People v. Richardson CA2/5

STATEMENT OF FACTS FROM THE MOTION TO SUPPRESS

Drug Enforcement Administration Special Agent Michael Cabral, experienced in investigations of organizations involved in large scale narcotics trafficking, was part of a task force conducting a wiretap investigation2 of the phone of George Casarez and two of his couriers on October 25, 2011. Intercepted phone calls indicated a delivery of “17 units of narcotics” would occur that day. Interception of Casarez’s phone calls in September 2011 lead to the seizure of 24 kilograms of cocaine.3 A green Nissan pickup

1 Statutory references are to the Health and Safety Code, except as otherwise indicated.

2A task force identified as L.A. Impact, comprised of local, state, and federal law enforcement agencies, participated in the investigation.

3The seizure occurred on September 24, 2011, one month before the offenses charged in this case.

2 truck was observed during the investigation leading to the September 2011 narcotics seizure. A surveillance was conducted on October 25, 2011, of a green Solara occupied by Casarez associates Jimmy Lopez and Fabricio Acosta. The Solara was previously involved in transporting narcotics. Several male…