Eray Basaran Complaint

8/3/2019 Eray Basaran Complaint

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UNITED STATES OF AMERICA

ERAY EMRE BASARAN

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TjlATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandr ia Divis ion CLERK, Js~Dlt.Tf-:rcT(XHJRTALFXANDRiA. Vlf-.C'i •'..

CRIMINAL NO: 1:11MJ836

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 Filed 10/04/11 Page 1 of 20 PageID# 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

informationprovidedby cooperating witnesses. All observations referenced in this affidavit that

were not made byme 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 ofVirginia 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 ofmarijuana, which was sent to various locations

in the Eastern District ofVirginia 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 inwhich he provided his home address as 519

S.L.S. (full address abbreviated, hereinafter "FAA"), Arlington, Virginia.

LAW ENFORCEMENT SURVE ILLANCE ON NOVEMBER 5. 2009

10. On or about November 5, 2009, l aw 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 $4,500payable 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

marijuanadistributor 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 seizureof $13,000in United StatesCurrency.

LAW ENFORCEMENT SEIZURE ON M AY 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. A

preliminary field test was conducted receiving a positive result formarijuana 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 andwere laterchargedand eachpleaded 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 marijuanatraffickingwith BASARANand 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 uti lized female associa tes to obtain cashier's checks made

payable to CW-2 to pay for shipments ofmarijuana.

15. Law enforcement officers interviewed CW-2, who sta ted that he l ived at 237 B.P.

(FAA), Lompoc, Californiaandwas not currently employed. CW-2made later statementsto law

enforcement admitting to mailing multiple packages, usually containing between four (4) and

five (5) pounds ofmarijuana to CW-1 in the Eastern District ofVirginia 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) 832 N.A. (FAA) Lompoc, California

CM. (FNA) 1240 H.A. (FAA) Goleta, California

CM. (FNA) 1412H.A. (FAA) Goleta, California

RD.(FNA) 1612N.H.S (FAA) Lompoc, California

J.A. (FNA) 1420W.S. (FAA) Lompoc, California

R.R. (FNA) 725 K.A. (FAA) Solvang, California

R&DDesigns 1412 L.A. (FAA) Santa Barbara, California

Northern Virginia Addresses

SJ.(FNA) 519S.L.S. (FAA) Arlington, Virginia

J.S. (FNA) 519 S.L.S. (FAA) Arlington, Virginia

CH. (FNA) 519 S.L.S. (FAA) Arlington, Virginia

J.S. (FNA) 519S.L.S.(FAA) Arlington, Virginia

E.S.(FNA) 5818 E.C. #152 (FAA) Alexandria, Virginia

R.W. (FNA) 8082 G.C. (FAA) Springfield, Virginia

M.S. (FNA) 12435 A.K.C (FAA) Woodbridge, Virginia

J.S. (FNA) 1407 B.A. #8 (FAA) 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 . 2 01 0

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 obtainedand executed on the package resulting in the

seizure of approximately six (6) pounds of suspected marijuana. A preliminary field test was

conductedreceivinga positive result formarijuana.

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 MARI JUANA 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

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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 .2 011

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




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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 ofVirginia

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 ofVirginia for further distribution. In or about the middle of 2009,

CW-4 and BASARANbegan to work together to obtain larger quantities ofmarijuana. 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 makingcash 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 (UCC-

3 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 ofmarijuana 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

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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 o f 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

considerationon pending state charges. CW-5 identified BASARAN as a large-scalemarijuana

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 $4,300for each poundof marijuana he purchasedfrom 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 hasmet withBASARAN on SouthColumbia 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 ofmarijuana

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 vehiclesare kept at his residence on South ColumbiaPike, Arlington,Virginia.

WESTERN UNION RECORDS

24. Law enforcement officers obt ai ned bus ines s r ecords 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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Date Sender

07/26/10 BASARAN

08/20/10 BASARAN

09/15/10 BASARAN

09/17/10 CW-4

10/04/10 BASARAN

11/26/10 BASARAN

11/27/10 CW-4

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Payee/Location Amoun t

D.A./San Jose, California $1,000

(same name as outlined in paragraph 20)

M.HVSan Jose, California $900

R.G./San Jose, California $2,600

R.MVSan Jose, California $2,500

S.M./San Jose, California $2,700

CW-1 /Santa Barbara, California $900

UCC-2/San Jose, California $400

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) Bankaccount #1: R.G. (FNA)- Bank ofAmerica, 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

accoun t .

Date CashDeposit/location CashWithdrawal/location

07/09/10

08/20/10

08/23/10

08/24/10

09/07/10

09/09/10

$6,200 / Washington, D.C.

$5,000 / Arlington, Virginia

$8,000 / Alexandria, Virginia



$1,650 / Falls Church, Virginia

(b) Bank account # 2: S.M. (FNA) - Bank ofAmerica, account ending in

numbers 1425. The account was used in this scheme from September 8, 2010 to September 16,

13

$6,200 / San Jose, California


$8,000 / Milpitas, California


$5 / San Jose, California






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2010. During the aforementionedperiodof time, $28,746 wasdeposited and subsequently

withdrawn f rom t he a ccount .

Date

09/08/10

09/09/10

09/13/10

09/14/10

09/16/10

Cash Deposit/location

$5,746 / Forestville, Maryland





(c) Bankaccount#3: "D" (same subject identifiedin paragraph 20) - Bankof

America, account ending in numbers 8099. The account was used in this schemefrom October

27,2010 toDecember 08,2010. Duringthe aforementioned periodof time, $48,725 was

deposited into theaccount and $48,575.27 was subsequently withdrawn from theaccount.

Date Cash Deposit/Location CashWithdrawal/location

10/27/10 $7,300 / Arlington, Virginia


11/16/10 $5,500 / Washington, D.C.

11/17/10 $8,000 / Forestville, Maryland



11 /30/10 $6,425 / Arlington, Virginia

12/03/10 $6,300 / Washington, D.C.


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Cash Withdrawal/location





$5,000 / Milpitas, California

$7,300 / Santa Clara, California








$5,960.27 / San Jose, California

*check to close account*




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(d) Bankaccount#4: M.P.(FNA)- Bankof America, accountending 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 Cash Deposit/Location Cash Withdrawal/location

12/06/10

12/07/10

12/08/10

01/14/11

03/07/11

03/09/11

(e)


$4,000 / Woodbridge, Virginia



$9,000 / San Jose, CA

Bank account #5: CH. (FNA) - JP Morgan Chase Bank / Wells Fargo,

account ending in number 0207. The account was used inthis scheme from February 9,2011 to

February 18,2011. During the aforementioned period of time, $22,810 was deposited into the

account and$22,600was subsequentlywithdrawn from the account.

Date CashDeposit/Location CashWithdrawal/location

02/09/11 $8,000 / Oxon Hill, Maryland $8,000 / San Jose, CA1

02/14/11 $6,810/Oxon Hill, Maryland $6,700 / San Jose, CA

02/16/11 8,000 / District Heights, Maryland $7,900 / San Jose, CA

(f) Bank account #6:R.F.L. - Bank ofAmerica, 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 notyet received records todetermine theexact branch locations where these amounts were withdrawn from

th is account .

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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.


02/24/11

02/25/11

02/28/11

03/09/11

03/10/11

03/11/2011

03/14/11

03/15/11

03/16/11

03/17/11


$9,000 / Oxon Hill, Maryland

$9,000 / Capitol Heights, Maryland





$8,000/ Arlington, Virginia






$9,000 / Oxon Hill, Maryland

16




$1,600/San Jose, CA

$400/ Transferto Acctending6441




$200/ Transferto Acctending6441






03/18/11

03/21/11

03/22/11

03/23/11

03/30/11

03/31/11

04/01/11

04/04/11

07/28/11

08/01/11

08/04/11

08/12/11

08/15/11

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$9,000 / Annandale, Virginia



$9,500/Arlington, Virginia

$9,500 / Mt. Vernon, Virginia

$9,500 / Washington, D.C.


$995 / Falls Church, Virginia *money order

$495 / Falls Church, Virginia *money order


(g) Bank account #7: R.L. /L.N.S.B. - Bank ofAmerica, account ending in

numbers 4038. The account was used in this scheme from July 28,2011 to August 22,2011.

During the aforementionedperiod of time, $141,000was deposited into the account and $70,700

was subsequently withdrawn from the account.





17

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$15,000/San Jose, CA




08/16/11

08/17/11

08/18/11

08/22/11

08/24/11

08/25/11

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$18,000/Falls Church, Virginia




(h) Bank account #8: R.C/CB.B.B. - Bank ofAmerica, 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 wasdeposited intothe account and$78,500

was subsequently withdrawn from the account.


08/01/11

08/04/11

08/08/11

08/12/11

08/15/11

08/16/11

08/17/11

08/22/11

08/24/11

08/26/11

08/29/11



$33,500 / Annandale, Virginia






$25,000 / Arlington, Virginia $20,000 / San Jose, CA


42,000 / Annandale, Virginia


CASH PURCHASE OF SUZUKI MOTORCYCLE ON JUNE 7.2011

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27. Law enforcement obtained business records that showed that on or about June 7,

2011, BASARAN purchased a 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

l ien 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.

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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 ofTitle 21, United States Code, Sections 841(a)(1)

and 846.

JameslMcHugH, Special Agent

DruWEnforcernent Administration

4 £worn andsubscribed to before metheJ_ day ofOctober 2011

JsL

John F. Anderson

UnitedStates MagistrateJudge

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Documents

Eray Basaran Complaint