Eray Basaran Complaint

Case 1:11-mj-00836-JFA Document 4 A^SH^V
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UNO
TjlATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA
Alexandria Division
CLERK, Js~Dlt.Tf-:rcT(XHJRT
ALFXANDRiA. Vlf-.C'i ''..
UNITED STATES OF AMERICA

CRIMINAL NO: 1:11MJ836
ERAY EMRE BASARAN
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT
I, James McHugh, being duly sworn, depose and state as follows:

1. I am a Special Agent with the Drug Enforcement Administration (DEA) and have
been so employed since 2001. During my time in law enforcement, I have participated in the
application for and execution of numerous arrest and search warrants in the investigation of
narcotics and organized crime related offenses, resulting in the prosecution and conviction of numerous individuals and the seizure of illegal drugs, weapons, illegal drug proceeds, and other
evidence of criminal activity. As a narcotics investigator, your affiant has interviewed many individuals involved in drug trafficking and has obtained information from them regarding the acquisition, sale, importation, manufacture, and distribution of controlled substances. Through
my training and experience, I am familiar with the actions, habits, traits, methods, and terminology utilized by the traffickers and users of controlled dangerous substances. I am
currently assigned to DEA's High Intensity Drug Trafficking Area Task Force.
I am an
"investigative or law enforcement officer of the United States" within the meaning of 18 U.S.C.
2510 (7), that is, I am an officer of the United States, who is authorized by law to conduct investigations of and make arrests for offenses enumerated in 18 U.S.C. 2516.
Case 1:11-mj-00836-JFA Document 4

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2.
This affidavit is made in support of a criminal complaint and arrest warrant
charging ERAY EMRE BASARAN with conspiracy to distribute 100 or more kilograms of marijuana, a Schedule I controlled substance, in violation of Title 21, United States Code,
Sections 841(a)(1) and 846.
3.
Since this affidavit is being submitted for the limited purpose of obtaining a
criminal complaint and arrest warrant, it is not intended to include each and every fact observed by me or known to the government. I have set forth other those facts necessary to support
probable cause. 4. The facts and information contained in this affidavit are based upon my personal
knowledge, information obtained from state and federal law enforcement officers, and
information provided by cooperating witnesses. All observations referenced in this affidavit that
were not made by me were related to me by the persons who made such observations. 6. Throughout the course of this investigation, law enforcement officers utilized
cooperating witnesses. For the purpose of this affidavit, all cooperating witnesses will be
referred to in the masculine gender. Each cooperating witness has provided information against
his own penal interest; said information has been independently corroborated by law
enforcement; and said information is considered reliable.
PROBABLE CAUSE
7.
In or about 2009, law enforcement officers obtained information that ERAY
EMRE BASARAN (hereafter BASARAN), along with others, were obtaining multiple pound
quantities of marijuana from sources of supply based in Florida and California for further
distribution in the Eastern District of Virginia and elsewhere.
8.
Through further investigation and information provided by confidential witnesses,
it was learned that BASARAN utilized rental vehicles to transport money from Northern
Virginia to Florida, returning with large quantities of marijuana. BASARAN and other co conspirators were also found to also be utilizing Federal Express (FedEx), United Parcel Service
(UPS), and the United States Postal Service (USPS) to send both money and cashier's checks to
suppliers based in the Santa Barbara and San Jose areas of California. It was also found that
these subjects utilized Western Union to "wire" money to the same suppliers. In exchange, they received packages containing multiple pounds of marijuana, which was sent to various locations
in the Eastern District of Virginia and elsewhere.
LAW ENFORCEMENT SEIZURE ON SEPTEMBER 16.2009
9.
On or about September 16, 2009, in Ridgeland, South Carolina, law enforcement
officers conducted a traffic stop of a rental vehicle operated by BASARAN, which was traveling southbound on Interstate 95. BASARAN and his passenger provided conflicting details of their reasons of travel and exhibited signs of nervousness. A law enforcement drug detection canine
alerted on the vehicle for the presence of controlled substance(s) and a search of the vehicle was
conducted. During the search of the rental vehicle, law enforcement officers seized $101,725 from the trunk of the vehicle, along with several cellular telephones. Law enforcement officers
conducted a voluntary interview with BASARAN in which he provided his home address as 519
S.L.S. (full address abbreviated, hereinafter "FAA"), Arlington, Virginia.
LAW ENFORCEMENT SURVEILLANCE ON NOVEMBER 5. 2009
10.
On or about November 5, 2009, law enforcement conducted surveillance in
Arlington, Virginia and observed BASARAN meet with a subject in the parking lot of a
Wachovia Bank. The subject was observed going into the bank and exiting a short time later
carrying an envelope. The subject was seen handing the envelope to BASARAN, who then drove away from the area. Law enforcement officers later obtained business records which
showed that on this date, the subject obtained two cashier's checks, one for $5,000 and another
for $4,500 payable to a subject in Lompoc, California.

LAW ENFORCEMENT SEIZURE ON APRIL 7.2010
11.
On or about April 7, 2010, law enforcement officers intercepted a suspicious
FedEx package addressed to A.L. (full name abbreviated, hereinafter "FNA"), 237 B.P. (FAA),
Lompoc, California from M.R. (FNA), 8127 W.C. (FAA), Springfield, Virginia. As further described in paragraphs 14 and 15 below, 237 B.P. (FAA) is the admitted address of a convicted
marijuana distributor and 8127 W.C. is the admitted address of a marijuana trafficking associate
of BASARAN. On April 8, 2010, following a positive indication by a law enforcement K-9
trained in the detection of illegal narcotics, a search warrant was obtained and executed on the
package resulting in the seizure of $13,000 in United States Currency.

LAW ENFORCEMENT SEIZURE ON MAY 24.2010
12.
On or about May 24, 2010, law enforcement officers intercepted a USPS package
addressed to J.S. (FNA), 519 S.L. (FAA) Street, Arlington, Virginia (same address presented by BASARAN in paragraph 9) from R&D Designs, 1412 L.A. (FAA), Santa Barbara, California. On May 24, 2010, following a positive indication by a law enforcement K-9 trained in the
detection of illegal narcotics, a search warrant was obtained and executed on the package
resulting in the seizure of approximately five (5) pounds of suspected marijuana. A test was
conducted at the Drug Enforcement Administration (DEA) Mid-Atlantic Laboratory, which
confirmed the substance to be marijuana and weighing approximately 2,248 grams.
LAW ENFORCEMENT SEIZURE AND STATEMENTS ON JUNE 3.2010
13.
On or about June 3, 2010, law enforcement officers executed search warrants at
237 B.P. (FAA), and 809 E.N.A. (FAA), in Lompoc, California, and 725 K.A. (FAA), Solvang, California. During the searches, law enforcement officers found a large quantity of equipment utilized to cultivate marijuana including "grow lights", irrigation systems, and other
paraphernalia, along with a total of approximately $23,039 in United States Currency.
Also
found were mailing labels from the USPS and FedEx. A total of approximately 98 suspected
marijuana plants were seized along with approximately 12 pounds of suspected processed
marijuana, almost all of which were located at 237 B.P. (FAA), Lompoc, California.
preliminary field test was conducted receiving a positive result for marijuana on the contraband
seized at the residence. When entry was made at 237 B.P. (FAA), two subjects were present inside of the residence. Both subjects agreed to speak to law enforcement about their drug
trafficking activities and were later chargedand each pleaded guilty to money laundering relating
to marijuana trafficking in the Eastern District of Virginia. CW-1 and CW-2 are cooperating
with law enforcement to obtain consideration for a reduction in sentence regarding federal
criminal charges they face in the Eastern District of Virginia. These cooperating witnesses,
hereafter referred to as CW-1 and CW-2, provided detailed information about their involvement
in marijuana trafficking with BASARAN and others.

14. Law enforcement officers interviewed CW-1, who stated that he lived at 8127
W.C. (FAA), Springfield, Virginia, the same address as on Federal Express package seized on April 7, 2010. CW-1 admitted that he and BASARAN had sent the package containing the money (as outlined in paragraph 11) and it was payment for marijuana that CW-2 had shipped to
Virginia. CW-1 stated that on previous occasions, he had sent money to CW-2 and received
multiple pounds of marijuana at various addresses in Virginia. CW-1 also stated that he met BASARAN approximately in the beginning of 2009 through an unindicted co-conspirator
(hereinafter referred to as UCC-1). UCC-1 recruited CW-1 and BASARAN to transport money
to Florida to purchase multiple pounds of marijuana which were brought back to Northern
Virginia for further distribution. CW-1 stated that he and BASARAN made several trips to
Florida at the request of UCC-1, returning with at least four (4) pounds of marijuana per trip.
During the summer of 2009, CW-1 became aware that CW-2 was "cultivating" marijuana in Lompoc, California, and he began to obtain packages containing marijuana from CW-2 for
himself and BASARAN. CW-1 stated that the money seized by law enforcement on September
16, 2009 (as outlined in paragraph 9) was comprised of money put together by himself, UCC-1 and BASARAN to purchase approximately fifteen (15) to twenty (20) pounds of marijuana for
further distribution. Following the money seizure, CW-1 and BASARAN began to regularly
obtain packages with marijuana from CW-2, through the previously mentioned mailing services.
CW-1 also stated that BASARAN utilized female associates to obtain cashier's checks made
payable to CW-2 to pay for shipments of marijuana.

15. Law enforcement officers interviewed CW-2, who stated that he lived at 237 B.P.
(FAA), Lompoc, Californiaand was not currently employed. CW-2 made later statementsto law
enforcement admitting to mailing multiple packages, usually containing between four (4) and five (5) pounds of marijuana to CW-1 in the Eastern District of Virginia and elsewhere. CW-2
stated that CW-1 told him that he was obtaining the marijuana for himself and his "partner,"
known to CW-2 as "Eray."
16.
Law enforcement officers conducted a review of the mailing labels seized from
the CW-2's residences which showed the following names and addresses:
California Addresses
CS. (FNA)
CM. (FNA) CM. (FNA) RD.(FNA) J.A. (FNA) R.R. (FNA) R&D Designs
832 N.A. (FAA)

1240 H.A. (FAA) 1412 H.A. (FAA) 1612 N.H.S (FAA) 1420 W.S. (FAA) 725 K.A. (FAA) 1412 L.A. (FAA)
Lompoc, California
Goleta, California Goleta, California Lompoc, California Lompoc, California Solvang, California Santa Barbara, California
Northern Virginia Addresses
SJ.(FNA) J.S. (FNA) CH. (FNA)

J.S. (FNA) E.S.(FNA)
R.W. (FNA) M.S. (FNA) J.S. (FNA)
519S.L.S. (FAA) 519 S.L.S. (FAA) 519 S.L.S. (FAA)

519S.L.S.(FAA) 5818 E.C. #152 (FAA)
8082 G.C. (FAA) 12435 A.K.C (FAA) 1407 B.A. #8 (FAA)
Arlington, Virginia Arlington, Virginia Arlington, Virginia

Arlington, Virginia Alexandria, Virginia
Springfield, Virginia Woodbridge, Virginia Woodbridge, Virginia
An additional United States Postal Service Express Mail label dated June 2, 2010 was
found addressed to R.W. (FNA), 8082 G.C (FAA), Springfield, Virginia from J.A. (FNA), 1420
W.S. (FAA), Lompoc, California.

LAW ENFORCEMENT SEIZURE ON JUNE 4. 2010
17.
On or about June 4, 2010, law enforcement officers intercepted the USPS package
addressed to J.S. (FNA), 8082 G.C. (FAA), Springfield, Virginia from R&D Designs, 1412 L.A
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(FAA), Santa Barbara, California. The California address is admittedly utilized by CW-2. On
June 4, 2010, following a positive indication by a law enforcement K-9 trained in the detection
of illegal narcotics, a search warrant was obtained and executed on the package resulting in the
seizure of approximately six (6) pounds of suspected marijuana. A preliminary field test was conducted receiving a positive result for marijuana.
BUSINESS RECORDS OBTAINED FROM FEDEX. UPS AND USPS PERTAINING TO PACKAGES INVOLVING CW-1 AND CW-2
18.
Law enforcement obtained business records from FedEx, UPS, and USPS for
information regarding packages shipped from or to the addresses affiliated with the mailing
labels seized from CW-2's residence (outlined in paragraph 16), as well as the packages seized from law enforcement (outlined in paragraphs 11,12, and 17). In reviewing the records obtained, it was found that between October 15, 2009 and June 4, 2010, approximately forty-three (43)
packages were mailed from the Northern Virginian addresses to either 725 K.A. (FAA), Lompoc, California or 237 B.P. (FAA), Lompoc, California. It was also found that between
October 15, 2009 and June 4, 2010, approximately forty-one (41) packages were mailed from the
known California addresses to the known Northern Virginia addresses. Most, if not all of the
mailing labels had characteristics consistent with the shipping of narcotics including next day delivery dates, waiver of signatures, false names and addresses, and cash payment for express
services. HISTORICAL INFORMATION PERTAINING TO CASHIER'S CHECKS SENT TO CW-2 FOR PAYMENT FOR MARIJUANA PACKAGES
19.
In or about April 2011, law enforcement officers arrested a subject in Alexandria,
Virginia on drug-related charges.
The subject pleaded guilty to this charge in Alexandria,
Virginia and agreed to cooperate with law enforcement. This cooperating witness, hereafter
referred to as CW-3, admitted his involvement in obtaining multiple cashier's checks made
payable to CW-2 at the direction of BASARAN. CW-3 stated that on or about November 5,
2009, he met with BASARAN, who provided him with a total of $9,500 in United States Currency. At the direction of BASARAN, CW-3 went into the Wachovia Bank and obtained
two cashier's checks totaling $9,500 with the provided currency. After obtaining the cashier's
checks, CW-3 met with BASARAN in the same parking lot and turned them over to him. CW-3
admitted completing this same routine with BASARAN on approximately three (3) to five (5)
other occasions. LAW ENFORCEMENT SEIZURE ON SEPTEMBER 21. 2010
20.
On or about September 21, 2010, law enforcement officers intercepted a
suspicious FedEx package addressed to D (FNA), 710 D.S. (FAA), San Jose, California from
M.P. (FNA), 116 S.W.S. (FAA), Arlington, Virginia. On September 22, 2010, following a positive indication by a law enforcement K-9 trained in the detection of illegal narcotics, a search
warrant was obtained and executed on the package resulting in the seizure of $23,300 in United
States Currency.
LAW ENFORCEMENT SEIZURE ON SEPTEMBER 2.2011
21.
On or about September 2, 2011, law enforcement officers intercepted a UPS
package addressed to E.B. (FNA), 118 S.W.S. (FAA) Street, Arlington, Virginia from UPS
Store, 302 T.A. (FAA) San Jose, California. On September 2, 2011, following a positive
indication by a law enforcement K-9 trained in the detection of illegal narcotics, a search warrant
was obtained and executed on the package resulting in the seizure of approximately five (5) pounds of suspected marijuana. Law enforcement conducted a preliminary field-test on the
seized item receiving a positive response for marijuana. Law enforcement met with the intended
Case 1:11-mj-00836-JFA Document 4 ^0^\^
recipient of the seized package, and he agreed to cooperate with law enforcement.
This
cooperating witness, hereafter referred to as CW-4, provided detailed information regarding his marijuana trafficking and involvement with BASARAN and others. CW-4 is cooperating to
obtain consideration for a reduction in sentence regarding federal criminal charges he may face in the Eastern District of Virginia
HISTORICAL INFORMATION PROVIDED BY CW-4
22.
CW-4 stated that in or about early 2009, he was aware that BASARAN was
traveling to Florida at the direction of UCC-1 to obtain multiple pounds of marijuana to bring
back to the Eastern District of Virginia for further distribution. In or about the middle of 2009,
CW-4 and BASARAN began to work together to obtain larger quantities of marijuana. He stated
that BASARAN was receiving packages of multiple pounds of marijuana from CW-2 from the Santa Barbara area and also from an additional unindicted co-conspirator, hereafter referred to as
UCC-2, who was based in San Jose, California. CW-4 stated that he and BASARAN utilized
various means to send the money to California for the payment for the marijuana packages,
which also included utilizing Western Union to send payments to individuals named by UCC-2
and making cash deposits in Virginia into banking accounts in California that were provided by
UCC-2. According to CW-4, BASARAN and two additional unindicted co-conspirators (UCC3 and UCC-4) also travelled to San Jose, California on several occasions during 2010 and 2011 in order to transport large amounts of money to UCC-2 for the purchase of marijuana. CW-4 stated that the package seized on September 2, 2011 (as outlined in paragraph 21) had been sent by UCC-2. CW-4 stated that most of the packages from San Jose, California contained up to
five (5) to six (6) pounds of marijuana at a cost of approximately $3,500 per pound. CW-4 stated
that BASARAN would store both marijuana and United States Currency (drug proceeds) at
10
BASARAN's previous residence located on Crystal Drive, Arlington, Virginia. CW-4 stated
that he and BASARAN obtained packages on a regular basis from 2009 to approximately the
summer of 2011.
HISTORICAL INFORMATION PROVIDED BY CW-5
23.
CW-5 approached law enforcement and began to cooperate with law enforcement
in September 2011. CW-5 is cooperating with law enforcement in the hopes of receiving consideration on pending state charges. CW-5 identified BASARAN as a large-scale marijuana
distributor. CW-5 stated that BASARAN currently resides with his girlfriend, UCC-3, at a
residence on South Columbia Pike, Arlington, Virginia. CW-5 stated that he purchased a total of
approximately 60 pounds of marijuana from BASARAN in 2011. CW-5 stated that he paid
approximately $4,300 for each pound of marijuana he purchased from BASARAN. CW-5 stated
that he would meet BASARAN at his residence on South Columbia Pike, Arlington, Virginia to
purchase the marijuana. CW-5 stated that he has met with BASARAN on South Columbia Pike as recently as two weeks ago. CW-5 stated that BASARAN's marijuana source of supply is
located in California. CW-5 stated that this source of supply sends large amounts of marijuana to BASARAN through the mail. CW-5 further stated that BASARAN recently purchased a black Cadillac sedan and motorcycle with proceeds from the sale of marijuana and that both of
these vehicles are kept at his residence on South Columbia Pike, Arlington, Virginia.
WESTERN UNION RECORDS
24.
Law enforcement officers obtained business records from Western Union in
reference to cash transactions completed by BASARAN and CW-4. The following transactions were found involving subjects identified by CW-4 as individuals to whom UCC-2 directed that
he send payments:
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Case 1:11-mj-00836-JFA Document 4 jf^^"\
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Date
Sender
BASARAN
Payee/Location
Amount
07/26/10
D.A./San Jose, California
$1,000
(same name as outlined in paragraph 20)

08/20/10
09/15/10
BASARAN
BASARAN
M.HVSan Jose, California R.G./San Jose, California
$900 $2,600
09/17/10
CW-4 BASARAN BASARAN

CW-4
R.MVSan Jose, California
$2,500
10/04/10
11/26/10
S.M./San Jose, California

CW-1 /Santa Barbara, California UCC-2/San Jose, California
$2,700
$900 $400
11/27/10
BUSINESS RECORDS OBTAINED FROM FEDEX. UPS AND USPS
PERTAINING TO PACKAGES INVOLVING SAN JOSE. CALIFORNIA
25.
Law enforcement obtained business records from FedEx, UPS, and USPS for
information regarding packages shipped from or to the addresses affiliated addresses provided by
CW-1 and CW-4, as well as the package seized from law enforcement (outlined in paragraphs
11, 12, 17, and 21). In reviewing the records obtained, it was found that between March 25,
2010 and September 2, 2011, approximately seven (7) packages were mailed from Northern Virginia to San Jose, Califorma. It was also found that between March 25, 2010 and September
2, 2011, approximately seventy-one (71) packages were mailed from San Jose, California to the
known Northern Virginia addresses. Most, if not all, of the mailing labels had characteristics
consistent with the shipping of narcotics including next day delivery dates, waiver of signatures,
false names and addresses, and cash payment for express services.
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BANKING RECORDS PERTAINING TO SAN JOSE ACCOUNTS

AFFILIATED WITH UCC-2
26.
Law enforcement obtained business records from Bank of America (BOA) and
Wells Fargo Bank (WFB) in reference to accounts utilized by UCC-2 with the following known
cash deposits made in Virginia, Washington, D.C, or Maryland by BASARAN and others, and
corresponding withdrawals in California. The banking records obtained were located through
information provided by CW-4, law enforcement surveillance, and security video from the
various institutions:
(a)
Bank account #1: R.G. (FNA) - Bank of America, account ending in
numbers 2145. The account was used in this scheme from July 9, 2010 to September 9,2010.
During theaforementioned period of time, $31,820 was deposited and withdrawn from the
account.
Date
07/09/10 08/20/10
Cash Deposit/location
$6,200 / Washington, D.C.
Cash Withdrawal/location
$6,200 / San Jose, California $5,000 / San Jose, California
$5,000 / Arlington, Virginia

$8,000 / Alexandria, Virginia
08/23/10 08/24/10
09/07/10
$8,000 / Milpitas, California

$5,970 / San Jose, California
$5 / San Jose, California $4,995 / San Jose, California

09/09/10
$1,650 / Falls Church, Virginia
(b)
Bank account # 2: S.M. (FNA) - Bank of America, account ending in
numbers 1425. The account was used in this scheme from September 8, 2010 to September 16,
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2010. During the aforementioned period of time, $28,746 was deposited and subsequently
withdrawn from the account. Date
Cash Deposit/location
09/08/10
09/09/10
$5,746 / Forestville, Maryland


09/13/10 09/14/10 09/16/10

$5,000 / Milpitas, California
(c)
Bank account #3: "D" (same subject identified in paragraph 20) - Bank of
America, account ending in numbers 8099. The account was used in this scheme from October 27,2010 to December 08,2010. Duringthe aforementioned period of time, $48,725 was
deposited into theaccount and $48,575.27 was subsequently withdrawn from theaccount.
Date
10/27/10
Cash Deposit/Location
$7,300 / Santa Clara, California $2,500 / San Jose, California
11/02/10
11/16/10

11/17/10
$8,000 / San Jose, California $4,200 / San Jose, California $2,500 / San Jose, California
11/24/10 11/26/10 11 /30/10

12/03/10
$4,200 / Arlington, Virginia $2,500 / Arlington, Virginia $6,425 / Arlington, Virginia

12/07/10
$5,960.27 / San Jose, California

* check to close account*
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(d)
Bank account #4: M.P. (FNA)- Bank of America, account ending in
numbers 2855. The account was used in this scheme from December 06,2010 to March 09, 2011. During the aforementioned period of time, $20,500 was deposited into the account and $20,400 was subsequently withdrawn from the account.
Date
12/06/10

$4,000 / San Jose, CA
12/07/10
12/08/10
$4,000 / Woodbridge, Virginia $3,000 / Forestville, Maryland

01/14/11 03/07/11 03/09/11
(e)
Bank account #5: CH. (FNA) - JP Morgan Chase Bank / Wells Fargo,
account ending in number 0207. The account was used in this scheme from February 9,2011 to
February 18,2011. During the aforementioned period oftime, $22,810 was deposited into the
account and $22,600 was subsequently withdrawn from the account.
Date
02/09/11
02/14/11 02/16/11
$8,000 / Oxon Hill, Maryland

$6,810/Oxon Hill, Maryland 8,000 / District Heights, Maryland
$8,000 / San Jose, CA1

$6,700 / San Jose, CA $7,900 / San Jose, CA
(f)
Bank account #6: R.F.L. - Bank of America, account ending in numbers
6342. The account was used in this scheme from March 09,2011 to April 07,2011. During the
1Law enforcement have determined that this account was based in San Jose, California; however, law enforcement
have notyetreceived records to determine theexact branch locations where these amounts were withdrawn from
this account.
15
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aforementioned period of time, $165,000 was deposited into the account and $164,772.81 was
subsequently withdrawn from the account.

Date
02/24/11
$9,000 / Oxon Hill, Maryland
$9,000 / Capitol Heights, Maryland $9,000 / San Jose, CA

02/25/11
02/28/11
03/09/11

$1,600/San Jose, CA

03/10/11

03/11/2011
$400 / Transferto Acct ending 6441

03/14/11

03/15/11

03/16/11
$200 / Transferto Acct ending 6441

03/17/11
$9,000 / Arlington, Virginia $9,000 / Oxon Hill, Maryland
16
Case 1:11-mj-00836-JFA Document 4 J0^\

JV^^S\
03/18/11
03/21/11
$9,000 / Annandale, Virginia

03/22/11 03/23/11
03/30/11

$9,500/Arlington, Virginia
03/31/11
$9,500 / Mt. Vernon, Virginia

04/01/11
04/04/11
$995 / Falls Church, Virginia *money order $495 / Falls Church, Virginia *money order 04/05/11 $9,000 / Arlington, Virginia
(g)
Bank account #7: R.L. /L.N.S.B. - Bank of America, account ending in
numbers 4038. The account was used in this scheme from July 28,2011 to August 22,2011.
During the aforementioned period of time, $141,000 was deposited into the account and $70,700
was subsequently withdrawn from the account.
Date
07/28/11 08/01/11
Cash Deposit/Location $19,000 / Falls Church, Virginia
08/04/11
08/12/11 08/15/11
$12,000 / Arlington, Virginia $24,000 / Arlington, Virginia

$ 15,000/San Jose, CA
17
Case 1:11-mj-00836-JFA Document 4 yffl^^V
08/16/11 08/17/11 08/18/11
$26,300 / Alexandria, Virginia $22,700 / Arlington, Virginia

08/22/11
08/24/11 08/25/11
$18,000/Falls Church, Virginia $19,000 / Falls Church, Virginia

$ 13,000/San Jose, CA
(h)
Bank account #8: R.C/CB.B.B. - Bank of America, account ending in
numbers 4033. The account was used in this scheme from August 1,2011 to August 17,2011.
During the aforementioned periodof time, $230,300 was deposited into the account and $78,500
was subsequently withdrawn from the account. Date
08/01/11 08/04/11
08/08/11 08/12/11 08/15/11 08/16/11
08/17/11
$33,500 / Annandale, Virginia


08/22/11
08/24/11 08/26/11 08/29/11

42,000 / Annandale, Virginia
$13,500/San Jose, CA
CASH PURCHASE OF SUZUKI MOTORCYCLE ON JUNE 7.2011
18
27.
Law enforcement obtained business records that showed that on or about June 7,
2011,
BASARAN
purchased
2011
Suzuki
GSX-R750
Motorcycle
(VIN
JS1GR7MA0B2102531) from Coleman Powersports, 435 South Washington Street, Falls
Church, Virginia. Business records were obtained from the Department of Treasury regarding the purchase of the motorcycle. A Form 8300 was filed by Coleman Powersports, showing BASARAN paid $12,000 of that money in United States currency, with $4,000 of that money
being in denominations of $100 or higher. The motorcycle was purchased in full and there is no
lien on the vehicle.
28.
Law enforcement obtained business records from the Virginia Employment
Commission (VEC) that showed the last reported wages for BASARAN occur in the third
quarter of 2009. There are no reported W-2 wages, via the VEC, in 2010 or 2011, or other indications of legitimate employment for BASARAN.
19
CONCLUSION
29.
Based on the foregoing, there is probable cause to believe that, between in and
around 2009 through in and around September 2011, ERAY EMRE BASARAN did unlawfully,
knowingly, and intentionally conspire to distribute 100 kilograms or more of marijuana, a

Schedule I controlled substance, in violation of Title 21, United States Code, Sections 841(a)(1)
and 846.
JameslMcHugH, Special Agent DruWEnforcernent Administration
Sworn and subscribed to before me theJ_ day of October 2011
JsL
John F. Anderson
United States Magistrate Judge
20

Eray Basaran Complaint

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Eray Basaran Complaint

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Case 1:11-mj-00836-JFA Document 4 A^SH^V

Filed 10/04/11 ^W^k 1 of 20 PageID# 4 Page

TjlATES DISTRICT COURT FOR THE

UNITED STATES OF AMERICA

ERAY EMRE BASARAN

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND ARREST WARRANT

I, James McHugh, being duly sworn, depose and state as follows:

Case 1:11-mj-00836-JFA Document 4

Filed 10/04/11 Page 2 of 20 PageID# 5

This affidavit is made in support of a criminal complaint and arrest warrant

In or about 2009, law enforcement officers obtained information that ERAY

Case 1:11-mj-00836-JFA Document 4

Filed 10/04/11 Page 3 of 20 PageID# 6

Through further investigation and information provided by confidential witnesses,

On or about September 16, 2009, in Ridgeland, South Carolina, law enforcement

On or about November 5, 2009, law enforcement conducted surveillance in

Case 1:11-mj-00836-JFA Document 4

Filed 10/04/11 Page 4 of 20 PageID# 7

for $4,500 payable to a subject in Lompoc, California.

On or about April 7, 2010, law enforcement officers intercepted a suspicious

package resulting in the seizure of $13,000 in United States Currency.

confirmed the substance to be marijuana and weighing approximately 2,248 grams.

Case 1:11-mj-00836-JFA Document 4

Filed 10/04/11 Page 5 of 20 PageID# 8

LAW ENFORCEMENT SEIZURE AND STATEMENTS ON JUNE 3.2010

On or about June 3, 2010, law enforcement officers executed search warrants at

paraphernalia, along with a total of approximately $23,039 in United States Currency.

in marijuana trafficking with BASARAN and others.

Case 1:11-mj-00836-JFA Document 4

Filed 10/04/11 Page 6 of 20 PageID# 9

payable to CW-2 to pay for shipments of marijuana.

Case 1:11-mj-00836-JFA Document 4

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832 N.A. (FAA)

Northern Virginia Addresses

SJ.(FNA) J.S. (FNA) CH. (FNA)

519S.L.S. (FAA) 519 S.L.S. (FAA) 519 S.L.S. (FAA)

Arlington, Virginia Arlington, Virginia Arlington, Virginia

W.S. (FAA), Lompoc, California.

Case 1:11-mj-00836-JFA Document 4

Filed 10/04/11 /^^wjh 8 of 20 PageID# 11 Page

In or about April 2011, law enforcement officers arrested a subject in Alexandria,

Virginia on drug-related charges.

The subject pleaded guilty to this charge in Alexandria,

Case 1:11-mj-00836-JFA Document 4

Filed 10/04/11 Page 9 of 20 PageID# 12

On or about September 21, 2010, law enforcement officers intercepted a

On or about September 2, 2011, law enforcement officers intercepted a UPS

Case 1:11-mj-00836-JFA Document 4 ^0^\^

Filed 10/04/11 Page 10 of 20 PageID# 13

Case 1:11-mj-00836-JFA Document 4

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Law enforcement officers obtained business records from Western Union in

Case 1:11-mj-00836-JFA Document 4 jf^^"\

Filed 10/04/11 Page 12 of 20 PageID# 15 /^^fK

D.A./San Jose, California

(same name as outlined in paragraph 20)

M.HVSan Jose, California R.G./San Jose, California

CW-4 BASARAN BASARAN

R.MVSan Jose, California

S.M./San Jose, California

BUSINESS RECORDS OBTAINED FROM FEDEX. UPS AND USPS

PERTAINING TO PACKAGES INVOLVING SAN JOSE. CALIFORNIA