STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE COUNTY OF NEW HANOVER SUPERIOR COURT DIVISION FILE NO. 17 CVS AFFIDAVIT LIEUTENANT S.A. BOUCHER, LIEUTENANT $.A. CHER, appearing before the undersigned notary and being duly swom (or affirmed), says that: 1. Tam nota party in this matter. 2. Teurrently, and for more than 20 years, have been employed as a police officer for the Wilmington Police Department, New Hanover County, North Carolina, and I am currently assigned to the Northwest Patrol Division. 3. Lam familiar with the property located at 2916 Market Street, Wilmington, New ‘Hanover County, North Carolina (hereinafter “the Property”). This address houses a hotel ‘commonly known as the Carolinian Inn, 4, know the Carolinian Inn property is owned by Rigi, Inc. 5. have researched records maintained by the North Carolina Secretary of State which relate to Rigi, Inc, 6. Records maintained by the North Carolina Secretary of State indicate: (A) Rigi, Inc., was formed on July 12, 1996; (B) Laxman 8. Odedra is the President and Registered Agent of Rigi, Ine.; (©) Hiri Odedra is the Secretary of Rigi, Inc, and has served in that capacity for more than 20 years; 7. Thave researched records maintained by the New Hanover County Register of ‘Deeds which relate to Defendants Laxman S. Odedra, Hiri Odedra, and Rigi, Inc. EXHIBIT8. Records maintained by the New Hanover County Register of Deeds indicate: (A) Laxman S. Odedra and wife Hiri Odedra conveyed the Property to Rigi, Inc., on December 17, 1998, (B) On December 17, 1998, Laxman S, Odedra and Hiri Odedra signed a Deed of Trust in the original principal amount of $1,200,000.00 on behelf of Rigi, Inc. (©) InMay 2013, Laxman 8. Odedra and Hiri Odedra purchased a tract of real estate in New Hanover County, At that time, they were husband and wife. 9. As part of my duties, I maintain regular contact with citizens who reside in and around the community where the Property is looated (hereinafter “such citizens”). 10. Ihave been advised by such citizens that the Caolinian Inn currently, and has for a considerable period of time, maintained a general reputation as a place whereon occurs: (A) Assignation; (B) Prostitution in the form of females engaging in sexual acts with males in ‘exchange for money or controlled substances; (©) legal possession and sale of controlled substances including heroin, powder cocaine, and crack cocaine; (D) _ Repeated acts which create and constitute breaches of the peace, including, but not limited to, assaults, robberies, shootings, and other violent and disruptive acts. 11. have been advised by such citizens, that many of the people who visit and loiter ‘on and about the Property, have reputations as prostitutes, drug dealers, and people prone to engage in violent criminal activities.12. Because of the easy availability of controlled substances, the Carolinian Inn is commonly referred to as “Drug Town.” 13. ‘The owners of the Carolinian Inn maintain a gererel reputation for knowing of the illegal activities occurring on their property but are unwilling or unable to prevent them from occurring. 14, Prostitutes and illegal drug users have told me they frequent the Property to engage in illegal activities. 15. . A prostitute has told me that she often engagediin sexual activities, including sexual intercourse and oral sex, with men at the Property in exchange for money or drugs. 16. A prostitute has told me that she engaged in sexual activities, such as oral sex on other women at the Property, in exchange for money. 17. Drug addicts have told me they frequent the Property to buy and use illegal drugs, including heroin, powder cocaine, and crack cocaine 18. Arrecovering heroin addict reported visiting the Property at least 20 times for the sole purpose of buying heroin. During one visit, the addict reported seeing approximately 1,000 Gosage units of heroin in a room at the Property. 19, A second recovering heroin addict admitted to buying and selling heroin on the Property. During one visit, the addict reported seeing approximately 100 dosage units of heroin ina room. On another visit, the addict watched a drug dealer package approximately two ounces of crack cocaine for sale in individual dosage units. 20. Wilmington Police Officers routinely respond to the Property in search of stolen cars and people who are wanted on various warrants.21, InDecember 2015, Rigi, Inc., and Laxman 8. Odedra were notified in writing that anuisance exists on the Carolinian Inn property. 22, Since the written notification was sent to Rigi, te. and Laxman $, Odedra, illegal activities have continued at the Carolinian Inn, Such activities include, but are not limited to violations of the North Carolina Controlled Substance Act, including a fatal heroin overdose; robbery; and assaults, 23. A recovering heroin addict personally reported to me having bought heroin or cocaine at the Property more than 25 times between January 2016 and June 2016. 24. have access to and have researched or otherwise caused to be researched official Wilmington Police Department records relating to investigations and calls for police service to the Property, such records setting forth activities of the department and setting forth matters observed pursuant to duty imposed by law as to which matters there was a duty to report. ‘The date and nature of these investigations and calls are attached to this affidavit and include but ace not limited to the information listed (see attachments 24-1) 28. Because of the criminal element attracted to the Property, the repeated occurrences of prostitution and drug violations on the Property, and the violent activities which coincide with the illegal drug trade, I believe the Carolinian Inn isa detriment to the community and clearly a public muisanee, 26. Further your affiant saith not. f L, f. Affiant Some (ramet) ad sbi meg ty ALAN 1. day of % (oma eat) ‘Notary Palio Ny Commission epirs 4 é “oBOURTR o 4Date May 6,2017 April 29, 2017 February 15, 2017 December 14, 2016 October 8, 2016 July 30, 2016 July 30, 2016 April 12, 2016 ATTACHMENTS 24-1 Calls and Investigations ASSAULT ON A FEMALE: Wilmington Police responded to room 118 at the Property in reference to a domestic disturbance. Officers found an intoxicated male who assaulted a female by hitting her in the face and neck, One person was arrested. ASSAULT WITH A DEADLY WEAPON: Wilmington Police responded to room 144 at the Property in reference to a domestic disturbance, Investigating officers found female occupant cut male occupant with a box cutter. COMMON LAW ROBBERY: Wilmington Police responded to the Property in reference to a robbery. Suspect entered office and requested clerk give him change for one dollar. When employee opened cash drawer, suspect took cash and fled. ASSAULT: Wilmington Police responded to the Property in reference to an assault. COMMUNICATING THREATS: Wilmington Police responded to the Property in reference to a complaint of a person communicating threats, DRUG OVERDOSE: Wilmington Police responded to Room 138 at the Property in reference to a drug overdose. Victim admitted to ingesting two or three dosage units of heroin. DRUG OVERDOSE: Wilmington Police responded to the Property in reference to a drug overdose. DRUG OVERDOSE: Wilmington Police responded to Room 112 at the Property in reference to a fatal drug overdose. Police found deceased victim, five syringes and 33 heroin bindle wrappings in the room. Hiri Odedra was identified by police as the “owner” of the Property. The victim overdosed on heroin the previous day near downtown Wilmington.Date April 12, 2016 January 14, 2016 December 11, 2015 ‘November 29, 2015 November 29, 2015 November 29, 2015 September 10, 2015 June 27, 2015 Calls and Investigations ASSAULT ON A FEMALE: Wilmington Police responded to Room 117 at the Property in reference to a domestic disturbance. Investigation revealed a male assaulted a female. One person was arrested, DRUG VIOLATION: Wilmington Police checked on a suspicious vehicle parked at the Property. One occupant of the vehicle was arrested for possession of heroinand possession of drug paraphernalia. NOTICE TO ABATE NUISANCE: Wilmington Police sent ‘written notice to the owner of the Carolinian Inn that a public nuisance exists on the Property. RESIST, OSBTRUCT, AND DELAY: While investigating a fatal shooting in room on the Property, Wilmington Police arrested a juvenile for resist, obstruct, and delay a law enforcement officer in the performance of his duties. DRUG VIOLATION: Wilmingion Police responded to the Property to serve an outstanding warrant on a person, The person, William Burton was arrested, searched, and found to be in possession of 8 dosage units of heroin. SHOOTING: Wilmington Police responded to Room 139 at the Property in reference to a shooting. Investigation revealed gunshot victim attempted to rob room occupant. A fight ensued. Room ‘occupant took gun from suspect and shot him several times. He later died, RESIST, OSBIRUCT, AND DELAY: Wilmington Police responded to Room105 at the Property in reference to a domestic disturbance. A female was arrested for misuse of the 911 system and resist, obstruct, and delay a lew enforcement officer. ARMED ROBBERY: Wilmington Police responded to room 137 at the Property in reference to a robbery. Male and female victims reported being robbed at gunpoin: on the Property. Suspects pistol whipped female victim and took male victim's wallet.Date June 26, 2015 June 12, 2015 June 7, 2015 May 20, 2015 May 20, 2015 April 24, 2015 April 7, 2015 March 21, 2015 March 17, 2015 Calls and Investigations DRUG VIOLATION: Wilmington Police executed a search ‘warrant in Room 136 at the Property. Officers seized more than 200 dosage units of heroin along with crack cocaine. Three people were arrested, DRUG OVERDOSE: Wilmington Police investigating a larceny at the Property discovered female overdose victim in Room 151 at ‘the Property. ARMED ROBBERY: Wilmington Police responded to the Property in reference to an armed robbery. Female victim reported being robbed at gunpoint in the parking area on the Property. Suspect took victim’s purse, cell phone, and $21.00. DRUG VIOLATION: Wilmingion Police responded to Room 141 at the Property in reference to a drug investigation. Officers seized 69 dosage units of heroin, marijuana, and drug paraphemalia. One person was arrested. DRUG VIOLATION: Wilmington Police arrested a female on the Property for possession of heroin. ASSAULT WITH A DEADLY WEAPON: Wilmington Police responded to the Property in reference to a fight. Officers found a female victim had been assaulted twice by male suspect who lad given her heroin, DRUG VIOLATION: A confidential source of information ‘working under the direction of the Wilmington Police Department purchased 10 dosage units of heroin from Thomas Jackson at the Property. ASSAULT ON A FEMALE: Wilmington Police responded to Room 141 at the Property in reference to and assault. Female ‘victim reported being pushed and struck in the back of the head by a male who refused to leave her room. DRUG VIOLATION: Wilmington Police seized two dosage units of heroin from a female in Room 137 at the Property.Date Jaruary 28, 2015 January 10, 2015 November 4, 2014 September 8, 2014 September 8, 2014 August 2, 2014 June 10, 2014 Calls and Investigations DRUG VIOLATION: Wilmington Police visited the Property to serve outstanding warrants on two people. One was arrested and found in possession of opiates and MDMA. A second person was charged with resist, obstruct, and delay a law enforcement officer. ASSAULT ON A FEMALE and DRUG VIOLATION: ‘Wilmington Police responded to room 139 at the Property in reference to an assault on a female. Officers discovered male and ‘female had assaulted each other. Officers also recovered 17 dosage units of heroin, 5 dosage units of clonazepam, and 7 small bags of marijuana. The male and female were arrested. DRUG COMPLAINT: Wilmington Police responded to Room 143 at the Property in reference to adrug complaint, After no one answered the door, the officer went to the office and spoke with an employee, The employee told the officer the area was “full of prostitution and possible narcotic activity.” DRUG VIOLATION: Wilmington Police responded to the Property in reference to a suspicious chemical found on a pillow case. Investigation led to Room 136 where officers found an active methamphetamine lab. One person was arrested for possession of methamphetamine, DRUG VIOLATION: Wilmington Police responded to Room 136 at the Property to assist Probation and Parole with a search. The probationer was found to be in possession of marijuana, drug paraphemalia (syringes), and heroin, ASSAULT ON A FEMALE: Wilmington Police responded to room 271 at the Property in reference to a disturbance, During a fight among several people in the room, a female was assaulted. DRUG VIOLATION: Wilmington Police responded to Room 140 at the Property in reference fo a complaint of drug violations, Officers found the room occupied by a person who admitted to being a prostitute. After finding a pipe used the smoke crack cocaine, the female was issued a citation for possession of drug parephernalia,Date May 19, 2014 April 5, 2014 November 1, 2013 October 3, 2013 July 5, 2013 July 4, 2013 July 1, 2013 May 7, 2013 March 7, 2013 Calls and Investigations DRUG VIOLATION: A confidential source of information working under the direction of the Wilmington Police Department purchased 10 dosage units of heroin from Reginald Fennell a the Property. ARMED ROBBERY: Wilmington Police responded to the Property in reference to an armed robbery. Victim reported suspect used a blunt object to rob him of a motor scooter, ASSAULT ON A FEMALE; Wilmington Police responded to room 108 at the Property in reference to a domestic disturbance. A sale was arrested for assault on a female. DRUG VIOLATION and ASSAULT: Wilmington Police arrested two people in Room 152 at the Property for possession of drug paraphernalia, One of the two aresices was charged with assault ‘on emergency personnel. DRUG VIOLATION: Wilmington Police amested one person on the Property for possession of drug paraphernalia and resist, obstruct, and delay a Jaw enforcement officer. DRUG VIOLATION: Wilmington Police arrested a person in Room 142 at the Property for possession of heroin. Officers found suspect hiding in a closet possessed 5 dosage units of heroin. ARMED ROBBERY: Wilmington Police responded to Room 138 at the Property in reference to anarmed robbery. Suspect walked into unlocked room, brandished s handgun, and demanded money. ‘Victim gave him $100.00. DRUG VIOLATION: Wilmington Police followed a suspicious vehicle to the Property and spoke with the female driver. She told the officers she was staying in Room 271. The female gave officers consent to search her room where they found 5 dosage units of heroin, DRUG OVERDOSE: Wilmington Police and EMS units responded to Room 143 at the Property in reference to a drug overdose. A female was found unconscious in the room. Two empty heroin bindles and a syringe were also found in the room.Date February 24, 2013 August 18, 2012 June 3, 2012 June 2, 2012 May 27, 2012 August 7, 2011 June 29, 2011 Calls and Investigations DISORDI ‘Wilmington Police responded to the Property in reference to a disturbance. One person was arrested for disorderly conduct. RAPE: Wilmington Police investigated a complaint ofa rape Which occurred in @ 100m at the Property. Suspect attacked and raped victiin as she was getting in the shower. RESIST, OBSTRUCT, AND DELAY: Wilmington Police responded to the office at the Property in reference to an assault. Male victim reported he was assaulted by people in Room 105. One person in the zoom was arrested for resist, obstruct, and delay a law enforcement officer after refusing to open the room door. DRUG VIOLATION: Wilmingion Police charged one person on the Property for possession of marijuana. Suspect concealed the marijuana in his buttocks. ARMED ROBBERY: Wilmington Police responded to Room 217 at the Property in reference to anarmed robbery. Victims reported suspect came in their room to use the rest room. Minutes later suspect brandished a handgun ashe exited the rest room. He demanded money, took $20.00, and left. ARMED ROBBERY: Wilmington Police responded to the office at the Property in reference to an armed robbery. Employee reported suspect said he had a gun and demanded money in the cash register. Suspect, who took approximately $90.00, was arrested later. ASSAULT BY POINTING A GUN: Victims were leaving on bicycles when three people loitering on the Property offered to sell them marijuana. Victims refused and notified hotel staff in the office. As victims rode away the three people chased them. One pointed a gun at them.