UNITED STATESDISTRICT COURT

DISTRICT OF CONNECTICUT
UNITED STATESOF AMERICA
:

ss:New Haven,Connecticut

COUNTYOF NEW HAVEN

AFFIDAVIT
I, DanaR' Mofenson,a SpecialAgentwith the Drug EnforcementAdministration,being
duly sworn,deposes
andstates:
l.

I am employedas a SpecialAgent with the Drug Enforcement

Administration

("DEA") andhavebeenso employedsinceAugust2004.

2.

I am currentlyassignedto the DEA New Haven District Office ("NHDO")

TacticalDiversionSquad("TDS"), which investigatesthosedrug traffickersand organizations

responsiblefor diverting and distributingpharmaceuticals
and other drugs within the Statesof
Connecticut'Due to the abuseand trafficking of opioid basedpharmaceuticalpills and the
correlatedabuseand traffickingof heroin,the DEA NHDO TDS is alsoactivelyinvestigating
investigationsinvolving individualsand organizationsinvolved with the distributionof heroin.
Duringmy assignment
to the DEA NHDO TDS,andpreviousassignment
to theDEA Bridgeport
Residentoffice High IntensityDrug TaskForce,I havepreparednumerousaffidavitsin support
of applicationsfor federal search warrants and arrest warrants,as well as in support of
authorizationsto conduct electronic surveillance.As a case agent, I have directed and
coordinatedelectronic surveillance,controlled purchasesof drugs, physical surveillance,
undercoveractivitiesas well as debriefedand managedconfidentialsources.I am familiar with
the mannerin which individualsobtain,finance,store,manufacture,
transport,and distribute
their illegaldrugs.I havea Bachelorof Arts anda Bachelorof Business
Administrationfrom the

University.I
Universityof Massachusetts
at Amherstanda Masterof Sciencefrom Northeastern
havecompletedthe sixteen-week
long DEA BasicAgentTraineeacademyin Quantico,VA. I
have also attendednumerouslaw enforcementtraining coursesrelatedto the field of drug law
enfbrcementandhold a PoliceInstructorCertificationon the topic of drug law enforcementwith
the Stateof ConnecticutPoliceOfficer Standards
andTrainingCouncil.
3.

I am an investigative
officer of the United Stateswithin the
or law enforcement

meaningif Title 18, United StatesCode,Section2510(7)in that I am empoweredby law to

conductinvestigations
in Title 18,UnitedStates
of andto makearrestsfor offensesenumerated
Code,Section2516. Currently,I am involvedin an investigationof severalheroinoverdoses
that occurredin Sheltonand Derby, Connecticutduring the week of February15, 2016. In
particular,I am investigatingviolationsof 2l U.S.C. $ 8a1(aX1)(possession
with intent to
to distributeheroin).
distribute,anddistributionof, heroin)and2l U.S.C.$ 846(conspiracy
4.

This affrdavit is submitted in support of a complaint charging Bradley

with
COMMEMORD (with a dateof birth (xxlxx/1995)that is knownto me) with possession
containinga detectableamountof
intentto distributeanddistributionof, a mixtureandsubstance
heroin, a ScheduleI controlledsubstance,
in violation of 2l U.S.C. $$ 8al(a)(l) and

841(bxlxc).
5.

In addition,this affidavitis submittedin supportof an applicationfor a search

probablecauseexiststo believe,andI do believe,

warrantdirectedat VerizonWirelessbecause
asmorefully setforth herein,thaton thecustomerdatastoragesystemof VerizonWireless,
thereexistsevidence,
fruits,andinstrumentalities
of violations2l U.S.C.$ 8al(aXl) (possession
with intentto distribute,anddistributionof, heroin)and2l U.S.C.$ 846(conspiracy
to distribute

heroin).Specifically,thewarrantseeksrecordsrelatedto COMERFORD'suseof cellular

telephone
number(203)892-8592,
whichis a cellulartelephone
servicedby VerizonWireless.
6.

This affidavit doesnot set forth all of the factsand evidencethat I havegathered

during the courseof the investigationof this matter. Rather,this affidavit setsforth facts
and
evidencethat are relevantto the requestedcomplaint and searchwarrant. The statements
containedin this affidavit are based,in part, on informationprovided by SpecialAgents
and
Task Force Officers of the DEA, as well as the Derby Police Departmentand Sheltonpolice
Departmentas well as officers from other law enforcementagencies,and on law enforcement
officers' review of seizedelectronicevidence(includingstoredtext messages),
and on the
experienceandtrainingof the affiant.
BACKGROUND
7.

This investigationby the DEA NHDO TDS involvesthe investigationinto a

seriesof heroinoverdoses
thatsharea commonheroinsourceof supply.The heroinsourceof the
supplyhasbeenidentifiedasBradleyCOMMERFORD.Two of theseheroinoverdoses
occurred
in Shelton,Connecticuton or about 02-16-2016
and one of the heroinoverdoses
occurredin
Derby, Connecticuton or about 02-17-2016.The two heroin overdosesoccurringin Shelton,
Connecticut
did not resultin death(identifiedthroughoutthis affidavitas Victim #l andVictim
#2), however,theoneheroinoverdoseoccurringin Derby,Connecticut
did resultin the deathof
thevictim (identifiedthroughoutthisaffidavitasvictim #3).
8.

Thus far in the investigation,investigatorswere able to analyzetelephonetext

messages
recoveredfrom the cellulartelephoneof Victim #3, analyzetelephonetoll records
associatedwith the sourceof supply, review medical recordsand speakwith victims
and
witnessesinvolvedwith the investigation.
Investigators
havealsohad the opportunityto speak

with COMMERFORDwhenhe wasarrestedon Februaryl8,20l6on

a Connecticutviolation of

Probation(VOp) warrant.
THE DEFENDANT
9'

BradleyCOMMERFoRDis a residentof Sixth Streetin

Derby,Connecticut.
As

referencedabove,COMMERFORDwas identified as the

heroin sourceof supply for at least
threeheroinrelatedoverdoes,oneof which resultedin a death,
occurringon or about 02-16-2016
andon or about02-17-2016.
l0'

On 08-16-2014,COMMERFORDwas arrestedby the Derby police

Department

and chargedwith Sale of a ControlledSubstance.

coMMERFoRD receiveda three-year
suspended
sentenceandwasorderedto servethreeyearsofprobationfor this charge.
I l'

On 10-23'2014,COMMERFORDwas arrestedby the Derby PoliceDepartment

and chargedwith Sale of a Controlled Substance.COMMERFORD

receiveda three-year
suspended
sentenceandwas orderedto servethreeyearsof probation(to run concurrent)
for this
charge.
12'

On 0l-15-2016,COMMERFORD
wasarrested
by the DerbyPoliceDepartment

and chargedwith Possession

of a ControlledSubstance
and Interferingand Resisting.These
chargesarepending.
13'

On 02-18-2016,membersof the Derby Police Departmentobtainedan

arrest

warrantfor CoMMERFORD charginghim with violation of probation.

Subsequent
to obtaining
the arest warranto members of law enforcementconducted a
motor vehicle stop of
coMMERFoRD and his associate,Brooke BIZEWSKI. CoMMERFoRD
had a cellular
telephone
in his possession
and$765in UnitedStatesCurrency.subsequent
to themotorvehicle
stop,DEA Task Forceofficer Brian McPaddenplaceda telephonecall
from a DEA telephoneto

telephonenumber203-892-8592,which, during the courseof the investigationand articulated

within this affidavit,hasbeenidentifiedas belongingto COMMERFORD.Momentsafter the
telephonecall, TFO McPaddenobservedCOMMERFORD'stelephonealert to an incoming
telephonecall. DEA spokewith BIZEWSKI, who statedthat she and COMMERFORDwere
travelingto waterbury,cT to meetwith their heroinsourceof supply"Duke."
PROBABLE CAUSE
INVESTIGATION OF VICTIM #1,VICTIM #2
14.

On 02-16-2016,membersof the SheltonPolice Departmentrespondedto a

reportedheroinoverdoseof an eighteenyearold male,hereinafter

referredto as Victim #1, at a
residence
locatedon CenterStreetin Shelton,CT.
15.

Medicalassistance
wasrendered
to Victim #1, who wassubsequently
transported

to the Griffin Hospitalin Derby,Connecticut

for evaluationandtreatment.
Victim #l wastreated
and was subsequentlyreleasedfrom the hospital.While at the residence,a juvenile witness,
hereinafterreferredto as Witness#1, statedto law enforcementthat Victim #1 does in fact
"snort" heroin. While at the hospital,law enforcementattemptedto speakwith Victim #1,
however,Victim #l initially refusedto answerquestions
of law enforcement.
16.

On the eveningof the overdoseof Victim #1, membersof the SheltonPolice

Departmentspokewith a Sourceof Information,who provideda telephonenumberof 203-8928592 as the telephonenumberbelongingto the heroin sourceof supplyfor Victim #1. The
Sourceof Informationalsostatedthat"Brad" soldherointo victim #1.
17.

On 02-17-2016,DEA TFO McPaddenand SheltonPolice DetectiveNugent

attemptedto speakagainwith Victim #l andWitness#1. Witness#l and Victim #l discussed

the overdosethat occurredon the previousday and statedthat "Brad" was the heroin sourceof

supplyfor thesuppliedheroin.Witness#l andVictim #l observed

socialmediaphotographs
and
law enforcement
photographsof COMMERFORDand identifiedthe photographsas ..Brad,o,
the
sourceof supplyfor the heroinof Victim # I . Victim # I statedto law enforcement
thatVictim # I
purchasedfive (5) "bagso'of heroin,sniffedone (l) bag of heroin
and that ,.within seconds,,
Victim #l statedthathe,.knew',he wasoverdosing.
l8'

While speakingwith law enforcement,

Witness#l statedthat, on 02-16-2016,

therewasa heroinoverdoseof a secondindividual,hereinafterreferredto

as Victim #2,

andthat

COMMERFORDwas the heroin sourceof supply for Victim #2. Witness

#l providedthe
identityof Victim #2, who hassincebeenidentifiedas a twenty-twoyear
old male,and

stated

that Victim #2 hadalsobeentransported

to Griffin Hospitalby a secondjuvenilewitness,herein
referred to as Witness #2, on 02-16-2016.Law enforcementwas not aware
of the heroin
overdoseof Victim #2 at the time as reportedby Witness#1. Subsequentto
receiving
informationrelatedto Victim #2, detectiveswith the Sheltonpolice Department
attemptedto
speak with Victim #2. Victim #2 acknowledged
the heroin overdosethat Victim #2 had,
experienced,
however,Victim #2 wouldnot continueto answerquestions
of law enforcement.
19'

On 02-18-2016,membersof the DEA NHDO provided an administrative

subpoenato Griffin Hospital for patient recordsof Victim #2. The DEA NHDO
did in fact
receivehospitalrecordsrelatedto the admittance
of Victim #2, for a heroinoverdoseon 02-162016'Membersof theDEA andSheltonPoliceDepartment
haveattempted
to contactyictim#2.
howevero
it is believedthatVictim #2 doesnot wishto speakwith law enforcement.
IIWESTIGATION OF VICTIM #3
20'

On 02-17-2016'at approximately5:43AM, membersof the Derby police

Departmentrespondedto a medicalemergency,which was determinedto be

a heroin overdose

of a twenty-threeyear old male,hereinafterreferredto as Victim #3, at a residencelocatedon

HawthorneAve in Derb!, CT. Medicalassistance
wasrenderedto Victim #3, however,Victim
#3 expiredafterbeingtransportedto Griffin Hospitalin Derby,Connecticut.
21.

DEA TFO McPadden

wasableto speakbrieflywith themotherof Victim #3. The

mother of Victim #3 reportedthat, approximatelyone week prior, Victim #3 confided that

Victim #3 wasusingheroinandthattheheroinsourceof supplyfor Victim #3 wasan individual
with the first nameof "Brad." Followingan interviewof the motherof Victim #3, and at the
requestof law enforcement,
the motherof "Victim #3" provideda cellulartelephonebelonging
to Victim #3 to law enforcement.
The telephonenumberutilizedby Victim #3 wasfoundto be in
frequentcontactwith telephone
number203-g92-g592.
TELEPHONE ANALYSIS
22.

On 02-17-2016,membersof the Monroe Police Departmentconductedan

electronicanalysisof the abovereferenced

telephonebelongingto Victim #3. Membersof the
DEA conducted
an analysisof thetelephone
text messages
recovered
asa resultof the electronic
analysis.
23.

A searchof the telephone"contactlist" of Victim #3 revealedthat telephone

number203-892-8592
is associated
with "Brad." The telephonenumberof Victim 3 wasfound
to be in frequentcontactwith 203-892-g1g2.
TEXT MESSAGES- COMMERFORD, VICTIM #3
24.

on 07-30-2015,at approximately3:24PMthrough3:30PM,the following text

messageconversation
took placebetweenvictim #3 andCOMMERFoRD:coMMERFoRD
stateso
"o'Yo nigger," "I'm back home." Victim # 3 states,"who's this." coMMERFoRD
states'"lts bradu don't got my num savedlol." Victim #3 states,"Nah got a new phonedude.,,

COMMERFORDstates."Ok call me whenu can."

25.

Based upon my training and experience,I believe that during the above

referencedtext messageconversation,Victim #3 andCOMMERFORDhave a conversationin

whichVictim #3 statesthat he hasa new telephoneanddoesnot havethetelephonenumberfor
number.
identifyingCOMMERFORD'stelephone
COMMERFORDsavedin his telephone
26.

On02-14-2016
l0:29PMthrough1l:49PM,the followingtext
at approximately

messageconversation
took placebetweenVictim #3 and COMMERFORD:Victim 3 states,
"Address??"COMERFORDstates,"19 dusty lane," "Newtowncr." Victim #3 states,"lght,"
"Outsidenigga,""Yoo," "Yo go nearur phonenigga."COMMERFORDstates,"Can u check
the car andseeif I droppedmoneydude,""PleasedudeI'll throw u a bag if u find it in looking
everywhere."
27.

Based upon my training and experience,I believe that during the above

referencedtext messageconversation,Victim #3 and COMMERFORDhave a conversationin

which Victim #3 is providedwith an addressand meetswith COMMERFORDfor the purchases
of Victim #3 purchasingheroinfrom COMMERFORD.I alsobelievethat after Victim #3 and
COMMERFORDmeet,COMMERFORDasksVictim #3 to seeif Victim #3 canlocatemoney
that COMMERFORDmay have inadvertentlyleft in the vehicleof Victim #3. I additionally
believe,that COMMERFORDstatesthathe will provideheroin("bag")to Victim #3 aboveand
beyondwhichVictim #3 paid for if Victim #3 is ableto locatethe moneythatwasinadvertently
left by COMMERFORDin thevehicleof Victim #3.
28.

On 02-16-2016"at approximately1l:02PM, the following text message

conversation
took place betweenVictim #3 and COMMERFORD:Victim #3 states,o'Atthe
door."COMMERFORDstates."Comin."Victim #3 states"isht."

29.

Based upon my training and experience,I believe that during the above

referencedtext messageconversation,
Victim #3 and COMMERFORDare completinga heroin
transaction.
I believethat at the time of the text messages,
Victim #3 is outsidethe residence
of
whereCOMMERFORDis at andis alertingCOMMERFORDasto whereVictim #3 is ("At the
door").I believethat,at the time of the text messages,
COMMERFORDinstructsVictim #3 to
("Comin") and that Victim #3 acceptsthe invitationto enterthe residence,
enterthe residence
attemptingto state"All right" which wasenteredinto the telephoneincorrectly("ight").
INTERVIEW OF COMMERFORD
30.

interviewed
On 02-18-2016,
membersof DEA andthe SheltonPoliceDepartment

COMMERFORD.COMMERFORDwas not forthcomingduring the interview with respectto

distributingherointo others.COMMERFORDdid statethat he usedheroin,had knowledgeof
significantheroindistributors.COMMERFORDstatedthat he had beennotifiedof two heroin
includingthat of Victim #3. COMMERFORDbecamevisibly upsetwhen speaking
overdoses,
about the death Victim #3. COMMERFORD stated that he had known Victim #3 for
COMMERFORD'sentirelife.
ADMINISTRATIVE SUBPOENA
31.

On 02-17-2016,membersof the DEA issuedan administrativesubpoenato

number203-892Verizonrequesting
subscriber
infbrmationandtoll recordsrelatedto telephone
8592. According to Verizon, this telephonenumber is currently subscribedto Sean
COMMERFORD,believedto be the fatherof BradleyCOMMERFORD.Also, accordingto
Verizon, this telephoneis currently in the "account" name of Bradley COMMERFORD,
effective 0l-18-2016 through 02-16-2016and was in the "account" name of Sean
COIMMERFORDfrom l2-l 6-2015 throush01- 18-20I 6.

SOCIAL MEDIA
32.

On 02-17-2016,
membersof the DEA conducteda searchof telephonenumber

203-892-8592
within a query functionavailableon the socialmediawebsiteFacebook.The
resultof the queryshowedthat telephonenumber203-892-8592
is associated
with a Facebook
"profile" of "BradCommerford."
BACKGROUND TO STORED COMMUNICATIONS
33.

In my training and experienceo

I have learnedthat Verizon Wirelessis a company

that provides cellular telephone access to the general public, and that stored electronic
communications,including retrievedand unretrievedvoicemail, text, and multimedia messages
fbr Verizon Wirelesssubscribersmay be locatedon the computersof Verizon Wireless. Further,
I am aware that computers located at Verizon Wireless contain information and other stored
electronic communicationsbelonging to unrelatedthird parties.
34.

Among the services commonly offered by wireless phone providers is the

capacity to send short text or multimedia messages(photos, audio, or video) from one
subscriber's phone or wireless device to another phone or wireless device via one or more
wireless providers. This service is often referred to as "Short MessageService" ("SMS") or
"Multimedia Messaging Service" ("MMS"), and is often referred to generically as "text
messaging"or "wireless messaging." Based on my knowledge and experience,I believe that
stored electronic communications,including SMS and MMS messagesthat have been sent or
received by subscribers,may be stored by Verizon Wireless for short periods incident to and
following their transmission. In addition, providers occasionallyretain printouts from original
storageof text messagesfor a particularsubscriber'saccount.
35.

Wirelessphone providers typically retain certain transactionalinformation about

the use of each telephone, voicemail, and text-messagingaccount on their systems.

This
infbrmation can include log files and messaginglogs showing all activity on
the account,such as
local and long distancetelephoneconnectionrecords,records of session
times and durations,
lists of all incoming and outgoing telephone numbers or e-mail addresses
associatedwith
particular telephonecalls, voicemail messages,
and text or multimedia

messages.providersmay

also have information about the dates,times, and methodsof connecting

associatedwith every
communicationin which a particularcellular device was involved.
36.

Many wireless providers retain information about the location in which

a

particular communication was transmitted or received. This information

can include data about
which "cell towers" (i.e., antennatowers covering specific geographic
areas)received a radio
signal from the cellular device and thereby transmitted or received
the communication in
question.
37'

Wireless providers may also retain text messaginglogs that include specific

information about text and multimedia messagessent or receivedfrom

the account,such as the
datesand times of the messages.A provider may also retain information
about which cellular
handset or device was associatedwith the account when the messages
were sent or received.
The provider could have this information becauseeach cellular device

has one or more unique

identifiers embedded inside it. Depending upon the cellular

network and the device, the
embeddedunique identifiersfor a cellular device could take several
different forms,

including an

Electronic Serial Number ("ESN"), a Mobile Electronic Identity Number (,.ME1N,'),

a Mobile
Identification Number ("MIN"), a SubscriberIdentity Module ("SIM"),
an InternationalMobile
SubscriberIdentifier ("IMS["), or an InternationalMobile Station Equipment
Identity (..IMEI").
When a cellular device connectsto a cellular antennaor tower, it
revealsits embeddedunique

identifiers to the cellular antennaor tower in order to obtain

service, and the cellular antennaor
tower recordsthoseidentifiersas a matterof course.
38'

Wirelessprovidersalso maintain businessrecordsand subscriberinformation

for

particular accounts. This information could include the subscribers'

full namesand addresses,
the addressto which any equipmentwas shipped,the date on which the

accountwas opened,the

length of service.the types of serviceutilized, the ESN or other unique identifier

for the cellular
device associatedwith the account,the subscribers'Social SecurityNumbers and
datesof birth,
all telephonenumbersand other identifiersassociatedwith the account,and a description
of the
servicesavailableto the accountsubscribers. In addition, wirelessproviders typically generate
and retain billing recordsfor eachaccount,which may show all billable calls (including outgoing
digits dialed). The providers may also have payment information for the account,including the
dates and times of payments and the means and source of payment (including any credit card or
bank account number).
39-

In some cases,wireless subscribersmay communicatedirectly with a wireless

provider about issuesrelating to the account, such as technical problems, billing inquiries, or
complaints flom other users.

Wireless providers typically retain records about such

communications,including records of contacts between the user and the provider's support
services, as well records of any actions taken by the provider or user as a result of the
communications.
40-

On 02-17-2016,membersof the DEA NHDO TDS issueda preservationorderto

Verizon Wireless. The order requestedthat Verizon preserveall text messagecommunications

occurring over telephonenumber 203-892'8592through 02-17-2016.I have sincecommunicated
with Verizon that the preservationrequestwas received and processed.Through my training and

experience,I understandthat text message

communications
at Verizon exist for periodsof time,
typicallynot exceedten (10) days,andthatthesetext messages
may be preserved
and provided
to law enforcement
with legalprocess.Baseduponmy trainingandexperience,
reviewof text
messagesexchangedbetweenVictim #3 and COMMERFORD,and other aspectsof this
investigation,I believethat the abovereferencedtext messages
preservedby Verizon will
provide additionalevidencewith respectto the illegal drug salesof COMMERFORDto
Victim#3andothers.
INFORMATION TO BE SEARCHEDAND THINGS TO BB SEIZED
41.

I anticipateexecutingthe searchwarrantunderthe ElectronicCommunications

PrivacyAct, in particularl8 U.S.C.$$ 2703(a).2703(b)(l)(A)

and2703(cXl)(A),by usingthe
warrantto requireVerizonWirelessto discloseto the governmentcopiesof the recordsandother
information(includingthe contentof communications)
particularlydescribedin SectionI of
AttachmentB. Upon receiptof the infonnationdescribedin SectionI of AttachmentB,
government-authorized
personswill review that infbrmation to locate the items describedin
SectionII of AttachmentB.
CONCLUSION
42.

I submitthat this affidavit supportsprobablecauseto believethat, in February

2016,BradleyCOMMERFORD(DOB xx/xx/I995)possessed
with the intentto distributeand
distributeda mixture and substance
containinga detectableamountof heroin,a ScheduleI
controlledsubstance,
in violationof 2l U.S.C.$$ 8a1(a)(l)and 841(b)(lXC). As a result,I
requestthattheattachedcomplaintissue.
43.

In addition,I requestthatthe Courtissuethe proposedsearchwarrant.This Court

hasjurisdictionto issuethe requested

warrantbecause
jurisdiction"as
it is "a courtof competent

ATTACHMENT A
Propertyto Be Searched
This warrantappliesto infbrmationassociatedwith the accountfor telephonenumber
(203) 892-8592,which is stored at premisesowned, maintained,controlled,or operatedby
VerizonWireless,a wirelessproviderheadquartered
at BaskingRidge,New Jersey.

ATTACHMENT B
Particular Things to be Seized
L

Information to be discrosedby vERIZON WIRELESS

To the extent that the information describedin AttachmentA is within the possession,

custody,or control of VERIZON WIRELESS, including any messages,records,

files, logs, or
information that have beendeletedbut are still availableto vERIZON WIRELESS
or have been
preservedpursuant to a requestmade under 18 u.s.c.
$ 2703(0, VERIZON wIRELESS is
requiredto disclosethe following information to the governmentfor each
accountor identifier
listed in AttachmentA:
a.

All voice mail, text, and multimedia messagesstoredand presentlycontainedin,

or on behalfof the accountor identifier;

b.

All existing printouts from original storageof all of the text messagesdescribed

c.

All transactionalinformation of all activity of the telephonesand/or voicemail

above;

accountsdescribedabove, including log files, messaginglogs, local and long distancetelephone

connection records, records of session times and durations, dates and times of connecting,
methods of connecting,telephonenumbers associat
"o ,Woutgoing

and incoming calls, cell

towersused,and/orlocations
usedfromJanuaryza,zotfiopresenu
d.

All text messaginglogs, including date and time of messages,and identification

numbersassociatedwith the handsetssendingand receivingthe message;

e.

All businessrecords and subscriber information, in any form kept, pertaining to

the individual accountsand/or identifiers describedabove, including subscribers'full

names,
addresses,shipping addresses,date account was opened,length of service,the types
of service
utilized, ESN (Electronic Serial Number) or other unique identifier for the wireless
device

associated
with the account,social Securitynumber,dateof binh, telephone
numbers,andother
identifiersassociated
with theaccount;
f'

oeqit3o billing records,showingall billablecallsincluding

outgoingdigits,from

bQ//

January26,20$ to fresent;
g'

AII paymentinformation,includingdatesand times of payments

and means
f)$27
sourceof payment(includingany credit or bank account
number),from January26,20tX;
present;
lI.

Information to be seizedby the government

All informationdescribedabove in Section I that constitutes
fruits, evidenceand

instrumentalities
of violationsof 2l U.S.c. $ sal(a)(l) (possession
with intentto distribute,and
distributionof, heroin) and,21 U.S.C. 846 (conspiracyto distribute
$
heroin) involving
BRADLEY COMERFORDsinceAugust1, 2015,including,for each
accountor identifierlisted
on AttachmentA, informationpertainingto the followingmatters:
a'

the illegal procurement,possessionor distributionof controlledsubstances.

includingbut not limitedto heroin;

b'

Recordsrelating to who created,used, or communicatedwith the account

or

identifier,includingrecordsabouttheiridentitiesandwhereabouts.