Case 1:19-mj-02005-EGT Document 2 Entered on FLSD Docket 01/04/2019 Pape 30f5
AFFIDAVIT IN SUPPORT OF AMENDED CRIMINAL COMPLAINT,
I, Adam Jefferson, being duly swom, depose and states as follows:
1. Tama Special Agent employed with Homeland Security Investigations (“HSI”) of the
United States Department of Homeland Security and have been so employed since February 2011.
Tam assigned to the Border Enforcement Security Task Force, Seaport Group. My current
responsibilities and duties include the investigation and enforcement of laws and regulations to
include narcotics, firearms, fraud, and violations of the Immigration and Nationality Act.
2. The facts contained in this Affidavit are based on my personal knowledge, as well as
knowledge, information, and documentation that I obtained from other law enforcement officers.
I am submitting this Affidavit for the limited purpose of establishing probable cause that
WILFORD THOBOURNE (“THOBOURNE") (1) dd knowingly and intentionally import into
the United States, from a place outside thereof, a controlled substance, in violation of Title 21,
United States Code, Section 952(a); and (2) did knowingly and intentionally possess with intent to
distribute a controlled substance, in violation of Title 21, United States Code, Section 841(a)(1).
The facts set forth herein do not constitute all the facts known to law enforcement officers
regarding this matter. Rather, it includes those facts necessary to establish probably cause in
support of the criminal complaint.' :
PROBABLE CAUSE
3. On Wednesday, January 2, 2019, HSI Special Agents and Customs and Border
Protection Officers (“CBPO”) conducted surveillance of the Oceania Riviera Cruise ship. The
vessel arrived at the Port of Miami from Puerto Rico, Gustavia, Castries, Kingstown, and various
+On January 3, 2019, the Honorable Edwin G. Torres signed the instant complaint, however, the
defendant’s name was typed incorrectly. The prior complaint read Wilfred Thobourne rather than
Wilford Thobourne. |Case 1:19-m-02005-EGT Document? Entered on FLSD Docket 0104/2019 Paye 4 of 5
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other paces in the Caribbean. At epproximssly, 1215 hous, agents observed crewmember,
THOBOURNE, exit the Riviera from the crew gangway. '
4, Agents observed THOBOURNE walk with an unnatural and siff gait as he walked on
the dock. Agents approached THOBOURNE, identified themselves and conducted a border search
of THOBOURNE and his belongings. During the border search, agents felt a hard object in the
groin area of THOBOURNE’s jeans. THOBOURNE was then escorted to the secondary area for
further examination.
5. During the secondary examination, CBP Officers conducted a fll search and pat-down
of THOBOURNE. During the search, CBP Officers discovered that THOBOURNE was wearing
approximately five pairs of various shorts and underwear underneath his jeans. CBP Officers
discovered a large object inside of a pair of black underwear wom by THOBOURNE. CBP
Officers probed the package and discovered a white powdery substance which field tested positive
for cocaine. The cocaine found inside of the underwear weighed approximately 817 grams (1.8
pounds). !
6. Thereafter, CBP Officers examined THOBOURNE’s sandals utilizing an X-ray
machine and discovered anomalies in the soles of the sandals. CBP Officers inspected the soles of
the sandals and discovered packages wrapped in duet tape in the foot bed of each of the sandals.
CBP Officers probed each package and discovered a white powdery substance which field tested
positive for cocaine, Te first package of cocaine weighed approximately 444 grams (97 pounds).
The second package of cocaine weighed approximately 442 grams (.97 pounds). The 7 weight
of the three packages of cocaine is approximately 1.7 kilograms (3.75 pounds).Case 1:19-mj-02005-EGT Document 2 Entered on FLSD Docket 01/04/2019 Page 5 of 5
CONCLUSION
7. Based upon the foregoing, I submit that there is probable cause to believe that
THOBOURNE: (1) did knowingly and intentionally import into the United States, from a place _
outside thereof, a controlled substance, in violation of Title 21, United States Code, Section 952(a);
and (2) did knowingly and intentionally possess with intent to distribute a controlled substance, in
violation of Title 21, United States Code, Section 841(a)(1).
‘Adam Jetson, Special Agent
United States Department of Homeland Security
Homeland Security Investigations (HSI)
Swom to before me and subscribed i my presence thig— day of January __, 2019.
United Statgs Magistrate Judge