Adekunle Adetokunbo Complaint

8/3/2019 Adekunle Adetokunbo Complaint

1/4

IN THE U N IT E D S TA T ES D IS TR IC T C OU RT F O

E A ST E RN D IS TR IC T OF VIRGINIA

Alexandria Div is ion

UNITED S TATES OF AMERICA

v.

LJAM 6 2012

CLERK, U.S. DISTRICT COURiALEXANDRIA. VIRGf.MiA

Case No. l:12mj 13A D EK U NL E T IT US ADETOKUNBO

Defendant .

A F F I D A V I T IN S U P P O R T O F C R I M I N A L C O M P L A I N T A N D A R R E S T W A R R A N T

I, Stephen Schneider, being duly sworn, depose and state as follows:I n t r o d u c t i o n

1. I am a Special Agent of the United States Department of Homeland Security,Homeland Security Investigations (HSI). I am assigned to the Washington Dulles InternationalAirport. My duties as a Special Agent with HSI include, but are not limited to, the investigationof federal laws governing the importation and exportation of controlled substances. I havereceived training in general law enforcement, including training in Title 21 of the United StatesCode. I am a graduate of the Federal Law Enforcement Training Center at Glynco, Georgia.

2. I am an "investigative or law enforcement officer" of the United States within themeaning of Title 18, United States Code, Section 2510(7), that is, an officer of the United Stateswho is empowered by law to conduct investigations of and to make arrests for offensesenumerated in Tit le 18, United States Code, Section 2516(1).

3. This affidavit is submitted in support of a criminal complaint charging that on orabout January 5, 2012, in Loudoun County, Virginia, within the Eastern District of Virginia,ADEKUNLE TITUS ADETOKUNBO knowingly or intentionally imported or attempted to

1

Case 1:12-mj-00013-IDD Document 2 Filed 01/06/12 Page 1 of 4 PageID# 2


2/4

import into the customs territory of the United States from any place outside thereof, orattempted to import into the United States from any place outside thereof, 100 grams or more ofa mixture or substance containing a detectable amount of heroin, a Schedule I controlledsubstance, in violation of 21 U.S.C. 952 & 963.

4. The facts set forth in this affidavit are based on my personal knowledge andreview of records, documents, and other physical evidence obtained during this investigation, aswell as information conveyed to me by other law enforcement officials.

5. This affidavit does not include each and every fact observed by me or known to

the government. I have set forth only those facts necessary to support a finding of probablecause.

P r o b a b le C a u s e

6. On or about January 5, 2012, ADETOKUNBO arrived at Dulles InternationalAirport, in Loudoun County, Virginia, within the Eastern District of Virginia, on a flight fromGhana.

7. Officers with Customs and Border Protection ("CBP") referred ADETOKUNBOto a secondary inspection area. ADETOKUNBO told CBP officers in a rambling statement thathe intended to visit the Washington, D.C. area for the purpose of purchasing computers, clothingand vehicles for his company.

8. ADETOKUNBO was asked by CBP Officers where he intended to stay. Hereplied that he was going to take a cab to an inexpensive hotel, indicating that he had not yetse lec ted the actual dest inat ion.



3/4

9. ADETOKUNBO stated that the address he provided on his customs declarationwas not his intended destination, and acknowledged that he knew he should have provided anaccurate address on th e form.

10. While one CBP Officer palpitated the abdominal region of ADETOKUNBO,another CBP Officer observed ADETOKUNBO react to the palpitation by flinching.

11. A search ofADETOKUNBO luggage by CBP Officers revealed a ja r ofVaseline.I know from my training and experience that internal drug smugglers use Vaseline and othersimilar substances to aid in expelling pellets previously ingested.

12. CBP officers transported ADETOKUNBO's to the hospital for an x-ray. At theReston Hospital Center within the Eastern District of Virginia, ADETOKUNBO's x-raysindicated the presence of foreign bodies in his abdomen. CBP officers then observedADETOKUNBO expel pellets from his rectum. CBP officers field-tested the contents of one ofthe expelled pellets, which tested positive for the presence of heroin. ADETOKUNBO hadexpelled pellets with a gross weight of approximately 446 grams at the time this affidavit wasprepared.

C o n c l u s i o n

13. Based upon the above information and my training and experience, I submit thatthere is probablecause to believe that on or about January 5, 2012, in Loudoun County, Virginia,within the Eastern District of Virginia, ADEKUNLE TITUS ADETOKUNBO knowingly orintentionally importedor attempted to import into the customs territory of the United States fromany place outside thereof, or attempted to import into the United States from any place outsidethereof, 100 grams or more of a mixture or substance containing a detectable amount of heroin, aSchedule I controlled substance, in violation of 21 U.S.C. 952 & 963.



4/4

Stephen Schneider, Special AgentU.S. Department of Homeland Security

Sworn to and subscribed before me this 6th day of January, 2012.

M .( i/ft^-?Theresa Carroll BuchananUnited States Magistrate JudgeAlexandria, Virginia


Adekunle Adetokunbo Complaint

Documents

Transcript of Adekunle Adetokunbo Complaint