Repost - Doc 54-1 Exhibit 1 OCR extract State of California-County of Orange
(Home address omitted)
STATEMENT OF PROBABLE CAUSE
Personally appeared before me this 11th day of February 2007, who on oath says he has, and there is, just probable and reasonable cause to believe and that he does believe, there is now on the premises located at (See Attachment -A") the following personal property to wit: US currency and other items consistent with the crimes of money laundering (See Attachment B). Your affiant says there is probable and reasonable cause to believe and that he does believe that said property mentioned constitutes ( C.P.C_ 1524 ) 2, 3, and 4, to wit: When the property or things were used as means of committing a public offense, or in the possession of another to whom he or she may have delivered it for the purpose of concealing it or preventing being discovered, when the property or things to be seized consists of any item constitutes any evidence which tends to show a felony has been committed or tends to show that a particular person/persons has committed a felony.
Your affiant, Michael D. Munn, is a DA investigator with the Orange County District Attorney's Office and has been so employed for over ( 9 ) years. During this period your affiant was assigned to Trial-prep, Gangs, DEA Task Force, Department of Justice Methamphetamine Lab Task Force, and now currently assigned to the Anti- Terrorism / Organized Crime Unit for the past five years.
Prior to being employed by the DA'S Office, your affiant was a police officer for the City of Buena Park from 1987 to 1998. While employed by Buena Park, your affiant worked a variety of specialized assignments. Your affiant was first assigned to the patrol division where your affiant was involved in the investigation of over 400 drug-related cases. Your affiant has prepared and executed over 100 drug related search warrants where controlled substances were located. Your affiant has an Associates Degree in Criminal Justice from Santa Ana Junior College and a B.A. in Organizational Leadership from Chapman University.
On February 10, 2007, at approximately 1740 hrs. your affiant received a telephone call from Sup. Inv. Morton from the Orange County DA's Anti Terrorism/Organized Crime Unit. Sup. Inv. Morton told your affiant that he had received a telephone call from Sgt Vince Luciano from the Texas Department of Safety. Sgt. Luciano reported the following to Sup. Inv. Morton and to your affiant a short time later.
STATEMENT OF PROBABLE CAUSE
On 2/8/2007, at approximately 1420 hrs, Trooper Danny Nunez (Texas DPS) stopped an AVIS Rental 2007 Chevrolet 4-D bearing South Carolina license number "279UYF" for speeding 84/70 mph. The driver's nervous behavior and conflicting story to the officer led to a consent search. The search resulted m the seizure of approx $146,700.00, which was stored in a DHL bag. Approximately $8,600.00 of this was located in a shoe stored in luggage. The driver now identified as David Justin WOODS DOB: 10/13/1981 was mirandized and interviewed. WOODS stated that in April of 2006 Matthew BROWN (WOOD'S high school friend) had paid for WOODS to vacation in Las Vegas. During that trip WOODS met a male subject by the name of Pawel DYNKOWSK1. DOB: 2/27/1985.
WOODS admitted to Sgt. Luciano that he had previously met a subject believed to be Joseph MANGIAPANE Jr. DOB: 2/8/1966 who was supposedly connected to Organized Crime through his father Joseph MANGIAPANE DOB. 12/10/1938 with a history of Extortion, Gambling, Book Making and Possession of Stolen Property.
WOODS stated that Matthew BROWN hired him on or about 2/1/2007 to fly to California specifically for a "driving job" that BROWN said was for MANGIAPANE Jr. WOODS was to be paid $10,000 for this driving job. WOODS agreed and Matthew BROWN paid for WOODS' airline ticket to fly into LAX Airport in Los Angeles.
On 2/6/2007 WOODS flew Continental Airlines to California. While at LAX WOODS rented a vehicle and drove to Matthew BROWN' s residence located at [xxxxxxxxxxxxxxx], in the County of Orange. WOODS was given a DHL bag by BROWN who told him that the DHL bag contained $140,000 dollars. The payment of $10,000 dollars for WOODS was on the top of the DHL bag.
WOODS left California the next day on 2/7/2007 with the DHL, bag BROWN had given him. WOODS was later stopped in the State of Texas by Trooper Danny Nunez when he located the money. WOODS told Sgt. Lucino that he was instructed to deliver the money seized to a subject by the name of Pawel DYNKOWSKI at [xxxxxxxxxx] Delaware.
A Texas DPS analyst positively identified Matthew BROWN and Pawel DYNKOWSKI which WOODS confirmed through DL photos. The residences of BROWN and DYNKOWSK1 were also verified via analytical efforts. MANGIAPANE Sr. was identified through investigative efforts and was positively identified by WOODS from a photograph obtained via the Internet that MANGIAPANE Jr. had previously showed WOODS.
STATEMENT OF PROBABLE CAUSE
Pawel DYNKOWSKI has a criminal arrest record that includes a Breach of Peace charge. MANGIAPANE Jr. has no identifiable history. However, MANGIAPANE Sr. shows up on www.Hollywoodmafia.com that refers MANGIAPANE is involved in stealing publishing rights and selling said rights overseas, drugs, and pornography.
WOODS told Sgt. Luciano that the currency he was given to him by Matthew BROWN is illegal money. However, he does not have any knowledge Es to how the proceeds from said money were from. Road maps verifying WOODS's statements were also located in the AVIS 'Rental car, which further confirms the analytical information.
Sgt. Luciano said WOODS agreed to cooperate with officials in Texas who wanted him to deliver the monies seized to Pawel DYNKOWSKI (Police control delivery) in Delaware. Delaware authorities obtained a search warrant based on the probable cause on WOODS. The affiant in the Delaware search warrant received information concerning suspicious currency transactions that Pawel DYNKOWSKI was making. DYNKOWSKI personal checking account was opened on 1-19-06 at the Commerce Bank located at 101 Hygein Drive, Newark, De. These suspicious transactions include but are not limited to the following ATM withdrawals: 6/16/06 $500.00, 6/16/06 $8000.00, 6/21/06 $50.00, 6/23/06 $5000.00, 6/30/06 $500.00, 6/30/06 $8000.00. The volume of currency withdrawals are beyond the normal activity parameters for a personal checking account. Investigators also learned that there were several deposits and wire transfers into DYNKOWSKI's account in excess of $100,000 linking him to possible companies such as Tetrix Financial, Pawel DYNKOWSKI Pension Financial Services, and Premier financial Services which may further be associated with money laundering type of activities.
Investigators also discovered that Pawel DYNKOWSKI has an email address associated with his banking account of PAWEL2005@Comcast.net, thus indicating that DYNKOWSKI uses his computer for banking transactions and or business transactions.
On 2/9/2007, Sgt. Vincent Luciano obtained an arrest warrant for Pawel DYNKOWSKI for the charge of money laundering, a violation of Texas Penal Code 34.02, a 2nd Degree Felony.
Sgt. Luciano told your affiant that Matthew BROWN had purchased his residence at [xxxxxxxxxxxx] for over 1.2 million. Sgt. Luciano believes that BROWN purchased his residence from illegal money laundering proceeds.
STATEMENT OF PROBABLE CAUSE
Your affiant received a fax from Sgt. Luciano detailing his investigation and the Delaware State Police investigation concerning the control delivery by WOODS to DYNOKOSKI and WOODS'S statements regarding Matthew BROWN, along with a colored photograph of BROWN. ( See A-1 through A-7 attached ). Analyst Iris Huang conducted a Data Quick search on Matthew BROWN. This search revealed that BROWS had purchased his residence at [xxxxxxxxxxxxxxxxx] on December 11, 2006 for I.2 million.
Your affiant prays that a search warrant be issued, based upon the facts, seizure of said property, or any part thereof for night time service, good cause being shown therefore and that the same be brought before this magistrate or retained subject to the order of the court, or any other court in which offenses(s) is respect to which the property or things taken, is triable, pursuant to section 1536 of the California Penal Code.
Night time service is requested, based on the courier and the recipient of the $147,000 being arrested on 2110/07 in the early evening hours and additional accomplices needing to be identified. The destruction of evidence and the movement of monies by additional accomplices who are involved in money laundering and in violation of 186.10 of the California Penal Code is evident in this case.
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