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Home Source documents Affidavit in Support of Search Warrants — No. 1:23-mj-01059 (Dkt. 3, D. Md.)

Affidavit in Support of Search Warrants — No. 1:23-mj-01059 (Dkt. 3, D. Md.)

Summary

An affidavit by FBI Special Agent Benjamin P. Johnson in support of search warrants for the persons of Tomeka Glenn and Kevin Davis, Case 1:23-mj-01059-JMC in the U.S. District Court for the District of Maryland, filed as Document 3 on 04/06/23. The warrants would take four buccal DNA swabs from each to compare with four loaded handguns found in the air ducts of their Baltimore residence when agents arrested them on January 6, 2023 on wire fraud conspiracy complaints. The affiant states that both were prohibited from possessing firearms: Glenn had convictions for credit card fraud and access device fraud, and Davis a 2013 federal marijuana conspiracy conviction that drew 63 months. The target offense is possession of a firearm by a prohibited person, 18 U.S.C. § 922(g)(1); the affidavit was attested by telephone before Magistrate Judge J. Mark Coulson in March 2023 and runs 9 pages.

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            Case 1:23-mj-01059-JMC Document 3 Filed 04/06/23 Page 1 of 9 Riley (x4959)

                           UNITED STATES DISTRICT COURT
                           FOR THE DISTRICT OF MARYLAND                                   ____ FILED ___ ENTERED
                                                                                          ____ LOGGED _____ RECEIVED
 IN THE MATTER OF THE SEARCH                                                             3:22 pm, Apr 06 2023
 OF                                                                                       AT BALTIMORE
                                                     FILED UNDER SEAL                     CLERK, U.S. DISTRICT COURT
 THE PERSON OF TOMEKA GLENN, AS                                                           DISTRICT OF MARYLAND
 IDENTIFED IN ATTACHMENT A-1, AND
                                                     CASE NO.     1:23-mj-01059-JMC       BY ______________Deputy
 THE PERSON OF KEVIN DAVIS, AS
 IDENTIFIED IN ATTACHMENT A-2



                   AFFIDAVIT IN SUPPORT OF SEARCH WARRANTS

       I, Special Agent Benjamin P. Johnson, being duly sworn, depose and state that:

                               PURPOSE OF THE AFFIDAVIT

       1.       This affidavit is made in support of an application for warrants pursuant to Fed.

R. Crim. 41 to search the persons of Tomeka Glenn (“GLENN”), born in March 1976, and

further described in Attachment A-1, and Kevin Davis (“DAVIS”), born in May 1980, and

further described in Attachment A-2, to obtain samples of DNA for comparison purposes in the

form of saliva in connection with an investigation of the offense of Possession of a Firearm By a

Prohibited Person, in violation of 18 U.S.C. § 922(g)(1) (the “TARGET OFFENSE”).

                                  AFFIANT BACKGROUND

       2.      I have been a Special Agent of the FBI since December 2021. I am currently

assigned to the FBI’s Baltimore Field Office where I conduct white-collar crime investigations in

Maryland. I have duties that include investigations of, among other matters, wire fraud, fraud

against the government, money laundering, public corruption, and civil rights. I have assisted and

participated in the preparation and execution of search and arrest warrants.

       3.      The information contained in this affidavit comes from my personal observations,

my training and experience, and information obtained from other investigators, witnesses, and

reports. Since this affidavit is being submitted for the limited purpose of establishing probable



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cause for securing the search warrants, I have not included every fact known to me concerning the

investigation.

       4.        Rather, I have set forth only those facts that I believe are necessary to establish

probable cause to believe that evidence, fruits, and instrumentalities of the TARGET OFFENSE

are located within the persons of GLENN and DAVIS.

                              BACKGROUND REGARDING DNA

       5.        I know from experience and training that DNA is found in human tissue and

provides a genetic “blueprint” for each person. DNA is unique to each person, and it has been

used by forensic scientists in a manner similar to fingerprints, that is, to identify persons who

have left their DNA behind at crime scenes or on items of evidence. DNA evidence is

potentially extremely accurate as a means of identifying individuals. DNA can be found in any

number of bodily tissues, including blood, hair, bone, and saliva.

       6.        A DNA sample suitable for comparison may be obtained by swabbing the inside

of a person’s mouth, commonly known as a “buccal swab.” Buccal samples are obtained by

asking the subject to open their mouth, whereupon a law enforcement officers (or the subject

upon request of the law enforcement officer) inserts a sterile, elongated “Q-tip” into the subject’s

mouth, which is then rubbed vigorously along the inside of the subject’s cheeks and elsewhere

inside the mouth. The FBI is requesting four (4) such samples be taken from each of GLENN

and DAVIS.

                                       PROBABLE CAUSE

                         DISCOVERY AND SEIZURE OF FIREARMS

       7.        On December 16, 2022, Criminal Complaints and Arrest Warrants were

authorized by the Honorable Matthew J. Maddox, United States Magistrate Judge for the District



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of Maryland, for GLENN and DAVIS in connection with the charge of Wire Fraud Conspiracy,

in violation of 18 U.S.C. § 1349.

        8.      On December 28, 2022, search warrants were authorized by the Honorable J.

Mark Coulson, United States Magistrate Judge for the District of Maryland, for the persons of

GLENN and DAVIS, as well as GLENN and DAVIS’s residence located at 2809 Claybrooke

Drive, Baltimore, Maryland 21244 to search for evidence, fruits, and instrumentalities of Wire

Fraud, in violation of 18 U.S.C. § 1343, and Wire Fraud Conspiracy, in violation of 18 U.S.C. §

1349.

        9.      On January 6, 2023, law enforcement arrested GLENN and DAVIS who were

present at 2809 Claybrooke Drive, Baltimore, Maryland 21244 at the time of the arrest. They

were the only people in the house at the time of the arrest. Law enforcement likewise executed

search warrants for the residence, as well as the persons of GLENN and DAVIS, seizing, among

other things, various electronic devices, financial documents, a large amount of foreign currency

and various high value jewelry.

        10.     Shortly before entering the residence, law enforcement observed a figure near one

of the windows near the main bedroom of the house. During the search of the residence, law

enforcement would go on to locate four handguns in the air ducts of the residence, two in the

main bedroom air duct (in the general vicinity of where the figure was earlier observed) and two

in the air duct of the bathroom closest to the main bedroom.

        11.     Each of the four firearms had an inserted magazine filled with ammunition. Two

of the weapons were each hidden in a gray color sock, inside of the ducts. Based on my training

and experience, criminals often conceal firearms, or other evidence, fruits, or instrumentalities of

criminal activity, in places not easily visible or accessible to law enforcement, to avoid discovery



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of illegal activity.

        12.     Before the execution of the search warrant at 2809 Claybrooke Drive, law

enforcement was aware of GLENN and DAVIS’s criminal history (discussed further below) and

the fact that each was prohibited from lawfully possessing firearms and ammunition.

Accordingly, law enforcement seized the four firearms and ammunition, and they are currently in

the custody of the FBI and awaiting forensic analysis, including DNA analysis.

        13.     Based on my knowledge, training, and experience, I know that the handling of

firearms can result in the direct transfer of DNA from the person handling the firearms to the

firearms.

                                     CRIMINAL HISTORY

        14.     GLENN has multiple past federal and state convictions for offenses punishable

by more than one year imprisonment. For example, she was convicted of felonious credit card

fraud in Fairfax County, Virginia on March 11, 2016. Further, on or about February 14, 2019,

she was also convicted of “Misdemeanor 1” Access Device Fraud in York County, Pennsylvania.

        15.     DAVIS also has a past federal criminal conviction. On or about May 6, 2013,

DAVIS pleaded guilty in the United States District Court for the District of Arizona to a charge

of Conspiracy to Distribute Marijuana, in violation of 21 U.S.C. § 846 and 841(a)(1). On July 24,

2013, the Arizona Court sentence Davis to 63 months incarceration, followed by four years of

Supervised Release.

                                         CONCLUSION

        16.     Based on the foregoing, I respectfully submit that there is probable cause to

believe that evidence, fruits, and instrumentalities of the TARGET OFFENSE are located

within the persons of GLENN and DAVIS.



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       17.    Accordingly, I respectfully request that the Court issue the proposed search

warrants pursuant to Federal Rule of Criminal Procedure 41 to search the persons listed in

Attachment A-1 and A-2 and seize the items listed in Attachment B-1 and B-2 to obtain DNA

samples from GLENN and DAVIS, so that the DNA samples may be compared to evidence

collected during the course of this investigation, including the four firearms seized from GLENN

and DAVIS’s residence located at 2809 Claybrooke Drive.



                                                    Respectfully submitted,



                                                    ________________________
                                                    Benjamin P. Johnson
                                                    Special Agent
                                                    Federal Bureau of Investigation




Affidavit submitted by email and attested to me as true and accurate by telephone consistent with
Fed. R. Crim. P. 4.1 and 41(d)(3) this 24
                                      _____________ of March 2023.




_______________________________________
THE HONORABLE J. MARK COULSON
UNITED STATES MAGISTRATE JUDGE




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                                       1:23-mj-01059-JMC



                                    ATTACHMENT A-1

                    DESCRIPTION OF PERSON TO BE SEARCHED

       Tomeka Glenn (“GLENN”) is described as a Black/African American female with dark

hair. According to records provided by the Maryland Motor Vehicle Administration. GLENN,

date of birth: March 27, 1976, is approximately 5’3” tall and weighs approximately 130 pounds.

       Attached below is GLENN’s driver’s license photograph.
         Case 1:23-mj-01059-JMC Document 3 Filed 04/06/23 Page 7 of 9
                                 1:23-mj-01060-JMC


                                    ATTACHMENT A-2

                    DESCRIPTION OF PERSON TO BE SEARCHED

       Kevin Davis (“DAVIS”) is described as a Black/African American male with dark hair.

According to records provided by the Maryland Motor Vehicle Administration, DAVIS, date of

birth: Marcy 27, 1976, is approximately 5’9” tall and weighs approximately 167 pounds.

       Attached below is DAVIS’s driver’s license photograph.
         Case 1:23-mj-01059-JMC Document 3 Filed 04/06/23 Page 8 of 9
                                1:23-mj-01059-JMC


                                  ATTACHMENT B-1

                                 ITEMS TO BE SEIZED

      This warrant authorizes the obtaining of DNA evidence by means of four oral buccal

DNA swabs to be obtained from Tomeka GLENN (described in Attachment A-1).
         Case 1:23-mj-01059-JMC Document 3 Filed 04/06/23 Page 9 of 9
                                1:23-mj-01060-JMC


                                  ATTACHMENT B-2

                                 ITEMS TO BE SEIZED

      This warrant authorizes the obtaining of DNA evidence by means of four oral buccal

DNA swabs to be obtained from Kevin DAVIS (described in Attachment A-2).


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