Case 2:21-mj-30536-DUTY ECF No. 1, PageID.

1
AUSA: Filed 11/11/21 Telephone:
Julie A. Beck Page 1 of 7 550-9333
(313)
AO 91 (Rev. ) Criminal Complaint Agent: Edward A. LaVigne Telephone: (956) 231-8719

UNITED STATES DISTRICT COURT

for the
Eastern District of Michigan

United States of America

v. Case: 2:21-mj-30536
Sandeep Singh and Judge: Unassigned,
Case No.
Karanpreet Singh Filed: 11-11-2021 At 03:12 PM
USA v. (1)SANDEEP SINGH, (2)
KARANPREET SINGH (CMP)(MLW)

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 November 11, 2021 in the county of Wayne in the
Eastern District of Michigan , the defendant(s) violated:
Code Section Offense Description
21 United States Code, Section 841(a)(1) Possession with intent to distribute controlled substances

This criminal complaint is based on these facts:

See attached affidavit in support

✔ Continued on the attached sheet.

Complainant’s signature

HSI Special Agent Edward A. LaVigne

Printed name and title
Sworn to before me and signed in my presence
DQGRUE\UHOLDEOHHOHFWURQLFPHDQV

Date: November 11, 2021 Judge’s signature

City and state: Detroit, Michigan Honorable Anthony P. Patti, US Magistrate Judge
Printed name and title
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AFFIDAVIT

I, Edward La Vigne, being duly sworn, depose and state the following:

1) I am a Special Agent (SA) with the United States Department of Homeland

Security, Immigration and Customs Enforcement (ICE) Homeland Security

Investigations (HSI) in Detroit, Michigan, which is located in the Eastern

District of Michigan. I have over 17 years of federal law enforcement

experience, and over ten years relating to border enforcement activities. During

my tenure with the Department of Homeland Security, I have conducted

numerous investigations relating to money laundering, contraband smuggling,

and drug distribution. The following information is based upon my own

investigation and previous experiences, as well as investigations conducted by

fellow law enforcement officers and their previous experiences.

2) I have personally participated in the investigation set forth below. I am familiar

with the facts and circumstances of the investigation through my personal

participation, from discussions with other law enforcement officers and agents,

from my discussions with witnesses and the suspects involved in the

investigation, and from my review of records and reports relating to the

investigation. I have not included details of every aspect of the investigation.

FACTS AND CIRCUMSTANCES IN SUPPORT OF PROBABLE CAUSE:

3) On November 11, 2021, Customs and Border Protection Officers (CBPO)

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contacted the Homeland Security Investigations (HSI) on call Special Agent

(SA) Andre Young regarding the outbound Customs inspection of commercial

truck drivers Sandeep SINGH, and Karandeep SINGH, both Canadian

permanent residents. SA Young in turn contacted the HSI Detroit Narcotics

Group to refer the information. HSI Detroit Special Agent Edward (Ted) La

Vigne was contacted by the supervisor and responded to the scene.

4) According to CBP Officers, S. SINGH attempted to drive his commercial truck

with attached commercial trailer from Detroit, Michigan to Windsor, Canada

via the Detroit Ambassador Bridge at approximately 11:20 PM on Wednesday,

November 10, 2021. CBPOs stated the truck operated by K. SIINGH’ was

selected for random inspection after entering the outbound plaza of the Detroit

Ambassador bridge.

5) During this outbound Customs inspection, a CBP Officer contacted S. SINGH

(driver) and K. SINGH (passenger). CBPO’s asked K. SINGH where they were

coming from and what they were transporting in the truck. K. SINGH

responded, “California with broccoli.” CBPOs asked S. SINGH what

commercial trucking company they worked for, and they both (S. SINGH and

K. SINGH) responded they worked for Pride Group, a commercial trucking

company based in Brampton, Ontario. CBPO’s asked both S. SINGH and K.

SINGH if they had had any firearms, narcotics, or U.S. currency over
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$10,000.00. S. SINGH and K. SINGH each gave a negative response to the

question indicating they didn’t have any of the objects or materials inquired

about by CBPO’s.

6) At that time CBPO’s referred the truck for further inspection. S. SINGH parked

the truck, and both he and K. SINGH were asked to exit the vehicle so that

CBPO’s could conduct a full inspection of the vehicle’s cab. CBPO’s again

asked S. SINGH and K. SINGH if they had any firearms, narcotics, or U.S.

currency over $10,000, and again both responded they did not. CBPO’s have

authority to inspect commercial cargo entering and departing the United States.

CBPO’s entered the cab of the truck and began their inspection. During the

inspection CBPO’s lifted the bottom bunk in the sleeping area of the truck, and

immediately noticed vacuum sealed bags with what appeared to be a white

“crystal” substance.

7) A CBPO K-9 handler and his K-9 were dispatched to the truck to conduct

further inspections. The K-9 was walked around the truck and indicated to the

presence of narcotics in the cab of the truck. The K-9 then entered the truck

and alerted to the presence of narcotics under the bunk bed in the truck’s cab.

The truck was then moved to a loading dock at the CBP facility where the white

“crystal” material was field tested and returned positive results for “d-

Methamphetamine hydrochloride.” CBPO’s removed approximately 45 bags

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containing the white “crystal” material from under the bottom bunk in the

sleeping compartment. CBPO’s field-tested eight additional packages of the

material and all of them returned positive results for “d-Methamphetamine

hydrochloride.”

8) On November 11, 2021 HSI SA La Vigne responded to the Detroit Ambassador

Bridge and reviewed items seized by CBP Officers. This review disclosed

approximately 45 vacuum sealed plastic bags with an approximate weight of

93.75 kilograms which is consistent with large-scale drug

smuggling/distribution. SA La Vigne is aware based upon experience that 93

kilograms of suspected Methamphetamine has an estimated retail value of

approximately $1,400,000.00 in the Toronto, Canada areas. SA La Vigne is

aware through prior investigations, that commercial truck drivers are actively

involved in smuggling methamphetamine from the U.S. into Canada and are

paid approximately $500 - $750 per kilogram smuggled. SA La Vigne is also

aware that commercial truck drivers involved with methamphetamine

smuggling typically receive under 40 kilograms to smuggle per occasion, unless

they have completed multiple successful smuggling ventures.

9) On November 11, 2021, a biographical questionnaire was conducted on S.

SINGH. After the questionnaire was completed, S. SINGH received his

Miranda warnings from HSI Special Agents. S. SINGH affirmed his right to
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counsel and questioning was ceased at that time. HSI SA’s as well as CBPO’s

observed at no time did S. SINGH ever ask why he was being detained, how

long he would be held, or any questions at all pertaining to his detention. This

behavior is extremely odd, as subjects detained for various reasons at the bridge

often inquire as to why they are being held, what they did wrong, and when

they’ll be free to leave.

10) On November 11, 2021, a biographical questionnaire was conducted on K.

SINGH. After the questionnaire was completed, K. SINGH received his

Miranda warnings from HSI Special Agents. K. SINGH affirmed his right to

counsel and questioning was ceased at that time. During the review of K.

SINGH’s biographical questionnaire, K. SINGH began to shake or shiver

uncontrollably, and his voice was quivering. K. SINGH also had a very

difficult time responding to basic questions in regard to his biographical

questionnaire. His mouth was very dry and he had a hard time speaking at

times. Based on my experience in interviewing subjects for approximately

twenty years, this is behavior is common with individuals that are under

extreme stress or duress. Additionally, like S. SINGH, at no time did K.

SINGH ever ask why he was being detained, how long he would be held, nor

did he ask any questions at all pertaining to his detention. This behavior is

extremely odd, as subjects detained for various reasons at the bridge often
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inquire as to why they are being held, what they did wrong, and when they’ll be

free to leave.

11) SA La Vigne is aware that this criminal conduct occurred within the Eastern

District of Michigan and based upon my training and experience, the drug

amount seized is an amount consistent with large scale narcotics distribution.

12) Based on the foregoing, there is probable cause to believe that Sandeep

SINGH, and Karanpreet SINGH violated 21 United States Code, Section

841(a)(1).

_________________________________
Special Agent Edward La Vigne
U.S. Department of Homeland Security
Homeland Security Investigations

Sworn to and subscribed before me in person or

by other, reliable electronic means.

_______________________________________
Honorable Anthony P. Patti
United States Magistrate Judge

Dated: November 11, 2021