance and UC-10 

gave HUGHES $20 in government funds. 

h. After the distribution to UC-10, UC-3 told HUGHES: “Three

[blows of heroin].” UC-3 asked: “You do six [blows of heroin] for fifty [$50]?” 

HUGHES replied: “I can’t do it, bro.” UC-3 asked: “Who’s your boss? Maybe you 

could ask.” HUGHES replied: “I, I can’t. I ain’t got no boss.” UC-3 responded: “Aww. 

Fuck.” UC-10 responded: “Maybe tomorrow when we come back.” 

i. According to UC-3 and body camera video, HUGHES then gave

UC-3 three tin foil packets containing a white powdery substance and UC-3 gave 

HUGHES $30 in government funds.

38. Based on my training and experience and knowledge of the

investigation, I believe that in the above exchanges: (a) Individual A asked UC-3 and 

UC-10 how much narcotics they wanted to buy; (b) UC-10 told Individual A that the 

UCs wanted to purchase three and five blows of heroin, respectively; (c) SAM 

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HOWARD asked UC-3 and UC-10 if they were the police and what type of heroin the 

Monticello DTO usually sells on Monticello Avenue in order to determine if the UCs 

could accurately identify the way in which the drugs are packaged and if they were 

customers or police; (d) UC-3 told SAM HOWARD that the Monticello DTO usually 

sold tin foil packaged heroin and SAM HOWARD acknowledged that UC-3 was 

correct; (e) SAM HOWARD then asked UC-3 and UC-10 how much heroin they want 

to purchase and UC-3 said three blows of heroin; (f) UC-10 confirmed they wanted 

heroin and SAM HOWARD confirmed that with Individual A, who indicated that he 

thought the UCs wanted crack-cocaine; (g) SAM HOWARD confirmed that the UCs 

could purchase their blows of heroin together; (h) HUGHES and UC-10 agreed that 

HUGHES would sell $30 worth of heroin; (i) after the initial sale, Individual A

whistled to notify the UCs that he and HUGHES had additional heroin to distribute; 

(j) HUGHES asked about the amount of heroin the UCs wanted to purchase and UC10 told him that he wanted two blows of heroin and HUGHES sold two blows of heroin 

to UC-10 for $20; (k) UC-3 then told HUGHES he wanted three additional blow of 

heroin and asked if HUGHES could sell him six blows of heroin for $50; and (l) 

HUGHES said that he could not sell six blows of heroin for $50, and when UC-3 

suggested HUGHES talk to his boss, HUGHES denied that he had a boss.

39. Following this transaction, UC-3 and UC-10 provided the tin foil packets 

supplied by SAM HOWARD, HUGHES, and Individual A to the DEA North Central 

Laboratory. According to the laboratory, the contents of the tin foil packets weighed 

approximately 2.194 grams and tested positive for the presence of heroin.

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D. TATE Delivers a Resupply of Heroin to the Monticello Avenue Drug Spot, 

a Portion of Which (18.095 Grams) STEVEN DYER Sells to UC-2 on 

April 9, 2019

40. On or about April 9, 2019, at approximately 11:39 a.m., UC-2 placed a 

recorded call to STEVEN DYER, using DYER Phone 1.10 During the conversation, 

UC-2 asked DYER: “Hey, you think you can give me umm . . . $400 [worth of heroin]?” 

DYER replied: “Huh?” UC-2 responded: “Four packs [of heroin, approximately 12 

grams of heroin], 400 [$400].” DYER replied: “Yeah, yeah, yeah, yeah.” UC-2 

responded: “Alright.” DYER said: “As soon as I make it, I’ll give you a call.” UC-2 

responded: “About a half hour you say?” DYER replied: “Yup, like 30 minutes.”

41. At approximately 12:30 p.m., law enforcement officials established 

surveillance in the area of Monticello Avenue in anticipation of UC-2 attempting to 

purchase heroin from DYER. UC-2 was equipped with an audio and video recording 

device prior to the transaction. Surveillance observed the following:

a. At approximately 12:43 p.m., UC-2 entered the Monticello 

Avenue Drug Spot and walked southbound towards W. Augusta Boulevard. UC-2 

arrived at a vacant lot on Monticello Avenue.

 

10 Law enforcement officials identified DYER and that DYER was the user of DYER Phone 1 

as follows: first, on February 19, 2019, an undercover agent (UC-7) purchased four tin foil 

packets of suspected heroin from an individual (DYER), who exited a residence on Monticello 

Avenue (“DYER Residence”). Law enforcement officials searched a Chicago Police Database 

for that address and found that DYER had previously been associated with DYER Residence 

in the database. Officers then pulled a photograph of DYER from the database. In a 

subsequent photo array, UC-7 identified DYER as the individual who sold him the four 

packets of heroin earlier that day. On February 26, 2019, UC-5 purchased four tin foil 

packets of heroin from DYER. During this transaction, UC-5 asked DYER for his phone 

number and DYER provided UC-5 with DYER Phone 1. UC-5 then called DYER Phone 1 to 

confirm that he had the correct phone number. Second, as discussed below, on April 9, 2019, 

DYER used DYER Phone 1 to call TATE, to obtain a resupply of narcotics, in front of UC-2.

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b. At approximately 12:47 p.m., DYER exited DYER Residence,

located at the Monticello Avenue Drug Spot, and walked to the backyard. 

42. According to UC-2 and body camera video, DYER began having a

recorded conversation with UC-2, who was still in the lot of another residence on 

Monticello Avenue next to DYER. DYER handed UC-2 a black plastic bag, which 

contained three clear-knotted bags, which further contained numerous tinfoil packets 

each containing an off-white powdery substance and UC-2 handed DYER $300 in 

government funds. During the recorded conversation between UC-2 and DYER:

a. DYER stated: “It [the heroin] still ain’t come yet.” UC-2 asked:

“What do you got, 3 [three packs of heroin]?” DYER replied: “Three packs [of heroin] 

yeah. Yeah, man, I’m finna see how long he [a coconspirator responsible for delivering 

resupplies of conspiracy narcotics to the drug spot, TATE] finna take to bring this 

other shit [other one pack of heroin]. Damn, I real needed it.” UC-2 asked: “How long 

you think he [TATE] is going to take?” DYER responded: “I don’t know, I’m finna see 

right now.” UC-2 responded: “I could wait in the area.” DYER replied: “yeah, yeah, 

yeah, just don’t leave.” 

43. Based on my training and experience and knowledge of the

investigation, I understand that in the above exchange: (a) DYER told UC-2 that the 

fourth packet of heroin had not arrived yet; (b) DYER told UC-2 that he would contact 

a coconspirator responsible for delivering a resupply of the DTO’s heroin to the drug 

spot (TATE) to see how long it would take for his supplier to bring the fourth packet 

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of heroin; and (c) UC-2 and DYER confirmed that UC-2 would wait in the area until 

DYER received the fourth packet of heroin.

44. According to UC-2 and body camera video from the interaction, at

approximately 12:49 p.m., DYER placed a call in UC-2’s presence. During this 

conversation, DYER stated: “Yup, my guy [UC-2] here, so how long you think you’ll 

need . . . Oh ok, so you right there.”11 

45. Based on a review of DYER Phone 1’s call records, at approximately

12:49 p.m., DYER placed an outgoing call to TATE, using Target Phone 1.12 This 

call lasted approximately 26 seconds. 

46. After the call, DYER then told UC-2: “Just wait right here.” According

to UC-2, DYER walked away from UC-2 through the gangway towards the front of 

DYER Residence. 

47. At this point, agents conducting surveillance observed and CPD pole

camera video reflected TATE walk up to the residence, enter the front yard, and walk 

11DYER’s end of the phone conversation was recorded over UC-2’s audio and recording device.

12 Law enforcement officials identified WILLIE TATE as one of two users of Target Phone 1 

as follows: first, on or about February 22, 2019, SOI-1 provided information about a narcotics 

trafficker whom he identified as “Junebug” (WILLIE TATE). After a February 26, 2019 

purchase of 18.095 grams narcotics from STEVEN DYER, during which purchase DYER 

provided his phone number (DYER Phone 1), agents went back to SOI-1 and asked SOI-1 for 

TATE’s phone number, and SOI-1 provided Target Phone 1. Second, agents obtained records 

from T-Mobile, which reflected that Target Phone 1 was registered to “Willie Tate.” Third, 

as discussed above, during the April 9, 2019 distribution of narcotics from DYER, DYER 

called Target Phone 1 in order to obtain additional narcotics to sell to the undercover agent, 

and surveillance observed and pole camera video reflected TATE arrive in the area around 

the time of the call. After TATE arrived in the area, he met with DYER and DYER 

subsequently provided the undercover agent with additional heroin.

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towards the gangway where DYER was waiting. Both TATE and DYER then walked 

together out of sight of surveillance. Shortly thereafter, law enforcement observed 

TATE walk away from the gangway and leave the area. 

48. According to UC-2, and a review of UC-2’s body cam video, at 

approximately 12:52 p.m., DYER returned to the backyard of his residence and 

handed UC-2 the remaining pack containing an off-white powdery substance and UC2 gave DYER another $100 in government funds. 

49. Based on the timestamp of the recording, reflecting that the call that 

UC-2 overheard was at 12:49 p.m., a review of DYER Phone 1’s call records, which 

reflected a call to Target Phone 1 that same time, corresponding surveillance and pole 

camera video that showed TATE arriving in the area moments later, TATE’s brief 

and secretive interaction with DYER soon after, and DYER’s distributing an 

additional packet of suspected heroin moments after meeting with TATE, I believe 

that the phone call that UC-2 overheard DYER making was a call to TATE, using 

Target Phone 1, in order to confirm that TATE was nearby in order to supply UC-2 

with the fourth packet of suspected heroin.

50. UC-2 provided the four packs supplied by DYER and TATE to the DEA 

North Central Laboratory. According to the laboratory, the packs weighed 

approximately 18.095 grams and tested positive for the presence of heroin.

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E. UCs Purchase 4.072 Grams of Heroin from SAM HOWARD and 

KAMRON GARRAWAY while BARNES Looks Out for Police on April 

19, 2019.

51. On or about April 19, 2019, at approximately 8:50 a.m., law enforcement 

officials established surveillance in the area of the Monticello Avenue Drug Spot in 

anticipation of undercover officers attempting to purchase narcotics from members of 

the Monticello DTO. UC-3 and UC-8 were equipped with audio and video recording 

devices prior to the transaction. 

52. At approximately 8:56 a.m., UC-3 and UC-8 approached SAM HOWARD 

and KAMRON GARRAWAY13 in front of a residence on Monticello Avenue and 

engaged in recorded conversation with both SAM HOWARD and GARRAWAY. 

During the conversation:

a. SAM HOWARD stated: “How many [blows of heroin]?” UC-3 

responded: “Can you, can you give me a special [discounted price for heroin]?” SAM

HOWARD replied: “Huh?” UC-3 responded: “Can you give me a pack [of heroin]?” 

SAM HOWARD, then speaking to GARRAWAY, stated: “You got a pack [of heroin]?” 

GARRAWAY responded: “Yeah. You know what’s up. You already know.” SAM 

HOWARD then stated to UC-3: “I’ll give you eleven [baggies of heroin] for hundred 

[$100] right now.” UC-3 responded: “Man, you can’t do twelve [baggies of heroin]?” 

 

13 Law enforcement officials identified KAMRON GARRAWAY as follows: on April 19, 2019 

UC-3 and UC-8 purchased, in total, 4.072 grams of heroin from an individual (later identified 

as GARRAWAY). Subsequent to that purchase of narcotics, officers approached the 

individual to identify him and completed an ISR. During that stop, the individual identified 

himself as KAMRON GARRAWAY. Law enforcement officials then pulled a photograph of 

KAMRON GARRAWAY from a law enforcement database and compiled a photo array for 

UC-3 and UC-8. Both UCs identified GARRAWAY as the individual who distributed the 

heroin on April 19, 2019.

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UC-8 then stated: “Bro, we do six [baggies of heroin] for fifty [$50].” SAM HOWARD 

replied: “I came out late. You know what I’m saying. I don’t know what’s going on.” 

GARRAWAY stated: “I know you [UC-3] want a deal. I’m working a pack [of heroin]. 

I give you more than that, I’m only. It’s only twelve [baggies of heroin] in there. So, 

if I give you eleven I’m only gonna make ten [$10] though. Honest to God. It’s only 

twelve [baggies of heroin] in there. I make $20. If I give you twelve, I’m not.” UC-8 

responded: “Come on, bro. You hook us up six [six baggies of heroin] for fifty [$50].” 

UC-3 then stated to SAM HOWARD: “You hook me up next time?” SAM HOWARD 

replied: “Yeah, I got you.” UC-3 responded: “Ok. That way I don’t have to come back.”

53. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) HOWARD asked UC-3 

how much heroin he needed to purchase; (b) UC-3 stated he needed a pack of heroin; 

(c) SAM HOWARD then asked GARRAWAY if he had a pack to sell to UC-3; (d) SAM 

HOWARD stated he will give UC-3 eleven baggies of heroin for $100; (e) UC-3 asked 

SAM HOWARD if he could give them twelve baggies of heroin for $100; (f) 

GARRAWAY then explained to UC-3 and UC-8 that there was only twelve baggies in 

a pack and if he gave away his whole pack for $100 he would not make any money.

54. Later in the recorded interaction, SAM HOWARD told BARNES: “Go to 

the corner, bro.” UC-3 responded: “What corner?” SAM HOWARD replied: “No, I’m 

talking to him [BARNES].” At this point, UC-3 observed BARNES walking to the 

northwest corner of Monticello Avenue and Augusta Blvd. 

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55. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange, SAM HOWARD instructed

BARNES to go to the corner of Monticello Avenue to look out for the police because 

SAM HOWARD, GARRAWAY, and the UCs were about to engage in a drug 

transaction.

56. GARRAWAY then stated to UC-3: “You want a pack [of heroin]? A 

Pack?” UC-3 responded: “Yeah, that way . . . .” UC-3 observed GARRAWAY jump 

the fence into the vacant lot of a residence on Monticello Avenue and stated: “Sam, I 

might not have it [a full pack of heroin].” SAM HOWARD then stated to UC-8: “How 

many [blows of heroin] you want?” UC-8 responded: “Six [6 baggies of heroin] for fifty 

[$50]. Come on, bro, like last time.” UC-8 then observed GARRAWAY reach to the 

ground and stated: “I ain’t got it [enough heroin], y’all.” UC-3 responded: “Fuck. 

Cause we don’t want to come back.”

57. According to UC-3, GARRAWAY made eye contact with SAM HOWARD 

and pointed at the corner where BARNES was standing as lookout. SAM HOWARD 

then communicated with BARNES, but UC-3 could not determine what SAM 

HOWARD said. 

58. SAM HOWARD then stated to GARRAWAY: “Alright, man, come on, 

man.” UC-3 then observed GARRAWAY walking towards UC-3, jump the fence back 

to the sidewalk and ask: “Ok, you want the pack [of heroin]?” UC-3 responded: “I do. 

You want two fifties [$50] of the . . . .” GARRAWAY replied: “It don’t matter.” UC-3 

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3 then gave GARRAWAY $100 in government funds. UC-3 then observed 

GARRAWAY count out three tin foil packets and give them to UC-8 at which point 

UC-8 gave GARRAWAY $30 in government funds. 

59. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) GARRAWAY told SAM 

HOWARD that he did not have enough heroin to supply both UC-3 and UC-8; (b) 

SAM HOWARD communicated with BARNES to make sure there was not police in 

the area so they can safely conduct the heroin transaction; and (c) GARRAWAY

served UC-3 with eleven tin foil packets of heroin and UC-8 with three tin foil packets 

of heroin.

60. UC-3 and UC-11 provided the eleven tin foils supplied by SAM 

HOWARD and GARRAWAY to the DEA North Central Laboratory. According to the 

laboratory, the substances in the packets weighed approximately 4.072 grams and 

tested positive for the presence of heroin. 

F. UC-2 Purchases 21.013 Grams of Heroin, Fentanyl, and Acetyl Fentanyl

From DYER on May 3, 2019.

61. On or about May 3, 2019, at approximately 8:30 a.m., law enforcement 

officials established surveillance in the area of Monticello Avenue in anticipation of 

UC-2 attempting to purchase narcotics DYER. UC-2 was equipped with an audio and 

video recording device prior to the transaction

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62. Around that time, UC-2 placed a call to DYER, using DYER Phone 1.14

According to UC-2, during the call, UC-2 stated to DYER that he wanted to purchase 

$500 worth of heroin from DYER. DYER agreed to sell the heroin to UC-2 and 

instructed UC-2 to come to his residence (DYER Residence) located on Monticello 

Avenue to conduct the transaction.

63. At approximately 8:48 a.m., surveillance observed and CPD Pod camera

video reflected UC-2 enter Monticello Avenue and walk southbound towards DYER

Residence. Surveillance observed UC-2 enter the alley behind DYER Residence and 

stop in the vacant lot on Monticello Avenue where UC-2 observed DYER standing by 

an opening of the back fence. 

64. According to UC-2, surveillance, and body camera video, as DYER

approached UC-2, DYER handed UC-2 a clear plastic bag containing five packs of 

Ziploc baggies, each containing an off-white powdery substance and UC-2 gave DYER 

$500 in government funds. UC-2 then engaged in a recorded conversation with 

DYER. During the conversation: 

a. UC-2 asked: “Hey, you changed the packaging [of the narcotics]?”

DYER replied: “Yeah, they [Monticello DTO members] took ‘em out the foil and put 

‘em in some bags.” UC-2 responded: “Yeah, cause last time you gave me black [type 

of packaging for heroin]. The black ones and I hope they’re [the new narcotics] the 

14 This call was not recorded due to technical issues with a law enforcement call recording 

system.

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same shit [same heroin as last time].” DYER replied: “yeah, the same shit [same 

heroin as last time].” 

b. UC-2 asked: “So you took them [heroin] out of foil and put ‘em 

[heroin] in these bags?” DYER replied: “Yeah, but I think they’re [Monticello DTO] 

going back to the foil. You know the guy [Monticello DTO member bagging the 

narcotics] that be doing that shit, you know what I’m saying. I guess sometimes he 

[Monticello DTO member bagging the narcotics] feeling like doing foil and sometimes 

takes it easy way out and puts ‘em [in] bags.” UC-2 responded: “You like to change it 

up?” DYER replied: “I just get like they [Monticello DTO] get it to me. As long as 

they flood [provide lots of narcotics to distribute], you know what I’m saying.” UC-2 

replied: “Alright, b, take care now.”

65. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) UC-2 asked DYER if the 

Monticello DTO changed the packaging from tin foil to Ziploc baggies; (b) DYER 

informed UC-2 that other members of the Monticello DTO, including a Monticello 

DTO member bagging the narcotics, changed the heroin packaging, but it is the same 

quality heroin as UC-2 had previously purchased; and (c) DYER stated that he did 

not care how the heroin was packaged as long as it was provided to him in sufficient 

quality to distribute on Monticello Avenue.

66. UC-2 provided the packets supplied by DYER to the DEA North Central 

Laboratory. According to the laboratory, the packets weighed approximately 21.013 

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grams and tested positive for the presence of heroin, fentanyl, and acetyl fentanyl (a 

fentanyl analogue). 

G. UCs Purchase 7.302 Grams of Heroin from ANTHONY DAVIS and 

FLOYD STEWART on May 3, 2019.

67. On or about May 3, 2019, at approximately 9:10 a.m., law enforcement 

officials established surveillance in the area of Monticello Avenue in anticipation of

UC-3 and UC-10 attempting to purchase narcotics from members of the Monticello 

DTO. UC-3 and UC-10 were equipped with audio and video recording devices prior 

to the transaction.

68. At approximately 9:20 a.m., surveillance observed and CPD Pod camera 

video reflected UC-3 enter Monticello Avenue and walk southbound towards W. 

Augusta Boulevard. Surveillance observed UC-3 and UC-10 engage in a recorded

conversation with ANTHONY DAVIS.15 During the encounter:

a. DAVIS asked: “How many [blows of heroin] you want?” UC-10 

responded: “Let me get five [blows of heroin].” 

b. UC-3 and UC-10 then followed DAVIS into the vacant lot at a 

residence on Monticello Avenue. Once in the vacant lot, UC-10 gave DAVIS $20 in 

 

15 Law enforcement officials identified ANTHONY DAVIS as follows: on May 3, 2019, UC-10 

purchased 2.286 grams of heroin from an individual (later identified as ANTHONY DAVIS). 

Following the distribution on May 3, 2019, law enforcement officials approached that 

individual and completed an ISR. During that stop, the individual identified himself as 

ANTHONY DAVIS. Officers then pulled a photograph of ANTHONY DAVIS from a law 

enforcement database. UC-10 reviewed the photograph and identified ANTHONY DAVIS as 

the individual who facilitated the sale of heroin on May 3, 2019.

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government funds and DAVIS gave UC-10 two blue Ziploc bags containing a white 

powdery substance. 

c. After the distribution to UC-10, UC-3 asked: “Hey, can I get that 

pack [of heroin]?” DAVIS replied: “Stay in the lot.” UC-3 responded: “Bro. Can I get 

that pack [of heroin] from last time? I want that deal like last time. I want that deal 

though.” DAVIS replied: “Could you stay in the lot?”

d. At this point, UC-3 and UC-10 waited in the vacant lot for 

approximately one to two minutes when Floyd STEWART16 approached counting 

numerous pink tint bags of suspected heroin. During the ensuing recorded encounter, 

UC-3 asked: “They [Monticello DTO heroin packaging] pink now?” STEWART 

replied: “How many [blows of heroin] you want?” UC-10 responded: “Let me get three 

more [blows of heroin].”

e. According to UC-10, STEWART pulled out three pink Ziploc 

baggies containing a white powdery substance and gave the three baggies to UC-10. 

UC-10 then gave STEWART $30 in government funds. 

f. During the ensuing recorded encounter, UC-3 stated: “I want a 

pack [12 bags of heroin, approximately 3-4 grams] like last time.” STEWART replied: 

“Come on.” UC-3 then observed STEWART reach into his pants pocket and pull out 

 

16 Law enforcement officials identified FLOYD STEWART as follows: on May 3, 2019, UC-3 

purchased 5.017 grams of heroin from an individual (later identified as FLOYD STEWART). 

Following the distribution on May 3, 2019, law enforcement officials approached the 

individual and completed an ISR. During that stop, the individual identified himself as 

FLOYD STEWART. Officers then pulled a photograph of FLOYD STEWART from a law 

enforcement database. UC-10 reviewed the photograph and identified FLOYD STEWART 

as the individual who facilitated the sale of heroin on May 3, 2019.

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numerous additional pink tint bags containing a white powdery substance. UC-3 

stated: “You got it. You gonna give me twelve [blows of heroin]?” According to UC-3, 

STEWART then gave UC-3 the pink tinted bags containing a white powdery 

substance while counting additional baggies. 

g. UC-3 then asked: “How much is that?” STEWART replied: “Three 

[blows of heroin].” UC-3 responded: “Three [blows of heroin].” STEWART replied: 

“Four. Five. Six. Eight. Nine. Ten. Is that a hundred [$100]?” According to UC-3, 

at this time, STEWART was counting out additional blows containing a white 

powdery substance, which STEWART provided to UC-3.

h. UC-3 responded: “No, you gave me twelve [blows of heroin] last 

time?” STEWART replied: “Was that a hundred [$100]? I’m gonna give you eleven 

[eleven blows of heroin].” UC-3 responded: “What?” STEWART replied: “I ain’t 

paying off that, bro?” UC-3 responded: “Hold on.” UC-3 then handed STEWART $100 

in government funds. STEWART then stated to UC-3: “How many [blows of heroin] 

you want?” UC-3 responded: “What?” STEWART replied: “How many more [blows 

of heroin] you want. Want anymore?” UC-3 responded: “No. I thought you were 

gonna give me twelve [blows of heroin].” STEWART replied: “I don’t get paid off that 

[turn a profit], bro.” UC-3 responded: “Ok. Alright, alright. That’s cool.”

69. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) UC-3 asked STEWART 

how many blows of heroin he had provided to UC-3 and STEWART said three; (b) 

STEWART then counted out additional blows of heroin (up to ten) that he provided 

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UC-3; (c) UC-3 asked for twelve blows of heroin for $100, which is the deal he said 

STEWART had previously given him; and (d) STEWART agreed to provide eleven 

blows of heroin rather than twelve, informing UC-3 that if he provided twelve blows

of heroin, he would not make a profit off the transaction.

70. According to body camera video, after the distribution, UC-3 yelled to 

STEWART as STEWART was walking away: “Hey, are these [the blows of heroin]

good [high quality] though? Cause now they’re different [in different colored bags].” 

STEWART replied: “They’re [the narcotics in the pink bag] the same as the blue 

bags.” UC-3 responded: “Oh, ok.” UC-3 and UC-10 then departed the area. While 

walking away, UC-3 approached DAVIS and asked: “Same shit [the narcotics in the 

different-colored bags] though, right?” DAVIS replied: “Yeah, it’s the same shit [the 

heroin in the blue and pink bags was the same and all came from the same supply].”

71. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) UC-3 asked STEWART if 

the heroin in the pink baggies was the same quality of the heroin in the blue baggies 

that he had previously purchased from STEWART and STEWART said that they 

were the same; and (b) UC-3 asked DAVIS if the heroin in the pink baggies and blue 

baggies was the same and DAVIS said that it was.

72. UC-3 and UC-10 provided the baggies containing a white powdery 

substance distributed by DAVIS and STEWART to the DEA North Central 

Laboratory. According to the laboratory: 

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a. the baggies containing a white powdery substance DAVIS and 

STEWART distributed to UC-10 weighed approximately .751 grams and tested 

positive for the presence of heroin, fentanyl, and acetyl fentanyl;

b. the baggies containing a white powdery substance STEWART 

distributed to UC-10 weighed approximately 1.535 grams and tested positive for the 

presence of heroin and fentanyl; and

c. the baggies containing a white powdery substance STEWART 

distributed to UC-3 weighed approximately 5.017 grams and tested positive for the 

presence of heroin and fentanyl.

H. UC-2 Purchases 33.345 Grams of Heroin and Furanyl Fentanyl from 

DYER on May 30, 2019.

73. On or about May 30, 2019, at approximately 3:30 p.m., UC-2 placed a 

recorded call to DYER, using DYER Phone 1. During the call, DYER stated: “What 

up, bro.” UC-2 responded: “Hey, B, what’s up, man?” DYER replied: “Yup, I’m good.” 

UC-2 responded: “I was out of town, my father, is real sick and stuff so I had to go 

down to umm, Indiana. Hey, bro, I just got back, man, my boss said everybody is 

hitting me up and telling me to go buy [U/I].” DYER replied: “Hell yeah.” UC-2 

responded: “Ok, about how long will it take you?” DYER replied: “Shit, how long you 

finna be?” UC-2 responded: “Umm, I can be there in about a half an hour.” DYER 

replied: “Ok cool.” UC-2 responded: “You coming, right? [U/I].” DYER replied: “Yeah, 

I got you.” UC-2 responded: “Alright, man, I need to get high, it was dry over there 

where I was at.” DYER replied: “Alright yeah.” UC-2 responded: “I think everyone 

else does to so we’re waiting on it. Alright, bro. I’ll see you in a half hour.”

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74. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) UC-2 told DYER that he 

had been out of town, but that he was told to purchase heroin; and (b) DYER and UC2 agreed to meet in order for DYER to distribute heroin to UC-2.

75. At approximately 4:10 p.m., surveillance observed and CPD Pod camera 

video reflected UC-2 arrive at the Monticello Avenue Drug Spot and walk towards 

DYER Residence. UC-2 was equipped with an audio and video recording device. At 

approximately 4:11 p.m., UC-2 placed a call to DYER who was using DYER Phone 

1.17 During the call, UC-2 stated: “Hey, B, I’m walking up to your house. Alright, I 

got to go all the way around. Alright I’ll be there in a second.” According to UC-2, 

during this call, DYER instructed UC-2 to go around to the alley and meet with DYER 

in the back yard of his residence.

76. Surveillance and CPD Pod camera video reflected UC-2 pass DYER 

Residence and walk towards the alleyway behind the residence and approach the rear 

fence. According to UC-2 and body camera video:

a. When UC-2 arrived at the back fence of DYER Residence, DYER 

was waiting in the back yard. DYER approached UC-2 and handed UC-2 a plastic 

bag containing six bundles each containing numerous clear Ziploc bags each 

containing a tan powdery substance. UC-2 then gave DYER $600 in government 

funds. UC-2 and DYER then engaged in a recorded conversation. During the 

conversation: 

 

17 UC-2’s portion of the call was recorded over UC-2’s body camera.

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b. UC-2 stated: “Yeah, I know, you got six [$600 worth of heroin]?” 

DYER replied: “Yeah, oh shit, got a little hole in it, [U/I].” UC-2 responded: “Alright 

man, how you been?” DYER replied: “Glad you’re back, man. Shit, I’ve been good, 

man, I’m glad my guy back, our real guy.” UC-2 responded: “So, is this the same guy 

[quality heroin] as the tin foil.” DYER replied: “Yeah, [U/I].” UC-2 responded: “But 

this is the same guy [quality heroin] as the tin foil?” DYER replied: “Yeah, same shit 

[quality heroin], [U/I] yeah, man, we [the Monticello DTO] buying right.” UC-2 

responded: “Alright, alright.” DYER replied: “Glad you’re back.” UC-2 responded: 

“Yeah, me too, take care now.” 

77. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) UC-2 confirmed that

DYER sold UC-2 $600 worth of heroin; and (b) UC-2 asked if the heroin DYER had 

distributed to UC-2 was the same heroin as the heroin that was packaged in tin foil,

and DYER confirmed that it was the same heroin.

78. UC-2 provided the bundles and Ziploc bags distributed by DYER to the 

DEA North Central Laboratory. According to the laboratory, the jabs weighed 

approximately 33.345 grams and tested positive for the presence of heroin and 

furanyl fentanyl.

I. UCs Purchases 5.29 Grams of Heroin from FRANKLIN, JEREMY 

HAMPTON, and JOHNNIE DANIELS on June 13, 2019.

79. On or about June 13, 2019, at approximately 2:17 p.m., surveillance 

observed and CPD Pod camera video reflected UC-3 and UC-10 walking southbound 

to the Monticello Avenue Drug Spot. UC-3 and UC-10 were equipped with audio and 

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video recording devices. As they were walking, FRANKLIN18 approached and had a 

recorded conversation with the UCs. During the conversation: 

a. FRANKLIN asked: “How many [blows of heroin] do you want?” 

UC-10 responded: “Let me get five [blows of heroin].”

b. According to UC-10, FRANKLIN walked across the street and 

jumped the fence into the yard of a residence on Monticello Avenue. At that time, 

UC-3 and UC-10 had a recorded conversation with JEREMY HAMPTON19 and 

JOHNNIE DANIELS.20 HAMPTON stated: “If you got money [to buy narcotics] go 

 

18 Law enforcement officials identified FRANKLIN as follows: on or about May 17, 2019, an 

undercover officer purchased a small quantity of heroin from an individual (FRANKLIN) on 

Monticello Avenue. Law enforcement officials were familiar with FRANKLIN based on 

multiple prior conversations agents and officers had with FRANKLIN. During the first 

conversation agents and officers had with FRANKLIN, FRANKLIN identified himself as 

KELVIN FRANKLIN. Following these interactions, agents and officers reviewed an arrest 

photo of “Kelvin Franklin” maintained by the Chicago Police Department and, based on that 

review, determined that (a) the individual who sold heroin to the undercover officer on May 

17, 2019 and (b) the individual with whom they directly spoke, matched FRANKLIN’s 

appearance and was FRANKLIN. In addition, during the course of the investigation, law 

enforcement officials took photographs of the individual selling heroin to UC-1, UC-3, UC-8 

and UC-10 on May 17, May 22, May 31, June 13, June 14, and June 18, 2019. Law 

enforcement officials compared the surveillance photographs and video recordings to the 

photographs from a CPD CLEAR database and determined that the individual who had sold 

heroin to the UCs on each of those occasions was FRANKLIN.

19 Law enforcement officials identified JEREMY HAMPTON as follows: on or about June 13, 

2019, UC-10 purchased approximately 2.776 grams of heroin and fentanyl from an individual 

(HAMPTON) on Monticello Avenue. After the sale, law enforcement officers stopped the 

individual who sold narcotics to UC-10 and the individual identified himself as JEREMY 

HAMPTON. Law enforcement officers then pulled a photograph of HAMPTON from a 

Chicago Police Department database. Later that day, UC-10 reviewed the photograph of 

HAMPTON and identified HAMPTON as the individual who had sold him heroin. 

20 Law enforcement officials identified JOHNNIE DANIELS as follows: on or about May 10, 

2019, UC-10 purchased approximately 1.266 grams of heroin from an individual (DANIELS) 

on Monticello Avenue. After the purchase, law enforcement officers stopped the individual 

who sold narcotics to UC-10 and the individual identified himself as JOHNNIE DANIELS. 

Law enforcement officers then pulled a photograph of DANIELS from a Chicago Police 

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into the lot. Whoever don’t got the money, keep walking.” UC-3 responded: “Ok.” 

DANIELS asked: “You keep walking then?” UC-3 responded: “No. I want to get some 

shit [narcotics] too.” DANIELS asked: “How many [blows of heroin] you want?” UC3 responded: “The six [blows of narcotics] for 50 [$50].” 

c. DANIELS then asked HAMPTON: “You do the six [blows of 

narcotics] for fifty [$50]?” UC-3 responded, “Yeah. I always get the six [blows of 

narcotics] for fifty [$50]. Tell him or SAM [HOWARD]. You know what I’m saying.” 

DANIELS replied: “I understand that. It’s not our call. It’s whoever got it [the 

narcotics].” 

d. UC-3 asked: “Oh. Who’s working it [the narcotics]? Ok. Ok. Ok. 

SAM [HOWARD] ain’t around?” DANIEL replied: “Naw.” UC-3 responded: “Fuck. 

You want me to wait in here [a vacant lot on Monticello Avenue]?” DANIELS replied: 

“Yeah. Go in there.” 

80. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) HAMPTON told the UCs 

to keep walking and leave the area if they did not have money to buy narcotics; (b) 

UC-3 told HAMPTON and DANIELS that they (the UCs) wanted to purchase 

narcotics; (c) DANIELS asked UC-3 how many blows the UCs wanted and UC-3 said 

six blows of heroin for $50; (d) DANIELS asked HAMPTON if he sold six blows of 

narcotics for $50; (e) UC-3 said that he always gets six blows of heroin for $50 and 

 

Department database. Later that day, UC-10 reviewed the photograph of DANIELS and 

identified DANEILS as the individual who had sold him heroin. 

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told DANIELS and HAMPTON to ask SAM HOWARD; (f) DANIELS said that he 

understood UC-3 got six blows of heroin for $50, but that he did not get to decide on 

prices and quantities and that decision was made by whomever controlled the 

narcotics at a given time; and (g) DANIELS said that SAM HOWARD was not in the 

area and told the UCs to wait in a nearby vacant lot in order to purchase heroin.

81. According to the UCs and body camera video:

a. Moments later, FRANKLIN walked towards the front of the 

vacant lot and had the following recorded exchange with UC-10. FRANKLIN asked 

UC-10: “What’s up? Who wants to buy [narcotics]?” UC-10 responded: “I do.” 

FRANKLIN replied: “Aight. Let me give you five [blows of narcotics].” FRANKLIN 

then gave UC-10 five clear plastic bags containing a white powdery substance and 

UC-10 gave FRANKLIN $50 in government funds. 

b. FRANKLIN then said: “He [referring to HAMPTON] gonna bring 

you six [blows of heroin] for fifty [$50].” UC-3 responded: “Ok.” Moments later, 

FRANKLIN yelled to UC-3: “Hey, pop.” UC-3 responded: “Yeah?” FRANKLIN said: 

“He [HAMPTON] said he can’t do that shit, six [blows] for fifty [$50] man.” UC-3 

asked: “Why not? You can’t ask SAM [HOWARD]? SAM knows me. He [SAM 

HOWARD] always gives me that deal.” FRANKLIN replied: “He [HAMPTON] said 

he can’t do it.” UC-3 responded: “You know I get a pack [eleven blows of heroin]?” 

FRANKLIN replied: “He [HAMPTON] said he can’t do it, bro.” UC-3 responded: 

“Fuck.” UC-10 stated: “Just give whatever [quantity of heroin], man.” UC-3 

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responded: “All right. That’s fine. I come back tomorrow. Give me the five [blows of 

heroin].” 

c. HAMPTON then gave UC-3 five clear plastic bags containing a 

white powdery substance and UC-3 gave HAMPTON $50 in government funds. UC3 stated to HAMPTON: “It’s [the money] real, man.” HAMPTON replied: “Counting 

the money.” FRANKLIN told the UCs: “My name Niko.”

82. Based on my training and experience and knowledge of the 

investigation, I believe that in the above exchange: (a) FRANKLIN asked the UCs if 

they wanted to buy heroin; (b) UC-10 said that he did and FRANKLIN gave him five 

blows of heroin for $50; (c) FRANKLIN told UC-3 that HAMPTON was going to bring 

him six blows of heroin for $50, but then said that HAMPTON could not sell UC-3 six 

blows for $50; (c) UC-3 said that SAM HOWARD gave him six blows for $50 and asked 

for eleven blows; (d) FRANKLIN said that HAMPTON could not sell that quantity; 

and (e) UC-3 agreed to buy five blows for $50 and come back the next day to purchase 

additional heroin.

83. UC-3 and UC-10 provided the bags supplied by FRANKLIN, HAMPTON 

and DANIELS to the DEA North Central Laboratory. According to the laboratory, 

the bags weighed approximately 5.29 grams and tested positive for the presence of 

heroin and fentanyl.

J. UC-2 Purchases 31.249 Grams of Heroin from DYER on June 14, 2019.

84. On or about June 14, 2019, at approximately 7:14 a.m., UC-2 placed a 

recorded call to DYER, using DYER Phone 1. During the call, UC-2 asked: “I wake 

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you up?” DYER replied: “No, I’m already up, I’m back here hitting one of my peoples

[supplying a customer with narcotics].” UC-2 responded: “Here’s the deal, man, I got 

$480, think I can get five [five packs of heroin] for that?” DYER replied: “Just come 

out already, I’mma work it out for you.” UC-2 responded: “Alright, alright, alright, 

I’m going to be there [DYER Residence] in about 15 minutes.”

85. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange, UC-2 asked DYER if he could 

purchase five packs of heroin for $480 and DYER told UC-2 to meet him at DYER 

Residence.

86. A short time after approximately 7:20 a.m., surveillance observed and 

CPD Pod camera video reflected UC-2 arrive on Monticello Avenue and enter the east 

alley behind DYER Residence. UC-2 was equipped with an audio and video recording 

device prior to the transaction. According to UC-2 and body camera video:

a. At approximately 7:41 a.m., UC-2 arrived at the back fence of 

DYER Residence, at which time DYER exited his residence and approached UC-2. 

DYER handed UC-2 five packs or “jabs” containing 54 clear Ziploc baggies, each 

containing a white powdery substance, and UC-2 gave DYER $480 in government 

funds. 

b. UC-2 stated: “You got $480 [worth of heroin], man?” DYER 

replied: “So look them four [packs of heroin] eleven [blows of heroin] right there and 

this a ten [blows of heroin]. Four eleven and a ten.” UC-2 responded: “Alright, I got 

it. Ah, man, I think I got more customers, man, so.” DYER replied: “[U/I] Yeah, hit 

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me up, bro, I’ll keep trying to make sure I hit my guy [TATE, who transports 

resupplies of DTO narcotics to the drug spot] to bring some extra. See what I’m 

saying, if I would’ve needed some extra ones [blows or packs of heroin].” UC-2 

responded: “Ok did you, alright.” DYER replied: “I, you got to do is hit me, bro. You 

know what I’m saying.” 

c. UC-2 asked: “Is this your only spot, man, cause sometimes I’m

like further like west.” DYER replied: “Sometimes when you need like that, I’ll try 

and meet you, bro. I got a car.” UC-2 responded: “Alright.” DYER responded: “I’ll 

try and meet you half way.” UC-2 responded: “Alright, you drive, bro. Alright cool.” 

DYER replied: “Yup.”

87. Based on my training and experience and knowledge of the

investigation, I understand that in the above exchange: (a) UC-2 asked DYER if 

DYER had $480 worth of heroin to sell UC-2; (b) DYER stated that he had four packs 

with eleven blows of heroin and one pack with ten blows of heroin; (c) UC-2 told DYER 

he has more customers and will want additional heroin; (d) DYER told UC-2 that he 

would call the individual who transports DTO narcotics to the drug spot (TATE) to 

provide additional heroin; and (e) DYER and UC-2 discussed meeting at different 

locations for DYER to supply UC-2 with heroin.

88. UC-2 provided the five packs or jabs containing 54 clear Ziploc baggies

distributed by DYER to the DEA North Central Laboratory. According to the 

laboratory, the bundles weighed approximately 31.249 grams and tested positive for 

the presence of heroin and fentanyl.

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K. UCs Purchase 25.575 Grams of Heroin and Fentanyl from SAM

HOWARD and FRANKLIN on June 18, 2019.

89. On or about June 18, 2019, at approximately 4:05 p.m., UC-3 placed a

recorded call to FRANKLIN, using Target Phone 2.21 During the call, FRANKLIN 

stated: “Who’s this? Oh, what’s up Vinny [fictitious name previously given by UC3]?” UC-3 responded: “What’s up, man? Hey, you on the block [Monticello Avenue]?” 

FRANKLIN later asked: “Yeah. What you need?” UC-3 responded: “Aight. I’ll be 

over there . . . give me about 15-20 minutes. Aight?” FRANKLIN replied: “Aight.”

90. Based on my training and experience and knowledge of the

investigation, I understand that in the above exchange, FRANKLIN asked UC-3 what 

kind and quantity of narcotics he wanted to purchase and UC-3 agreed to meet with 

FRANKLIN on Monticello Avenue to purchase narcotics.

91. At approximately 4:06 p.m., UC-10 placed a recorded call to FRANKLIN,

using Target Phone 2. During the call, UC-10 said: “Hey, Niko. It’s Sasha [fictitious 

21 Law enforcement officials identified FRANKLIN as the user of Target Phone 2 as follows: 

during the undercover purchase of suspected narcotics on June 13, 2019, discussed above, 

FRANKLIN gave UC-3 his phone number (Target Phone 2). UC-3 and UC-10 later called 

Target Phone 2 and, based on their in-person interactions with FRANKLIN, determined that 

FRANKLIN was the user of Target Phone 2. In addition, during intercepted calls over Target 

Phone 1, SAM HOWARD referred to the user of Target Phone 2 as “Kevo.” Based on 

encounters with FRANKLIN and other members of the Monticello DTO, agents understand 

that FRANKLIN, whose first name is “Kelvin,” goes by the nickname “Kevo.”

On or about August 12, 2019, the Honorable Rebecca Pallmeyer, Chief Judge for the Northern 

District of Illinois, entered an order authorizing the initial interception of wire 

communications to and from Target Phone 2. Interception began on August 14, 2019 and 

terminated on September 12, 2019. On or about September 18, 2019, the Honorable Gary 

Feinerman, Acting Chief Judge for the Northern District of Illinois, entered an order 

authorizing the renewed interception of wire communications and the initial interception of 

electronic communications to and from Target Phone 2. Interception began on September 

19, 2019 and terminated on October 18, 2019.

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name for UC-10]. I’m with Vinny [UC-3].” FRANKLIN replied: “Yeah.” UC-10 said: 

“I’m gonna, gonna . . . you got, you gotta more than a hundred [$100 worth of 

narcotics]. Can you give me a deal?” FRANKLIN replied: “Alright, come on. We 

[members of the Monticello DTO] over here.”

92. Based on my training and experience and knowledge of the

investigation, I understand that in the above exchange, UC-10 asked FRANKLIN for 

a deal on $100 worth of narcotics and FRANKLIN told UC-10 to come to the 

Monticello Avenue Drug Spot where he and other members of the Monticello DTO 

were selling narcotics.

93. Shortly after approximately 4:32 p.m., surveillance observed and CPD

Pod camera video reflected UC-3 and UC-10 enter the Monticello Avenue Drug Spot 

and meet with FRANKLIN and SAM HOWARD. UC-3 and UC-10 were equipped 

with audio and video recording devices prior to the transaction. During their recorded 

encounter:

a. SAM HOWARD asked: “How much [heroin] you need?” UC-3

responded: “How you doing? I was asking for you last time.” SAM HOWARD replied: 

“Tell me how much [heroin] you want.” UC-3 said: “He’s [UC-10] trying to get a 

hundred [$100 worth of heroin]. I was trying to see if I could get some [heroin]. Is 

there any way I can get your number so I can call you?” SAM HOWARD replied: 

“How much [heroin] you need? I make sure [to get you] how much [heroin] you need.” 

UC-3 responded: “No, because I don’t want to deal . . . Every time I come here and 

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you’re not here.” SAM HOWARD replied: “Alright. We [the Monticello DTO] gotcha. 

Go right over there [SAM HOWARD pointed to a vacant lot].”

b. FRANKLIN was in the vacant lot holding numerous bags of

suspected narcotics. FRANKLIN then gave UC-10 eleven baggies containing a white 

powdery substance and UC-10 gave FRANKLIN $100 in government funds. 

c. UC-3 asked UC-10: “How much you get [how much narcotics did

you purchase]?” UC-10 responded: “Hundred [$100 worth of heroin].” UC-3 then 

asked FRANKLIN: “Did you [FRANKLIN] throw him a deal [eleven blows for $100]?” 

FRANKLIN replied: “Yeah. I got him eleven [eleven baggies for $100]. You want the 

same thing?” UC-3 responded: “I usually got two [$200 worth of heroin]. Cause that’s 

what I told Sam [SAM HOWARD].” FRANKLIN replied: “You want two [$200 worth 

of heroin]?” UC-3 responded: “Yeah. You got two [$200 worth of heroin]?” 

FRANKLIN replied: “Aight, I give you two to two [twenty-two blows of heroin for 

$200]. You want two hundred [$200 worth of heroin].” 

d. UC-3 responded, “Can you throw another one [another blows of

heroin]?” FRANKLIN replied: “I just did.” FRANKLIN said: “He [SAM HOWARD] 

usually make me give out ten [ten baggies of heroin for $100].” UC-3 responded: “I 

know. That’s why I want a deal [an additional blows of heroin].” FRANKLIN said: “I 

giving out twenty two [22 blows for $200].” 

94. Based on my training and experience and knowledge of the

investigation, I understand that in the above exchange: (a) UC-3 asked FRANKLIN 

if he had given UC-10 eleven blows of heroin for $100 and FRANKLIN confirmed that 

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he had and asked UC-3 if he wanted the same deal; (b) UC-3 said that he usually 

purchased $200 worth of heroin from SAM HOWARD and FRANKLIN offered to sell 

UC-3 $200 worth of heroin; (c) UC-3 asked FRANKLIN for an extra blows of heroin 

for each pack and FRANKLIN said he would give UC-3 twenty-two blows for $200; 

and (d) FRANKLIN said that SAM HOWARD usually directed FRANKLIN to only 

give our ten blows of heroin for $100.

95. According to UC-3 and the body camera video, UC-3 then gave 

FRANKLIN $200 in government funds. UC-3 and FRANKLIN had the following 

recorded exchange: 

a. UC-3 stated: “You give me twenty two on that [22 blows of heroin], 

right?” FRANKLIN replied: “Yeah. Hey, next time, bro, you call my phone [Target 

Phone 2]!” FRANKLIN said: “Look. You don’t have to talk to Sam [SAM HOWARD] 

no more.” UC-3 responded: “Right.” FRANKLIN said: “That’s why I gave you my 

number [Target Phone 2].” 

b. UC-3 stated: “But I thought Sam [SAM HOWARD] was your 

Boss!” FRANKLIN replied: “I ain’t got no boss.” UC-3 said: “Because every time he 

[SAM HOWARD] [tells] you guys what to do. Alright?” FRANKLIN replied: “He 

[Sam] could of told me to give you twelve [12 blows for $100]. That’s what I gonna do 

right now.” UC-3 responded: “Alright . . . Alright. I’ll call you next time.”

c. FRANKLIN bent down and went through a black plastic bag and 

counted numerous clear Ziploc bags containing a white powdery substance. 

FRANKLIN then put the remaining bags in the black plastic bag and concealed the 

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bag in the front right tire of a vehicle parked on the street. FRANKLIN then 

approached UC-3 and counted out 22 bags and gave them to UC-3.

96. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) UC-3 confirmed with 

FRANKLIN that he was getting twenty-two blows of heroin for the $200 he had 

provided and FRANKLIN agreed; (b) FRANKLIN encouraged UC-3 to call him 

directly, using Target Phone 2, to facilitate future narcotics transactions; (c) UC-3 

said that he had not done so previously because he understood that he needed to go 

through SAM HOWARD first, whom he understood to be FRANKLIN’s boss; and (d) 

FRANKLIN denied that SAM HOWARD was his boss, but said that he would have 

given UC-3 the deal that SAM HOWARD offered FRANKLIN and would do so here.

97. UC-3 and UC-10 provided the bags distributed by FRANKLIN and SAM 

HOWARD to the DEA North Central Laboratory. According to the laboratory, the 

bags provided by the UCs weighed approximately 25.575 grams and tested positive 

for the presence of heroin and fentanyl.

L. UC-2 Purchases 31.926 Grams of Heroin and Fentanyl from DYER on 

June 28, 2019.

98. On or about June 28, 2019, at approximately 8:34 a.m., UC-2 placed a 

recorded call to DYER, using DYER Phone 1. During the call, UC-2 asked: “Hey man, 

you up on the block [Monticello Avenue Drug Spot]?” DYER replied: “Yeah, yeah, 

yeah I’m at the crib [DYER Residence, located in the area of the Monticello Avenue

Drug Spot].” UC-2 responded: “Think you can hook me up with 500 [$500 worth of 

heroin]?” DYER replied: “Huh?” UC-2 responded: “500 blow [heroin].” DYER replied: 

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“Yeah, yeah, yeah.” UC-2 responded: “Alright, man, I didn’t think it would be a 

problem, cause, it’s just 5 [$500 worth of heroin]. I’ll be there in about five to seven

minutes man.” DYER replied: “Alright, I’m waiting on you.” 

99. At approximately 8:43 a.m., surveillance and CPD Pod camera video 

observed UC-2 arrive on the Monticello Avenue Drug Spot and walk towards DYER 

Residence. UC-2 passed DYER Residence and walked towards the alleyway behind 

DYER Residence and UC-2 approached the rear fence of DYER Residence. UC-2 was 

equipped with an audio and video recording device. According to UC-2 and body 

camera video: 

a. As UC-2 approached the rear fence, DYER was already waiting 

in the back yard. DYER handed UC-2 a black plastic bag containing five packs with 

numerous tin foil packets inside. UC-2 then gave DYER $500 in government funds. 

b. DYER stated: “They [the heroin] back in the foils [tin foil 

packaging] too.” UC-2 responded: “They back in the foils [tin foil packaging]?” DYER 

replied: “Yup, aluminum foil.” UC-2 responded: “Yeah I don’t know about the foil, 

but the foil for some reason is better, man?” DYER replied: “Yeah, my guy [Moticello 

DTO associate who packages and resupplies block with DTO heroin] one minute have 

foil, the other have bags, [U/I].” UC-2 responded: “As long as it’s [the heroin] the 

same thing. Yeah, that’s what I’m saying.” DYER replied: “As long as he [DYER’s 

heroin supplier from the Monticello DTO] keeping it coming too.” UC-2 responded: 

“Right, right, yeah, man.” 

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c. DYER stated: “When you get the bags, mother fuckers like [U/I]. 

As long as he don’t switch it up, see what he did last time, the guy, our real guy 

[Monticello DTO’s source of narcotics supply] got busted, so they [SAM HOWARD

and FRANKLIN, who have connection with DTO’s source of supply] went and fucked 

with another dude [a different heroin supplier]. You know when I had the blue bags. 

That was not our [the Monticello DTO’s] shit, that was the shit they went to get from 

another motherfucker [a different heroin supplier], see our guy [narcotics supplier] 

got bumped [arrested], but our guy been back.” UC-2 responded: “He [narcotics 

supplier] got bumped, man?” DYER replied: “Yeah, our guy [narcotics supplier] got 

bumped, but he cool, so the feds grabbed his ass.” UC-2 responded: “Oh really? Is 

he, is he out already?” DYER replied: “Yeah he out, he cool.” UC-2 responded: “So 

then he was [U/I] to bring you?” DYER replied: “So we [Monticello DTO] always 

gonna have foils or bags.” UC-2 responded: “Ok.” DYER replied: “[U/I].” UC-2 

responded: “Alright, B.” DYER replied: “Hit me up, bro, [U/I].” 

100. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) DYER told UC-2 that the 

heroin he had distributed to UC-2 was back in the tin foil packaging; (b) DYER said 

that his heroin supplier occasionally had tin foil and occasionally had bags containing 

the heroin; (c) UC-2 said that he had no preference as long as it was of the same 

quality and DYER agreed that he had no preference as long as the heroin kept coming 

from his supplier; (d) DYER referenced a prior heroin supplier who had been arrested 

and the Monticello DTO using a different heroin supplier while their prior heroin 

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supplier was in federal custody; and (e) DYER told UC-2 that the Monticello DTO 

would always have heroin available to purchase.

101. UC-2 provided the five packs each with the tin foil packets containing a 

white powdery substance supplied by DYER to the DEA North Central Laboratory. 

According to the laboratory, the contents of the tin foil packets weighed 

approximately 31.926 grams and tested positive for the presence of heroin and 

fentanyl.

M. UCs Purchases 40.338 Grams of Heroin from FRANKLIN on July 18, 

2019.

102. On or about July 18, 2019, at approximately 2:00 p.m., UC-3 placed a 

recorded call to FRANKLIN. During the phone call:

a. FRANKLIN stated: “What’s up, Vinny [name provided by UC-3]?” 

UC-3 responded: “What’s up, Niko [FRANKLIN]. Hey, you gonna be, uh. You 

around?” FRANKLIN replied: “I’m always around.” UC-3 responded: “Aight. You, 

you on the block [Monticello Avenue Drug Spot]? You want me to meet you there or 

what?” FRANKLIN replied: “I’m on the block [Monticello Avenue] already, man. Just 

meet me on the block [Monticello Avenue].” 

b. UC-3 responded: “Ok. Hey. Alright, cool. Hey, I’m gonna bring 

Sasha [UC-10] with me. Cool.” FRANKLIN replied: “Yeah. What you all need [how 

much narcotics]?” UC-3 responded: “Uh. Same shit, man. Fucking soft [heroin].” 

FRANKLIN replied: “Ok. Twenty three [23 blows] and eleven [eleven blows].” UC-3 

responded: “Aight, cool.” FRANKLIN responded: “Bet.”

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103. At approximately 2:35 p.m., surveillance observed and CPD Pod camera 

video reflected UC-3 and UC-10 arrive at the Monticello Avenue Drug Spot. Body 

camera video from UC-3 and UC-10 reflected FRANKLIN standing in the front yard 

of a residence on Monticello Avenue. UC-3 and UC-10 were equipped with audio and 

video recording devices prior to the transaction. During the ensuing recorded 

interaction, and according to UC-3 and UC-10:

a. FRANKLIN stated: “Hey, Vinny [UC-3].” UC-3 and UC-10 

walked towards FRANKLIN and FRANKLIN motioned for UC-3 and UC-10 to go to 

the back alley of the residence. 

b. Once in the back alley, FRANKLIN closed the back door of the 

residence and walked down from the porch towards UC-3 and UC-10. FRANKLIN 

counted numerous clear Ziploc bags and stated: “Eleven [11 blows of heroin].” UC-3 

said to UC-10: “That’s [the 11 blows] for you.” FRANKLIN then gave UC-10 eleven 

clear zip lock baggies containing a white powdery substance and UC-10 gave 

FRANKLIN $100 in government funds. 

c. UC-3 then gave FRANKLIN $200 in government funds. UC-10 

then asked UC-3: “Ok. You getting more or no?” UC-3 responded: “Yeah . . . [U/I] . . 

. what’s that?” FRANKLIN then gave UC-3 eleven clear plastic bags containing a 

white powdery substance. FRANKLIN stated: “Eleven [blows of heroin].” UC-3 

responded: “Eleven [blows of heroin].” 

d. FRANKLIN then gave UC-3 another twelve clear Ziploc baggies 

containing a white powdery substance. UC-3 asked: “How much is that?” 

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FRANKLIN replied: “Twenty three [blows of heroin] altogether.” UC-3 responded: 

“Ok. Can you give me more [heroin]? Another hundred [$100 worth]?” FRANKLIN 

replied: “Yeah.” UC-3 replied: “Hundred dollars’ worth.” FRANKLIN replied: 

“Hundred dollars’ worth?” UC-3 responded: “Yeah. I got to get it for my guy.” 

e. UC-3 gave FRANKLIN an addition $100 in government funds 

and FRANKLIN gave UC-3 eleven more clear plastic Ziploc baggies containing a 

white powdery substance. UC-3 responded: “How much is that?” FRANKLIN 

replied: “Eleven bags [of heroin].” UC-3 replied: “Give me one extra one [baggie of 

heroin].” FRANKLIN replied: “I told you eleven [baggies of heroin].” UC-3 

responded: “Come on. Throw me one bone, [one additional baggie of heroin] man. I 

want to make some off that one. Come on.” FRANKLIN replied: “Here, Vinny [UC3].” FRANKLIN then gave UC-3 one more clear plastic Ziploc baggie (bringing the 

total to twelve) containing a white powdery substance. 

104. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) UC-3 gave FRANKLIN 

$200 in government funds; (b) FRANKLIN gave UC-3 twenty-three bags containing 

a white powdery substance; (c) UC-3 asked FRANKLIN for another $100 worth of 

heroin; (d) FRANKLIN agreed and gave UC-3 eleven more baggies of heroin for $100; 

(e) UC-3 asked FRANKLIN for an additional free baggie of heroin so he could make 

a small profit when re-selling the drugs; and (f) FRANKLIN gave UC-3 one additional 

baggie of heroin.

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105. In total, FRANKLIN gave UC-3 and UC-10 thirty-five baggies 

containing a white powdery substance. UC-3 and UC-10 provided the thirty-five 

baggies supplied by FRANKLIN to the DEA North Central Laboratory. According to 

the laboratory, the substance inside the packets provided by UC-3 and UC-10 

weighed approximately 40.338 grams and tested positive for the presence of heroin.

N. UCs Purchase 6.294 Grams of Heroin from SAM HOWARD, ROBERT 

STUCKEY and SAVAN WARD on October 1, 2019.

106. On or about October 1, 2019, at approximately 7:40 a.m., surveillance 

observed and CPD Pod camera video reflected UC-3 and UC-11 meeting with SAVAN 

WARD22 and SAM HOWARD at the Monticello Avenue Drug Spot. UC-3 and UC-11 

were equipped with audio and video recording devices. During the recorded 

conversation: 

a. UC-3 stated: “Hey what’s up, you guys got it [narcotics]? You guys 

up?” WARD replied: “Yeah.” UC-3 responded: “Can I get like last time?” WARD

replied: “What you trying to do?” UC-3 responded: “Huh. This mother . . . .” SAM 

HOWARD replied: “It’s all good. What [quantity of narcotics] you need?” UC-3 

responded: “I know. I’m just saying, I’m talking. He’s [WARD] talking to me. I don’t 

know.” WARD replied: “What [quantity of narcotics] you need?” 

 

22 Law enforcement officials identified SAVAN WARD and ROBERT STUCKEY as follows: 

on October 1, 2019, UC-3 and UC-11 purchased 6.294 grams of heroin from SAM HOWARD 

and two other individuals (WARD and STUCKEY). Following the distribution on October 1, 

2019, law enforcement officials searched a CPD database and obtained booking photographs 

of SAVAN WARD and ROBERT STUCKEY and conducted photo arrays. UC-3 reviewed the 

photographs and identified SAVAN WARD and ROBERT STUCKEY as the individuals with 

SAM HOWARD who sold him and UC-11 the heroin.

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b. UC-3 responded: “How you been? This my girl [referencing UC11].” SAM HOWARD replied: “Hey.” WARD replied: “Hello.” UC-3 responded: “Can 

you do the deal [discounted price for heroin]?” SAM HOWARD replied: “Tell me. I . 

. . .” UC-3 responded: “A pack [of heroin].” SAM HOWARD replied: “Alright. Hold 

on. Stay right there.” UC-3 stated: “You [UC-11] want some too?” UC-11 stated: 

“Yeah.” UC-3 stated to SAM HOWARD: “Hey, hey.” SAM HOWARD replied: “Huh?” 

UC-3 responded: “Her too, she getting some for her sister. How many [blows of 

heroin] you [UC-11] want?” UC-11 responded: “Can you give me six [6 blows of 

heroin] for fifty [$50].” UC-3 responded: “Can you give . . . yeah can you?” SAM 

HOWARD replied: “Yeah. Go to the back [of the residence].” UC-3 responded: “Ok.”

107. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) UC-3 asked if WARD, 

have any heroin for sale; (b) WARD asked UC-3 what quantity of narcotics he wanted 

to purchase; (c) UC-3 asked for a deal and then asked SAM HOWARD for a pack of 

heroin; (d) SAM HOWARD directed UC-3 to wait for the heroin in a vacant lot of 

Monticello Avenue; (e) UC-3 then told SAM HOWARD that UC-11 wanted to 

purchase heroin and UC-11 asked for six baggies of heroin for $50; and (f) SAM

HOWARD told the UCs to go to the back of the residence on Monticello Avenue. 

108. At this point, UC-3 and surveillance observed, and CPD Pod camera 

video reflected, SAM HOWARD walk to a different residence on Monticello Avenue 

and engage in conversation with STUCKEY who was at the front door of the 

residence. Shortly thereafter, while the UCs were in the vacant lot on Monticello 

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Avenue, UC-3 observed SAM HOWARD and STUCKEY walk towards the UCs. 

During this portion of the recorded conversation:

a. UC-3 stated: “How much [narcotics] you gonna give me though?” 

SAM HOWARD replied: “You all got to come back cause it’s [the narcotics] the last 

one [pack of heroin]. You all come back I gotcha you all. Cause you really . . . this 

[the last pack of heroin] is for somebody. Somebody want the whole ten [ten baggies 

of heroin]. The whole.” 

b. UC-3 responded: “Ok. Can you at least give me some [blows of 

heroin]?” SAM HOWARD replied: “Yeah. You all got to split them [the blows of 

heroin] though. I’m gonna give her . . . .” UC-11 responded: “Oh. That’s fine. I’ll 

split with you some.”

109. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) SAM HOWARD told the 

UCs that they have to come back later because the Monticello DTO street-level 

traffickers only had one pack of heroin left and the pack was earmarked for another 

customer; (b) UC-3 asked if SAM HOWARD could give the UCs some blows of heroin; 

and (c) SAM HOWARD told UC-3 that he is going to give UC-11 some heroin and UC11 will have to share it with UC-3. 

110. UC-3 then observed SAM HOWARD counting out seven clear zip lock 

baggies each containing a white powdery substance. During this portion of the 

recorded conversation:

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a. SAM HOWARD stated: “Four. Five. Six. Seven. I’m, I’m gonna 

do you a deal [provide additional blows of heroin] later. I can’t. This [pack of heroin] 

for some. This already counted.” SAM HOWARD then gave UC-3 seven clear plastic 

bags containing a white powdery substance.

b. SAM HOWARD stated: “That’s seven [blows of heroin]. It’s seven

[blows of heroin].” UC-3 responded: “Yeah, you got your own [customer]. Another 

customer.” SAM HOWARD replied: “Yeah. Yeah. So.” UC-3 responded: “I got you.” 

HOWARD replied: “But, but I’m gonna give it [heroin] to you all bunch of. I’m gonna 

come wait. That’s the other thing [another supply of heroin] we [the Monticello DTO]

got left. How many [blows of heroin] you want?” 

c. UC-3 stated: “Oh. You got them different [a new supply of heroin 

in different packaging] now?” SAM HOWARD replied: “Yeah, man.” UC-3 

responded: “Are these . . . good [high quality]?” SAM HOWARD replied: “It’s the 

bomb. It’s a . . . listen.” UC-3 responded: “It’s better [quality] than the tin foils

[normal heroin]?” SAM HOWARD replied: “Yeah. I swear to God.” UC-3 responded: 

“Ok.” 

d. UC-11 stated: “You take six [blows of heroin] for fifty [$50].” UC3 responded: “Cause last time.” SAM HOWARD replied: “Can’t. That’s all we got left 

right now. I trying to split for both . . . You know what I’m saying.” UC-3 responded: 

“How much [quantity of heroin] you gonna give us for?” HOWARD replied: “It’s only. 

This ain’t nothing.” UC-3 responded: “No. How much is it? Twelve [blows of heroin].” 

SAM HOWARD replied: “It’s fourteen [blows of heroin].” UC-3 responded: “How 

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much you gonna give it for?” SAM HOWARD replied: “Give me . . . uh.” UC-3 

responded: “Hundred [$100].” 

e. STUCKEY replied: “Fourteen [blows of heroin].” SAM HOWARD 

replied: “Give me. Give me one-twenty [$120].” UC-3 responded: “Oh, man.” SAM 

HOWARD replied: “I can’t. This.” UC-3 responded: “Niko [FRANKLIN] gives it [that 

deal] to me.” SAM HOWARD replied: “I, I know. Listen this the last pack [of heroin].” 

UC-3 responded: “Ok.” SAM HOWARD replied: “I’m split for both you all. I’m give 

you seven [7 blows of heroin] and give her seven [7 blows of heroin].” 

111. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) SAM HOWARD gave UC3 and UC-11 seven blows of heroin each, which would normally cost approximately 

$120; (b) SAM HOWARD confirmed that he was providing the last of the heroin 

available for sale on the block at the time, which he said was of the same quality as 

the normal tin-foil heroin distributed by the Monticello DTO; (c) the UCs asked for a 

deal on the price of the heroin and STUCKEY confirmed that it was fourteen blows, 

which SAM HOWARD said would cost $120; and (d) UC-3 said that he got a lower 

price from FRANKLIN and SAM HOWARD said that he knew, but that this was the 

last pack of heroin that the Monticello DTO had on hand to distribute and that he 

could not give the UCs a deal.

112. According to UC-3, SAM HOWARD gave UC-11 six clear Ziploc baggies

containing a white powdery substance and UC-11 then gave HOWARD $50 for the 

narcotics. During this portion of the recorded conversation:

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a. UC-3 stated: “You got . . . then throw one [blow of heroin] in. 

Throw it in.” SAM HOWARD replied: “Huh . . . [U/I].” UC-3 responded: “Come on. 

You know we always come back. How much?” SAM HOWARD replied: “Give me 

sixty bucks [$60].” UC-3 then gave HOWARD $60 in government funds. 

b. UC-3 then asked: “You can’t throw it [a blow of heroin] in?” 

STUCKEY asked: “You gonna buy it [the additional blow of heroin]?” UC-3 

responded: “Give it for five [$50]. Five [$50]. Come on!” SAM HOWARD replied: “I 

got you.” UC-3 responded: “Ok. I’ll take it. I’ll take it. Cause then I don’t want to 

come back.” 

c. STUCKEY gave UC-3 one clear Ziploc baggie containing a white 

powdery substance and UC-3 gave STUCKEY an additional $10 for the narcotics. 

d. UC-3 asked: “Niko [FRANKLIN] ain’t around?” SAM HOWARD 

replied: “He [FRANKLIN] be like around hour. Everything cool [U/I].” UC-3 

responded: “No, no, I know. I know, I got you.” SAM HOWARD responded: “What 

you need? I know I got you. But when I say I got you. I got you.” UC-3 went on to 

ask: “You got C [crack cocaine]?” SAM HOWARD replied: “Yeah we [the Monticello 

DTO] got C [crack cocaine].” UC-3 responded: “Ok. Alright, how much we can get on 

that?” SAM HOWARD replied: “That’s . . . come on, come back. I don’t got this. My 

peoples [the Monticello DTO] got this.” UC-3 responded: “They [crack cocaine] dimes 

[$10] or nickels [$5].” 

113. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) UC-3 asked HOWARD 

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whether or not FRANKLIN was on Monticello Avenue selling narcotics and SAM 

HOWARD said that FRANKLIN would be around in an hour or so; (b) SAM 

HOWARD asked what narcotics UC-3 needed and UC-3 asked SAM HOWARD if the

Monticello DTO had any crack cocaine for sale and how much crack cocaine he could 

purchase; and (d) SAM HOWARD stated that other member of the Monticello DTO 

had crack cocaine for sale and that they charge $5 or $10 per bag of crack cocaine. 

114. The UCs provided the 14 total baggies supplied by SAM HOWARD, 

WARD, and STUCKEY to the DEA North Central Laboratory. According to the 

laboratory, the substances weighed approximately 6.294 grams and tested positive 

for the presence of heroin. 

IV. LEE, BONDS, SAM HOWARD, AND FRANKLIN MANAGE THE 

NARCOTICS SUPPLY AT THE MONTICELLO AVENUE DRUG SPOT

115. As agents continued to conduct controlled purchases of narcotics from 

Monticello DTO members at the Monticello Avenue Drug Spot, agents began to 

intercept SAM HOWARD and FRANKLIN, and later LEE and BONDS, coordinating 

and managing the supply of narcotics distributed at the drug spot.

A. SAM HOWARD and FRANKLIN Arrange to Resupply the Monticello 

Avenue Drug Spot Following DYER’s Sale of Narcotics to UC-2 on 

August 16, 2019. 

116. As discussed below, on or about August 16, 2019, DYER sold UC-2 a 

quantity of fentanyl analogue-laced heroin and advised UC-2 that all the individuals 

selling narcotics at the Monticello Avenue Drug Spot work together. Following the 

sale, SAM HOWARD instructed UC-2 to begin buying narcotics from him directly, 

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then arranged with FRANKLIN to resupply the Monticello Avenue Drug Spot with 

more narcotics.

1. DYER Sells UC-2 6.34 Grams of Heroin Laced With Fentanyl and 

Furanyl Fentanyl on August 16, 2019.

117. On or about August 16, 2019, at approximately 8:19 a.m., UC-2 placed 

a recorded call to DYER, using DYER Phone 1. During the call, DYER asked: What’s 

the word?” UC-2 responded: “Think I can get $300 worth [of narcotics], bro?” DYER 

replied: “Umm, let me umm, right now I just got two [$200 worth of narcotics] . . . .” 

UC-2 responded: “I’ll take the two [$200 worth of narcotics].” DYER replied: “Ok, cool 

I got two [$200 worth of narcotics] for you.” UC-2 responded: “Alright.” UC-2 

responded further: “Alright, bro. I’ll be there in about 15-20 minutes.”

118. At approximately 8:35 a.m., surveillance observed and CPD Pod camera 

video reflected UC-2 arrive at the Monticello Avenue Drug Spot and walk towards 

DYER Residence. As UC-2 approached DYER Residence, UC-2 placed another call 

to DYER, using DYER Phone 1. During the recorded call, UC-2 stated: “Hey, B, as a 

matter of fact I’m walking right in front of your house.” DYER replied: “Ok, cool, I’m 

on my way down. Meet you in the back.” UC-2 responded: “Alright.”

119. Surveillance then observed and CPD Pod camera video reflected UC-2 

walk to the alleyway behind DYER Residence. Once there, UC-2 observed DYER 

walking towards the back fence from DYER Residence. UC-2 was equipped with an 

audio and video recording device. During this recorded meeting:

a. As DYER approached UC-2, DYER handed UC-2 two plastic bags 

containing several blue zip lock bags and packages wrapped in tin foil, which bags 

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and tin foil packages contained a white powdery substance and UC-2 gave DYER 

$200 in government funds. 

b. DYER was engaged in a phone conversation. During the call, 

DYER said to the individual on the other end of the call: “Yeah, ok, as soon as you 

make it, hit me up right, right ok, cool. Alright, I already know how n----s be trying 

to hold packs [of narcotics] for themselves, yeah, whatever you can give me.” 

c. DYER stated to UC-2: “I’m glad to see you back.” UC-2 

responded: “You getting some more packs [of narcotics]?” DYER replied: “Yeah, I’m 

gonna get some more [packs of narcotics], yeah, look them from last night, I sold, 

them was my bros, I sold them, yeah, my guy [co-conspirator who transports DTO 

heroin to the block] on his way with the other shit [additional narcotics].” UC-2 

responded: “Ok.” DYER replied: “He [co-conspirator who transports DTO heroin to 

the block] talking about, I’m not gonna be able to hit you with seven packs [of 

narcotics]. I might have to hit you with four [packs of narcotics], I’ll take whatever, 

I ain’t tripping, just bring that shit [the four packs of narcotics].” UC-2 responded: 

“Yeah, yeah, yeah.” DYER replied: “Yeah, I’m glad you’re back.” 

120. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) UC-2 asked DYER if he 

was going to have additional narcotics for distribution; (b) DYER had a phone call, 

during which he complained about people not providing him with additional narcotics 

to distribute; (c) DYER told UC-2 that he sold narcotics that he had on him yesterday 

and was going to be re-supplied; and (d) DYER said that his associate who transports

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narcotics to the DTO members at the drug spot indicated that he might only be able 

to provide DYER with four packs of narcotics and DYER said that he would take the 

four packs of narcotics.

121. Later in the recorded conversation:

a. UC-2 said: “Yeah, man, so you get like seven packs [of heroin] per 

day. Oh, is that what you get?” DYER replied: “But I really like say . . . Start me off 

in the morning. I normally get 7 [packs of heroin] in the morning, I’ve been already 

run through them [the seven packs of heroin] by the afternoon and then get my next 

shit [a new supply of heroin] for the night time so I usually run through it [the heroin] 

like that so now that I know you are back I’m gonna be holding that shit [the heroin] 

to the side.” 

b. UC-2 responded: “Yea, cause the other guys [UC-2’s purported 

narcotics customers] are calling too that they want more. I just hurried up and got a 

few [blows of heroin].” DYER replied: “As soon as I do, I’m gonna call you, as soon as 

I get that shit [a new supply of heroin].” 

c. UC-2 asked: “How about your boys out here in the street? You’re 

not with them? Or?” DYER replied: “Yeah, I’d be fucking with them too, though . . . 

You know what I’m saying, just say we are all together [Monticello DTO], but I just 

be fucking with the back. They [other Monticello DTO members] be catching 

deliveries out there in the front.”

122. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) DYER stated that he 

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typically receives seven packs of heroin each morning from the DTO associate who 

provides narcotics for the drug spot; (b) DYER stated that he usually sells those seven 

packs of heroin by the afternoon and then will get additional heroin to distribute at 

night; (c) DYER told UC-2 that once he gets more heroin, he will contact UC-2 and 

set it aside for UC-2; and (d) UC-2 asked DYER if he is associated with the other 

street-level traffickers at the Monticello Avenue Drug Spot and DYER said that they 

are all together, but that other members of the Monticello DTO deal with customers 

on the street and DYER deals to the customers coming through the alleyway.

123. UC-2 provided the baggies and tin foils supplied by DYER to the DEA 

North Central Laboratory. According to the laboratory, the contents of the baggies 

and tin foils weighed approximately 6.34 grams and tested positive for the presence 

of heroin, furanyl fentanyl, and fentanyl.

2. SAM HOWARD Encourages UC-2 to Begin Obtaining Narcotics 

from Him Directly

124. On August 16, 2019, soon after UC-2 met with DYER and as he was 

walking away from DYER Residence, UC-2 encountered SAM HOWARD. During the 

recorded conversation: 

a. UC-2 asked: “What’s up, man?” SAM HOWARD replied: “Hey, 

you still be fucking with buddy in the house [DYER]?” UC-2 responded: “Yeah, with 

B.” SAM HOWARD asked: “What he sell you?” UC-2 responded: “two . . . two packs

[of heroin].” SAM HOWARD replied: “They [narcotics] good [high quality], they 

good?” UC-2 responded: “Yeah, they [narcotics] be good.” SAM HOWARD asked: 

“Aluminum foil [heroin wrapped in aluminum foil]? Aluminum foil?” UC-2 

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responded: “What you mean? Say that again?” SAM HOWARD replied: “Aluminum 

foil [heroin wrapped in aluminum foil]? Aluminum foil baggies?” UC-2 responded: 

“No, no, no, they’re tin foils.” SAM HOWARD replied: “Ok, ok, ok alright.” 

b. UC-2 stated: “Yeah, he [DYER] been taking care of me for months 

now.” SAM HOWARD replied: “Ok, that’s cool.” UC-2 responded: “Alright, man, now 

if you give me a deal, I’ll buy from you.” SAM HOWARD replied: “I got you next time, 

next time I got you.” UC-2 responded: “Alright, I got your number, man?” SAM 

HOWARD replied: “I don’t got my phone, I got you next time.” UC-2 responded: 

“Alright, man, cause usually I buy like five to seven packs.” SAM HOWARD replied: 

“Ok, ok.”

125. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) SAM HOWARD asked 

UC-2 if he was purchasing heroin from DYER; (b) UC-2 confirmed that he had 

purchased heroin from DYER and SAM HOWARD asked if the heroin was high 

quality; (c) UC-2 confirmed that it was high quality heroin and SAM HOWARD and 

UC-2 confirmed that the heroin was wrapped in tin foil; (d) UC-2 said that DYER had 

been supplying heroin to UC-2 for months and offered to buy heroin from SAM 

HOWARD if SAM HOWARD gave him a deal (free blows of heroin with each pack); 

and (e) SAM HOWARD refused to give UC-2 his phone number, but said that he 

would serve UC-2 the next time UC-2 went to Monticello Avenue to buy heroin.

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3. SAM HOWARD and FRANKLIN Arrange to Resupply the 

Monticello Avenue Drug Spot between August 16 and 20, 2019

126. On or about August 16, 2019, at approximately 2:33 p.m. (TP2 Session 

479), FRANKLIN, using Target Phone 2, received a call from SAM HOWARD, using 

Target Phone 3.23 During the call:

a. FRANKLIN stated: “[U/I] on the block [Monticello Avenue Drug 

Spot]. What’s the word, Sut.” SAM HOWARD responded: “You got up with my dude 

[co-conspirator who transports DTO heroin to the block]?” FRANKLIN replied: “I got 

up with him [co-conspirator who transports DTO heroin to the block] already. You 

[U/I] the 6 car [6 packets of narcotics] though right?” SAM HOWARD responded: 

“[U/I] what you [U/I]?” FRANKLIN replied: “Green, I got him. But you want me to 

get uh, 1 [packet of narcotics] left. You want me to give it to one of the motherfuckers 

that’s out here [narcotics distributors on Monticello Avenue]?” SAM HOWARD 

asked: “Finished with it [is FRANKLIN out of narcotics]?” FRANKLIN replied: “Am 

I finished, finished [out of narcotics]? Nah. Almost though.” 

 

23 Law enforcement officials identified SAM HOWARD as the user of Target Phone 3 based 

on the following: On or about May 24, 2019, at approximately 8:11 p.m. (TP1 Session 123), 

an individual other than TATE used Target Phone 1 on a call with Individual A. During the 

call, Individual A said: “This Nub?” The user of Target Phone 1 responded: “No, this Sam.” 

Individual A responded: “What the fuck you on Nub phone for, Sam?” SAM HOWARD 

replied: “This ain’t no Nub phone, baby, this June Bug [TATE’s] phone.” Law enforcement 

officials otherwise familiar with SAM HOWARD’s voice from interactions with SAM 

HOWARD at the Monticello Avenue Drug Spot listened to the above recording and identified 

SAM HOWARD as the user of Target Phone 1. Monitors later listened to intercepted calls 

involving the user of Target Phone 3 and identified that voice as the same individual who 

was using Target Phone 1 (SAM HOWARD).

On or about September 18, 2019, the Honorable Gary Feinerman, Acting Chief Judge for the 

Northern District of Illinois, entered an order authorizing the interception of wire 

communications to and from Target Phone 3. Interception began on September 19, 2019 and, 

for Target Phone 3, terminated on September 27, 2019.

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b. Later in the conversation, FRANKLIN said: “He [another 

narcotics trafficker] gave me 3 [units of narcotics] I can bring you a 4 car [units of 

narcotics] right now. That’s what I’m trying to tell you.” SAM HOWARD responded: 

“I’m trying to tell you do it low key. Nobody see what you doing. That’s all I’m trying 

to say. You ain’t see Rob [Monticello DTO co-conspirator], nobody . . .” FRANKLIN 

later stated: “Police hot as hell [active and present in the area of the Monticello 

Avenue Drug Spot] anyway. Transformers [unmarked police cars] parked on 

Thomas. Blue and white [marked police car] just came up the one way and they was 

parked on Augusta when I pulled up.” 

c. SAM HOWARD responded: “A’ight fuck it. You say you got a 4 

car [units of narcotics] right now?” FRANKLIN replied: “Yeah.” SAM HOWARD 

responded: “How long [U/I]?” FRANKLIN replied: “[U/I] I’m waiting on a phone call. 

If you want to do something, I can put 2 packs [units of narcotics] out here and I could 

work them bitches.” SAM HOWARD responded: “No, you ain’t got to do all that. [U/I] 

park it and bring the 4 [units of narcotics] and we finna slide. I’m finna call him. 

Know what I’m saying . . . .” 

127. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) SAM HOWARD and 

FRANKLIN discussed the supply of narcotics available at the Monticello Avenue 

Drug Spot; (b) SAM HOWARD asked FRANKLIN if he had supplied a member of the 

Monticello DTO to give him more narcotics; (c) FRANKLIN and SAM HOWARD 

discussed the presence of police in the area of the Monticello Avenue Drug Spot; and 

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(d) FRANKLIN told SAM HOWARD that the street-level Monticello DTO traffickers 

needed two packs of narcotics from SAM HOWARD to sell at the Monticello Avenue

Drug Spot. 

128. On or about August 20, 2019, at approximately 6:12 p.m. (TP2 Session 

1330), FRANKLIN, using Target Phone 2, called SAM HOWARD, using Target Phone 

3. During the call, SAM HOWARD stated: “Where you at?” FRANKLIN replied: “I’m 

at the gas station, what up?” SAM HOWARD responded: “You send Will [WILL 

HOWARD] out?” FRANKLIN replied: “Will [WILL HOWARD] ain’t [I/A] the phone, 

man.” SAM HOWARD responded: “Not Will [WILL HOWARD]. You know I’m 

talking about the other n----.” FRANKLIN replied: “Yeah.” SAM HOWARD 

responded: “What, you gave him a 3 plate [units of narcotics], 3 piece slice or 2?” 

FRANKLIN replied: “You talking about Blood [Monticello DTO member]? 2 [units of 

narcotics?” SAM HOWARD responded: “A’ight, okay.”

129. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange SAM HOWARD asked 

FRANKLIN how much narcotics FRANKLIN gave a Monticello DTO member known 

as “Blood” and FRANKLIN said that he gave “Blood” two units of narcotics.

B. FRANKLIN Provides DYER a Quantity of Heroin Laced with a Fentanyl 

Analogue, a Portion of Which (Approximately 22.7 Grams) DYER Sells 

to UC-2 on September 3, 2019.

130. On or about August 29, 2019, at approximately 11:26 a.m., UC-2 placed 

a recorded call to DYER, who was using DYER Phone 1. During the call, UC-2 asked: 

“You think you can get me 6, 600 [$600] of blow [heroin] today?” DYER replied: “You 

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said later?” UC-2 responded, “Ugh, you tell me, I got all day, brother.” DYER replied: 

“Umm yeah I should be able to get that [$600 worth of heroin] to you by later, right 

now I have a good 300 [$300 worth of heroin].” UC-2 asked: “How long will it take you 

to get the six [$600 worth of heroin]?” DYER replied” “I’m finna hit my guy 

[FRANKLIN] right now. I get it [heroin] from real quick and I hit you right back.” 

131. On or about August 29, 2019, at approximately 11:57 a.m. (TP2 Session 

2978), FRANKLIN, using Target Phone 2, received a call from DYER, using DYER 

Phone 1. This call lasted 31 seconds and, due to suspected technical issues, no audio 

was captured. Based on the above call with UC-2 indicating that he was going to call 

his associate who controls the DTO’s heroin supply, and the call summarized below, 

where DYER indicates to UC-2 that he spoke to his associate, I believe that during 

this call DYER ordered $300 worth of heroin from FRANKLIN.

132. On or about August 29, 2019, at approximately 12:00 p.m., UC-2 

received a call from DYER, who was using DYER Phone 1. During the call, DYER 

said: “Yeah, so look, my guy [FRANKLIN] said it will probably be an hour, hour and 

a half before he can get me something else [the other $300 worth of heroin].” UC-2 

responded: “Alright, alright, what time is it now, it’s about 12, ok so around 1:30 

then?” DYER replied: “Yup, once he do [FRANKLIN re-supplies DYER], I’ll just hit 

you back.” UC-2 responded: “Alright, yeah, so it might be sooner.”

133. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) DYER told UC-2 that he 

had spoken to his heroin supplier/another Monticello DTO member (FRANKLIN), 

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and that FRANKLIN told him that he would be able to supply DYER with heroin in 

approximately an hour or so; and (b) DYER told UC-2 that he would call UC-2 when 

he obtained the heroin from FRANKLIN.

134. On or about August 29, 2019, at approximately 12:09 p.m. (TP2 Session 

2981), FRANKLIN, using Target Phone 2, called DYER, using DYER Phone 1. 

During the call:

a. DYER stated: “I was hitting you up to see if you had a couple of 

extra ones for my guy [UC-2].” FRANKLIN replied: “What? Some loose ones [baggies 

of heroin]?” DYER responded: “Uh-uh, hell no.” FRANKLIN replied: “What they 

want?” DYER responded: “Packs [full packs of heroin].” FRANKLIN replied: “How 

many [packs of heroin]?” DYER responded, “He need 3 [packs of heroin].” 

b. FRANKLIN stated: “Let me see what they [other members of the 

Monticello DTO] got. I can see what I can scrape up. You can tell him come through 

here [Monticello Avenue Drug Spot].” DYER responded: “Alright cool and then yeah, 

just let me know and then I’ll let him know. A’ight.”

135. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) DYER asked FRANKLIN 

if FRANKLIN could supply DYER with $300 worth of heroin so that DYER can supply 

UC-2 and FRANKLIN asked if DYER wanted loose baggies of heroin; (b) DYER told 

FRANKLIN that his customer (UC-2) did not want baggies, but packs of heroin; and 

(c) FRANKLIN told DYER to tell DYER’s customer (UC-2) to go to the Monticello 

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Avenue Drug Spot so that FRANKLIN could arrange for the appropriate quantity of 

heroin to be distributed.

136. Over the next two hours, UC-2 and DYER exchanged several missed 

calls. At that point, law enforcement put off the controlled purchase of narcotics until 

September 3, 2019.

137. On or about September 3, 2019, at approximately 1:19 p.m., UC-2 placed 

a recorded call to DYER, using DYER Phone 1. During the call, UC-2 asked: “Yeah, 

hey, man, umm, how many bags [of narcotics] you got right now?” DYER replied: 

“Well look, lemme hit you right back, ‘cause I don’t know how many [bags of narcotics] 

I got. Let me hit you right back, so I can umm . . . .” UC-2 responded: “Alright, let 

me know.”

138. On or about September 3, 2019, at approximately 1:22 p.m. (TP2 Session 

4437), FRANKLIN, using Target Phone 2, received a call from DYER, using DYER 

Phone 1. During the call:

a. DYER stated: “[U/I] gonna need you. I’m gonna see him [narcotics 

customer, UC-2] . . . .” FRANKLIN replied: “Huh?” DYER responded: “I say I’m 

probably finna need you, so you can . . . you know . . . so I could hit my guy [narcotics 

customer, UC-2]. I’m gonna see how many [bags of narcotics DYER has available to 

sell]. You dig? ‘Cause you know . . . .” FRANKLIN replied: “Okay, just let me know, 

cause I think I got like 1 or 2 [packs of heroin] on me. I gotta go see. That’s why I 

was calling you.”

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b. FRANKLIN replied: “I called you anyway. I was finna ask you, 

did you need one [pack of narcotics] because I remember you said earlier, you had one 

[pack of narcotics] earlier.” DYER responded: “Yeah. Cause see my guy [DYER’s 

customer, UC-2] . . . I just told him . . . he just called me. He was like, ‘Man, I’ll 

probably need about 5 or 6 [packs of narcotics].” I said, ‘Man, bro, I ain’t even gonna 

lie. Let me call you right back. I’m gonna call my guy [DYER’s supplier/Monticello 

DTO member, FRANKLIN]. I’m gonna see what he got and then I could put what I 

got, and then we’ll see what we get from there.’ So you think you probably got 2 [2 

packs of narcotics] if possible?” FRANKLIN replied: “Yeah, hold on. No, I said I think 

. . . . I know I got one [pack of narcotics], for sure.” DYER responded: “Right, you 

know you got one [pack of narcotics], for sure.” FRANKLIN replied: “Yeah. Let me 

check the other one here.” 

c. DYER responded: “Right. Alright, look, I’m just gonna let his 

[DYER’s customer, UC-2] ass know motha fucka only got like 3 packs [of narcotics] 

for his ass. I could give him my 2 [packs of narcotics] and then your 1 [pack of 

narcotics], and he’ll have to . . . .” FRANKLIN later said: “[U/I] could we get them 

[additional narcotics] though. ‘Cause I could probably like help you out [supply 

additional narcotics]. Like what you could be getting, you could get it now for the 100 

[$100] . . . .” DYER responded: “Yeah, that’s what I’m saying . . . .” FRANKLIN 

replied: “12 [baggies of narcotics] or whatever.” DYER responded: “[U/I] his 11 

[baggies of narcotics] for the 100 [$100]. [U/I] Shit, I’m gonna see what he [DYER’s 

customer, UC-2] want, cause we’ll fuck around [U/I], you know, bump his head, if you 

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got some. Just make it what he needs . . . even if you got like 10 [baggies of narcotics]. 

I’ll just short his ass [provide fewer baggies than in a typical pack, 13]! I don’t care. 

As long he get almost what he wants.” 

d. FRANKLIN replied: “Look, this is what I’m gonna tell you. Call 

him [DYER’s customer, UC-2] and see like, for sure what [quantity of narcotics] he 

wants, and then call me right back so I could see.” DYER responded: “Right.” 

FRANKLIN replied: “If that’s the case, depending on how long he could take, we could 

call and try to get some more [narcotics].” DYER responded: “Hell yeah, that’s what 

I said. I’m gonna hit his [DYER’s customer, UC-2] ass right back, see and I’m gonna 

hit you right back.” FRANKLIN replied: “Alright.”

139. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) DYER called FRANKLIN 

to see if FRANKLIN had enough narcotics to supply DYER and accommodate the 

request of UC-2; (b) FRANKLIN said that he had 1 or 2 packs of narcotics 

(approximately 12 to 24 baggies); (c) DYER told FRANKLIN that UC-2 wanted to 

purchase a substantial quantity of narcotics (between 5 and 6 packs) and that DYER 

had told UC-2 he would call FRANKLIN to see how much narcotics he could get to 

distribute to UC-2; (c) DYER and FRANKLIN talked about providing UC-2 with 

several packs of narcotics and possibly shorting him on the total amount; and (d)

FRANKLIN told DYER to call UC-2 back, confirm the total quantity of narcotics UC2 wanted, and then FRANKLIN would see if they could obtain more if necessary. 

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140. On or about September 3, 2019, at approximately 1:28 p.m., UC-2 

received a call from DYER, using DYER Phone 1. During the call:

a. DYER told UC-2: “Yup, I only got 2 [packs of narcotics], but my 

guy [FRANKLIN] said he gonna get me two [packs of narcotics], so . . . .” UC-2 

responded: “So 4 [packs of narcotics] altogether.” DYER replied: “Yup.” UC-2 

responded: “Alright, yeah, if you want to I could even go pick it up from your guy 

[FRANKLIN], so you don’t have to go. You know what I mean? I can have my boss 

drop me off. We can do it that way too.” DYER replied: “Yeah, all you gotta do is hit 

me up. He [FRANKLIN] just told me, ummm, let me know what you gonna do. So 

he [FRANKLIN] can bring it, if you’re gonna come through.” 

b. UC-2 responded: “Yeah, yeah for sure, for sure, yeah let me get 

the 4 [packs of narcotics], if that’s all you can get for sure, you’re going to give me the 

four [packs of narcotics]?” DYER replied: “Yeah.” UC-2 responded: “Ok.” UC-2 

responded: “I’ll bring $400.” DYER replied: “Ok cool.” UC-2 responded: “They [UC2’s fictitious narcotics customers] love your, your heroin, man. They love their heroin, 

that’s why that’s why, ‘cause we go to a couple of places, man, but they love that tin 

foil, bro.” DYER replied: “Yeah, yup, that’s [heroin] what I got. So, yeah, uh, just hit 

me up, I’m finna tell him he [DYER’s supplier, FRANKLIN] can bring it [the packs 

of heroin].” UC-2 responded: “Alright, B, man, I’ll see ya in a bit.”

141. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) DYER told UC-2 that he 

was going to obtain 2 packs of narcotics from DYER’s supplier/Monticello DTO 

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member (FRANKLIN) and would be able to provide 4 packs of narcotics to UC-2; (b) 

UC-2 confirmed the amount (4 packs of narcotics) and amount that he would pay 

DYER ($400) and offered to pick up 2 packs directly from FRANKLIN; (c) UC-2 told 

DYER that his narcotics customers loved the quality of the heroin that UC-2 

purchased from DYER and DYER said that he had that same quality heroin; and (d) 

DYER told UC-2 that he would contact FRANKLIN to bring the 2 packs of heroin.

142. On or about September 3, 2019, at approximately 1:28 p.m. (TP2 Session 

4438), FRANKLIN, using Target Phone 2, received a call from DYER, using DYER 

Phone 1. During the call:

a. DYER stated: “So look, this is what you could do. You could just 

get me a whole one [pack of narcotics] and 8 [baggies of narcotics].” FRANKLIN 

replied: “A whole one [pack of narcotics] and 8 [baggies of narcotics]?” DYER 

responded: “Yeah.” FRANKLIN replied: “Okay.” DYER responded: ’”Cause I just 

told him [DYER’s customer, UC-2], I could fuck with it like that. Cause that n---- . . 

. he was trying to go too over board [obtain too much narcotics in one purchase], so I 

told him, ‘As soon as we get right, right, I’m gonna hit his line.’ ‘Cause that n---- [UC2] was trying to spend a whole 1,000 [$1,000]. And I told him, ‘Oh, bro, you gotta 

wait.’” FRANKLIN replied: “How many you got [packs of narcotics]? How many you 

got all together? You ain’t got none [packs of heroin] up there?” DYER responded: “3 

[packs of narcotics].” FRANKLIN replied: “3 whole ones [packs of narcotics]?” 

b. DYER responded: “3 [packs of narcotics]. So that’s why I told him 

[DYER’s customer, UC-2], ‘Just wait ‘til a motha fucka do something,’ [U/I].” 

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FRANKLIN replied: “You got 3 whole ones [packs of narcotics] up top?” DYER 

responded: “Yeah.” FRANKLIN replied: “Alright, call his ass [DYER’s customer, UC2] back!” DYER responded: “Put together for him [DYER’s customer, UC-2].” 

FRANKLIN replied: “Call his [DYER’s customer, UC-2] ass back! Tell his [DYER’s 

customer, UC-2] ass you got . . . tell his [DYER’s customer, UC-2] ass to bring like 

700 [$700]. You got ‘em.” DYER responded: “Yeah.” FRANKLIN replied: “Yo 3 

[packs of narcotics] . . . I got 2 [packs of narcotics] . . . I think what’s his name [another 

Monticello DTO member] got 2 [packs of narcotics], so see, that’s 4 [packs of narcotics] 

right there.” DYER responded: “Yeah. He [DYER’s customer, UC-2] still on his way 

though, so I’m gonna slide down you.” FRANKLIN replied: “Alright I’m just gonna 

put the whole one [pack of narcotics] and the 8 [baggies of narcotics] together for you.” 

DYER responded: “Alright.”

143. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) DYER asked FRANKLIN 

for narcotics FRANKLIN had on hand, including 1 full pack of heroin (12 baggies)

and 8 loose baggies of heroin; (b) FRANKLIN said that his customer, UC-2, was 

asking for too large a quantity of narcotics ($1,000 worth) and that he wanted his 

customer to wait; (c) FRANKLIN and DYER confirmed the amount of narcotics they 

had available to distribute to UC-2, including 3 packs with DYER; (d) FRANKLIN 

told DYER to charge UC-2 $700 for the total amount of narcotics (4 packs and 8 loose 

baggies); (e) FRANKLIN said that other members of the Monticello DTO had full 

packs of narcotics that DYER could give to UC-2; and (f) DYER told FRANKLIN that 

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UC-2 was on his way, so he could not collect additional heroin from other members of 

the Monticello DTO.

144. At approximately 2:02 p.m., surveillance observed and CPD Pod camera 

video reflected UC-2 enter the alley behind DYER Residence at the Monticello Avenue 

Drug Spot. UC-2 was equipped with an audio and video recording device. According 

to UC-2 and body cam video, when UC-2 approached the fence at DYER Residence, 

DYER walked over to UC-2 and handed UC-2 four packs, which contained tin foil 

packets and UC-2 gave DYER $400 in government funds. UC-2 then departed the 

area.

145. UC-2 provided the tin foil packets supplied by DYER to the DEA North 

Central Laboratory. According to the laboratory, the contents weighed 

approximately 22.7 grams and tested positive for the presence of heroin and furanyl 

fentanyl.

146. Less than seven minutes after this transaction, at approximately 2:09 

p.m. (Call Session 4440), FRANKLIN, using Target Phone 2, received a call from 

DYER, using DYER Phone 1. During the call, DYER said: “I say when you gonna be 

out front [street side of the Monticello Avenue Drug Spot] again?” FRANKLIN 

replied: “Uh, soon as we wrap the rest of this shit [narcotics] up. Grey transit 

[unmarked police vehicle] went past. They [police] didn’t even look down here.” 

DYER responded: “Right. I’m gonna slide up, then I’m gonna slide down.” 

FRANKLIN replied: “I’m right here. I’m already in the front. I’m right here, come 

on.”

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147. At approximately 2:11 p.m., CPD POD camera video reflected DYER 

walking down the front steps of DYER Residence, while FRANKLIN was standing in 

front of DYER Residence. At that point, DYER handed FRANKLIN an object through 

the wrought iron fence and the two quickly departed in different directions.

148. Based on my training and experience and knowledge of the 

investigation, including several prior purchases of narcotics by UCs from DYER and 

FRANKLIN on Monticello Avenue, the intercepted calls between FRANKLIN and 

DYER from earlier that day, UC-2’s purchase of narcotics from DYER minutes 

earlier, and CPD POD camera video reflecting a meeting between DYER and 

FRANKLIN minutes later, I believe that DYER met with FRANKLIN in order to 

provide FRANKLIN with proceeds from the sale of narcotics to UC-2 or in order for 

FRANKLIN to re-supply DYER with additional narcotics.

C. FRANKLIN Supplied WILL HOWARD with Narcotics, a Portion of 

Which (3.6 Grams of Heroin and 1.2 Grams of Cocaine) was Seized by 

LEOs on September 4, 2019.

149. On or about September 4, 2019, at approximately 10:25 a.m., 

surveillance observed DYER park his vehicle in front of a residence at the Monticello 

Avenue Drug Spot and FRANKLIN exit the passenger’s side front door. FRANKLIN 

then walked to a different residence on Monticello Avenue and met with WILL 

HOWARD.24 During that meeting, FRANKLIN reached under his hooded sweatshirt 

and removed a black bag, which he handed to WILL HOWARD.

 

24 Law enforcement officials identified WILL HOWARD as follows: as discussed below, on 

September 4, 2019, WILL HOWARD was arrested following the review of CPD Pod camera 

video reflecting him engage in a suspected hand-to-hand transaction of narcotics and the 

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150. Based on my training and experience and knowledge of the 

investigation, including numerous narcotics transactions brokered by FRANKLIN 

and DYER and intercepted calls regarding FRANKLIN supplying members of the 

Monticello DTO with narcotics, and, as discussed below, CPD Pole Camera video 

depicting WILL HOWARD transfer items to an unknown male in exchange for money 

and the later seizure of a bag containing tin foil packets further containing a white 

powdery substance and blue Ziploc baggies further containing a white rock-like 

substance, I believe that during their meeting, FRANKLIN provided WILL 

HOWARD with narcotics for distribution.

151. That same day, at approximately 10:40 a.m., CPD Pod camera video 

located on Monticello Avenue captured the following:

a. WILL HOWARD gestured towards an older male and engaged in 

a short conversation with him before approaching the wrought iron fence of a 

residence on Monticello Avenue. 

b. At that point, WILL HOWARD reached through the fence and 

retrieved one of two small cigarillos bags hidden inside the fence. WILL HOWARD 

then reached into the bag and retrieved small items from the bag, before placing the 

bag back onto the grass of the residence. 

 

seizure of narcotics from that same area. As part of the arrest, WILL HOWARD was 

processed and fingerprinted and identified based on preexisting records in the Chicago Police 

Department database from prior arrests.

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c. WILL HOWARD returned to the older male and provided the 

items that he had just retrieved from the bag to the older male in exchange for an 

unknown amount of cash. 

152. Based on their training and experience, knowledge of the investigation, 

and monitoring of the CPD Pod camera video, officers believed that they had just 

witnessed a narcotics transaction and relocated to the area to perform an 

investigatory stop and a search of the lawn at the residence on Monticello Avenue. 

153. During this search, agents seized the two cigarillo bags, from which they 

had observed WILL HOWARD retrieve the items he later provided to the older male 

in exchange for cash. The two cigarillo bags contained five tin-foil packets containing 

a white powdery substance and ten blue-tinted Ziploc bags each containing a white 

rock-like substance. 

154. Agents submitted the substances they seized from WILL HOWARD’s 

cigarillo bags to the Illinois State Laboratory for analysis. The Illinois State 

Laboratory determined that the substances within the tin foils contained 

approximately 3.6 grams of heroin and that the blue Ziploc contained approximately 

1.2 grams of cocaine. 

155. At approximately 10:51 a.m., officers observed WILL HOWARD on the 

1000 block of North Lawndale Avenue, approximately one-half block away from the 

residence on Monticello Avenue where agents had seized the heroin and cocaine. 

Officers arrested WILL HOWARD relating to an active arrest warrant for traffic 

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violations. Minutes earlier, CPD officers briefly detained FRANKLIN before 

releasing him. 

156. On or about September 4, 2019, at approximately 10:48 a.m. (TP2

Session 4604), FRANKLIN, using Target Phone 2, called Individual I, using 

Individual I Phone. During the call:

a. FRANKLIN stated: “The police just had me, so I’m not doing 

nothing [dealing in narcotics] right now! You hear me? Nothing!” Individual I 

responded: “I know, your uncle called me. It’s booming [lots of law enforcement] over 

there.” FRANKLIN replied: “Yeah. Shit shaking right now. I’m sorry, but shit 

shaking right now.” Individual I responded: “Nah, it’s cool! I’d rather for you to be 

safe than sorry.” FRANKLIN replied: “Hell yeah.” 

b. Individual I stated: “He [FRANKLIN’s uncle] coming back from 

down there. He [FRANKLIN’s uncle] say he saw you ride past him.” FRANKLIN 

replied: “Yeah, they had me for mistaken identity. Ain’t even me!” Individual I 

responded: “For real?” FRANKLIN replied: “Hell yeah! I coulda just went to jail for 

somebody else [WILL HOWARD’s] shit [narcotics]!” FRANKLIN later stated: “I 

already know. Shit, the motha fucka they looking for [WILL HOWARD], they [CPD] 

got him.” Individual I responded: “They got him?” FRANKLIN replied: “Yeah. They 

be looking for my homie [WILL HOWARD].” 

157. Based on my training and experience and knowledge of the 

investigation, I believe that: (a) FRANKLIN told Individual I that he had just been 

arrested in connection with WILL HOWARD’s narcotics; (b) FRANKLIN told 

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Individual I that he was not going to be selling narcotics around that time because of 

the arrest and the presence of law enforcement in the area; (c) FRANKLIN told 

Individual I that the police had arrested WILL HOWARD; and (d) FRANKLIN 

believed that WILL HOWARD had been arrested for narcotics because FRANKLIN 

had supplied him with narcotics just over 20 minutes earlier. 

158. On or about September 4, 2019, at approximately 11:14 a.m. (TP2 

Session 4612), FRANKLIN, using Target Phone 2, received a call from Individual C, 

using Individual C Phone 1. During the call, FRANKLIN stated: “Yeah, this n----

[WILL HOWARD] ain’t even get up outta there. Guess where they catch him at? 

Lawndale. Walking.” Individual C responded: “Oh, so he [WILL HOWARD] thought 

he was just carefree, just walking down the street?” FRANKLIN replied: “Yeah, and 

they found the shit [heroin and cocaine]!”

159. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) FRANKLIN told 

Individual C that WILL HOWARD was arrested walking in the area; (b) Individual 

C asked FRANKLIN if WILL HOWARD was just walking casually and FRANKLIN 

agreed that he was; and (c) FRANKLIN said that law enforcement had recovered the 

narcotics that WILL HOWARD possessed and distributed. 

D. LEE and BONDS Discuss Narcotics that They Previously Cut on Behalf 

of the DTO Prior to Giving them to SAM HOWARD and FRANKLIN for 

Distribution at the Monticello Avenue Drug Spot in September 2019.

160. On or about September 22, 2019, at approximately 1:47 p.m. (TP2

Session 6763), SAM HOWARD, using Target Phone 2, received a call from LEE, using 

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Target Phone 5.25 During the call: 

a. LEE stated: “What’s good though, you good?” SAM HOWARD 

replied: “Yeah. Hey, they say . . . .” SAM HOWARD then began speaking to 

FRANKLIN on his end of the call,26 asking, “You said they [narcotics customers] said 

what?” FRANKLIN, on SAM HOWARD’s end of the call stated: “They said it’s 

 

25 Law enforcement officials identified ANTONIO LEE and identified LEE as the user of 

Target Phone 5 as follows: on or about October 4, 2019, intercepted calls over Target Phone 

2 (TP2 Sessions 9036, 9038 9040 and 9041) reflected that FRANKLIN was going to meet with 

the user of Target Phone 5 for a re-supply of narcotics. Based on those calls, agents 

established surveillance on FRANKLIN and SAM HOWARD and followed FRANKLIN and 

SAM HOWARD to a residence on the 2000 block of N. Karlov Street in Chicago. Agents 

observed SAM HOWARD enter and exit the residence and, shortly thereafter, surveillance 

observed MORRIO BONDS arrive in BONDS Vehicle. Minutes later, another individual 

exited the residence and departed the area in BONDS Vehicle with BONDS. During that 

surveillance, agents took a photograph of the individual who exited the residence and 

departed with BONDS. Law enforcement later reviewed a booking photograph of LEE from 

a Chicago Police Department database and determined that LEE was the individual depicted 

in the photograph discussed above.

On or about October 9, 2019, FRANKLIN, using Target Phone 2 (TP2 Sessions 10216 - 10229, 

1031-10241, 1025-10248), exchanged several calls with the user of Target Phone 5. During 

those calls, FRANKLIN and the user of Target Phone 5 discussed a meeting for a re-supply 

of narcotics. Based on those calls, agents monitored the meeting area using CPD POD 

cameras located in the area. At approximately 1:49 p.m., surveillance observed a black Jeep 

drive onto the block of 1000 N. Monticello Ave. and FRANKLIN enter the rear driver’s side 

of the Jeep. At approximately 2:00 p.m., surveillance observed LEE exit a nearby residence 

and walk towards the Jeep. Approximately two minutes later, surveillance observed LEE 

enter the rear driver’s seat of the same Jeep that FRANKLIN had just entered. Surveillance 

observed LEE exit the vehicle shortly thereafter and depart the area. Based on those 

intercepted calls and surveillance observations, agents determined that: (1) LEE was the user 

of Target Phone 5 communicating with FRANKLIN about a re-supply of narcotics; and (2) 

LEE met with FRANKLIN to re-supply FRANKLIN with narcotics.

On or about October 28, 2019, the Honorable Rebecca Pallmeyer, Chief Judge for the 

Northern District of Illinois, entered an order authorizing the interception of wire and 

electronic communications to and from Target Phone 5. Interception began on October 28, 

2019 and terminated on November 26, 2019.

26 Law enforcement officials identified both SAM HOWARD and FRANKLIN’s voices using 

Target Phone 2 during the course of this intercepted call.

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[narcotics previously supplied by LEE] not the same.” SAM HOWARD then stated 

to LEE: “They [narcotics customers at the Monticello Avenue Drug Spot] said it’s [the 

narcotics] not the same [quality]. It’s different.” 

b. LEE responded: “What they [narcotics customers] say though? I 

know it’s [the narcotics] the same [quality]. He [MORRIO BONDS,27 associate 

responsible for cutting DTO narcotics with additives to increase quantity] probably 

ain’t shake [mix the narcotics] the way I shake [mix the narcotics]. What they 

[narcotics customers] say though?” SAM HOWARD then resumed speaking to 

FRANKLIN, asking: “They said it’s [narcotics] too strong?” SAM HOWARD then said 

to LEE: “They [narcotics customers] said it’s [narcotics] too strong, man. It [the 

narcotics] look mostly white. They said it’s [narcotics] under than what you give them 

[narcotics customers]. They said it’s under that. It [the narcotics] ain’t really popping 

no shit [does not have the same effect] but it [the narcotics] ain’t the same.” 

 

27 On September 22, 2019, between 1:18 a.m. and 2:54 a.m. (TP2 Sessions 6677 through 6696, 

6698-6703), FRANKLIN, using Target Phone 2, exchanged multiple text messages with 

BONDS, using Target Phone 4. In one text message at approximately 1:25 a.m. (TP2 Session 

6680), BONDS said to FRANKLIN: “He [LEE] told me to put it [narcotics supply] in your 

hands.” In messages later that day between approximately 2:40 p.m. and 2:52 p.m., (TP2 

Sessions 6777 through 6784), FRANKLIN, using Target Phone 2, exchanged messages with 

BONDS, using Target Phone 4. In one message at 2:50 p.m., (TP2 Session 6782), BONDS 

wrote: “Tell him [SAM HOWARD] to let me know what he got left [how much narcotics].” 

FRANKLIN responded, (TP2 Session 6783): “Shidd [shit] we still up there [Monticello Avenue 

Drug Spot] It’s b [been] a slow morning n afternoon bt [but] I gotchu [will be able to provide 

narcotics proceeds].” Based on these messages between FRANKLIN and SAM HOWARD 

regarding the distribution of narcotics on September 22, 2019 and managing of the drug 

supply, I believe that in the intercepted call between FRANKLIN, SAM HOWARD, and LEE 

that same day, LEE referenced BONDS as the individual with whom he was working who 

cut the narcotics supplied to the Monticello DTO.

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c. LEE responded: “He [FRANKLIN, relaying the comments from 

the narcotics customers] says what now?” SAM HOWARD replied: “He [FRANKLIN] 

says it’s [the narcotics] really not the same. It ain’t how you do it [not the way that 

LEE normally mixes narcotics].” LEE responded: “Everything [the narcotics and 

additives] the same. He [FRANKLIN] said what? It’s too strong? He [BONDS] made 

it [the narcotics] too strong?” 

d. FRANKLIN got on the phone and replied: “I had two of my people 

[narcotics customers] try that [the narcotics] you know what I’m saying? One bought 

one [pack of narcotics]. He [narcotics customer] took a whole bag out the window [got 

rid of the narcotics]. Literally. A whole bag out the window.” LEE responded: “He 

threw the whole bag [of narcotics] out the window? What was he saying? Was it [the 

narcotics] too strong for ‘em? What though?” FRANKLIN replied: “What he’s 

[narcotics customer] saying is that, yeah he ain’t like it [the narcotics]. Then I had T 

called me. I had my auntie try one. She’s like it’s [U/I]. She like, ‘But it’ll [narcotics] 

do. It’s [the narcotics] too strong. So when you hit it you, you get to coughing. If a 

motherfucker with asthma do it and they get to coughing they ass probably go into a 

asthma attack.” 

e. SAM HOWARD got on the phone and said: “It’s [the narcotics] too 

strong. That shit strong.” FRANKLIN replied: “That shit [narcotics] white like chalk, 

that shit ain’t like [U/I] with the little specks or none of that. That shit pure white. 

Like that motherfucker just powder [the narcotics was not cut like it normally was].” 

SAM HOWARD replied: “Right.”

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161. Based on my training and experience and knowledge of the 

investigation, I believe that in the above exchange: (a) SAM HOWARD and 

FRANKLIN informed LEE that narcotics customers were dissatisfied by LEE and 

BONDS’s most recent supply of narcotics, which they found to be too strong; (b) LEE 

told SAM HOWARD and FRANKLIN that the narcotics were the same quality, but 

that BONDS had mixed the narcotics, which may have been done differently than he 

normally mixes the narcotics; (c) FRANKLIN told LEE that one customer used the 

narcotics and immediately threw an entire bag out his car window because he did not 

like the narcotics and that he had given a sample to his aunt, who also found the 

narcotics to be different than normal; and (d) FRANKLIN and SAM HOWARD told 

LEE that the narcotics appeared different (pure white and powdery), which was 

atypical.

162. On or about September 22, 2019, at approximately 1:52 p.m. (TP2 

Session 6764), SAM HOWARD, using Target Phone 2, received a call from LEE, using 

Target Phone 5. During the call: 

a. LEE stated: “Yeah, I was trying to park. The fucking police was 

behind me and shit and I ain’t had no seat belt on. What he [FRANKLIN] say now? 

He said god dammit one . . . Auntie said it [narcotics] worked but she said it’s too 

strong too. One motherfucker [narcotics customer] said what?” SAM HOWARD 

replied: “He [narcotics customers] said, ‘We gonna get rid of it [narcotics].’ But it’s 

like . . .” 

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b. LEE responded: “No, they [narcotics customers] ain’t saying . . . 

That n---- don’t know . . . The thing I ain’t want him [BONDS] to go hit it [narcotics] 

like I hit it. I told him [BONDS] to do it [cut the narcotics] a little softer [less 

additive]. That’s probably why it’s [narcotics] too strong. You know what I’m saying?” 

SAM HOWARD replied: “Yeah.” 

c. LEE responded: “Then mother fucker [BONDS] shake [cut the 

narcotics] ain’t like mine. I don’t give a fuck who you with on Chicago. That mother 

fucker shake ain’t like mine. Everything in that biz [supply and quality of narcotics 

is] good. It’s [narcotics] probably too strong for a motherfucker. I know. Everything 

I got [supply of narcotics] is so fucking strong. You know what I’m saying? Then 

some motherfuckers that hit it, they’ll . . . if it’s too strong, that don't mean it ain’t no 

good. It’s too strong for them. Dude, probably put that motherfucker out the window 

‘cause it was too strong for him.” 

d. SAM HOWARD replied: “Yeah, that’s probably what it was 

[narcotics were too strong].” LEE responded: “I’m keeping it 100 I know my D 

[heroin]. He [narcotics customer] probably tasted it [narcotics], and he like, no, he 

probably told to sell to him to himself and then threw the motherfucker out the 

window. But, we cool. I’ll be back tonight. In the morning. But, yeah, that’s all it 

was. I just try to coach him [teach BONDS to cut the narcotics] through the fucking 

phone and shit. That’s all that was.” SAM HOWARD replied: “Alright. Motherfucker 

see you though, motherfucker [U/I].” 

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e. LEE responded: “Yeah, go ahead and run through that shit [sell 

the narcotics]. We cool. Just tell every motherfucker we passing out [handing out 

samples for free] Tuesday morning. I don’t need him. Fuck that shit.” SAM 

HOWARD replied: “Okay.” LEE responded: “[U/I] We just gonna do it anyway. You 

already know how I'm coming out there, I’m passing out [handing out free samples of 

narcotics] every week anyway.” SAM HOWARD replied: “Okay, Okay.”

163. Based on my training and experience and knowledge of the 

investigation, including several prior purchases of narcotics by UCs from FRANKLIN 

at the Monticello Avenue Drug Spot, I believe that in the above exchange: (a) LEE 

summarized what FRANKLIN had told him about complaints FRANKLIN had heard 

about the most recent supply of narcotics; (b) SAM HOWARD told LEE that they 

wanted to get sell the most recent supply of narcotics; (c) LEE informed SAM 

HOWARD that he had BONDS cut the narcotics and make them stronger and that 

each person who cuts bulk narcotics does it differently, but that the quality of the 

narcotics was high and that the customers were probably not prepared for the 

strength of the narcotics; (d) LEE told SAM HOWARD that he was being forthright 

with SAM HOWARD and that, with this supply, he had been trying to teach BONDS 

to cut narcotics, but by telephone, which may have led to it being too strong; and (e) 

LEE said that he would be providing free samples of narcotics on Tuesday, September 

24, as he had been doing in recent weeks.

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E. BONDS Arranges the Collections of Narcotics Proceeds from FRANKLIN

on September 23, 2019.

164. On or about September 23, 2019, between 4:32 p.m. and 7:22 p.m. (TP2 

Sessions 7013, 7014, 7016, 7018, 7019, 7020, 7027, 7028, 7029, 7030, 7032, 7034 and 

7035), FRANKLIN, using Target Phone 2, exchanged a series of text messages with 

BONDS, using Target Phone 4.28 During that exchange:

a. BONDS wrote: “You got 200 [$200] on you.” FRANKLIN 

responded: “Slide [come by Monticello Avenue Drug Spot].” BONDS replied: “✔.” 

FRANKLIN responded: “How far r Yu I gotta drop my kids off ion like Dem standing 

 

28 Law enforcement officials identified BONDS and identified BONDS as the user of Target 

Phone 4 as follows: on or about September 26, 2019, between 1:07 p.m. and 1:14 p.m., law 

enforcement officials intercepted text messages (TP2 Sessions 7465, 7466, 7467 and 7468) 

between FRANKLIN, using Target Phone 2, and the user of Target Phone 4. Based on those 

calls, law enforcement officials anticipated a meeting between FRANKLIN and the user of 

Target Phone 4 (BONDS). During those text messages: FRANKLIN wrote: “Omw [on my 

way] to yu [you].” The user of Target Phone 4 (BONDS) replied: “✔” FRANKLIN responded: 

“Downstairs.” The user of Target Phone 4 (BONDS) replied: “Ok.” Based on my training and 

experience and knowledge of the investigation, I believe that in the above exchange,

FRANKLIN told the user of Target Phone 4 (BONDS) that he was going to the residence of 

the user of Target Phone 4 to obtain narcotics and the user of Target Phone 4 indicated that 

he was ready to re-supply narcotics to FRANKLIN.

At approximately 1:19 p.m., agents conducted surveillance in in the area of W. Jackson Street 

and N. Hamlin Blvd and observed FRANKLIN outside a vehicle speaking with a man later 

identified as BONDS. Agents continued surveillance of the unidentified male, and, at 

approximately 1:33 p.m., agents observed the male enter a silver Pontiac Grand Prix 

(BONDS Vehicle) and begin driving at a high rate of speed and make an illegal U-turn. 

Officers conducted a traffic stop of BONDS Vehicle, at which time the driver, the same 

individual agents had observed meeting with FRANKLIN, provided an Illinois driver’s 

license bearing the name “MORRIO BONDS,” which picture matched his appearance.

Later that day, the CPD officers who conducted the traffic stop on BONDS, listened to TP2 

Sessions #6876, 6919, 7036 and 7137 and confirmed that the voice of the user of Target Phone 

4 was the same man that they had encountered during the traffic stop (BONDS).

On or about October 28, 2019, the Honorable Rebecca Pallmeyer, Chief Judge for the 

Northern District of Illinois, entered an order authorizing the interception of wire and 

electronic communications to and from Target Phone 4. Interception began on October 28, 

2019 and terminated on November 26, 2019. 

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on the block.” BONDS replied: “Do you just htl [hit the line or call BONDS] when 

you get back.” FRANKLIN responded: “Ight.” 

b. Later that evening, FRANKLIN asked again: “Yooo Yu still 

coming to grab tht [$200 in narcotics proceeds].” BONDS replied: “Yep.” FRANKLIN 

responded, “Weneva Yu ready.” BONDS replied: “On the way.” FRANKLIN 

responded: “Ok.”

165. Based on my training and experience and knowledge of the 

investigation, I believe that in the above exchange FRANKLIN and BONDS made 

arrangements for FRANKLIN to provide BONDS with $200 in narcotics proceeds for 

BONDS to put towards the next supply of narcotics. 

166. On or about September 23, 2019, at approximately 7:17 p.m. (TP2 

Session 7036), FRANKLIN, using Target Phone 2, received a call from BONDS, using 

Target Phone 4. During the call, FRANKLIN stated: “I’m right here. I’m finna turn 

the corner. I’m hitting one of my people [serving a narcotics customer] real quick.” 

BONDS replied: “A’ight. I’m finna come back around the block. I’m in this Grand 

Prix, the one that’s tinted up.” FRANKLIN responded: “Okay.”

167. Based on my training and experience and knowledge of the 

investigation, including several prior purchases of narcotics by UCs from FRANKLIN 

at the Monticello Drug Spot, I believe that in the above exchange FRANKLIN 

informed BONDS that he was in the area supplying a customer with narcotics and 

that he was available to provide BONDS with the $200 in narcotics proceeds.

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F. LEE Instructs FRANKLIN to Distribute Narcotics to BONDS on 

September 29, 2019.

168. On or about September 29, 2019, at approximately 7:17 p.m. (TP2 

Session 8091), FRANKLIN, using Target Phone 2, received a call from LEE, using 

Target Phone 5. During the call, LEE stated: “Hey, my little bro, [BONDS] he finna 

pull up. They need a whole one [one full pack of heroin], lil bro.” FRANKLIN replied: 

“Hold on, wait, wait. You say what now?” LEE responded: “My little bro [BONDS], 

he need a whole one [pack of narcotics]. He finna be pulling up in like five minutes.” 

FRANKLIN replied: “All right, just call me when he [BONDS] right there.” LEE 

responded: “[U/I] pulling up. And I’ll meet him [BONDS] around here. He coming.” 

FRANKLIN replied: “Okay, I gotcha.” LEE responded: “He coming [U/I].” 

FRANKLIN replied: “All right.”

169. Based on my training and experience and knowledge of the 

investigation, I believe that in the above exchange, LEE asked FRANKLIN to supply 

BONDS with one packet of heroin and FRANKLIN agreed to do so.

170. On or about September 29, 2019, at approximately 7:23 p.m. (TP2 

Session 8095), FRANKLIN, using Target Phone 2, received a call from LEE, using 

Target Phone 5. During the call, FRANKLIN stated: “Yeah, where he [BONDS] at?” 

LEE responded: “Let me see where he at. He in a light grey Grand Prix probably. Let 

me see where he at. Hold on.”

171. On or about September 29, 2019, between approximately 7:23 p.m. and 

7:33 p.m. (TP2 Sessions 8096-8097, 8100), FRANKLIN, using Target Phone 2, 

exchanged text messages with LEE, using Target Phone 5. In that exchange, LEE 

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wrote: “5 mints [minutes] pulling up lil bro.” FRANKLIN replied: “‘Ight.” 

FRANKLIN then wrote: “Hit me [call] wen [when] he [BONDS] get right here I got 

my ppl [Monticello DTO members or narcotics customers] waiting on me.”

172. Based on my training and experience and knowledge of the 

investigation, I believe that in the above exchange: (a) LEE told FRANKLIN that 

BONDS would be arriving in the area of Monticello Ave. in order for FRANKLIN to 

supply BONDS with one packet of narcotics; and (b) FRANKLIN told LEE to call him 

when BONDS arrived because he had Monticello DTO members or narcotics 

customers waiting for him to provide additional narcotics.

173. On or about September 29, 2019, at approximately 7:43 p.m. (TP2 

Session 8103), FRANKLIN, using Target Phone 2, received a call from LEE, using 

Target Phone 5. During the call, FRANKLIN stated: “Yo, he [BONDS] right there?” 

LEE responded: “Yeah, in the Grand Prix.” FRANKLIN replied: “All right.”

174. Based on my training and experience and knowledge of the 

investigation, I believe that in the above exchange: (a) FRANKLIN asked LEE if 

BONDS was on Monticello Avenue and LEE confirmed that BONDS was on the block 

in a Grand Prix in order to receive the one packet of narcotics from FRANKLIN; and 

(b) at around 7:43 p.m. on September 29, 2019, FRANKLIN distributed one packet of 

narcotics to BONDS at LEE’s request.

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G. LEE and BONDS Arrange to Re-Supply FRANKLIN with Narcotics

175. On or about September 29, 2019, at approximately 8:11 p.m. (TP2 

Session 8110), FRANKLIN, using Target Phone 2, sent a text message to LEE, using 

Target Phone 5. The text read: “The bears are down by one.” 

176. Approximately four minutes later, at approximately 8:15 p.m. (TP2 

Session 8116), FRANKLIN, using Target Phone 2, sent the same text message to 

BONDS, using Target Phone 4. The text read: “The bears are down by one.”

177. Based on my training and experience and knowledge of the 

investigation, I believe that in the above text messages, FRANKLIN informed LEE 

and BONDS that the members of the Monticello DTO had distributed narcotics and 

were down to one packet of narcotics on hand for distribution.29 

178. On or about September 29, 2019, at approximately 8:58 p.m. (TP2 

Session 8121), FRANKLIN, using Target Phone 2, received a call from LEE, using 

Target Phone 5. During the call, LEE asked: “What’s the word?” FRANKLIN replied: 

“I had text you. I don’t know if [you] had got it.” LEE responded: “I got it. I was just 

calling. . . My phone had died.” FRANKLIN replied: “All right. Hold on. But yeah, 

but like my text say the bears down by one [the Monticello DTO was down to one 

 

29 According to publicly available information on ESPN.com, on September 29, 2019, the 

Chicago Bears played an NFL game against the Minnesota Vikings. Based on my review of 

the box score, the Chicago Bears won the game 16 to 6 and never trailed the Vikings during 

the game. Accordingly, as discussed above and below, I do not believe that FRANKLIN’s text 

message was a reference to the score of the NFL game on September 29, 2019 and was instead 

a reference to the Monticello DTO’s narcotics supply.

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packet of narcotics for distribution].” LEE responded: “The last one [packet of 

narcotics], all right.” FRANKLIN replied: “All right.”

179. Based on my training and experience and knowledge of the 

investigation, I believe that in the above exchange, FRANKLIN and LEE discussed 

how the Monticello DTO was down to its last packet of narcotics and FRANKLIN was 

asking LEE to re-supply him with narcotics in order for FRANKLIN to re-supply the 

street-level distributors of the Monticello DTO.

180. On or about September 29, 2019, at approximately 11:23 p.m. (TP2 

Session 8137), FRANKLIN, using Target Phone 2, received a call from LEE, using 

Target Phone 5. During the call, LEE said: “I was trying to see if you gonna slide 

right here before I slid off, going to the crib.” FRANKLIN responded: “You can go to 

the crib [LEE did not need to go to Monticello Avenue].” LEE replied: “I’mma try to 

get up with you tonight or first thing in the morning. I’m trying to find me a ride. 

Don’t worry about it. [U/I]. I’mma get you right [supply FRANKLIN with narcotics]. 

You all right.” FRANKLIN responded: “All right.”

181. Based on my training and experience and knowledge of the 

investigation, I believe that in the above exchange: (a) LEE asked if he should meet 

with FRANKLIN on Monticello Avenue in order to re-supply FRANKLIN with 

narcotics; (b) FRANKLIN told LEE that they could meet tomorrow in order for LEE 

to re-supply FRANKLIN with narcotics; and (c) LEE assured FRANKLIN that he 

would re-supply him with narcotics that night or early in the morning the next day.

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H. Law Enforcement Officials Seize Cocaine from BONDS and Individual 

J on November 22, 2019.

182. On or about November 22, 2019, between approximately 11:34 a.m. and 

12:48 p.m. (TP5 Sessions 2654, 2655 and 2656), LEE, using Target Phone 5, 

exchanged multiple text messages with BONDS, using Target Phone 4. In these 

messages, LEE stated: “How u looking on the dog food [heroin].” BONDS responded: 

“I still got 3 [units of heroin].” LEE replied: “Yoo trinna hold it [heroin] for u how 

long u gone b.”

183. Based on my training and experience and knowledge of the 

investigation, including approximately 80 undercover purchases of narcotics at the 

Monticello Avenue Drug Spot and prior and subsequent intercepted communications, 

I believe that in the above exchange: (a) LEE asked BONDS how much heroin he had 

left to distribute; (b) BONDS told LEE he had three units of heroin left; and (c) LEE 

informed BONDS that he was trying to hold onto additional heroin in order to supply 

BONDS.

184. On or about November 22, 2019, at approximately 12:57 p.m. (TP5 

Session 2659), BONDS, using Target Phone 4, called LEE, using Target Phone 5. 

During the call, LEE stated: “Yo?” BONDS responded: “If you got somebody 

[customer] that’s finna buy [narcotics], go and talk to them. I can’t do nothing ‘til 

they run me this other [I/A].” LEE replied: “A’ight.” BONDS responded: “Yeah, you 

know [U/I]. I guess I’mma have to wait. Shit, I can’t do nothing ‘til they run me this 

other 100 [$100]. And that’s gonna be the while, that’s gonna be everything. I guess. 

I don’t know.” LEE replied: “A’ight.”

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185. Based on my training and experience and knowledge of the 

investigation, including approximately 80 undercover purchases of narcotics at the 

Monticello Avenue Drug Spot, I believe that in the above exchange, BONDS told LEE 

that if LEE had someone else to whom to sell the heroin, he should sell it because 

BONDS was waiting for narcotics proceeds and could not meet with LEE.

186. On or about November 22, 2019, at approximately 1:22 p.m. (TP5 

Session 2664), LEE, using Target Phone 5, received a phone call from BONDS, using 

Target Phone 4. During the call, LEE stated: “Hello?” BONDS responded: “I need 

that [heroin] boy. Hold that [heroin]. I’m finna get with you in 30-40 minutes. 

Gimme like 30-40 minutes. I’m finna get with you. I’m putting together the last of it 

[money for the heroin or heroin to distribute] so I can [I/A].” LEE replied: “A’ight, 

just call me.” BONDS responded: “Nah, I’m talking about hold that [heroin]. [I/A].” 

LEE replied: “I said, a’ight. Just call me.” BONDS responded: “A’ight. I’m putting 

together the [U/I] shit [money for the heroin or heroin to distribute] right fast.”

187. Based on my training and experience and knowledge of the 

investigation, including approximately 80 undercover purchases of narcotics at the 

Monticello Avenue Drug Spot, I believe that in the above exchange: (a) BONDS told 

LEE to hold onto heroin in order to supply BONDS and LEE agreed; and (b) BONDS 

told LEE that he was putting together money to buy the heroin or remaining heroin 

to distribute.

188. At approximately 3:42 p.m., surveillance observed a gray Pontiac Grand 

Prix, which agents had on prior occasions observed BONDS driving (BONDS Vehicle 

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1) park near a residence on the 2000 block of N. Karlov Avenue, near LEE’s 

Residence.30 BONDS entered the driver’s seat of the vehicle and walked over to the 

front of LEE’s Residence and used his telephone.

189. At approximately 3:48 p.m. (TP4 Session 6790), BONDS, using Target 

Phone 4, called LEE, using Target Phone 5. During the call, BONDS stated: “I’m in 

the front [of LEE’s Residence].”

190. Moments after the telephone call between LEE and BONDS, 

surveillance observed LEE exit the front entrance of LEE’s Residence and engage in 

a conversation with BONDS before both individuals entered the residence. A few 

minutes later, surveillance observed BONDS exit the same door surveillance 

observed BONDS enter, enter the driver’s seat of the Grand Prix and depart the area. 

Law enforcement officials continued to follow BONDS in the Grand Prix.

191. Based on my training and experience and knowledge of the 

investigation, including approximately 80 undercover purchases of narcotics at the 

Monticello Avenue Drug Spot, the intercepted calls discussed above, the seizure of 

narcotics from BONDS and Individual J, discussed below, and the intercepted call 

between BONDS and LEE discussed below, I believe that during the meeting between 

BONDS and LEE in LEE’s Residence, LEE supplied BONDS with heroin.

 

30 Law enforcement officials identified LEE’s Residence as follows: law enforcement officials 

reviewed the call records for Target Phone 5, used by LEE and determined that the person 

with whom he exchanged the most calls was Individual K. Law enforcement officials 

searched a law enforcement database and found numerous reports involving Individual K

and LEE associated with LEE’s Residence. Subsequently, law enforcement officials 

conducted surveillance of LEE’s Residence and observed LEE entering and exiting LEE’s 

Residence and FRANKLIN and SAM HOWARD meeting with LEE at LEE’s Residence.

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192. At approximately 4:04 p.m., law enforcement officials conducted a traffic 

stop on BONDS in the Grand Prix for failure to signal before changing lanes. During 

the stop:

a. Law enforcement officials asked the driver (BONDS) and 

passenger (Individual J) to exit the vehicle.

b. Law enforcement officials observed an item inside of Individual 

J’s mouth, which appeared to be a bag of suspected narcotics and Individual J was 

instructed to spit out the bag. Both BONDS and Individual J acknowledged that 

Individual J had contraband concealed in his mouth and Individual J promptly spit 

a clear plastic bag containing a white chunky substance on the ground. 

193. Following this seizure, agents processed the bag containing the white 

chunky substance into evidence and submitted it to the North Central Lab for testing. 

According to the North Central Lab, the white chunky substance weighed 3.108 

grams and text positive for the presence of cocaine.

194. On or about November 22, 2019, at approximately 4:22 p.m. (TP5 

Session 2713), BONDS, using Target Phone 4, called LEE, using Target Phone 5. 

During the call: 

a. LEE stated: “Hello?” BONDS replied: “Boy, them people [police] 

just booked my uncle with that shit [cocaine seized by police], boy!” LEE responded: 

“They was finna book him?” BONDS replied: “On my momma! He right here in the 

car with me. They just made him spit it [cocaine] out his mouth. On my momma! 

They took the shit [cocaine] and let us go. He [the officer] said: ‘we looking for pipes 

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[guns]. But if ya’ll [U/I] anything . . . .’ Uncle was trying to swallow that mother 

fucker [bag of cocaine] but he couldn’t. I swear to god. On my momma, they was just 

finna book us. He said, ‘spit it out now or both of ya’ll going to jail.’ Right here on 

Pulaski and [U/I]. They followed me all the way from up there. They was on my from 

all the way up there, just following me, following me and then finally pulled me over. 

They just took that shit [cocaine]. ‘If it was some weed, I don’t want this shit. We 

want some pipe [guns].’ Man, that shit scared the fuck outta me.” 

b. LEE responded: “Both of y’all [U/I]?” BONDS replied: “Yeah.” 

LEE responded: “Crazy.” BONDS replied: “That’s why I told you go on spit the shit 

[cocaine] out. ‘Cause he’s like, ‘fuck it.’ He spit it [the cocaine] out. ‘We ain’t gonna 

take you.’ He [the officer] was a man of his word though, shit.” 

c. BONDS later asked: “When you gonna have some more C 

[cocaine]? ‘Cause I gotta run that shit [deliver additional narcotics for sale]. ‘Cause 

I don’t got none [cocaine] right now. They got the last of that shit [cocaine] out there.” 

LEE responded: “Yeah. I’m waiting. [U/I] to wrap this bread [narcotics proceeds]. 

That’s part of the count, what I just gave you.” BONDS replied: “Damn, this shit 

crazy.”

195. Based on my training and experience and knowledge of the 

investigation, including approximately 80 undercover purchases of narcotics at the 

Monticello Avenue Drug Spot, the intercepted calls between LEE and BONDS 

discussed above, and the seizure of suspected heroin from Individual J, I believe that 

in the above exchange: (a) BONDS told LEE about his and Individual J’s encounter 

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with police, during which encounter the officer told Individual J to spit narcotics out 

of his mouth and agreed not to arrest Individual J; (b) according to BONDS, the officer 

told BONDS and Individual J that he was looking for guns, not narcotics, and 

threatened to arrest BONDS and Individual J only if Individual J did not spit out the 

heroin; (c) BONDS asked LEE when LEE would have additional narcotics to 

distribute to BONDS, because BONDS needed to deliver additional narcotics and did 

not have any additional heroin to distribute; and (d) LEE told BONDS that he was 

counting and packaging narcotics proceeds in order to buy additional narcotics and 

referenced the narcotics he had just provided to BONDS. 

V. MONTICELLO DTO MEMBERS DISCUSS THE MANAGEMENT AND 

OPERATION OF THE MONTICELLO AVENUE DRUG SPOT

196. Throughout the conspiracy, members of the Monticello DTO discussed 

the management and operation of the Monticello Avenue Drug Spot, including (i) the 

coordinated efforts of all street-level traffickers selling narcotics on the block; (ii) the 

sale of narcotics packaged by and obtained from the same source; (iii) street-level 

managers directing customers to street-level traffickers to complete hand-to-hand 

exchanges; (iv) DTO leaders directing DTO block managers to distribute free samples 

of narcotics to increase sales at the drug spot; (v) DTO members coordinating efforts 

to monitor and avoid detection by law enforcement; (vi) the possession of firearms to 

protect the drug spot; (vii) the staffing and hiring of street-level traffickers on the 

block; and (viii) the monitoring of the narcotics supply and street-level traffickers at 

the Monticello Avenue Drug Spot.

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A. Monticello DTO Member Acknowledges that Everyone Selling Narcotics 

at the Monticello Avenue Drug Spot Is Working Together. 

197. As discussed above, on August 19, 2019, DYER sold a quantity of 

narcotics to UC-2 at the Monticello Avenue Drug Spot. During their recorded 

conversation, UC-2 asked: “How about your boys out here in the street [Monticello 

Avenue]. You’re not with them? Or?” DYER replied: “Yeah, I’d be fucking with them 

too, though . . . You know what I’m saying, just say we are all together [Monticello 

DTO], but I just be fucking with the back. They [other Monticello DTO members] be 

catching deliveries out there in the front.” 

198. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange, DYER confirmed that he was 

working with the other street-level traffickers for the Monticello DTO, as some 

traffickers handled drug sales in the street and DYER handled drug sales in the 

alleyway. 

B. Street-Traffickers at the Monticello Avenue Drug Spot Are Selling 

Similarly Packaged Narcotics Obtained from the Same Stash. 

199. As discussed above, street-level bosses distributed smaller packs of 

narcotics from larger supplies of DTO narcotics to street-level traffickers, who in turn

sold those packaged narcotics to end-use customers. 

200. For example, as discussed above, on April 9, 2019, UC-2 purchased 

18.095 grams of heroin from DYER and TATE. As UC-2 was approaching DYER to 

purchase the heroin, BARNES approached UC-2 and asked: “what [narcotics do] you 

want?” UC-2 replied: “No no . . . he’s [DYER] going to take care of me [provide 

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narcotics to UC-2].” BARNES replied: “We’re right here with it [heroin].” UC-2 

responded: “No he’s [DYER] going to take care of me.” UC-2 then purchased the 

heroin from DYER. After UC-2 purchased the heroin from DYER, and as UC-2 was 

departing the area, BARNES approached UC-2 again and told UC-2: “It’s [the heroin] 

the same shit too.” 

201. Based on my training and experience and knowledge of the 

investigation, I believe that in the above exchange, BARNES informed UC-2 that the 

heroin BARNES was attempting to sell UC-2 was the same heroin that UC-2 had 

purchased from DYER because they were both supplied by the same people and both 

members of the same DTO (the Monticello DTO).

202. In addition, as discussed above, on or about August 16, 2019, SAM 

HOWARD approached UC-2 after UC-2 purchased approximately 6.34 grams of a 

substance containing heroin, furanyl fentanyl (a fentanyl analogue), and fentanyl 

from DYER. During the conversation: 

a. SAM HOWARD asked: “Hey you still be fucking with buddy in 

the house [DYER]?” UC-2 responded: “Yeah with B [DYER].” SAM HOWARD 

replied: “What he [DYER] sell you?” UC-2 responded: “two [packs of heroin and 

fentanyl] . . . two packs [of heroin and fentanyl].” SAM HOWARD replied: “They good, 

they good [quality heroin and fentanyl]?” UC-2 responded: “Yeah they [the narcotics] 

be good.” SAM HOWARD asked: “Aluminum foil? Aluminum foil [packaging]?” UC2 responded: “What you mean? Say that again?” SAM HOWARD replied: “Aluminum 

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foil? Aluminum foil baggies?” UC-2 responded: “No, no, no they’re tin foils [packaging 

for the heroin and fentanyl].” SAM HOWARD replied: “Ok, ok, ok alright.” 

b. UC-2 stated: “Yeah he [DYER] been taking care of me for months 

now.” SAM HOWARD replied: “Ok, that’s cool.” UC-2 responded: “Alright man, now 

if you give me a deal, I’ll buy from you.” HOWARD replied: “I got you next time, next 

time I got you.” 

203. Based on my training and experience and knowledge of the 

investigation, I believe that in the above exchange: (a) SAM HOWARD asked if UC2 had purchased narcotics from DYER and UC-2 confirmed that he had; (b) SAM 

HOWARD and UC-2 discussed the packaging and quality of the narcotics; and (c) UC2 confirmed that he had purchased narcotics from DYER on Monticello Avenue for 

months, but could purchase directly from SAM HOWARD31 going forward and SAM 

HOWARD said that he would sell to UC-2 the next time UC-2 came to Monticello 

Avenue to purchase narcotics.

C. DTO Street-Level Bosses Directed Customers at the Monticello Avenue 

Drug Spot to Street-Level Traffickers. 

203. Street-level bosses directed narcotics customers to particular streetlevel traffickers. For example, as discussed above, on April 2, 2019, UC-3 and UC-10 

 

31 Based on my training and experience and knowledge of the investigation, I understand 

that individual street-level traffickers, while working with the Monticello DTO and selling 

the same product, derive additional profit for personally selling narcotics. Specifically, as 

discussed above, street-level traffickers typically keep the profit from the sale or 1 or 2 

baggies from a jab or pack and return the remaining proceeds to the street-level managers 

and individuals with connections to the narcotics suppliers. Accordingly, I believe that in the 

above exchange, SAM HOWARD asked UC-2 to purchase from him directly in the future to 

maximize SAM HOWARD’s personal profit.

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purchased approximately 2.194 grams of heroin from SAM HOWARD, HUGHES, and 

Individual A. Prior to the transaction, UC-3 and UC-10 approached SAM HOWARD 

to purchase the heroin, however, SAM HOWARD directed both UCs to the end of the 

block where street-level traffickers (HUGHES and Individual A) were serving 

customers.

204. Similarly, as discussed above, on April 19, 2019, UC-3 and UC-8 

purchased approximately four grams of heroin from SAM HOWARD and 

GARRAWAY. Prior to the transaction, UC-3 and UC-8 approached SAM HOWARD 

and SAM HOWARD asked to the UCs: “how many [blows or baggies of heroin]?” The 

UCs told SAM HOWARD they wanted twelve blows of heroin and SAM HOWARD 

asked GARRAWAY: “You got a pack [of heroin]?” SAM HOWARD and GARRAWAY

then sold the UCs approximately four grams of heroin from GARRAWAY’s pack of 

narcotics. 

205. As discussed above, on June 18, 2019, UC-3 and UC-10 purchased 

approximately 25 grams of heroin and fentanyl-laced heroin from FRANKLIN and 

SAM HOWARD. Prior to the narcotics transaction, SAM HOWARD approached the 

UCs and asked: “how much [narcotics] you need?” The UCs told SAM HOWARD that 

they wanted two packs of heroin and SAM HOWARD directed the UCs to go to a 

vacant lot on Monticello Avenue. Once the UCs arrived in the vacant lot, FRANKLIN 

distributed approximately 25 grams of heroin and fentanyl-laced heroin in exchange 

for $300 in government funds.

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206. On numerous occasions, FRANKLIN negotiated the cost and quantity of 

DTO narcotics with DTO customers at the Monticello Avenue Drug Spot, then 

directed those customers to street-level traffickers, like STUCKEY, to handle the 

hand-to hand exchange of money and narcotics. For example: 

a. On or about October 4, 2019, at approximately 3:12 p.m. (TP2 

Session 9176), FRANKLIN, using Target Phone 2, received a call from Individual B, 

using Individual B Phone. During the call, FRANKLIN stated: “Yo.” Individual B 

responded: “I’m a slide [come to the Monticello Avenue Drug Spot to obtain narcotics] 

in one minute.” FRANKLIN replied: “What [quantity of narcotics] you need?” 

Individual B responded: “Just one [blow or baggie of heroin].” FRANKLIN replied: 

“Alright. My homie’s [ROBERT STUCKEY] gonna get up with you.”

b. Moments later, at approximately 3:12 p.m. (TP2 Session 9177), 

FRANKLIN, using Target Phone 2, placed a call to STUCKEY (aka “Ant”), using 

STUCKEY Phone.32 During the call, FRANKLIN stated: “Hey, gray car, heavy tint, 

one time [one blow or baggie of heroin]. Finna pull up. Dude in the back [alley], he 

want one [blow or baggie of heroin]. You hit [serve] him already?” STUCKEY 

 

32 Law enforcement officials identified STUCKEY as the user of STUCKEY Phone as follows: 

on or about September 29, 2019, at approximately 2:04 p.m. (TP2 Session 8043), FRANKLIN, 

using Target Phone 2, called STUCKEY, using STUCKEY Phone. During the call, 

STUCKEY identified himself as “Ant.” Based on review of criminal history records for 

STUCKEY, law enforcement officials understand that “Ant” is STUCKEY’s nickname. In 

addition, on or about October 1, 2019, law enforcement officials conducted a controlled 

purchase of approximately 6.294 grams of heroin from SAM HOWARD, STUCKEY, and 

WARD. The controlled purchase was audio and video recorded. Law enforcement officials 

reviewed the audio and video recording from the October 1, 2019 controlled purchase and 

intercepted phone calls involving STUCKEY Phone and determined that STUCKEY was the 

user of STUCKEY Phone.

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responded: “Yeah.” FRANKLIN replied: “That green [U/I] finna pull up in the front 

though, he want one [blow or baggie of heroin].” STUCKEY responded: “Alright, bet.”

c. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) Individual B called 

FRANKLIN and asked for one blow or baggie of heroin; (b) FRANKLIN directed 

Individual B to another DTO member (STUCKEY), who would handle the narcotics 

exchange (c) FRANKLIN called STUCKEY and confirmed that STUCKEY had sold 

narcotics to Individual B in the back alley of the Monticello Avenue Drug Spot, as 

FRANKLIN had arranged; and (d) FRANKLIN directed STUCKEY to serve another 

customer with one blow or baggie of heroin in front of a residence on Monticello 

Avenue.

207. FRANKLIN negotiated the sale of 12 blows of narcotics to another 

customer on or about October 5, 2019, then directed that customer to STUCKEY to 

complete the sale. Specifically:

a. On or about October 5, 2019, at approximately 10:46 a.m. (TP2 

Session 9307), FRANKLIN, using Target Phone 2, received a call from Individual D, 

using Individual D Phone. During the call, Individual D stated: “Hey, remember 

what we talked about?” FRANKLIN replied: “Yeah.” Individual D responded: “That’s 

[the narcotics] what I want.” FRANKLIN replied: “Okay. What you got though?” 

Individual D responded: “Huh?” FRANKLIN replied: “What you got 100 [$100] or 

120 [$120]?” Individual D responded: “Yeah.” FRANKLIN replied: “100 [$100]?” 

Individual D responded: “Yup.” FRANKLIN replied: “Alright.” Individual D asked: 

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“How many [blows or baggies of heroin] can I get? How many tickets [blows or baggies 

of heroin]?” FRANKLIN replied: “You know I give out 11 [11 blows or baggies of 

heroin] tickets for 100 [$100], but I’m gonna tell him [STUCKEY] to give you 12 [12 

blows or baggies of heroin].” Individual D responded: “Alright, that’s good. I’m over 

here on . . . I’m right down the street.” FRANKLIN replied: “Okay, let me [make] a 

phone call.” Individual D responded: “Huh?” FRANKLIN said: “I said let me make 

the phone call for you. Gonna call you right back.” Individual D responded: “Alright.” 

b. Two minutes later, at approximately 10:48 a.m. (TP2 Session 

9309), FRANKLIN, using Target Phone 2, placed a call to STUCKEY, using 

STUCKEY Phone. During the call, FRANKLIN stated: “You still got [U/I]]?” 

STUCKEY responded: “Yeah.” FRANKLIN replied: “I got a P [narcotics customer] 

finna come [to Monticello Avenue]. Give him 12 [blows or baggies of heroin] for the 

100 [$100].” STUCKEY responded: “Alright.”

c. Based on my training, experience, and knowledge of the 

investigation, I believe that, in the above calls: (a) Individual D told FRANKLIN that 

he wanted to purchase $100 worth of heroin; (b) FRANKLIN told Individual D that 

$100 would typically get 11 blows or baggies of heroin, but FRANKLIN would have a 

different street-level distributor give Individual D 12 blows or baggies of heroin; (c) 

FRANKLIN told Individual D that he had to call the street-level distributor to setup 

the sale; (d) FRANKLIN then called STUCKEY and directed him to distribute 12 

blows or baggies of heroin to Individual D for $100.

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208. FRANKLIN negotiated another sale of nine baggies of narcotics to 

another customer on or about October 6, 2019, and again directed that customer to 

STUCKEY to complete the sale. Specifically:

a. On or about October 6, 2019, at approximately 1:33 p.m. (TP2 

Session 9708), FRANKLIN, using Target Phone 2, placed a call to Individual E, using 

Individual E Phone. During the call, Individual E stated: “I’m right here.” 

FRANKLIN replied: “Nah, what I was gonna say? Hey look, ‘cause something 

happened over there on the block so I need you to meet me over there [Monticello 

Avenue]. I’m sorry and I’ll give you nine [9 baggies of heroin] for your eighty [$80], 

okay?” Individual E responded: “Alright. So you want me to go back to the block 

[Monticello Avenue]?” FRANKLIN replied: “Yeah, I’mma give you nine [9 baggies of 

heroin] for your eighty [$80] for the inconvenience.”

b. Three minutes later, at approximately 1:36 p.m. (TP2 Session 

9709), FRANKLIN, using Target Phone 2, called STUCKEY, using STUCKEY Phone. 

Individual F answered the call from FRANKLIN. During the call, FRANKLIN told 

Individual F: “Tell Ant [STUCKEY] that Nissan [Individual E] finna pull up. Tell 

him [STUCKEY] to give her nine [9 baggies of heroin] for eighty [$80]. Tell him to do 

that off mine [from FRANKLIN’s personal supply of narcotics] though.” Individual F 

said [aside]: “Ant [STUCKEY]. Ant [STUCKEY]. It’s Kevo [FRANKLIN]. He said 

do it off his [supply of narcotics].” FRANKLIN replied: “Just give him [STUCKEY] 

the phone. Just give him the phone.” STUCKEY stated: “Hello.” FRANKLIN replied: 

“Go [U/I] for me. That blue Nissan [Individual E] finna pull up. Give her nine [9 

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baggies of heroin] for eighty [$80] and put the other blows [baggies] [U/I].” STUCKEY 

responded: “A’ight.” 

c. Based on my training and experience and knowledge of the 

investigation, I understand that, in the above calls: (a) Individual E told FRANKLIN 

that she was in the area to purchase narcotics from him; (b) FRANKLIN directed 

Individual E to go back to the Monticello Avenue Drug Spot to purchase the heroin; 

(c) because he was asking Individual E to go back to Monticello Avenue, he was going 

to provide her with 9 baggies of heroin for $80; and (d) FRANKLIN then called 

STUCKEY and directed him to sell Individual E nine baggies of narcotics from 

FRANKLIN’s personal supply for $80.

D. DTO Leader LEE Directs FRANKLIN to Have Street-Level Traffickers

Distribute Samples of New Batches of Narcotics to Customers to Increase 

Sales at the Monticello Avenue Drug Spot. 

209. Leaders of the Monticello DTO, like LEE, coordinated with the streetlevel bosses, like FRANKLIN, to direct street-level traffickers at the Monticello 

Avenue Drug Spot to handout samples of narcotics to customers to create demand for 

new batches of narcotics. 

210. For example, on or about October 8, 2019, at approximately 8:31 a.m. 

(TP2 Session 10037), FRANKLIN, using Target Phone 2, placed a call to Individual 

E, using Individual E Phone. During the call, Individual E stated: “I’m coming your 

way, I woke up sick as fuck [ill from heroin withdrawal].” FRANKLIN responded: 

“That’s good, that’s good. Come on ‘cause I got something [heroin] for you anyway.” 

Individual E replied: “Oh my God. Great. I’m coming straight to you.” FRANKLIN 

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responded: “Alright.” Individual E replied: “You know I never come this early.” 

FRANKLIN responded: “I know, I’m passing out [samples of heroin] anyway, that’s 

why I called.” Individual E replied: “Okay cool.”

211. On or about October 8, 2019, at approximately 8:38 a.m. (TP2 Session 

10040), FRANKLIN, using Target Phone 2, received a call from Individual G, using 

Individual G Phone. During the call, Individual G stated: “Where you at?” 

FRANKLIN responded: “I’m on Monticello and Augusta, I’m in the back. In the 

Alley.” Individual G replied: “In the Alley?” FRANKLIN responded: “Okay, cool. 

Alright.” Individual G replied: “This one [sample of heroin] is on the house [free], 

right?” FRANKLIN responded: “Yeah, man. It’s called a pass, that’s what the pass 

out is for, to give the shit [heroin] out free.” Individual G replied: “Okay, okay, I got 

you. Alright, I’m going.” FRANKLIN responded: “Alright.”

212. Two days later, on or about October 10, 2019, LEE directed FRANKLIN 

to pass out more free samples of heroin at the Monticello Avenue Drug Spot. At 

approximately 12:05 p.m. (TP2 Session 10340), FRANKLIN, using Target Phone 2, 

called LEE, using Target Phone 5. During the call, LEE asked: “You all good?” 

FRANKLIN responded: “Yeah. Knocking this shit down, little by little [selling from 

a stash of heroin].” LEE replied: “You all good, though?” FRANKLIN responded: 

“Yeah.” LEE replied: “Let everybody [Monticello DTO members] know we passing 

out [giving out samples of heroin] again Saturday at 6:00.” FRANKLIN responded: 

“Okay.” LEE replied: “A’ight.” FRANKLIN responded: “Okay.”

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E. DTO Members Monitor Police Presence at the Monticello Avenue Drug 

Spot and Alert Each Other to Avoid Detection of the DTO. 

213. Members of the Monticello DTO were aware of police presence in the 

area and alerted one another about the police in order to protect their drug 

distribution business. For example, on or about August 29, 2019, at approximately 

6:45 p.m. (TP2 Session 3095), FRANKLIN, using Target Phone 2, placed a call to 

WILL HOWARD, using WILL HOWARD Phone.33 During the call, FRANKLIN 

stated: “Yo’. Hey, Grey trans [unmarked police car] [U/I].” WILL HOWARD 

responded: “Yeah?” FRANKLIN replied: “Just turned up to the block going towards 

Thomas.” WILL HOWARD responded: “A’ight.” FRANKLIN replied: “[U/I] where it 

went. They going towards [U/I].” Later during the call, WILL HOWARD said [aside]: 

“Hey. Hey [U/I]. Hey [U/I], hey [U/I] grey trans [unmarked police car] going [U/I].” 

FRANKLIN later said: “Driving up [U/I] alley right now. The police right there [U/I]. 

Hey, I think they in traffic coming towards us [Monticello DTO members on 

Monticello Avenue]. I can’t see ‘em.”

214. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange, FRANKLIN warned WILL 

HOWARD, a Monticello DTO street-trafficker, that the police were driving around 

 

33 Law enforcement officials identified WILL HOWARD as the user of WILL HOWARD Phone 

as follows: as discussed above, on September 4, 2019, WILL HOWARD was arrested in 

connection with the possession and distribution of narcotics around the Monticello Drug Spot. 

Following the arrest, law enforcement officials was interviewed and booked. The law 

enforcement officials who participated in the arrest and interview reviewed intercepted 

phone calls involving the user of WILL HOWARD Phone and determined that WILL 

HOWARD was the user of WILL HOWARD Phone.

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the area of the Monticello DTO and WILL HOWARD warned other street-level 

traffickers at the Monticello Avenue Drug Spot. 

215. On or about September 9, 2019, at approximately 10:23 a.m. (TP2 

Session 5612), FRANKLIN, using Target Phone 2, received a call from SAM 

HOWARD, using Target Phone 3. During the call, FRANKLIN asked: “Where you 

at?” SAM HOWARD responded: “Shit, just ran to try and talk to these peoples 

[members of the Monticello DTO]. Why, what’s up?” FRANKLIN replied: “Oh. What 

I was finna say? I’m finna slide to your slot [residence], who there [Monticello 

Avenue]?” SAM HOWARD responded: “I don’t [U/I]. I think Bubba still there. I don’t 

know.” FRANKLIN replied: “Alright, well, um, I’m finna sit over here. It’s some 

foogy shit. It too foogy [large police presence] over there right. I don’t know what’s 

going on. So, I’m finna go sit at yo’ crib. I’m waiting on you. I got the count [proceeds 

from narcotics sales at the Monticello Avenue Drug Spot], too.” SAM HOWARD 

responded: “Police hot as hell?” FRANKLIN replied: “Man, I don’t know what the 

fuck going on, but today don’t seem right, and I’m not gonna stand right there 

[Monticello Avenue].”

216. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange: (a) FRANKLIN asked SAM 

HOWARD who was on Monticello Avenue and SAM HOWARD replied that he was 

not sure; (b) FRANKLIN told SAM HOWARD that there was a large police presence 

on Monticello Avenue; (c) SAM HOWARD asked if the police were active in the area 

and FRANKLIN confirmed that they were; and (d) FRANKLIN said he was not sure 

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why there were so many police in the area but that he was going to avoid Monticello 

Avenue while the police were around.

217. As part of the Monticello DTO’s operations, street bosses directed other

members of the Monticello DTO to act as lookout for police while other members of 

the Monticello DTO distributed narcotics. For example:

a. On February 19, 2019, law enforcement established surveillance

near the Monticello Avenue Drug Spot to observe undercover purchases of narcotics. 

On multiple occasions that day, law enforcement officials observed members of the 

Monticello DTO walk up and down Monticello Avenue and the surrounding blocks

looking into vehicles. Based on my training and experience, I believe that the 

Monticello DTO members were looking to vehicles to see if anyone was conducting 

surveillance of their narcotics distribution operations.

b. As discussed above, on April 19, 2019, two undercover officers

approached SAM HOWARD, GARRAWAY, and BARNES to purchase heroin. While 

the UCs purchased heroin from SAM HOWARD and GARRAWAY, SAM HOWARD 

instructed BARNES to serve as a lookout on the corner to watch out for law 

enforcement. BARNES did as SAM HOWARD instructed and SAM HOWARD did 

not move forward with the sale to the UCs until after he and GARRAWAY had 

checked-in with BARNES.

F. FRANKLIN Directs Individual C to Retrieve Firearm to Protect

Monticello Drug Spot on October 5, 2019.

218. On or about October 5, 2019, at approximately 1:24 p.m. (TP2 Session

9363), FRANKLIN, using Target Phone 2, placed a call to Individual C, using 

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Individual C Phone. During the call, FRANKLIN said: “Look, I’m gonna need you to 

do something very, very important . . . which is something I know you don’t wanna 

do, but since I’m not there, I’m gonna really need you to do this. Hello?” Individual 

C replied: “I’m listening.” FRANKLIN responded: “I need you to go under the 

mattress, put that [firearm] in a bag, take it to Ant [STUCKEY].” Individual C 

replied: “Alright.” FRANKLIN responded: “Please. And thank you.” Individual C 

replied: “Alright.” FRANKLIN responded: “And watch how you handle it [the 

firearm], ‘cause it’s loaded and there’s one [round] in the head [chamber] already. Or 

you could just go get him [STUCKEY] and bring him back there, and he grab it [the 

firearm]. Hello? Hello?”

219. Based on my training and experience and knowledge of the

investigation, I understand that in the above exchange, FRANKLIN instructed 

Individual C to retrieve a loaded firearm from under a mattress and deliver it to 

STUCKEY.

220. On or about October 5, 2019, at approximately 1:27 p.m. (TP2 Session

9365), FRANKLIN, using Target Phone 2, placed a call to STUCKEY, using 

STUCKEY Phone. During the call: 

a. FRANKLIN stated: “What you doing? Hey, something [the

firearm] finna get dropped off to you. You know when I told you, like man, [U/I] under 

the van, go towards the front of it and you’ll find that [the firearm] right there.” 

STUCKEY replied: “[U/I].” FRANKLIN responded: “That’s [the firearm] gonna get 

dropped off to you. Look, even worry about. Look, the green and black thing [the 

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firearm] finna get dropped off to you in like . . . a good, like 30 minutes.” STUCKEY 

replied: “Okay.” 

b. FRANKLIN stated: “You know what I’m saying? I’m gonna call

you . . . .” STUCKEY replied: “Ah-ha.” FRANKLIN responded: “And gonna you . . . 

I’m gonna call you when Blood [another Monticello DTO member] when they’re ready 

for it [the firearm], they gonna have it [the firearm]. You feel me? I just . . . you know 

where I slide my shit [firearms] at, under there [the van]?” STUCKEY replied: 

“Right.” FRANKLIN responded: “That’s where you [U/I] that is. With the . . . under 

. . . .” STUCKEY replied: “Alright.” FRANKLIN stated: “On top of the hook thing, so 

it [the firearm] won’t fall down.” STUCKEY replied: “Alright.” 

c. FRANKLIN stated: “Alright. And I’m just gonna call him [Blood]

and let him know that you got it [the firearm] already. But she [Individual C] should 

be on her way with it [the firearm].” STUCKEY replied: “Okay.” FRANKLIN 

responded: “She [Individual C] gonna pull up in the back.” STUCKEY replied: 

“Okay.”

221. Based on my training and experience and knowledge of the

investigation, I understand that in the above exchange: (a) FRANKLIN told 

STUCKEY that Individual C was going to deliver a firearm to him by attaching it to 

a hook under a van on Monticello Avenue; and (b) at some point, FRANKLIN was 

going to contact STUCKEY and have STUCKEY deliver the firearm to another 

Monticello DTO member (Blood).

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222. At approximately 3:15 p.m., law enforcement observed Individual C

driving a black Buick SUV on West Thomas Street and conducted a traffic stop for a 

broken tail light and failure to make a complete stop at a stop sign. During the stop, 

Individual C informed officers that she had a loaded handgun inside of her bag 

located on the front passenger seat of the vehicle. Officers then seized a Sig Sauer 

9mm handgun, serial number 47A130064. A photograph of the firearms is depicted 

below: 

223. Based on my training and experience and knowledge of the

investigation, I believe that FRANKLIN requested that Individual C retrieve a 

firearm and provide it to Monticello DTO members (STUCKEY and Blood) in order 

to protect the Monticello Avenue Drug Spot, including the narcotics and narcotics 

proceeds in the area.

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G. LEE Directs FRANKLIN to Have DTO’s Street-Level Traffickers Selling

Heroin at the Monticello Avenue Drug Spot in the Early Morning Hours

and Discusses Hiring Additional Traffickers to Work that Early Shift.

224. On or about October 7, 2019, at approximately 2:26 p.m. (TP2 Session

9930), FRANKLIN, using Target Phone 2, received a call from LEE, using Target 

Phone 5. During the call, LEE asked: “You out of that brown [heroin]?” FRANKLIN 

responded: “Uh, skoo? Yeah.” LEE replied: “Let every motherfuckers [Monticello 

DTO members] know that start at 7:00 [a.m.].” FRANKLIN responded: “Okay.” LEE 

replied: “Let our latinos and shit know.” FRANKLIN responded: “I already know.” 

LEE replied: “Alright.” FRANKLIN responded: “I got you. I’m [U/I] doing right now.”

225. Based on my training and experience and knowledge of the

investigation, I understand that in the above exchange, LEE asked FRANKLIN if the 

Monticello DTO ran out of heroin to distribute on Monticello Avenue and FRANKLIN 

said that they had and LEE told FRANKLIN to make sure Monticello DTO streetlevel traffickers are out on the block selling by 7:00 a.m.

226. On or about October 8, 2019, between approximately 11:50 a.m. and

11:58 a.m. (TP2 Session 10072 through 10080), FRANKLIN, using Target Phone 2, 

exchanged a series of text messages with LEE, using Target Phone 5. During that 

exchange: 

a. LEE stated: “Find sum body 2 work each corner [of Monticello

Avenue] 60 [$60] a day again start time at 6 am.” FRANKLIN replied: “Ok bet.” 

FRANKLIN asked: “Wen [when] it starts?” LEE responded: “They can still start 

2day.” LEE further stated: “But they gotta b on it.” FRANKLIN replied: “Ok bt they 

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can’t go no where.” LEE responded: “An let me know when they posted [selling 

narcotics at the Monticello Avenue Drug Spot].” FRANKLIN replied: “Ok.” 

FRANKLIN further stated: “Well I got one on Augusta rn [right now].” LEE 

responded: “Ok.”

227. Based on my training and experience and knowledge of the

investigation, I understand that in the above exchange, LEE told FRANKLIN to find 

additional street-level traffickers for the Monticello DTO to sell heroin on Monticello 

Avenue for $60 a day.

228. On or about October 9, 2019, at between approximately 6:17 p.m. and

6:48 p.m. (TP2 Session 10160 through 10182), FRANKLIN, using Target Phone 2, 

exchanged a series of text messages with LEE, using Target Phone 5. During that 

exchange: 

a. LEE wrote: “Bet ok that’s what’s up lil bro we need to try an get

us sum workers [street-level traffickers] to cum out at 5 [5:00 a.m.] until u make it 

out I’ll stand on them if I got 2 untile [until] u make it out cuz.” LEE further stated: 

“we need that am [morning ] traffic foreal [for real].” FRANKLIN replied: “Now tht 

ik [I know] fa a fact is true.” LEE responded: “I’ll pay 50 [$50] off the pack frum 5 2 

7 [5 a.m. to 7 a.m.] or untile [until] u make it around.” LEE further stated: “30$ for 

S frum 5 2 730 an 50 [$50] off the pac frum 5 2 730 [5:00 a.m. to 7:30 a.m.] every am

[morning].” FRANKLIN replied: “I'll definitely find me somebody.” 

b. LEE responded: “We don’t b having no workers C i didn’t know

that an we paying 40 [$40] y is that we should have all type of workers.” LEE further 

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stated: “What ever u gotta do to get workers get them an what ever it take to get them 

2 cum out early um gone halla bro when he cum out cuz this a real life job for me.” 

LEE further stated: “I jus wanna c all my ppl get money we cum out early like all my 

other ppl do pees will b coming none stop cuz I’m gone keep it good [the quality of the 

heroin will be high].” LEE further stated: “But how u looking [how much heroin do 

you have left].” FRANKLIN replied: “A bit low [low supply of heroin].” FRANKLIN 

further stated: “Bt I’m on my way ova there.” LEE responded: “Ok.” LEE further 

stated: “Call Sam [SAM HOWARD] tell him call me.” FRANKLIN replied: “Ok.”

229. Based on my training and experience and knowledge of the

investigation, I understand that in the above exchange: (a) LEE told FRANKLIN to 

find a street-level traffickers to sell heroin on Monticello Avenue from 5 a.m. until 7 

a.m. or 7:30 a.m. and that trafficker would earn $50 off of every pack of heroin sold;

(b) FRANKLIN agreed and said that he will find an additional street-level trafficker

to work Monticello Avenue those hours; (c) LEE complained that the Monticello DTO 

does not have enough workers willing to work early hours and that trafficking heroin 

is a business to him; (d) LEE told FRANKLIN that, if they can find a street-level 

trafficker, business will be good because he will continue to supply high-quality 

heroin to the Monticello DTO; (e) LEE asked FRANKLIN if the Monticello DTO had 

enough heroin to sell on Monticello Avenue and FRANKLIN said that supply was 

low; and (f) LEE agreed to re-supply the Monticello DTO and told FRANKLIN to have 

SAM HOWARD call him.

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H. LEE Monitors the Narcotics Supply and Street-Level Traffickers at the

Monticello Avenue Drug Spot in October 2019.

230. On or about October 11, 2019, between approximately 7:06 a.m. and 7:10

a.m. (TP2 Sessions 10447 to 10451), FRANKLIN, using Target Phone 2, exchanged a

series of text messages with LEE, using Target Phone 5. During that exchange, LEE 

asked: “Y’all [Monticello DTO] out [of narcotics or street-level narcotics traffickers], 

lil bro.” FRANKLIN replied: “Yea.” LEE responded: “Bet, told bro um gone try an 

find a frew [few] workers [narcotics distributors to work on Monticello Avenue] to 

help y’all out if I can u Sam [SAM HOWARD] ain’t made [make] it out.” FRANKLIN 

replied: “Yea.”

231. Based on my training and experience and knowledge of the

investigation, I believe that in the above exchange: (a) LEE asked FRANKLIN if the 

Monticello DTO was out of narcotics or street-level dealers at the Monticello Avenue 

Drug Spot and FRANKLIN replied that they were; and (b) LEE said that he would 

re-supply the Monticello DTO with narcotics and/or offered additional street-level 

dealers to sell narcotics on Monticello Avenue.

232. On October 11, 2019, at approximately 6:10 p.m. (TP2 Session 10543),

FRANKLIN, using Target Phone 2, received a call from LEE, using Target Phone 5. 

During the call, LEE asked: “You good?” FRANKLIN replied: “Yeah, I’m good. Slow 

motion on this cold ass day.” LEE responded: “Okay, just making sure. Just checking 

on you.”

233. Based on my training and experience and knowledge of the

investigation, I believe that in the above exchange LEE asked FRANKLIN if 

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FRANKLIN and the Monticello DTO members needed additional narcotics and 

FRANKLIN responded that they did not because business (selling narcotics) was slow 

on account of the weather.

234. On or about October 15, 2019, between approximately 8:24 p.m. and 8:29

p.m. (TP2 Sessions 10957 to 10959), FRANKLIN, using Target Phone 2, exchanged

several text messages with LEE, using Target Phone 5. During that exchange, LEE 

asked FRANKLIN: “How u looking lil bro.” FRANKLIN replied: “Getting low.” LEE 

responded: “Ok.”

235. Based on my training and experience and knowledge of the

investigation, I believe that in the above exchange: (a) LEE asked FRANKLIN about 

the Monticello DTO’s supply of narcotics; and (b) FRANKLIN informed LEE that the 

Monticello DTO was running low on narcotics; and (c) LEE agreed to supply 

additional narcotics to the Monticello DTO.

VI. BETWEEN FEBRUARY 2019 AND NOVEMBER 2019, THE

MONTICELLO DTO DISTRIBUTED AT LEAST 12.6 KILOGRAMS OF

HEROIN, 16.2 KILOGRAMS OF FENTANYL-LACED HEROIN, 7.4

KILOGRAMS OF FENTANYL-ANALOGUE LACED HEROIN, AND 2.56

KILOGRAMS OF FENTANYL-ANALOGUE AND FENTANYL-LACED

HEROIN AT THE MONTICELLO AVENUE DRUG SPOT

236. Based on the quantity of narcotics purchased by undercover officers

throughout the course of the investigation, intercepted phone calls reflecting 

thousands of dollars of narcotics proceeds generated on a daily basis during the course 

of the interception periods alone, surveillance, and CPD Pod camera video reflecting 

street-level traffickers on Monticello Avenue transacting business, I believe that, 

between February 2019 and November 2019, members of the Monticello DTO 

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possessed with intent to distribute and distributed in excess of 12.6 kilograms of 

heroin, 16.2 kilograms of fentanyl-laced heroin, 7.4 kilograms of fentanyl-analogue 

laced heroin, and 2.56 kilograms of fentanyl-analogue and fentanyl-laced heroin. 

237. Between February 19, 2019 and October 2019, undercover officers

conducted approximately eighty controlled purchases of heroin, fentanyl-laced 

heroin, and fentanyl-analogue laced heroin from various members of the Monticello 

DTO at the Monticello Avenue Drug Spot. In total, over the course of these eighty 

controlled purchases, undercover officers purchased:

• approximately 182.315 grams of heroin;

• approximately 243.522 grams of heroin laced with fentanyl;

• approximately 112.859 grams of heroin laced with a fentanyl analogue;

and

• approximately 39.954 grams of heroin laced with fentanyl and a

fentanyl analogue.

238. Based on the investigation, including the approximately eighty

undercover purchases, surveillance of the Monticello Avenue Drug Spot, review of 

CPD Pole Camera video, and intercepted phone calls and text messages, law 

enforcement officials understand that: 

a. The Monticello DTO obtained and distributed heroin, usually

laced with fentanyl or a fentanyl analogue, to customers on Monticello Avenue and 

in the surrounding area in 0.2 gram user-quantities wrapped in tin-foil or baggies. 

Customers typically purchased around a “pack” or “jab” which contained twelve or 

thirteen “blows” or “baggies” (approximately 2.5 grams of heroin and/or heroin-laced 

fentanyl) for approximately $120, with the street-level traffickers earning $20 as 

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profit, and the remainder of the proceeds directed to the street-level bosses (SAM 

HOWARD and KELVIN FRANKLIN) who would then provide a portion to the DTO 

leaders (WILLIE TATE, MORRIO BONDS, and ANTONIO LEE) who were 

responsible for obtaining the narcotics from the DTO’s source of supply. 

b. The Monticello DTO distributed approximately $7,200 worth of

narcotics (heroin, fentanyl-laced heroin, fentanyl-analogue laced heroin, or heroin 

laced with both fentanyl and fentanyl-analogue) at the Monticello Avenue Drug Spot 

per day and typically operated the Monticello DTO seven days per week from the 

hours of 5:30 a.m. through midnight. Based on intercepted phone calls and 

statements made by DYER, both discussed below, the 80 undercover purchases of 

narcotics, and surveillance and pole camera video, law enforcement officials believe 

that Monticello DTO members provided street-level dealers with approximately three

bundles of narcotics in the morning and three bundles of narcotics in the afternoon. 

Because each bundle contained ten jabs and each jab had twelve baggies or tin foils, 

each bundle contained approximately 120 baggies/tin foils of narcotics. In 

distributing six bundles per day, the Monticello DTO sold approximately 720 

baggies/tin foils, which each contained approximately 0.2 grams of narcotics. 

Accordingly, I believe the Monticello DTO distributed at least 144 grams of narcotics

per day. 

c. Throughout the 60-day interception of Target Phone 2,

FRANKLIN was intercepted discussing drug transactions over the phone. Based on 

a review of intercepted calls of Target Phone 2 between around August 14, 2019 and 

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October 18, 2019, an approximately 60-day period, FRANKLIN alone discussed the 

distribution of approximately 2,933 baggies of narcotics (approximately 586.6 grams

or 293.3 grams of narcotics per month).34 

d. During the interception of Target Phone 2, law enforcement 

officials also intercepted numerous calls regarding narcotics proceeds. Based on a 

review of intercepted calls involving Target Phone 2 between around August 14, 2019 

and October 18, 2019, FRANKLIN alone discussed exchanging approximately 

$12,621 for heroin.35

239. As discussed above, on August 19, 2019, DYER met with and sold 

narcotics to an undercover agent. During that recorded conversation, DYER stated, 

“[I] normally get 7 [packs of heroin] in the morning, I’ve been already run through 

them [the seven packs of heroin] by the afternoon and then get my next shit [a new 

supply of heroin] for the night time so I usually run through it [the heroin] . . . .” 

240. Based on my training and experience and knowledge of the 

investigation, I understand that in the above exchange DYER told the undercover 

agent that he distributed approximately seven packs of narcotics (a total of 84 blows 

and approximately 17.5 grams of narcotics) per morning and was then re-supplied 

with narcotics in the afternoon and that he would distribute all of the afternoon 

 

34 In numerous intercepted calls, FRANKLIN discussed the sale of narcotics with customers 

and members of the Monticello DTO, but did not reference specific quantities or units of 

narcotics. The analysis above does not include those calls. 

35 As discussed above, in numerous intercepted calls, FRANKLIN discussed narcotics 

proceeds with customers and members of the Monticello DTO, but did not reference specific 

dollar amounts. The analysis above does not include those calls.

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supply of narcotics as well. Accordingly, based on his own estimates, DYER alone 

was responsible for distributing at least 30 grams of heroin at the Monticello Drug 

Spot per day.

241. Moreover, as discussed above, in the approximately 80 undercover

purchases between February 2019 and October 2019, LEOs obtained a total of 

approximately 585.149 grams of narcotics, which consisted of approximately 188.9 

grams of heroin (32.6% of total narcotics), approximately 244.39 grams of fentanyllaced heroin (41.7% of total narcotics), approximately 112.859 grams of fentanylanalogue laced heroin (19.3% of total narcotics), and approximately 39 grams of

heroin laced with fentanyl and a fentanyl-analogue (6.6% of total narcotics). 

242. While the volume of narcotics trafficked on a given day varied based on,

among other things, the number of workers at the Monticello Avenue Drug Spot, the 

weather, the presence of law enforcement, the size of customer orders, or the volume 

of customers present at the Monticello Avenue Drug Spot, based upon the foregoing, 

I believe that, on average, the Monticello DTO was selling at least 144 grams of 

narcotics per day over the course of approximately 282 days (between February 19, 

2019, and November 26, 2019). Based on the percentages of drug types purchased 

over the course of approximately 80 controlled buys made over an extended period of 

time, I believe that between February 2019 and November 2019, members of the 

Monticello DTO possessed with intent to distribute and distributed 12.6 kilograms of 

heroin, 16.2 kilograms of fentanyl-laced heroin, 7.4 kilograms of fentanyl-analogue 

laced heroin, and 2.56 kilograms of fentanyl-analogue and fentanyl-laced heroin.

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Conclusion 

243. Based on the above, I respectfully submit that there is probable cause to

believe that from no later than in or about February 2019 and continuing to in or 

about November 2019, SAM HOWARD, WILLIE TATE, also known as “Junebug,” 

KELVIN FRANKLIN, also known as “Kevo” or “Nico,” STEVEN DYER, MORRIO 

BONDS, ANTONIO LEE, BRYANT BARNES, DWAYNE PETERSON, ANTHONY 

DAVIS, FLOYD STEWART, WILL HOWARD, JEREMY HAMPTON, JOHNNIE 

DANIELS, TORIAN JOHNSON, JAMES HUGHES, KAMRON GARRAWAY, 

SAVAN WARD, and ROBERT STUCKEY, also known as “Ant,” did conspire with 

each other, and with others known and unknown to knowingly and intentionally 

possess with intent to distribute and distribute a controlled substance, namely, 400 

grams or more of a mixture and substance containing a detectable amount of fentanyl 

(N-phenyl-N-[1-(2-phenylethyl)-4-piperindinyl] propanamide), a Schedule II 

Controlled Substance, one kilogram or more of a mixture and substance containing a 

detectable amount of heroin, a Schedule I Controlled Substance, and a quantity of a 

mixture and substance containing a detectable amount of acetyl fentanyl, valeryl 

fentanyl, and furanyl fentanyl, Schedule I Controlled Substances and analogues of 

fentanyl (N-phenyl-N-[1-(2-phenylethyl)-4-piperidinyl] propanamide), a Schedule II 

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Controlled Substance, in violation of Title 21, United States Code, Section 841(a)(1), 

all in violation of Title 21, United States Code, Section 846.

FURTHER AFFIANT SAYETH NOT.

JAMES J. LEE

Special Agent, Drug Enforcement 

Administration

SUBSCRIBED AND SWORN to before me on July 14, 2020.

HEATHER K. MCSHAIN

United States Magistrate Judge

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