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Case 1:10-mj-00400-SKG Document 1 Filed 02/03/10 Page 1 of 3

UNITED STATES DISTRICT COURT

DISTRICT OF MARYLAND

UNITED STATES OF AMERICA

v. CRIMINAL COMPLAINT

JAMES BOSTIC CASE NUMBER: /0- 101) S K ""

I, the undersigned complainant, being duly sworn state the following is true and correct to
the best of my knowledge and belief. On or about February 2, 2010, defendant, (Track Statutory Language
,offense)

:James Bostic, did knowingly, intentionally possess with intent to distribute 5 kilograms or more of a
:substance containing a detectable amount of cocaine, a Schedule II controlled substance

in violation of Title ~ United States Code, Section(s) 841

I further state that I am a Task Force Officer of the Drug Enforcement Administration, and that this
complaint is based on the following facts: Official Title

SEE ATTACHED AFFIDAVIT

!Continued on the attached sheet and made a part hereof: ~s D No

T~~
~Drug~'Enforcement Administration

'SWo

at Baltimore, Maryland
 Case 1:10-mj-00400-SKG Document 1 Filed 02/03/10 Page 2 of 3

AFFIDAVIT

This affidavit is submitted in support of a criminal complaint charging James

Bostic a.k.a. "JIMMY" (DOB 5/03/71) with the following: possession with the intent to
distribute five kilograms or more of cocaine in violation of Title 21 United States Code,
Section 841.

I, TFO Brian Shutt, being duly swore say as follows: I am a Task Force Officer of
D~ug Enforcement Administration (DEA), is an investigative or law enforcement officer
of the United States within the meaning of 18 U.S.C. 2510 (7) and Section 10-401 (6) of
the Courts and Judicial Proceedings Article of the Annotated Code of Maryland; 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 18 U.S.C. 2516 and Article 27 of the
Annotated Code of Maryland.
I have been a sworn police officer with the Baltimore City Police Department since
June 20, 2002 and am currently assigned to the Violent Crime Impact Division, HIDT A
Task Force. Prior to my employment with the B,altimore City Police Department, I was a
sworn Deputy Sheriff with the Cecil County Sheriffs Office from June 1999. While
emplQyed as a hiw enforcement officer, I have held positions within the Patrol Division,
and the Criminal Investigative Division. I have completed two separated six-month basic
Police
'I
Academies that included classes pertaining to Controlled Dangerous Substances
(CDS). I have also attended more than ten advanced investigative courses. Prior
assignments with the Baltimore City Police include uniform patrol division in the Eastern
District, and also the Eastern District Drug Unit. I have personally conducted and
participated in numerous investigations involving criminal activity including but not
limited to controlled substances, violent crime, and firearms violations. I have
participated in the arrest of over 800 persons for narcotics, violent crime, and/or firearms
violations and have authored and/or executed more than 300 Search and Seizure
W~arrantsrelating to narcotics, violent crime, and/6r firearms violations.

On February 2, 2010, law enforcement was provided information from a reliable

confidential source (CS) that a multi-kilogram drug transaction involving James Bostic
(the defendant) was going to occur in room XXX of the Marriott Residence Inn in White
Marsh, Maryland. This same CS provided information ~o law enforcement in December
of 2009 that the defendant would be making a large cash payment to a representative of
the Los Zetas Mexican Drug Cartel for previously obtained cocaine and marijuana on
December 29, 2009 at the Marriott Residence Inn in White Marsh, Maryland.

On December 29, 2009, law enforcement pre-wired a room for audio and video
recording. Bostic was observed to enter the room carrying a suitcase. Bostic opened the
suitcase, and began removing plastic bags. Bostic remarked to the people in the room
th~t it's "590." During the meeting with the cartel representatives, Bostic discusses the
poor quality of the marijuana he had received and asked when he could expect his next
shipment of cocaine.

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Filed 02/03/10 Page 3 of 3 Sf- &--

After this meeting, the cartel representatives began counting the money, which
was in the plastic bags from the suitcase that Bostic brought into the room. The money
was placed into heat-sealed bags and secreted in a Ford Explorer. On December 30,
i!

2009, as the cartel representatives were leaving Maryland, a vehicle stop was conducted
of the Ford Explorer. A canine scan of the vehicle was positive for the presence of
controlled substances, and the vehicle was searched. During the search approximately,
. $589,000 in U.S. currency was recovered.

On February 2, 2010, after receiving information from the same CS that a drug
transaction was going to occur between Bostic and a cartel representative, law
enforcement again pre-wired a room for audio and video recording. At approximately
2:30 p.m., Bostic was observed to enter the room and meet with the cartel representative.
The representative produced a suitcase. While being monitored by the recording
equipment in the room, Bostic opened the suitcase and began counting kilograms of
cocaine. Bostic actually counted the quantity of cocaine twice. After counting the
cocaine, Bostic took the suitcase and exited the room. While in the hallway, Bostic
detected the presence of law enforcement officers. Bostic dropped the suitcase, and
began to flee down a flight of stairs in the hotel. He was eventually apprehended after a
foM pursuit with several law enforcement officers on the parking lot of the hotel. A
search was conducted incident to his arrest and recovered from his person was a large
hunting style knife and a large sum of U.S,. Currency. The bag was recovered and found
to contain approximately 12 kilograms of cocaine.

I know based upon my training and experience that the quantity of cocaine (12
kilograms) recovered was intended for distribution rather than personal consumption.

Based upon on the aforementioned facts, there is probable cause to believe James
Bostic a.k.a. "JIMMY" (DOB 5/03/71) did possess with the intent to distribute five
kilograms or more of cocaine in violation of Title 21 United States Code, Section 841

Under penalty of perjury, I affirm that the events recounted in the foregoing
affidavit are true and accurate to the best of my knowledge.

Drug Enforcement Administration