Affidavit of Drug Bust in Southeastern Mass.

Complaint Affidavit
I, Kevin C. Hersey, a Special Agent with the Drug Enforcement Administration being
duly sworn, state:
1. As a result of being a Special Agent, I am an investigative or law enforcement officer of the
United States within the meaning of Section 2510(7) of Title 18 of the United States Code,
in that I am empowered by law to conduct investigations of, and to make arrests for, offenses
enumerated in Title 18, United States Code, Section 2516.
2. I am a Special Agent with the United States Department of Justice, Drug Enforcement
Administration (DEA). I have served in this capacity for over 20 years and have been
assigned to the New England Field Division for the past 12 years. Prior to my current
assignment, I was assigned to the New York Field Division. My primary duties as a DEA
Special Agent include the investigation of organized narcotics traffickers. I have received
training in the field of narcotics enforcement and investigations including, but not limited
to, training regarding the identification of common street drugs such as cocaine and heroin.
During my tenure as a DEA Special Agent, I have worked on hundreds of drug
investigations. Many of these investigations involved the organized domestic and
international importation and distribution of kilogram quantities of cocaine and heroin. I
have participated in approximately 10 investigations that involved the use of court-ordered
eavesdropping, including being the Affiant for a large scale investigation that occurred in
2008. Through my training, education, and experience, I have also become familiar with the
manner in which illegal drugs are transported, stored, and distributed, and with the methods
of payment for such drugs.
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3. I have written and/or participated in the execution of numerous search warrants resulting in
the seizures of large quantities of controlled substances; packing implements and other
paraphernalia involved in the manufacture and distribution of controlled substances; large
amounts of United States currency, ledger books, bank records, telephone books, receipts,
drug customer lists and other documents relating to the manufacturing, transportation,
ordering, purchasing and distribution of controlled substances. I have participated in the
debriefing of dozens of defendants, informants and witnesses who had personal knowledge
regarding large-scale narcotics trafficking organizations. I have participated in all aspects
of drug investigations including conducting surveillance, executing searches pursuant to
court-ordered search warrants and executing arrests. As a result of my assignments, I have
received extensive specialized training in the field of narcotics identification, investigation
and enforcement.
4. Based upon my training and experience, I am familiar with the methods of operation
employed by narcotics traffickers operating at the local, statewide, national and international
levels, including those involving the distribution, storage and transportation of narcotics and
the collection of monies that constitute the proceeds of narcotics trafficking activities. I am
aware that drug traffickers commonly use cellular telephones in furtherance of their drug
trafficking activities and frequently change cellular telephone numbers and cellular
telephones in an effort to thwart law enforcement’s use of electronic surveillance. I am also
aware that narcotics traffickers speak in vague, guarded or coded language when discussing
their illegal activities, and employ a variety of counter-surveillance techniques in order to
detect if their vehicles are being followed by members of law enforcement.
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5. My extensive narcotics training has familiarized me with the general characteristics of
cocaine and heroin distribution “cells.” A distribution cell consists of 2 or more individuals
who work in concert for the sole purpose of the distribution of large amounts of narcotics.
Distribution cells are highly organized and disciplined, with a clear chain of command and
control. Distribution cells consist of workers, supervisors, and managers. They are
extremely surveillance conscious and have a good understanding of methods used by law
enforcement agencies to investigate their activities. It has been my experience that
distribution cells are often also instructed in how to best thwart law enforcement efforts to
obtain Title III interceptions by limiting the use of cell-phones to 2 to 3 months, using
pre-paid non-registered cell phones which they exchange or pool within the group, or
cellular phones registered to an alias or business. Distribution cell groups also employ
aggressive counter surveillance tactics. Distribution cell groups are often supplied on a
consignment basis by larger importation groups, with a strict timetable for payment.
Distribution cell groups often network with other distribution cells in order to maintain a
constant supply of the distributed drug. Distribution cell groups often maintain locations
other than their primary residences to be used as secure points of distribution or storage of
money and/or drugs.
6. I have personally participated in the investigation of the subjects named in this Affidavit
since December, 2009. I am familiar with the facts and circumstances of this investigation
from oral and written reports made to me by other Agents of the DEA, other federal, state
and local law enforcement agencies and a review of summaries of wiretap interceptions and
the underlying recordings.
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7. Based on my training and experience, I am aware that it is a violation of Title 21, United
States Code, Section 846 for individuals to conspire to distribute and to distribute heroin.
I submit this affidavit in support of an application for a criminal complaint charging that
from on or about June, 2010, until on or about November, 2010, the following defendants,
1) Tiffany Marie ANDRADE; 2) Claudio ARAUJO a/k/a “Lenny” a/k/a UM9889; 3)
Alessio BARBOSA a/k/a “Alexio”, a/k/a “Alex”, a/k/a “A” a/k/a “Ace”; 4) Dany L.
BRANDAO a/k/a UM6122; 5) Nicholas DEANGELIS a/k/a UM1027; 6) Emanuel
DOCANTO a/k/a “Mandog” a/k/a UM4026; 7) Miguel A. FERNANDES a/k/a “Miguel”;
8) Ismael FIGUEROA; 9) Ivan FONSECA a/k/a UM3507; 10) Iury Jandir GOMES a/k/a
“Utes”; 11) Alector GONCALVES a/k/a “JG”; 12) Tamara HOLLIS; 13) Carey
MONTEIRO a/k/a UF6102 a/k/a UF1163; 14) Elsio MONTEIRO a/k/a UM3005; 15)
Robert PARSONS a/k/a UM8385; 16) Emanuel RIBEIRO a/k/a UM9458; 17) Jose G.
ROSA a/k/a “Jose” a/k/a “J” a/k/a “Big Poppa”; 18) Virgilio ROSA a/k/a “Turbo”; 19) Nine
SILVEIRA; 20) Gregory STUBBS; 21) Timothy T. TAMULEVICH, a/k/a “Tiny”; 22)
Justin A TEIXEIRA a/k/a “Becky”; 23) Carla VICENTE a/k/a UF2296; and 24), Catherine
WATTS a/k/a “Kate”, did conspire to possess with intent to distribute and to distribute, in
excess of one kilogram of heroin, in violation of Title 21, United States Code, Sections 846
and 841(b)(1)(A).
8. Since this Affidavit is being submitted for the limited purpose of establishing probable
cause, I have not included each and every fact known to me concerning this investigation.
I have set forth only the facts that I believe are necessary to establish the necessary
foundation the pending charges.
OVERVIEW OF INVESTIGATION
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9. This affidavit is based on an investigation which originated in approximately December,
2009. This investigation has used information from numerous confidential sources, physical
surveillance, and court-authorized interception of wire communications. On May 26, 2010,
July 1, 2010, August 4, 2010, September 7, 2010, October 7, 2010, and November 1, 2010,
the Honorable Richard G. Stearns, United States District Judge, in the District of
Massachusetts, authorized the interception of various telephones being used by members of
the targeted narcotics trafficking organization. In total, ten (10) telephones were intercepted,
including cellular telephones of Jose ROSA (target telephone # 1), Carey MONTEIRO
(target telephone # 3), Dany BRANDAO (target telephone # 5), Iury GOMES (target
telephone # 8), Miguel FERNANDES (target telephone # 6), Justin TEIXEIRA (target
telephone # 9), and Carla VICENTE (target telephone # 10).
10. During the course of the investigation, information was gathered which indicated that the
charged defendants were members of a large heroin distribution organization, which was
distributing significant quantities of heroin in and around Brockton, Massachusetts. The
investigation revealed that Miguel FERNANDES, Jose ROSA, Iury GOMES, and Justin
TEIXEIRA were each large scale heroin distributors, who had numerous heroin sources of
supply, criminal associates, and heroin customers. For purposes of organization in this
criminal complaint affidavit, I have divided the facts into four sections, the first relates to
Miguel FERNANDES and his criminal associates, the second relates to Jose ROSA and his
criminal associates, the third relates to Iury GOMES and his criminal associates, and the
fourth section relates to Justin TEIXEIRA and his criminal associates. As evidenced
throughout this Affidavit, there is significant overlap of defendants and criminal activity
between the four sections, which is why this matter is being charged as a single conspiracy.
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11. During the course of the investigation, significant information was gathered regarding the
criminal activities of Miguel FERNANDES and his criminal associates. On September 7,
2010, October 7, 2010, and November 1, 2010, the Honorable Richard G. Stearns authorized
the interception of target telephone # 6, used by Miguel FERNANDES. Previous to those
interceptions, Miguel FERNANDES was also intercepted on target telephone # 1, used by
Jose ROSA. Between June, 2010 and November, 2010, ROSA used target telephone # 1
to receive and distribute large quantities of heroin, totaling in excess of one kilogram of
heroin. During the course of the interceptions in this investigation, we learned that
FERNANDES is a large scale heroin distributor, who receives larger quantities of heroin for
distribution from Carla VICENTE; that FERNANDES has a criminal associate named
Emanuel DOCANTO, who facilitates the receipt and distribution of heroin; a criminal
associate named Tamara HOLLIS, who is associated with FERNANDES and who delivered
six fingers of heroin to Virgilio ROSA on behalf of FERNANDES on October 28, 2010; that
FERNANDES has a criminal associate named Magnuson MARTINS, who stores heroin and
narcotics proceeds for FERNANDES; and that FERNANDES has numerous larger scale
heroin customers, including Alessio BARBOSA, Nicholas DEANGELIS, Iury GOMES,
Alector GONCALVES, Virgilio ROSA, and Jose ROSA. During the course of this
investigation heroin was seized directly from FERNANDES on October 7, 2010; from
FERNANDES’s heroin customer, Nicholas DEANGELIS, on September 29, 2010; and from
FERNANDES’ heroin customer, Virgilio ROSA, on October 28, 2010.
12. During the course of the investigation, significant information was also gathered regarding
the criminal activities of Jose ROSA and his associates. On May 26, 2010, July 1, 2010,
August 4, 2010, September 7, 2010 and November 1, 2010, 2010, the Honorable Richard G.
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Stearns, United States District Judge, in the District of Massachusetts, authorized the
interception of telephone number (774) 259-9786 – target telephone # 1, used by ROSA.
ROSA was also intercepted on target telephone # 3, used by MONTEIRO, target telephone
# 5, used by BRANDAO, target telephone # 6, used by FERNANDES, target telephone #
8, used by GOMES, and target telephone # 9, used by TEIXEIRA. Between June, 2010 and
November, 2010, ROSA used target telephone # 1 to receive and distribute large quantities
of heroin, totaling in excess of one kilogram of heroin. During the course of the
interceptions, we learned that ROSA had numerous heroin sources of supply, including
Miguel FERNANDES, Ismael FIGUEROA, Carey MONTEIRO, Virgilio ROSA, Justin
TEIXEIRA, and Catherine WATTS. The interceptions further revealed that ROSA had
several criminal associates who packaged and distributed heroin on behalf of ROSA and
independently, including Tiffany Marie ANDRADE, Claudio ARAUJO, Alessio
BARBOSA, Dany BRANDAO, Alector GONCALVES, Nine SILVEIRA, and Gregory
STUBBS. Interceptions also revealed that ROSA had heroin customers, who received
quantities of heroin which indicated that said persons were redistributing the heroin to
additional unknown persons, including Robert PARSONS, and Tim TAMULEVICH.
During the course of this investigation heroin was seized from Tim TAMULEVICH, who
is a heroin customer of ROSA and who had just received heroin from ROSA.
criminal activities of Iury GOMES and his criminal associates. On August 4, 2010, the
Honorable Richard G. Stearns authorized the interception of target telephone # 8, used by
Iury GOMES. GOMES was also intercepted on target telephone # 1, used by Jose ROSA
and target telephone # 6, used by FERNANDES. Between June, 2010 and November,
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2010, GOMES received and distributed large quantities of heroin, totaling in excess of one
kilogram of heroin. During the course of the interceptions in this investigation, we learned
that GOMES is a large scale heroin distributor, who receives large quantities of heroin for
distribution from FERNANDES and ROSA; that GOMES has had several criminal
associates named Ivan FONSECA, Elsio MONTEIRO, and Emanuel RIBEIRO, who
receive, process, and distribute heroin on behalf of GOMES; and that GOMES has heroin
customers, including Claudio ARAUJO. During the course of this investigation, heroin was
seized from Ivan FONSECA, a criminal associate of GOMES, on August 10, 2010.
criminal activities of Justin TEIXEIRA and his criminal associates. On October 7, 2010 and
November 1, 2010, the Honorable Richard G. Stearns authorized the interception of target
telephone # 9, used by TEIXEIRA. Previous to those interceptions, TEIXEIRA was also
intercepted on target telephone # 1, used by Jose ROSA. Between June, 2010 and
November, 2010, TEIXEIRA used target telephone # 9 to receive and distribute large
quantities of heroin. During the course of the interceptions in this investigation, we learned
that TEIXEIRA is a large scale heroin distributor, who receives large quantities of heroin
for distribution from UM3839 a/k/a UM0708; that TEIXEIRA is a heroin source of supply
for ROSA and GOMES; that TEIXEIRA has a criminal associate who is not the subject of
this Complaint; and that TEIXEIRA has several heroin customers, including Nine
SILVEIRA and Iury GOMES. During the course of this investigation, approximately fifteen
fingers or 150 grams of heroin was seized directly from TEIXEIRA on November 2, 2010.
CRIMINAL INVESTIGATION AND EVIDENCE

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AGAINST CHARGED DEFENDANTS
15. The following transactions are examples of intercepted conversations, which I believe
involve the distribution of varied quantities of heroin. This section is divided by defendants,
as possible. However, the defendants and their transactions intercepted in this matter are
integrally intertwined, and as such, some sections will merely be a reference back to prior
paragraphs, which illustrate the defendants criminal participation in the charged conspiracy.
I. MIGUEL FERNANDES AND HIS CRIMINAL ASSOCIATES
criminal activities of Miguel FERNANDES and his criminal associates. On September 7,
2010, October 7, 2010, and November 1, 2010, the Honorable Richard G. Stearns authorized
the interception of target telephone # 6, used by Miguel FERNANDES. Previous to those
interceptions, Miguel FERNANDES was also intercepted on target telephone # 1, used by
Jose ROSA. Between June, 2010 and November, 2010, FERNANDES used target
telephone # 6 to receive and distribute large quantities of heroin, totaling in excess of one
that FERNANDES is a large scale heroin distributor, who receives larger quantities of heroin
for distribution from Carla VICENTE; that FERNANDES has a criminal associate named
Emanuel DOCANTO, who facilitates the receipt and distribution of heroin; a criminal
associate named Tamara HOLLIS, who is associated with FERNANDES and who delivered
six fingers of heroin to Virgilio ROSA on behalf of FERNANDES on October 28, 2010; that
FERNANDES has a criminal associate named Magnuson MARTINS, who stores heroin and
narcotics proceeds for FERNANDES; and that FERNANDES has numerous larger scale
heroin customers, including Alessio BARBOSA, Nicholas DEANGELIS, Iury GOMES,

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Alector GONCALVES, Virgilio ROSA, and Jose ROSA. During the course of this
investigation heroin was seized directly from FERNANDES on October 7, 2010; from
FERNANDES’s heroin customer, Nicholas DEANGELIS, on September 29, 2010; and from
FERNANDES’ heroin customer, Virgilio ROSA, on October 28, 2010. The following are
examples of conversations that have been intercepted, during the course of this investigation,
that focus on the above-named criminal defendants.
A. October 7, 2010, Seizure of Heroin from FERNANDES
17. On October 7, 2010, a car stop was conducted on a vehicle in which FERNANDES was a
passenger and DOCANTO was the driver of the vehicle. Ultimately, FERNANDES was
found to be in possession of approximately 40 grams of heroin. The following interceptions
led to the car stop and seizure.
18. On October 7, 2010, at approximately 7:19 p.m., an incoming call was received on target
telephone # 6 from telephone number (774) 259-7427. FERNANDES spoke to Alessio
BARBOSA, a heroin customer of FERNANDES. BARBOSA asked FERNANDES if he
had any “work” and FERNANDES said yes. BARBOSA asked the “price”. FERNANDES
stated that he had “6" and that the “price” was the “same as the other.” I believe that “work”
was code for heroin; that FERNANDES indicated that he had “6" fingers of heroin available
for distribution; and that the price was the same price that BARBOSA paid the last time he
received heroin from FERNANDES. At approximately 7:24 p.m., an incoming call was
received on target telephone # 6 from telephone number (774) 259-7427. FERNANDES
spoke to BARBOSA. BARBOSA stated that he “needs three.” FERNANDES stated that
he would be there in 15 minutes. I believe that FERNANDES was going to deliver “three”
fingers of heroin to BARBOSA.

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telephone # 6 from telephone number (508) 562-8091. FERNANDES spoke to
GONCALVES. FERNANDES told GONCALVES that he would be there in two minutes.
At approximately 7:46 p.m., FERNANDES told GONCALVES to come downstairs. At
approximately 7:47 p.m., GONCALVES told FERNANDES that his “girlfriend is going
downstairs and she will bring 650.” FERNANDES told GONCALVES that he will give him
“one more and he can pay for that tomorrow.” I believe that GONCALVES sent his
girlfriend to meet with FERNANDES; that the girlfriend was delivering $650, which was
payment for a finger or 10 grams of heroin; and that FERNANDES was going to give
GONCALVES “one more” or an additional finger of heroin which GONCALVES could pay
for the following day.
20. On October 7, 2010, at approximately 7:54 p.m., surveillance observed a silver Nissan
Maxima bearing Massachusetts registration number 1978MD in the driveway of 16 Forest
Avenue in Brockton, Massachusetts, the believed residence of GONCALVES. An
unidentified Cape Verdean woman exited the residence, walked to the passenger side
window. The woman then returned to 16 Forest Avenue and the Maxima departed the area.
I believe that DOCANTO and FERNANDES were in the Nissan Maxima; that DOCANTO
and FERNANDES delivered two fingers of heroin to the woman for GONCALVES; that
DOCANTO and FERNANDES received $650 cash, which was payment for one of the
fingers of heroin, from GONCALVES girlfriend; and that the woman and the heroin went
into 16 Forest Avenue.
21. On October 7, 2010, at approximately 8:07 p.m., a car stop was conducted on a gray Nissan
Maxima with Massachusetts registration number 1978MD. DOCANTO, a criminal associate

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of FERNANDES, was determined to be the driver of the vehicle and Miguel FERNANDES
was determined to be the passenger of the vehicle. FERNANDES was placed under arrest
for the possession of marijuana packaged for distribution. Subsequently, FERNANDES was
determined to be in possession of approximately 40 grams of heroin, which was initially
concealed in FERNANDES’ pants.
B. FERNANDES’ Heroin Source of Supply – Carla VICENTE
22. During the course of this investigation, numerous conversations were intercepted on target
telephone # 1, used by ROSA, target telephone # 6, used by FERNANDES, and target
telephone # 10, used by VICENTE, which indicated that Carla VICENTE was a heroin
source of supply for FERNANDES and that VICENTE had a criminal associate Tamara
HOLLIS, who participated in the distribution of heroin. Three transactions are detailed
below, during which VICENTE and/or HOLLIS delivered varied quantities of heroin to
FERNANDES.
I. September 21, 2010, FERNANDES and DOCANTO Received At Least 22 Fingers of Heroin
from Carla VICENTE and Distributed Fingers of Heroin to ROSA, GOMES, and BARBOSA
23. On September 20, 2010 and September 21, 2010, a series of conversations occurred on target
telephone # 1, used by ROSA and target telephone # 6, used by FERNANDES, which
indicated that FERNANDES, who was transported by his criminal associate DOCANTO,
received approximately 22 fingers or 220 grams of heroin from VICENTE; that
FERNANDES distributed a portion of said heroin to Jose ROSA, Iury GOMES, and Alessio
BARBOSA, specifically, “100" grams of heroin to GOMES, “one” finger or ten grams of
heroin to BARBOSA, and between ten and fifteen fingers or 100 to 150 grams of heroin to
ROSA; and that DOCANTO and FERNANDES delivered money to VICENTE, which was
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payment for the heroin received. The following conversations are summaries of translations
of conversations that were intercepted regarding the above mentioned heroin transaction.
24. On September 20, 2010, at approximately 5:00 p.m., an outgoing call was placed on target
telephone # 6 to telephone number (774) 776-5141. FERNANDES spoke to GOMES.
GOMES told FERNANDES that he wanted “100" and asked “do you think you can get it
today.” FERNANDES stated that he was suppose to and that he would call GOMES “as
soon as I put my hands on it.” I believe that GOMES wanted 100 grams of heroin and that
FERNANDES was in the process of getting the heroin.
25. On September 21, 2010, at approximately 8:58 a.m., an incoming call was received on target
telephone # 6 from telephone number (774) 776-5141. FERNANDES spoke to GOMES.
GOMES asked nothing yet and FERNANDES responded “I didn’t get it yet.”
FERNANDES asked GOMES if he still wanted the same amount and GOMES affirmed. I
believe that GOMES was waiting for 100 grams of heroin and that FERNANDES had not
yet received the heroin from his source of supply.
telephone # 6 to telephone number (774) 259-2296 – target telephone # 10. FERNANDES
spoke to VICENTE. VICENTE told FERNANDES that she was waiting for the “dude to
call her back.” I believe that VICENTE is FERNANDES’ heroin source of supply; that
FERNANDES was checking with VICENTE on the status of the heroin; and that VICENTE
was waiting for her heroin source of supply to call her back.
27. On September 21, 2010, at approximately 3:36 p.m., an incoming call was received on target
telephone # 6 from telephone number (774) 259-7427. FERNANDES spoke to BARBOSA.
FERNANDES told BARBOSA that he had not gotten “anything yet”. BARBOSA told
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FERNANDES to “save one for him.” I believe that FERNANDES had not yet received the
heroin and that BARBOSA wanted one finger of heroin from FERNANDES, when he
received the heroin, for distribution.
telephone # 6 to telephone number (774) 259-4026. FERNANDES spoke to DOCANTO.
FERNANDES told DOCANTO that there was nothing left. FERNANDES told DOCANTO
that “they have to go pick up the other because there is nothing.” I believe that DOCANTO
is a criminal associate of FERNANDES, who distributes heroin and transports
FERNANDES to receive heroin; and that DOCANTO was picking up FERNANDES to go
receive a larger quantity of heroin.
spoke to VICENTE. VICENTE asked FERNANDES whether he was at the “house from
that day” and FERNANDES affirmed. VICENTE stated that she would be there in two
minutes. I believe that FERNANDES and DOCANTO were meeting with VICENTE and
possibly VICENTE’s source of supply to receive a quantity of heroin.
telephone # 6 to target telephone # 1. FERNANDES spoke to ROSA. FERNANDES told
ROSA that he had picked up the “stuff” but that the “guy” did not have the quantity, he “has
22". FERNANDES told ROSA that he had “5 to 7" with him and that he will be there in a
few. I believe that FERNANDES met with VICENTE and a heroin source of supply; that
FERNANDES received at least “22" fingers of heroin or approximately 220 grams of heroin;
and that FERNANDES was en route to deliver 5 to 7 fingers or 50 to 70 grams of heroin to

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ROSA.
FERNANDES asked GOMES if he was ready and told GOMES to meet him at Elm Avenue
off Belmont Street. I believe that FERNANDES wanted to meet with GOMES to deliver 10
fingers or 100 grams of heroin for distribution.
32. On September 21, 2010, at approximately 5:48 p.m., surveillance observed Nissan Maxima
bearing Massachusetts registration 1978MD arrive in the vicinity of 62 Elm Avenue.
FERNANDES and DOCANTO were observed exiting the vehicle and entering 62 Elm
Avenue. I believe that FERNANDES and DOCANTO had received heroin from VICENTE
and were taking the heroin to 62 Elm Avenue for distribution.
GOMES told FERNANDES that he would be there in ten minutes. I believe that GOMES
was going to meet FERNANDES at Elm Avenue in approximately 10 minutes, to receive
approximately 10 fingers or 100 grams of heroin.
34. On September 21, 2010, at approximately 6:15 p.m., surveillance observed a Nissan Altima
bearing Massachusetts registration 5AG560, with two dark skinned males, travel from 267
Green Street, the believed residence of GOMES, to the vicinity of 62 Elm Avenue.
Surveillance observed a dark skinned male, consistent with DOCANTO, exit 62 Elm Avenue
and approach the driver’s side of the Nissan Altima. DOCANTO and the males appeared
to conduct a transaction on the driver’s side of the vehicle. DOCANTO then re-entered 62
Elm Avenue. The Nissan Altima departed the area and was surveiled traveling to 55
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Highland Terrace. The two males exited the vehicle and entered 55 Highland Terrace, which
is a believed residence of RIBEIRO, a criminal associate of GOMES, and a stash location
used by GOMES.
telephone # 6 from target telephone # 1. FERNANDES spoke to ROSA. ROSA told
FERNANDES to bring “10" and he will get “five more later.” I believe that ROSA had
arrived at 62 Elm Avenue and was instructing FERNANDES that he wanted ten fingers of
heroin then and would get the additional five fingers of heroin later.
36. On September 21, 2010, shortly after 6:15 p.m., surveillance observed a black BMW X5
bearing Massachusetts registration 593CB2, which is a vehicle known to be used by ROSA,
arrive on Elm Avenue and park in front of 62 Elm Avenue. Surveillance then departed the
area, as detailed above, to follow the GOMES vehicle. I believe that ROSA was at 62 Elm
Avenue to pick up 10 fingers or 100 grams of heroin.
telephone # 6 to telephone number (774) 259-7427. FERNANDES spoke to BARBOSA.
FERNANDES told BARBOSA that he will be there right now. BARBOSA told
FERNANDES to come to the back door. I believe that FERNANDES was delivering one
finger or ten grams of heroin to BARBOSA for distribution.
telephone # 6 to telephone number (774) 259-7427. FERNANDES spoke to BARBOSA.
BARBOSA told FERNANDES that the “thing is good, really good.” BARBOSA explained
that “its hard” and “he sold it all.” BARBOSA told FERNANDES that if he brought more
BARBOSA would buy it. I believe that BARBOSA prepared and distributed the heroin that
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he had received from FERNANDES; that the quality of the heroin from FERNANDES was
very good; and that BARBOSA wanted more heroin from FERNANDES.
telephone # 6 from telephone number (774) 259-2296 – target telephone # 10.
FERNANDES spoke to VICENTE. FERNANDES asked for the total and VICENTE said
“16710.” FERNANDES then said “the total is 22.” I believe that FERNANDES had given
VICENTE a quantity of money for the 22 fingers of heroin that he had received on
September 21, 2010, possibly $16,710, which included partial payment for a previous
quantity of heroin.
ii. September 24, 2010, VICENTE Received Fifty Fingers of Heroin and Distributed Heroin to
FERNANDES and DOCANTO
40. On September 24, 2010, a series of conversations occurred on target telephone # 6, used by
FERNANDES, which indicated that VICENTE received “50" fingers of heroin from her
source of supply and that FERNANDES, who was transported by his criminal associate
DOCANTO, received a portion of heroin for future distribution. The following
conversations are summaries of translations of conversations that were intercepted regarding
the above mentioned heroin transaction.
spoke to VICENTE. FERNANDES asked VICENTE if she was good and VICENTE stated
“not yet”. I believe that FERNANDES needed more heroin and that VICENTE was
indicating that the heroin had not yet arrived.
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telephone # 6 from telephone number (508) 685-6046. FERNANDES spoke to UF6046,
believed to be Tamara HOLLIS. HOLLIS told FERNANDES to meet them. At
approximately 9:17 p.m., an incoming call was received on target telephone # 6 from
telephone number (774) 259-2296. FERNANDES spoke to VICENTE. VICENTE asked
FERNANDES if he was on his way and FERNANDES stated that “mandog” didn’t answer
his telephone yet. At approximately 9:17 p.m., an outgoing call was placed on target
FERNANDES asked DOCANTO to come over and get him and bring him to go “pick up
the stuff from Carla.” DOCANTO agreed. At approximately 9:19 p.m., an outgoing call
was placed on target telephone # 6 to telephone number (774) 259-2296 – target telephone
# 10. FERNANDES spoke to VICENTE. FERNANDES asked VICENTE where she was
and VICENTE stated “at the house I brought you to that day.” FERNANDES stated that he
would be there in five minutes. I believe that VICENTE and HOLLIS had received a supply
of heroin and that DOCANTO was driving FERNANDES to pick up the heroin from
VICENTE.
telephone # 6 from telephone number (774) 259-2296 – target telephone # 10.
FERNANDES spoke to VICENTE. VICENTE asked FERNANDES if he wanted to pick
“it up tomorrow” and FERNANDES stated that he would get it now. VICENTE told
FERNANDES to bring the red bag. FERNANDES asked VICENTE how much and
VICENTE explained “the dude came he didn’t bring all of it he will bring more tomorrow.”
FERNANDES asked how much and VICENTE said “50". FERNANDES said “half of what
you said.” FERNANDES stated “I’m going to pick it up now.” I believe that VICENTE had
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met with her source of supply; that VICENTE had received “50" fingers of heroin from her
source of supply; that the 50 fingers of heroin was half the heroin that she and FERNANDES
had expected; and that FERNANDES was going to pick up the 50 fingers or a portion
thereof, of heroin from VICENTE.
iii. October 27, 2010, FERNANDES Received Heroin from VICENTE and FERNANDES and
DOCANTO Distributed Heroin to GONCALVES, and GOMES, and on October 28, 2010,
HOLLIS Delivered Six Fingers of Heroin to Virgilio ROSA, Which Was Seized
44. On October 27, 2010, at approximately 11:05 a.m., an incoming call was received on target
telephone # 6 from telephone number (508) 847-8622. FERNANDES spoke to UF8622,
known as VICENTE’s sister. VICENTE, who was with FERNANDES, spoke to UF8622.
UF8622 told VICENTE “it’s on its way.” At approximately 3:02 p.m., an outgoing call was
placed on target telephone # 10, used by VICENTE, to telephone number (508) 847-8622.
VICENTE spoke to UF8622, VICENTE’s sister. VICENTE’s sister asked VICENTE for
her favorite number and VICENTE’s sister said “five, four”. VICENTE agreed. At
approximately 4:16 p.m., VICENTE asked her sister “what number did you tell me” and
VICENTE’s sister answered “5,5". I believe that VICENTE was going to receive a shipment
of heroin; that UF8622 was explaining that the heroin was “on it’s way” and that the heroin
was going to cost VICENTE “5,5" or $550 a finger.
45. On October 27, 2010, FERNANDES had a series of calls indicating that he was waiting for
what I believe to be the heroin. At approximately 11:48 a.m., FERNANDES told Virgilio
ROSA “I should be clear in less than an hour.” Virgilio ROSA said “don’t forget about me”.
FERNANDES asked Virgilio ROSA “you want the same or less.” Virgilio ROSA said
“same, maybe add another one”. At approximately 12:37 p.m., FERNANDES told
GONCALVES “that thing is just about to get here, another half hour.” At approximately
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3:19 p.m., FERNANDES told GOMES “I’m getting some stuff, do you want some work”.
GOMES told FERNANDES let me call you back after I count the money, “get me 10". I
believe that Virgilio ROSA wanted “six” fingers of heroin; that GONCALVES wanted
“three” fingers of heroin; and that GOMES wanted ten fingers of heroin, from the heroin
that FERNANDES was about to receive from VICENTE.
46. On October 27, 2010, at approximately 3:52 p.m., an outgoing call was placed on target
telephone # 6 to telephone number (508) 562-8091. FERNANDES spoke to GONCALVES.
FERNANDES told GONCALVES that “the stuff is ready”. GONCALVES and
FERNANDES agree to meet at the garage. FERNANDES asked GONCALVES how many
and GONCALVES stated “2". At approximately 3:53 p.m., GONCALVES stated “bring me
three instead”. At approximately 4:41 p.m., FERNANDES and GONCALVES agree to meet
at “Dino’s”. At approximately 4:50 p.m., FERNANDES told GONCALVES that he would
be there in one minute. I believe that FERNANDES delivered two fingers or twenty grams
of heroin to GONCALVES.
telephone # 6 from telephone number (774) 776-5141. FERNANDES told GOMES that he
was right around the corner. At approximately 5:16 p.m., GOMES told FERNANDES that
he saw him. I believe that FERNANDES was delivering 10 fingers or 100 grams of heroin
to GOMES.
48. On October 28, 2010, at approximately 11:53 a.m., a conversation occurred on target
telephone # 6 with telephone number (508) 316-6258. FERNANDES asked Virgilio ROSA
if he is at home and Virgilio ROSA said yes. FERNANDES told Virgilio ROSA that he
would meet him at his house. At approximately 1:09 p.m., FERNANDES told Virgilio
20
ROSA near the “laundromat” at Montello. At approximately 1:36 p.m., Virgilio ROSA told
FERNANDES that he was arriving and that he was wearing a black shirt and a black and red
hat. FERNANDES told Virgilio ROSA to go inside and that FERNANDES would be
sending a “girl” to see him. FERNANDES asked Virgilio ROSA “if it is six” and Virgilio
ROSA affirmed. I believe that FERNANDES was sending HOLLIS to deliver “six” fingers
or 60 grams of heroin to Virgilio ROSA.
telephone # 6 to telephone number (508) 685-9838. FERNANDES spoke to HOLLIS.
FERNANDES told HOLLIS that there is a “dude” there with “black hat and black shirt” he
is going to “give you the money to give him the thing.” HOLLIS told FERNANDES to tell
him to wait and explained that she was getting food. At approximately 1:57 p.m.,
FERNANDES asked HOLLIS “if he got it” and HOLLIS responded yes. Based on the
foregoing and the following surveillance, I believe that HOLLIS delivered six fingers of
heroin to Virgilio ROSA.
50. On October 28, 2010, surveillance was conducted. At approximately 1:49 p.m.
surveillance observed a black male, wearing a black tee shirt and a black and red hat,
standing in front of a laundromat at 707 N. Montello Street, Brockton, MA. The male was
looking up and down the street as if waiting. At approximately 1:50 p.m., surveillance saw
a gray Hyundai, MA plate 985 DW1 park near the laundromat. The Hyundai is registered
to Tamara Hollis, and surveillance was able to identify the driver as HOLLIS. An unknown
female and a young child got out of the Hyundai and entered the laundromat and Hollis
remained in the vehicle. The male in the black and red hat, subsequently identified as
Virgilio ROSA, then approached the driver's side of the Hyundai. Surveillance saw Virgilio
21
ROSA remove his clenched hand from his pants pocket and then place his hand inside of the
driver's side window of the vehicle as if handing something to HOLLIS. Virgilio ROSA
then removed his hand from the vehicle and placed it into his right front pants pocket.
HOLLIS then exited the Hyundai and entered the laundromat. Virgilio ROSA then walked
to a green 1994 Honda Accord, MA plate 168 MS8 that is registered to Claude Desir Jr.,
DOB 11/10/85. Virgilio ROSA got into the driver's seat of the Honda and departed the area.
A short while later, the Honda was stopped by a uniformed Brockton Police Officer. After
the Brockton Police Officer activated the lights on the cruiser, Virgilio ROSA was observed
reaching his arm out of the driver's door window and throwing an object out of the vehicle
over the roof to the street on the right side of the vehicle. The Honda eventually stopped at
the side of the road and surveillance recovered the object that was thrown from the vehicle.
Recovered from the side of the road was six (6) cylindrical objects, consistent with fingers
of heroin, that were further contained within a wrapping of clear plastic. Virgilio ROSA and
Claude Desir Jr, the front seat passenger in the Honda, were arrested for Trafficking in
excess of 28 grams of heroin.
telephone # 6 from telephone number (508) 685-9838. FERNANDES spoke to HOLLIS.
FERNANDES asked HOLLIS about the day at the laundry. FERNANDES asked HOLLIS
whether “the dude that she served at the laundry, did she see him inside or outside”.
HOLLIS said outside. FERNANDES asked “inside the car or outside and HOLLIS said
outside. HOLLIS asked why and FERNANDES explained that “he got locked that day . .
. got caught with that shit . . . fifteen thousand dollars bail.” FERNANDES told HOLLIS
you should have served him “inside . . . [n]ext time you do it you do it inside.” I believe that
22
FERNANDES learned that Virgilio ROSA had been arrested and was questioning HOLLIS
regarding the details of the heroin delivery that had occurred between HOLLIS and Virgilio
ROSA, just prior to Virgilio ROSA’s arrest.
C. FERNANDES’ Criminal Associate – Emanuel DOCANTO
52. The interception of target telephone # 6, used by FERNANDES, revealed that FERNANDES
had a criminal associate named Emanuel DOCANTO. Interceptions revealed that
DOCANTO drove FERNANDES to pick up large quantities of heroin, as detailed in the
previously discussed September 21, 2010 and September 24, 2010 transactions between
FERNANDES and VICENTE; that DOCANTO delivered heroin to heroin customers; and
that DOCANTO received money, which was payment for narcotics previously delivered.
The following conversations are summaries of translations of additional conversations that
were intercepted which are examples of DOCANTO’s participation in the charged
conspiracy.
i. DOCANTO Distributed Heroin for FERNANDES
telephone # 6 from telephone number (774) 259-4026. FERNANDES spoke to DOCANTO.
DOCANTO told FERNANDES that he was on his way and asked if FERNANDES “has
anything bagged up.” FERNANDES said no. DOCANTO told FERNANDES that he had
“someone coming over for the other finger . . . [and] a few people that wanted bags.”
FERNANDES told DOCANTO to have them wait and explained that he woke up late. I
believe that DOCANTO is a criminal associate of FERNANDES, who distributes heroin for
FERNANDES; that DOCANTO wanted to know whether FERNANDES had anything
“bagged up” or ready for distribution and that DOCANTO was ready to deliver a “finger”
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or ten grams of heroin to one customer and “bags” or smaller quantities of heroin to
additional persons.
DOCANTO told FERNANDES “my boy is coming down for a finger”. FERNANDES
confirmed that he was home and told DOCANTO to call him when he was close. At
approximately 3:50 p.m., DOCANTO told FERNANDES that his “boy” was about to be
there. DOCANTO told FERNANDES that “his boy” would give him “650.” I believe that
DOCANTO was sending a heroin customer to FERNANDES; that FERNANDES was going
to deliver one finger of heroin; and that the customer was going to give FERNANDES $650
for the heroin.
telephone # 6 from telephone number (781) 439-7383. FERNANDES spoke to UM7383.
UM7383 told FERNANDES that he “needs one.” FERNANDES told UM7383 that he was
busy but that we would “call his boy.” At approximately 2:46 p.m., an outgoing call was
placed on target telephone # 6 to telephone number (774) 259-4026. FERNANDES spoke
to DOCANTO. FERNANDES left DOCANTO a voicemail that “somebody needs to see
him.” At approximately 2:54 p.m., an incoming call was received on target telephone # 6
from telephone number (774) 259-4026. FERNANDES spoke to DOCANTO.
FERNANDES told DOCANTO that the “Spanish guy” needs some thing. DOCANTO told
FERNANDES to tell “him” to meet him at Advance auto part. I believe that DOCANTO
was going to meet with a heroin customer to deliver heroin.
ii. DOCANTO Brought Heroin and Drove FERNANDES To Distribute Heroin

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FERNANDES told DOCANTO that he had a “few plays” and that he wanted to know when
DOCANTO could pick him up. DOCANTO told FERNANDES that he would come get him
and FERNANDES asked DOCANTO to bring “4 with him” and explained that “MG, Jeje,
and other people are waiting for plays.” I believe that FERNANDES wanted DOCANTO
to pick up four fingers of heroin and drive FERNANDES to deliver the heroin to
FERNANDES’ heroin customers.
D. FERNANDES’ Criminal Associate – Tamara HOLLIS
57. As previously detailed, on September 24, 2010, HOLLIS contacted FERNANDES and
arranged for a meeting with VICENTE, in order to FERNANDES to receive 50 fingers of
heroin. As detailed previously in Section I, A, iii, on October 28, 2010, HOLLIS delivered
six fingers of heroin to Virgilio ROSA, which was subsequently seized in the vicinity of
Virgilio ROSA. Also, on August 16, 2010, surveillance observed HOLLIS meet with
FERNANDES and based on intercepted conversations, I believe that HOLLIS delivered six
fingers of heroin to FERNANDES, for further distribution. The following conversations are
summaries of translations of conversations that were intercepted which illustrate HOLLIS’
participation in the charged conspiracy.
i. August 16, 2010, FERNANDES Received Six Fingers of Heroin from HOLLIS and VICENTE
and Delivered a Portion of Heroin to BARBOSA for ROSA
58. On August 16, 2010, conversations were intercepted which revealed that ROSA, a heroin
customer of FERNANDES, wanted “6" fingers or 60 grams of heroin and that FERNANDES
was unable to deliver the heroin until FERNANDES met with his heroin source of supply.
25
Surveillance observed FERNANDES meet with HOLLIS and VICENTE and then a
conversation was intercepted, which I believe indicated that FERNANDES had delivered
the heroin to a representative of ROSA. The following conversations are summaries of
translations of conversations that were intercepted regarding the above mentioned heroin
transaction.
59. On August 16, 2010, at approximately 2:35 p.m., an outgoing call was placed on target
telephone # 1 to telephone number (508) 232-9529. ROSA spoke to FERNANDES. ROSA
told FERNANDES that “he would grab 6" and to “call the dude.” I believe that ROSA was
ordering 6 units of heroin from FERNANDES and that FERNANDES was going to call his
source of supply to get the heroin.
60. On August 16, 2010, at approximately 2:46 p.m., an incoming call was received on target
telephone # 1 from telephone number (508) 232-9529. ROSA spoke to FERNANDES.
FERNANDES stated that “he said that he will be in Abington in 45 minutes and I can meet
up with him. At approximately 4:20 p.m., an incoming call was received on target telephone
# 1 from telephone number (508) 232-9529. ROSA spoke to FERNANDES. FERNANDES
stated that the “dude” called him and he was “leaving now.” I believed that FERNANDES
was going to meet his source of supply to get a quantity of heroin.
61. On August 16, 2010, surveillance of FERNANDES was conducted. A Nissan Maxima with
Massachusetts registration 1978 MD, which is known to be driven my Emanuel DOCANTO,
a criminal associate of FERNANDES, was observed in the vicinity of Panorama in
Brockton, Massachusetts. At approximately 5:00 p.m., agents observed a silver Hyundai
with Massachusetts registration number 985 DW1, registered to Tamara HOLLIS, park in
the parking lot of Panorama, two spaces from the DOCANTO vehicle. Agents observed the
26
female driver of the vehicle, later determined to be HOLLIS, exit the Hyundai and get into
the rear of the DOCANTO vehicle. Shortly thereafter, HOLLIS exited the DOCANTO
vehicle and returned to the Hyundai and left the area. At approximately 5:10 p.m., a car stop
was conducted on the Hyundai. The driver of the vehicle was identified as Tamara HOLLIS
and the passenger of the vehicle was identified as Carla VICENTE. During the course of the
car stop, agents determined that telephone number (774) 259-2296 was being used by
VICENTE. I believe that FERNANDES and DOCANTO met with VICENTE and HOLLIS
and that HOLLIS delivered six fingers of heroin to FERNANDES.
FERNANDES stated that “I dropped it off” but that he wouldn’t go there anymore. ROSA
stated that from now on they could meet by the highway and ROSA stated that he has a
“house by the highway.” I believe that FERNANDES received a quantity of heroin from
VICENTE and HOLLIS and then “dropped it off” to ROSA’s associate BARBOSA for
distribution.
ii. October 28, 2010, FERNANDES Had HOLLIS Deliver Six Fingers of Heroin to Virgilio
ROSA, Which Was Seized From Virgilio ROSA
63. As previously detailed in Section I, Part B, iii, on October 28, 2010, a series of conversations
occurred during which Virgilio ROSA requested “six” finger of heroin from FERNANDES;
FERNANDES told Virgilio ROSA to meet at the laundromat; FERNANDES contacted
HOLLIS and told her who and where to meet; surveillance observed HOLLIS meet with
Virgilio ROSA; and then six fingers or approximately 60 grams of heroin was seized from
Virgilio ROSA.
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iii. Additional Criminal Actions of HOLLIS
telephone # 6 to telephone number (508) 685-9838. FERNANDES spoke to HOLLIS.
FERNANDES asked HOLLIS whether she was at home. FERNANDES told HOLLIS that
he “left that thing inside the basket inside of the closet . . . and not to let them get close
around there.” HOLLIS affirmed. I believe that FERNANDES had something concealed
within a basket inside the closet of 82 French Avenue, Second Floor, in Brockton,
Massachusetts, which is HOLLIS’ residence and where FERNANDES is currently residing.
telephone # 6 from telephone number (508) 685-9838. FERNANDES spoke to HOLLIS.
FERNANDES told HOLLIS to “grab the finger by the back door and bring it to me at
Dino’s”. I believe that FERNANDES was using 82 French Avenue, Second Floor, in
Brockton, Massachusetts, to store his heroin and that HOLLIS was going to bring a finger
or ten grams of heroin to FERNANDES for further distribution.
E. FERNANDES’ Heroin Customer – Alessio BARBOSA
had numerous larger scale heroin customers, including Alessio BARBOSA. Interceptions
revealed that BARBOSA would request and receive multi-finger quantities of heroin from
FERNANDES and further distribute said heroin. As previously detailed, on October 7,
2010, FERNANDES was en route to deliver three fingers of heroin to BARBOSA when the
vehicle in which FERNANDES was riding was stopped and four fingers of heroin was
seized from FERNANDES. Also, as previously detailed, on September 21, 2010, and
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September 26, 2010, FERNANDES and DOCANTO delivered heroin to BARBOSA. As
discussed later in this Affidavit, BARBOSA was also intercepted extensively on target
telephone # 1, used by ROSA, because BARBOSA was a criminal associate of ROSA, who
received and distributed heroin daily. The following are additional examples of
BARBOSA’s criminal interactions with FERNANDES, during the course of the charged
conspiracy.
i. October 9, 2010, FERNANDES Delivered Five Fingers of Heroin to BARBOSA
FERNANDES asked BARBOSA what he needed. BARBOSA told FERNANDES to bring
him “5" and he will “pay for the 3 and . . . give him another $100 on top.” FERNANDES
stated that he was coming in a few. I believe that FERNANDES was going to deliver “5"
fingers of heroin to BARBOSA; that BARBOSA was going to pay for three of the fingers
of heroin; that BARBOSA was going to owe FERNANDES for the two additional fingers
of heroin plus $100 extra, for being fronted the heroin.
ii. October 19, 2010, FERNANDES Delivered Five Fingers of Heroin to BARBOSA
BARBOSA stated that he needed “two”. FERNANDES confirmed “two”. FERNANDES
asked BARBOSA if he was at home. At approximately 8:41 p.m., BARBOSA told
FERNANDES that he was “home”. At approximately 9:37 p.m., FERNANDES told
BARBOSA that he was at the door. I believe that FERNANDES was delivering two fingers
of heroin to BARBOSA at his home, which is located at 55 City Hall Square, Apartment #
29
2, in Brockton, Massachusetts.
iii. November 2, 2010, FERNANDES Delivered Two Fingers of Heroin to BARBOSA
69. On November 2, 2010, at approximately 11:47 a.m., an incoming call was received on target
BARBOSA stated that he was hungry and waiting on work since yesterday. FERNANDES
stated that he was at home and had no ride. FERNANDES asked BARBOSA what he
wanted and BARBOSA stated “three or four”. FERNANDES stated that he had “2" put
away and BARBOSA agreed to take “two for now”. At approximately 12:51 p.m.,
FERNANDES told BARBOSA that he was still looking for a ride. BARBOSA asked
FERNANDES how much he was bringing and FERNANDES stated “two”. BARBOSA
asked how much “12" and FERNANDES affirmed. At approximately 1:21 p.m.,
FERNANDES told BARBOSA that he was outside. I believe that FERNANDES traveled
to BARBOSA’s residence at 55 City Hall Square to deliver two fingers of heroin to
BARBOSA and that BARBOSA was going to pay FERNANDES $1200 for the heroin.
70. On November 2, 2010, surveillance was established. At approximately 1:25 p.m., agents
observed a dark colored sedan arrive in the parking lot in front of 55 City Hall Square in
Brockton, MA, the believed residence of BARBOSA. FERNANDES was observed walking
from the area of the vehicle towards the front of 55 City Hall Square. I believe that
FERNANDES was delivering two fingers of heroin to BARBOSA.
F. FERNANDES’ Heroin Customer – Nicholas DEANGELIS
had numerous frequent heroin customers, including Nicholas DEANGELIS. Interceptions
revealed that DEANGELIS would request and receive finger or multi-finger quantities of
30
heroin from FERNANDES and further distribute said heroin. As detailed below, I believe
that on September 18, 2010, September 20, 2010, and September 22, 2010, FERNANDES
delivered additional quantities of heroin to DEANGELIS. Then on September 29, 2010,
FERNANDES delivered in excess of one finger of heroin to DEANGELIS, which was
seized from DEANGELIS. During the course of the investigation, I believe that
DEANGELIS has received in excess of 22 fingers or 220 grams of heroin from
FERNANDES. The following are examples of DEANGELIS’ criminal interactions with
FERNANDES, during the course of the charged conspiracy.
i. September 10, 2010, FERNANDES’ Distributed Heroin to DEANGELIS
DOCANTO told FERNANDES that he was on his way and asked if FERNANDES “has
anything bagged up.” FERNANDES said no. DOCANTO told FERNANDES that he had
“someone coming over for the other finger . . . [and] a few people that wanted bags.”
FERNANDES told DOCANTO to have them wait and explained that he woke up late. I
believe that DOCANTO is a criminal associate of FERNANDES, who distributes heroin for
FERNANDES.
DEANGELIS. FERNANDES told DEANGELIS that he didn’t have any and that he had to
go and get it. DEANGELIS told FERNANDES to “come through, I have people.” I believe
that DEANGELIS is a heroin customer of FERNANDES; that DEANGELIS wanted a
31
quantity of heroin from FERNANDES; and that DEANGELIS’ “people” or heroin
customers were waiting for the heroin.
74. On September 10, at approximately 1:35 p.m., an outgoing call was placed on target
telephone # 6 to telephone number (774) 360-6770. FERNANDES spoke to MARTINS.
FERNANDES asked MARTINS “are you at home.” MARTINS affirmed. FERNANDES
explained that “I’m going to pass by to go pick up a couple of things . . . I will be downstairs
in a couple of minutes.” I believe that MARTINS resides at 12 Wyman Street in Brockton,
Massachusetts; that MARTINS stores heroin and narcotics proceeds for FERNANDES; and
that on this day, FERNANDES was picking up heroin from MARTINS for distribution.
DEANGELIS. DEANGELIS asked FERNANDES what was up and he stated “I’ll be there
in five minutes.” I believe that FERNANDES picked up heroin from MARTINS at 12
Wyman Street and that as a result, FERNANDES was ready to distribute heroin to
DEANGELIS.
DEANGELIS. DEANGELIS told FERNANDES “I’m gonna need another one in half an
hour.” FERNANDES told DEANGELIS to call him. I believe that DEANGELIS needed
another “one” or another finger of heroin from FERNANDES.
ii. September 12, 2010, FERNANDES’ Distributed Heroin to DEANGELIS
telephone # 6 to telephone number (508) 692-1027. FERNANDES spoke to DEANGELIS.

32
FERNANDES stated that he was getting something to eat and that he would see
DEANGELIS after he ate.
FERNANDES told MARTINS that he was on the way to “pick up a few things to bring it
somewhere.” FERNANDES stated that when he arrived he would call MARTINS to come
down. On September 12, at approximately 1:57 p.m., an outgoing call was placed on target
FERNANDES stated that he was downstairs. I believe that MARTINS stores heroin and
narcotics proceeds for FERNANDES; and that on this day, FERNANDES was picking up
heroin from MARTINS for distribution.
DEANGELIS. DEANGELIS asked FERNANDES if he was outside and FERNANDES told
DEANGELIS to start walking. I believe that FERNANDES had received heroin from
storage from MARTINS and that as a result, FERNANDES had heroin for distribution to
DEANGELIS.
iii. September 13, 2010, FERNANDES’ Distributed Heroin to DEANGELIS
80. On September 13, 2010, at approximately 12:27 p.m., an incoming call was received on
target telephone # 6 from telephone number (508) 692-1027. FERNANDES spoke to
DEANGELIS. DEANGELIS stated that “I need two, two of those things.” DEANGELIS
asked what the price would be and whether he could get it lower for two. FERNANDES
said no and explained that he already discounted $25. DEANGELIS told FERNANDES that
33
he would contact FERNANDES when he got to Brockton. I believe that DEANGELIS
wanted “two” fingers of heroin from FERNANDES for distribution.
DEANGELIS. DEANGELIS told FERNANDES to “come see him now for two.”
FERNANDES agreed. DEANGELIS confirmed with FERNANDES that it is the “same
stuff.” FERNANDES affirmed. I believe that FERNANDES was going to meet with
DEANGELIS and deliver two fingers of heroin.
FERNANDES stated that he was going to pick up “another one of those things for someone”
and asked MARTINS to “get one of those out of the car and hold it for him.” I believe that
MARTINS stores heroin and narcotics proceeds for FERNANDES; and that on this day,
FERNANDES was picking up heroin from MARTINS for distribution to DEANGELIS.
DEANGELIS stated that he was still waiting on FERNANDES and FERNANDES told
DEANGELIS to start walking because he was close. I believe that FERNANDES had
picked up a quantity of heroin from MARTINS and was ready to deliver the heroin to
DEANGELIS.
FERNANDES asked MARTINS whether he was home. FERNANDES explained that he

34
was going to pass by in about 5 minutes and to “get the thing that it is about to end, save it
for me.” I believe that MARTINS stores heroin and narcotics proceeds for FERNANDES;
and that on this day, FERNANDES was picking up heroin from MARTINS for distribution.
FERNANDES asked MARTINS whether he was downstairs or upstairs. MARTINS stated
that he was “downstairs by the door.” FERNANDES asked MARTINS “the last thing I gave
you to save, you didn’t mix it with the other one, did you.” MARTINS stated yeah.
MARTINS stated that he had to “get it upstairs.” FERNANDES told MARTINS to “put it
in a plastic bag and bring me downstairs.” I believe that MARTINS stores heroin and
narcotics proceeds for FERNANDES; and that on this day, FERNANDES was picking up
heroin from MARTINS for distribution.
iv. September 18, 2010, FERNANDES’ Delivered Heroin to DEANGELIS
DEANGELIS. DEANGELIS asked FERNANDES whether he was “good, same stuff” and
FERNANDES said yeah. DEANGELIS stated that he had a car and would come to Elm in
five minutes. At approximately 9:05 p.m., an incoming call was received on target telephone
# 6 from telephone number (508) 692-1027. DEANGELIS told FERNANDES that he was
there at the bottom of the stairs. FERNANDES told DEANGELIS to wait at the bottom of
the stairs. I believe that DEANGELIS wanted a quantity of heroin from FERNANDES and
that DEANGELIS had traveled to meet with FERNANDES to get the heroin.
v. September 20, 2010, FERNANDES’ Delivery of Heroin to DEANGELIS

35
DEANGELIS asked FERNANDES if he could come see him for the “same stuff.”
FERNANDES said yes in 20 minutes. At approximately 4:59 p.m., FERNANDES told
DEANGELIS that he was about to pull up. I believe that DEANGELIS wanted a quantity
of heroin from FERNANDES and that FERNANDES was delivering said heroin to
DEANGELIS.
vi. September 22, 2010, FERNANDES’ Delivered Heroin to DEANGELIS
88. On September 22, 2010, at approximately 10:56 a.m., an incoming call was received on
DEANGELIS. DEANGELIS asked FERNANDES “if it is still the same stuff” and
FERNANDES answered yes. DEANGELIS asked FERNANDES whether “can drop the
price, same price.” FERNANDES stated “675, I can’t go lower than that.” DEANGELIS
told FERNANDES to “hit me up, I’m good and ready.” I believe that DEANGELIS wanted
another delivery of heroin and that DEANGELIS was receiving one finger of heroin each
time from FERNANDES; and that DEANGELIS was paying $675 per finger of heroin.
vii. September 29, 2010, FERNANDES’ Delivered Heroin to DEANGELIS and Seizure of Heroin
from DEANGELIS
89. On September 29, 2010, at approximately 11:56 a.m., an outgoing call was placed on target
DEANGELIS told FERNANDES that he was coming to “pick up.” DEANGELIS stated that
he would be there in fifteen minutes. At approximately 12:30 p.m., DEANGELIS told
FERNANDES that he was there.
36
90. As a result of the above-referenced conversations, on September 29, 2010, surveillance
observed DEANGELIS arrive in a silver Nissan Sentra bearing Massachusetts registration
number 221GP7, in the vicinity of Belmont and Elm Street in Brockton, Massachusetts.
DEANGELIS was observed entering and departing a building, believed to be used by
FERNANDES. DEANGELIS got into the passenger side of the vehicle and departed the
area. A traffic stop was conducted on the vehicle, DEANGELIS was found in possession
of one finger of believed heroin and 8 40 bags of believed heroin. DEANGELIS was
arrested, charged, and is currently incarcerated.
G. FERNANDES’ Heroin Customer – Iury GOMES
had numerous frequent heroin customers, including Iury GOMES. Interceptions revealed
that GOMES would request and receive multi-finger quantities of heroin from
FERNANDES, usually ten fingers of heroin or 100 grams of heroin at a time and further
distribute said heroin. As detailed earlier in this Affidavit, on September 21, 2010 and
October 27, 2010, GOMES received, what I believe to be, 100 grams of heroin, on each
occasion. As detailed later in this Affidavit, is additional information that GOMES was a
heroin source of supply to ROSA; that ROSA was a heroin source of supply for GOMES;
and that GOMES has several heroin criminal associates. The following are examples of
criminal transactions between FERNANDES and GOMES.
i. August 12, 2010, FERNANDES Delivered 10 Fingers of Heroin to GOMES
92. On August 12, 2010, at approximately 11:07 a.m., an incoming call was received on target
telephone # 8 from telephone number (508) 232-9529 -- target telephone # 6. GOMES
spoke to FERNANDES. FERNANDES told GOMES that “I have a dude with good stuff
37
he’s asking 650.” GOMES asked “how much for 100 . . . 100 for 6.” GOMES clarified “call
him ask him for 100 gram”. FERNANDES stated that he would call “him” and “call you
right”. I believe that FERNANDES had a “dude” or a heroin source of supply that sold
heroin for $650 a finger; that GOMES wanted to know whether the source would sell the
heroin for “6" or $600 a finger if GOMES bought 100 grams of heroin; and that
FERNANDES was going to contact his source of supply and then contact GOMES again.
telephone # 8 from telephone number (508) 232-9529 -- target telephone # 6. GOMES
spoke to FERNANDES. FERNANDES stated that “he only has 9 . . . I told him to make
another 625.” GOMES asked if it was ready and FERNANDES stated 45 minutes. I believe
that FERNANDES contacted a source of supply of heroin; that the source of supply had “9"
fingers of heroin available; that the source was going to make one additional finger of
heroin; and that the price for the heroin was going to be $625 a finger.
telephone # 8 to telephone number (508) 232-9529 -- target telephone # 6. GOMES spoke
to FERNANDES. FERNANDES stated that he was going over there now. At
approximately 12:17 p.m., GOMES asked FERNANDES if he was all set; FERNANDES
affirmed; and GOMES stated that he was coming “out right now.” I believe that
FERNANDES had traveled to meet GOMES and that GOMES was delivering money to
FERNANDES for the 10 fingers of heroin.
telephone # 8 to telephone number (508) 232-9529 -- target telephone # 6. GOMES spoke
to FERNANDES. FERNANDES stated that he was about to get “it” in five minutes and that
38
“as soon as I get it I’ll swing thru.” At approximately 1:25 p.m., FERNANDES asked
GOMES where he was and GOMES stated on Laureston near Prestige.” I believe that
FERNANDES had received the ten fingers of heroin and was driving to meet GOMES to
deliver the heroin.
96. On August 12, 2010, surveillance was established in the vicinity of 267 Green Street in
Brockton, MA, the believed residence of GOMES. A Nissan Altima with Massachusetts
Registration number 5AG 560, used by GOMES, was parked in the driveway. At
approximately 1:15 p.m., the Nissan Altima departed the area. At approximately 1:30 p.m.,
the Nissan Altima was observed in the driveway of 129 Laureston Street in Brockton MA
and a Gray Maxima (1978 MD), used by FERNANDES, parked in the same driveway,
behind the Altima. FERNANDES and GOMES were observed, as well as one unidentified
male in FERNANDES vehicle. GOMES was then surveiled entering the building of 129
Laureston Street, which was determined to be the residence of Elsio MONTEIRO, a criminal
associate of GOMES.
ii. August 17, 2010, FERNANDES Delivered 6 Fingers of Heroin to GOMES
telephone # 8 to telephone number (508) 232-9529. GOMES spoke to FERNANDES.
GOMES asked FERNANDES if “he can do 20 of them for 550.” FERNANDES stated that
he will “call the dude then call him back.” I believe that GOMES wanted 20 fingers of
heroin from FERNANDES; that GOMES wanted the heroin for $550/finger or 10 gram
quantity; and that FERNANDES was going to contact one of his heroin sources of supply.
telephone # 8 from telephone number (508) 232-9529. GOMES spoke to FERNANDES.

39
FERNANDES told GOMES bad news and explained that “he only has 10 until tomorrow
. . . and I want 5 for me.” GOMES told FERNANDES “so give me the 10 for $600.”
FERNANDES told GOMES “I’ll get you 6.” I believe that FERNANDES had spoken to one
of his heroin sources of supply; that the source only had 10 fingers for distribution; that
GOMES wanted 10 fingers for $600 and FERNANDES indicated that he would get 6 fingers
for GOMES.
FERNANDES stated that he had passed by and he didn’t see GOMES’ car. GOMES stated
that he was in the house and my boy is going outside now. At approximately 6:24 p.m.,
FERNANDES told GOMES “I gave it to him dude with scooter.” I believe that
FERNANDES delivered 6 fingers of heroin to Laureston Street to Elsio MONTEIRO.
iii. October 24, 2010, FERNANDES Delivered Fifty Grams of Heroin to GOMES
GOMES asked FERNANDES if he had “good works” and FERNANDES affirmed.
GOMES asked for “one hundred" and FERNANDES stated that he did not think that he had
a “hundred, maybe fifty”. FERNANDES affirmed that GOMES wanted it and GOMES
affirmed. I believe that GOMES wanted a “hundred” or a hundred grams of heroin; that
FERNANDES did not have 100 grams of heroin available for distribution; but that
FERNANDES was going to deliver 50 grams of heroin to GOMES.

40
FERNANDES told GOMES to meet him at Dino’s because he does not have a car. GOMES
told FERNANDES to meet him at the carwash. FERNANDES told GOMES to pretend that
he is cleaning the car and FERNANDES will put it inside the car. I believe that
FERNANDES was going to deliver 50 grams of heroin to GOMES at the carwash.
102. On October 24, 2010, surveillance was established in the vicinity of Dino’s Bar. Agents
observed FERNANDES standing in front of Dino’s. At approximately 3:13 p.m., agents
observed a 2000 black Cadillac Escalade with Massachusetts Registration 142 NH9, pull
into the car wash across the street from Dino’s. FERNANDES was observed walking across
the street toward where the Cadillac was parked. FERNANDES was lost from view and then
when the Cadillac came into view again, FERNANDES was observed exiting from the rear
passenger door of the Escalade and crossing the street towards Dino’s Bar. Surveillance
followed the black Escalade. At approximately 3:23 p.m, the Escalade arrived at 55
Highland Terrace. Two Cape Verdean males were observed to exit the vehicle, walk down
the driveway of 55 Highland Terrace and enter the side door of the home. One of the males
was later determined to be Emanuel RIBEIRO.
H. FERNANDES’ Heroin Customer – Alector GONCALVES
had numerous larger scale heroin customers, including Alector GONCALVES.
Interceptions revealed that GONCALVES would request and receive multi-finger quantities
of heroin from FERNANDES and further distribute said heroin. As discussed later in this
Affidavit, GONCALVES has also been intercepted on target telephone # 1, as a heroin
customer of ROSA. The following are a few examples of GONCALVES’ criminal
interactions with FERNANDES, during the course of the charged conspiracy.

41
i. September 20, 2010, GONCALVES Received Half a Finger of Heroin from FERNANDES
GONCALVES. GONCALVES asked FERNANDES if he “had the stuff” and
FERNANDES stated that he was getting it in about 45 minutes. GONCALVES asked
FERNANDES if he had “at least a half” and FERNANDES answered “just in pieces.”
GONCALVES asked FERNANDES “did you bag it up” and FERNANDES said “yeah, I
don’t know if your people would want it that way.” GONCALVES asked how many and
FERNANDES stated “15". GONCALVES told FERNANDES to bring “it to me.” At
approximately 1:29 p.m., FERNANDES told GONCALVES that he was on his way. I
believe that GONCALVES wanted a half a finger or 5 grams of heroin; that FERNANDES
did not have the heroin available at that time; but that GONCALVES was going to take 15
smaller units of heroin that FERNANDES had packaged for distribution; and that
FERNANDES was delivering the heroin to GONCALVES.
ii. September 27, 2010, GONCALVES Received One Finger of Heroin from FERNANDES
GONCALVES told FERNANDES that he wants a “finger” and asked FERNANDES his
location. FERNANDES asked GONCALVES if he has a car and GONCALVES said yes.
FERNANDES told GONCALVES that he was “at the house where they met up . . . at
Belmont Street.” GONCALVES told FERNANDES to give him ten or fifteen minutes. At
approximately 2:17 p.m., GONCALVES told FERNANDES that he was there. At
approximately 2:19 p.m.,, GONCALVES told FERNANDES that he was outside and
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FERNANDES stated that he was coming down. I believe that GONCALVES traveled to 62
Elm Ave in Brockton, MA, to receive heroin from FERNANDES and that FERNANDES
delivered one “finger” or ten grams of heroin to GONCALVES.
iii. October 7, 2010, GONCALVES Received One Finger of Heroin from FERNANDES
GONCALVES. FERNANDES told GONCALVES that he would be there in two minutes.
At approximately 7:46 p.m., FERNANDES told GONCALVES to come downstairs. At
approximately 7:47 p.m., GONCALVES told FERNANDES that his “girlfriend is going
downstairs and she will bring 650.” FERNANDES told GONCALVES that he will give him
“one more and he can pay for that tomorrow.” I believe that GONCALVES sent his
girlfriend to meet with FERNANDES; that the girlfriend was delivering $650, which was
payment for a finger or 10 grams of heroin; and that FERNANDES was going to give
GONCALVES “one more” or an additional finger of heroin which GONCALVES could pay
for the following day.
107. On October 7, 2010, at approximately 7:54 p.m., surveillance observed a silver Nissan
Maxima bearing Massachusetts registration number 1978MD in the driveway of 16 Forest
Avenue in Brockton, Massachusetts, the believed residence of GONCALVES. An
unidentified Cape Verdean woman exited the residence, walked to the passenger side
window. The woman then returned to 16 Forest Avenue and the Maxima departed the area.
At approximately 8:07 p.m., a car stop was conducted of the vehicle. DOCANTO and
FERNANDES were in the vehicle and found to be in possession of approximately 40 grams
of heroin and $2,270. I believe that DOCANTO and FERNANDES were in the Nissan
43
Maxima; that DOCANTO and FERNANDES delivered two fingers of heroin to the woman
for GONCALVES; that DOCANTO and FERNANDES received $650 cash, which was
payment for heroin, from GONCALVES girlfriend; and that the woman and the heroin went
into 16 Forest Avenue.
iv. October 27, 2010, GONCALVES Received Three Fingers of Heroin from FERNANDES
FERNANDES told GONCALVES that the “stuff” is ready. GONCALVES told
FERNANDES that he would meet him at the garage. FERNANDES asked how many and
GONCALVES stated “2". At approximately 3:53 p.m., GONCALVES told FERNANDES
“bring me three instead”. FERNANDES agreed. At approximately 4:41 p.m.,
FERNANDES told GONCALVES to meet him at “Dino’s”. GONCALVES agreed. At
approximately 4:50 p.m., GONCALVES told FERNANDES that he was there and
FERNANDES stated that he would be there in a minute. I believe that FERNANDES was
delivering “three” fingers of heroin to GONCALVES.
v. FERNANDES and GONCALVES Discussed Potential Violence
109. On October 7, 2010, at approximately 11:17 a.m., an outgoing call was placed on target
FERNANDES told GONCALVES that “Play and the guys are getting together to rob me,
this dude told me yesterday.” FERNANDES told GONCALVES that I am “going there and
[I] will take his life.” GONCALVES told FERNANDES to “hit him with a bullet on his
ass.” FERNANDES stated that he has some “stuff to try.” GONCALVES asked if the “stuff
is good”. FERNANDES stated that its “supposed to be stronger, and that it came from
44
someone else.” FERNANDES explained that “he will try it before he takes the whole
quantity.” FERNANDES told GONCALVES that “they have him, Jose and Iury on sight.”
GONCALVES asked FERNANDES who told him and FERNANDES said “some dude told
him”. GONCALVES stated “they will be going there shots to shots.” FERNANDES stated
that he is “waiting for them, and that he [FERNANDES] has his eyes opened.”
GONCALVES told FERNANDES to “let me know what’s up.” I believe that the first part
of this conversation concerns a potential violent act against a yet unknown person. I believe
that FERNANDES heard that he was going to be the target of a robbery and that
FERNANDES, ROSA (Jose), and GOMES (Iury) are planning to meet the guy that is going
to commit the robbery and possibly shoot the person who is going to commit the robbery.
I believe that the second part of the conversation when FERNANDES says he has some
“stuff to try” that is “supposed to be stronger” relates to heroin; that FERNANDES has a
new batch of heroin; that is suppose to be stronger; and that FERNANDES is going to take
a small amount, test the quality; and then get more heroin if the quality is good.
I. FERNANDES’ Heroin Customer – Jose ROSA
had numerous larger scale heroin customers, including Jose ROSA. Interceptions revealed
that Jose ROSA would request and receive multi-finger quantities of heroin from
FERNANDES and further distribute said heroin. As discussed later in this Affidavit, ROSA
was intercepted extensively in this investigation, using target telephone # 1, and that during
said interceptions, I learned that ROSA has several other heroin sources of supply, criminal
associates, and independent heroin customers. The details of the criminal interactions
between ROSA and FERNANDES are best placed in the ROSA section of this Affidavit
45
because the transactions include actions by criminal associates of ROSA and therefore, are
detailed in Section II, Part A.
J. FERNANDES’ Heroin Customer – Virgilio ROSA
had numerous larger scale heroin customers, including Virgilio ROSA Interceptions
revealed that Virgilio ROSA would request and receive multi-finger quantities of heroin
from FERNANDES and further distribute said heroin. As discussed later in this Affidavit,
Virgilio ROSA was also intercepted frequently on target telephone # 1, used by ROSA, and
that Virgilio ROSA, was at one time a heroin source of supply of ROSA and at another time,
a heroin customer of ROSA. As detailed in the Tamara HOLLIS section of this Affidavit,
on October 28, 2010, approximately six fingers or sixty grams of heroin was seized from
Virgilio ROSA. The following are examples of Virgilio ROSA’s criminal interactions with
FERNANDES, during the course of the charged conspiracy.
i. October 9, 2010, FERNANDES Distributed Five Fingers of Heroin to Virgilio ROSA
112. On October 9, 2010, at approximately 11:46 a.m., an incoming call was received on target
telephone # 6 from telephone number (508) 232-1456. FERNANDES spoke to Virgilio
ROSA. Virgilio ROSA asked FERNANDES if he was “working” and FERNANDES
affirmed. Virgilio ROSA told FERNANDES that he wanted “the same thing as the other
day.” FERNANDES asked what and Virgilio ROSA said “5". FERNANDES asked Virgilio
ROSA where he was and Virgilio ROSA said his house on West Chestnut. FERNANDES
told Virgilio ROSA that he would call him to meet and explained that “he got into trouble
and does not want to be moving around.” I believe that FERNANDES was going to deliver
“5" fingers of heroin to Virgilio ROSA and that Virgilio ROSA was going to have to meet
46
FERNANDES because FERNANDES did not want to be “moving around” with the heroin,
after recently being arrested with 40 grams of heroin.
ROSA. FERNANDES told Virgilio ROSA that he was “ready with it” and told Virgilio
ROSA to meet FERNANDES at Tedeschi in Belmont. FERNANDES stated that he would
meet Virgilio ROSA in five to ten minutes. I believe that FERNANDES was delivering five
fingers or 50 grams of heroin to Virgilio ROSA.
ii. October 18, 2010, FERNANDES Delivered Six Fingers of Heroin to Virgilio ROSA
ROSA. FERNANDES stated that the “stuff is ready and that it’s fire.” Virgilio ROSA
stated that he needed “six more.” At approximately 5:59 p.m., FERNANDES told Virgilio
ROSA to meet him at “Dino’s” in 5 minutes. I believe that FERNANDES delivered six
fingers of heroin to Virgilio ROSA.
FERNANDES told DOCANTO that he had been waiting for him and stated “I’ve walked
about 5000 meters today I’ve sold like ten fingers.” I believe that FERNANDES was
admitting that he had distributed ten fingers or 100 grams of heroin that day.
iii. October 28, 2010, FERNANDES Had HOLLIS Deliver Six Fingers of Heroin to Virgilio
ROSA, Which Was Seized From Virgilio ROSA
116. As previously detailed in Section I, Part B, iii, on October 28, 2010, a series of conversations
47
occurred during which Virgilio ROSA requested “six” finger of heroin from FERNANDES;
FERNANDES told Virgilio ROSA to meet at the laundromat; FERNANDES contacted
HOLLIS and told her who and where to meet; surveillance observed HOLLIS meet with
Virgilio ROSA; and then six fingers or approximately 60 grams of heroin was seized from
Virgilio ROSA.
II. JOSE ROSA AND HIS CRIMINAL ASSOCIATES
117. During the course of the investigation, significant information was also gathered regarding
the criminal activities of Jose ROSA and his associates. On May 26, 2010, July 1, 2010,
August 4, 2010, September 7, 2010 and November 1, 2010, 2010, the Honorable Richard G.
Stearns, United States District Judge, in the District of Massachusetts, authorized the
interception of telephone number (774) 259-9786 – target telephone # 1, used by ROSA.
ROSA was also intercepted on target telephone # 3, used by MONTEIRO, target telephone
# 5, used by BRANDAO, target telephone # 6, used by FERNANDES, target telephone #
8, used by GOMES, and target telephone # 9, used by TEIXEIRA. Between June, 2010 and
November, 2010, ROSA used target telephone # 1 to receive and distribute large quantities
of heroin, totaling in excess of one kilogram of heroin. During the course of the
interceptions, we learned that ROSA had numerous heroin sources of supply, including
Miguel FERNANDES, Carey MONTEIRO, Virgilio ROSA, Justin TEIXEIRA, and
Catherine WATTS. The interceptions further revealed that ROSA had several criminal
associates who packaged and distributed heroin on behalf of ROSA and independently,
including Tiffany Marie ANDRADE, Alessio BARBOSA, Dany BRANDAO, and Gregory
STUBBS. Interceptions also revealed that ROSA had heroin customers, who received
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quantities of heroin which indicated that said persons were redistributing the heroin to
additional unknown persons, including Robert PARSONS, and Tim TAMULEVICH.
During the course of this investigation heroin was seized from Tim TAMULEVICH, who
is a heroin customer of ROSA and who had just received heroin from ROSA.
A. ROSA’s Heroin Source of Supply – Miguel FERNANDES
118. The interception of target telephone # 1, used by ROSA, and target telephone # 6, used by
FERNANDES, revealed that FERNANDES was a heroin source of supply for Jose ROSA.
Interceptions revealed that Jose ROSA would request and receive multi-finger quantities of
heroin from FERNANDES and further distribute said heroin. The following are examples
of transactions that were intercepted between FERNANDES and ROSA.
i. July 10, 2010, ROSA’s Associate BARBOSA Received Two Fingers of Heroin from
FERNANDES
119. On July 10, 2010, at approximately 7:49 p.m., an incoming call was received on target
telephone # 1 from telephone number (508) 232-9529 – target telephone # 6. ROSA spoke
to FERNANDES. FERNANDES asked ROSA what he wanted and ROSA stated “three”.
I believe that ROSA wanted “three” fingers of heroin from FERNANDES and that
FERNANDES was going to deliver the heroin.
telephone # 1 from a telephone with IMS number 316010162871302. ROSA spoke to
BARBOSA. BARBOSA told ROSA that he needed the “loot” and explained that “Miguel”
was coming over. ROSA told BARBOSA to see how much he had there. ROSA explained
that he had more “loot” to put on top of that. ROSA told BARBOSA that he is bring “3" and
that “three fingers is 1900 . . . 1800 I mean.” At approximately 8:50 p.m., BARBOSA told
49
ROSA that “I got 1800 in the safe.” I believe that “Miguel” is a reference to Miguel
FERNANDES; that FERNANDES was going to deliver three fingers or thirty grams of
heroin to ROSA and that BARBOSA was going to count the “loot” or money and determine
whether he had the $1800 to pay FERNANDES; and that BARBOSA had $1800 in a safe
that was going to be used to pay FERNANDES for the heroin.
BARBOSA. BARBOSA told ROSA that “Miguel” “he took 12 instead of 1800 for 2 all he
had.” I believe that BARBOSA met with “Miguel”; that “Miguel” is FERNANDES; that
FERNANDES delivered “two” fingers of heroin or 20 grams of heroin; and that BARBOSA
paid FERNANDES $1200 for the heroin.
ii. August 5, 2010, ROSA and BARBOSA received Six Fingers of Heroin from FERNANDES
BARBOSA. BARBOSA told ROSA “I have a play for a finger at $800 and I need a 50
white.” ROSA stated that he did not have any fingers. BARBOSA asked if he could get
one. ROSA stated that he probably had “$800 in 40s.” BARBOSA stated that he could call
“Miguel” for one. ROSA stated that he was about to call “Miguel.” BARBOSA told ROSA
to call him for “6 and sell me one.” I believe that BARBOSA had a customer that wanted
a “finger” or 10 grams of heroin; that ROSA did not have a finger available; that ROSA was
going to contact “Miguel” or FERNANDES for the heroin; and that BARBOSA wanted
ROSA to get “6" or 60 grams of heroin and give one finger or 10 grams of heroin to
BARBOSA for distribution.

50
telephone # 1 to telephone number (508) 232-9529 -- target telephone # 6. ROSA spoke to
FERNANDES. FERNANDES stated “she’s coming to meet me”. ROSA asked
FERNANDES if he wanted to go to “Alessio’s” and “get the money” and FERNANDES
agreed and confirmed that ROSA wanted “6" for which ROSA stated that he would pay
“$4000.” I believe that FERNANDES was going to meet with his female source of supply;
that FERNANDES was going to meet with “Alessio” BARBOSA to receive $4,000 for
payment of the heroin; and that ROSA and BARBOSA were going to receive 6 fingers of
heroin or approximately 60 grams of heroin.
BARBOSA. ROSA asked BARBOSA “how many pieces are left” and BARBOSA stated
“I just got work give me a minute to break it down.” ROSA asked “Miguel already brought
it” and BARBOSA stated that “I just got it.” I believe that ROSA wanted to know how
many “pieces” of heroin were available for distribution and that BARBOSA indicated that
“Miguel” FERNANDES had just brought “work” or additional heroin, which I believe was
6 fingers of heroin.
iii. August 6, 2010, ROSA and BARBOSA Received Five Fingers of Heroin from FERNANDES
FERNANDES. ROSA asked FERNANDES “did the girl come”. FERNANDES stated that
he was trying to hook up right now. ROSA told FERNANDES to “call her, I’ll take 5.”
FERNANDES stated “I’m going to call her and call you right back.” I believe that “girl”
51
was reference to VICENTE; that ROSA wanted “5" fingers of heroin or 50 grams of heroin;
and that FERNANDES was going to reach out for his source of supply.
telephone # 1 to a telephone with IMS number 316010162871302. ROSA spoke to
BARBOSA. ROSA told BARBOSA that she only has “5 for now and that he owes Miguel
1600.” ROSA explained “we’ll get 5 now and tomorrow we will get 20.” I believe that
ROSA’s reference to “she” was a reference to FERNANDES’ heroin source of supply; that
ROSA was going to get “5" fingers or 50 grams of heroin today; and that ROSA was hoping
to get “20" or 200 grams of heroin the following day.
FERNANDES. ROSA told FERNANDES to tell the “female” that he “wants 6 and
tomorrow he wants 20.” ROSA told FERNANDES that “Dany” will bring him the money.
I believe that ROSA wanted FERNANDES to get 6 fingers of heroin from his source of
supply today and 20 fingers of heroin tomorrow, for ROSA and that Dany BRANDAO was
going to deliver the money to FERNANDES for the heroin.
telephone # 1 from telephone number (774) 444-6122. ROSA spoke to BRANDAO.
BRANDAO told ROSA that “Alessio” gave me “46". ROSA explained that “I owe Miguel
16. BRANDAO explained that “he gave me 46 I put my 6 that’s 52.” I believe that this
conversation concerned money; that “Alessio” BARBOSA gave BRANDAO “46" or $4600
to give to FERNANDES for payment for heroin; and that BRANDAO added his own “6"
or 600 which was also payment for heroin.

52
iv. August 21, 2010, ROSA and BARBOSA Received 14 Fingers of Heroin from FERNANDES
FERNANDES told ROSA that he talked to the “dude.” ROSA asked FERNANDES “if they
can get it for 525.” FERNANDES stated that he was not sure. ROSA stated “he wants to
get 30 fingers.” FERNANDES stated “he’ll probably do $550 each for the 30 fingers.”
ROSA told FERNANDES that he would do “20 at a time for $550 each”. FERNANDES
stated that “the female connect may do 525 each straight money.” I believe that
FERNANDES had spoken to the “dude” or his male heroin source of supply; that
FERNANDES believed that the source would sell the heroin for $550 each for 30 fingers or
300 grams of heroin; that ROSA wanted 20 fingers of heroin or 200 grams of heroin for
$550; and that FERNANDES thought that his alternate female source of supply might sell
the fingers of heroin for $525 each.
telephone # 1 to telephone number (508) 232-9529. ROSA spoke to FERNANDES.
FERNANDES stated that “the guy who has the 15 for them has the same stuff . . . and is
holding it for them.” FERNANDES stated “600.” ROSA told FERNANDES to tell them
to wait until morning. I believe that FERNANDES had spoken to one of his heroin sources
of supply; that the source of supply had 15 fingers of heroin available for distribution; and
that the price for the heroin was going to be $600 per finger of heroin.
131. On August 21, 2010, at approximately 11:40 a.m., an outgoing call was placed on target
telephone # 1 to telephone number (508) 232-9529. ROSA spoke to FERNANDES. ROSA
asked FERNANDES “you want to get that thing.” ROSA explained “I have the money all
53
ready in Brockton.” FERNANDES stated that “I’ll call him.” I believe that ROSA wanted
FERNANDES to reach out for his heroin source of supply and get heroin for ROSA.
FERNANDES stated “he just called me he said he is gonna bring it in like ½ hour.” ROSA
told FERNANDES that “I’ll bring it to you now.” I believe that FERNANDES had heard
from his heroin source of supply; that FERNANDES was going to receive heroin for ROSA
from his source of supply in approximately one half hour; and that ROSA was going to
deliver “it” or the money for the heroin to FERNANDES.
BARBOSA. ROSA told BARBOSA to have “9" ready and to put it in a bag. I believe that
ROSA wanted “9" or $9,000 from BARBOSA to give to FERNANDES to pay for the heroin
that FERNANDES was going to receive from his source of supply.
telephone # 1 to telephone number (508) 232-9529. ROSA spoke to FERNANDES.
FERNANDES stated that “I have the thing he said he thought he had 15 he had only 14 but
he brought it to me. FERNANDES stated that he was home and coming now. I believe that
FERNANDES received 14 fingers of heroin from his source of supply and was going to be
delivered to ROSA.
v. September 16, 2010, ROSA and ANDRADE Received Fifteen Fingers of Heroin from
FERNANDES
54
telephone # 6 from target telephone # 1. FERNANDES spoke to ROSA. FERNANDES told
ROSA that he had spoken to the “guy”; that the guy had “fourteen to fifteen”; but that “he
won’t do it for the price he told you before.” ROSA stated that he wanted to get more than
that. FERNANDES explained to ROSA that he told him “40" and that “he said Sunday he
may have it.” ROSA stated to “[c]heck me here at Menlo” and FERNANDES stated that “I
will go there we will talk.” I believe that ROSA wanted a quantity of heroin from
FERNANDES; that FERNANDES had spoken to his source of supply; that the source of
supply had 14 or 15 fingers of heroin available for distribution; that ROSA wanted 40 fingers
of heroin but that the source of supply did not have that quantity available for distribution
at this time; and that ROSA and FERNANDES were going to meet in person to discuss the
details.
telephone # 1 from telephone number (508) 933-6943. ROSA spoke to “Tiffany” believed
to be Tiffany Marie ANDRADE. ROSA asked Tiffany ANDRADE to do him a favor.
ROSA explained “I need you to go to the crib and get 8425 . . . and bring it near Hamilton
where Miguel stays.” I believe that ROSA wanted Tiffany ANDRADE to get $8425 and
deliver the money to FERNANDES, which was payment for 14 or 15 fingers of heroin.
telephone # 6 to target telephone # 1. FERNANDES spoke to ROSA. ROSA told
FERNANDES to come outside and that “she” will be there in a second. FERNANDES
stated that he was outside waiting. ROSA told FERNANDES to wait on the driveway and
explained that “she” will be there any minute. I believe that “Tiffany” was delivering
“8425" dollars to FERNANDES which was payment for 14 or 15 fingers of heroin.

55
to be Tiffany Marie ANDRADE. Tiffany ANDRADE told ROSA that the “staties have
somebody posted in front of Dairy Queen . . . [and that] she is outside Miguel’s now.”
to be Tiffany Marie ANDRADE. Tiffany ANDRADE told ROSA that she was home now.
Tiffany ANDRADE stated that there were staties “near Minot, up near the fairgrounds, they
are still at Dairy Queen, so I am the fuck out of here, I am home.” ROSA told Tiffany
ANDRADE “your legit” and Tiffany ANDRADE stated “I know I am legit, but I am also
not legit in a way, too, because I don’t have a license for the other things.” ROSA responded
“he already gave it to you” and Tiffany ANDRADE said yes. ROSA told Tiffany
ANDRADE to leave it there. I believe that Tiffany ANDRADE delivered the money to
FERNANDES, that FERNANDES gave Tiffany ANDRADE 15 fingers of heroin and that
Tiffany ANDRADE brought the 15 fingers or 150 grams of heroin to 24 Central Street in
Easton, MA where Tiffany ANDRADE resides with ROSA.
vi. September 24, 2010, ROSA Received One Finger of Heroin from FERNANDES and
Delivered Two Fingers of Heroin to TAMULEVICH, Which Was Seized from TAMULEVICH
target telephone # 1 from telephone number (508) 232-8703. ROSA spoke to
TAMULEVICH. TAMULEVICH asked ROSA if he had the same stuff. TAMULEVICH
asked ROSA “[c]an I get 2 of them.” ROSA stated that he could only do one right now.
I believe that TAMULEVICH wanted two fingers of heroin but that ROSA only had one
56
finger of heroin available for distribution at that time.
target telephone # 6 from target telephone # 1. FERNANDES spoke to ROSA. ROSA asked
FERNANDES if he had any product and FERNANDES stated a little bit. ROSA asked
FERNANDES for “all of it” and FERNANDES told ROSA that he would call him back. I
believe that ROSA wanted heroin from FERNANDES and that FERNANDES was going to
call ROSA back.
TAMULEVICH. ROSA told TAMULEVICH to give him 20 minutes and he would have
“both of them.” I believe that ROSA was getting additional heroin and that once he received
the additional heroin he would be able to deliver two fingers of heroin to TAMULEVICH.
telephone # 1 to target telephone # 6. ROSA spoke to FERNANDES. FERNANDES told
ROSA that he was en route to his house. ROSA asked FERNANDES to meet at the same
spot. On September 24, 2010, at approximately 12:47 p.m., a pole camera located at 243
Belmont Street, Brockton, MA documented the arrival of a gray Nissan Maxima, known to
be used by DOCANTO and FERNANDES, and the fact that the car backed into the
driveway. ROSA was observed exiting the Minot Street door and walking on the driveway
out of view. At approximately 12:50 p.m., the Maxima departed the driveway and ROSA
re-entered the side door of the residence. I believe that ROSA received at least one finger
of heroin from FERNANDES, at that time.
57
telephone # 1 to telephone number (508) 232-8703. ROSA spoke to TAMULEVICH.
ROSA told TAMULEVICH to “come to Minot.” I believe that ROSA received heroin from
FERNANDES and possibly TEIXEIRA and that ROSA was now able to deliver two fingers
of heroin to TAMULEVICH.
telephone # 1 from telephone number (508) 232-8703. ROSA spoke to TAMULEVICH.
TAMULEVICH is at the door. Conversation is heard in which ROSA indicates that “Tiny”
or TAMULEVICH has something concealed within his pants. TAMULEVICH said “16"
and asked if it was “the same right” which ROSA confirmed. I believe that TAMULEVICH
picked up two fingers of heroin and paid ROSA $1600.
146. On September 24, 2010, surveillance observed TAMULEVICH arrive at 243 Belmont Street,
which is a multi-unit dwelling that abuts Minot Street. TAMULEVICH was observed
entering the building, exiting the building and departing the area. After TAMULEVICH left
the area, a marked cruiser observed the driver of the vehicle, in which TAMULEVICH was
the passenger, run a stop sign. The vehicle was pulled over. The Officer observed the
passenger of the vehicle fidgeting in his pants area and at a later point, remove something
from his pants area and relocate the item. The Officer conducted a search of the shoe and
found two cylinder type packages, which is believed to be heroin and weighed
approximately 22 grams. The passenger was determined to be TAMULEVICH and was
arrested for possession with intent to distribute heroin. TAMULEVICH made a statement
that he paid $800 for the fingers. TAMULEVICH is not cooperating. TAMULEVICH has
been released on bond.
B. ROSA’s Heroin Source of Supply – Ismael FIGUEROA a/k/a UM3553

58
i. November 3, 2010, ROSA Received Four Fingers of Heroin from FIGUEROA at 24 Central
Street in Easton, MA, facilitated by ANDRADE
147. On November 3, 2010, at approximately 2:08 p.m., an outgoing call was placed on telephone
# 1 to telephone number (978) 394-3553. ROSA spoke to UM3553, a new heroin source of
supply, later determined to be Ismael FIGUEROA. ROSA said “you’re gonna bring me 6,
right?” FIGUEROA said yeah and then explained “I can bring you 4 and then I’ll owe just
2.” At approximately 6:35 p.m., FIGUEROA told ROSA that “I’ll be there in 25.” I believe
that FIGUEROA is a heroin source of supply and that FIGUEROA was en route to deliver
“4" fingers of heroin.
148. On November 3, 2010, at approximately 6:52 p.m., an incoming call was received on target
telephone # 1 from telephone number (774) 360-4898. ROSA spoke to ANDRADE.
ANDRADE told ROSA “what you told me . . . but there’s still not going to be enough. I
didn’t count the 50's.” ROSA told ANDRADE to “[g]o in the jeans too.” I believe that
ANDRADE is looking for money to pay FIGUEROA; that ANDRADE had not yet found
enough money but that ROSA directed ANDRADE to the “50's” or $50 bills; that
ANDRADE was collecting money to pay FIGUEROA because ROSA had informed
ANDRADE that FIGUEROA was going to be delivering heroin to ANDRADE and that
ANDRADE was going to have to pay FIGUEROA for the heroin.
149. On November 3, 2010, at approximately 7:31 p.m., an incoming call was received on
telephone # 1 from telephone number (978) 394-3553. ROSA spoke to FIGUEROA. ROSA
asked FIGUEROA whether he was there. FIGUEROA said yeah and ROSA stated “My girl
is about to come outside and let you come in.” I believe that FIGUEROA was delivering the
heroin to ANDRADE at 24 Central Street, in Easton, MA.

59
150. On November 3, 2010, at approximately 7:31 p.m., an outgoing call was placed on target
telephone # 1 to telephone number (774) 360-4898. ROSA spoke to ANDRADE. ROSA
told ANDRADE to “open the door for the dude outside. Just bring him in the living room
and just give it to him.” I believe that the “dude” was FIGUEROA; that ANDRADE was
going to let FIGUEROA into 24 Central Street; that ANDRADE was going to take
possession of the four fingers of heroin; and that ANDRADE was going to “give it to him”
or pay FIGUEROA for the heroin.
151. On November 3, 2010, at approximately 7:40 p.m., surveillance observed a Nissan sedan
parked in the left side of the driveway at 24 Central Street, Easton, MA. Agents observed
that the car was running; that the driver’s seat was unoccupied, and that a passenger was in
the vehicle. A short time later, the vehicle was seen with a driver, exiting the driveway and
departing the area. I believe that the passenger of the vehicle was FIGUEROA and that
FIGUEROA and the driver of the vehicle delivered heroin to ANDRADE and received
money from ANDRADE, which was payment for the heroin, at 24 Central Street in Easton,
MA.
ii. November 6, 2010, ROSA Received Twenty-Two Fingers of Heroin from FIGUEROA at 24
Central Street in Easton, MA
152. On November 6, 2010, at approximately 11:19 a.m., an outgoing call was placed on target
telephone # 1 to telephone number (978) 394-3553. ROSA spoke to FIGUEROA
FIGUEROA asked “how much you need” and ROSA said “20". FIGUEROA stated that he
would check with his cousin and let ROSA know. ROSA said “bring 22 I got nothing.” I
believe that FIGUEROA was going to deliver “22" fingers of heroin to ROSA.
153. On November 6, 2010, at approximately 5:45 p.m., FIGUEROA told ROSA that he would
60
be there in 25 minutes. At approximately 6:14 p.m., FIGUEROA told ROSA that he was
there. I believe that FIGUEROA traveled to 24 Central Street in Easton MA and was going
to meet with ROSA to deliver 22 fingers of 220 grams of heroin.
154. On November 6, 2010, at approximately 6:15 p.m., surveillance observed a Nissan Sedan
with Massachusetts Registration 6PK 450 park on the left side of the driveway at 24 Central
Street. On November 6, 2010, at approximately 6:26 p.m., ROSA stated that he would be
there in three minutes. At approximately 6:35 p.m., surveillance observed the BMW X5,
known to be used by ROSA pull into the driveway at 24 Central Street, next to the other
vehicle. I believe and that FIGUEROA and ROSA met at 24 Central Street, which is
ROSA’s residence, and FIGUEROA delivered 22 fingers of heroin to ROSA.
155. On November 6, 2010, at approximately 7:35 p.m., the Nissan with plate number 6PK 450
departed the driveway at 24 Central Street. The vehicle was followed and a car stop was
conducted. Two males were in the vehicle. The driver of the vehicle was David A. Ruiz.
The passenger of the vehicle was Ismael FIGUEROA. The driver of the vehicle was in
possession of $5,000 in cash which he stated was going to be used to purchase a vehicle.
The passenger of the car was in possession of $6,000, which FIGUEROA also said was
going to be used to purchase a vehicle. Ruiz and FIGUEROA were released. I believe that
the $11,000 in the vehicle was payment made by ROSA for 20 fingers of heroin, which is
20 fingers of heroin for $550 per finger of heroin and that the additional two fingers of
heroin was owed to ROSA by FIGUEROA from a prior transaction, as discussed in the
interceptions.
156. On November 14, 2010, conversations were intercepted between target telephone # 1 and
telephone number (978) 394-3553, used by FIGUEROA. At approximately 2:50 p.m.,

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ROSA told FIGUEROA “this shit is getting too weak” and FIGUEROA explained “I got this
other people that just brought me a whole one” and then ROSA told FIGUEROA “bring me
like 15 . . . I only have two left”. At approximately 3:59 p.m., FIGUEROA told ROSA “I’m
taking off at 6:30" and confirmed with ROSA “you want 15 right”. At approximately 7:40
p.m., a conversation occurred, during which a technical malfunction prevented hearing
FIGUEROA’s portion of the conversation, however, ROSA was heard stating “I got to grab
the dough”. At approximately 7:56 p.m., FIGUEROA told ROSA that he would be 25
minutes. Shortly thereafter, a car stop was conducted on the vehicle being used by
FIGUEROA. FIGUEROA and David Ruiz were found to be in the vehicle. A canine alerted
to the presence of narcotics in the front of the vehicle. The vehicle was towed to a safe place
and searched. No narcotics were found. No search was conducted of FIGUEROA or Ruiz.
At approximately 10:22 p.m., FIGUEROA placed a call to ROSA and told ROSA that he had
been stopped again and that the car had been searched. FIGUEROA told ROSA “I’m going
there to take this. . . . I’ll be there in like 20 . . . straight to your crib”. The following
morning, at approximately 8:22 a.m., ROSA contacted FIGUEROA, stated that he was en
route, and asked to be texted the address. Surveillance was established and ROSA traveled
to 48 Whiting Street in Lynn, MA, which is the same location where FIGUEROA had been
located the previous evening, prior to traveling to meet ROSA. ROSA detected surveillance
while en route back to Brockton. Once ROSA was back in the area, conversations were
intercepted on target telephone # 1, which indicated that ROSA was once again distributing
heroin. Based on the foregoing, I believe that either FIGUEROA delivered heroin to ROSA
the night of November 14, 2010, which was not discovered at the time of the car stop, or
ROSA picked up heroin from FIGUEROA on November 15, 2010.

62
C. ROSA’s Heroin Source of Supply – Carey MONTEIRO
157. During the course of the interception of target telephone # 1, used by ROSA, interceptions
were obtained which revealed that Carey MONTEIRO was a heroin source of supply for
ROSA. As detailed below, ROSA received finger quantities of heroin from MONTEIRO
on several occasions, early in this investigation. On July 12, 2010, approximately two
fingers of heroin was seized from Flavio OLIVEIRA, who was a heroin customer of
MONTEIRO and who had received said heroin from MONTEIRO. The following
interceptions are examples of the heroin trafficking activities that occurred between ROSA
and MONTEIRO during the charged conspiracy.
i. June 7, 2010, ROSA Received Eight Fingers of Heroin from MONTEIRO
158. On June 7, 2010, a series of conversations were intercepted on target telephone # 1, during
which ROSA requested “5" fingers of heroin from MONTEIRO and then an additional “3"
fingers of heroin, for a total of eight fingers or 80 grams of heroin. MONTEIRO was
surveiled making two separate deliveries to 19 West Chestnut Street, which was a residence
of Virgilio ROSA, a criminal associate of ROSA, which I believe were the two separate
deliveries of heroin.
159. On June 7, 2010, at approximately 2:42 p.m., an outgoing call was placed on target
telephone # 1 to a telephone with IMS number 316010150580963. ROSA spoke to Virgilio
ROSA. ROSA asked Virgilio ROSA where he was at and Virgilio ROSA stated “I’m about
to get over there.” ROSA told Virgilio ROSA to go to his “crib so you can go meet that
chick over there.” ROSA explained that “she should be there right now, and just be secret
please she doesn’t want to be in that area.” I believe that ROSA was instructing Virgilio
ROSA to go to his “crib” located at 19 West Chestnut Street because MONTEIRO was en
63
route to deliver five fingers of heroin to Virgilio ROSA, at West Chestnut.
telephone # 1 to telephone number (857) 334-6102. ROSA spoke to MONTEIRO. ROSA
asked MONTEIRO if she could “make it 5.” MONTEIRO stated that she could turn around.
ROSA confirmed “5" and MONTEIRO agreed. At approximately 3:04 p.m., MONTEIRO
stated that she would be there in five minutes. I believe that ROSA wanted five fingers of
heroin and that MONTEIRO was going to deliver the five fingers or 50 grams of heroin to
Virgilio ROSA, a criminal associate of ROSA.
161. On June 7, 2010, at approximately 3:20 p.m., surveillance observed a black Saab bearing
Massachusetts Registration 54FW75 pull into the driveway of 19 West Chestnut Street.
After about three minutes, the black Saab departed the driveway. The driver of the vehicle
was observed to be a light skinned female in her late 20s or early 30s. I believe that the
woman was MONTEIRO and that MONTEIRO traveled to 19 West Chestnut and delivered
5 fingers of heroin to Virgilio ROSA.
162. On June 7, 2010, at approximately 8:37 p.m., an incoming call was received on target
telephone # 1 from telephone number (617) 202-1163. ROSA spoke to MONTEIRO a/k/a
UF1163. ROSA stated that “I want 3 more.” MONTEIRO stated that she would be there
in 25 minutes. At approximately 9:14 p.m., MONTEIRO asked if anyone was there and
ROSA stated that he would be there in one minute. MONTEIRO stated that she would be
right there. I believe that ROSA wanted “3" more units of heroin from MONTEIRO and
that MONTEIRO was delivering the heroin to ROSA at 19 West Chestnut Street.
163. On June 7, 2010, at approximately 9:20 p.m., surveillance observed a white Cadillac
Escalade with Massachusetts registration number 593 CB2, known to be used by ROSA, pull
64
into the driveway at 19 West Chestnut Street. Approximately two to three minutes later a
black Saab bearing Massachusetts Registration 54FW75 also pulled into the driveway of 19
West Chestnut Street. At approximately 9:50 p.m., the Escalade and Saab departed the
driveway at 19 West Chestnut Street. I believe that MONTEIRO traveled to 19 West
Chestnut and delivered 3 fingers of heroin to ROSA.
ii. June 8, 2010, ROSA Received Ten Fingers of Heroin from MONTEIRO
stated “I need 8.” MONTEIRO agreed. “Jose” stated that he needed it for “550" and to make
sure it was good. MONTEIRO stated that the stuff last night wasn’t her. ROSA stated that
it was “whacked.” MONTEIRO stated that “whenever I do it its good” and that she was
doing it then and would be done in a half an hour. ROSA stated “do it real good and I’ll
grab 10.” I believe that ROSA wanted “10" fingers of heroin for $550 each and that
MONTEIRO was going to be available to deliver the heroin shortly.
asked MONTEIRO whether she was still coming and MONTEIRO stated that she was
coming right then. At approximately 10:03 p.m., MONTEIRO told ROSA that she would
be there in “15 minutes.” At approximately 10:07 p.m., ROSA asked MONTEIRO to
“swing to Danny’s place.” MONTEIRO asked the “hot spot” and stated that she would pick
him up but would not go there. ROSA told MONTEIRO to call “him” and MONTEIRO
confirmed that she had the number. ROSA stated that “he” knows what to give her. I
believe that MONTEIRO delivered “10" fingers of heroin to 117 Menlo Street.
65
iii. June 20, 2010, ROSA Received Five Fingers of Heroin from MONTEIRO
telephone # 1 to telephone number (617) 202-1163 – target telephone # 3. ROSA spoke to
MONTEIRO. ROSA told MONTEIRO that he was trying to get “10" depending on the
quality. MONTEIRO stated that she had “5" for you right now. MONTEIRO told ROSA
to ask “Danny” how it was and explained that “I saw him last night.” ROSA stated that he
was going to “grab a piece from him” and see. ROSA stated that he would call “Danny.”
I believe that ROSA wanted “10" fingers of heroin or approximately 100 grams of heroin
from MONTEIRO; that MONTEIRO had “5" or 50 grams of heroin available; that ROSA
was concerned regarding the quality of the heroin; that MONTEIRO told ROSA to ask
“Danny,” regarding the quality because MONTEIRO had given heroin to “Danny,” the
previous evening; and that “Danny” is reference to Flavio OLIVEIRA.
iv. July 2, 2010, ROSA Received Five Fingers of Heroin from MONTEIRO
167. On July 2, 2010, at approximately 11:52 a.m., an outgoing call was placed on target
telephone # 1 to telephone number (617) 331-7118 – MONTEIRO’s second telephone.
ROSA spoke to MONTEIRO. ROSA told MONTEIRO to “bring me five.” MONTEIRO
stated that she was busy but that she would be on her way as soon as she was done. I believe
that ROSA wanted “five” units of heroin from MONTEIRO.
168. On July 2, 2010, at approximately 2:50 p.m., an outgoing call was placed on target telephone
# 1 to telephone number (617) 331-7118 – MONTEIRO’s second telephone. ROSA spoke
to MONTEIRO. ROSA asked MONTEIRO to bring “another six.” MONTEIRO stated that
she could “give you four right now” and then come back later. MONTEIRO explained that
the “rest of it is in Boston.” MONTEIRO stated that she would be there in two minutes. I
66
believe that ROSA wanted “six” fingers or approximately 60 grams of heroin; that
MONTEIRO only had “four” fingers or 40 grams of heroin with her; and that MONTEIRO
keeps or stashes her heroin somewhere in Boston.
# 2 to a telephone with IMS number 316010162871302. ROSA spoke to BARBOSA.
ROSA stated that “the girl” only has “4" so “get 2 for you and 2 for Turbo.” BARBOSA
explained that she was already there and that “he got 5 from her and she gave Turbo five,
purchased with Turbo’s money.” ROSA stated that “she is bringing another 4, 2 for me and
2 for you” and that ROSA was going to call “Miguel” later. I believe that MONTEIRO
delivered five fingers or fifty grams of heroin to “Turbo,” who is believed to be Virgilio
ROSA; five fingers of heroin to BARBOSA; and that MONTEIRO was going to return with
four additional fingers of heroin or 40 grams of heroin, 20 grams for ROSA and 20 grams
for BARBOSA.
v. July 6, 2010, ROSA and BARBOSA Return Low Quality Heroin to MONTEIRO
170. On July 6, 2010, at approximately 12:12 p.m., an outgoing call was placed on target
BARBOSA. ROSA told BARBOSA that the stuff from ‘Miguel” is more brown and the
girl’s is white. ROSA stated that the “girl’s stuff is no good.” In a subsequent call at
approximately 12:21 p.m., BARBOSA told ROSA that “it’s garbage” and “I’ll put it all in
a bag and call the girl.” I believe that “Miguel” is a reference to FERNANDES; that the
“girl” is MONTEIRO; that ROSA had received heroin from FERNANDES and
MONTEIRO; that the quality of the heroin from MONTEIRO was not as good as the heroin
from FERNANDES; and that BARBOSA was going to call MONTEIRO and return the
67
heroin.
telephone # 3 from telephone number (774) 259-7427. MONTEIRO spoke to BARBOSA.
BARBOSA told MONTEIRO that the “shit is garbage.” BARBOSA explained that “it looks
the same crushes the same when you cook it it turns white” and “there is no rush”.
BARBOSA told MONTEIRO to come and get the “21/2.” I believe that MONTEIRO had
delivered a quantity of heroin to BARBOSA; that BARBOSA had redistributed said heroin;
that “Alexio’s” customers were complaining about the quality of the heroin; and that
BARBOSA was going to return “21/2" or two and a half fingers of heroin to MONTEIRO.
vi. MONTEIRO’s Conversation Regarding Arrest of Flavio OLIVEIRA a/k/a “Danny”
telephone # 3 to telephone number (617) 830-2515. MONTEIRO spoke to UM2515.
MONTEIRO told UM2515 that she had gone to see someone; that she had given “him two
whole ones” and the police in Brockton “ran up on both of us.” I believe that MONTEIRO
is referring to the stop and subsequent arrest of Flavio OLIVEIRA, who had approximately
two fingers of a substance which field tested positive for the presence of heroin, in his
possession as well as marijuana and a half a gram of cocaine. OLIVEIRA is not cooperating
and has been released on bond.
vii. September 8, 2010, MONTEIRO Contacts Target Telephone # 1 Regarding Sample of

Heroin
telephone # 1 from telephone number (617) 202-1163. BRANDAO, who was using ROSA’s
telephone, spoke to MONTEIRO. MONTEIRO told BRANDAO “I need to drop him off
a sample.” MONTEIRO stated that she would call back when she got to Brockton. I believe
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that MONTEIRO had a sample of heroin for ROSA and that she was going to deliver the
sample of heroin.
D. ROSA’s Heroin Source of Supply – Virgilio ROSA
were obtained which revealed that Virgilio ROSA has a heroin source of supply and that
Virgilio ROSA was supplying large quantities of heroin to ROSA, for distribution. Also
during the interception of target telephone # 1, there were interceptions which revealed that
Virgilio ROSA was also a heroin customer of ROSA, who received quantities of heroin from
ROSA for further distribution. As previously detailed in the FERNANDES section of this
Affidavit, Virgilio ROSA was also a heroin customer of FERNANDES and on October 28,
2010, six fingers or 60 grams of heroin was seized from Virgilio ROSA. The following
and Virgilio ROSA during the charged conspiracy.
i. August 22, 2010, ROSA and BARBOSA Receive Ten Fingers of Heroin from Virgilio ROSA
and BARBOSA Distributed Five Fingers of Heroin to GOMES
Virgilio ROSA. ROSA asked Virgilio ROSA “if the dude still got the same stuff.” Virgilio
ROSA stated that he “didn’t hit him up.” ROSA asked Virgilio ROSA to “set it up for
tomorrow . . . 10 . . . try to get it for 5.” I believe that ROSA wanted Virgilio ROSA to reach
out to his heroin source of supply; to try to get “10" fingers of heroin for $500 a finger.
telephone # 1 to a telephone with IMS number 316010150580963. ROSA spoke to Virgilio
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ROSA. Virgilio ROSA stated that he didn’t get in touch “with the dude yet” . . . [w]hen I
talk to him, I’m going to make that move.” I believe that Virgilio ROSA was trying to
contact his heroin source of supply to obtain heroin for ROSA and that Virgilio ROSA was
unable to reach the source of supply, so far.
telephone #1 from target telephone # 8. ROSA spoke to GOMES. ROSA told GOMES that
he was still waiting. GOMES told ROSA as soon as you get it because I got somebody
waiting. I believe that GOMES wanted five fingers of heroin from ROSA and that ROSA
was waiting for the heroin from Virgilio ROSA.
Virgilio ROSA. Virgilio ROSA stated that he had “just talked to the dude” and was going
to “go over there and grab it.” I believe that Virgilio ROSA had spoken to his heroin source
of supply and that Virgilio ROSA was going to go meet with BARBOSA, get the money for
the heroin, and get the heroin from the source of supply for ROSA.
BARBOSA. BARBOSA told ROSA “I gave Turbo 55". ROSA stated that “you weren’t
suppose to give him 55 you were suppose to give him 5250.” I believe that “Turbo” is
Virgilio ROSA; that Virgilio ROSA had collected “55" or $5,500 from BARBOSA as
payment for 10 fingers or 100 grams of heroin; and that ROSA indicated that BARBOSA
should have paid Virgilio ROSA $5250 for the heroin because the heroin was being
purchased for $525 a finger.
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telephone # 8 from target telephone # 1. GOMES spoke to ROSA. ROSA told GOMES to
go to Hunt Street “it was brought over late.” I believe that BARBOSA received ten fingers
of heroin from Virgilio ROSA and that ROSA was telling GOMES that he could go get the
heroin from BARBOSA.
BARBOSA. ROSA asked if “Turbo’s” stuff “is round.” BARBOSA stated that he didn’t
even check how much “Turbo” brought. BARBOSA told ROSA “it’s all round and one
piece, so I’ll break it and give him a finger.” ROSA told BARBOSA not to “break it, to give
it to him the way it is . . . he’s buying five fingers.” ROSA told BARBOSA to “weigh it
first.” I believe that BARBOSA received ten fingers or almost 100 grams of heroin from
Virgilio ROSA and that ROSA was having BARBOSA weigh the heroin and then distribute
five of the fingers or 50 grams of heroin to GOMES.
BARBOSA. BARBOSA stated that “one of them are 50.9 the other is 40.1.” ROSA told
BARBOSA to give “him” the “50.1" and “the other one will have to be brought back.” I
believe that BARBOSA weighed the heroin that he had received from Virgilio ROSA; that
one package of heroin weighed 50.1 grams, which ROSA instructed BARBOSA to give to
GOMES and the other package contained 40.1 grams of heroin and therefore, was going to
be returned to Virgilio ROSA.
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telephone # 8 to target telephone # 1. GOMES spoke to ROSA. GOMES told ROSA to tell
“Alex” to come outside. I believe that GOMES was at Hunt Street to pick up 50 grams of
heroin from BARBOSA.
telephone # 8 to target telephone # 1. GOMES spoke to ROSA. GOMES stated that the
“thing today was short 5 grams.” At approximately 6:19 p.m., ROSA told GOMES that “the
thing was not short 5 grams and GOMES stated “the whole thing does not weigh 50 dude.”
I believe that GOMES received 50 grams of heroin from ROSA; that GOMES stated that the
heroin was short 5 grams; that ROSA disputed the claim; and that GOMES explained that
it did not weigh “50" grams.
E. ROSA’s Heroin Source of Supply – Justin TEIXEIRA
were obtained which revealed that TEIXEIRA was a heroin source of supply for ROSA. On
October 7, 2010, the Honorable Richard G. Stearns authorized the interception of target
telephone # 9, used by TEIXEIRA, which revealed that TEIXEIRA had a heroin source of
supply and varied criminal associates/heroin customers. The information obtained from
target telephone # 9 is detailed later in this Affidavit, in the TEIXEIRA portion of this
Complaint Affidavit, including a November 2, 2010, heroin seizure from TEIXEIRA. The
following interceptions are examples of the heroin trafficking activities that occurred
between ROSA and TEIXEIRA during the charged conspiracy.
i. ROSA Received Twenty Fingers of Heroin from TEIXEIRA Facilitated by ANDRADE
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TEIXEIRA. TEIXEIRA asked ROSA “what you need another one?” ROSA stated “I don’t
have anything.” At approximately 6:31 p.m., TEIXEIRA told ROSA that the “dude not
around his cousins around, he only has 30 til Monday.” ROSA told TEIXEIRA “tell him
to make it for 525.” TEIXEIRA explained that he wanted “550 each one.” ROSA asked
TEIXEIRA to tell him “to make it 525 and we will take it all.” At approximately 6:53 p.m.,
TEIXEIRA said no deal. I believe that TEIXEIRA’s source of supply had “30" fingers of
heroin available for distribution; that ROSA wanted to buy the heroin for “525" or $525 per
finger of heroin; that TEIXEIRA’s source of supply wanted $550 per finger of heroin; that
ROSA wanted to take all 30 fingers of heroin if the price was $525 per finger of heroin; and
that TEIXEIRA’s source of supply was unwilling to sell the heroin for $525 a finger.
187. On September 25, at approximately 7:52 p.m., an incoming call was received on target
TEIXEIRA. TEIXEIRA asked ROSA whether he wanted “that.” TEIXEIRA asked ROSA
how much he wanted and ROSA said “at least 20". TEIXEIRA told ROSA “I don’t have
enough to grab it.” ROSA told TEIXEIRA to give him a ½ an hour. I believe that
TEIXEIRA wanted to know whether ROSA wanted “that” or the heroin; that ROSA wanted
“20" or twenty fingers of heroin; and that TEIXEIRA did not have enough money, so that
ROSA was going to have to provide the money for the heroin.
telephone # 1 to a telephone with IMS number 316010150594540. ROSA spoke to Tiffany
ANDRADE. ROSA told Tiffany ANDRADE to “grab 11". Tiffany ANDRADE said “how
much did you say 11 hundred?” and ROSA said “no, $11,000.” Tiffany ANDRADE told
ROSA to tell him to meet her at his house. At approximately 9:19 p.m., Tiffany ANDRADE
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told ROSA that she “just gave Beckey the money.” I believe that ROSA wanted Tiffany
ANDRADE to retrieve and deliver $11,000 to “Becky” or TEIXEIRA as payment for the
20 fingers of heroin at $550 a finger, that TEIXEIRA was getting from his source of supply.
TEIXEIRA. TEIXEIRA told ROSA that “Tiffany” shorted him a stack but that he was about
to count it. ROSA told TEIXEIRA that “it suppose to be 11.” At approximately 9:31 p.m,
TEIXEIRA told ROSA that he had made a mistake and that “he has all the $11,000.” I
believe that Tiffany ANDRADE delivered $11,000 to TEIXEIRA, which was payment for
the 20 fingers of heroin.
TEIXEIRA. TEIXEIRA told ROSA that he was waiting on the dude and that it should take
about 15 minutes. ROSA confirmed “20" and TEIXEIRA affirmed. I believe that
TEIXEIRA was waiting for the heroin to be delivered.
target telephone # 1 from telephone number (508) 496-5255. ROSA spoke to Tiffany
ANDRADE. ROSA asked Tiffany ANDRADE if she was alone and told Tiffany
ANDRADE “I need you to bring work home.” Tiffany ANDRADE asked “where am I
getting it.” At approximately 12:29 p.m., ROSA told Tiffany ANDRADE that he was ready.
ROSA explained that “he just got here.” ROSA told Tiffany ANDRADE that he was at
“Minot.” I believe that ROSA was at Minot Street; that TEIXEIRA had delivered 20 fingers
of heroin to ROSA; and that ROSA wanted ANDRADE to take the heroin home to 24
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Central Street in Easton, Massachusetts.
target telephone # 1 from telephone number (774) 444-6122. ROSA spoke to BRANDAO.
ROSA told BRANDAO “I am over here in the trap with about a half a thing.” BRANDAO
asked “half a tank” and ROSA said “half a big thing.” I believe that ROSA received 20
fingers of heroin from TEIXEIRA and in excess of 10 fingers of heroin from FERNANDES
and that ROSA had a “half a big thing” or 500 grams of heroin at Minot Street.
F. ROSA’s Source of Supply – Catherine WATTS
were obtained which revealed that Catherine WATTS had a heroin source of supply and
supplied ROSA with heroin on several occasions. The following interceptions are examples
of the heroin trafficking activities that occurred between ROSA and WATTS during the
charged conspiracy.
i. July 26, 2010, ROSA and BRANDAO Receive At Least One Finger Sample of Heroin from
WATTS
telephone # 1 from telephone number (617) 694-1408. ROSA spoke to UF1408, later
determined to be Catherine WATTS. WATTS asked ROSA if he was “looking for two
fingers?” WATTS told ROSA that she was the person that he would be dealing with. ROSA
stated that he had heard from Gregg that this stuff is really good. ROSA stated that he was
trying to get it for “6". WATTS stated that she can’t do it for “6" do to the high quality.
ROSA stated that he wanted a “direct steady source.” WATTS stated that he could get “two
fingers everyday.” WATTS stated that she has people who come through for “5 everyday.”
WATTS told ROSA that “her guy was ready to go now.” WATTS told ROSA that the
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lowest she can go is “750 each”. Later in the conversation, WATTS agreed to “700 each”.
I believe that WATTS is a new source of supply for ROSA; that WATTS was prepared to
deliver “two fingers” or 20 grams of heroin to ROSA; that ROSA wanted to pay “6" or $600
per finger of heroin; that WATTS stated that she wouldn’t take less than “7" or $700 a
finger; and that WATTS has other customers who take five fingers of heroin a day.
195. On July 26, 2010, at approximately 10:11 a.m., an outgoing call was placed on target
telephone # 1 to telephone number (617) 694-1408. ROSA spoke to WATTS. WATTS
asked ROSA if he was going to place an order. WATTS stated that her connection was
Dominican; that she will sell him her connection; that ROSA needs to meet the connection
and “he” has to feel comfortable with ROSA. WATTS explained that the “first order has to
be small”; that her “connect refuses to meet him on the first deal” and that “after a few deals
ROSA will be able to deal with him directly.” ROSA agreed to “two fingers” for $700. I
believe that WATTS has a Dominican source of supply; that WATTS and her source of
supply are willing to meet with and deal directly with ROSA in the future; that ROSA
wanted two fingers of heroin or 20 grams; and that ROSA was willing to pay $700 a finger
for the heroin.
196. On July 26, 2010, a series of conversations were intercepted on target telephone # 1 between
ROSA and WATTS, during which ROSA and WATTS discussed the fact that ROSA was
en route to meet WATTS. At approximately 12:22 p.m., WATTS told ROSA to park his
vehicle in the parking lot of the supermarket and that she would come over and meet him.
WATTS explained that she would be standing in front of Johnnie’s Food Master and that she
would be wearing a blue shirt and black pants. I believe that ROSA was meeting WATTS
to receive a quantity of heroin.
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197. On July 26, 2010, at approximately 12:35 p.m., surveillance observed a black BMW X5,
known to be used by ROSA, enter the Johnnie’s Food Master parking lot. Agents observed
an unknown female wearing the clothing described by the woman on the telephone, later
identified as WATTS, get into ROSA’s vehicle. WATTS exited the vehicle a few minutes
later and headed towards 25 Beacon Street in Somerville, MA.
telephone # 1 from telephone number (617) 694-1408. ROSA spoke to WATTS. WATTS
told ROSA to come into the lobby of “25 Beacon Street and buzz apartment # 27. Shortly
thereafter, surveillance observed ROSA and BRANDAO park their vehicle and enter 25
Beacon Street. At approximately 1:19 p.m., ROSA and BRANDAO were observed exiting
25 Beacon Street and proceed to the BMW. Based on the foregoing, I believe that ROSA
and BRANDAO picked up a quantity of heroin from WATTS at 25 Beacon Street, Apt. #
27, in Somerville, Massachusetts.
telephone # 1 to telephone number (617) 694-1408. ROSA spoke to WATTS. ROSA told
WATTS that ‘I took the tape off it was like 9 grams.” WATTS responded that “I’ll let him
know he’ll just bring it next time.” I believe that WATTS delivered a quantity of heroin, in
fingers to ROSA, and that at least one of the fingers was “9 grams” of heroin, instead of 10
grams of heroin. I believe that WATTS was stating that “him” or her source of supply would
make up the difference, the next time they conducted a transaction.
ii. September 2, 2010, ROSA Received Ten Fingers of Heroin from WATTS
telephone # 1 to telephone number (617) 694-1408. ROSA spoke to WATTS. WATTS told
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ROSA that “I already talked to my guy, he’s ready with whatever you need, I told him you
might grab ten and he said that whatever you need he’s got.” At approximately 12:57 p.m.,
WATTS told ROSA “talked to my guy and he would do ten for six.” ROSA stated “perfect
I’m taking it.” WATTS said “you want ten” and ROSA stated that he would be there in an
hour and a half or an hour. At approximately 12:58 p.m., an incoming call was received on
target telephone # 1 from telephone number (617) 694-1408. ROSA spoke to WATTS.
WATTS stated “I just wanted to make sure . . . but you meant 10 like a 100 right. ROSA
said yeah. I believe that WATTS source of supply was willing to supply ten fingers or
“100" grams of heroin for $600 for each finger and that ROSA was going to take the heroin.
201. On September 2, 2010, at approximately 4:29 p.m., ROSA told WATTS that he was jumping
on the highway and that he would be there in about an hour. At approximately 5:11 p.m.,
ROSA told WATTS that he was passing exit 13 by Dorchester. I believe that ROSA was
en route to meet with WATTS and receive the ten fingers of heroin.
202. On September 2, 2010, a series of conversations were intercepted between ROSA and
UM6963, who is a heroin customer of ROSA. Initially, at approximately 6:01 p.m., ROSA
told UM6963 that it would be an hour, then at approximately 7:05 p.m., ROSA told UM6963
that it was going to be 30 minutes, and then at 8:37 p.m., ROSA told UM6963 that it was
going to be 10 minutes. I believe that ROSA was in Somerville meeting with WATTS and
receiving the heroin and that after ROSA received the heroin he traveled back to Brockton
and was able to begin delivering heroin to his customers, including UM6963.
G. ROSA’s Criminal Associate – Tiffany Marie ANDRADE
were obtained which revealed that Tiffany ANDRADE was the girlfriend of ROSA as well
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as a criminal associate of ROSA, who delivered money to criminal associates for the
purchase of heroin; transported heroin; and packaged heroin for distribution, in furtherance
of the conspiracy. The following interceptions are examples of the heroin trafficking
activities that occurred between ROSA and Tiffany ANDRADE during the charged
conspiracy.
i. September 9, 2010, Tiffany ANDRADE Processes Heroin for ROSA
telephone # 1 from telephone number (508) 496-5255. ROSA spoke to Tiffany ANDRADE.
ROSA asked Tiffany ANDRADE if she was home and Tiffany ANDRADE stated she was
pulling in. ROSA told Tiffany ANDRADE that he needed her to “make 3.4 of that thing”
and explained “get a piece of paper to scoop it up with . . . 3.4 of that and .4 of the brown.”
Then at approximately 6:07 p.m., ROSA told Tiffany ANDRADE for the brown “make it
.5 try to get it rocky if you can.” I believe that Tiffany ANDRADE was processing heroin
for ROSA to distribute.
ii. September 16, 2010, ANDRADE Delivered Money to FERNANDES for Heroin and Received
Fifteen Fingers of Heroin
205. As previously detailed in Section II, A, v, of this Affidavit, on September 16, 2010, ROSA
requested “fourteen to fifteen” fingers of heroin from FERNANDES; ROSA asked
ANDRADE to deliver “8425" and deliver it to “Miguel”, which was the cost of the heroin;
ANDRADE delivered the money to FERNANDES; and when ANDRADE delivered the
money to FERNANDES, ANDRADE received and transported the fifteen fingers of heroin.
iii. September 25, 2010, ANDRADE Delivered Money to TEIXEIRA for Heroin and Transports
Heroin
206. As previously detailed in Section II, E, i, of this Affidavit, on September 25, 2010, ROSA
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requested “at least 20" fingers of heroin from TEIXEIRA; TEIXEIRA stated “I don’t have
enough to grab it”; ROSA contacted ANDRADE and asked her to “grab 11"; ANDRADE
said “how much did you say 11 hundred?” and ROSA said “no, $11,000.”; ANDRADE told
ROSA that she “just gave Beckey the money”; that TEIXEIRA delivered twenty fingers of
heroin to ROSA; and then ROSA told ANDRADE to “I need you to bring work home”,
which I believe was a reference that ROSA needed ANDRADE to transport the heroin.
iv. September 30, 2010, Conversations Between ROSA and ANDRADE Regarding Narcotics
Proceeds
207. On September 30, 2010, a series of direct connect conversations occurred between ROSA
and Tiffany ANDRADE. During the course of the conversations, ANDRADE stated “that
30 grand is mine, I’m keeping it . . . [a]nd I’m gonna take your gun and I’m gonna put it in
your car. ANDRADE stated “you ain’t got evidence it’s yours because it’s drug money . .
. [n]ow I got 30 g’s.” Later in the conversation, ROSA told ANDRADE to “put all his stuff
together and to give his mom his money.” ANDRADE stated that she will give everything
to his mother “but the inappropriate stuff she will put in . . . the vehicle.” I believe that
ROSA and ANDRADE were having an argument and that ANDRADE made statements that
there was $30,000 which was drug proceeds and a gun at ROSA’s apartment.
v. October 6, 2010, ANDRADE Delivered Money to ROSA and BRANDAO for Heroin
208. Interceptions revealed that on October 6, 2010, ROSA received 25 fingers of heroin from
UM7907. During the course of that heroin transaction, ROSA requested and ANDRADE
delivered money, which was a portion of the payment for the heroin. On October 6, 2010,
at approximately 3:21 p.m., an incoming call was received on target telephone # 1 from a
telephone with IMS number 316010150594540. ROSA spoke to Tiffany ANDRADE.
ROSA told ANDRADE “I need 92" and ANDRADE clarified “92 individual C notes or
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9200.” ROSA stated that it was the same thing. ANDRADE asked ROSA where she was
going and ROSA stated “come to Dany’s crib.” I believe that ROSA wanted ANDRADE
to deliver “92" or $9,200 to ROSA at “Dany’s” or Dany BRANDAO’s house, so that ROSA
could take the money and pay for the heroin that he was going to be getting from UM7907.
vi. November 3, 2010, Delivery of Four Fingers of Heroin to ANDRADE at 24 Central Street
in Easton, MA
209. As previously detailed in Section II, Part B, i, on November 3, 2010, ANDRADE took
delivery of four fingers of heroin from a criminal associate of FIGUEROA, as FIGUEROA
waited in the car.
H. ROSA’s Criminal Associate – Claudio ARAUJO a/k/a UM9889 a/k/a UM0389
210. During the course of the interception of target telephone # 1, numerous conversations were
intercepted between ROSA and Claudio ARAUJO, in which ROSA and ARAUJO conducted
narcotics trafficking activities. As detailed below, ARAUJO sent heroin customers to ROSA
for heroin and ARAUJO received heroin from ROSA for further distribution. Conversations
were also intercepted on target telephone # 8, used by GOMES, which indicated that
ARAUJO received heroin from GOMES, and on target telephone # 6, used by
FERNANDES, which indicated that ARAUJO received heroin from FERNANDES. The
following are summaries of some of the conversations that have been intercepted during the
course of this investigation.
i. Claudio ARAUJO Received Heroin from ROSA and Sends Heroin Customers to ROSA for
Heroin
telephone # 1 to a telephone with IMS number 316010150560389. ROSA told ARAUJO
“finger for 7". ROSA explained “I have to charge 7". ARAUJO told ROSA “your crazy I
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send Alex plays all the time, I’m sending you a play and then I re-up from who else? You.”
ROSA stated “I want the 7 for a finger”. At approximately 1:58 p.m., ARAUJO told ROSA
“the play was there”. ROSA asked “what do they want” and ARAUJO said “2". ROSA
stated that he was pulling up. I believe that ARAUJO was admitting that he was sending
heroin “plays” or customers to ROSA and BARBOSA. I also believe that ARAUJO and
ROSA were discussing the price of a finger of heroin, which ARAUJO, based on subsequent
conversations, purchased from ROSA for $650.
telephone # 1 from telephone number (508) 375-8346. ARAUJO told ROSA to go to third
and ROSA asked “you got three people there and ARAUJO stated “it’s three pieces.” ROSA
told ARAUJO to send “them to Hamilton.” I believe that ARAUJO was sending heroin
“plays” or customers to ROSA.
telephone # 1 from a telephone with IMS number 316010150560389. ARAUJO told ROSA
“I got this other play for ½ finger”. ROSA asked ARAUJO “you want a finger too” and
ARAUJO stated “just a ½ I still got 4 things left 4 grams.” At approximately 6:12 p.m.,
ARAUJO told ROSA that he was about to be on Hamilton to pick up the ½. At
approximately 6:33 p.m., ROSA asked ARAUJO if he wanted “pieces instead” and
ARAUJO asked “how much do you make out of a half” and ROSA answered “14, 13.” At
approximately 6:38 p.m., ROSA told ARAUJO that he would give him “15 40s already
bagged up to make his life easier.” I believe that ARAUJO was sending a heroin “play” or
customer to ROSA and that ARAUJO was buying a half a finger of heroin from ROSA,
which was bagged and ready for further distribution.
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telephone # 1 from a telephone with IMS number 316010150560389. ARAUJO told ROSA
“I’m sending one your way for 3 browns.” ARAUJO also stated “I need a half I’m about to
come pick it up you got it with you. ROSA stated that he would call when he got to Menlo.
I believe that ARAUJO was sending heroin “plays” or customers to ROSA and that
ARAUJO was going to Menlo Street to pick up a “half” a finger of heroin.
telephone # 1 from telephone number (508) 375-8346. ARAUJO told ROSA “same people
in the Audi about to go to Minot”. ROSA said not to send them there and explained that the
landlord was there. ROSA asked what they wanted and ARAUJO said “[p]robably 4 more”.
ROSA to ARAUJO to send them to Menlo. I believe that ARAUJO was sending heroin
“plays” or customers to ROSA.
target telephone # 1 from telephone number (508) 375-8346. ARAUJO asked ROSA
“[w]here should I send him” and ROSA asked who. ARAUJO said “the dude yesterday
wants 4 and the girl wants 2". ROSA said to send the dude to Menlo. I believe that
ARAUJO was sending heroin “plays” or customers to ROSA.
ii. Claudio ARAUJO Received Heroin from FERNANDES
telephone # 6 from telephone number (508) 375-8346. FERNANDES spoke to ARAUJO.
ARAUJO told FERNANDES “I have a play for you right now for a half.” FERNANDES
agreed. ARAUJO stated that its for “JA” who has a car and will meet him. I believe that
ARAUJO was sending heroin “plays” or customers to FERNANDES.
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ARAUJO. ARAUJO told FERNANDES “a whole one”. FERNANDES stated that he
would swing through in ten minutes and ARAUJO stated “I’ll give you 600.” I believe that
FERNANDES was going to deliver one finger of heroin to ARAUJO and that ARAUJO was
going to pay FERNANDES $600.
iii. Claudio ARAUJO Received Heroin from GOMES
telephone # 8 from telephone number (774) 259-9889. GOMES spoke to ARAUJO.
ARAUJO asked GOMES if he sold “fingers”. GOMES stated “I’ll sell one for $650.”
ARAUJO stated that he would tell the guy. I believe that ARAUJO wanted to know whether
GOMES would sell a “finger” or 10 grams of heroin; that GOMES was willing to sell a
finger; that the price for the finger was $650; and that ARAUJO was going to check with his
associate to determine whether the associate wanted the finger of heroin.
telephone # 8 to telephone number (774) 259-9889. GOMES spoke to ARAUJO. ARAUJO
stated “he wants a ½ a finger.” GOMES and ARAUJO discussed where GOMES should
deliver. I believe that ARAUJO's associate wanted “½ a finger” or 5 grams of heroin.
telephone # 8 from telephone number (774) 259-9889. GOMES spoke to ARAUJO.
ARAUJO told GOMES “I need half a finger.” GOMES told ARAUJO to go to Hunt Street.
I believe that ARAUJO wanted a “half a finger” or 5 grams of heroin.
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telephone # 8 to telephone number (508) 408-3507. GOMES spoke to UM3507, later
identified as Ivan FONSECA. GOMES told FONSECA to “make 5 grams and the boy will
be there in a few.” I believe that FONSECA was being instructed to prepare 5 grams of
heroin and to give said heroin to ARAUJO or a friend of ARAUJO.
I. ROSA’s Criminal Associate – Alessio BARBOSA
were obtained which revealed that BARBOSA was a criminal associate of ROSA.
Interceptions revealed that BARBOSA received quantities of heroin, packaged said heroin,
distributed the heroin, and collected narcotics proceeds, at the direction of ROSA and
independently. Interceptions also revealed that BARBOSA carried a weapon and
participated in a violent act against a criminal associate of BARBOSA and ROSA. As
previously discussed, interceptions of target telephone # 6 also revealed that BARBOSA was
a multi-finger heroin customer of FERNANDES. The following interceptions are examples
of the heroin trafficking activities that occurred between ROSA and BARBOSA during the
charged conspiracy.
i. BARBOSA Received Heroin from FERNANDES for ROSA on July, 10, 2010, August 5, 2010,
August 11, 2010, and August 21, 2010
224. As detailed in Section II, Part A, i,ii,iv, on July 10, 2010, August 5, 2010, and August 21,
2010, BARBOSA facilitated a multi-finger heroin transaction between ROSA and
FERNANDES, including the receipt of the heroin, payment of money for the heroin; and/or
further distribution of the heroin.
ii. BARBOSA Received Heroin from MONTEIRO for ROSA on July 2, 2010 and July 6, 2010
225. As detailed in Section II, Part C, iv, v, on July 2, 2010 and July 6, 2010, BARBOSA
facilitated a multi-finger heroin transaction between ROSA and MONTEIRO, including the
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receipt of the heroin, payment of money for the heroin; and/or further distribution of the
heroin.
iii. BARBOSA Received Heroin from Virgilio ROSA for ROSA on August 22, 2010
226. As detailed in Section II, Part D, i, on August 22, 2010, BARBOSA facilitated a multi-finger
heroin transaction between ROSA and Virgilio ROSA, including the receipt of the heroin,
payment of money for the heroin; and/or further distribution of the heroin.
iv. July 2, 2010, BARBOSA Distributed Heroin for ROSA
227. On July 2, 2010, at approximately 11:47 a.m., an incoming call was received on target
telephone # 1 from telephone number (508) 232-8703. ROSA spoke to TAMULEVICH.
TAMULEVICH told ROSA that he would be in the driveway in 1 minute. I believe that
TAMULEVICH was going to arrive at 117 Menlo Street to obtain a quantity of narcotics
from an associate of ROSA. At approximately 11:48 a.m., an outgoing call was placed on
target telephone # 1 to IMS number 316010162871302. ROSA spoke to BARBOSA.
ROSA told BARBOSA to make “Tiny” a “3.7" from the “girl’s stuff” and a “3 grams white”
and he is going to be outside in one second. At approximately 11:50 a.m., an outgoing call
was placed on target telephone # 1 to IMS number 316010162871302. ROSA spoke to
BARBOSA. ROSA asked BARBOSA whether he had a “½ finger of the girls stuff.”
BARBOSA stated no and explained “its all bagged up.” ROSA instructed BARBOSA to
“make 5 grams from the dark brown stuff that I came with.” ROSA explained that he
wanted to give “Tiny” the “girls stuff.” BARBOSA stated that he didn’t have the “girls
stuff” because “its all bagged up.” ROSA told BARBOSA to “get 4 grams and put it in one
bag.” BARBOSA asked “for Tiny” and ROSA affirmed. At the end of the conversation,
ROSA told BARBOSA that “we will have another half in 20 minutes.” I believe that this
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conversation concerned a pending delivery of narcotics from BARBOSA to
TAMULEVICH; that ROSA was instructing BARBOSA to give “Tiny” or TAMULEVICH
the “girls stuff” or possibly heroin provided by MONTEIRO; that BARBOSA had “bagged”
or prepared all the heroin to be distributed; that ROSA instructed BARBOSA to put “4
grams” of heroin together for “Tiny”; and that ROSA indicated that he was going to get an
additional quantity of heroin within the next 20 minutes.
v. BARBOSA’s Use of Gun in Furtherance of Narcotics Trafficking
telephone # 5 from telephone number (774) 259-7427. BRANDAO spoke to BARBOSA.
BARBOSA and BRANDAO discuss the fact that BARBOSA was moving. BRANDAO
told BARBOSA that he was moving to a place with “shootings and drug dealing.”
BARBOSA stated that “where I go my hammer goes with me.” I believe that BARBOSA.
carries his “hammer” or gun with him, during the course of his narcotics trafficking
activities.
vi. July 21, 2010, Violence by ROSA, BARBOSA, and BRANDAO Against Mark Stubbs, in
Furtherance of Narcotics Trafficking Activities
229. On July 21, 2010, a series of conversations were intercepted which revealed that ROSA
believed that Mark Stubbs, a small time heroin customer of ROSA, had stolen narcotics
proceeds from ROSA and that ROSA and BARBOSA committed a violent act against Mark
Stubbs.
telephone # 5 from telephone number (508) 496-5255. BRANDAO spoke to ROSA, who
was using Tiffany’s telephone. ROSA told BRANDAO that “Mark” got me. ROSA
explained that he had stashed “4G’s” . . . “at the crib in Stoughton” and that “a piece of the
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sheetrock missing . . . so I know for a fact he went there . . . we got to . . . bring him to Hunt
Street we will go with the thing and take all the money he has on him right now.” I believed,
based on this conversations and others, that ROSA suspected that Mark STUBBS had stolen
cash from ROSA, which was narcotics proceeds and that ROSA wanted BRANDAO to bring
a “thing” or a gun, meet with ROSA, and threaten/harm “Mark” STUBBS, in an attempt to
get ROSA’s money back from Mark STUBBS.
231. Even though numerous law enforcement actions were taken, a violent act was committed on
Mark Stubbs. On July 21, 2010, at approximately 10:00 p.m., police officers were at the
scene in the area of 215 Court Street. Upon arrival, the officers observed five males, three
of whom left the area, without identification. Shortly thereafter, Mark STUBBS came
walking out of the rear door. He was bleeding from the forehead and yelling ‘I can’t believe
this shit, these motherfuckers would think I would rob them.” Gregory STUBBS, who was
present yelled to him “the police are standing right here.” Mark STUBBS then saw the
police and began to say that he had gotten into an argument with his friend while playing
video games and was sucker punched. Mark STUBBS refused medical attention and refused
to provide any more information. Mark STUBBS yelled about the location of his keys and
telephone and Alessio BARBOSA brought the keys to Mark STUBBS.
telephone # 5 to target telephone # 1. BRANDAO spoke to BARBOSA. BARBOSA told
BRANDAO “we had him up here, we broke his nose and everything.” BRANDAO asked
“Gregg’s brother” and BARBOSA affirmed. BRANDAO asked if he called the cops and
BARBOSA explained that “no, when everything finished and we were taking them out of
here, police grabbed them out back when they were going to their cars.” BARBOSA stated
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that he was “clean the blood.” BRANDAO asked “you guys beat up Mark” and BARBOSA
said “yeah.” I believe that ROSA and BARBOSA beat up Mark STUBBS in an attempt to
get narcotics proceeds back from STUBBS, which ROSA believed that STUBBS had stolen
from ROSA.
vii. August 13, 2010, BARBOSA and ROSA Discuss Potential Death Threat Against “Jigga”
BARBOSA. ROSA told BARBOSA that “he knows where Jigga is everyday.” ROSA
explained that he had someone looking for “Jigga” and that “Jigga” works 3-11 somewhere
in East Bridgewater. ROSA told BARBOSA that “we should go get him at work.”
BARBOSA stated that they “will shoot him up blast him with bullets block him shoot him
right in his car . . . shoot him twice in the head then put two more in his head and then we
bounce.” ROSA stated that “I bought something crazy too the other day.” BARBOSA told
ROSA not to talk on the phone “when we see each other we will plan it.”
J. ROSA’s Criminal Associate – Dany BRANDAO
were obtained which revealed that BRANDAO was a criminal associate of ROSA, who was
sometimes a heroin source of supply for ROSA and at times a heroin customer of ROSA as
well as a person who assisted ROSA in the receipt and distribution of heroin. As previously
detailed in the section of Alessio BARBOSA, interceptions also revealed that BRANDAO
was going to bring a gun and participate in a violent act against Mark Stubbs, a heroin
customer of ROSA. On July 1, 2010, the Honorable Richard G. Stearns, authorized the
interception of target telephone # 5, used by BRANDAO. Interceptions further revealed that
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BRANDAO had an independent heroin source of supply, specifically UM7396; that
BRANDAO received multi-finger quantities of heroin from UM7396; and that on September
2, 2010, two fingers of heroin were seized from David Eaton, who was a heroin customer
of UM7396. The following interceptions are examples of the heroin trafficking activities
that occurred between ROSA and BRANDAO and BRANDAO and UM7396, as applicable,
during the charged conspiracy. UM7396 is not presently the subject of this Affidavit.
i. June 4, 2010, BRANDAO Received and/or Distributed Heroin for ROSA
235. On June 4, 2010, at approximately 8:41 a.m., an incoming call was received on target
telephone # 1 from telephone number (781) 738-1157. ROSA spoke to UF1157.1 UF1157
asked ROSA whether she could come and “grab.” ROSA stated that she had to go to
“Brockton.” UF1157 stated that she was in Brockton. ROSA asked UF1157 whether she
was waiting for “one.” At approximately 8:43 a.m., an outgoing call was placed on target
telephone # 1 to telephone number (774) 444-6122 – target telephone # 5. ROSA spoke to
BRANDAO. ROSA stated “2-40 on third.” BRANDAO stated “of what” and ROSA stated
“brown.” At approximately 8:48 a.m., ROSA spoke to BRANDAO. ROSA stated that “she
got there right now.” BRANDAO asked “how much does she want 2" and ROSA affirmed.
I believe that BRANDAO is a criminal associate of ROSA; that ROSA wanted BRANDAO
to deliver “2" units of a “40" bag of heroin to UF1157; and that BRANDAO did in fact,
deliver the heroin to UF1157.
ii. July 6, 2010, BRANDAO Received and/or Distributed Heroin for ROSA
1
UF1157 is not named as a target of this investigation at this time, because
UF1157 is believed to be a small time user of heroin and as such, is not the focus of this
investigation.
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telephone # 5 from target telephone # 1. BRANDAO spoke to ROSA. ROSA told
BRANDAO to make “six forties.” ROSA explained that “I got two people going over there
for three.” ROSA told BRANDAO that he would call when they get there. At
approximately 7:45 p.m., ROSA told BRANDAO to “bring those six outside.” BRANDAO
confirmed that it was “two different people” and ROSA affirmed. At approximately 8:09
p.m., ROSA told BRANDAO to bring “four of brown” outside. I believe that ROSA was
instructing BRANDAO to distribute heroin to customers who were coming to meet
BRANDAO.
telephone # 5 from telephone number (774) 259-9635. BRANDAO told the unknown male
that he was “at Menlo bagging up like a slave.” I believe that BRANDAO was preparing
and distributing heroin at 117 Menlo Street.
iii. September 8. 2010, BRANDAO Received and/or Distributed Heroin for ROSA
telephone # 1 to telephone number (774) 444-6122. ROSA spoke to BRANDAO. ROSA
asked BRANDAO “ did you break up all the fingers or do you have one that isn’t broken
yet.” BRANDAO explained that “I got one that isn’t broken yet.” ROSA told BRANDAO
to “make two halves and they’ll give you $800 and I’ll bring you the two that I have on me.”
I believe that ROSA wanted BRANDAO to deliver “two halves” or 10 grams of heroin to
PARSONS, and that PARSONS was going to pay BRANDAO $800 for the heroin.
iv. October 6, 2010, BRANDAO Received and/or Distributed Heroin for ROSA
239. As previously discussed in this Affidavit, on October 6, 2010, ROSA and BRANDAO
received 25 fingers of heroin from UM7907. During the course of that heroin transaction,
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ROSA requested and ANDRADE delivered money, which was a portion of the payment for
the heroin to “Dany’s crib.” Conversations were then intercepted that ROSA and
BRANDAO went to Lawrence to meet with UM7907, deliver the money for the heroin, and
receive the heroin from UM7907. During the transaction, ROSA spoke to BRANDAO. And
stated “he went inside . . . don’t know he is about to come out . . . he went in with the dough
. . . everytime I call him he says he is about to come.”
v. July 6, 2010, BRANDAO Received Two Fingers of Heroin from UM7396 And Attempts to
Deliver to BARBOSA
telephone # 5 from telephone number (857) 445-7396. BRANDAO spoke to UM7396.
UM7396 asked BRANDAO when he would be there and BRANDAO asked “which one you
got.” UM7396 stated that it was “the same shit” and that he was going to meet “with the guy
right now he gonna give it to me.” At approximately 1:33 p.m., BRANDAO asked UM7396
whether he “already got it” and UM7396 stated that it got it then and BRANDAO asked it
was “the soft shit with the peppers” and UM7396 stated that it looks the same. At
approximately 2:36 p.m., UM7396 told BRANDAO that he is there and BRANDAO stated
“I’m coming in.” I believe that UM7396 is a source of supply for BRANDAO; that
UM7396 had received narcotics from his source of supply; that the narcotics were similar
in appearance to narcotics that BRANDAO had received from UM7396 before; and that
BRANDAO was going to go get the narcotics from UM7396.
# 5 to telephone number (774) 259-7427. BRANDAO spoke to BARBOSA. BRANDAO
asked BARBOSA to “come downstairs so I can give you the shit to put upstairs real quick.”
BARBOSA asked BRANDAO “what you have” and BRANDAO responded “two fingers.”
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BARBOSA told BRANDAO to put it at his house. BARBOSA stated that he was not at the
crib. I believe that BRANDAO received two fingers of heroin from UM7396; that
BRANDAO wanted to store the heroin at 117 Menlo Street with BARBOSA; that
BARBOSA was not present and refused; and that, as observed, on the pole camera,
BRANDAO then left the area of 117 Menlo Street.
vi. August 24, 2010, BRANDAO Requests Three Fingers of Heroin from ROSA
BRANDAO told ROSA “I want 3". I believe that BRANDAO wanted “3" fingers of heroin
from ROSA.
vii. September 13, 2010, BRANDAO Requests Three Fingers of Heroin from TEIXEIRA
BRANDAO asked ROSA where he was and ROSA said Menlo. BRANDAO asked ROSA
if “Miguel out of commission or you just . . . with Becky.” BRANDAO explained “I need
another three if you want me to hit him up I will.” ROSA stated that “he is here with me.”
BRANDAO asked for another “3". ROSA told BRANDAO “he said 650.” ROSA told
BRANDAO that “he” said he will be there in ten minutes. BRANDAO stated that he was
at his crib on Kenwood. I believe that TEIXEIRA was with ROSA on Menlo Street; that
BRANDAO wanted an additional “three” fingers of heroin; and that TEIXEIRA was going
to deliver the heroin to BRANDAO on Kenwood Street.
K. ROSA’s Criminal Associate – Alector GONCALVES
i. November 2, 2010, GONCALVES Distributed Narcotics to ROSA’s Customers
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telephone # 1 to telephone number (508) 562-8091. ROSA spoke to GONCALVES. ROSA
told GONCALVES that he had a play for “2 white 1 brown”. GONCALVES stated “I have
it. Send it.” GONCALVES told ROSA “send them to my house.” I believe that ROSA had
a customer that wanted a small quantity of “white” or cocaine and “brown” or heroin; that
ROSA wanted to know whether GONCALVES had the drugs available for delivery; that
GONCALVES indicated that he had the drugs; that GONCALVES wanted the delivery to
occur at his house, which is known to be located at 16 Forest Avenue in Brockton; and that
ROSA was going to send his customer to GONCALVES house to receive narcotics.
telephone # 1 to telephone number (857) 247-3667. ROSA spoke to UM3667. ROSA asked
UM3667 whether he knew where “Forest Avenue” and gave UM3667 directions to house
number “16" on Forest Avenue. ROSA told UM3667 to pull all the way in the driveway.
GONCALVES and told GONCALVES the “dude’s going upstairs right now for the white
and brown.” I believe that UM3667 was at 16 Forest Avenue and was walking up the stairs
to meet with GONCALVES and receive narcotics.
ii. November 4, 2010, GONCALVES Distributed Narcotics to ROSA’s Customers
GONCALVES. ROSA asked GONCALVES “do you want to play for 40" and
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GONCALVES told ROSA “send them to my house.” I believe that ROSA was going to
send a heroin customer to GONCALVES te receive a small quantity of heroin.
telephone # 1 from telephone number (617) 694-6696. ROSA spoke to UM6696. UM6696
stated “I am at 16 Forest Ave.” ROSA asked if the black Escalade was in the driveway and
UM6696 affirmed. ROSA told UM6696 to “go up to the third floor and knock on the door”
and “tell him J sent you”. I believe that ROSA was directing his customer to the residence
of GONCALVES, which is 16 Forest Avenue, third floor, in order for UM6696 to receive
heroin.
L. ROSA’s Criminal Associate – Nine SILVEIRA
were obtained which revealed that SILVEIRA was a criminal associate of ROSA, who
delivered heroin on behalf of ROSA, who was a heroin customer of ROSA, and who
collected money as proceeds from the sale of heroin for ROSA. The following interceptions
are examples of the heroin trafficking activities that occurred between ROSA and
SILVEIRA during the charged conspiracy.
i. October 3, 2010, Nine SILVEIRA Distributed Heroin for ROSA
250. On October 3, 2010, a series of conversations were intercepted on target telephone # 1 and
a telephone with IMS number 316010162857119, during which ROSA tasked Nine
SILVEIRA to make “plays” or distribute heroin to ROSA’s heroin customers. For example,
at 1:08 p.m., ROSA told SILVEIRA “I got tons of plays” and SILVEIRA told ROSA “I’m
about to back to my crib and grab it now . . . the street near the bakery.” At approximately
1:59 p.m., ROSA told SILVEIRA “dude is about to be over there for 3". At approximately
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2:15 p.m., ROSA stated “a play for 2" and SILVEIRA asked “can I bring him a gram”. At
approximately 3:04 p.m., ROSA asked SILVEIRA “how many pieces you got left” and
SILVEIRA answered “9 40's”. I believe that the above referenced conversations concerned
small quantities of heroin and that SILVEIRA was distributing heroin for ROSA.
ii. November 2, 2010, SILVEIRA Received Half a Finger of Heroin from ROSA
telephone # 1 to a telephone with IMS number 316010162857119. ROSA spoke to Nine
SILVEIRA. SILVEIRA told ROSA “that is not a half”. ROSA asked “what was it” and
SILVEIRA explained that “I only bagged up . . . 480 out of that . . . feels like a good 3 ½
grams or something.” ROSA explained “I made a gram, a gram, a gram and . . . 1.5 40
which is exactly half a finger, a little less than half a finger. I believe that SILVEIRA had
received a half a finger of five grams of heroin from ROSA; that SILVEIRA had bagged up
the heroin for redistribution; and that SILVEIRA believed that he did not get the whole 5
grams of heroin.
iii. November 5, 2010 and November 6, 2010, SILVEIRA Distributed Heroin for ROSA
252. On November 5, 2010, a series of conversations were intercepted on target telephone # 1 and
a telephone with IMS number 316010162857119, during which ROSA tasked Nine
SILVEIRA to make “plays” or distribute heroin to ROSA’s heroin customers. For example,
at approximately 9:49 a.m., ROSA told SILVEIRA to wake up and explained “I got some
plays for you”. At approximately 10:38 a.m., ROSA told SILVEIRA “white boy is in your
backyard . . . wants a 40". At approximately 11:16 a.m., ROSA told SILVEIRA “sending
play for 2 to Milton in a white GMC”. On November 6, 2010, at approximately 10:25 a.m.,
ROSA told SILVEIRA “I got 2 plays going on for 3". At approximately 10:28 a.m.,
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SILVEIRA told ROSA the dude owes me “5 bucks he shorted me” and ROSA stated “next
time don’t give it to him”. At approximately 2:15 p.m., SILVEIRA asked “that play for 200
what’s he want 5 40's” and ROSA confirmed “3 for a hundred, 5 for 200". I believe that the
above referenced conversations concerned small quantities of heroin and that SILVEIRA
was distributing heroin for ROSA.
iv. November 7, 2010, SILVEIRA Received Three Fingers of Heroin from ROSA
253. On November 7, 2010, at approximately 10:42 a.m., an outgoing call was placed on target
telephone # 1 to a telephone with IMS number 316010162857119. ROSA spoke to Nine
SILVEIRA. ROSA asked SILVEIRA “what do you want” and SILVEIRA stated “another
finger”. ROSA said “just one” and SILVEIRA stated “let me get two”. ROSA told
SILVEIRA “you’re supposed to grab at least three each time you re-up” and SILVEIRA
stated “get 3". At approximately 2:02 p.m., ROSA asked SILVEIRA “you at the crib” and
SILVEIRA stated yeah. ROSA stated “I am about to go over there”. At approximately 2:26
p.m., ROSA told SILVEIRA to come out. I believe that SILVEIRA wanted “3" fingers of
heroin from ROSA and that ROSA was meeting with SILVEIRA to deliver the heroin.
254. On November 7, 2010, at approximately 2:24 p.m., surveillance observed a black BMW X5,
known to be used by ROSA pull into the driveway of 298 N. Warren Avenue in Brockton,
MA. And park in front of the garage. Surveillance observed Nine SILVEIRA exit the
residence from the side door and at approximately 2:28 p.m. SILVEIRA got into the rear
passenger seat of the black BMW. At approximately 2:31 p.m., SILVEIRA was observed
getting out of the BMW and returning to 298 N. Warren, through the side door of the
residence. At approximately 2:32 p.m., the black BMW departed the area.
M. ROSA’s Criminal Associate – Gregory STUBBS
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were obtained which revealed that STUBBS was a criminal associate of ROSA, who
delivered heroin on behalf of ROSA, who was a heroin customer of ROSA, who collected
money as proceeds from the sale of heroin for ROSA; and who set up an introduction
between ROSA and WATTS, who supplied ROSA with fingers of heroin. The following
and STUBBS during the charged conspiracy.
i. July 7, 2010, Gregory STUBBS Distributed Heroin for ROSA
# 1 to telephone number (781) 975-9066. ROSA told STUBBS that he needs “2 gs and 2
40s” outside now. STUBBS agreed and affirmed the quantities. At approximately 3:41
p.m., ROSA told STUBBS that there was a dude outside for “3 grams.” ROSA told
STUBBS that the guy would give him $250. STUBBS stated that he had a “244" that he was
bringing down that could “pass for 3.” STUBBS stated that “[i]ts one big ass rock.” ROSA
told STUBBS to tell him that it is “3 grams” and that he will give STUBBS “350" for it. I
believe that STUBBS was distributing heroin on behalf of ROSA.
ii. August 9, 2010, Gregory STUBBS Distributed Heroin for ROSA
257. On August 9, 2010, an incoming call was received on target telephone # 1 from telephone
number (781) 975-9066. ROSA spoke to Gregory STUBBS. STUBBS told ROSA that he
was “at Alex’s.” STUBBS asked “Alex,” who was in the background, “how many pizzas
he wants.” “Alex” stated “five pizzas.” STUBBS told ROSA “5 fing pizzas.” I believe that
STUBBS was working with “Alex” or BARBOSA to deliver narcotics; that STUBBS
statement “5 fing pizzas” was code for the fact that BARBOSA wanted ROSA to get an
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additional five fingers of heroin for distribution.
258. On August 10, at approximately 11:05 a.m., an outgoing call was placed on target telephone
# 1 to a telephone with IMS number 316010162871302. ROSA spoke to BARBOSA.
BARBOSA stated “I need a finger I have a play for $800.” ROSA stated “I gave you five
fingers yesterday.” I believe that ROSA delivered “five fingers” or approximately 50 grams
of heroin to BARBOSA, for distribution, on August 9, 2010.
iii. September 18, 2010, STUBBS Delivered Finger of Heroin to TAMULEVICH
TAMULEVICH. TAMULEVICH stated “I need a big one.” ROSA clarified a “whole one”
and told TAMULEVICH 15 minutes. At approximately 1:53 p.m., ROSA asked
TAMULEVICH the number to his house and TAMULEVICH stated “117". Then at
approximately 2:10 p.m., an incoming call was received on target telephone # 1 from
telephone number (781) 975-9066. ROSA spoke to STUBBS. STUBBS asked ROSA what
number on Bellevue and ROSA said “17". At approximately 2:11 p.m., an outgoing call was
placed from target telephone # 1 to TAMULEVICH and ROSA stated “my boy is outside.”
I believe that TAMULEVICH wanted a finger of heroin and that STUBBS was delivering
the heroin to TAMULEVICH’s house at 117 Bellevue.
iv. STUBBS Facilitated ROSA Meeting and Getting Heroin from WATTS
telephone # 1 from telephone number (781) 975-9066. ROSA spoke to Gregory STUBBS.
STUBBS stated that he “found some fire out of this girl in Cambridge.” ROSA asked
STUBBS if he could introduce her to ROSA. STUBBS asked ROSA “how much do you
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want to start with, just one”. ROSA asked STUBBS to ask her “how much for a whole one.”
I believe that STUBBS was a heroin customer of a woman in Cambridge, later determined
to be Catherine WATTS; that STUBBS had received heroin from WATTS that was “fire”
or a great quality; and that STUBBS was going to introduce ROSA to WATTS, so that
ROSA could get larger quantities of heroin from WATTS.
261. On July 24, 2010, a series of conversations occurred between ROSA and STUBBS regarding
the heroin available from WATTS and the price of the heroin. At approximately 2:42 p.m.,
an outgoing call was placed on target telephone # 1 to telephone number (781) 975-9066.
ROSA spoke to Gregory STUBBS. ROSA asked what the chick said and STUBBS stated
“the chick says it is fire and she sells it all the time for 8". ROSA stated “I never buy it for
8.” At approximately 4:08 p.m., an incoming call was received on target telephone # 1 from
telephone number (781) 975-9066. ROSA spoke to Gregory STUBBS. STUBBS asked
ROSA whether he wanted to go “to Cambridge and meet the girl” and ROSA said yes and
told STUBBS to pick him up. At approximately 5:10 p.m., ROSA stated that ‘I just want
one but 700 is too much. STUBBS stated that he would call ROSA back. At approximately
5:22 p.m., STUBBS told ROSA that he was “heading there” but that “she already re-upped
and didn’t get anything for Jose since he failed to negotiate a deal.” ROSA stated that he
wanted a lower price. I believe that STUBBS was going to meet WATTS; that STUBBS
was getting a small quantity of heroin from WATTS; and that WATTS did not get any
heroin for ROSA because WATTS and ROSA had failed to agree on a price for the heroin.
ROSA told STUBBS that he was with the “chick herself in Cambridge.” STUBBS spoke
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to WATTS.. STUBBS asked WATTS whether they worked “something out” and WATTS
stated “he’s all set.” ROSA got back onto the telephone and asked STUBBS “[i]t’s that
good” and STUBBS stated “off the chain.” I believe that ROSA met with WATTS and
received an unknown quantity of heroin from WATTS.
263. As previously detailed in the WATTS section of this Affidavit, on July 26, 2010, a series of
conversations were intercepted on target telephone # 1 between ROSA and WATTS, during
which ROSA and WATTS discussed the fact that ROSA was en route to meet WATTS; that
ROSA “took the tape off it was like 9 grams.” WATTS responded that “I’ll let him know
he’ll just bring it next time,” which I believe indicated that ROSA met with WATTS and
received a 9 gram sample of heroin.
telephone # 1 to telephone number (781) 975-9066. ROSA spoke to Gregory STUBBS.
ROSA told Gregory STUBBS that “we going to Kate’s”. Gregory STUBBS asked “to test”.
I believe that ROSA was going to meet with WATTS and her source of supply and that
ROSA wanted STUBBS to come along to test the quality of the heroin.
v. STUBBS Received Heroin from ROSA for Independent Distribution
STUBBS asked ROSA “how much for half a finger” and ROSA said “475.” STUBBS asked
for “$360" and ROSA held firm on “$380" and then in a subsequent call agreed to $375. In
a subsequent call, ROSA told STUBBS to go to Hunt Street.
vi. October 22, 2010, STUBBS Received Heroin from TEIXEIRA
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telephone # 9 from telephone number (781) 975-9066. TEIXEIRA spoke to STUBBS.
STUBBS asked TEIXEIRA “how much do you want for 4 gs”. STUBB explained that he
wanted “4 gs, I got 300.” TEIXEIRA told STUBBS “I will give a 3.5 for 300.” At
approximately 5:19 p.m., STUBBS told TEIXEIRA that “I am sending Donnie for that 3.5
slice of pizza.” I believe that STUBBS wanted “4 g’s” or 4 grams of heroin from
TEIXEIRA; that TEIXEIRA was willing to give STUBBS 3.5 grams of heroin for $300; and
that STUBBS was sending a criminal associate to pick up “3.5 slice of pizza” which was
code for 3.5 grams of heroin.
vii. November 9, 2010 and November 10, 2010, STUBBS Received Heroin from ROSA
telephone # 1 from telephone number (781) 975-9066. ROSA spoke to STUBBS. STUBBS
told ROSA he was on his way and ROSA told STUBBS “go into the hallway around the
carriage and it will be there in the box”. ROSA told STUBBS to have the “straight four”
when I get out. STUBBS stated that he was on his way. At approximately 2:06 p.m.,
STUBBS asked ROSA “did you make that this morning” and ROSA said “yeah, straight 5".
STUBBS explained that “I did it free, then I got a scal . . . weighed it and it was alright”.
Agents believe that ROSA left five grams of heroin for STUBBS and that this conversation
verified that STUBBS received the heroin and was processing the heroin for further
distribution.
telephone # 1 from telephone number (781) 975-9066. ROSA spoke to STUBBS. STUBBS
told ROSA that “I need the same thing as last night”. ROSA told STUBBS to come down.
At approximately 10:13 a.m., STUBBS told ROSA that he was at the door. Agents believe
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that STUBBS was meeting with ROSA to receive five additional grams of heroin.
269. On November 10, 2010, at approximately 10:15 a.m., surveillance observed a Mercury
Marquis with Massachusetts registration 73L S50 stop in front of 24 Central Street, Easton,
MA. Surveillance observed a tall black male, recognized to be Gregory STUBBS, exit the
passenger seat of the vehicle and walk to the left side of the driveway of 24 Central Street.
STUBBS was then observed walking from the left side of the driveway, getting into the same
vehicle, and departing the area.
N. ROSA’s Heroin Customer – Robert PARSONS
were obtained which revealed that Robert PARSONS was a heroin customer of ROSA, who
received and redistributed heroin, in furtherance of the conspiracy. I believe that during the
course of the charged conspiracy that PARSON received in excess of 16 “fingers” or
approximately 160 grams of heroin. The following interceptions are examples of the heroin
trafficking activities that occurred between ROSA and PARSONS during the charged
conspiracy.
i. September 18, 2010, Finger Transaction
telephone # 1 to telephone number (781) 727-8385. ROSA spoke to PARSONS. PARSONS
asked ROSA if he could get a “finger”. ROSA stated in a half an hour. PARSONS asked
ROSA if the stuff was “rock hard or the other stuff”. ROSA stated the usual and explained
“rock hard.” PARSONS told ROSA “as soon as you get a finger call me” and ROSA stated
that is was gonna be 20 minutes. PARSONS asked if he should head over and ROSA
affirmed. At approximately 3:03 p.m., an outgoing call was placed on target telephone # 1
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to telephone number (781) 727-8385. ROSA spoke to KELLEHER, a criminal associate and
sister of PARSONS. KELLEHER stated that she needed “one and a half” and ROSA stated
‘I only got one.” ROSA told KELLEHER to meet him on Belmont. I believe that
PARSONS ordered one “finger” of heroin from ROSA; that ROSA was ready to deliver the
one finger of heroin to KELLEHER; that KELLEHER, who was picking up the heroin from
ROSA, wanted one a half fingers of heroin; that ROSA was ready to deliver the one finger
of heroin to KELLEHER; and that the delivery of the heroin was going to take place at 243
Belmont Street, which is a distribution location used by ROSA.
ii. September 19, 2010, Finger Transaction
telephone # 1 to telephone number (781) 727-8385. ROSA spoke to PARSONS. PARSONS
asked ROSA if he could get a “finger”. ROSA stated in a half an hour, forty minutes. I
believe that PARSONS wanted a finger of heroin.
iii. September 21, 2010, Finger and a Half Transaction
target telephone # 1 from telephone number (781) 727-8385. PARSONS stated that he
would be there in about an hour and ROSA stated that he would save a “half.” PARSONS
stated “I need a whole one.” ROSA agreed to “save [him] a whole one.” At approximately
12:41 p.m., ROSA told PARSONS “I only have a half.” I believe that PARSONS wanted
a finger of heroin for distribution but that ROSA only had a half a finger available at the
time.
target telephone # 1 from telephone number (781) 727-8385. ROSA spoke to PARSONS.
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PARSONS asked ROSA if he was all set and ROSA asked “what do you want.” PARSONS
stated “a finger.” ROSA told PARSONS “½ hour on Menlo.” I believe that PARSONS
wanted a finger of heroin from ROSA and that ROSA was going to give PARSONS the
heroin in approximately one half an hour.
iv. November 10, 2010, ROSA Has BRANDAO Deliver A Finger of Heroin to PARSONS At 17
Kenwood Street
telephone # 1 to telephone number (781) 727-8385. ROSA spoke to KELLEHER,
PARSONS sister. KELLEHER asked for a “whole one”. ROSA told KELLEHER to call
when she got to the Brockton line. At approximately 2:47 p.m., ROSA spoke to PARSON
and KELLEHER and told them to go to “Kenwood Street”. At approximately 3:00 p.m.,
ROSA told PARSONS to “jump inside the escalade”. At approximately 3:02 p.m., an
outgoing call was placed on target telephone # 1 to telephone number (774) 444-6122.
ROSA spoke to BRANDAO. ROSA told BRANDAO “hurry up the dude for the finger is
here”. BRANDAO told ROSA that he was coming down.
276. On November 10, 2010, at approximately 2:58 p.m., surveillance observed a gray 2002
Cadillac Escalade with Massachusetts registration FF618A, parked across the street from 17
Kenwood Street in Brockton, MA. BRANDAO was observed sitting in the driver’s seat of
the Escalade. At approximately 3:03 p.m., surveillance observed a 2008 Chrysler Sebring
with Massachusetts registration number DV793 pull up across the street from the Escalade.
The male operator of the Sebring, later determined to be Robert PARSONS, was observed
getting out of the Sebring and getting into the rear of the Escalade. At approximately 3:05
p.m., PARSONS was observed exiting the Escalade, getting into the Sebring, and departing
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the area. On November 10, 2010, at approximately 3:14 p.m., a car stop was conducted on
the Sebring. The driver of the vehicle was identified as Robert PARSONS and the passenger
of the vehicle was identified as Jackalyn KELLEHER.
O. ROSA’s Heroin Customer – Tim TAMULEVICH
were obtained which revealed that TAMULEVICH was a heroin customer of ROSA. On
September 24, 2010, approximately 20 grams of heroin was seized from TAMULEVICH,
which I believe, based on intercepted conversations, was supplied to TAMULEVICH by
ROSA. During the course of the heroin conspiracy, TAMULEVICH is believed to have
received in excess of 100 grams of heroin. The following interceptions are examples of the
heroin trafficking activities that occurred between ROSA and TAMULEVICH during the
charged conspiracy.
i. August 22, 2010, ROSA Delivered One Finger of Heroin to TAMULEVICH
telephone # 1from telephone number (508) 232-8703. ROSA spoke to TAMULEVICH.
TAMULEVICH stated that he wanted a “finger” and asked how much. ROSA stated “800".
I believe that ROSA was going to sell TAMULEVICH a finger or 10 grams of heroin for
$800.
ii. September 21, 2010, TAMULEVICH Gets More Heroin from ROSA
TAMULEVICH. ROSA asked TAMULEVICH if people like it and TAMULEVICH stated
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“it leaves a lot of shit on the bottom.” ROSA told TAMULEVICH “you got to cook it.”
TAMULEVICH stated “I do cook it.” ROSA explained that “I just had to grab it because
I was waiting for the usual.” TAMULEVICH stated “I want one of the usuals” and that ‘I
got the money for it ready.” I believe that ROSA received heroin from an alternate source
of supply; that a portion of the heroin had been distributed to TAMULEVICH; that the
quality of the heroin was not as good; and that TAMULEVICH wanted more heroin but
some of the higher quality.
iii. September 22, 2010, ROSA Delivered One Finger of Heroin to TAMULEVICH
TAMULEVICH. TAMULEVICH told ROSA “I need one”. ROSA asked TAMULEVICH
when he was going to start grabbing “two.” ROSA told TAMULEVICH to “meet me on
Menlo.” I believe that TAMULEVICH wanted one finger of heroin and that ROSA was
going to deliver the heroin to TAMULEVICH at Menlo Street.
iv. September 24, 2010, ROSA Delivered Two Fingers of Heroin to Tim TAMULEVICH, Heroin
Seized from TAMULEVICH
281. As previously detailed in Section II, Part A, vi, of this Affidavit, on September 24, 2010,
ROSA delivered two fingers of heroin to TAMULEVICH and said heroin was seized from
TAMULEVICH.
III. IURY GOMES AND HIS CRIMINAL ASSOCIATES
criminal activities of Iury GOMES and his criminal associates. On August 4, 2010, the
Honorable Richard G. Stearns authorized the interception of target telephone # 8, used by
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Iury GOMES. GOMES was also intercepted on target telephone # 1, used by Jose ROSA
and target telephone # 6, used by FERNANDES. Between June, 2010 and November,
2010, GOMES received and distributed large quantities of heroin, totaling in excess of one
that GOMES is a large scale heroin distributor, who receives large quantities of heroin for
distribution from FERNANDES, ROSA, and UM0020; and that GOMES has had several
criminal associates named Ivan FONSECA, Elsio MONTEIRO, and Emanuel RIBEIRO,
who receive, process, and distribute heroin on behalf of GOMES. During the course of this
investigation, heroin was seized from Ivan FONSECA, a criminal associate of GOMES, on
August 10, 2010. The following are examples of intercepted conversations that have been
intercepted, during the course of this investigation, that focus on the above-named criminal
defendants.
A. GOMES’ Source of Supply – Miguel FERNANDES
had numerous larger scale heroin customers, including Iury GOMES Interceptions revealed
that GOMES would request and receive multi-finger quantities of heroin, usually ten or 100
grams of heroin, from FERNANDES and further distribute said heroin. As previously
detailed in Section I, Part G, on August 12, 2010, FERNANDES delivered 10 fingers of
heroin to GOMES; on August 17, 2010, FERNANDES delivered 6 fingers of heroin to
GOMES; on September 21, 2010, FERNANDES delivered 10 fingers of heroin to GOMES;
and on October 24, 2010, GOMES received 50 grams of heroin from FERNANDES.
B. GOMES’ Source of Supply – ROSA
284. The interception of target telephone # 1, used by ROSA, revealed that ROSA was a heroin
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source of supply for Iury GOMES Interceptions revealed that GOMES would request and
receive multi-finger quantities of heroin from ROSA and further distribute said heroin. As
previously detailed, in Section II, Part D, i of this Affidavit, on August 22, 2010, GOMES
received five fingers of heroin from BARBOSA/ROSA.
C. GOMES’ Criminal Associate – Ivan FONSECA
285. The interception of target telephone # 8 revealed that GOMES had a criminal associate
named Ivan FONSECA. Interceptions revealed that FONSECA received, weighed,
processed, and delivered heroin, on behalf of GOMES. On August 10, 2010, FONSECA
was arrested with 8 grams of heroin. The following are examples of interceptions that
occurred during the charged conspiracy.
i. August 5, 2010, GOMES obtained 100 grams of heroin from a source of supply, UM0020,
and Delivered Heroin to FONSECA for Processing and Distribution
telephone # 8 from telephone number (617) 386-0020. GOMES spoke to UM0020.
GOMES asked UM0020 whether he had anything there and UM0020 told GOMES that he
would call him right back. At approximately 3:13 p.m., GOMES asked UM0020 whether
“you got it” and UM0020 stated yes. GOMES asked if it was “good stuff” and UM0020
replied yeah. GOMES asked UM0020 if he was at the “crib” and UM0020 stated yeah “stop
by there.” At approximately 3:40 p.m., GOMES told UM0020 that he was outside.
UM0020 told GOMES to stay there and explained that he was about to pull up. I believe
that UM0020 is a heroin source of supply; that GOMES wanted heroin from UM0020; that
UM0020 had heroin available for distribution; that UM0020 affirmed that the heroin was
“good” quality; and that GOMES was meeting with UM0020 to receive a quantity of heroin.
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telephone # 8 to telephone number (508) 408-3507. GOMES spoke to Ivan FONSECA.
GOMES told FONSECA that “I’m going to your house now have the money ready.”
GOMES stated “I’m bringing you something.” I believe that GOMES was traveling to 26
Hunt Street in Brockton, MA to meet with FONSECA and deliver the heroin to FONSECA,
which GOMES had just received from UM0020, for further distribution.
telephone # 8 from telephone number (508) 408-3507. GOMES spoke to Ivan FONSECA.
FONSECA told GOMES “it weighed 100.9.” GOMES asked “without the bag”.
FONSECA stated “with the bag.” GOMES told FONSECA to “take it out of the bag and
see how much.” At approximately 4:09 p.m., FONSECA told GOMES “without the bag it
weighed 98.7.” I believe that FONSECA weighed the heroin that he had received from
GOMES and that the weight of the heroin was 100.9 grams of heroin with the bag and 98.7
grams of heroin without the bag.
telephone # 8 to telephone number (617) 386-0020. GOMES spoke to UM0020. GOMES
told UM0020 that “the stuff weighed 98.7.” GOMES told UM0020 “your doing this all the
time last time it was .5.” UM0020 stated “alright I’ll give it to you.” I believe that GOMES
was informing UM0020 that he had only received “98.7" grams of heroin and not 100 grams
of heroin; that GOMES further indicated that he was shorted .5 or one half a gram of heroin
the last time; and that UM0020 indicated that he would give GOMES the additional heroin.
ii. August 5, 2010 - August 10, 2010 – Heroin Distribution Conducted By FONSECA
290. Between August 5, 2010 and August 10, 2010, numerous conversations were intercepted on
target telephone # 8, during which FONSECA distributed what I believe to be heroin and
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crack cocaine to narcotics customers, at the direction of GOMES. The following are
examples of said transactions.
telephone # 8 from telephone number (508) 304-0958. GOMES spoke to UF0958. UF0958
asked for “12 again for $360.” GOMES told UF0958 to go to the east side and gave her
directions to “Hunt Street.” At approximately 11"48 a.m., UF0958 stated that she was on
Hunt Street and GOMES stated that “his buddy” will come over to her. At approximately
11:59 a.m., an outgoing call was placed on target telephone # 8 to telephone number (508)
408-3507. GOMES spoke to UM3507, later identified as Ivan FONSECA. GOMES told
FONSECA to make “12 bags for chick who is outside.” FONSECA asked how much and
GOMES stated “11 bags”. FONSECA asked of “brown” and GOMES said yeah. At
approximately 12:05 p.m., an outgoing call was placed on target telephone # 8 to telephone
number (508) 408-3507. GOMES spoke to UM3507, later identified as Ivan FONSECA.
GOMES asked FONSECA if he saw her and FONSECA affirmed. FONSECA asked
GOMES how much she was suppose to give him and GOMES stated “360.” I believe that
UF0958 is a heroin customer who wanted “12" bags of heroin from GOMES and was going
to pay $360 for the heroin; that GOMES tasked FONSECA to deliver the heroin to UF0958;
and that FONSECA met with UF0958 delivered the heroin and collected $360, which was
payment for the heroin.
telephone # 8 to telephone number (508) 846-7075. GOMES spoke to UM7075. UM7075
asked GOMES for “2 brown bags”. GOMES told UM7075 to go to Hunt Street. At
approximately 10:12 a.m., an outgoing call was placed on target telephone # 8 to telephone
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number (508) 408-3507. GOMES spoke to FONSECA. GOMES told FONSECA to “make
2 grams of brown and take it outside he is in a black maxima.” FONSECA asked “2 brown”
and GOMES corrected “no 2 grams.” At approximately 10:14 a.m., an outgoing call was
placed on target telephone # 8 to telephone number (508) 408-3507. GOMES spoke to
UM3507, later identified as Ivan FONSECA. GOMES told FONSECA to “make sure 2
grams.” FONSECA stated “I have a little one that you brought its 2.3, do you want me to
take a little off.” GOMES said yes and told FONSECA to “cut it with a knife” and “take it
to the dude in the black Nissan.” I believe that UM7075 wanted “2 brown”; that GOMES
told FONSECA to prepare 2 grams of heroin; and that FONSECA was getting the 2.0 grams
of heroin from a package of 2.3 grams of heroin that GOMES had given FONSECA.
telephone # 8 to telephone number (508) 408-3507. GOMES spoke to FONSECA. GOMES
told FONSECA “bring a chick . . . . in a red car 3 brown.” FONSECA stated that he was
out. FONSECA told GOMES to send them to south side pizza. At approximately 11:04
a.m., an outgoing call was placed on target telephone # 8 to telephone number (508) 408-
3507. GOMES spoke to FONSECA. GOMES told FONSECA he’s there “3 brown.”
FONSECA asked in a black car and GOMES stated that he believed that “it’s a girl in a
black car.” At approximately 11:05 a.m., an outgoing call was placed on target telephone
# 8 to telephone number (508) 408-3507. GOMES spoke to Ivan FONSECA. FONSECA
told GOMES all set. GOMES stated that there is a “play for 2 brown right there in a white
car.” FONSECA agreed. At approximately 11:14 a.m., an incoming call was received on
target telephone # 8 from telephone number (508) 408-3507. GOMES spoke to FONSECA.
FONSECA told GOMES to “call that dude back” and explained that “he put money in a
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cigarette case.” GOMES told FONSECA to count it and FONSECA stated that he did and
the guy took off. GOMES told FONSECA not to give them “anything until you count the
money.” I believe that FONSECA was delivering heroin to heroin customers and that during
the delivery one customer had not paid the entire amount of money for the heroin delivered.
iii. August 10, 2010, Arrest of FONSECA with Heroin
telephone # 8 from telephone number (774) 360-3005. GOMES spoke to UM3005, later
determined to be Elsio MONTEIRO. Elsio MONTEIRO stated that he had just been
contacted and that “San Saint” just got locked up. On August 10, 2010, at approximately
1:13 p.m., an incoming call was received on target telephone # 8 from telephone number
(774) 360-3005. GOMES spoke to Elsio MONTEIRO. Elsio MONTEIRO explained that
“they found him with mad stuff on him.” On August 10, 2010, at approximately 1:17 p.m.,
an outgoing call was placed on target telephone # 8 to telephone number (774) 360-3005.
GOMES spoke to Elsio MONTEIRO. GOMES stated that “I didn’t send him no play . . .
I sent him a play like 2 to 3 hours . . . [not] at this time.” I believed, based on the above
referenced calls that FONSECA had been arrested by the police and that UM3507 had been
in possession of “work” or narcotics.
295. Further inquiry revealed that on August 10, 2010, in an unrelated investigative action, Ivan
FONSECA was arrested. At the time of his arrest FONSECA had a telephone in his
possession, which was telephone number (508) 408-3507 – the telephone used by
FONSECA. FONSECA was charged with possession to distribute Class A and Class B
narcotics, which consisted of 13 bags of heroin or approximately 8 grams of heroin and 7
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bags of “crack” cocaine or 2.5 grams of “crack” cocaine.
telephone # 8 to telephone number (774) 826-9458. GOMES spoke to UM9458, determined
to be Emanuel RIBEIRO. GOMES told UM9458 that “one of my workers got caught up at
work.” GOMES stated “he had 40 pieces on him he is a dick, walk around with 40 pieces
dude.” GOMES explained that he was “in a hot spot, he didn’t even get caught doing a play
or nothing, he just got caught in the wrong spot.” I believe that GOMES was explaining
that FONSECA had been arrested; that FONSECA had 40 pieces or 40 bags of narcotics;
and that FONSECA was arrested at a location which is hot or known for narcotics
distribution.
D. GOMES’ Criminal Associate – Elsio MONTEIRO
297. The interception of target telephone # 8 revealed that GOMES had another criminal associate
named Elsio MONTEIRO. Interceptions revealed that Elsio MONTEIRO and GOMES
received six fingers of heroin from FERNANDES for distribution on August 18, 2010 and
that Elsio MONTEIRO received, weighed, processed, and delivered heroin, on behalf of
GOMES. The following are examples of interceptions that occurred during the course of the
charged conspiracy.
i. August 17, 2010, GOMES and Elsio MONTEIRO Receive 6 Fingers of Heroin from
FERNANDES
GOMES asked FERNANDES if “he can do 20 of them for 550.” FERNANDES stated that
he will “call the dude then call him back.” I believe that GOMES wanted 20 fingers of
heroin from FERNANDES; that GOMES wanted the heroin for $550/finger or 10 gram
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quantity; and that FERNANDES was going to contact one of his heroin sources of supply.
299. On August 17, 2010, at approximately 3:01 p.m., a conversation occurred on target
telephone # 8. GOMES spoke to FERNANDES. FERNANDES told GOMES that the “dude
said that the lowest is 575" and GOMES told him to do it. FERNANDES said that he was
going to call the dude and then he will call him back. I believe that FERNANDES had
spoken to one of his heroin sources of supply and that the price for heroin was going to $575
for a finger of heroin.
FERNANDES told GOMES bad news and explained that “he only has 10 until tomorrow
. . . and I want 5 for me.” GOMES told FERNANDES “so give me the 10 for $600.”
FERNANDES told GOMES “I’ll get you 6.” I believe that FERNANDES had spoken to one
of his heroin sources of supply; that the source only had 10 fingers for distribution; that
GOMES wanted 10 fingers for $600 and FERNANDES indicated that he would get 6 fingers
for GOMES.
FERNANDES stated that he had passed by and he didn’t see GOMES’ car. GOMES stated
that he was in the house and my boy is going outside now. I believe that FERNANDES was
delivering 6 fingers of heroin to Laureston Street to Elsio MONTEIRO.
telephone # 8 to telephone number (774) 360-3005. GOMES spoke to Elsio MONTEIRO.
GOMES told Elsio MONTEIRO to get “6 fingers from dude outside.” I believe that
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FERNANDES was delivering 6 fingers of heroin to Laureston Street to Elsio MONTEIRO.
FERNANDES told GOMES “I gave it to him dude with scooter.” I believe that
FERNANDES delivered 6 fingers of heroin to Laureston Street to Elsio MONTEIRO.
ii. Elsio MONTEIRO is a criminal associate of GOMES who Delivered heroin and collects
narcotics proceeds
telephone # 8 from telephone number (774) 360-3005. GOMES spoke to Elsio
MONTEIRO. During the conversation, GOMES told Elsio MONTEIRO “I’ll give you
plays so you can do them from your house.” GOMES told Elsio MONTEIRO “you have to
have a stash outside of the crib.” GOMES explained “I’m going to call you ahead of time,
like ten minutes away and tell you what to get ready then you can bounce.” Elsio
MONTEIRO stated that that would be great. GOMES stated that he was “waiting for Sao
Vicente” and “then I’ll go get work at his house.” I believe that Elsio MONTEIRO is going
to be working with GOMES to facilitate the distribution of narcotics; that Elsio MONTEIRO
is going to distribute from and store narcotics in his apartment; and distribute said narcotics
as detailed by GOMES.
telephone # 8 to telephone number (781) 975-2094. GOMES spoke to “Kristina”. GOMES
told “Kristina” that he had just picked up some “fire.” “Kristina” stated that she was going
to head that way. GOMES asked “Kristina” how much she wanted and “Kristina” asked
how much for “12". GOMES answered “$400.” “Kristina” stated that she would be right
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there. At approximately 1:37 p.m., an incoming call was received on target telephone # 8
from telephone number (781) 975-2094. GOMES spoke to “Kristina”. GOMES told
“Kristina” to pull over at the beginning of “Laureston.” On August 11, 2010, at
approximately 1:37 p.m., an outgoing call was placed on target telephone # 8 to telephone
number (774) 360-3005. GOMES spoke to Elsio MONTEIRO. GOMES told Elsio
MONTEIRO that a “girl wants 12 she is at the top of your street.” Elsio MONTEIRO asked
“12 white” and GOMES affirmed and explained “she’ll give you 400.” I believe that
“Kristina” is a narcotics customer of GOMES; that “Kristina” wanted “12" units of “white”
or cocaine; that Elsio MONTEIRO was going to deliver the cocaine; and that “Kristina” was
going to pay Elsio MONTEIRO $400 for the cocaine.
telephone # 8 from telephone number (781) 367-3824. GOMES spoke to UF3824. UF3824
told GOMES that she would be there in “5" and GOMES asked “6 for 200". UF3824
affirmed. On August 11, 2010, at approximately 3:43 p.m., an outgoing call was placed on
target telephone # 8 to telephone number (774) 360-3005. GOMES spoke to Elsio
MONTEIRO. GOMES told Elsio MONTEIRO to take the “girl” “6 brown” at KFC on the
south side and she will give you $200. I believe that Elsio MONTEIRO was going to deliver
UF3824 “6" units of heroin for $200.
GOMES asked Elsio MONTEIRO “how many 40 bags” and Elsio MONTEIRO stated “38".
GOMES stated that he was coming to get “5 pieces.” I believe that GOMES was inquiring
regarding the quantity of narcotics that were being stored with Elsio MONTEIRO.
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E. GOMES’ Criminal Associate – Emanuel RIBEIRO
308. The interception of target telephone # 8 revealed that GOMES had another criminal associate
named Emanuel RIBEIRO. Interceptions revealed that RIBEIRO received ten fingers of
heroin from FERNANDES for distribution on September 9, 2010 and that RIBEIRO
received, weighed, processed, and delivered heroin, on behalf of GOMES. The following
are examples of interceptions that occurred during the course of the charged conspiracy.
i. RIBEIRO Begins Processing and Distributing Heroin for GOMES
telephone # 8 to telephone number (774) 826-9458. GOMES spoke to RIBEIRO. GOMES
asked RIBEIRO “you want that thing or not I’m leaving Wednesday.” RIBEIRO stated that
he would definitely do it for you. GOMES asked RIBEIRO whether he had “work” and
RIBEIRO said no. GOMES asked RIBEIRO how much he needed and RIBEIRO stated “a
finger right now.” GOMES stated that he would give RIBEIRO “11 pieces”. RIBEIRO
asked GOMES how long he was going and GOMES stated 18 days. I believe that GOMES
is taking an 18 day trip; that RIBEIRO was going to take over the narcotics business for
GOMES while he was gone; and that RIBEIRO wanted a finger of heroin or 10 grams of
heroin for immediate distribution.
asked RIBEIRO whether he was sure that he wanted to do that and RIBEIRO said yes.
GOMES indicated that he was en route to RIBEIRO's house “right now with 50 grams.” I
believe that RIBEIRO was going to distribute heroin for GOMES and that GOMES was
going to the house of RIBEIRO to deliver 50 grams of heroin for distribution.
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telephone # 8 to telephone number (774) 826-9458. GOMES spoke to RIBEIRO. RIBEIRO
told GOMES “no scale over here” and GOMES told RIBEIRO to come home and he would
get “it” at Laureston. At approximately 12:25 p.m., an incoming call was placed on target
GOMES asked Elsio MONTEIRO whether he was home and explained that he had come to
get the scale. I believe that RIBEIRO and GOMES needed a scale to weigh and package the
heroin prior to further distribution.
asked RIBEIRO whether he saw him and RIBEIRO said “male 100 right” and GOMES said
he gave you “100" and GOMES explained his name is “Dominic”. GOMES stated that
there is another there for “2 brown in an old Buick.” RIBEIRO told GOMES that he had to
break a piece and GOMES told RIBEIRO “when you get the chance break up a finger.” I
believe that RIBEIRO is now a criminal associate of GOMES who is receiving, preparing,
and distributing heroin for GOMES.
ii. September 9, 2010, RIBEIRO Received Ten Fingers of Heroin from FERNANDES
313. On September 9, 2010, at approximately 8:36 a.m., an incoming call was received on target
telephone # 6 from telephone number (508) 857-9759. FERNANDES spoke to a male,
RIBEIRO, who was previously intercepted on Target Telephone # 8 using telephone number
774-826-9458. FERNANDES told RIBEIRO that the guy who supplied raised the price to
“625". RIBEIRO asked for “10". I believe that RIBEIRO wanted 10 fingers of heroin from
FERNANDES and that the price was $625 per finger of heroin.
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telephone # 6 to telephone number (508) 857-9759. FERNANDES spoke to RIBEIRO.
FERNANDES told RIBEIRO that the “number . . . was $6250.” RIBEIRO stated that he
would give it to “him” today. FERNANDES told RIBEIRO that he was leaving at around
“12". I believe that RIBEIRO wanted 10 fingers of heroin from FERNANDES and that the
price was $625 per finger of heroin.
RIBEIRO stated that he was ready. FERNANDES stated that he would “pick it up in about
20 mins.” FERNANDES explained that he was “meeting with him at about 11:30.” I
believe that FERNANDES wanted to pick up the money from RIBEIRO for the 10 fingers
of heroin because FERNANDES was going to meet with the heroin source of supply at
11:30.
FERNANDES stated that he was outside. RIBEIRO stated that he was coming out now.
I believe that FERNANDES wanted to pick up the money from RIBEIRO for the 10 fingers
of heroin.
telephone # 6 from telephone number (508) 857-9759. FERNANDES spoke to RIBEIRO.
RIBEIRO told FERNANDES that he was here. FERNANDES asked whether he was by the
Panorama. RIBEIRO affirmed and explained that he “met your boy here.” FERNANDES
asked RIBEIRO “he gave it to you” and RIBEIRO stated that he was going to “give it to me
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now.” I believe that RIBEIRO met with a criminal associate of FERNANDES and that
RIBEIRO was in the process of receiving ten fingers of heroin.
iii. September 20, 2010, RIBEIRO Wants 100 Grams of Heroin from FERNANDES
telephone # 6 to telephone number (508) 857-9759. FERNANDES spoke to RIBEIRO, on
a telephone used by GOMES. RIBEIRO stated “I need another 100 grams.” FERNANDES
stated “I’ll call the guy to see.” I believe that RIBEIRO wanted 100 grams of heroin and that
FERNANDES was going to contact his source of supply and determine whether he could
get the heroin.
iv. October 24, 2010, FERNANDES Delivered Fifty Grams of Heroin to GOMES and RIBEIRO
319. On October 24, 2010, as detailed previously in Section I, Part G, iii, GOMES asked for “one
hundred" from FERNANDES; FERNANDES stated not a “hundred, maybe fifty”;
FERNANDES told GOMES to meet him at the carwash; FERNANDES was observed
exiting from the rear passenger door of the Escalade driven by GOMES; and then two Cape
Verdean males, one of whom was RIBEIRO, were observed arriving together from the
delivery to 55 Highland Terrace
IV. JUSTIN TEIXEIRA AND HIS CRIMINAL ASSOCIATES
criminal activities of Justin TEIXEIRA2 and his criminal associates. On October 7, 2010 and
November 1, 2010, the Honorable Richard G. Stearns authorized the interception of target
telephone # 9, used by TEIXEIRA. Previous to those interceptions, TEIXEIRA was also
2
On November 2, 2010, the user of target telephone # 9 placed an outgoing call and identified
himself to the caller as Justin TEIXEIRA.
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intercepted on target telephone # 1, used by Jose ROSA. Between June, 2010 and
November, 2010, TEIXEIRA used target telephone # 9 to receive and distribute large
quantities of heroin, totaling in excess of one kilogram of heroin. During the course of the
interceptions in this investigation, we learned that TEIXEIRA is a large scale heroin
distributor, who receives larger quantities of heroin for distribution from UM3839 a/k/a
UM0708; that TEIXEIRA is a heroin source of supply for ROSA and GOMES and that
TEIXEIRA has several heroin customers, who are not presently being charged in this matter.
During the course of this investigation, approximately fifteen fingers or 150 grams of heroin
was seized directly from TEIXEIRA on November 2, 2010. The following are examples of
conversations that have been intercepted, during the course of this investigation, that focus
on the above-named criminal defendants.
A. TEIXEIRA’s Heroin Source of Supply – UM3839 a/k/a UM0708
i. October 14, 2010, TEIXEIRA Received Twenty Fingers of Heroin from UM3839 a/k/a
UM0708
321. On October 14, 2010, at approximately 10:47 a.m., an outgoing call was placed on target
telephone # 9 to telephone number (508) 436-0708. TEIXEIRA spoke to UM0708.
TEIXEIRA asked UM0708 whether this was his new number and UM0708 stated that it was
his other phone. TEIXEIRA asked UM0708 whether he still had “the same work”. UM0708
told TEIXEIRA that he switched it up. TEIXEIRA asked “the hard shit” and UM0708 stated
“its hard, people like this stuff right here, my boy told me it’s the bomb.” TEIXEIRA asked
UM0708 “do you have 20 of them”? UM0708 confirmed “20". UM0708 stated that he was
in the “river” and that he would be around soon. TEIXEIRA told UM0708 to hit him up as
soon as he got around. I believe that UM0708 is a heroin source of supply for TEIXEIRA;
that TEIXEIRA wanted “20" fingers of heroin; and that UM0708 was going to deliver the
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heroin to TEIXEIRA when he returned from the “river” or Fall River.
telephone # 9 to telephone number (508) 436-0708. TEIXEIRA spoke to UM0708.
UM0708 told TEIXEIRA that he would be around in about half hour. At approximately 5:42
p.m., an incoming call was received on target telephone # 9 from telephone number (508)
436-0708. TEIXEIRA spoke to UM0708. UM0708 asked how long and TEIXEIRA stated
that he was at the crib waiting for him. UM0708 stated that he would be over there in 4
minutes and asked TEIXEIRA whether he would be there in ten. TEIXEIRA agreed. I
believe that TEIXEIRA and UM0708 were going to meet and that TEIXEIRA was going to
receive 20 fingers of heroin from UM0708.
323. Surveillance was located in the area of 35 Clinton Street, which is believed to be the “crib”
or residence of TEIXEIRA. A black male in a red and black sweatshirt was observed
walking from the area of 35 Clinton Street to an unknown residence in the area of Curve
Street. The same male was then observed walking back to the vicinity of Clinton Street and
entering 35 Clinton Street.
telephone # 9 from telephone number (508) 436-0708. TEIXEIRA spoke to UM0708.
UM0708 told TEIXEIRA “there’s straight 10 here.” TEIXEIRA said “my fault . . . come
to my crib and give you 15.” I believe that UM0708 had delivered 20 fingers or 200 grams
of heroin to TEIXEIRA; that TEIXEIRA had paid “straight 10" or $10,000 for the heroin;
but that TEIXEIRA owed “15" or $1500 additional dollars for the heroin because the 20
fingers of heroin for $575 per finger of heroin was $11,500.
ii. November 2, 2010, TEIXEIRA Received Fifteen Fingers of Heroin from UM3839 a/k/a
UM0708, Which Was Seized from TEIXEIRA
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telephone # 9 from telephone number (508) 436-3839. TEIXEIRA spoke to UM3839 a/k/a
UM0708. TEIXEIRA told UM3839 “let me get 15 of them.” UM3839 told TEIXEIRA that
he would call when he was at the “spot.” At approximately 6:29 p.m., UM3839 told
TEIXEIRA “I have 10, I’m just waiting for the other 5 to get here.” At approximately 6:52
p.m., UM3839 told TEIXEIRA “I got that” and “I’m over here.” I believe that UM3839 is
TEIXEIRA’s heroin source of supply; that TEIXEIRA wanted “15" fingers or 150 grams of
heroin; and that UM3839 was prepared to deliver the heroin to TEIXEIRA.
326. On November 2, 2010, surveillance observed a black male matching TEIXEIRA'S physical
description walking a pit bull dog wearing what appeared to be a dark colored jacket with
red sleeves in front of TEIXEIRA’s residence located at 35 Clinton Street. The black male
was observed crossing over Grove Street and proceed down Curve Street and then was
observed coming back up Wellington Place toward Curve Street. At this time, a police
officer attempted to approach the male, in order to identify the male. While the police
approached the black male he attempted to run from law enforcement. The black male was
observed throwing an item. The male was caught and determined to be Justin TEIXEIRA.
The package that TEIXEIRA had thrown was retrieved and determined to be a clear plastic
wrapped package containing 15 finger shaped items suspected to be heroin. TEIXEIRA was
arrested.
B. TEIXEIRA’s Heroin Customer – Nine SILVEIRA
telephone # 9 to a telephone with IMS number 316010162857119, believed to be Nine
SILVEIRA. TEIXEIRA spoke to SILVEIRA. SILVEIRA told TEIXEIRA to “bring a
124
finger to my crib” and TEIXEIRA stated “I don’t know what you are talking about.”
SILVEIRA stated “bring some of those brownies that you cooked yesterday.” TEIXEIRA
laughed and agreed. I believe that SILVEIRA is a heroin customer of TEIXEIRA and that
SILVEIRA wanted a finger or 10 grams of heroin.
C. TEIXEIRA’s Heroin Customer – Iury GOMES
telephone # 9 to telephone number (774) 776-5141. TEIXEIRA spoke to GOMES. GOMES
told TEIXEIRA to “bring that shit through” and TEIXEIRA stated “I’ll bring two today”.
I believe that TEIXEIRA was going to deliver “two” fingers of heroin to GOMES.
telephone # 9 to telephone number (774) 776-5141. TEIXEIRA spoke to GOMES. GOMES
asked TEIXEIRA “where you put my shit yesterday” and TEIXEIRA stated “I was going
to leave it . . . but I wanted to make sure nobody took it. I’ll bring it to you right now.” I
believe that TEIXEIRA was going to deliver heroin to GOMES.
CONCLUSION
330. Based upon the information above, I submit that this affidavit provides probable cause for
a criminal charging that from on or about June, 2010, until on or about November, 2010, the
following defendants, 1) Tiffany Marie ANDRADE; 2) Claudio ARAUJO a/k/a “Lenny”
a/k/a UM9889; 3) Alessio BARBOSA a/k/a “Alexio”, a/k/a “Alex”, a/k/a “A” a/k/a “Ace”;
4) Dany L. BRANDAO a/k/a UM6122; 5) Nicholas DEANGELIS a/k/a UM1027; 6)
Emanuel DOCANTO a/k/a “Mandog” a/k/a UM4026; 7) Miguel A. FERNANDES a/k/a
“Miguel”; 8) Ismael FIGUEROA; 9) Ivan FONSECA a/k/a UM3507; 10) Iury Jandir
125
GOMES a/k/a “Utes”; 11) Alector GONCALVES a/k/a “JG”; 12) Tamara HOLLIS; 13)
Carey MONTEIRO a/k/a UF6102 a/k/a UF1163; 14) Elsio MONTEIRO a/k/a UM3005; 15)
Robert PARSONS a/k/a UM8385; 16) Emanuel RIBEIRO a/k/a UM9458; 17) Jose G.
ROSA a/k/a “Jose” a/k/a “J” a/k/a “Big Poppa”; 18) Virgilio ROSA a/k/a “Turbo”; 19) Nine
SILVEIRA; 20) Gregory STUBBS; 21) Timothy T. TAMULEVICH, a/k/a “Tiny”; 22)
Justin A TEIXEIRA a/k/a “Becky”; 23) Carla VICENTE a/k/a UF2296; and 24), Catherine
WATTS a/k/a “Kate” did conspire to possess with intent to distribute and to distribute, in
excess of one kilogram of heroin, in violation of Title 21, United States Code, Sections 846
and 841(b)(1)(A).
___________________________________
KEVIN C. HERSEY
SPECIAL AGENT
DRUG ENFORCEMENT ADMINISTRATION
Sworn and subscribed to me this day of November , 2010.
______________________________
JENNIFER C. BOAL
UNITED STATES MAGISTRATE JUDGE
DISTRICT OF MASSACHUSETTS
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Affidavit of Drug Bust in Southeastern Mass.

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Affidavit of Drug Bust in Southeastern Mass.

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Complaint Affidavit

duly sworn, state:

1. As a result of being a Special Agent, I am an investigative or law enforcement officer of the

enumerated in Title 18, United States Code, Section 2516.

During my tenure as a DEA Special Agent, I have worked on hundreds of drug

investigations. Many of these investigations involved the organized domestic and

international importation and distribution of kilogram quantities of cocaine and heroin. I

have participated in approximately 10 investigations that involved the use of court-ordered

of payment for such drugs.

paraphernalia involved in the manufacture and distribution of controlled substances; large

ordering, purchasing and distribution of controlled substances. I have participated in the

regarding large-scale narcotics trafficking organizations. I have participated in all aspects

of drug investigations including conducting surveillance, executing searches pursuant to

court-ordered search warrants and executing arrests. As a result of my assignments, I have

received extensive specialized training in the field of narcotics identification, investigation

telephones in an effort to thwart law enforcement’s use of electronic surveillance. I am also

their illegal activities, and employ a variety of counter-surveillance techniques in order to

detect if their vehicles are being followed by members of law enforcement.

enforcement agencies to investigate their activities. It has been my experience that

money and/or drugs.

the underlying recordings.

1) Tiffany Marie ANDRADE; 2) Claudio ARAUJO a/k/a “Lenny” a/k/a UM9889; 3)

BRANDAO a/k/a UM6122; 5) Nicholas DEANGELIS a/k/a UM1027; 6) Emanuel

DOCANTO a/k/a “Mandog” a/k/a UM4026; 7) Miguel A. FERNANDES a/k/a “Miguel”;

foundation the pending charges.

surveillance, and court-authorized interception of wire communications. On May 26, 2010,

Massachusetts, authorized the interception of various telephones being used by members of

telephone # 9), and Carla VICENTE (target telephone # 10).

distributing significant quantities of heroin in and around Brockton, Massachusetts. The

criminal activities of Miguel FERNANDES and his criminal associates. On September 7,

the interception of target telephone # 6, used by Miguel FERNANDES. Previous to those

interceptions, Miguel FERNANDES was also intercepted on target telephone # 1, used by

heroin customers, including Alessio BARBOSA, Nicholas DEANGELIS, Iury GOMES,

FERNANDES’ heroin customer, Virgilio ROSA, on October 28, 2010.

interception of telephone number (774) 259-9786 – target telephone # 1, used by ROSA.

# 5, used by BRANDAO, target telephone # 6, used by FERNANDES, target telephone #

Miguel FERNANDES, Ismael FIGUEROA, Carey MONTEIRO, Virgilio ROSA, Justin

independently, including Tiffany Marie ANDRADE, Claudio ARAUJO, Alessio

BARBOSA, Dany BRANDAO, Alector GONCALVES, Nine SILVEIRA, and Gregory

additional unknown persons, including Robert PARSONS, and Tim TAMULEVICH.

Honorable Richard G. Stearns authorized the interception of target telephone # 8, used by

telephone # 9, used by TEIXEIRA. Previous to those interceptions, TEIXEIRA was also

CRIMINAL INVESTIGATION AND EVIDENCE

I. MIGUEL FERNANDES AND HIS CRIMINAL ASSOCIATES

criminal activities of Miguel FERNANDES and his criminal associates. On September 7,

the interception of target telephone # 6, used by Miguel FERNANDES. Previous to those

interceptions, Miguel FERNANDES was also intercepted on target telephone # 1, used by

heroin customers, including Alessio BARBOSA, Nicholas DEANGELIS, Iury GOMES,

that focus on the above-named criminal defendants.

A. October 7, 2010, Seizure of Heroin from FERNANDES

found to be in possession of approximately 40 grams of heroin. The following interceptions

led to the car stop and seizure.

telephone # 6 from telephone number (774) 259-7427. FERNANDES spoke to Alessio

BARBOSA, a heroin customer of FERNANDES. BARBOSA asked FERNANDES if he

received on target telephone # 6 from telephone number (774) 259-7427. FERNANDES

fingers of heroin to BARBOSA.

telephone # 6 from telephone number (508) 562-8091. FERNANDES spoke to

GONCALVES. FERNANDES told GONCALVES that he would be there in two minutes.

At approximately 7:46 p.m., FERNANDES told GONCALVES to come downstairs. At

for the following day.

Maxima bearing Massachusetts registration number 1978MD in the driveway of 16 Forest

Avenue in Brockton, Massachusetts, the believed residence of GONCALVES. An

into 16 Forest Avenue.