Case 2:24-mj-00020-kjd Document 5 Filed 02/08/24 Page 1 of 1

U.?. DIS Tf<ICT COURT

AO 91 (Rev. I 1/1 !) Criminal Complaint DIS I RICT OF VERMONT
t- • ,-

UNITED STATES DISTRICT COURT 202~fEB-S AH g: OI

for the
District of Vermont CLERK
BY
United States of America ) ---;!"'~;~ -~___s:;;;__ ~
__ ==.K=-
V. )
BRYANNA ROONEY,
)
)
Case No. 2: Z '-/- --j - 20, -1, -~ •.3
THOMAS ROONEY, and
JAKIY TRAMAINE COREY KEITH (aka "AB") )
)
)
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 December 2023 through present in the county of Orleans in the
District of ___V_e_r_m_o_n_t___ , the defendant(s) violated:

Code Section Offense Description

21 U.S.C. §§ 846 and 841 Knowingly and intentionally conspiring with one another and other individuals
in the District of Vermont to distribute and possess with intent to distribute
controlled substances-including cocaine base.

\
This criminal complaint is based on these facts:

See Affidavit.

if Continued on the attached sheet.

Attested to by reliable electronic means
Complainant's signature

Scott Labor, Special Agent, HSI

Printed name and title

Attested to by the complainant in accordance with the requirements of Fed. R. Crim. P. 4.1 by
_ _ _ _ _ _ _ _ _ _ _(specify reliable electronic means)

Date: 2./P/2't:
TI

City and state: Burlington, Vermont Kevin J. Doyle, Magistrate Judge, U.S. District Court
Printed name and title
 Case 2:24-mj-00020-kjd Document 5-1 Filed 02/08/24 Page 1 of 7

AFFIDAVIT IN SUPPORT OF
CRIMINAL COMPLAINT

I, Scott Labor, being first duly sworn, hereby depose and state as follows:

Introduction and Agent Background

1. I submit this affidavit to demonstrate probable cause to charge Bryanna Rooney,

Thomas Rooney, and Jakiy Tramaine Corey Keith (aka "AB") with knowingly and intentionally

conspiring to distribute and to possess with intent to distribute controlled substances, including

cocaine base, between December 2023 and the present in violation of21 U.S.C. §§ 841 and 846.

2. I am a Special Agent with Homeland Security Investigations (HSI), the investigative

component of the Department of Homeland Security (DHS), and I have been since 2005. I am

currently assigned to the HSI Derby resident agency. In my capacity as a Special Agent, I am

familiar with federal laws regarding the possession and transfer of firearms as well as federal

laws regarding the distribution of, possession with the intent to distribute, and conspiracy to

distribute controlled substances. I have been trained in the investigation of violations of those

laws, and I have participated in many such investigations. I have applied for and executed search

warrants related to those violations, including searches of residences, searches of electronic

devices, and searches of location information for electronic devices and vehicles. I have

participated in all phases of investigations of those violations, including interviews with firearm

purchasers who traded firearms for controlled substances and interviews with users and

distributors of controlled substances. As a result of my participation in these investigations, I am

familiar with the techniques employed by distributors of controlled substances and their means

of acquiring, transporting, storing, preparing, and distributing controlled substances; their means

of collecting, transporting, and transferring the proceeds of controlled substances; and their

means of acquiring, using, and trafficking firearms in connection with the controlled substance

1
 Case 2:24-mj-00020-kjd Document 5-1 Filed 02/08/24 Page 2 of 7

violations. Among those investigations, I have specifically participated in the investigation and

prosecution of controlled substance and firearm crimes in the "Northeast Kingdom" of Vermont

(including portions of Orleans, Essex, and Caledonia Counties).

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents, law enforcement officers, and witnesses

in the course of this investigation. This investigation has involved a collaboration with the

Northern Vermont Drug Task Force (NVDTF), HSI, ATF, the Federal Bureau oflnvestigation

(FBI), and the Vermont State Police (VSP), as well as other assisting state and local law

enforcement organizations. I have personally participated in many aspects of this investigation,

and I have reviewed information from other investigators, business records and recordings, law

enforcement reports and affidavits, and interviews with witnesses involved. When a statement of

another individual is included herein, it is presented in sum and substance, unless it is shown to

be quoted directly. This affidavit is intended to show only that there is probable cause for the

requested search warrant, so it does not set forth all of my knowledge about this matter.

4. On February 6, 2024, I applied for a warrant to search the residence of Bryanna

Rooney and Thomas Rooney located at 7021 Vermont Route 100 in the town of Troy, Vermont

(the SUBJECT PROPERTY) for evidence of violations of21 U.S.C. §§ 846 and 841. The

Honorable Kevin J. Doyle, United States Magistrate Judge, granted the search warrant, and it

was then assigned District of Vermont case number 2:24-mj-00020. A copy of the search

warrant application and my affidavit is appended to this application as Exhibit # 1. The

information contained in it remains true to the best of my knowledge and belief, and I

incorporate it into this application.

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 Case 2:24-mj-00020-kjd Document 5-1 Filed 02/08/24 Page 3 of 7

Probable Cause

5. Investigators have conducted periodic surveillance of the SUBJECT PROPERTY as

part of an ongoing drug conspiracy investigation. In the preceding days, the SUBJECT

PROPERTY had also become the focus of a missing-person investigation. According to family

members who reported her missing to VSP on February 3, 2024, Kayla Wright had been

associating with individuals at the SUBJECT PROPERTY, had stayed at the SUBJECT

PROPERTY at times, and had been involved with narcotics for some time. Kayla's family had

last heard from her at approximately 3:15 am on February 2, 2024. Kayla's family also indicated

she had been associating with an individual going by "AB," and they showed VSP Sergeant

Daniel Lynch the Facebook profile for "AB." NVDTF Detective Sergeant Gardner and I

verified that the "AB" profile shown to Sgt. Lynch was the same "Anthony Borrow" profile used

to set up the second controlled purchase

(https://www.facebook.com/profile.php?id=61553413059939)1, as described in Exhibit #1.

Kayla's family provided Kayla's cell phone number to VSP, and an emergency request for

specific location information ("ping") was initiated by state authorities. Ping data showed

Kayla's phone to be in the vicinity of the SUBJECT PROPERTY.

6. Sgt. Lynch went to the SUBJECT PROPERTY on February 3, 2024, and he spoke

with Bryanna Rooney, a resident and co-owner of the SUBJECT PROPERTY. Bryanna Rooney

did not report any crimes to Sgt. Lynch. When informed that law enforcement was aware that

Kayla's phone was in the house, Bryanna Rooney found it on a pile of clothes between two

1
I note that the profile was spelled "Anthony Burrow" in Exhibit 1. I checked the profile and
confirmed the spelling as "Anthony Borrow" on the Facebook page.
3
 Case 2:24-mj-00020-kjd Document 5-1 Filed 02/08/24 Page 4 of 7

bedrooms. All of those with whom Sgt. Lynch spoke at the house denied knowing who had been

using the phone.

7. Later, on February 3, 2024, several VSP Troopers returned to the SUBJECT

PROPERTY and met with residents Holly Fields (father of Bryanna Rooney) and Jody

Illingworth (partner of Holly Fields). Neither Fields nor Illingworth reported any crimes to the

Troopers, and both denied knowing where Kayla was; Illingworth stated she had last seen Kayla

on February 2, 2024. The Troopers asked where everyone who had been at the house earlier,

including Bryanna Rooney and Thomas Rooney, had gone in the interim. Fields and Illingworth

stated they did not know.

8. On February 3, 2024, one of Kayla's family members reported to VSP that she had

been contacted by "Borrow" ("AB") via Facebook and told by "Borrow" that Kayla was dead.

According to the family member, "Borrow" indicated a kid named "Kash KD" on Facebook had

shot Kayla and disposed of her body by concealing it in a toolbox and tossing it into Big Falls

the previous night.

9. On the afternoon of February 6, 2024, VSP received information that two individuals

had located a toolbox on a sandbar in the river in the vicinity of Big Falls. VSP Troopers

responded to the area and located a black Craftsman truck-bed-style toolbox with a silver

diamond-plated top. A trooper pried open the top and found a deceased female whose

appearance was consistent with Kayla Wright. As of the time of drafting, formal identification

and an autopsy by the Medical Examiner are in progress.

10. Also, on the afternoon of February 6, 2024, investigators conducted periodic

surveillance on the SUBJECT PROPERTY. They observed a Massachusetts-plated sedan briefly

stop at the SUBJECT PROPERY. Two male subjects left the SUBJECT PROPERTY and

4
 Case 2:24-mj-00020-kjd Document 5-1 Filed 02/08/24 Page 5 of 7

entered the sedan, which then departed the area. Investigators maintained constant surveillance

of the sedan from the time it left the SUBJECT PROPERTY, and it made no stops before police

observed it traveling well in excess of the speed limit while southbound on Interstate 91 in the

town of Westminster, Vermont. They initiated a traffic stop, and the vehicle yielded. The driver

and front-seat passenger were identified, but the two backseat passengers-the two who had

exited the SUBJECT PROPERTY-refused to identify themselves. One of them was later

identified as Jakiy Tramaine Corey Keith; the other was determined to be a 15-year-oldjuvenile

associate of Keith's. While the driver was being investigated for possible driving under the

influence, based in part on a distinct smell of marijuana emanating from the vehicle and in part

on the driver's statements, a police canine trained to detect the odor of certain controlled

substances conducted a free-air sniff of the vehicle. The canine alerted to the presence of the

odor of controlled substances, and the sedan was subsequently searched. Investigators seized a

backpack from the floorboard between Keith's feet, and it contained several thousand dollars in

United States currency. They also seized a backpack from the trunk of the sedan, and it

contained a large amount of suspected fentanyl and individual packages of suspected cocaine

base. Investigators also seized a small amount (estimated to be approximately 1-2 grams) of

suspected cocaine base from Keith's person. Keith was detained and transported to the

Westminster VSP Barracks.

11. Detective Sergeant LaBombard and Detective Sergeant Gardner interviewed Jakiy

Keith at the Westminster Barracks. I have spoken with Det. Sgt. Gardner about that interview.

He recognized Keith to be "AB" based on a video recording of the first controlled purchase

described in Exhibit #1. When shown a still image from that recording, Keith identified the

individual pictured as himself. Keith acknowledged knowing Kayla, stating that he had last seen

5
 Case 2:24-mj-00020-kjd Document 5-1 Filed 02/08/24 Page 6 of 7

her on Friday February 2, 2024, at around 4:00 am at the SUBJECT PROPERTY. He claimed

that he went to sleep shortly thereafter and that Kayla was not at the house when he woke up. He

claimed he tried to contact Kayla's cell phone later that evening; when she did not respond, he

communicated with Kayla's sister. Keith stated that, when he did not see Kayla the following

day (Saturday February 3, 2024), he confronted all of the people in the house with his handgun

and rifle and demanded to know where she was. Keith stated that one of the people present,

Aaron Camp, told him a male subject named "Kash" came to the house on Friday morning,

confronted Kayla and argued about fake cash, and then shot Kayla three times with a 9-

millimeter handgun. Keith continued the narrative he claimed Camp told him, saying that

"Kash" told Camp and Josh Pendleton to clean the kitchen and dispose of the body and that

Camp placed Kayla in a toolbox that was outside in the front yard. Keith described the toolbox

they used as having a diamond-plated top. Keith stated that Camp took him to the Big Falls area

on Saturday afternoon to show him where Camp had dumped the toolbox in the river the night

before. Keith stated that he did not hear gunshots that morning (Friday February 2, 2024) and

that he did not know anything had occurred at the house, but he was present in the kitchen when

Camp recovered two 9-millimeter casings that Camp later flushed down the toilet when State

Police came to the house.

12. On February 7, 2023, HSI agents executed the search warrant at the SUBJECT

PROPERTY. The following people were located within the SUBJECT PROPERTY and

detained for further investigation: Bryanna Rooney, Thomas Rooney, Holly Fields, Jody

Illingworth, Terron (Josh) Pendleton, and Quintin Everett (aka "DB"). The search itself is

ongoing, based on the need for forensic examination of the crime scene, so an inventory has not

yet been produced. When the HSI tactical team entered and cleared the SUBJECT PROPERTY,

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 Case 2:24-mj-00020-kjd Document 5-1 Filed 02/08/24 Page 7 of 7

however, team members observed multiple items of drug paraphernalia consistent with drug

trafficking, including electronic scales, razor blades, baggies, "crack" pipes, and other packaging

materials. HSI tactical team members further observed what appeared to be blood in the garage,

kitchen, and basement area of the SUBJECT PROPERTY.

Conclusion and Requests

13. For the reasons described above and in Exhibit #1, I submit there is probable cause

to believe that Bryanna Rooney, Thomas Rooney, and Jakiy Tramaine Corey Keith (aka "AB")

knowingly and intentionally conspiring with one another and with others to distribute and to

possess with intent to distribute controlled substances, including cocaine base, between

December 2023 and the present in the District of Vermont in violation of 21 U.S.C. §§ 841 and

846. I request the Court issue a Criminal Complaint charging them accordingly.
+!
Dated at Burlington, in the District of Vermont, this L day of February, 2024.

Attested to by reliable electronic means {Facetime)

Scott Labor, Special Agent
Homeland Security Investigations

Attested to by the complainant iJtccordance with the requirements of Fed. R. Crim. P. 4.1 by
Facetime video call on this _Z__ day of February 2024.

HON. KEVIN J. DOYLE

United States District Court
District of Vermont

7
 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 1 of 22

AO 106 (Rev. 04/10) Application for a Search Warrant

L'.t. QiGffdCf ce1,;n
DISTRICT OF VERMONT
UNITED STATES DISTRICT COURT Fil.ED
for the
202~ FEB -6 AH IQ: 37
District of Verniont
CLERK
In the Matter of the Search of
(Briefly describe the property to be searched BY &r~~r~K
or identify the person by name and address) Case No.
7021 Vermont Route 100,Troy, Vermont
z ~ '2.,'-(-~ - z.o

APPLICATION FOR A SEARCH WARRANT

I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):
See Attachment A.
District of Vermont
located in the
------- ----- - - - - - - , there is now concealed (identify the
person or describe the property to be seized):

See Attachment B.

The basis for the search under Fed. R. Crim. P. 4l(c) is (check one or more):
'evidence of a crime;
Nf contraband, fruits of crime, or other items illegally possessed;
m property designed for use, intended for use, or used in committing a crime;
ma person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section Offense Description
21 U.S.C. §§ 846 and 841 Conspiracy to distribute and PWID controlled substances

The application is based on these facts:

See attached Affidavit.

~ Continued on the attached sheet.

CJ Delayed notice of _ _ days (give exact ending date if more than 30 days: _ _ _ _ _ ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet,.?
/'
- . t;(~?----=-~--~=---~,_
·- • • .•· Applicant's signature

Scott Labor, Special Agent, HSI

Printed name and title

Sworn to before me and signed in my presence.

Date:

City and state: Burlington, Vermont Honorable Kevin J. Doyle, U.S. Magistrate Judge
Printed name and title

EXHIBIT 1
 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 2 of 22

ATTACHMENT A

PROPERTY TO BE SEARCHED

The SUBJECT PROPERTY is the premises at 7021 Vermont Route 100 in the town of
Troy, Vermont. The residence is a single-story ranch-style building that is yellow in color with
white trim and an attached one-bay garage. The front of the residence faces generally west onto
Vermont Route 100. There are accessible exterior doors on the front (northwest) side the residence
and on the rear (southeast) side of the residence.

Google Earth image of SUBJECT PROPERTY location

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Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 3 of 22

Aerial view of front (northwest side) and garage of SUBJECT PROPERTY

Aerial view of northeast side of SUBJECT PROPERTY

2
Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 4 of 22

Aerial view ofrear (southeast side) of SUBJECT PROPERTY

3
 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 5 of 22

ATTACHMENTB

Items to be Seized

I. Any evidence, contraband, fruits, or instrumentalities of criminal conduct related to

violations of 21 U.S.C. §§ 846 and 841, including:

a. Any illegally possessed controlled substances, including cocaine/cocaine base, heroin,

and fentany 1,

b. Any associated paraphernalia, tools, or materials associated with preparing, packaging,

storing, transporting, and distributing controlled substances (such as scales, glassine and

plastic baggies, safes, lockboxes, and devices used to consume controlled substances);

c. Any documents, records, or photographs related to the acquisition, possession, storage,

distribution, or transportation of any contrplled substances illegally possessed or to the

acquisition, storage, or transfer of proceeds from controlled substances;

d. United States currency or cryptocurrency and all records pertaining to the possession or

transfer of the currencies;

e. Any firearms, ammunition, or associated materials (such as apparent firearms, firearm

cases, ammunition or firearm boxes, and firearm components);

f. Records related to assets possessed, owned, sold, or transferred potentially using the

proceeds of distribution of controlled substances, to include historical, current, or future

plans to acquire or transfer assets;

g. All cell phones, electronic devices, or electronic storage media that reasonably appear to

be possessed or used by Jose Jusino, "AB," or other residents of the SUBJECT

PROPERTY that are capable of storing data such as contacts; notes; text messages;

messages sent via applications and social networking sites such as WhatsApp, Facebook,

Twitter, Instagram and others; digital photographs; or other electronic records; and
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 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 6 of 22

h. Records and information relating to the identity, residency, ownership, and/or location of

the suspects, including leased, utility records, receipt of benefits, or bills showing money

owed, due, or previously paid.

II. For any device or storage medium whose seizure is authorized by this warrant in Section I

above (hereinafter, "DEVICE"), this warrant also authorizes the search of such device

(including a forensic examination) for evidence of violations described above, including the

following:

a. Information regarding the identifying features of the DEVICE, including make, model,

serial number, IMSI/IMEI/ESN/unique identifier, user-assigned name, and assigned

phone number;

b. Contact information in contact lists, including names, screen names, nicknames, phone

numbers, and similar identifying information of associates, customers, and sources;

c. Records of telephone numbers or message recipients to which communications were sent

and from which communications were received, as well as the logs of incoming,

outgoing, and missed calls, text messages, and similar communications;

d. Location information of the DEVICE at various times pertinent to the investigation

(which includes December 2023 to the present);

e. Any information regarding bank records, checks, credit card bills, account information,

and other financial records;

f. Content of text messages, multimedia messages, numeric messages, alphanumeric

messages, and voicemail messages;

g. Digital photographs and videos of individuals involved in the distribution and possession

of controlled substances or collection of proceeds; and

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h. Evidence of user attribution (including the purpose of the DEVICE's use, who used it,

and when) showing who used or owned the devices at the time the things described in

this warrant were created, edited, or deleted, such as logs, phonebooks, saved usemames

and passwords, documents, and browsing history.

3
 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 8 of 22

AFFIDAVIT IN SUPPORT OF
RESIDENTIAL SEARCH WARRANT APPLICATION

I, Scott Labor, being first duly sworn, hereby depose and state as follows:

Introduction and Agent Background

1. I submit this affidavit to demonstrate probable cause to search a residence used by

the residents and occupants for the preparation, storage, and distribution of controlled substances

and the storage of proceeds from those distributions. Based on the information below, pursuant

to Federal Rule of Criminal Procedure 41, I am applying for a warrant authorizing the search of

the residence of Thomas Rooney and Bryanna Rooney located at 7021 Vermont Route 100 in the

town Troy, Vermont (the SUBJECT PROPERTY)-a location within the District of Vermont. I

submit there is probable cause to search the SUBJECT PROPERTY for evidence relating to

violations of 21 U.S.C. §§ 841 and 846-specifically, distribution of controlled substances,

possession with intent to distribute controlled substances, and conspiracy to commit those

offenses. The SUBJECT PROPERTY is described with greater particularity in Attachment A.

The categories of items to be seized from the SUBJECT PROPERTY are listed in Attachment B.

2. I am a Special Agent with Homeland Security Investigations (HSI), the investigative

component of the Department of Homeland Security (DHS), and I have been since 2005. I am

currently assigned to the HSI Derby resident agency. In my capacity as a Special Agent, I am

familiar with federal laws regarding the possession and transfer of firearms as well as federal

laws regarding the distribution of, possession with the intent to distribute, and conspiracy to

distribute controlled substances. I have been trained in the investigation of violations of those

laws, and I have participated in many such investigations. I have applied for and executed search

warrants related to those violations, including searches of residences, searches of electronic

devices, and searches of location information for electronic devices and vehicles. I have

1
 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 9 of 22

participated in all phases of investigations of those violations, including interviews with fireann

purchasers who traded firearms for controlled substances and interviews with users and

distributors of controlled substances. As a result of my participation in these investigations, I am

familiar with the techniques employed by distributors of controlled substances and their means .

of acquiring, transporting, storing, preparing, and distributing controlled substances; their means

of collecting, transporting, and transferring the proceeds of controlled substances; and their

means of acquiring, using, and trafficking firearms in connection with the controlled substance

violations. Among those investigations, I have specifically participated in the investigation and

prosecution of controlled substance and firearm crimes in the ''Northeast Kingdom" of Vermont

(including portions of Orleans, Essex, and Caledonia Counties).

3. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents, law enforcement officers, and witnesses

in the course of this investigation. This investigation has involved a collaboration with the

Northern Vermont Drug Task Force (NVDTF), HSI, ATF, the Federal Bureau of Investigation

(FBI), and the Vermont State Police (VSP), as well as other assisting state and local law

enforcement organizations. I have personally participated in many aspects of this investigation,

and I have reviewed information from other investigators, business records and recordings, law

enforcement reports and affidavits, and interviews with witnesses involved. When a statement of

another individual is included herein, it is presented in sum and substance, unless it is shown to

be quoted directly. This affidavit is intended to show only that there is probable cause for the

requested search warrant, so it does not set forth all of my knowledge about this matter.

2
 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 10 of 22

Probable Cause

.4. In December 2023, HSI and the NVDTF started an investigation into the distribution

offentanyl and cocaine base in the Orleans County area of Vermont. The targets of the

investigation were Jose Jusino (also known as "Derrick Rose," whose year of birth is 1999),

William Jusino (also known as "Marcus Garvey," whose year of birth is 1992), a man locally

known as "AB" (identity unknown to law enforcement), Bryanna Rooney (year of birth 1994),

and Thomas Rooney (year of birth 1999). NVDTF had received information from a cooperating

individual (referred to herein as CI-1 and "she/he" and "him/her")1 that Jose Jusino (known to

CI-1 as "Derrick Rose" or "D Rose") and "AB" were actively selling fentanyl and cocaine base

(colloquially known as "crack" or "hard") in collaboration with others in Orleans County. CI-1

indicated that "Derrick Rose" was the lead "dealer" of a group of individuals ("crew'') from

Connecticut that were most recently staying at "Bryanna Fields's" house in Troy, Vermont. I

know Bryanna Fields to be married to Thomas Rooney and to have the married name of Bryanna

Rooney. CI-1 indicated that "Derrick Rose" had told him/her that Rooney's residence was his

current "spot," which I know is common lingo for a place to meet people for drug transactions.

NVDTF agents were familiar with Jose Jusino from periodic, ongoing drug investigations in the

Northeast Kingdom beginning in 2020. NVDTF Detective Aaron Lefebvre showed CI-1 an

unmarked photograph of Jose Jusino, and CI-1 positively identified the individual in the

photograph as "Derrick Rose," noting that she/he did not know the real name of"Derrick Rose."

1
At the time of this investigation, CI-1 was assisting HSI and NVDTF for monetary
compensation that was not contingent upon the identity of the target(s) of the investigation.
Based on CI-1 's statements to NVDTF, CI-1 is a recovering cocaine user. CI-1 has no known
criminal history based on the databases available to HSI and NVDTF. Based on CI-1 's
performance, the NVDTF detectives believe CI-1 is a reliable and credible source of
information.

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5. Another individual cooperating with NVDTF (referred to herein as CI-2 and

"she/he" and "him/her")2 informed detectives that a man known as "AB" was selling crack and

fentanyl in Orleans County. During the investigation described below, NVDTF determined that

"AB" was working with Jose Jusino and that Bryanna Rooney and Thomas Rooney were hosting

Jose Jusino and "AB," among other associates, in their residence at 7021 Vermont Route 100

(the SUBJECT PROPERTY) for the purpose of preparing, storing, and distributing drugs.

6. During January 2024, NVD1F and HSI conducted two separate controlled purchases

at the SUBJECT PROPERTY using CI-1. During the controlled purchases, "Derrick Rose"

(Jose Jusino) and/or "AB" (who identity is presently unknown) either coordinated or directly

conducted the controlled substance transaction. Other individuals-including Bryanna Rooney,

Thomas Rooney, and Jason Willey, each of whom is known to NVDTF detectives through prior

law enforcement contacts and investigations-were present during the transactions and

participated in some manner. If Jose Jusino or "AB" did not directly conduct the controlled

purchase, one or the other participated in the transaction by arranging it with CI-1 and directing

him/her to the SUBJECT PROPERTY. In both controlled purchases, suspected crack cocaine

was purchased by CI-1, surrendered to investigators by CI-1, and seized as evidence.

2
During a later portion of this investigation, CI-2 was also assisting HSI and NVDTF for
monetary compensation that was not contingent upon the identity of the target(s) of the
investigation. Based on CI-2's statements to NVDTF prior to working with NVDTF, Cl-2 was a
current user of"crack" cocaine; however, she/he was attempting to become sober. CI-2's
criminal history comprises three misdemeanor convictions for driving under the influence;
investigators are not aware of any other convictions. CI-2's statements to NVDTF investigators
during this investigation were corroborated by investigators' observations and by surveillance
during the events, so the NVDTF detectives believe CI-2 was a reliable and credible source of
information despite CI-2's use of cocaine before she/he was working with NVDTF.
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 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 12 of 22

Week ofJanuary 3, 2024 - Controlled Purchase Arranged through Jose Jusino

7. During this investigation, multiple controlled purchases of narcotics were arranged

with Jose Jusino and/or "AB" using CI-1. One of the controlled purchases was conducted during

the week of January 3, 2024, and it occurred at the SUJBECT PROPERTY.

a. CI-1 knew "Derrick Rose" (Jose Jusino) to use the Facebook account

labeled as "Robbert Rose" (https://www.facebook.com/profile.php?id=61550203277)

through prior interactions with him, and CI-1 told NVDTF detectives she/he could call or

message his Facebook Messenger account to arrange a crack cocaine purchase. Prior to

the controlled purchase, CI-1 contacted Jose Jusino-at the direction and in the presence

of NVDTF investigators-via Facebook Messenger messages exchanged with the

"Robbert Rose" account. Investigators observed the exchanged messages. In the

messages, Jose Jusino indicated CI-1 could "pull up" (which CI-1 and I understood to

mean come to a location to buy drugs), but he did not specify where to go. CI-1

understood that to mean she/he should go to the "spot" "Derrick Rose" had previously

indicated, the residence of"Bryanna Fields" (Bryanna Rooney) in Troy-a town in

Orleans County, Vermont. The messages arranged to purchase a "half ball" of crack

cocaine. 3 Jose Jusino further instructed Cl-1 to ask for "AB," which CI-1 understood to

mean she/he was to ask for "AB" upon arriving at the Rooney residence.

b. Investigators with NVDTF employed standard controls during this and the

other controlled purchases described below. For example, investigators met with CI-1

prior to the transaction and searched CI-1 and CI-1 's vehicle to determine if she/he

3
Based on my training and experience, I know that a "half ball" refers to approximately 1116th
ounce (approximately 1. 7 grams) of cocaine or cocaine base-that is, half of an "eight-ball,"
which is approximately I/8th ounce (approximately 3.5 grams) of cocaine or cocaine base.
5
Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 13 of 22

possessed any cash or controlled substances. CI-1 was then provided with $140 of

prerecorded currency for the planned purchase. CI-1 was also provided with audio/video

recording and audio transmitting devices so the investigators could monitor the

transaction in real time and review recordings after the event to corroborate CI-1 's

statements about the event. Investigators provided surveillance of the transaction

location and of CI-1 from the time CI-1 met with the investigators before the event until ·

CI-1 met with investigators after the event (except when CI-1 was inside of a structure or

vehicle for the transaction). CI-1 was then searched again after the event to ensure she/he

did not possess any controlled substances or currency that was not surrendered to the

investigators following the transaction. CI-1 then provided a sworn statement about the

transaction and the events surrounding; it.

c. Investigators obseryed CI-1 arrive at the Rooney residence located at 7021

Vermont Route 100 in Troy, Vermont (the SUBJECT PROPERTY) and enter the

residence through the front door. According to Cl-1 'slater sworn statement, CI-1 was

met by Holly Fields at the door. I know Holly Fields to be the father of Bryanna Rooney.

CI-1 told Holly Fields she/he was there to see "AB," and CI-1 met a male called "AB" in

the kitchen of the residence. CI-1 and "AB" discussed the price at which CI-1 had

purchased from Jose Jusino in the past, and "AB" agreed to sell the "half ball" for $120.

CI-1 handed the currency she/he had been provided by NVDTF to "AB" and received a

"half ball" of suspected crack cocaine from "AB." Investigators then observed CI-1

exiting the front door of the SUBJECT PROPERTY and leaving the driveway.

d. The agents met with CI-1 at a prearranged location. CI-1 surrendered the

purchased substance and $20 to NVDTF detectives. CI-1 stated that "AB" returned $20

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Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 14 of 22

to him/her in fulfillment of the transaction CI-1 had arranged with Jose Jusino via

Facebook Messenger messages using the "Robbert Rose" account. CI-1 stated that

• she/he provided the $140 to a male named "AB," that "AB" provided the crack cocaine,

and that "AB" returned $20 to him/her.

e. The surrendered substance was later field tested by NVDTF Detective Aaron

Lefebvre. The substance in the baggie tested presumptively positive for the presence of

cocaine using a NIK test kit. The suspected "crack" cocaine weighed approximately 2.1

grams, inclusive of packaging.

f. Investigators later reviewed recordings of the event from devices provided to

CI-1, and the recordings corroborated CI-1 's description of the transaction with "AB."

"AB" could be seen receiving the money from CI-1. At one point, Jason Willey was

readily visible standing at the kitchen island holding a quantity of apparent crack cocaine

in both hands. NVDTF investigators are familiar with and able to recognize Jason Willey

based on prior interactions, including an incident that occurred on or about January 1,

2022, when Jason Willey was shot by another drug dealer in the town of Holland,

Vermont. Drug paraphernalia-such as packaging materials, foil, digital scales, and tied-

off baggies-was visible on the kitchen island. Two still frame images from the video

recording of the controlled purchase appear below, depicting the kitchen island and the

individual investigators identified as Jason Willey.

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 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 15 of 22

Week ofJanuary 10, 202 4 - Controlled Purchase Arranged through "AB"

8. During the week of January 10, 2024, investigators made a second controlled

purchase from individuals at the SUBJECT PROPERTY using CI-1. CI-1 told NVDTF

detectives she/he could call or message "AB's" Facebook Messenger account to arrange a crack

cocaine purchase with him. Prior to the controlled purchase, at the direction and under the

observation ofNVDTF investigators, CI-1 contacted "AB" via Facebook Messenger with "AB"

using the "Anthony Burrow" (https://www.facebook.com/profile.php?id=6l553413059939)

profile name.

a. CI-1 requested a half ball of crack cocaine, and "AB" indicated it was fine to

stop by. Although no location was designated in the messages, CI-1 asked "AB" if they

were still in the same location, and "AB" responded affirmatively. CI-1 understood that

to mean that the transaction was to take place at the SUBJECT PROPERTY.

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Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 16 of 22

b. Similar controls were employed during this purchase, in that CI-1 was briefed

and searched prior to the purchase, was provided with recording and transmitting

equipment, was provided with $120 of prerecorded currency for the purchase, was

surveilled to and from the purchase location, and was searched and debriefed after the

purchase.

c. NVDTF investigators observed CI-1 reach the SUBJECT PROPERTY and

enter it through the front door. During a sworn statement after the resulting transaction,

CI-1 indicated she/he had arrived at the SUBJECT PROPERTY and met Thomas

Rooney-who was previously known to CI-I-inside the front door. Thomas Rooney

instructed CI-1 to keep his/her phone concealed, apparently concerned that it could be a

recording device. Thomas Rooney led CI-1 through the residence where they spoke with

Bryanna Rooney, with whom CI-1 was already familiar. Thomas Rooney asked CI-1 if

she/he had a bag he could use as packaging, and Cl-1. said no. Bryanna Rooney then told

Thomas Rooney she had a bag that could be used. Thomas Rooney told CI-1 the cocaine

weighed "1.7'' (grams). CI-1 thanked them, and Bryanna said, "You're welcome."

Thomas Rooney then asked CI-1 to smoke a "free hit" before leaving. Shortly thereafter,

investigators saw CI-1 departing the SUBJECT PROPERTY, and they followed CI-1 to a

prearranged meeting location.

d. Upon meeting with investigators following the transaction, CI-1 surrendered

the suspected "crack" cocaine she/he had purchased at the SUBJECT PROPERTY to

Detective Lefebvre. During a recorded sworn statement, CI-1 described the transaction at

the Rooney residence and informed the detective that he/she had used crack cocaine

while there. CI-1 provided the $120 from NVDTF to Thomas Rooney upon entering the

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 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 17 of 22

residence. Walking through the house, CI-1 observed several firearms on the kitchen

counter and a handgun resting next to a man on the couch who CI-1 did not know but

estimated was in his late twenties. Thomas Rooney and CI-1 went into a room where

Bryanna Rooney and another unknown male were. Thomas Rooney then began weighing

drugs on a scale, and Bryanna Rooney gave him a baggie to package them. After CI-1

received the "half ball" from Thomas Rooney, he wanted CI-1 to smoke cocaine with

them. CI-1 felt that was a ''test" to ensure he/she was not a confidential informant and

that, based on his/her experience, if you don't use the drugs when asked by the dealer,

you will get hurt. CI-1 advised he/she smoked "crack" cocaine to avoid getting hurt.

e. Detective Lefebvre field tested the substance in the plastic baggie CI-1

surrendered to him using a NIK test kit. The substance tested presumptively positive for

the presence of cocaine and weighed approximately 2.1 grams (inclusive of packaging).

f. Investigators later reviewed recordings of the event from devices provided to

CI-1. The audio portions of the recordings corroborated CI-1 's description of the

interactions with Thomas Rooney and Bryanna Rooney. Their voices-with which

Detective Lefebvre is familiar from prior interactions-could be heard while he was

interacting with CI-1 during the controlled purchase.

Late January 2024 - Interactions between CI-2 and "AB"

9. During the week of January 30, 2024, investigators communicated with individuals

associated with the SUBJECT PROPERTY using CI-2, with whom they had just started working

under an agreement with NVDTF. On January 30, 2024, NVDTF investigators met with CI-2.

CI-2 stated that she/he had gone to the SUBJECT PROPERTY on January 26, 2024-before

having signed an agreement with NVDTF· as a formal cooperator-with Shayne Prue. Shayne
 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 18 of 22

Prue is known to NVDTF investigators, who believe him to be a dealer of controlled substances

in the Orleans County, Vermont area based on prior investigations. CI-2 stated that, while at the

SUBJECT PROPERTY with Shayne Prue, she/he met a black male going by the name "AB."

CI-2 told investigators that she/he wasn't at the property for long before she/he was asked to

leave by occupants of the property. CI-2 stated that, several minutes later, Shayne Prue came out

of the SUBJECT PROPERTY with a large amount of drugs. Detectives showed CI-2 an

unmarked image of a man they suspected might be "AB," and CI-2 stated that the image

appeared to be the person she/he knew as "AB." CI~2 stated that on January 28, 2024, she/he

received a Facebook Messenger message from profile "Anthony Burrow"

(https://www.facebook.com/profile.php?id=61553413059939). CI-2 stated that she/he

recognized an image on the Facebook account to be "AB." CI-2 stated that "AB" asked him/her

via Facebook Messenger if she/he was the person that got kicked out of the house a couple of

days ago. CI-2 stated that "AB" apologized and indicated that he and his crew get nervous when

new people show up. CI-2 stated that "AB" told him/her that she/he could come back to the

SUBJECT PROPERTY anytime she/he needed.

10. Prior to meeting with CI-2 on January 30, 2024, CI-2 had been instructed by

NVDTF detectives to contact "AB" via Facebook Messenger if possible. CI-2 sent a message to

the "Anthony Burrow" profile, but CI-1 told detectives that "AB" was offline and hadn't

responded to his/her message.

11. On January 31, 2024, CI-2 contactedNVDTF investigators and stated that "AB"

responded that day. "AB" told CI-2 that he wasn't at the house, but that someone would be there

in his place. CI-2 further stated that "AB" said he would be back on Friday (presumably

February 2, 2024).

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 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 19 of 22

12. Since December 2023, investigators have periodically surveilled the area around

the SUBJECT PROPERTY. During such surveillance operations, investigators have observed a

large number of subjects coming to and leaving from the SUBJECT PROPERTY in short time

frames. Based on my training and experience, I know that such interactions may be indicative of

drug-distribution activities.

13. Based on my training, experience, and participation in other controlled substances

investigations, I know the following:

a. Both small- and large-scale drug traffickers often maintain, on hand, large

amounts of U.S. currency obtained from the distribution of controlled substances and

used to finance their ongoing drug businesses.

b. Controlled substance traffickers commonly maintain books, records, receipts,

notes, ledgers, electronic/digital data (including on cell phones), money orders, and other

documents relating to the transportation, acquisition, and distribution of controlled

substances. Those records frequently include communications and photographs on

cellular phones that are used to exchange text messages and communications in

applications such as Facebook Messenger, Textnow, and WhatsApp.

c. Controlled substance traffickers often provide controlled substances on

consignment (fronting them) to their clients.

d. The aforementioned books, records, receipts, notes, ledgers, etc. are

commonly maintained where controlled substance traffickers can have ready access to

them, particularly in their residences and stash locations.

e. It is common for both small- and large-scale drug traffickers to conceal

contraband, proceeds of drug sales, and records of transactions in secure locations within

12
Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 20 of 22

their residence and/or other residences, either vacant or occupied by other members of the

trafficking conspiracy (stash houses), and/or their businesses, to conceal them from law

enforcement authorities.

f. Persons involved in both small- and large-scale drug trafficking commonly

conceal in their residences, stash houses, and businesses caches of drugs, large amounts

of currency, financial instruments, firearms, and other items of value and/or proceeds of

drug transactions and evidence of financial transactions relating to the attainment and

concealment of large sums of money acquired from engaging in narcotic trafficking

activities.

g. It is common practice for both small- and large-scale narcotic traffickers to

travel to source areas to purchase and otherwise facilitate their trafficking. After

purchasing controlled substances, the traffickers will transport narcotics (or cause them to

be transported) to areas in which they will distribute them. Such methods of

transportation in this region typically involve rented or borrowed vehicles or vehicles

driven by "runners" who drive the vehicle containing proceeds or controlled substances

in exchange for controlled substances.

h. Narcotics traffickers commonly maintain contact lists consisting of names,

nicknames, screen names, addresses, and/or telephone numbers in books, documents,

ledgers, or digital data forms. Those contact lists include information about their

associates in the trafficking organization, their sources of supply, and their customers.

i. Drug traffickers often take or cause to be taken photographs of themselves,

their associates, their property (including firearms), their products, and proceeds from

13
 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 21 of 22

distributions. The photographs are usually maintained on electronic devices at the

residences used for their activities and/or businesses of the traffickers.

j. Drug traffickers commonly have in their possession (that is on their persons,

in their vehicles, and at residences they occupy or use, and/or their businesses) firearms

and ammunition to protect themselves, their controlled substances, and the proceeds from

distributions from robberies. Those firearms often include pistols, revolvers, rifles, and

shotguns, and they occasionally include machine guns, silencers, or other restricted

weapons. Drug traffickers will also frequently trade controlled substances for other

goods, to include firearms.

Conclusion and Requests

14. For the reasons described above, I submit there is probable cause to believe that

violations of Title 21, United States Code, Sections 846 and 841 have occurred in or at the

SUBJECT PROPERTY at 7021 Vermont Route 100, Troy, Vermont. Further, probable cause

exists to believe that the SUBJECT PROPERTY may contain evidence of those criminal

offenses, contraband and fruits of those offenses, and property that has been used in committing

those offenses. Accordingly, I request the Court issue a search warrant authorizing the search of

the SUBJECT PROPERTY described in Attachment A and the seizure from that SUBJECT

PROPERTY of items listed in Attachment B.

Dated at Burlington, in the District of Vermont, this ,t~day of February, 2024.

,~~' .•
.//·.,.·· ...
/_,· .
.,./t:-a------·•'·--------
«-·z (._.,..,-·•
?
Scott Labor, Special Agent
Homeland Security Investigations

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 Case 2:24-mj-00020-kjd Document 5-2 Filed 02/08/24 Page 22 of 22

.J..!
Subscribed and sworn to before me in Burlington, Vermont on this ..fr._ day of February, 2024.

Magistrate Judge
United States District Court
District of Vermont

15