Case 1:12-mj-00060-TCB Document 2

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IN THE UNITED STATES DISTRICT COURT FOR ffiHE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

.' prn __

UNITED STATES OF AMERICA

Case No. l:12-mj-60

ABIODUN ADENIYIADEBANJO,
Defendant.

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

1, Christopher Hall, being duly sworn, depose and state as follows:

Introduction

1.

I am a Special Agent of the United States Department of Homeland Security,

Homeland Security Investigations (HSI). I am assigned to the Washington Dulles International Airport. My duties as a Special Agent with HSI include, but are not limited to, the investigation of federal laws governing the importation and exportation of controlled substances. I have

received training in general law enforcement, including training in Title 21 of the United States

Code. I am a graduate of the Federal Law Enforcement Training Center at Glynco, Georgia. 2. I am an "investigative or law enforcement officer" of the United States within the

meaning of Title 18, United States Code, Section 2510(7), that is, an officer of the United States

who is empowered by law to conduct investigations of and to make arrests for offenses
enumerated in Title 18, United States Code, Section 2516(1). 3. This affidavit is submitted in support of a criminal complaint charging that on or

about January 29, 2012, in Loudoun County, Virginia, within the Eastern District of Virginia,
ABIODUN ADENIYI ADEBANJO knowingly or intentionally imported or attempted to import
1

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into the customs territory of the United States from any place outside thereof, or attempted to

import into the United States from any place outside thereof, 100 grams or more of a mixture or
substance containing a detectable amount of heroin, a Schedule I controlled substance, in violation of 21 U.S.C. 952 and 963.

4.

The facts set forth in this affidavit are based on my personal knowledge and

review of records, documents, and other physical evidence obtained during this investigation, as
well as information conveyed to me by other law enforcement officials. 5. This affidavit does not include each and every fact observed by me or known to

the government. I have set forth only those facts necessary to support a finding of probable
cause.

Probable Cause

6.

On or about January 29, 2012, ADEBANJO arrived at Dulles International

Airport, in Loudoun County, Virginia, within the Eastern District of Virginia, on a direct flight
from Rome.

7.

ADEBANJO told Customs and Border Protection ("CBP") Officers that he ADEBANJO

intended to travel to Atlanta, Georgia to visit friends and purchase cars.

represented himself as an employee of Lufthansa Airlines and presented an employee badge that
CBP Officers believed to be counterfeit.

8.

CBP Officers referred ADEBANJO to a secondary inspection area. A narcotics

detection canine picked up a scent from ADEBANJO's luggage. A search of ADEBANJO's

luggage by CBP Officers revealed several condoms and a net. I know from my training and

experience that internal drug smugglers use condoms to aid in ingesting pellets and use nets to
catch the pellets once expelled.

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9.

CBP officers also noted that ADEBANJO's abdomen was abnormally rigid.

ADEBANJO agreed to have his abdominal area x-rayed and ADEBANJO was transported to Reston Hospital Center within the Eastern District of Virginia. ADEBANJO's x-rays indicated

the presence of foreign bodies in his abdomen. CBP officers then observed ADEBANJO expel
pellets from his rectum. CBP officers field-tested the contents of one of the expelled pellets,

which tested positive for the presence of heroin. The total gross weight of all of the pellets
expelled by ADEBANJO was 557.2 grams.

10.
contain drugs.
11.

ADEBANJO acknowledged that he swallowed the pellets, which he understood to

During the interview of ADEBANJO, he admitted to law enforcement that he lied

on his visa application. ADEBANJO indicated on his visa application he was an employee of
Lufthansa Airlines, but ADEBANJO stated to law enforcement that he has never been an

employee of Lufthansa Airlines.

Conclusion

12.

Based upon the above information and my training and experience, I submit that

there is probable cause to believe that on or about January 29, 2012, in Loudoun County,

Virginia, within the Eastern District of Virginia, ABIODUN ADENIYI ADEBANJO knowingly
or intentionally imported or attempted to import into the customs territory of the United States

from any place outside thereof, or attempted to import into the United States from any place outside thereof, 100 grams or more of a mixture or substance containing a detectable amount of
heroin, a Schedule I controlled substance, in violation of 21 U.S.C. 952 and 963.

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Christopher H/ll
Special Agent U.S. Department of Homeland Security

Sworn to and subscribed before me this 1st day of February, 2012.

/s/

heresa Carroll Buchanan

Uai'.rJ Stales Magistrate Judge

The "Honorable Theresa C. Buchanan

United States Magistrate Judge

Alexandria, Virginia