Criminal Complaint — United States of America v. Devin King (Case 2:22-mj-30377-DUTY)

Summary

A criminal complaint and supporting affidavit against Devin King in the U.S. District Court for the Eastern District of Michigan, case 2:22-mj-30377, ECF No. 1, filed 09/06/22. It charges conspiracy to possess with intent to distribute and to distribute oxycodone, psilocyn/psilocybin and marijuana from the year 2020 through September 2022 in Wayne County, and distribution of psilocyn/psilocybin and of oxycodone. The affidavit of ATF Special Agent Mary E. Behler quotes messages found on King's cellular device under a federal search warrant obtained on September 30, 2021. It describes distributions on or about July 20, 2022 and July 29, 2022. It was sworn before Jonathan J.C. Grey, United States Magistrate Judge, on September 6, 2022.

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Case 2:22-mj-30377-DUTY ECF Nag jy Pag¢glb.d. Giled 09/06/22 THAD: 96 BS 226-9100

amelie Asher
AO 91 (Rev. 11/11) Criminal Complaint Special Agent: Mary E. Behler ATF Telephone: (330) 716-2666

UNITED STATES DISTRICT COURT

for the

Eastern District of Michigan

United States of America
Vv. Case: 2:22—mj-30377

Devin King N Assigned To : Unassigned
Case No. 4 scion. Date : 9/6/2022
Description: CMP USA v. SEALED
MATTER (SO)
CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the date(s) of __ the year 2020 through September 2022 __ in the county of Wayne in the
Eastern District of Michigan , the defendant(s) violated:
Code Section Offense Description
21 U.S.C. § 846, 841(a)(1), 841(b)(1)(C), Conspiracy to possess with intent to distribute and to distribute
and 841(b)(1)(D)

oxycodone, psilocyn/psilocybin, and marijuana; distribution of

psilocyn/psilocybin; and distribution of oxycodone.

This criminal complaint is based on these facts:
See attached Affidavit

[_] Continued on the attached sheet. Vy Probha

[ (Lomptainant ’s signature

Special Agent Mary E. Behler, ATF

Printed name and title

Sworn to before me and signed in my presence

and/or by reliable electronic means. | , f
v

Date: September 6, 2022 Judge’s signature Vv

City and state: Detroit, MI Hon. Jonathan J.C. Grey, United States Magistrate Judge

Printed name and title
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.2 Filed 09/06/22 Page 2 of 33

AFFIDAVIT IN SUPPORT OF AN CRIMINAL COMPLAINT

I, Mary E. Behler, being first duly sworn, hereby state:

INTRODUCTION AND AGENT BACKGROUND

1. I am an “investigative or law enforcement officer of the United
States” within the meaning of Section 2510(7) of Title 18, United States Code, 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 Section 2516,
Title 18, United States Code. I have been employed by the Bureau of Alcohol,
Tobacco, Firearms and Explosives (ATF), United States Department of Justice, as
a Special Agent since December of 2013. I graduated from the Criminal
Investigator Training Program and the ATF Special Agent Basic Training Program
at the Federal Law Enforcement Training Center in Glynco, Georgia. During my
employment with ATF, I have conducted and/or participated in numerous criminal
investigations involving the illegal possession, use, and sale of firearms, drug
trafficking violations, and criminal street gangs.

2. I make this affidavit from personal knowledge based on my
participation in this investigation, including interviews conducted by myself and/or
other law enforcement agents, communications with others who have personal
knowledge of the events and circumstances described herein, and information

gained through my training and experience.
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.3 Filed 09/06/22 Page 3 of 33

3. I submit this affidavit in support of a criminal complaint charging that,
at least as early as 2020 through on or about the date of this complaint, in the
Eastern District of Michigan, the defendant, DEVIN KING (B/M; DOB:
XX/XX/1999), knowingly conspired and agreed with persons known and
unknown, to possess with the intent to distribute and to distribute a mixture or
substance containing a detectable amount of oxycodone, a Schedule I controlled
substance, a mixture or substance containing a detectable amount of psilocyn
and/or psilocybin, a Schedule I controlled substance, and marijuana, a Schedule I
controlled substance, in violation of Title 21, United States Code, Sections 846,
841(a)(1), 841(b)(1)(C), and 841(b)(1)(D). Additionally, on or about July 20,
2022, in the Eastern District of Michigan, defendant DEVIN KING distributed a
mixture or substance containing a detectable amount of psilocyn and/or psilocybin,
a Schedule I controlled substance, in violation of Title 21, United States Code,
Sections 841(a)(1) and 841(b)(1)(C). Also, on or about July 29, 2022, in the
Eastern District of Michigan, defendant DEVIN KING distributed a mixture or
substance containing oxycodone a Schedule IJ controlled substance, in violation of

Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(C).
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.4 Filed 09/06/22 Page 4 of 33

PROBABLE CAUSE

KING’S INVOLVEMENT IN NARCOTICS TRAFFICKING
4. On September 30, 2021, I obtained a Federal Search Warrant for
DEVIN KING’s cellular device (18-50629-158). I observed the following
examples of KING’s involvement in a narcotics-trafficking conspiracy on DEVIN
KING’s cellular device:

a. On May 21, 2020, DEVIN KING sent a message to a
conspirator, stating, “Can I get a zip [ounce] for the brother
price?” Based on my training, experience, and knowledge about
the investigation, I believe that KING is asking to receive
narcotics at a discounted price. The conspirator responded, “If
you want exotic [a type of marijuana strain] 300 [referencing
price] ...that all I got.”

b. On September 26, 2020, Devin KING sent a message to a
conspirator, stating, “Sell the rest of the black bag for me Gang
I'll be back in the morning...The weed in the cabinet where the
snacks at...Aye bitch...Call me gang...Ready for another gang
finishing up my lil bit na.” The conspirator directed KING to
202XX Ilene and stated, “Bring 3 for her.” KING stated, “Bet

I’m finna go to the nino too.” The conspirator responded, “Alr
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.5 Filed 09/06/22 Page 5 of 33

5.

make that sells [meaning sales] first.” Based on my training,
experience, and knowledge about the investigation, I believe
that KING and this individual are conspiring to sell and

distribute narcotics together.

. Additionally, on November 20, 2020, DEVIN KING sent a

message to a conspirator stating, “I got some percs [Percocet’s]
gang wanna buy them or you loaded?” The conspirator

responded that he already has a lot.

. On November 26, 2020, a conspirator sent a message in a group

chat, stating, “I’m about leave out now ah yeah ik comming to
the block pull them ps [Percocet] out for me.” KING
responded, “Okay bet you I’m [they in] the box.” Based on my
training, experience, and knowledge about the investigation, I
believe that KING and the conspirator are involved in the
possession, sale, and distribution of Percocet pills together.

Additionally, on August 29, 2022, KING posted a photograph

to his publicly available Instagram account depicting KING in possession of a

suspected firearm and suspected marijuana. KING captioned the photograph,

“Niggas starting beef with me tryna earn some stripes fuck around and lose they

life Y.” Based on my training, experience, and knowledge about the
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.6 Filed 09/06/22 Page 6 of 33

investigation, I believe that KING is in possession of a firearm while possessing

narcotics.

é. bigg.two

oay

184 likes

bigg.two Niggas starting beef with me tryna earn some
stripes fuck around and lose they life W @

5 ago

6. Throughout the course of the investigation, law enforcement
identified the 193XX Archdale Street, Detroit, Michigan as a location where
DEVIN KING and others distribute narcotics (hereinafter referred to as the
“ARCHDALE LOCATION”). The following controlled purchases were
conducted utilizing an undercover ATF Agent or a Confidential Informant at

the premises between the dates July 20, 2022, and August 30, 2022.
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.7 Filed 09/06/22 Page 7 of 33

BUY #1

7. On July 20, 2022, ATF Special Agents and Task Force Officers
(“TFOs”) conducted an operational briefing prior to a controlled purchase
operation utilizing ATF Confidential Informant 28831! (““CI-28831”). Law
enforcement initiated surveillance around the ARCHDALE LOCATION.
Special Agent Gatza provided CI-28831 with audio/video recording devices to
capture the controlled purchase. I instructed CI-28831 to purchase marijuana
and Percocet pills for $200 in pre-recorded government funds from Devin
KING. Special Agent Gatza provided CI-28831 with the pre-recorded Agent
Cashier Funds, for the controlled purchase prior to the operation and ATF
personnel conducted both mobile surveillance and audio electronic surveillance
of the undercover controlled purchase.

8. At approximately 12:02 PM, CI-28831 arrived at the
ARCHDALE LOCATION, exited his/her vehicle, and walked in the front door

of the residence.

' CI-28831 has provided useful and reliable information in the past. CI-28831 has
assisted and conducted with approximately nine (9) controlled purchases of
narcotics during other federal investigations. During this investigation, payments
have been made to CI-28831 by law enforcement officials for services and
expenses incurred. At no time was the information provided by CI-28831
determined to be false or misleading.
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.8 Filed 09/06/22 Page 8 of 33

9.

. CI-28831 informed the unknown black male inside the

ARCHDALE LOCATION, he/she needed some weed and

asked if he had some “percs” (referring to Percocet pills).

. CI-28831 asked, “How many Percs can I get for a hundo

[PH]?...What do you got?”

. The unknown male asked CI-28831 what he/she is trying to get

stating, “You trying to get some 10s?” CI-28831 stated he/she

would get some 10s (referring to the milligrams)

. The unknown male asked, “You say you wanted $100 in

weed?” CI-28831 responded in the affirmative.

. ClI-28831 provided the unknown male the pre-recorded

government funds in exchange for the narcotics. CI-28831
departed the ARCHDALE LOCATION.

At approximately 12:08 PM, CI-28831 met Special Agent

Gatza and I at a pre-determined location. CI-28831 provided me with five (5)

zip lock plastic baggies containing suspected marijuana and five (5) Percocet

pills. Subsequent laboratory testing of the suspected Percocet pills identified the

substance as Oxycodone, a Schedule II controlled substance.
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.9 Filed 09/06/22 Page 9 of 33

BUY #2
10. During the month of July 2022, an ATF undercover Agent
(“U/C”) communicated with KING utilizing the Target Cellular Device
regarding the sale of suspected psilocybin mushrooms and suspected Percocet
pills and then conducted a controlled purchase of suspected psilocybin
mushrooms with KING at the ARCHDALE LOCATION in Detroit.
a. On July 19, 2022, a U/C Agent observed that KING’s
Instagram account posted a picture of psilocybin mushrooms
for sale. The U/C Agent contacted KING through Instagram
and referenced purchasing 4 of an ounce of the psilocybin
mushrooms. KING confirmed that he would sell an amount to
the U/C Agent for $70 and advised the U/C Agent to contact

him on Instagram the following day.

Wanna go to mars? Call my ®

phone I'll take you there §

Screenshot #1 Screenshot #2
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.10 Filed 09/06/22 Page 10 of 33

11. On July 20, 2022, ATF Special Agents and TFOs conducted an
operational briefing prior to the undercover controlled purchase. ATF provided
the U/C Agent with the pre-recorded Agent Cashier Funds, for the controlled
purchase prior to the operation and ATF personnel conducted both mobile
surveillance and audio electronic surveillance of the undercover controlled
purchase.

12. At approximately 12:05 pm, the U/C Agent contacted KING
via Instagram messenger and informed KING that he was getting close to
Detroit. The U/C Agent asked KING for an address by texting, “Need some
numbers to punch in bro.” KING responded at 12:17 pm, by messaging a

13. At approximately 12:20 pm, the U/C Agent called KING on the
number that KING provided. During the conversation, KING told the U/C
Agent that he was near 7 Mile and Southfield, and he would send the U/C
Agent an address. KING then provided the address “19355 Archdale.”

14. At approximately 12:37 pm, the U/C Agent activated the
audio/video recording devices. The U/C Agent left the staging location and
drove to the deal location. The following observations/actions were made by

U/C Agent during the transaction:
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.11 Filed 09/06/22 Page 11 of 33

b. At approximately 12:42 pm, the U/C Agent parked in the
driveway of 19355 Archdale Street, Detroit, MI. The U/C
Agent observed a newer Cadillac Escalade backed into the
driveway and the U/C Agent parked in the driveway near the
sidewalk. Shortly after parking, KING exited a residence on
the opposite side of the street (later identified as the
ARCHDALE LOCATION). KING exited using the front, west
facing door, and walked towards the U/C vehicle. Once KING
walked into the driveway, he walked past the U/C vehicle and
briefly entered the Cadillac Escalade. After a few moments,
KING closed the door to the Cadillac Escalade and approached
the U/C Agent on the passenger’s side. KING stated “Sup bro,
I’m going to get it right now. It’s across the street,” and walked
back to the east side of the street and entered the ARCHDALE
LOCATION through the front door.

i. At approximately 12:44 pm, KING left the ARCHDALE
LOCATION through the front door and again crossed the
road back to where the U/C Agent was parked. KING
walked up to the U/C vehicle at the front passenger door

and handed the U/C Agent a clear plastic baggy

10
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.12 Filed 09/06/22 Page 12 of 33

containing the psilocybin mushrooms and a digital scale
through the open window. The U/C Agent weighed the
bag containing suspected psilocybin mushrooms while
KING was standing outside the front passenger’s door.
The digital scale registered a weight of eight grams. The
U/C Agent then handed KING $70.00 in pre-recorded

buy funds and gave KING the digital scale.

(Below is a screenshot from BWC worn by the U/C)

(Below are two screenshots from video captured by undercover vehicle)

1]
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.13 Filed 09/06/22 Page 13 of 33

b. At approximately 12:45 pm, KING then left the vehicle and returned

to the ARCHDALE LOCATION and entered through the front door.
c. The U/C Agent then left the area and drove to a staging location. I
took the clear baggy containing suspected psilocybin mushrooms into
my custody. A subsequent laboratory report confirmed the
mushrooms tested positive for 6.94 grams of psilocyn and/or

psilocybin, a Schedule I controlled substance.

12
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BUY #3

15. On July 29, 2022, ATF personnel conducted an operational
briefing prior to a U/C controlled purchase. ATF provided the U/C Agent with
the pre-recorded Agent Cashier Funds, for the controlled purchase prior to the
operation and ATF personnel conducted both mobile surveillance and audio
electronic surveillance of the undercover controlled purchase.

16. Prior to the meeting, the ATF U/C Agent engaged in cellphone
communication with KING on the Target Cellular Device, for the purposes of
arranging the undercover purchase of Percocet pills. KING informed the U/C
Agent he had “Percs 10-30,” weed, and weed Kool-Aid. Shortly thereafter,
KING called the U/C Agent from the Target Cellular Device. The U/C Agent
informed KING he would buy five 15mg “Percs” for $25.00 each, for a total
price of $125.00.

17. At approximately 1:55 pm, the U/C Agent departed the staging
location and drove toward the ARCHDALE LOCATION. The following
observations/actions were made by the U/C Agent during the transaction:

18. At approximately 2:07 pm, the U/C Agent parked in the
driveway of 19355 Archdale Street, Detroit, MI. The U/C Agent called KING’s

number but did not get an answer.

13
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19. At approximately 2:13 pm, KING came from the residence on
the opposite side of the street (the ARCHDALE LOCATION).

20. KING approached the U/C vehicle on the passenger’s side and
spoke the U/C Agent through the open front passenger’s window. The U/C
Agent asked KING if he had them (referring to the Percocet pills).

21. KING stated that he was going over there to go get them.
KING stated he was wanting the $125.00 in buy funds before going to get the
pills. When the U/C Agent was hesitant in fronting the buy money, KING
threw his cellphone on the front passenger seat as collateral. The U/C Agent
then gave KING the buy money. KING then walked over to the ARCHDALE
LOCATION and entered through the front, west facing door. KING’s
cellphone was a green colored Apple iPhone.

22. At approximately 2:15 pm, KING exited the ARCHDALE
LOCATION through the front door and crossed the road back to where the U/C
Agent was parked. KING walked up to the undercover vehicle at the front
passenger door and handed the U/C Agent five white pills through the open
window. The white-colored, oval-shaped pills had an imprint of “R P” on one

side and “15” on the other side.

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Case 2:22-mj-30377-DUTY ECF No.1, PagelD.16 Filed 09/06/22 Page 16 of 33

(Below is a screenshot from video)

KING handing U/C five pills

i. At approximately 2:15 pm, KING then left the undercover vehicle.
ii. The U/C Agent left the area and drove to the ATF Office where the five
pills were turned over to me. The laboratory results identified the
substance as Oxycodone.

BUY #4

23. On August 16, 2022, ATF personnel conducted an operational
briefing prior to a controlled purchase operation utilizing ATF CI-28831. ATF
S/A Gatza conducted a search of CI-28831’s person and vehicle and no
contraband was found. ATF S/As and Task Force Officers initiated surveillance
around the ARCHDALE LOCATION. S/A Gatza provided CI-28831 with

audio/video recording devices to capture the controlled purchase. I instructed

15
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.17 Filed 09/06/22 Page 17 of 33

the CI to purchase Percocet pills for $300 in pre-recorded government funds
from Devin KING. I showed CI-28831 a photograph of Devin KING. S/A
Gatza provided CI-28831 with the pre-recorded Agent Cashier Funds, for the
controlled purchase prior to the operation and ATF personnel conducted both
mobile surveillance and audio electronic surveillance of the undercover
controlled purchase. At approximately 12:21 PM the electronic recording
devices were turned on.

24. Atapproximately 12:22 PM, CI-28831 departed the staging
location and proceeded toward the ARCHDALE LOCATION.

a. At approximately 12:29 PM, CI-28831 arrived at the ARCHDALE
LOCATION, exited his/her vehicle and walked in the front door of
the residence.

b. CI-28831 informed a male and other occupants at the residence
he/she needs “300 of them perks.” A male stated, “What you need,
like what kind?”

c. CI-28831 asked what he/she got from the male last time. The male
responded, “10?” CI-28831 asked the other “fellas” how they are
doing.

d. CI-28831 asked, “What you all doin’ for a whole script?” A male

responded, “We ain’t got it like that.”

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e. The male handed CI-28831 the suspected Percocet pills stating,
“Here’s 15 of em’.” CI-28831 thanked the males and departed the
residence.

f. At approximately 12:32 PM, CI-28831 exited the ARCHDALE
LOCATION, entered his/her vehicle and departed the area.

g. At approximately 12:40 PM, CI-28831 met S/A Gatza and I at a
pre-determined location. CI-28831 provided me with one (1) zip
lock plastic baggie containing fifteen suspected Percocet pills. S/A
Gatza conducted a search of CI-28831’s person and vehicle and no
contraband was found. This concluded the controlled purchase.
The laboratory results identified the substance as Oxycodone.

25. During a debrief, CI-28831 stated that there were numerous
individuals inside the residence during the controlled purchase. CI-28831 stated
DEVIN KING was present inside the residence and was seated directly in front
of him/her while he/she was in the living room.

BUY #5

26. On August 30, 2022, at approximately 11:10 AM, ATF S/As

Totten, Jacobs, and Campbell met CI-28831 at a pre-determined location. Upon

arrival, S/A Campbell and Totten conducted a search of CI-28831’s person and

17
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.19 Filed 09/06/22 Page 19 of 33

vehicle with no contraband being found. ATF S/As initiated surveillance around

the ARCHDALE LOCATION.

27. S/A Totten provided CI-28831 with audio/video recording

devices to capture the controlled purchase. S/A Totten instructed the CI to

purchase Percocet pills for $270 in pre-recorded government funds from Devin

KING.

. At approximately 11:17 AM, CI-28831 departed the staging

location and proceeded toward the ARCHDALE LOCATION.

. At approximately 11:26 AM, CI-28831 arrived at the ARCHDALE

LOCATION, exited his/her vehicle, and walked in the front door

of the residence.

. CI-28831 informed a male, who referred to himself as “Quan,”

he/she was looking for percs.

. “Quan” stated, “You want 10’s?” CI-28831 stated he/she wants

the ones he/she paid $20 per pill last time. “Quan” stated he was

waiting for his man to pull up with them.

. CI-28831 asked what else he had. “Quan” responded, “20s, 15s.”

CI-28831 asked “Quan” to fill him up.

. CI-28831 asked for “Quan’s” number, “Quan” replied that the spot

is always open, and CI-28831 can just pull up whenever. “Quan”

18
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.20 Filed 09/06/22 Page 20 of 33

later provided his phone number to CI-28831 and stated he goes by
“Quan.”
g. “Quan” then started packaging the narcotics and utilizing a

calculator on his cell phone.

h. “Quan” handed CI-28831 the suspected Percocet pills and CI-
28831 departed the ARCHDALE LOCATION.

i. At approximately 11:45 AM, CI-28831 met S/A Totten, S/A
Jacobs and S/A Campbell at a pre-determined location. CI-2883 1
provided S/A Totten with one (1) zip lock plastic baggie
containing nine suspected Percocet pills. S/A Campbell conducted

a search of CI-28831’s person and vehicle. This concluded the

19
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.21 Filed 09/06/22 Page 21 of 33

controlled purchase. The laboratory results are pending on the
suspected Percocet pills.

28. On September 2, 2022, I reviewed fixed surveillance footage of
the ARCHDALE LOCATION. The following is a summary of my
observations:

29. On September 2, 2022, at approximately 4:57 PM, I observed
DEVIN KING (wearing a black and white hat, blue jeans and a white t-shirt)
standing in the front yard of the ARCHDALE LOCATION on a cellular
device. A black male wearing a black t-shirt approached the ARCHDALE
LOCATION and entered through the front door. Approximately one minute
later, the black male exited the ARCHDALE LOCATION and walked away
from the residence. A black male with braids exited the ARCHDALE
LOCATION and stood next to KING. Both KING and the unknown male
were on their cellular devices (Image la). Based on my training, experience,
and knowledge about the investigation, it is my belief the black male in the
black t-shirt entered the ARCHDALE LOCATION to conduct a suspected

narcotics sale.

20
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.22 Filed 09/06/22 Page 22 of 33

Image la

30. At approximately 4:59 PM, a black male wearing a blue t-shirt
walked up to the residence and entered the ARCHDALE LOCATION. At
approximately 5:00 PM, the black male with braids departed in a white sedan
parked in the driveway and the black male in a blue t-shirt walked away from
the ARCHDALE LOCATION (Image 1b). Based on my training,
experience, and knowledge about the investigation, it is my belief the black
male in the blue t-shirt entered the ARCHDALE LOCATION to conduct a

suspected narcotics sale.

21
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.23 Filed 09/06/22 Page 23 of 33

Image 1b

31. At approximately 5:01 PM, a black male wearing a black shirt
and black Adidas pants (with stripes down the sides) entered the
ARCHDALE LOCATION. Shortly thereafter, KING exited the
ARCHDALE LOCATION. The black male wearing the Adidas pants then
exited the ARCHDALE LOCATION and stood next to KING. KING and
the unknown male appeared to look out toward the street (Image Ic). A
black male wearing a black t-shirt arrived at the ARCHDALE LOCATION

and entered through the front door.

22
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.24 Filed 09/06/22 Page 24 of 33

Image Ic

32. KING and the black male wearing the Adidas pants walked
toward the street. At approximately 5:03 PM, the black male wearing the
black t-shirt (who entered the ARCHDALE LOCATION at 5:01 PM) exited
the ARCHDALE LOCATION and departed the area. KING walked back
toward the ARCHDALE LOCATION and stood in the front yard. Based on
my training, experience, and knowledge about the investigation, it is my
belief the black male in the black t-shirt entered the ARCHDALE
LOCATION to conduct a suspected narcotics sale.

33. At approximately 5:04 PM, KING pulled a suspected firearm
out of his waistband with his right hand and brandished it directly in front of
the ARCHDALE LOCATION (Image 2a, Image 2b, Image 2c). KING held

a black cellphone in his left hand. KING returned the suspected firearm to

23
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.25 Filed 09/06/22 Page 25 of 33

his waistband and a black male wearing a white t-shirt and black shorts

entered the ARCHDALE LOCATION.

Image 2a

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Image 2b (Zoomed In)

25
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.27 Filed 09/06/22 Page 27 of 33

Image 2c

34. The black male wearing the white t-shirt exited the
ARCHDALE LOCATION and stood on the porch, appearing to talk to
KING. At approximately 5:06 PM, KING and the black male wearing the
white t-shirt entered the ARCHDALE LOCATION. Based on my training,
experience, and knowledge about the investigation, it is my belief the black
male in the white t-shirt entered the ARCHDALE LOCATION to conduct a
suspected narcotics sale.

35. At approximately 5:07 PM, a white mid-size Chevrolet SUV
arrived at the ARCHDALE LOCATION and dropped a black male wearing

a white shirt and black pants off at the curb. The white SUV then backed into

26
Case 2:22-mj-30377-DUTY ECF No.1, PagelD.28 Filed 09/06/22 Page 28 of 33

the ARCHDALE LOCATION driveway. The black male entered the

ARCHDALE LOCATION (Image 3a).

Image 3a

36. At approximately 5:08 PM, the black male wearing the white
t-shirt exited the ARCHDALE LOCATION with KING and _ the
abovementioned black male wearing a white t-shirt and black shorts. The
black male with the white shirt and black pants entered the white SUV and
departed. KING entered the ARCHDALE LOCATION. Based on my
training, experience, and knowledge about the investigation, it is my belief
the black male in the white SUV entered the ARCHDALE LOCATION to
conduct a suspected narcotics sale.

37. I reviewed the fixed surveillance footage associated to the

ARCHDALE LOCATION and observed numerous short stays, a high level

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Case 2:22-mj-30377-DUTY ECF No.1, PagelD.29 Filed 09/06/22 Page 29 of 33

of foot traffic and cars arriving and departing with a short duration. In
addition, I observed KING and suspected associates frequently walking in
and out of the ARCHDALE LOCATION and standing in the front yard on
their cellular devices. The below image was from approximately 5:23 PM
when I observed numerous suspected customers at the ARCHDALE
LOCATION (Image 4a). Based on my training, experience, and knowledge
about the investigation, it is my belief the individuals entered the

ARCHDALE LOCATION to conduct suspected narcotics sales.

Image 4a

38. At approximately 5:40 PM, I observed KING depart the
ARCHDALE LOCATION and enter the front passenger seat of a gold
Chevrolet sedan. KING entered the vehicle with a black male wearing a gold

hat, white tank top, and gold shorts (driver of vehicle) (Image Sa).

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Case 2:22-mj-30377-DUTY ECF No.1, PagelD.30 Filed 09/06/22 Page 30 of 33

Image 5a

39. Based on my training, experience and knowledge about the
investigation, I believe that narcotics trafficking was occurring at the
ARCHDALE LOCATION on September 2, 2022. I believe this because the
frequent travel patterns with short stays, excessive foot traffic to and from a
house, and loitering around a house are common signs of drug activity at or
near aresidence. This belief is also based, in part, on the previous controlled
narcotics purchases occurring at or near the ARCHDALE LOCATION, and
a conspirator’s statement that the ARCHDALE LOCATION is always open.

40. On September 2, 2022, at approximately 5:57 PM, I observed
KING, wearing a black and white hat, blue jeans, and a white t-shirt, post a
“live” story to his Instagram page, “bigg.two.” During the live video, KING

is driving with the abovementioned black male wearing the gold hat and

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Case 2:22-mj-30377-DUTY ECF No.1, PagelD.31 Filed 09/06/22 Page 31 of 33

KING is in possession of two suspected firearms. Specifically, KING is in
possession of a suspected black pistol, with an extended magazine, located
in his waistband, and a suspected AK-style pistol. During the video KING

states, “Purple Heart Vet.”

3} duecegang_jay =
# Ride with the vets or stay in the park 2

@ thelifeofkayb._ joined

Hey brotha!

a) thelifeofkayb._ joined
e thelifeofkayb._

Hey brotha!
i) seriouslylove.rae joined

( ) seriouslylove.rae joined

Image 6a Image 6b

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Case 2:22-mj-30377-DUTY ECF No.1, PagelD.32 Filed 09/06/22 Page 32 of 33

| love you be safe !

2) rodfrm_daskurf7 joined

"> headshotkingZ_, 7milefrank26 joined

yy) 448s_r_us joined

Image 6c

CONCLUSION

41. Based upon the aforementioned facts stated herein, there is probable
cause to believe that the defendant, DEVIN KING (DOB: XX/XX/1999),
beginning at least as early as 2020 and continuing through the date of this
complaint, knowingly conspired and agreed with persons known and unknown, to
possess with the intent to distribute and to distribute a mixture or substance
containing a detectable amount of oxycodone, a Schedule I controlled substance, a
mixture or substance containing a detectable amount of psilocyn and/or psilocybin,
a Schedule I controlled substance, and marijuana, a Schedule I controlled

substance, in violation of Title 21, United States Code, Sections 846, 841(a)(1),

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Case 2:22-mj-30377-DUTY ECF No.1, PagelD.33 Filed 09/06/22 Page 33 of 33

841(b)(1)(C), and 841(b)(1)(D); and on or about July 20, 2022, in the Eastern
District of Michigan, knowingly and intentionally distributed psilocyn and/or
psilocybin, a Schedule I controlled substance, in violation of Title 21, United
States Code, Sections 841(a)(1) and 841(b)(1)(C); and on or about July 29, 2022,
in the Eastern District of Michigan, knowingly and intentionally distributed
oxycodone, a Schedule I controlled substance, in violation of Title 21, United

States Code, Sections 841(a)(1) and 841(b)(1)(C).

Respectfully submitted,

Mary IE, Béhler-Special Agent

Bureau of Alcohol, Tobacco,
Firearms and Explosives

Sworn to before me and signed in my presence
and/or by reliable electronic means.

Honorable Jonathan J.C. Grey —
United States Magistrate Judge

Dated: September 6, 2022

32


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