USDC IN/ND case 3:24-mj-00053-MGG document 1 filed 07/02/24 page 1 of 9

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
Northern District
__________ DistrictofofIndiana
__________

United States of America )

v. )
DENARDO A. MCCORMACK
) Case No.
) 3:24-MJ-53 MGG
)
)
)
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 7/2/2024 in the county of St. Joseph in the
Northern District of Indiana , the defendant(s) violated:

Code Section Offense Description

21 U.S.C § 841 (a)(1) Possession of a controlled substance with the intent to distribute.

This criminal complaint is based on these facts:

See Affidavit of Crisha Bishop, Special Agent, Drug Enforcemnt Administration (DEA)

✔ Continued on the attached sheet.

u

&ULVKD%LVKRS
Complainant’s signature

Crisha Bishop, SA, DEA

Printed name and title

Sworn to before me and signed in my presence.

Date: 07/02/2024 s/ Michael G. Gotsch, Sr.

Judge’s signature

City and state: South Bend, IN Hon. Michael G. Gotsch, Sr.

Printed name and title
 USDC IN/ND case 3:24-mj-00053-MGG document 1 filed 07/02/24 page 2 of 9

STATEMENT IN SUPPORT OF COMPLAINT

I, Crisha L. Bishop, being first duly sworn, hereby depose and state as

follows:

INTRODUCTION

1. I am a Special Agent (“SA”) of the Drug Enforcement

Administration (“DEA”). I have been a SA with DEA since December 2023. I

have received training from the DEA Special Agent Training Academy located

in Quantico, Virginia. While at the Special Agent Training Academy, I received

formal training in investigative techniques, drug identification, the federal

laws pertaining to drug investigations, instruction in financial investigations

and telephonic investigations. I have received on-the-job training from

supervisors, senior DEA Agents, and detectives regarding the manner in which

drugs are trafficked. I am currently assigned to the DEA Merrillville District

Office, South Bend, Indiana Group.

2. This Affidavit sometimes refers to federal and local law

enforcement officers as “Agents.” Unless otherwise indicated, all statements

herein are related in substance and in part and are not verbatim. This Affidavit

is intended to show merely that there is sufficient probable cause for the

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requested warrant and does not set forth all of my knowledge about this

matter.

3. Based on facts set forth in the Affidavit, there is probable cause to

believe that Denardo MCCORMACK violated Title 21, United States Code,

Section 841(a)(1), by unlawfully possessing with intent to distribute controlled

substances, including a mixture and substance containing a detectable amount

of N-phenyl-N-[1-(2-phenylethyl)-4-piperidinyl] propanamide (fentanyl), a

Schedule II controlled substance.

Probable Cause

4. On July 1, 2024, United States Magistrate Judge for the Northern

District of Indiana Michael G. Gotsch Sr. issued a warrant (3:24-MJ-51-MGG)

authorizing Agents to search the residence located at 738 S. Bendix Drive,

South Bend, Indiana (hereinafter the “Bendix Drive residence”).

5. On July 2, 2024, at approximately 6:05 a.m., members of the Drug

Enforcement Administration (DEA), Bureau of Alcohol, Tobacco, Firearms,

and Explosives (ATF), Indiana State Police, Mishawaka Police Department,

South Bend Police Department, and St. Joseph County Police department

hereinafter collectively referred to as “Agents,” executed the search warrant at

the Bendix Drive Residence. Agents approached the residence and knocked on

the door loudly several times. Agents verbally called out “DEA, Police, Search

Warrant!” several times prior to entry. After several moments of not receiving

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a response, Agents manually breached the front door of the residence. Upon

the entering the residence, Agents encountered a male subject (hereinafter,

“MCCORMACK”) in the bedroom believed to be MCCORMACK’s located on

the southeast corner of the residence. MCCORMACK was detained,

handcuffed, and searched without incident. There was no one else located

inside of the residence.

6. Once MCCORMACK was secure and the residence was deemed

secure, Agents began a systematic search of the premises. The paragraphs

below contain lists of the some of the evidence that was seized. This Affidavit

does not contain a complete list, as collection efforts remain ongoing. This

Affidavit contains a list sufficient for the purposes of establishing probable

cause that MCCORMACK has violated federal criminal law.

7. During a search of a bedroom located on the southeast side of the

residence (designated “Room E”), Agents located the following items:

Black duffle bag located under bed:

x Within the black duffle bag, Agents located one (1) tan Steyr Arms

Inc. 223 caliber rifle (bearing serial number: 9USA618) with one

magazine containing an unknown amount of .223 caliber

ammunition;

x One (1) brown wooden and black Century Arms .762 caliber rifle

(bearing serial number: RAS47063446);

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x One (1) Black M&P Smith and Wesson .22 caliber rifle (bearing

serial number: LAD2065);

x One (1) unknown make and model black .223 caliber rifle (bearing

serial number: 040125); and

x One brown (1) Ruger .22 caliber rifle (bearing serial number: 233-

08054).

Closet of bedroom E:

x Within the closet on a shelf, Agents located two additional

firearms:

o One Ruger 57 black 5.7 caliber handgun (bearing serial

number: 64222641); and

o One Ruger 57 black 5.7 caliber handgun (bearing serial

number: 64306204), reported Stolen through South Bend,

Indiana.

Based on my training and experience, I know that individuals involved in drug

trafficking often use firearms in furtherance of drug trafficking. By the very

nature of drug trafficking, these individuals are typically in possession of large

amounts of money or drugs at any given time. To protect their supply and

proceeds from being stolen or taken against their will, drug traffickers will

often carry and possess firearms to protect themselves. Those firearms are

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oftentimes kept in close proximity to their drug supply or proceeds to allow for

easy access.

8. During a search of the bedroom (designated “E”), Agents located a

black Amazon Basics safe sitting on the floor (along the south wall of the

bedroom). On top of the safe, Agents located two (2) bundles of an

undetermined amount of United States currency tied with a rubber band

around. Inside of the safe Agents located a large amount of U.S. currency

wrapped in bundles with a rubber band; and an Indiana Bureau of Motor

Vehicles title for a white BMW X6 SUV titled to MCCORMACK. Inside the

bedroom, Agents also recovered two plastic zip lock bags containing

approximately 480 grams and 470 grams respectively of a substance that field-

tested positive for marijuana.

Kitchen (designated as “B’) located on the northeast

x Agents located in the drawer next to the fridge (southeast corner) one (1)

loaded black Beretta APX 9mm handgun (bearing serial number:

A154062X) and one (1) magazine containing an unknown amount of

9mm live ammunition.

Black Duffle bag located in the northeast corner of Kitchen (designated as “B”)

x Inside Agents located one black Gold Standard Whey protein container

containing twenty-two (22) knotted plastic bags containing blue round

pills marked with a “female figure” on one side and nothing on the other

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side. The shape and color (shade of blue) of the pills can vary, however,

leading me to believe the pills were clandestinely manufactured to

resemble pharmaceutical oxycodone pills. From numerous prior

investigations, and based on lab testing done on other seized pills, I know

that these pills are consistent with fentanyl-laced pills that mimic the

appearance of oxycodone pills. Based on my training and experience, it

is common for drug distributors to distribute fake pills or pills laced with

fentanyl instead of true opioids because they are less expensive and

easier to access. Based on my training and experience, I believe these

bags contain several thousand pills, which I know to be an amount of

pills indicative of distribution. These pills were later weighed and

determined to have a gross weight of 819 grams;

x A digital scale, which in my experience can be used by drug traffickers

to weigh drugs and prepare drugs for distribution;

x Clear plastic sandwich bag containing a white powder which

presumptively tested positive for cocaine and later weighed and

determined to have a gross weight of 75.5 grams;

x One (1) clear plastic bag tied in a knot at the end with a white rock like

substance inside which presumptively tested positive for crack cocaine

and later weighed and determined to have a gross weight of 27.6 grams;

and

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x One “UPS” package labeled to MCCORMACK.

Bathroom (designated “C”):

x Agents located a crystal-like substance in the toilet which presumptively

tested positive for fentanyl and later weighed and determined to have a

gross weight of 170.9 grams; and

x One (1) large zip lock plastic bag behind the bathroom door with a white

residue in it.

Bedroom (designated “D”)

x Agents located a bill counter and one (1) mag pull drum magazine.

Basement (designated “H”)

x One (1) larger pill press and one (1) smaller pill press (unknown further

at this time). Near the pill press’s in the basement, Agents located:

o Four (4) vacuum sealed plastic bags containing an unknown

amount of light blue round pills stamped with a “female figure” on

one side and nothing on the other side (same resemblance and

stamping to the pills located in the kitchen) (unknown test);

o One clear plastic bag containing a white powdery substance

(unknown weight and test at this time); and

o One clear plastic bag containing a light blue powder like substance

(unknown weight and test at this time).

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9. All of the above described events occurred in the Northern District

of Indiana.

CONCLUSION

10. Based on the evidence recovered at the Bendix Drive address I

believe that the Bendix Drive address is MCCORMACK’s home and

specifically Bedroom E is where MCCORMACK stays. The evidence recovered,

including a large amount of suspected fentanyl-laced pills, currency, several

firearms, and UPS packages, BMV title, was likely engaged in the distribution

of controlled substances in violation of Title 21, United States Code, Section

841(a)(1). Therefore, I submit that there is probable cause to arrest

MCCORMACK for the above-described charges.

Further your affiant sayeth naught.

&ULVKD%LVKRS
Crisha Bishop
Special Agent
Drug Enforcement Administration

Subscribed and sworn to before me, July , 2024.

s/ Michael G. Gotsch, Sr.

Hon. Michael G. Gotsch, Sr.
United States Magistrate Judge
Northern District of Indiana