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AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT FILED

for the
February 2, 2023
Northern District of Texas
__________ __________
KAREN MITCHELL
United States of America ) CLERK, U.S. DISTRICT
v. )
COURT
) Case No.
) 121-BK
)
)
)
Defendant(s)

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 in the county of in the
District of , the defendant(s) violated:

Code Section Offense Description

This criminal complaint is based on these facts:

Continued on the attached sheet.

Complainant’s signature

Printed name and title

his facsimile

Date: February 2, 2023

Judge’s signature

City and state:

Printed name and title
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AFFIDAVIT IN SUPPORT OF AN APPLICATION

FOR A CRIMINAL COMPLAINT

I, Bert Ingram, being duly sworn, depose and state as follows:

1. I am a Task Force Officer with the Drug Enforcement Administration and have

been since August 2018. I have been a sworn Texas Peace Officer since May

2007 and possess a Master Peace Officer Certification. I previously worked for

the Carrollton Police Department as a patrol officer, gang officer, and was a

Carrollton Narcotics Detective April 2010 – October 2021. I honorably retired

from the Carrollton Police Department in October 2021. In the same month,

October 2021, I was sworn in as an Investigator/Task Force Officer for the

Hickory Creek Police Department where I continue to serve and perform my

duties as a full-time sworn DEA Task Force Officer assigned to the High

Intensity Drug Trafficking Area Group #1 within the DEA Dallas Field

Division. During my law enforcement career, I have received training in all the

normal methods of investigation, including, but not limited to, electronic and

visual surveillance, general questioning of witnesses, confidential informants,

pen registers, the use of mobile tracking devices, the use of cellular telephone

Global Positioning Satellite (GPS) information to locate individuals, the use of

undercover agents, and the use and execution of search warrants. I have

participated as a law enforcement officer in investigations of unlawful

narcotics distribution and have conducted wiretap investigations, physical and

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electronic surveillances, undercover transactions, the execution of search and

arrest warrants, debriefings of informants, and review of taped conversations

and drug records. Through my training, education and experience, I have

become familiar with the manner in which illegal drugs are transported, stored

and distributed, and the methods of payments for such drugs. I am also familiar

with some of the methods by which narcotics traffickers communicate and

code words commonly used by narcotics traffickers.

2. During my career, I have participated in narcotics investigations. I have also

participated in the debriefing of defendants, informants, and witnesses who had

personal knowledge regarding narcotics trafficking organizations. The

investigations that I have conducted and participated in have been for the

unlawful importation of, possession with intent to distribute, and distribution of

controlled substances, as well as the related laundering of monetary

instruments, the conducting of monetary transactions involving the proceeds of

specified unlawful activities and conspiracies associated with criminal

narcotics offenses. As a result, I am familiar with how person(s) and/or groups,

who illegally import, traffic, distribute, and sell narcotics use various criminal

enterprise schemes to conduct their activities. Additionally, I am familiar with

and have personally worked multiple cases involving overdoses of controlled

substance and investigating offenses related to the delivery of a controlled

substance(s) which have resulted in serious bodily injury and/or death. Based
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on this experience, I have become well-versed in the methodology utilized in

narcotics trafficking operations, the unique trafficking patterns employed by

narcotics organizations, and their patterns of drug distribution.

3. I am familiar with blue “M30” pills based on my training, work related

experience, and my numerous cases investigating the trafficking, distribution,

and overdose cases involving “M30” pills. I know the original, actual

prescription pills were originally popular amongst opiate abusers when

“Percocet” was a popular abused opiate. Later, international drug trafficking

organizations started producing and trafficking a highly potent and addictive

synthetic opiate known as fentanyl. The raw fentanyl would commonly be

mixed with acetaminophen and other binder type substances and pressed into

various tablets/pills. Criminal organizations and distributors would use pill

press machines and press the fentanyl powder mixture into tablets/pills with

the most common in my experience being a small round blue pill with a “M30”

imprinted on the tablets. These “M30” pills are sold by criminal organizations

such as Mexico based drug trafficking organizations (DTO’s) for one dollar

($1) to two dollars ($2) per pill when buying large bulk amounts. The US

based distribution cells of these DTO’s then distribute them to US street level

dealers for three dollars ($3) to five dollars ($5) per “M30” pill. The street

level dealers then sell them to consumers for ten dollars ($10) per “M30” pill.

These “M30” pills are commonly referred to as “percs”, “yerks”, “yerky”,

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“blues”, and “M30’s”. I know through training and work-related experience,

users will commonly crush up the “M30” pill and snort it into the nasal

cavities.

4. This affidavit sets forth facts and suggests reasonable inferences from those

facts establishing that there is probable cause to believe that from the fall of

2022 to current and specifically January 27, 2023 in the Dallas Division of the

Northern District of Texas, Luis Eduardo Navarrete (herein after Navarrete)

and Magaly Mejia Cano (herein referred to as Mejia Cano) conspired to

distribute a mixture or substance containing a detectable amount of fentanyl in

violation of Title 21 U.S.C. 846 – Conspiracy to Distribute and Possess with

the Intent to Distribute a Controlled Substance.

5. The information contained in this affidavit is based on my personal knowledge

and experience, my personal participation in this investigation, and information

obtained from other law enforcement officers and/or agents involved in this

investigation. Since this affidavit is being submitted for the limited purpose of

securing an arrest warrant, I have not included each and every fact known to

me concerning this investigation. I have set forth only the facts that I believe

are necessary to establish probable cause to believe that a violation of 21

U.S.C.§ 846 has been committed by Navarrete and Mejia Cano.

FACTS AND CIRCUMSTANCES

6. During January 2023, I, along with Carrollton Police Department (CPD) Street

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Crimes Unit (SCU) members, Student Resource Officers (SRO) and CPD

Patrol Officer have investigated a series of juvenile medical emergencies

consistent with fentanyl overdoses. CPD Officers and I have identified ten (10)

total juvenile overdoses (three deceased) from September 18, 2022 to present

day. The most recent overdose death occurring February 1, 2023. The juvenile

overdose victims’ range in age from 13 to 17 years of age and are students of

RL Turner High School, Dewitt Perry Middle School and Dan F. Long Middle

School (Carrollton Farmers Branch Independent School District). Additionally,

CPD Officers and I have identified eight (8) juvenile dealers with moderate to

significant involvement in the distribution of “M30” pills known to contain

fentanyl. The juvenile dealer’s range in age from 14 to 16 years of age and are

students of RL Turner High School.

7. During the course of the investigation regarding the overdoses and juvenile

dealers, CPD Officers and I have identified adults, Luis Eduardo Navarrete

and Magaly Mejia Cano as distributors of “M30” pills containing fentanyl. I

have reviewed CPD reporting, case notes, interviews, phone evidence,

surveillance notes, photographs, videos, and have conducted my own

interviews which is consistent with Navarrete and Mejia Cano distributing

“M30” pills containing fentanyl pills to several juveniles in the area near RL

Turner High School and Dewitt Perry Middle School, both of Carrollton,

Texas – Northern District of Texas.

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8. CPD Officers and I have conducted multiple days and hours of surveillance

from January 5, 2023 to current day. The surveillance was focused at Navarrete

and Mejia Cano’s residence located at 1823 Highland Drive, Carrollton, Texas

– Northern District of Texas. On multiple occasions, law enforcement

members have observed Navarrete and Mejia Cano conduct hand-to-hand

transactions with multiple individuals who sometimes arrive on foot and in

vehicles. Many of the hand-to-hand transactions were with juvenile students of

RL Turner High School.

9. Juvenile overdose victim (hereinafter referred to as JODV#4) is 14-year-old

female student at RL Turner HS., who overdosed at her home on or about

December 24, 2022, after ingesting a “M30” pill and was transported to the

hospital by medics and survived. I reviewed the medical emergency call for

service and believe it to be consistent with a fentanyl overdose. JODV#4 and

JODV#2 knew each other and were in the same associated within the same

social group. I later interviewed JODV#4 who confirmed the details with me

She is documented again as juvenile overdose victim (“JODV#7”) because she

overdosed again (2nd time) at her home on or about January 16, 2023. She was

transported to the hospital by medics where she was hospitalized for multiple

days, temporarily partially paralyzed, but survived. I reviewed the medical

emergency call for service and believed it to be consistent with a fentanyl

overdose. Carrollton SCU Detective Cuellar and I later interviewed her and her
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mother at their home where she confirmed she had consumed a “M30” pill,

which she reportedly had been supplied by a juvenile dealer (referred to as

“JD#2”). She advised me that the first “M30” pill she overdosed from on

December 24, 2022 had been supplied by a separate 16-year-old juvenile

dealer (referred to as “JD#1”). I reviewed her reported statements with her

cellphone messages, specifically associated with Instagram direct chat

messaging which reflect she had been previously supplied by “JD#1”.

Carrollton SCU Detective Cuellar was familiar with her first overdose case and

familiar with “JD#1” who had been previously contacted/interviewed by Det.

Cuellar. I observed messages from “JD#1” consistent with “M30” distribution.

Furthermore, the female (JODV#4/7) stated she was familiar with Luis

Navarrete and stated she had previously purchased multiple “M30” pills from

Navarrete and described his address which was accurate.

10. Juvenile Dealer #6 (JD#6), who is a16-year-old male student at RL Turner HS.

On January 12, 2023, Carrollton SCU Detective Pool was on surveillance at

1823 Highland Drive and observed Navarrete conduct and hand to hand

transaction with JD#6 in front of his (Navarrete) residence. JD#6 then

appeared to crush up a pill and snort it on the front porch area of the residence.

JD#6 then appeared to manipulate small pieces of paper and possibly package

drugs. JD#6 departed Navarrete’s residence and walked towards RL Turner

HS. RL Turner HS SRO Stefanovik was notified and attempted to located

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JD#6. SRO Stefanovik reported entering a bathroom in the school and hearing

the sole occupant of the bathroom, JD#6 making a “snorting sound” in a

bathroom stall. JD#6 appeared to be intoxicated and was in the possession of a

razor blade and “snort straw” with residue. JD#6 admitted the paraphernalia

was used to ingest a “perc pill” (commonly referred to which is a “M30” pill).

SRO Stefanovik later conducted a consent search with JD#6 and JD#6 mother

present in which he (SRO Stefanovik) observed messages between JD#6 and

Instagram user “Luis.214” which is Navarrete’s known Instagram handle. The

message confirmed JD#6 had been supplied by Navarrete as observed on

surveillance.

11. Also, while conducting surveillance on or about January 27, 2023, CPD

Detective Mark Pool observed a subject (hereinafter referred to as “CCS”)

arrive and conducted a hand-to-hand transaction at the front door of the

residence. CCS departed the location and was contacted by Carrollton Patrol

Officers and subsequently arrested for a traffic related warrant. CCS was

transported to the Carrollton Jail and searched where two (2) “M30” fentanyl

pills were located on CCS’s person. The pills later showed a presumptive

positive field test for fentanyl. Carrollton Detectives Mark Pool and Fernando

Cuellar contacted CCS. CCS was provided their Miranda Warnings which was

understood by CCS. CCS was not promised anything or guaranteed anything,

but CCS agreed to cooperated with law enforcement and immediately started
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talking about Navarrete. CCS voluntarily showed phone messages which

Navarrete instructed CCS to go to his (Navarrete) house and CCS would be

available to get the pills from a female at the house, later identified as Mejia

Cano and consistent with Detective Pool’s surveillance observations. CCS later

identified a photograph of Magaly Mejia Cano as the same female who sold

CCS the two (2) “M30” pills seized by law enforcement. Later the same day

(01/27/2023), CCS and Carrollton SCU members conducted a recorded

controlled purchase operation at the residence. CCS went to the front of the

residence and was met by Navarrete. Navarrete provided CCS multiple “M30”

fentanyl pills in exchange for Carrollton Police Department controlled U.S.

Currency. SCU members debriefed CCS and retrieved the purchased evidence.

A field test of the purchased pills showed a presumptive positive for fentanyl.

12. Luis Navarrete and Magaly Mejia Cano’s residence is located almost

directly in between RL Turner High School and Dewitt Perry Middle School. I

used Google earth and conducted a check of 1823 Highland Drive, Carrollton,

Texas, which Navarrete and Mejia Cano reside and sell deadly fentanyl pills to

juveniles. Their residence is approximately five (5) blocks (approx. 1,355 feet)

to the north of RL Turner High School and two (2) blocks (approx. 1,200 feet)

to the southeast of Dewitt Perry Middle School.

13. Based on the investigation to date involving sworn officers’ observations,

reporting, surveillance, cooperating sources, TFO Ingram believes Luis

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Eduardo Navarrete and Magaly Mejia Cano are actively distributing deadly

fentanyl pills to juveniles within the Northern District of Texas.

14. Based on the aforementioned facts and circumstances, together with my

training and experience, I believe that there is sufficient probable cause to

believe that since the fall of 2022 to current and specifically, January 27, 2023,

Navarrete and Mejia Cano conspired to distribute a mixture or substance

containing a detectable amount of fentanyl, in violation of Title 21 U.S.C. 846

–Conspiracy to Distribute and Possess with the Intent to Distribute a

Controlled Substance, namely fentanyl.

________________________
Bert M. Ingram
Task Force Officer - DEA

Agent sworn and confirmed his facsimile signatures and the veracity of the
foregoing, all via reliable electronic means, on February 2, 2023, pursuant to Fed. R.
Crim. P. 4.1.

_________________________
RENEE HARRIS TOLIVER
UNITED STATES MAGISTRATE JUDGE

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