AO 91 (Rev. I Ill !

) Criminal Complaint
SEALED
Case 1:20-cr-00076-DKW Document 1 Filed 04/30/20 Page 1 of 7

BY THE ORDER OF THE COURT

PageID #: 1

UNITED STATES DISTRICT COURT

for the
District of Hawaii FILED IN THE
UNITED
UN ITED STATES DISTRICT COURT
DISTRICT OF HAWAII
United States of America ) Apr30,
Apr 30, 2020
v. ) SUE BEITIA, CLERK

) Case No.
Trevor Keegan
) 20-473 KJM
)
)
)
Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
<;>nor about the date(s) of . Dec. 4, 2019 to the present in the county of Honolulu in the
District of Hawaii , the defendant(s) violated:
- - - - --
Code Section Offense Description
21 U.S.C. §§ 841(a)(1) & 846 Conspiracy to distribute controlled substances.

This criminal complaint is based on these facts:

See attached affidavit.

~ Continued on the attached sheet.

Joshua W. Kent, Special Agent

Printed name and title

Sworn to before me and signed in my presence.

Date; April 30, 2020 at 12:38 p.m.

Kcnacth J. Mansfield
City and state: Honolulu, Hawaii United States Magistrate Judge
 Case 1:20-cr-00076-DKW Document 1 Filed 04/30/20 Page 2 of 7 PageID #: 2

AGENT’S AFFIDAVIT
IN SUPPORT OF CRIMINAL COMPLAINT

Joshua W. Kent, being duly sworn, deposes and states as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I am a Drug Enforcement Administration (“DEA”) Special Agent

currently assigned to the Honolulu District Office. I have been a Special Agent

with the DEA since June 2019. I am currently assigned to Honolulu Airport Task

Force, where my duties include, but are not limited to, investigating federal drug

crimes, including the unlawful manufacture and distribution of controlled

substances. Prior to entering the DEA, I was a Child Protective Investigator for the

Hillsborough County Sheriff’s Office. I am empowered by law to conduct

investigations of and to make arrests for criminal offenses arising from violations

of the Controlled Substances Act.

2. I have become knowledgeable with the enforcement of federal laws

pertaining to narcotics and dangerous drugs. I attended and successfully

completed the Basic Agent training program necessary to become a certified

Special Agent at the DEA Academy in Quantico, Virginia. I have been involved in

numerous drug related arrests and surveillances operations. I have participated in

drug trafficking investigations in which court-authorized wire interception was

utilized. I have conducted and/or participated in investigations that resulted in the

seizure of various quantities of methamphetamine, heroin, other controlled

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substances, and of narcotic proceeds. Based on my training and experience, I have

become well versed in the methodology utilized in narcotics trafficking operations,

the specific types of language used by narcotic traffickers, the unique trafficking

patterns employed by narcotics organizations and their patterns of drug abuse.

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

training and experience, and information obtained from other agents and witnesses.

This affidavit is intended to show merely that there is sufficient probable cause for

the specified violation of federal law and does not set forth all of my knowledge

about this matter.

4. This affidavit is made in support of a criminal complaint and arrest

warrant for TREVOR KEEGAN, for the crime of Conspiracy to Distribute

Controlled Substances, a violation of Title 21, United States Code, Sections

841(a)(1) and 846.

PROBABLE CAUSE
AND BACKGROUND OF INVESTIGATION
5. In September 2019, a United States Air Force Office of Special

Investigations confidential source provided information that an individual was

utilizing the social media application Snapchat to advertise and conduct drug sales,

particularly with active duty military service members.

6. The matter was referred to DEA, which identified the individual as

Austin White through his public Snapchat account and a photograph from his State

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of Hawaii driver’s license. White’s public Snapchat account showed the public

advertisement of various controlled substances for sale with listed prices. One of

the advertised controlled substances was Lysergic Acid Diethylamide (“LSD”),

more commonly known as “acid,” which is a schedule I controlled substance.

7. Utilizing Snapchat, investigators contacted White for a drug purchase.

On December 4, 2019, White sold an undercover agent (“UC-1”), approximately

twenty grams of a suspected LSD mixture in the form of ingestible gummies for

$200 at an address in the District of Hawaii.

8. On January 13, 2020, White sold UC-1 approximately fifteen grams

of suspected LSD mixture in both blotter paper and ingestible gummy form for

$500 at an address in the District of Hawaii.

9. On February 18, 2020, White sold UC-1 approximately forty-eight

paper blotter tabs of suspected LSD for $900 at an address in the District of

Hawaii. During this drug purchase, White told UC-1 that his source of supply for

the LSD “works in chemistry” and “makes his own stuff.” During further

conversations with UC-1, White has referred to his source of supply as “the

chemist” and “the cook.”

10. On March 18, 2020, during a recorded phone call, White told UC-1

that making 300 paper blotter tabs of LSD would be “easy” for his source of

supply.

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11. On March 30, 2020, White told UC-1 to meet him at an address in the

District of Hawaii for purposes of another LSD purchase. White told UC-1 that his

source of supply would bring the LSD and that White would retrieve the LSD from

him. White also told UC-1 that White was the “middle man.” During the

purchase, White told UC-1 that the source of supply was nearby and pointed to a

vehicle occupied by only one individual. UC-1 gave White $2,500. White then

immediately entered the vehicle that he associated with the source of supply.

White then returned to UC-1 and handed over 166 paper blotter tabs of suspected

LSD. Directly after the March 30 drug purchase, the vehicle White associated with

his source of supply departed the area. Your affiant observed the driver of this

vehicle and positively identified the driver as TREVOR KEEGAN from his Hawaii

driver’s license photograph. This vehicle was also registered to a “Trevor

Keegan.”

12. According to his Facebook account, KEEGAN works at the State of

Hawaii’s Department of Health Disease Outbreak Control Division as an “extract

tech.” Through conversations with DEA Forensic Chemists, your affiant knows an

“extract tech” may possess knowledge of chemistry and how to operate a lab and

utilize lab equipment.

13. The paper blotter tabs from both the January 13 and February 18,

2020 purchases were tested at DEA South West Lab with positive results for the

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presence of LSD. 1 The paper blotter tabs purchased on March 30, 2020, were also

submitted to the DEA South West Lab. Those results are pending, however these

paper blotter tabs are of the same likeness as those purchased from White on

January 13 and February 18, 2020.

14. As recently as April 23, 2020, White has continued to advertise the

sale of controlled substances, including LSD, using Snapchat.

CONCLUSION OF THE AFFIANT

15. Therefore, based on my training and experience and the

aforementioned facts, I believe that probable cause exists that on or about

December 4, 2019 and continuing to the present day, in the District of Hawaii,

TREVOR KEEGAN did commit the crime of Conspiracy to Distribute

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The ingestible gummies did not test positive for the presence of LSD.
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Controlled Substances, a violation of Title 21, United States Code, Sections

841(a)(l) and 846._

Respectfully submitted,

Joshua$(kent V
Special Agent, DEA

Sworn to under oath before me telephonically,

and attestation acknowledged pursuant to
Federal Rule of Criminal Procedure 4.l(b)(2)
On April 2.Q__, 2020.

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