International Drug Bust

Case 2:21-mj-00056-CKD Document 1 Filed 04/07/21 Page 1 of 36
AO 91 (Rev. 11/11) Criminal Complaint
UNITED STATES DISTRICT COURT

for the FILED
Eastern District of California Apr 07, 2021
CLERK, U.S. DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
United States of America )

v. )
) Case No. 2:21-mj-0056 CKD
)
Parampreet SINGH, Ranvir SINGH and Amandeep
MULTANI
Defendant(s)
)
)
)
SEALED
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
August 25, 2020 through the present
On or about the date(s) of date
in the county of Sacramento in the
Eastern District of California , the defendant(s) violated:

Code Section Offense Description
COUNT ONE – 21 U.S.C. §§ 841(a)(1) and 846 - Conspiracy to Distribute and Possess with Intent to Distribute at Least 5 Kilograms
of a Mixture and Substance Containing a Detectable Amount of Cocaine; Heroin; Opium; and Ketamine (August 25, 2020 through the
present).
COUNT TWO – 21 U.S.C. § 841(a)(1) - Distribution of at Least 500 Grams of a Mixture and Substance Containing a Detectable
Amount of Cocaine (March 11, 2021).
This criminal complaint is based on these facts:
(see attachment)
☒ Continued on the attached sheet.
/s/
Complainant’s signature
DEA Special Agent Joshua Matas

Printed name and title
Sworn to me and signed telephonically.
Date: April 7, 2021 at 8:01 am

Judge’s signature
City and state: Sacramento, California Carolyn K. Delaney, U.S. Magistrate Judge
Printed name and title
AFFIDAVIT IN SUPPORT OF SEARCH WARRANTS AND CRIMINAL COMPLAINT
I, Joshua Matas, being duly sworn, depose and state as follows:
Background and Expertise
1. I am a Special Agent with the Drug Enforcement Administration (“DEA”),

Sacramento District Office, and have been so employed since 2018. As such, I am a
“federal law enforcement officer” within the meaning of Federal Rule of Criminal
Procedure 41(a)(2)(C), that is, a government agent engaged in enforcing criminal laws and
duly authorized by the Attorney General to request a search warrant. I am responsible for
conducting investigations into narcotics traffickers and assisting in their apprehension.
These investigations are conducted both in an undercover and overt capacity and involve
electronic surveillance, cellphone-location evidence, confidential informants, and the
execution of search and arrest warrants. Prior to becoming a DEA Special Agent, I
graduated from the University of Florida with a Bachelor’s of Science in Chemical
Engineering in 2012. Upon being hired by DEA I completed a four-month DEA Basic
Agent School at Quantico, Virginia. After completing DEA Basic Agent School in
September 2018, I was assigned to the Sacramento District Office.
2. I was trained as a DEA Special Agent at the DEA Academy, Quantico, Virginia.
During my training, I received special training in the Controlled Substance Act, Title 21
United States Code, including but not limited to, Sections 841(a)(1) and 846, Controlled
Substance Violations and Conspiracy to Commit Controlled Substance Violations,
respectively. I have received special training regarding criminal organizations engaged in
conspiracies to manufacture and/or possess with intent to distribute methamphetamine,
cocaine, cocaine base, heroin, marijuana, MDMA, fentanyl, and other dangerous drugs
prohibited by law. I received further training in search and seizure law, financial
investigations and money laundering techniques, and many other facets of drug law
enforcement. I have also spoken to and worked with experienced federal, state, and
municipal agents and narcotics officers regarding the methods and means employed by
drug manufacturers and drug traffickers.
3. During the course of my employment as a DEA Special Agent, I have participated in

numerous criminal investigations. I have participated in executing numerous Federal and
State search warrants involving controlled substances, the seizure of narcotics-related
records and other types of evidence that document the activities of criminal organizations
in both the manufacturing and distribution of controlled substances. To successfully
conduct these investigations, I have utilized a variety of investigative techniques and
resources, including physical and electronic surveillance, and various types of infiltration,
including undercover agents, informants, and cooperating sources. I have participated in
multiple investigations targeting individuals and organizations trafficking cocaine, heroin,
marijuana, methamphetamine, fentanyl, and other drugs.
4. Through my training, experience, and interaction with other experienced Special

Agents, Task Force Agents, and other drug investigators, I have become familiar with the
1
methods employed by drug traffickers to smuggle, safeguard, store, transport, and

distribute drugs, to collect and conceal drug related proceeds, and to communicate with
other participants to accomplish such objectives. These methods include the use of
telephones, pre-paid or debit calling cards, public telephones, wireless communications
technology such as paging devices and cellular telephones, counter-surveillance,
elaborately planned smuggling schemes tied to legitimate businesses, and use of codes in
communications in an attempt to avoid detection by law enforcement. Based on my
training and experience, I also know that violators of the controlled substances laws often
purchase telephones or subscribe to telephone service using false names and/or other
individuals’ names to avoid detection by law enforcement.
Scope of Requested Search Warrants
5. This affidavit supports an application for warrants to search the locations and vehicles
further described below and in Attachments A-1 through A-9. The contraband, objects,
and information for which we will search are described in Attachment B. Attachments
A-1 through A-8 and Attachment B are incorporated by reference.
6. This Affidavit is submitted in support of warrants to search the following locations and
vehicles:
a. The residence located at 3001 Goshawk Street, Davis, California (“Target

Location 1”), as described in Attachment A-1;
b. The residence located at 1710 Baines Avenue, Sacramento, California (“Target

c. The residence located at 2209 Stansfield Drive, Roseville, California(“Target

d. The commercial property located at 847 Harbor Boulevard, West Sacramento,

California (“Target Location 4”) as described in Attachment A-4;
e. The following vehicles:
1. 2003 HUMMER SUV, Maroon with CA license #PJB37 (“Target

Vehicle 1”), as described in Attachment A-5.
a. Registered to Parampreet SINGH at 847 Harbor Boulevard, West
Sacramento, California
b. Parked at 847 Harbor Boulevard (suspected stash location) and
2393 Alta Garden Lane corresponding to geo-location data
generated from telephone number 209-500-0001, which is used by
Parampreet SINGH
2. 2019 AUDI sedan, Blue with CA license #SLOWA5 (“Target

2
a. Registered to Parampreet SINGH at 847 Harbor Boulevard, West

Sacramento, California
b. Parked at Target Location 1 and Target Location 4 corresponding
to geo-location data generated from telephone number 209-500-
0001, which is used by Parampreet SINGH
3. 2015 Volkswagen SUV, Blue with CA license #8SSC112 (“Target

a. Registered to Manit MULTANI at 7871 Mission Grove Parkway
S, Apt 115, Riverside, California
b. Driven by Amandeep MULTANI and Ranvir SINGH to and from
1 KG cocaine deal
4. 2015 Toyota sedan, White with CA license #7NTH692 (“Target Vehicle

4”), as described in Attachment A-8
i. Registered to Ranvir SINGH at 1710 Baines Avenue, Sacramento,
CA
ii. Parked at Target Location 2 and 2393 Alta Garden Lane
5. 2016 Mercedes SUV, White with CA license #PB711 (“Target

Vehicle 5”) as described in Attachment A-9.
a. Registered to Sarbjit SINGH at 1710 Baines Avenue, Sacramento,
California
b. Driven by Ranvir SINGH and parked at Target Location 2
7. I request authority to search Target Locations 1, 2, 3 & 4 and Target Vehicles 1, 2,

3, 4, & 5 for the items described in Attachment B.
Scope of Requested Criminal Complaint
8. This affidavit also supports an application for a criminal complaint and arrest warrants
for:
a. Parampreet SINGH
(Counts 1-2)
b. Ranvir SINGH
(Counts 1-2)
c. Amandeep MULTANI
(Counts 1-2)
COUNT ONE – Conspiracy to Distribute and Possess with Intent to Distribute at

Least 5 Kilograms of a Mixture and Substance Containing a
Detectable Amount of Cocaine; Heroin; Opium; and Ketamine, in
3
violation of 21 U.S.C. §§ 841(a)(1) and 846 (August 25, 2020

through the present).
COUNT TWO – Distribution of at Least 500 Grams of a Mixture and Substance

Containing a Detectable Amount of Cocaine, in violation of 21
U.S.C. § 841(a)(1) (March 11, 2021).
9. 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 only that there is sufficient probable cause for the requested warrants
and does not set forth all of my knowledge about this matter.
Statement of Probable Cause

Background and Overview of Investigation
10. In October 2020, I was contacted by DEA Ottawa Country Office (“CO”) agents
regarding the drug trafficking activities of Parampreet SINGH, Ranvir SINGH and
Amandeep MULTANI in Sacramento, CA. The DEA Ottawa CO agents advised that in
June 2020, they began investigating members of the Parampreet SINGH drug trafficking
organization (“DTO”), which they later found is based in Sacramento, CA and extends to
the greater Toronto, Canada metropolitan area. The DEA Ottawa CO investigators further
advised that the York Regional Police (a Canadian police department in the greater
Toronto area), is utilizing a police officer acting in an undercover capacity (“UC-1”) to
directly communicate with DTO members, who are involved in facilitating the trafficking
of cocaine, heroin, opium, and ketamine across international borders. The York Regional
Police have received assistance in their investigation from other law enforcement
agencies, including the Royal Canadian Mounted Police and the DEA.
11. The investigation has led to the identification of multiple members of the DTO and
their methods of communication, including the telephone numbers used by multiple DTO
members. The investigators have been able to successfully coordinate multiple undercover
purchases of kilogram quantity amounts of cocaine, opium, and ketamine, a schedule III
controlled substance, in the greater Toronto, Canada area; and a kilogram of cocaine in
Sacramento, California. These purchases were brokered through communications with
Parampreet SINGH, MULTANI, and/or Ranvir SINGH, some of the details of which are
described below.
12. During their communications with UC-1 and other undercover officers, as further
detailed below, Parampreet SINGH, MULTANI, and/or Ranvir SINGH have offered to
supply up to hundreds of kilograms of cocaine, heroin, opium, and ketamine at a time, in
both Canada and the United States. They have also stated that they have drug trafficking
connections to Mexico, India, Pakistan, Afghanistan, and Germany, in addition to the
United States and Canada.
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Introduction of UC-1 to Parampreet SINGH in August 2020
13. On June 2, 2020, UC-1 was in contact with a Canada-based DTO member and
engaged in drug-related conversations detailing the price of a kilogram of cocaine at
$60,000 Canadian dollars (“CAD”). The DTO member told UC-1 that his drug link in
the United States was “Dudi” (later identified as Parampreet SINGH), who was based out
of California. The DTO member gave UC-1 a phone number for Parampreet SINGH,
661-510-3143, to facilitate further conversations detailing drug trafficking logistics.
14. On August 25, 2020, UC-1 initially contacted Parampreet SINGH at 661-510-3143. 1
UC-1 asked the user if he was Dudi, and the user confirmed he was. Parampreet SINGH
further communicated with UC-1 on this day by calling from a second device with phone
number 209-500-0001. While using 209-500-0001, Parampreet SINGH told UC-1 that he
resided in Davis, California. When UC-1 requested information on sourcing some “stuff”
(referring to narcotics), Parampreet SINGH advised he would call back at a later date.
15. On September 20, 2020, UC-1 contacted Parampreet SINGH utilizing WhatsApp at
phone number 209-500-0001. Parampreet SINGH advised there was a shipment of opium
arriving in Vancouver consisting of 25-30 “pieces,” which UC-1 understood to refer to
kilograms. Parampreet SINGH said he wished that UC-1 would coordinate a pick-up of
this shipment with his Canada-based counterparts.
16. Further conversation with Parampreet SINGH occurred between the dates of
September 20, 2020 and October 18, 2020. During these conversations, Parampreet
SINGH related that there was cocaine available for sale at $33,000 USD and that there
were 25 kilograms of heroin for sale. Parampreet SINGH continued engaging in drug-
related conversations while using 209-500-0001, in which he advised UC-1 that there was
more money to be made if pick up of the cocaine was arranged in California. Parampreet
SINGH also advised UC-1 to download another encrypted messaging application BOTIM.
Based on my training and experience, I believe SINGH’s consistent use of encrypted apps
shows his level of expertise in his attempts to avoid detection of his drug-related
conversations by law enforcement.
Controlled Purchase of approximately 1 kilogram of Ketamine in Brampton, Canada, on

October 21, 2020, coordinated by Parampreet SINGH and Ranvir SINGH
17. In October 2020, Parampreet SINGH stated that he had a contact in possession of 200
kilograms of ketamine. Parampreet SINGH asked UC-1 if somebody would buy the
ketamine for “40” a piece, believed to mean $40,000 per kilogram of Ketamine.
Parampreet SINGH then passed UC-1 a phone number, 253-205-6137, for his “cousin”
whom he referred to as “Lally,” and who was later identified as Ranvir SINGH.
1
The communications between UC-1 and SINGH have occurred primarily in the Punjabi
language, as well as in English and Spanish at times. The descriptions of these communications
in this Affidavit are based on reports prepared by UC-1, summarizing in English UC-1’s
communications with SINGH.
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Parampreet SINGH told UC-1 that Ranvir SINGH would handle the drug deal related to
the purchase of ketamine. On October 19, 2020, UC-1 spoke with Ranvir SINGH on
BOTIM over 253-205-6137. During this conversation, Ranvir SINGH asked if UC-1
wanted to buy two pieces of ketamine, to which UC-1 advised he only wanted to purchase
one sample kilogram. 2 Ranvir SINGH then confirmed that he had a lot of pieces and that
on the day of the drug buy, he would have his guy contact UC-1 via WhatsApp. The
coordination efforts of UC-1 with Parampreet SINGH and Ranvir SINGH resulted in the
purchase of approximately 1 kilogram of ketamine in Brampton, Ontario, Canada (a
suburb of Toronto) on October 21, 2020, for $23,000 USD and $8,100 CAD.
Surveillance Regarding Parampreet SINGH and Ranvir SINGH
18. On November 2, 2020, a search warrant to obtain precise location data from 209-500-
0001 was signed by the Honorable Kendall J. Newman. Investigators received precise
location data from 209-500-0001 from November 5, 2020 to December 2, 2020. The data
generated from this search warrant revealed that the user of the telephone frequents a
residence in the area of 3001 Goshawk Street, Davis, California (Target Location 1),
which is known to be associated with Parampreet SINGH. The data also showed the user
of 209-500-0001 in the area of 847 Harbor Blvd, West Sacramento, California (Target
Location 4), which is a commercial property associated with Parampreet SINGH.
19. On November 2, 2020, investigators conducted drive-by surveillance of the residence

located at 3001 Goshawk Street, Davis, California (Target Location 1) and observed a
blue Audi sedan bearing a California license plate of SLOWA5 (Target Vehicle 2),
registered to Parampreet SINGH at 847 Harbor Blvd, West Sacramento, California
(Target Location 4).
20. On November 6, 2020, at approximately 4:35 pm investigators conducted drive-by

surveillance at 847 Harbor Blvd, West Sacramento (Target Location 4). Investigators
observed a Hummer SUV bearing personalized plate PJB37 (Target Vehicle 1),
registered to Parampreet SINGH at 847 Harbor Blvd, West Sacramento, California
(Target Location 4). The precise location data provided on November 6, 2020 between
the times of 4:30 pm & 4:44 pm show 209-500-0001 located within approximately 330
meters of 847 Harbor Blvd, West Sacramento, California (Target Location 4).
21. On November 13, 2020, investigators conducted a drive by surveillance at 1710

Baines Avenue, Sacramento, CA (Target Location 2); an address associated with Ranvir
SINGH. The residence is a standalone single-family residence displaying numbers "1710"
next to the garage door entrance. The residence is located on the southwest corner of the
intersection of Baines Avenue and Blackrock Drive. Investigators observed a white
Toyota Camry bearing CA license plate 7NTH692 (Target Vehicle 4) (valid, registered to
2
The communications between UC-1 and Ranvir SINGH have occurred primarily in the
Punjabi language. The descriptions of these communications in this Affidavit are based on
reports prepared by UC-1, summarizing in English UC-1’s communications with Ranvir SINGH.
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Ranvir SINGH at 1710 Baines Avenue, Sacramento, CA) parked in the driveway of 1710
Baines Avenue.
22. On December 4, 2020, investigators conducted surveillance of Ranvir SINGH at 1710

Baines Avenue, Sacramento, California (Target Location 2). Investigators observed two
vehicles parked in the residence driveway facing in the direction of the garage door; a
white 2016 Mercedes SUV with a personalized California license plate PB711 (Target
Vehicle 5), which is registered to Sarbjit SINGH at 1710 Baines Avenue, Sacramento, CA
and a white 2015 Toyota Camry with California license plate 7NTH692 (Target Vehicle
4) which is registered to Ranvir SINGH at 1710 Baines Avenue, Sacramento, CA. At
approximately 9:50 am, investigators observed a male, wearing a blue hooded sweater and
jeans, exit the residence while talking on a cellphone and enter the driver's side door of the
Mercedes SUV parked in the driveway. Surveillance then observed the Mercedes back
out of the driveway and travel westbound on Baines Avenue. Surveillance members
followed the Mercedes from the residence and visually confirmed the driver of the
Mercedes as Ranvir SINGH by comparing the driver’s appearance to that of the
photograph on record for Ranvir SINGH's California driver’s license. During this
surveillance operation, investigators lost visual of Ranvir SINGH’s vehicle while in
transit. At approximately 12:20 pm, investigators conducted an address check at an
apartment complex located at 2393 Alta Garden Lane, Sacramento, CA which is an
address related to Ranvir SINGH through his business affiliation of Miri Piri
Transportation INC. The white Mercedes driven by Ranvir SINGH earlier in the day was
observed by investigators parked directly in front of 2393 Alta Garden Lane.
Investigators observed Ranvir SINGH repeatedly appear from the front door area related
to 2393 Alta Garden Lane until the surveillance was terminated.
Controlled Purchase of 1 kilogram of ketamine in Brampton, Canada on November 13, 2020,

coordinated by Parampreet SINGH and Ranvir SINGH
23. On November 10-13, UC-1 engaged in numerous communications with Parampreet

SINGH at 209-500-0001 and Ranvir SINGH at 253-205-6137 regarding a purchase of 1
kilogram of ketamine, which resulted in the purchase of approximately 1 kilogram of
ketamine on November 13, 2020, in Brampton, Canada for $20,000 CAD, with $13,000
CAD to be paid later.
Controlled Purchase of 1 kilogram of purported ketamine in Brampton, Canada on December

3, 2020, coordinated by Parampreet SINGH and MULTANI
24. On December 3, 2020, UC-1 contacted Parampreet SINGH via the encrypted text
messaging application BOTIM at 209-500-0001 to coordinate the purchase of
approximately 1 kilogram of ketamine in Canada. Parampreet SINGH then passed a
number to the UC for “his guy,” later identified as Amandeep MULTANI, using 732-705-
0883, who would facilitate the completion of the drug buy of approximately 1 kilogram of
ketamine for $33,000 CAD in Brampton, Canada later that day. Following extensive
communications with MULTANI (who told UC-1 he was in California) regarding the
details and security measures for the transaction, UC-1 purchased approximately 1
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kilogram of purported ketamine for $33,000 in Brampton, Canada, from a Canada-based

DTO member taking directions from MULTANI. 3 Subsequent lab testing in Canada
revealed the purported ketamine in fact contained Diphenhydramine, a non-controlled
substance that is one of the primary active ingredients in Benadryl.
Controlled Purchase of 1 kilogram of Ketamine and sample of Heroin in Canada on

December 9, 2020, facilitated by Parampreet SINGH and MULTNAI
25. On December 8, 2020, UC-1 had a conversation with Parampreet SINGH at 209-500-
0001 via BOTIM. Parampreet SINGH advised UC-1 to contact the previous connection,
which UC-1 understood to mean MULTANI.
26. Minutes later, UC-1 was contacted by MULTANI via WhatsApp using 732-705-0883.
MULTANI asked UC-1 if they were ready to which the UC responded that they would be
ready the next day on December 9, 2020. MULTANI told UC-1 that he would be meeting
the “same guy” and that the driver was only available during the evenings. MULTANI
then told UC-1 that “Paji”, believed to be referring to Parampreet SINGH, told him what
UC-1 was looking for. MULTANI said he would get good pricing for both, believed to be
referring to cocaine and heroin.
27. On December 9, 2020, UC-1 again spoke to Parampreet SINGH via BOTIM at 209-
500-0001. Parampreet SINGH told UC-1 that his father was sick and that he would be
visiting India. Parampreet SINGH told UC-1 that the person whom UC-1 spoke with
previously (understood to refer to MULTANI) was the guy who connects people from
India, Afghanistan, Germany, the United States and Canada. Parampreet SINGH further
explained that UC-1 should keep MULTANI happy. Parampreet SINGH further stated
that the people in UC-1’s “village” (i.e., the Toronto area) have 100 pieces (understood to
mean kilograms) of “kala” (black in Punjabi, understood to mean opium).
28. Later that day, UC-1 engaged in extensive communications with MULTANI over
732-705-0883, which resulted in the purchase of approximately 1 kilogram of purported
ketamine and a sample of heroin from the DTO member who delivered the ketamine on
December 3, and who was being directed by MULTANI, for $33,000 CAD in Brampton,
Canada. Subsequent lab testing in Canada revealed the purported ketamine in fact
contained Dephenhydramine and confirmed the heroin sample to be heroin.
Parampreet SINGH Informs UC-1 He has 100-200 kilograms of Cocaine Available
29. On December 23, 2020, Parampreet SINGH used 209-500-0001 to contact UC-1 via
the BOTIM application. The two spoke about whether UC-1 wanted to purchase more
ketamine. UC-1 expressed concerns about the previous purchases because of the quality
of the product. Parampreet SINGH advised UC-1 that he would secure a new price of
3
The communications between UC-1 and MULTANI have occurred primarily in the
Punjabi language. The descriptions of these communications in this Affidavit are based on
reports prepared by UC-1, summarizing in English UC-1’s communications with MULTANI.
8
$25,000 per kilogram of ketamine. Parampreet SINGH then stated that he had arranged
for 100 to 200 “trucks,” which UC-1 understood to mean kilogram units of cocaine, to be
delivered to Canada. Parampreet SINGH stated that they were “39,” believed to mean
$39,000 USD per kilogram of cocaine. Parampreet SINGH confirmed that the shipment
would be originating from California.
Controlled Purchase of 1 kilogram of Ketamine in Toronto, Canada, on December 29, 2020,

coordinated by Parampreet SINGH
30. On December 29, 2020, UC-1 purchased approximately 1 kilogram of ketamine for
$25,000 CAD in Toronto, Canada, in a deal arranged by Parampreet SINGH using 209-
500-0001.
Controlled Purchases of 1.5 kilograms of Opium in Brampton, Canada, on January 7, 2021,

coordinated by MULTANI
31. On January 7, 2021, UC-1 purchased approximately 1.5 kilograms of opium in

Canada for a total of $33,500 CAD, in two separate transactions (of approximately 900
grams and 600 grams respectively) that UC-1 negotiated with MULTANI.
Controlled Purchase of 1 kilogram of Cocaine in the greater Toronto area, Canada, on

January 27, 2021, facilitated by Parampreet SINGH and MULTANI
32. On January 27, 2021, UC-1 purchased approximately 1 kilogram of cocaine in

Canada for $60,000 CAD, in a deal arranged by MULTANI. The next day, UC-1
communicated with Parampreet SINGH via a BOTIM call. Parampreet SINGH asked
how much UC-1 sold the cocaine for from the deal the previous day, and UC-1 said
$70,000 and that they each made $5,000 (UC-1 and Parampreet SINGH), according to a
50/50 profit sharing arrangement they had previously discussed. Parampreet SINGH then
vouched for MULTANI and said that MULTANI would provide more work (understood
to be a reference to cocaine), upwards to 30 kilograms. UC-1 responded that UC-1’s
buyers would be requesting that amount.
Controlled Delivery of $6,300 USD broker fee to Parampreet SINGH and MULTANI in
Sacramento, CA on February 3, 2021
33. UC-1 arranged for the delivery of $6,300 USD to Parampreet SINGH in Sacramento,
California, on February 3, 2021, as partial payment for approximately 2 kilograms of
ketamine and 1.5 kilograms of opium previously purchased in Canada on November 8,
2020 (ketamine), December 9, 2020 (ketamine), and January 7, 2021 (opium). A second
undercover officer (“UC-2”) delivered the broker fee to Parampreet SINGH on behalf of
UC-1. During this meeting in Sacramento, California, investigators positively identified
Parampreet SINGH as the individual who met with UC-2. Investigators also observed
Parampreet SINGH depart as a passenger in a Volkswagen SUV bearing a California
license plate 8SSC112 (Target Vehicle 3). Investigators identified the driver of the
Volkswagen SUV as MULTANI via a photograph provided from a DHS-HSI database
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check. Investigators then followed Target Vehicle 3 back to 2393 Alta Garden Lane,
Sacramento, CA. Surveillance members observed MULTANI and Parampreet SINGH
exit the vehicle and observed MULTANI walk up a sidewalk toward the condominium at
2393 Alta Garden Lane, on the north side of the condominium complex. MULTANI
walked north up the second sidewalk west of the condominium complex entrance. At the
same approximate time, Parampreet SINGH walked to a red Hummer SUV parked
furthest away from the Volkswagen and briefly did something near the driver’s side door.
Investigators subsequently identified the license plate of this vehicle as PJB37 (2003
Hummer, valid, registered to Parampreet SINGH at 847 Harbor Blvd., West Sacramento,
CA) (Target Vehicle 1). Moments later, Parampreet SINGH walked up the same
sidewalk, passing MULTANI, who briefly returned to Target Vehicle 3 and appeared to
retrieve something from the vehicle before returning back up the same sidewalk.
Controlled Purchase of 1 Kilogram of Cocaine in Brampton, Canada, on February 12, 2021,

coordinated by MULTANI
34. On February 12, 2021, UC-1 purchased approximately 1 kilogram of cocaine in

Brampton, Canada for $60,000 CAD, in a deal arranged by MULTANI.
Surveillance Regarding MULTANI and Parampreet SINGH
35. On February 23, 2021, a search warrant to obtain precise geo-location data of
MULTANI’s telephone number 732-705-0883 was signed by the Honorable Deborah
Barnes. Between March 3 and March 24, 2021, investigators analyzed the geo-location of
732-705-0883, which frequented the area of properties previously identified as related to
the DTO: 2393 Alta Garden Lane, Sacramento, CA and 847 Harbor Boulevard, West
Sacramento, CA (Target Location 4).
36. On March 5, 2021, a search warrant to obtain precise geo-location data of 209-500-
0001, used by Parampreet SINGH, was signed by the Honorable Deborah Barnes.
Between March 8 and March 24, 2021, investigators analyzed the geo-location data of
209-500-0001 (Parampreet SINGH), which frequented the area of properties previously
identified as related to Parampreet SINGH: 3001 Goshawk Street, Davis, CA (Target
Location 1) and 847 Harbor Boulevard, West Sacramento, CA (Target Location 4).
Controlled Purchase of 1 kilogram of cocaine coordinated by Parampreet SINGH and

conducted by MULTANI and Ranvir SINGH in Sacramento, CA on March 11, 2021; Target
Location 4 is identified as a suspected stash location
37. On March 9, 2021, UC-1 contacted Parampreet SINGH and arranged for the purchase
of approximately 1 kilogram of cocaine for $40,000 USD by UC-2 in Sacramento, CA.
They also agreed that UC-2 would deliver an additional $5,890 USD as payment for the
January 27 and February 12, 2021 cocaine deals facilitated by SINGH and MULTANI
with UC-1 in Toronto, Canada. UC-1 coordinated this deal while communicating with
Parampreet SINGH via BOTIM at 209-500-0001. Parampreet SINGH informed UC-1
that MULTANI would pick up the money and that MULTANI would handle matters.
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During the phone call communication, Parampreet SINGH handed his cell phone to
MULTANI, who confirmed directly with UC-1 that he (MULTANI) would be picking up
the money on Thursday March 11, 2021, in Sacramento, CA.
38. On March 10, 2021, UC-1 contacted MULTANI via WhatsApp at 732-705-0883, and
told MULTANI that the money for the deal will be arriving in his area later that day.
MULTANI responded by saying that it was “here” and “ready.” Investigators believe that
MULTANI was referring to the location of the cocaine and that MULTANI was advising
UC-1 that he was in possession of the cocaine in Sacramento, CA.
39. On March 11, 2021, in anticipation of a drug buy with MULTANI, surveillance was
established at 2393 Alta Garden Lane, Sacramento, CA, which was previously identified
as an address associated to Ranvir SINGH, Parampreet SINGH and MULTANI.
Surveillance members observed MULTANI’s vehicle, a blue Volkswagen SUV with
California plate 8SSC112 (Target Vehicle 3), parked in front of the condominium at 2393
Alta Garden. Subsequently, surveillance members observed MULTANI driving Target
Vehicle 3 away from the condominium until the vehicle was out of sight. Sometime later,
the geo-location data for 209-500-0001 (Parampreet SINGH) and MULTANI’s cell phone
(732-705-0883) revealed that both devices were in the approximate area of 847 Harbor
Boulevard (Target Location 4), the location of the Chevron gas station owned by
Parampreet SINGH. Earlier in the day, UC-1 contacted Parampreet SINGH at 209-500-
0001. Parampreet SINGH advised UC-1 that the deal was set for 1:00 pm and that
Parampreet SINGH already spoke to MULTANI. The subsequent communications
between UC-1, Parampreet SINGH and MULTANI ultimately facilitated a meeting
between UC-2 and MULTANI, during which UC-2 handed MULTANI $45,890 USD as
payment for approximately 1 kilogram of cocaine, payments for prior cocaine deals in
Canada on January 27 and February 12, 2021, that Parampreet SINGH and MULTANI
had coordinated, and a broker fee meant for Parampreet SINGH. MULTANI appeared at
the initial meet location in his blue Volkswagen SUV (Target Vehicle 3) with a male
passenger who was later identified as Ranvir SINGH. Ranvir SINGH and MULTANI
were then followed to 847 Harbor Blvd, West Sacramento, CA (Target Location 4),
which is the Chevron gas station owned by Parampreet SINGH. Investigators observed
Ranvir SINGH and MULTANI exit Target Vehicle 3 and enter the gas station
convenience store at Target Location 4. Then investigators observed Ranvir SINGH and
MULTANI exit the gas station (Target Location 4) and enter Target Vehicle 3.
Surveillance members observed MULTANI was in possession of a green plastic bag that
appeared weighed down as he entered Target Vehicle 3. Ranvir SINGH and MULTANI
were then followed back into the area of the initial meet with UC-2. At this time UC-1,
who was coordinating the meet directly with MULTANI, told MULTANI that the meet
location was changed to the Cheesecake Factory restaurant located at 1771 Arden Way.
The surveillance team then lost visual of Target Vehicle 3 for approximately 15-20
minutes as the vehicle made several quick stops and direction changes which surveillance
members identified as counter-surveillance. This tactic is used by many subjects involved
in the trafficking of narcotics to attempt to increase the difficulty for law enforcement to
maintain visual of a target vehicle while in transit. During the break in visual surveillance,
MULTANI’s phone pinged in the vicinity of the nearby condominium at 2393 Alta
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Garden Lane. Soon thereafter, an unknown grey Toyota Corolla parked next to UC-2’s
vehicle in the parking lot of the Cheesecake Factory. UC-2 then exited his vehicle and
walked up to the passenger side window of the Toyota Corolla and identified the driver of
the vehicle as Ranvir SINGH and the passenger as MULTANI. MULTANI then handed
UC-2 a green plastic bag which contained approximately 1 kilogram of suspected cocaine.
Investigators administered a presumptive test on a sample of the white powdery substance
that was contained in the green plastic bag which tested positive for Cocaine HCL. The
green plastic bag appeared to be same as the green plastic bag that MULTANI carried as
he and Ranvir SINGH left the Chevron gas station at 847 Harbor Blvd (Target Location
4).
Additional Information Regarding Target Location 2
40. On March 25, 2021, at approximately 10:15 a.m., investigators observed a white
Toyota sedan bearing CA license plate 7NTH692 (2015 Toyota, valid, r/o Ranvir SINGH
at 1710 Baines Ave., Sacramento, CA) parked in the driveway of the residence located at
1710 Baines Ave., Sacramento, CA. At the same approximate time, investigators observed
a white Mercedes SUV bearing CA license plate PB711 (2016 Mercedes, valid, r/o Sarbjit
SINGH at 1710 Baines Ave., Sacramento, CA) (Target Vehicle 5) parked on Blackrock
Dr., east of the residence. 1710 Baines Ave., Sacramento, CA is located on the northwest
corner of the intersection of Baines Ave. and Blackrock Dr.
Surveillance of MULTANI at 2209 Stansfield Drive, Roseville, California (Target

Location 3)
41. On March 31, 2021, static surveillance was established at the intersection of Pleasant
Grove Blvd and Monument Drive. Subsequently, surveillance observed a blue
Volkswagen SUV with California license plate 8SSC112, (Target Vehicle 3) travel
westbound from that intersection. Investigators followed the vehicle as it made a right
turn on Somerton Court and lost visual. Upon canvassing the immediate neighborhood,
investigators reacquired Target Vehicle 3, which was parked in the driveway of 2209
Stansfield Drive, Roseville, California (Target Location 3). SA Josh Matas drove past
the residence as the driver of the vehicle, who he positively identified as Amandeep
MULTANI, exited the driver’s door of Target Vehicle 3 while the garage door
immediately in front of Target Vehicle 3 was observed open. At the same approximate
time, location data for cellular telephone 732-705-0883, used by MULTANI, showed that
the cellular telephone was located within a radius that includes Target Location 3.
Analysis of historical location data for MULTANI’s cellular telephone revealed that
MULTANI frequented an area within the radius that includes Target Location 3 and that
MULTANI would remain there overnight.
42. On April 5, 2021, at approximately 7:19 am, surveillance was conducted of Target
Location 3. Investigators observed Target Vehicle 3 parked in the driveway facing the
garage door. At the same time, location data for MULTANI’s cellular telephone was
located within a radius that includes Target Location 3. At approximately 9:01 am,
Target Vehicle 3 was not observed in the driveway of the residence and the location data
12
for MULTANI’s phone showed that the cellular telephone was located away from Target
Location 3. Sometime later, investigators observed Target Vehicle 3 parked in the
driveway facing an opened garage door and the location data for MULTANI’s phone
showed that the cellular telephone was again located within the radius that includes
Target Location 3.
Intelligence Regarding Phone Subscriber and Thomson Reuter CLEAR Checks
43. Inquiries in March 2021 with Verizon revealed that cellular telephone number 209-
500-0001, used by Parampreet SINGH, was an active phone number with Verizon as of
August 21, 2017. The account is subscribed in the name of Ranvir SINGH with a listed
contact name of Parampreet SINGH. The subscriber address is listed as PO Box 348090,
Sacramento, California. Further database checks in March 2021, utilizing the Thomson
Reuters CLEAR database, revealed that Parampreet SINGH maintains a listed address of
3001 Goshawk Street, Davis, CA 95616 (Target Location 1).
44. Inquiries in March 2021 with T-Mobile revealed that cellular telephone number 732-
705-0883, used by MULTANI, was an active phone number with T-Mobile as of July 8,
2020. The account is subscribed in the name of Manjit Muleani. The subscriber address
is listed as 7871 Mission Grove Parkway, Apt 115, Riverside, CA. Further database
checks in March 2021, utilizing the Thomson Reuters CLEAR database revealed that
Amandeep MULTANI maintains a listed address of 7871 Mission Grove Parkway, Apt
115, Riverside, CA.
45. Inquiries in March 2021 with Verizon revealed that cellular telephone number 253-
205-6137, used by Ranvir SINGH, was an active phone number with Verizon as of
December 1, 2013. The account is subscribed in the name of Ranvir SINGH. The
subscriber address is listed as PO Box 348090, Sacramento, California. This phone
number has the same subscriber name and address as telephone number 209-500-0001,
used by Parampreet SINGH. Further database checks in March 2021, utilizing the
Thomson Reuters CLEAR database revealed that Ranvir SINGH maintains a listed
address of 1710 Baines Avenue, Sacramento, CA (Target Location 2).
Intelligence Regarding Toll Analysis
46. In March 2021, investigators conducted toll analysis of Parampreet SINGH, Ranvir
SINGH and Amandeep MULTANI’s identified phone numbers: 209-500-0001, 253-205-
6137 and 732-705-0883, respectively. Investigators have found that all three phone
numbers have maintained contact from November 5, 2020 to March 17, 2021.
Information Regarding Businesses Associated to Parampreet SINGH, Ranvir SINGH and

MULTANI
47. Investigators searched Articles of Incorporation of a General Stock Corporation

(hereinafter AOI) filed with the Secretary of State, State of California, to identify MIRI
PIRI TRANSPORTATION, INC. (California corporation number C3684728). The AOI,
13
filed on June 12, 2014 that corresponds to MIRI PIRI TRANSPORTATION, INC.,
identified Parampreet SINGH as the Incorporator and Agent for Service of Process. The
AOI lists 2701 Del Paso Rd., Suite 294, Sacramento, CA as the corporate address. A
Statement of Information (hereinafter SOI) filed on October 5, 2017, lists Parampreet
SINGH as the only person associated with the corporation (identified as CEO, Secretary,
CFO, Director and Agent for Service of Process) and lists 4800 Kokomo Dr., Unit 3414,
as an address associated with the corporation. An AOI filed on January 24, 2020, lists
4800 Kokomo Dr., Unit 3414 as the street address of the principal executive and business
offices. However, the same AOI lists Ranvir SINGH, 1710 Baines Ave., Sacramento, CA
as the CEO, Secretary, CFO and Agent for Service of Process. The documents identify
MIRI PIRI TRANSPORTATION, INC. as a “transportation” or “transportation services”
business. A SAFFER Web Company Snapshot links MIRI PIRI TRANSPORTATION,
INC to physical address 2393 Alta Garden Lane, Sacramento, CA and phone number 916-
900-8243. An open source query revealed 916-900-8243 is used as the contact
information for MIRI PIRI TRANSPORTATION INC. and lists 4800 Kokomo Drive,
Sacramento, California as the location of the business.
48. Investigators searched public databases and identified the business 5AAB EXPRESS
LLC linked to 2393 Alta Garden Lane, Sacramento, CA. Public databases provide
California Corporation Number 202032410826 for 5AAB EXPRESS LLC. A SAFER
Web Company Snapshot links 5AAB EXPRESS LLC to physical address 2393 Alta
Garden Lane, Sacramento, CA; telephone number 732-705-0883; USDOT number
3529978 and State Carrier ID Number MC-1174828. Investigators identified 732-705-
0883 as a cellular telephone number used by Amandeep MULTANI. An AOI for a LLC
Registration with the Secretary of State, State of California, identify 5AAB EXPRESS
LLC (Entity Number 202032410826). The AOI, filed on November 17, 2020, identify
Manjit MULTANI as the Organizer of 5AAB EXPRESS LLC and the Agent for Service
of Process. The AOI lists 2393 Alta Garden Lane, Sacramento, CA as the street and
mailing address for 5AAB EXPRESS LLC. The AOI filed on December 3, 2020, lists
Manjit Singh MULTANI as the only person associated with the corporation (identified as
CEO, Manager, Member and Agent for Service of Process). The AOI further identifies
5AAB EXPRESS LLC as a “transportation” business. In January 2020, Canadian
investigators provided information regarding a January 2021 social media posting in
which Parampreet SINGH congratulated Amandeep MULTANI for opening a trucking
business.
Training and Experience Regarding Drug Trafficking and Drug Traffickers
49. As a result of my experience and training, I have learned that traffickers who deal in
various quantities of controlled substances, or those that assist in that venture, maintain
and tend to retain accounts or records of those transactions. Such records detail amounts
outstanding, owed, or expended, along with records tending to indicate the identity of co-
conspirators. These records may be kept on paper or contained in memory calculators or
computers. It is also my experience that these traffickers tend to keep these accounts and
records in their residence and in the areas under their control. It is my training and
experience, that in the case of drug dealers, evidence is likely to be found where the
14
dealers live. United States v. Angulo-Lopez, 791 F.2d 1394, 1399 (9th Cir. 1986). It is
also my training and experience that where criminal activity is long-term or ongoing,
equipment and records of the crime will be kept for some period of time. United States v.
Greany, 929 F.2d 523, 525 (9th Cir. 1991).
50. Based upon my experience and training, I have learned that drug traffickers often
place their assets in names other than their own to avoid detection of those assets by law
enforcement and the Internal Revenue Service (IRS); that those persons are commonly
family members, friends, and associates who accept title of assets to avoid discovery and
detection; that traffickers also often place assets in the ownership of corporate entities to
avoid detection by law enforcement agencies and although these assets are in other
individual(s) or corporate names, the traffickers continue to use these assets and exercise
dominion and control over them. Typically, drug traffickers keep records of those
registrations and transactions in their residence.
51. I have learned that large-scale drug traffickers often have on hand large amounts of
United States currency in order to maintain and finance their ongoing business. It has
been my experience that drug traffickers often keep large sums of currency, caches of
drugs, financial instruments, precious metals, jewelry, automobiles and other items of
value and/or proceeds of drug transactions, including evidence of financial transactions
related to obtaining, transferring, secreting or spending large sums of money acquired
from engaging in the acquisition and distribution of controlled substances in their
residence or in the areas under their control.
52. In my experience, traffickers commonly have in their possession, that is, on their
person, at their residence and in the areas under their control, firearms, including but not
limited to handguns, pistols, revolvers, rifles, shotguns, machine guns and other weapons.
Such firearms are used by drug violators to protect their illicit drug trafficking operations,
and themselves against law enforcement and other drug violators because the illicit drug
trade is an inherently dangerous illegal activity involving large amounts of valuable
contraband and drug proceeds. Such property may include, but is not limited to, narcotics
and other dangerous drugs, jewelry, narcotic paraphernalia, books, records, ledgers and
quantities of currency.
53. In my experience, traffickers commonly have in their possession, that is on their

person, at their residences, and their vehicles, and in the areas under their control and
which they have free and ready access to, drugs, including but not limited to in this case,
cocaine, heroin, opium, and ketamine, which they intend to distribute. It is my experience
that drug traffickers commonly utilize these areas (vehicles, residences, properties, etc.) as
locations to conceal their narcotics from law enforcement.
54. In my experience, drug traffickers may take or cause to be taken, photographs or

videotapes of themselves, their associates, their property, and their product. Such
traffickers often maintain photographs and/or videotapes at their residence or in the areas
under their control.
15
55. In my experience, large scale traffickers often maintain in their possession and at their
residence fictitious identification, including but not limited to, driver’s licenses,
employment cards, insurance cards, social security cards, certificates of birth and
passports which are obtained by the traffickers and utilized in an effort to prevent law
enforcement identification of the traffickers and their drug trafficking activities.
56. In my experience, drug traffickers often utilize vehicles in which to transport and
distribute controlled substances in facilitation of their trafficking activities. It has also
been my experience that traffickers will also utilize vehicles as locations in which to store
controlled substances prior to distribution. During prior investigations, I have observed
that drug traffickers will often utilize vehicles registered in the names of individuals other
than themselves in an effort to avoid detection by law enforcement.
57. In addition, these traffickers tend to attempt to legitimize their assets by establishing
domestic and foreign businesses, by creating shell corporations, by utilizing bank haven
countries and attorneys specializing in drafting and establishing such entities employed to
“launder” the proceeds derived from the distribution of controlled substances.
58. In establishing these entities, the traffickers sometimes must travel to meetings in
foreign countries as well as domestically. As a result of that travel, records are generated
reflecting travel by commercial and private aircraft, Commercial Ocean and private
vessels as well as common carrier(s).
59. Individuals involved in the distribution of cocaine, heroin, and other illegal drugs often
make, or cause to be made, pictures, videos, movies, compact discs, floppy discs, or other
such items which are or contain photographic or digital images in order to memorialize
their narcotics distribution, use, possession, or any other activities surrounding their drug
trafficking activities, and that such items often identify co-conspirators in their drug
trafficking activities.
60. It has been my experience in the past, and particularly in this case, that when suspects
utilize mobile telephones to communicate with cooperating individuals or undercover
agents to set up drug deals, records relating to these activities will be found stored in the
cellular telephone.
61. I know that narcotics traffickers use mobile telephones to communicate with one
another, either by voice or text message. Mobile telephones preserve in their memory a
history of incoming, outgoing, and missed calls, which can lead to evidence of the
telephone numbers of other narcotics traffickers and the dates and times that they and/or
the mobile telephone user dialed one another’s telephones. Mobile telephones also
contain in their memory a telephone book. This allows the user to store telephone
numbers and other contact information; the information stored in a telephone used by a
narcotics trafficker is evidence of the associations of the narcotics trafficker, some of
which are related to his or her illegal business. Mobile telephones also contain in their
memory text messages sent, received, and drafted by the mobile telephone user. The text
message history of a narcotics trafficker’s mobile telephone can contain evidence of
16
narcotics trafficking because it shows the communications or planned communications of

a narcotics trafficker and the telephone numbers of those with whom the narcotics
trafficker communicated or intended to communicate. Mobile telephones also have a
voicemail function that allows callers to leave messages when the telephone user does not
answer. Narcotics traffickers sometimes leave voice messages for each other and this is
evidence both of their mutual association and possibly their joint criminal activity.
Mobile telephones can also contain other user-entered data files such as “to-do” lists,
which can provide evidence of crime when used by a narcotics trafficker. Mobile
telephones can also contain photographic data files, which can be evidence of criminal
activity when the user was a narcotics trafficker who took pictures of evidence of crime.
Mobile telephone companies also store the data described in this paragraph on their own
servers and associate the data with particular users’ mobile telephones.
62. From my training and experience, I know that individuals that drug traffickers also
frequently use computers and other electronic media to conduct their trade and to keep
track of drug inventories, proceeds, and debts. This information can be found in electronic
records that might take the form of files, documents, and other data that is user-generated.
Some of these electronic records, as explained below, might take a form that becomes
meaningful only upon forensic analysis.
63. As further described in Attachment B, this application seeks permission to locate not
only computer files that might serve as direct evidence of the crimes described on the
warrant, but also for evidence that establishes how computers were used, the purpose of
their use, who used them, and when.
64. Thus, the forensic analyst needs all assisting software (operating systems or
interfaces, and hardware drivers) and any applications software, which may have been
used to create the data (whether stored on hard drives or on external media), as well as all
related instructional manuals or other documentation and security devices. Moreover,
searching computerized information for evidence or instrumentalities of crime commonly
requires the seizure of the entire computer’s input/output periphery devices (including
related documentation, passwords and security devices) so that a qualified expert can
accurately retrieve the system’s data in a controlled environment.
65. In cases of this sort, laptop computers and/or smartphones are also used as
instrumentalities of the crime to commit offenses involving interstate drug sales and
movement of drug proceeds. Devices such as modems and routers can contain information
about dates, frequency, and computer(s) used to access the Internet. The laptop or smart
phone may also have fingerprints on them indicating the user of the computer and its
components.
66. Similarly, files related to the purchasing and selling of controlled substances, as well
as, the movement of currency found on computers and other digital communications
devices are usually obtained from the Internet or the cellular data networks using
application software which often leaves files, logs or file remnants which would tend to
show the identity of the person engaging in the conduct as well as the method of location
17
or creation of the data, search terms used, exchange, transfer, distribution, possession or
origin of the files. Files that have been viewed via the Internet are sometimes
automatically downloaded into a temporary internet directory or “cache”. The browser
often maintains a fixed amount of hard drive space devoted to these files, and the files are
only overwritten as they are replaced with more recently viewed internet pages or if a user
takes steps to delete them. Thus, the ability to retrieve residue of an electronic file from a
hard drive depends less on when the file was downloaded or viewed than on a particular
user’s operating system, storage capacity, and computer habits.
67. “User attribution” evidence can also be found on a computer and is analogous to the
search for “indicia of occupancy” while executing a search warrant at a residence. For
example, registry information, configuration files, user profiles, e-mail, e-mail address
books, “chat,” instant messaging logs, photographs, and correspondence (and the data
associated with the foregoing, such as file creation and last accessed dates) may be
evidence of who used or controlled the computer or storage medium at a relevant time.
Your affiant knows from training and experience that digital software or hardware exists
that allows persons to share digital access over wired or wireless networks allowing
multiple persons to appear on the Internet from the same IP address. Examination of these
items can reveal information about the authorized or unauthorized use of internet
connection at the residence.
68. Searching the computer(s) for the evidence described in the attachment may require a
range of data analysis techniques. For example, information regarding user attribution or
internet use is located in various operating system log files that are not easily located or
reviewed. In addition, a person engaged in criminal activity will attempt to conceal
evidence of the activity by “hiding” files or giving them deceptive names. As explained
above, because the warrant calls for records of how a computer has been used, what it has
been used for, and who has used it, it is exceedingly likely that it will be necessary to
thoroughly search storage media to obtain evidence, including evidence that is not neatly
organized into files or documents. Just as a search of a premises for physical objects
requires searching the entire premises for those objects that are described by a warrant, a
search of this location (the computer) for the things described in this warrant will likely
require a search among the data stored in storage media for the things (including
electronic data) called for by this warrant. Additionally, it is possible that files have been
deleted or edited, but that remnants of older versions are in unallocated space or slack
space. This, too, makes it exceedingly likely that in this case it will be necessary to use
more thorough techniques.
69. Based upon knowledge, training and experience, your affiant knows that a thorough
search for information stored in storage media often requires agents to seize most or all
storage media to be searched later in a controlled environment. This is often necessary to
ensure the accuracy and completeness of data recorded on the storage media, and to
prevent the loss of the data either from accidental or intentional destruction. Additionally,
to properly examine the storage media in a controlled environment, it is often necessary
that some computer equipment, peripherals, instructions, and software be seized and
examined in the controlled environment. This is true because of the following:
18
a. The nature of evidence: As noted above, not all evidence takes the form of
documents and files that can be easily viewed on-site. Analyzing evidence of how
a computer has been used, what it has been used for, and who has used it requires
considerable time, and taking that much time on premises could be unreasonable.
Also, because computer evidence is extremely vulnerable to tampering and
destruction (both from external sources and from code embedded in the system as
a “booby-trap”), the controlled environment of a laboratory is essential to its
complete and accurate analysis.
b. The volume of evidence and time required for an examination: Storage media
can store the equivalent of millions of pages of information. Additionally, a
suspect may try to conceal criminal evidence; he or she might store it in random
order with deceptive file names. This may require searching authorities to peruse
all the stored data to determine which particular files are evidence or
instrumentalities of crime. Analyzing evidence of how a computer has been used,
what it has been used for, and who has used it requires considerable time, and
taking that much time on premises could be unreasonable. As explained above,
because the warrant calls for forensic electronic evidence, it is exceedingly likely
that it will be necessary to thoroughly examine storage media to obtain evidence.
Reviewing information for things described in the warrant can take weeks or
months, depending on the volume of data stored, and would be impractical and
invasive to attempt on-site.
c. Technical requirements: Computers can be configured in several different

ways, featuring a variety of different operating systems, application software, and
configurations. Therefore, searching them sometimes requires tools or knowledge
that might not be present on the search site. The vast array of computer hardware
and software available makes it difficult to know before a search what tools or
knowledge will be required to analyze the system and its data on-site. However,
taking the storage media off- site and reviewing it in a controlled environment
will allow its examination with the proper tools and knowledge.
d. Variety of forms of electronic media: Records sought under this warrant could
be stored in a variety of storage media formats that may require off-site reviewing
with specialized forensic tools.
70. Based on the foregoing, and consistent with Rule 41(e)(2)(B), when persons
executing the warrant conclude that it would be impractical to review the media on-site,
the warrant I am applying for would permit seizing or imaging storage media that
reasonably appear to contain some or all of the evidence described in the warrant, thus
permitting its later examination consistent with the warrant. The examination may require
techniques, including but not limited to, computer-assisted scans of the entire medium that
might expose many parts of a hard drive to human inspection in order to determine
whether it is evidence described by the warrant.
19
71. As described above and in Attachments A-1 through A-9, and Attachment B, this
Affidavit seeks permission to search and seize things that are related to the cocaine,
heroin, ketamine and opium trafficking conspiracy between Parampreet SINGH,
Amandeep MULTANI and Ranvir SINGH, in whatever form such things are stored.
Based on my knowledge, training, and experience, I know that electronic devices can store
information for long periods of time. Even when a user deletes information from a device,
it can sometimes be recovered with forensics tools. Similarly, things that have been
viewed via the Internet are typically stored for some period of time on the device. This
information can sometimes be recovered with forensics tools.
72. It is my opinion, based on my training and experience, and the training and experience
of other law enforcement investigators to whom I have spoken, that the items listed in
Attachment B are items most often associated with the distribution of controlled
substances, including cocaine, heroin, opium, and ketamine, as well as the proceeds from
such illegal operations.
73. The facts set forth in this Affidavit are known to me as a result of my personal
participation in this investigation, through conversations with other agents who have
participated in this investigation, and from reviewing official reports, documents, and
other evidence obtained as a result of this investigation. This Affidavit is not an
exhaustive enumeration of the facts that I have learned during the course of this
investigation but, instead, are facts that I believe support a finding of probable cause to
search the requested locations.
74. Based on my experience and training, and after consulting with other law enforcement
officers experienced in drug investigations, I know that individuals involved in drug
dealing often maintain at their residences, vehicles, and their persons the items described
in Attachment B. Individuals involved in drug dealing also often maintain paraphernalia
for packaging, weighing, cutting, testing, distributing, and identifying controlled
substances. Therefore, I am requesting authority to seize all the items listed in Attachment
B to this Affidavit and incorporated here by reference.
75. REQUEST FOR SEALING: I further request that the Court order that all
papers in support of this application, including the affidavit and search warrant, be sealed
until further order of the Court. These documents discuss an ongoing criminal
investigation that is neither public nor known to all of the targets of the investigation.
Accordingly, there is good cause to seal these documents because their premature
disclosure may seriously jeopardize that investigation.
Fazit
76. Based on the information described above and the totality of the information gathered
during the investigation, there is probable cause to believe that Parampreet SINGH,
Amandeep MULTANI, and Ranvir SINGH have, between at least August 25, 2020 and
the present, conspired with one another and others to distribute and possess with intent to
distribute cocaine, heroin, opium and ketamine from Sacramento, California and
20
elsewhere. Further, there is probable cause to believe that the execution of search
warrants at Target Locations 1-4 and Target Vehicles 1-5 would generate evidence of
crimes in violation of 21 U.S.C §§ 846 and 841.
I swear under penalty of perjury, that the foregoing information is true and correct to the
best of my knowledge, information and belief.
/s/
____________________________
Joshua Matas
Special Agent
Drug Enforcement Administration
Sworn to and subscribed to me telephonically on April __,

7 2021. at 8:01 am
____________________________
Hon. Carolyn K. Delaney
United States Magistrate Judge
Approved as to form:
__/s/David Spencer______________
David W. Spencer
Assistant United States Attorney
21
Attachment A-1
Search Warrant Site
3001 Goshawk Street, Davis, California
A. TARGET LOCATION 1 – The premises to be searched are located at 3001 Goshawk

Street, Davis, California. The residence is a single family, white, two story residence with the
numbers “3001” prominently displayed in black lettering on the residence south of the front
door. The residence is located on the northwest corner of the intersection of Goshawk St. and
Falcon Ave., Davis, CA. The front door of the residence faces Goshawk St., and the driveway
and garage doors (three car attached garage) of the residence face Falcon Avenue. A photo of the
premises to be searched is below.
B. The place to be searched includes the residence, all rooms, attics, basements, and storage
areas; all trash receptacles; and all surrounding grounds, garages, storage rooms, or outbuildings
of any kind, attached or unattached, located on the premises.
Attachment A-2
Search Warrant Site
1710 Baines Avenue, Sacramento, California
A. TARGET LOCATION 2 – The premises to be searched are located at 1710 Baines

Avenue, Sacramento, California. The residence is a standalone single family
residence displaying numbers "1710" next to the garage door entrance. The residence is located
on the southwest corner of the intersection of Baines Avenue and Blackrock Drive. A photo of
the premises to be searched is below.
Attachment A-3
Search Warrant Site
2209 Stansfield Drive, Roseville, California 95747
A. TARGET LOCATION 3 – The premises to be searched are located at 2209 Stansfield

Drive, Roseville, California 95747. The residence is a standalone single family residence
displaying numbers “2209” over the left corner of the garage entrance. The residence is located
directly south of the intersection of Kersey Court and Stansfield Drive. A photo of the residence
is provided below.
Attachment A-4
Search Warrant Site
847 Harbor Boulevard, West Sacramento, California
A. TARGET LOCATION 4 – The premises to be searched are located at 847 Harbor
Boulevard, West Sacramento, California. The commercial property is a Chevron Extra Mile
gas station displaying numbers "847" over the front entrance in white lettering. The commercial
property is located on the northeast corner of the intersection of Harbor Blvd and Evergreen
Ave., West Sacramento, CA. Photographs of the premises to be searched are below.
B. The place to be searched includes the convenience store, all rooms, attics, basements,
offices, and storage areas; all trash receptacles; and all surrounding grounds, garages, storage
rooms, or outbuildings of any kind, attached or unattached, located on the premises.
Attachment A-5
A. TARGET VEHICLE 1 - 2003 HUMMER SUV, Maroon with CA license #PJB37
Registered to Parampreet SINGH at 847 Harbor Boulevard, West Sacramento, California.
B. The search of TARGET VEHICLE 1 is to include all internal and external compartments
and all containers that may be associated with the storage of controlled substances, proceeds of
controlled substances sales, digital media, or their instrumentalities. A photo of the vehicle is
below.
Attachment A-6
A. TARGET VEHICLE 2 - 2019 AUDI sedan, Blue with CA license #SLOWA5

registered to Parampreet SINGH at 847 Harbor Boulevard, West Sacramento, California. The
search of TARGET VEHICLE 2 is to include all internal and external compartments and all
containers that may be associated with the storage of controlled substances, proceeds of
controlled substances sales, digital media, or their instrumentalities. A photo of the vehicle is
below.
Attachment A-7
A. TARGET VEHICLE 3 - 2015 Volkswagen SUV, Blue with CA license #8SSC112

Registered to Manit MULTANI at 7871 Mission Grove Parkway S, Apt 115, Riverside,
California.
B. The search of the TARGET VEHICLE 3 is to include all internal and external
compartments and all containers that may be associated with the storage of controlled
substances, proceeds of controlled substances sales, digital media, or their instrumentalities. A
photo of the vehicle is below.
Attachement A-8
A. TARGET VEHICLE 4 - 2015 Toyota sedan, White with CA license #7NTH692

registered to Ranvir SINGH at 1710 Baines Avenue, Sacramento, California. The search of
TARGET VEHICLE 4 is to include all internal and external compartments and all containers
that may be associated with the storage of firearms or firearms parts, proceeds of firearms sales,
digital media, or their instrumentalities. A photo of the vehicle is below.
substances, proceeds of controlled substances sales, digital media, or their instrumentalities. A
photo of the vehicle is below
Attachment A-9
A. TARGET VEHICLE 5 - 2016 Mercedes SUV, White with CA license #PB711

registered to Sarbjit SINGH at 1710 Baines Avenue, Sacramento, California. The search of
TARGET VEHICLE 5 is to include all internal and external compartments and all containers
that may be associated with the storage of firearms or firearms parts, proceeds of firearms sales,
digital media, or their instrumentalities. A photo of the vehicle is below.
substances, proceeds of controlled substances sales, digital media, or their instrumentalities.
Attachment B
Items to be seized
Law enforcement is authorized to search and seize property that constitutes evidence, fruits, and
instrumentalities of violations of the following federal statutes (the “Target Offenses”):
• 21 U.S.C. §§ 841(a)(1) and 846 – Conspiracy to distribute and possess with intent
to distribute cocaine, opium, heroin and ketamine.
• 21 U.S.C. § 841(a)(1) – Distribution and possession with intent to distribute
cocaine, opium, heroin and ketamine.
As further described in the Affidavit, the specific evidence, fruits, and instrumentalities of the
Target Offenses for which agents may search includes:
1. Controlled substances, including heroin, opium, cocaine, and ketamine, or items used to
distribute controlled substances; drug-trafficking paraphernalia, including scales, measuring
devices, and weighing devices; narcotics diluting or cutting agents; narcotics packaging
materials, including plastic, tin foil, cellophane, jars, plastic bags, and containers; and plastic
surgical gloves;
2. United States and foreign currency linked to drug trafficking and/or the proceeds of drug
trafficking, including the pre-recorded U.S. currency used to purchase cocaine, opium, heroin
and ketamine during this investigation;
3. Narcotics or money ledgers, narcotics distribution or customer lists, narcotics supplier lists,
correspondence, notations, logs, receipts, journals, books, pay and owe sheets, records and other
documents noting the price, quantity, date and/or times when narcotics were purchased,
possessed, transferred, distributed, sold or concealed;
4. Telephone paging devices, beepers, mobile phones, car phones, answering machines and
tapes, and other communication devices which could be used to participate in a conspiracy to
distribute controlled substances in violation of 21 U.S.C. § 841(a)(1);
5. Bank account records, wire transfer records, bank statements, safety deposit keys and records,
money wrappers, money containers, income tax returns, evidence of financial transfer, or
movement of money generated from the sale of narcotics;
6. Personal telephone books, address books and other such address listings, letters, cables,
telegrams, telephone bills, photographs, audio and video tapes connected to drug trafficking,
personal notes and other items reflecting names, addresses, telephone numbers, communications,
and illegal activities of associates in drug trafficking activities;
7. Financial instruments purchased with large amounts of currency derived from the sale of
controlled substances, including traveler’s checks, bonds, stock certificates, cashier’s checks and
certificates of deposit; money counting machines, money wrappers and bags used to carry
controlled substances;
8. Records, documents and deeds reflecting the purchase or lease of real estate, vehicles,
precious metals, jewelry, or other items obtained with the proceeds from the sale of controlled
substances;
9. Records, items, and documents reflecting travel, including airline tickets, credit card receipts,
travel vouchers, hotel and restaurant receipts, canceled checks, maps and written directions to
location;
10. Handguns, shotguns, rifles, explosives, and other firearms/incendiary devices and
ammunition that may be used to facilitate the distribution or possession of, with the intent to
distribute controlled substances or discovered in the possession of a prohibited person; and
11. Indicia of occupancy, residency, control or ownership of the premises and things described
in this warrant, including utility bills, telephone bills, loan payment receipts, rent documents,
canceled envelopes and keys, photographs, and bank records.
12. Any digital devices or other electronic storage media and/or their components used as a
means to commit the violations described above, including:
a. any digital device or other electronic storage media capable of being used to commit,
further, or store evidence or fruits of the Target Offenses;
b. any digital devices or other electronic storage media used to facilitate the
transmission, creation, display, encoding or storage of data, including word processing
equipment, modems, docking stations, monitors, cameras, printers, plotters, encryption
devices, and optical scanners;
c. any magnetic, electronic or optical storage device capable of storing data, such as
floppy disks, hard disks, tapes, CD-ROMs, CD-R, CD-RWs, DVDs, optical disks, printer
or memory buffers, smart cards, PC cards, memory calculators, electronic dialers,
electronic notebooks, and personal digital assistants;
d. any documentation, operating logs and reference manuals regarding the operation of
the digital device or other electronic storage media or software;
e. any applications, utility programs, compilers, interpreters, and other software used to
facilitate direct or indirect communication with the computer hardware, storage devices,
or data to be searched;
f. any physical keys, encryption devices, dongles and similar physical items that are
necessary to gain access to the computer equipment, storage devices or data; and
g. any passwords, password files, seed words, test keys, encryption codes or other
information necessary to access the computer equipment, storage devices or data.
13. For any digital device or other electronic storage media upon which electronically stored
information that is called for by this warrant may be contained, or that may contain things
otherwise called for by this warrant:
a. Any and all names, words, telephone numbers, email addresses, time/date information,
messages or other electronic data in the memory of the digital device or other electronic
storage media or on a server and associated with the digital device or electronic storage
media, including:
i. Incoming call history;

ii. Outgoing call history;
iii. Missed call history;
iv. Outgoing text messages;
v. Incoming text messages;
vi. Draft text messages;
vii. Telephone book;
viii. Emails;
ix. Data screen or file identifying the telephone number associated with the
mobile telephone searched;
x. Data screen, file, or writing containing serial numbers or other information to
identify the electronic device searched;
xi. Voicemail;
xii. User-entered messages (such as to-do lists); and
xiii. Stored media such as photographs or video.
b. Any and all locations, addresses, GPS coordinates, names, time/date information, or
other electronic data related to addresses and driving directions.
c. All information and records related to violations of 21 U.S.C. § 841(a) (drug

trafficking) and/or 21 U.S.C. § 846 (conspiracy to traffic drugs), including but not limited
to:
i. Data and information related to stored applications and/or websites used to

communicate with associates and co-conspirators;
ii. Data, information, or documents related to the manufacture of controlled

substances, including the acquisition, possession, and use of equipment,
paraphernalia, chemicals, and materials used in the manufacturing process;
iii. lists of customers and related identifying information;
iv. types, amounts, and prices of drugs trafficked as well as dates, places, and
amounts of specific transactions;
v. any information related to sources of drugs or drug manufacturing materials

and equipment (including names, addresses, phone numbers, email addresses, or
any other identifying information);
vi. any information recording schedule or travel;
vii. all bank records, checks, credit card bills, account information, and other
financial records;
viii. data, information, or documents related to the receipt of proceeds from

controlled substances distribution and the transfer, investment, control, and
disposition of those proceeds;
ix. records of Internet Protocol addresses used;
x. records of Internet activity, including firewall logs, caches, browser history and
cookies, “bookmarked” or “favorite” web pages, search terms that the user
entered into any Internet search engine, and records of user-typed web addresses;
xi. any communications related to drug trafficking;
xii. Stored media such as photographs or video.
d. evidence of who used, owned, or controlled the digital device or other electronic
storage media at the time the things described in this warrant were created, edited, or
deleted, such as logs, registry entries, configuration files, saved usernames and
passwords, documents, browsing history, user profiles, email, email contacts, "chat,"
instant messaging logs, photographs, and correspondence;
e. evidence of software that would allow others to control the digital device or other
electronic storage media, such as viruses, Trojan horses, and other forms of malicious
software, as well as evidence of the presence or absence of security software designed to
detect malicious software;
f. evidence of the lack of such malicious software;
g. evidence of the attachment to the digital device of other storage devices or similar
containers for electronic evidence;
h. evidence of counter-forensic programs (and associated data) that are designed to

eliminate data from the digital device or other electronic storage media;
i. evidence of the times the digital device or other electronic storage media was used;
j. passwords, encryption keys, seed words, and other access devices that may be
necessary to access the digital device or other electronic storage media;
k. documentation and manuals that may be necessary to access the digital device or other
electronic storage media or to conduct a forensic examination of the digital device or
other electronic storage media;
l. Contextual information necessary to understand the evidence described in this

attachment.
14. Records and things evidencing the use of an Internet Protocol (IP) address to communicate
with the internet, including:
a. routers, modems, and network equipment used to connect computers to the internet;
b. records of Internet Protocol addresses used;
c. Records of internet activity, including firewall logs, caches, browser history and
cookies, “bookmarked” or “favorite” web pages, search terms that the user entered into
any internet search engine, and records of user-typed web addresses.
As used above, the terms “records” and “information” include all of the foregoing items of
evidence in whatever form and by whatever means they may have been created or stored,
including any form of computer or electronic storage (such as flash memory or other media that
can store data) and any photographic form.
THE SEIZURE OF DIGITAL DEVICES OR OTHER ELECTRONIC STORAGE MEDIA

AND/OR THEIR COMPONENTS AS SET FORTH HEREIN IS SPECIFICALLY
AUTHORIZED BY THIS SEARCH WARRANT, NOT ONLY TO THE EXTENT THAT
SUCH DIGITAL DEVICES OR OTHER ELECTRONIC STORAGE MEDIA CONSTITUTE
INSTRUMENTALITIES OF THE CRIMINAL ACTIVITY DESCRIBED ABOVE, BUT ALSO
FOR THE PURPOSE OF CONDUCTING OFF-SITE EXAMINATIONS OF THEIR
CONTENTS FOR EVIDENCE, INSTRUMENTALITIES, OR FRUITS OF THE
AFOREMENTIONED CRIME.

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Case 2:21-mj-00056-CKD Document 1 Filed 04/07/21 Page 1 of 36

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

United States of America )

Eastern District of California , the defendant(s) violated:

This criminal complaint is based on these facts:

☒ Continued on the attached sheet.

DEA Special Agent Joshua Matas

Sworn to me and signed telephonically.

Date: April 7, 2021 at 8:01 am

AFFIDAVIT IN SUPPORT OF SEARCH WARRANTS AND CRIMINAL COMPLAINT

I, Joshua Matas, being duly sworn, depose and state as follows:

Background and Expertise

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

3. During the course of my employment as a DEA Special Agent, I have participated in

4. Through my training, experience, and interaction with other experienced Special

methods employed by drug traffickers to smuggle, safeguard, store, transport, and

Scope of Requested Search Warrants

a. The residence located at 3001 Goshawk Street, Davis, California (“Target

b. The residence located at 1710 Baines Avenue, Sacramento, California (“Target

c. The residence located at 2209 Stansfield Drive, Roseville, California(“Target

d. The commercial property located at 847 Harbor Boulevard, West Sacramento,

e. The following vehicles:

1. 2003 HUMMER SUV, Maroon with CA license #PJB37 (“Target

2. 2019 AUDI sedan, Blue with CA license #SLOWA5 (“Target

a. Registered to Parampreet SINGH at 847 Harbor Boulevard, West

3. 2015 Volkswagen SUV, Blue with CA license #8SSC112 (“Target

4. 2015 Toyota sedan, White with CA license #7NTH692 (“Target Vehicle

5. 2016 Mercedes SUV, White with CA license #PB711 (“Target

7. I request authority to search Target Locations 1, 2, 3 & 4 and Target Vehicles 1, 2,

Scope of Requested Criminal Complaint

COUNT ONE – Conspiracy to Distribute and Possess with Intent to Distribute at

violation of 21 U.S.C. §§ 841(a)(1) and 846 (August 25, 2020

COUNT TWO – Distribution of at Least 500 Grams of a Mixture and Substance

Statement of Probable Cause

Introduction of UC-1 to Parampreet SINGH in August 2020

Controlled Purchase of approximately 1 kilogram of Ketamine in Brampton, Canada, on

Surveillance Regarding Parampreet SINGH and Ranvir SINGH

19. On November 2, 2020, investigators conducted drive-by surveillance of the residence

20. On November 6, 2020, at approximately 4:35 pm investigators conducted drive-by

21. On November 13, 2020, investigators conducted a drive by surveillance at 1710

22. On December 4, 2020, investigators conducted surveillance of Ranvir SINGH at 1710

Controlled Purchase of 1 kilogram of ketamine in Brampton, Canada on November 13, 2020,

23. On November 10-13, UC-1 engaged in numerous communications with Parampreet

Controlled Purchase of 1 kilogram of purported ketamine in Brampton, Canada on December

kilogram of purported ketamine for $33,000 in Brampton, Canada, from a Canada-based

Controlled Purchase of 1 kilogram of Ketamine and sample of Heroin in Canada on

Parampreet SINGH Informs UC-1 He has 100-200 kilograms of Cocaine Available

Controlled Purchase of 1 kilogram of Ketamine in Toronto, Canada, on December 29, 2020,

Controlled Purchases of 1.5 kilograms of Opium in Brampton, Canada, on January 7, 2021,

31. On January 7, 2021, UC-1 purchased approximately 1.5 kilograms of opium in

Controlled Purchase of 1 kilogram of Cocaine in the greater Toronto area, Canada, on

32. On January 27, 2021, UC-1 purchased approximately 1 kilogram of cocaine in

Controlled Purchase of 1 Kilogram of Cocaine in Brampton, Canada, on February 12, 2021,

34. On February 12, 2021, UC-1 purchased approximately 1 kilogram of cocaine in

Surveillance Regarding MULTANI and Parampreet SINGH

Controlled Purchase of 1 kilogram of cocaine coordinated by Parampreet SINGH and

Additional Information Regarding Target Location 2

Surveillance of MULTANI at 2209 Stansfield Drive, Roseville, California (Target

Intelligence Regarding Phone Subscriber and Thomson Reuter CLEAR Checks

Intelligence Regarding Toll Analysis

Information Regarding Businesses Associated to Parampreet SINGH, Ranvir SINGH and

47. Investigators searched Articles of Incorporation of a General Stock Corporation