/ STATE OF NORTH CAROLINA COUNTY OF GUILFORD STATE OF NORTH CAROLINA On Relation of CITY OF GREENSBORO Plaintiff, vs. KHAN AND KHAN, INC. a North Carolina Corporation Defendant. IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION ncvs/JX£>S3 VERIFIED COMPLAINT (JURY TRIAL REQUESTED) AND REQUEST FOR TEMPORARY RESTRAINING ORDER NOW COMES the Plaintiff, pursuant to Chapter 19 ofthe North Carolina General Statutes, more particularly, North Carolina General Statutes §§ 19-2.1 and 19-2.2, and complaining of the Defendant, alleges and says: 1. The Plaintiff is the State ofNorth Carolina on relation of the City of Greensboro, a body politic and corporate, organized and existing under the laws of the State of North Carolina and is specifically empowered pursuant to provisions ofNorth Carolina General Statute § 19-2.1 to bring this action. 2. The subject real property ofthis action is located within Guilford County, North Carolina.
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STATE OF NORTH CAROLINA
COUNTY OF GUILFORD
STATE OF NORTH CAROLINAOn Relation ofCITY OF GREENSBORO
Plaintiff,
vs.
KHAN AND KHAN, INC.a North Carolina Corporation
Defendant.
IN THE GENERAL COURT OF JUSTICESUPERIOR COURT DIVISION
ncvs/JX£>S3
VERIFIED COMPLAINT
(JURY TRIAL REQUESTED)AND REQUEST FOR TEMPORARY
RESTRAINING ORDER
NOW COMES the Plaintiff, pursuant to Chapter 19 ofthe North Carolina General Statutes,
more particularly, North Carolina General Statutes §§ 19-2.1 and 19-2.2, and complaining of the
Defendant, alleges and says:
1. The Plaintiff isthe State ofNorth Carolina on relation ofthe City ofGreensboro,
abody politic and corporate, organized and existing under the laws ofthe State ofNorth
Carolina and is specifically empowered pursuant to provisions ofNorth Carolina General
Statute § 19-2.1 to bring this action.
2. The subject real property ofthis action is located within Guilford County, North
Carolina.
3. Defendant Khan and Khan, Inc., is acorporation organized and existing under the laws
ofthe State ofNorth Carolina with its principal office and place ofbusiness located in Guilford
County, North Carolina.
4. Khan and Khan, Inc., owns the property housing the business known as the Greensboro
Inn, located at 135 Summit Avenue, Greensboro, Guilford County, North Carolina (hereinafter
the Property). The Property is further described in the Deed duly recorded in Deed Book 3508,
Page 1592, in the Office ofthe Guilford County Register of Deeds, acopy ofwhich is attached
hereto and incorporated herein by reference asExhibit A.
5. The Property described hereinabove, now and for some considerable period oftime prior
to the filing ofthis Complaint, has been established, continued, maintained, owned, and used by
Khan and Khan, Inc., as aplace for the purpose ofprostitution and the illegal possession and
sale ofcontrolled substances as defined in theNorth Carolina Controlled Substance Act.
6. The Property described hereinabove now, and for some considerable period of time prior
to the filing ofthis Complaint, has been established, continued, maintained, owned, and used by
Khan and Khan, Inc., as aplace wherein and whereon are carried on, conducted, or permitted,
repeated acts which create and constitute abreach ofthe peace, including but not limited to
armed robberies, assaults on females, assaults inflicting serious injury, aggravated assault, and
communicating threats.
7. During Defendant's ownership ofthe Property, law enforcement authorities have made
at least fourteen drug charges against individuals upon the Property and have seized heroin,
cocaine, andmarijuana from such individuals.
8. Prior to filing this action, Defendant Khan and Khan, Inc., received written notice from
the Plaintiff that a nuisance existed or was maintained on the Property. Acopy ofthe written
notice isattached hereto and incorporated herein by reference asExhibit B.
9. In addition to and in support ofallegations contained in this Complaint, Greensboro
(n) Adrienne Jones Possession ofcocaine with intent tosell and deliver
(o) Adrienne Jones Possession of cocaine
(P) Adrienne Jones Possession of cocaine
(q) Jameson Oliver Assault on a child under 12
(r) Karen D. Hall Possession of cocainePossessionof drug paraphernalia
(s) Jovon Clarke Possession ofcocaine with intent tosell and deliver
(t) James R. Jones Possession ofcocaine
(u) Malik Curry Possession ofcocaine with intent to
sell and deliverPossessionof marijuanawith intentto sell and deliver
(v) Charlene Simpson Possession ofcocaine
(w) John L. Stevenson Possession ofastolen vehicle
11. The Property has ageneral reputation among citizens within the community and among
the law enforcement community as a public nuisance, as the term is defined pursuant to North
Carolina General Statute 19-1, etseq., and as aplace where numerous unlawful activities have
taken place and where police services are repeatedly needed.
12. In addition to and in support ofallegations contained in this Complaint, a number of
citizens have signed affidavits containing information and describing factual circumstances and
occurrences which support the Plaintiff's cause ofaction. The affidavits are attached hereto and
incorporated herein by reference as follows: the Affidavit ofMs. Shelley Weidler is Exhibit I;
the Affidavit of Mr. Frank Burton is Exhibit J; the Affidavit of Mr. Ron Estes is Exhibit K; the
Affidavit ofMs. Holly Anderson is Exhibit L; the Affidavit of Mr. Richard Gantt isExhibit M;
and the Affidavit ofMr. Richard Levy is Exhibit N.
13. The Property has been operated in such a manner as to make said place indecent,
disgraceful, and intolerable for the residents living nearby, and the general public traveling the
public streets adjacent to said premises, either as pedestrians or in motor vehicles, and unless
said nuisance isabated; these citizens will besubjected to theintolerable and dangerous
conditions and illegal activity existing upon said Property.
14. The Defendant knew, orby the exercise ofdue diligence, should have known ofthe acts
or conduct complained of in the Plaintiffs cause ofaction have occurred on the Property for a
considerable period oftime before and up to the filing ofthis Complaint.
15. The Plaintiff isinformed, believes and therefore alleges that the real estate and
improvements thereon, and other personal property ofthe Defendant which may be found in and
around said Property, constitutes ageneral nuisance, and in the interest ofpublic morals and the
health and safety of the community, and in the interest ofpublic decency, should be condemned
and abated as provided byN.C. Gen. Stat. § 19-2.1.
16. That as demonstrated from the attached Affidavits, and the allegations contained herein,
there is reasonable apprehension of immediate and irreparable injury, loss, or damage that will
result before notice can be served and a hearing held on the Plaintiffs application for a
Temporary Restraining Order, in that upon information and belief, the public safety and public
morals ofthe community will continue to be irreparably disturbed by the existence ofthe
nuisance maintained on Defendant's premises; and that removal ofpersonal property and
contents ofthe place where the nuisance is alleged to exist will defeat the right of the Plaintiff
and the local government to the said property as provided in North Carolina General Statute §
19-6. The Plaintiff therefore, is entitled to the issuance ofaTemporary Restraining Order,
without notice, pursuant to the provisions ofNorth Carolina General Statute §§ 19-2.3 and 1A-1,
Rule 65(b), ofthe North Carolina Rules ofCivil Procedure, pending ahearing on Plaintiffs
application for apreliminary injunction, and until further orders ofthe Court; and for an Order
instructing the officer serving the prayed for Temporary Restraining Order to enter the Property
and forthwith make and return into the Court an inventory ofthe personal property and contents
situated inand used inconducting or maintaining thenuisance.
WHEREFORE, the Plaintiffprays the Court allow itthe following relief:
1. Issue aTemporary Restraining Order ex parte in accordance with
North Carolina General Statutes §§ 19-2.3 and 1A-1, Rule 65(b), ofthe North Carolina Rules of
Civil Procedure, preserving the status quo and restraining the Defendant and all other persons
from:
(A) Removing or in any manner interfering with any evidence or personal
property or contents ofthe Property where the nuisance is alleged to exist
except as otherwise specifically directed by the Court, until the decision
ofthe Court granting or refusing a preliminary injunction, and until
further Order of the Court.
(B) Engaging in or allowing any other person to engage in any act upon the
Property which violates the laws ofthe state or local government.
2. Issue an Order instructing the officer serving the prayed for Temporary Restraining
Order, to forthwith enter the Property and make and return into the Court an inventory ofthe
personal property, monies, and contents situated in and used in conducting or maintaining the
nuisance.
3. Issue an order preliminarily enjoining the Defendant, its servants, agents or lessees,
from operation of the nuisance complained of, to the extent that said business shall be closed as
authorized by General Statute § 19-2.5 pending trial in this case.
4. Allow ajury totry the issues of this action.
5. Issue an Order perpetually enjoining the Defendant and any other person or entity
from operating or maintaining apublic nuisance upon the Property described hereinabove.
6. Issue an Order perpetually enjoining the Defendant from operating or
maintaining apublic nuisance elsewhere within the jurisdiction of the State ofNorth Carolina.
7. Issue an order of forfeiture ofall personal property, monies, contents and other
considerations used in conducting and maintaining said nuisance as provided by North Carolina
General Statute §§ 19-6,19-1.3,19-l(c), and any other section ofChapter 19, Article 1, of the
North Carolina General Statutes.
8. Issue an Order of Forfeiture vesting title ofthe Property in the Guilford County
Board ofEducation as provided by N.C. General Statute § 19-6.1.
9. Order an accounting be made by the Defendant ofall monies estimated to have
been taken in as gross income from such unlawful commercial activity, to be forfeited to the
general funds ofthe Greensboro City and Guilford County governments as fruits ofan unlawful
enterprise, and for such other damages allowed under N.C. General Statute §19-6.
10. Tax against the Defendant the costs ofthis action as provided in North
Carolina General Statute §§ 19-6 and 19-8, such costs to include, but not be limited to,
reasonable attorney's fees, court costs, and other costs for the investigation and prosecution of
this proceeding, and that such costs be declared alien on the real and personal property used in
maintaining the nuisance.
11. Allow the Plaintiff such other and further relief as the Court deems just, proper
andequitable.
This the Qf^&ay of Ttecern<bgy ,2011.THE CITYOF GREENSBORO, NORTH CAROLINA
By:James A. ClarkN.C. State Bar No. 26558Associate General CounselGreensboro City Attorney's OfficePost Office Box 3136Greensboro, North Carolina27402-3136Telephone: (336) 373-2320Facsimile: (336) 373-2078E-mail: [email protected]
STATE OF NORTH CAROLINA VERIFICATION
COUNTY OF GUILFORD
Kenneth C. Miller, being duly sworn, deposed and says, that he is employed as the Chief
ofPolice ofthe City of Greensboro, North Carolina, the Relator in this action, and as such he is
duly authorized to verify the foregoing Complaint; that he knows the contents thereof; that as to
those allegations to which he has personal knowledge, he knows that such allegations are true;
that as to those allegations made upon information and beliefor which are based on the
knowledge and information ofother officers, agents or employees of the City ofGreensboro or
the State ofNorth Carolina, hebelieves them to be true.
Sworn to (or affirmed) and subscribed before
^davof/W/W1^ .2011.Mn,
Notary Public
IM-JUSMy Commission Expires 0/
(Official Seal)
************
JENNIFER G. SMITH-SUTPHINNOTARY PUBLIC
GUILFORD COUNTY.. NCc»^
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i&g 184798 4.003 DEEDS ADDN PAGE<S> «•=*
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ECONO LODGES OF AMERICA, INC., aNORTH CAROLINA CORPORATION
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KHAN AMD KHAN, INC., a NorthCarolina Corporation.
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at Page. .77.7. of the. 8aid:.Registry
Amap sbowlne the above described property isrecorded in Plat Uouk Pns*TO HAVE AND TO HOLD the aforesaid lot or parcel of land and all privilege, and appurtenance, thereto belonging tothe Grantee in fee simple.
And the Grantor covenant, with the Grantee that Orantorto s.i.edI of the1J^^^^^SjJy^^.'Sthe same in fee simple, that title i. marketable snd free and clear of tiVenf^^^^SSSS^tAdefend the title against tb. lawful claims of all person. *™™"**l£^?et*Ua' htnitt*WrTitle to the property hereinabove described is subject to the following exeept-ons.
SAVE ~™»~S^£^WZ£Z a^i'Iosoci^rof Raleigh.tt£&fc s-.ass^sSi^2c-? g»ffl2 puoiirsistryin Book 3346 at Page 841 of the Guilford County, North Carolina Public Registry,Se oalance upon slid indebtedness to be paid by the Grantees herein as apartof the consideration for this conveyance.
Grantors hereby transfer unto Grantees all their right title and interestin and to that certain escrow account maintained by First Federal savingsand Loan Association (of Raleigh, North Carolina).
BEGINNING at an iron pin at the intersection °£ the southernmargin of E. Lihasay Avenue, (formerly Bishop street) with thenorthwestern margin of Summit Avenue <f«™^iL the northwlsternrunning thence South 31 deg. 58 min. West along the "^thwesteF"margin of Summit Avenue (formerly Church Street) 106.77 feet to aniron pim thence North 69 deg. 46 min. West 226.26 «t i™«pipe; thence North 31 deg. 17 min. East 74.84 feet to an «-onpip thence South 68 del. 31 min. East 2.46 feet to an iron pipe;EhSnce North 28 deg. 43 min. East 58.78 feet to an iron pipe inthe southern margin of E. Lindsay Avenue (formerly Bishop Street);thence South 62 deg. 51 min. East along ^e southern^margin of E.Lindsay Avenue (formerly Dishop Street) 49.90 feet to an ironpipe; thence South 28 deg. 50 min. West 53.87 feet to an ironDiDes thence South 68 deg. 31 min. East 25.26 feet to an ironKpT> tnlncl North 28 del. 50 min. East 50.97 feet to an iron pipeinPtne southern margin of E. Lindsay ^enue formerly BishopStreet); thence South 62 deg. 51 min. East along the s°«th,|rnmawin of E. Lindsay Avenue (formerly Bishop Street) "9.75 tee£?otte point of BEGINNING. And being the property conveyed to theG«ntorPby that deed recorded in Book 3346 at Page 777, ••»• »£exceot that parcel conveyed to the City of Greensboro for a streetISent re^ed in Boole 3452 at Page "4, reference^ which isherewith made, all said documents being recorded in the GuiltoraCounty Public Registry.
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City of GreensboroNorth Carolina
Januarv'27,2011
Khan and Khan, Inc.135 Summit Ave.Greensboro, NC 27401Attention: Aman Khan, President and Registered Agent
RE: The Greensboro Inn135 Summit Ave.
Greensboro, NC 27401
Dear Mr. Kahn,
Records at the North Carolina Secretary of State indicate that you are the President and Registered Agent of theproperty looted at 135 Summit Ave., Greensboro, North Carolina. The Greensboro Inn winch ,s bemg operated asa motel currently occupies said property.
Dunne the past several years, the Greensboro Police Department has responded to anumber of calls at TheGe™ ooTnn. Reported unlawful activities on the property include repeated acts which create and consu ute aS of the peace, including fights, assaults, and violations of the North Carolina Controlled Subsfcnee Act.Citizens in the community have repeatedly complained to law enforcement authorit.es about such act.vtt.esoccurring atThe Greensboro Inn.
Chapter 19 of the North Carolina General Statutes defines apublic nuisance and gives the district attorneys attorneyaeneral ocal <>overnmen., or aprivate citizen the right to seek court action to abate or stop anuisance. PossibleSSdeforfeiture of property, court ordered closure of property, permanent restrictions on the use ofproperty, civil fines, accounting, liens and invalidation of leases.
This letter is notice to you of your property being used in amaimer that could be illegal pursuant to Chapter 19,Article 1, ofthe North Carolina General Statutes.
The ilWal activities occurring at The Greensboro Inn must be eliminated before they become worse and endangertofirf2S!^hi«dhl. community. If these problems cannot be addressed by(you as ^propertyow he only option remaining is to seek assistance from acourt^^^^^2^wants to solicit your support and assistance, as the property owner, man effort to resolve the problems. Pleasecontact me within ten (10) days to discuss this situation.
Verytruly yours,
Captain Richard B. WhisenantGreensboro Police Department tiAHioiTVice Narcotics Division Q300 W. Washington St.Greensboro, NC 27401336-373-2484rii'lmnlwliisenant^/.'urccnsboro-nc.i'ov
CONV OFFN: M ASSAULT ON A FEMALESENT LEN: 150 D - SENT TYPE: IPROB: 018 M SUPERVISED WITHDRAWN:AREA CD: ACCD: HWY: V LIC:CDL: N CMV: N HAZ: N TRP/DIST: V ST:$20IPF/$55ATTY/$60APPT/15D-SPLT
REST JUDGE PAID TO-BE-PAIDSFA R
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400 GUILFORD
DISPOSED
MAGISTRATE ORDER
RICKER,NATASHA,LARAY3328 A BECK STGREENSBORO NC 27405 DEF ATTY: RIERSON,JENNIFER TYP: PCHG/ARRN OFFN: F PWISD MARIJUANA 90-95(A)COMPLAINANT: BROWN,T,K CPD ISSUED: 010110 SERVED: 010110OFFN DATE: 010110 ARRN DATE: MOTIONS DATE: DISP DATE: 032310CONT. D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
ICA INQUIRY 01 10CR 065086 GR FILM:R S DOB/AGE CR FILING DATE: 010110B F 07211987 DLtf: 25087839 NC
CIT8: TRIAL DATE: 032310
CSLR: CSLRC: AMVRA:
PLEA VER MOD FINE COSTS WCC
GL GU JU $ $ $CONV OFFN: M POSSESS MARIJUANA UP TO 1/2 OZSENT LEN: - SENT TYPE:PROB: WITHDRAWN:AREA CD: ACCD: HWY: V LIC:CDL: N CMV: N HAZ: N TRP/DIST: V ST:
REST JUDGE PAID TO-BE-PAID
PDS
90-95CD)(4)CONS F/JGMT: 10CR 034322APPEALED TO SUPERIOR:
ICA INQUIRY 01 10CR 033159 GR FILM:R S DOB/AGE CR FILING DATE: 031810W M 08251966 DLS: 1787845 NC
CITS: C9209924 TRIAL DATE: 060710CSLR: CSLRC: AM GB1D
DEF ATTY: WAIVED TYP: W VRA:
400 GUILFORD
DISPOSED
CITATION
PATTON,DOUGLAS,MICHAEL4700 CHARLOTTESVILLE RD
GREENSBORO NC 27410CHG/ARRN OFFN: M POSS OPEN CNTNR ALC BEV IN PASS AREA OF 18B-401COMPLAINANT: DELL,T,D CPD ISSUED: 030510 SERVED: 030510OFFN DATE: 030510 ARRN DATE: MOTIONS DATE: DISP DATE: 042610CONT. D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
PLEA VER MOD FINE COSTS WCC REST JUDGE PAID TO-BE-PAIDGU GU JU $ $ 125.00 $ SEB YESCONV OFFN: M POSS OPEN CNTNR ALC BEV IN PASS AREA OF 18B-401SENT LEN: - SENT TYPE: C CONS F/JGMT:pR0B. WITHDRAWN: APPEALED TO SUPERIORAREA CD- ACCD: N HWY: OT V LIC: XPT6920 TRANS TO SUPERIORCDL: N CMV: N HAZ: N TRP/DIST: V ST: NC V TYP: U APPELLATE$20 IP FEE/060710 MTN TO EXT COMPL ALLOWED(FOSTER)
ARREST DATE:
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4 00 GUILFORD
DISPOSED
INDICTMENT
JACKSON,D'ANGELO,LEQUIN
135 SUMMIT AV # 210GREENSBORO NC 27406 DEF ATTY: BAILEY,SABRINA,MCHG/ARRN OFFN: F PWISD COCAINECOMPLAINANT: DIAZ.D
OFFN DATE: 071310 ARRN DATE:
CONT. D: 00 S: 00 C: 00 NR: 00
PLEA VER MOD FINE
5016-0113-3*^
ICA INQUIRY 51 10CRS082993 GR FILM: 1001669999R S DOB/AGE CRS FILING DATE: 081610B M 03051982 DL#: 21329704 NC
SENT LEN: 014 M - 017 M SENT TYPE: APROB: WITHDRAWN:AREA CD: ACCD: HWY: V LIC:CDL: N CMV: N HAZ: N TRP/DIST: V ST:ATTY FEE $225/CIVIL JUDG/MASSEY/GARLICK
PLEA VER MODGU GU JU $ $ *CONV OFFN: M POSSESS DRUG PARAPHERNALIASENT LEN: 030 D - SENT TYPE: ApR0B. WITHDRAWN:AREA CD: ACCD: HWY: V LIC:CDL: N CMV: N HAZ: N TRP/DIST: V ST:GCJ
FINE COSTS WCC REST JUDGE
SFA
90-113.22
CONS F/JGMT:APPEALED TO SUPERIOR
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PAID TO-BE-PAID
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PLEA VER MOD FINEGL GU JU $ $ $CONV OFFN: M POSS STOLEN GOODS/PROP (M)SENT LEN: - SENT TYPE: CPROB: WITHDRAWN:AREA CD: ACCD: HWY: V LIC:CDL: N CMV: N HAZ: N TRP/DIST: V ST:CREDIT TIME SERVED(15DYS)
400 GUILFORD ICA INQUIRY 01 09CR 086045 GR FILM:DISPOSED R S DOB/AGE CR FILING DATE: 071409MAGISTRATE ORDER B F 07211987 DL#: 25087839 „„^RICKER,NATASHA,LARAY CIT#: TRIAL DATE: 0323103328 A BECK ST CSLR: CSLRC: AMGREENSBORO NC 27405 DEF ATTY: RIERSON,JENNIFER,L TYP: P VRA:CHG/ARRN OFFN: M POSSESS MARIJUANA UP TO 1/2 OZ 90-95(D)(4)COMPLAINANT: LONE,M,K CPD ISSUED: 071409 SERVED: 071409OFFN DATE: 071409 ARRN DATE: MOTIONS DATE: DISP DATE: 032310CONT D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
PLEA VER MOD FINE
GU GU JU $ $ $CONV OFFN: M POSSESS MARIJUANA UP TO 1/2 OZSENT LEN: - SENT TYPE:PROB: WITHDRAWN:AREA CD: ACCD: HWY: V LIC:CDL: N CMV: N HAZ: N TRP/DIST: V ST:ORD DESTROY
COSTS WCC REST
ARREST DATE.:
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4 00 GUILFORD
DISPOSED
MAGISTRATE ORDER
DOCKERY,MARK,ANTHONY,SR
10541 US HWY 158 W
RUFFIN NC 27326
CHG/ARRN OFFN: M ASSAULT ONCOMPLAINANT: STRADER,B,C
OFFN DATE: 04 0707 ARRN DATE
CONT. D: 00 3: 00 C: 00 NR: 00
ICA INQUIRY 01 07CR 084580 GR FILM:R S DOB/AGE CR FILING DATE: 040707W M 04021969 DL#: 2080331 NC
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DEF ATTY: BAUCINO,WAYNE TYP: P VRA: YA FEMALE 14-33(C)(2)
CPD ISSUED: 040707 SERVED: 040707
MOTIONS DATE: DISP DATE: 052207RSONCO: GANG REL: DV CV: N
PLEA VER MOD FINE COSTS WCC REST
GU GU JU $ $ 110.00 $CONV OFFN: M ASSAULT ON A FEMALE
SENT LEN: 075 D - SENT TYPE: C
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CDL: N CMV: N HAZ: N TRP/DIST: V ST: VNO A-T-H PW/NO CONT W/CHILD OF AMANDA FRAFERTY/13,14,15/TASC-COMPLY/NA 3X PER WEEK W/PROOF TO PO/DVIP OR LIKEPROGRAM IN ROCK.CO
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400 GUILFORD
DISPOSED
MAGISTRATE ORDER
DOCKERY,MARK,ANTHONY,SR
10541 US HWY 158 W
ICA INQUIRY 01 07CR 084582 GR FILM:R S DOB/AGE CR FILING DATE: 040707W M 04021969 DL#: 2080331 NC
CIT#: TRIAL DATE: 052207CSLR: CSLRC: AM
RUFFIN NC 27326 DEF ATTY: BAUCINO,WAYNE,TCHG/ARRN OFFN: M FALSE IMPRISONMENT
ICA INQUIRY 51 07CRS089746 GR FILM: 0800509999R S DOB/AGE CRS FILING DATE: 080707B F 05011964 DL#: 5531945 NC
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VRA:
CONT. D: 00 S: 00 C: 00 NR: 00
COSTS V.'CC REST JUDGE
RWS
90-95(A)
CONS F/JGMT:APPEALED TO SUPERIOR
TRANS TO SUPERIOR
V TYP: APPELLATE
PAID
DV CV: N
TO-BE-PAIDPLEA VER MOD FINE
GU GU JU $ $ $CONV OFFN: F PWISD COCAINE
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400 GUILFORD ICA INQUIRY 02 07CR 093399 GR FILM:DISPOSED R S DOB/AGE CR FILING DATE: 063007MAGISTRATE ORDER B M 09121970 DLS: 7014607 NCOLIVER,JAMESON, KEITH CITS: TRIAL DATE: 0423093505 POWER ST CSLR: CSLRC: PM GB1CGREENSBORO NC 27405 DEF ATTY: WAIVED TYP: W VRA: YCHG/ARRN OFFN: M MISDEMEANOR PROBATION VIOL 15A-1345COMPLAINANT: CALVERT,M,J CPD ISSUED: 063007 SERVED: 063007OFFN DATE: 063007 ARRN DATE: MOTIONS DATE: DISP DATE: 090208CONT. D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
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400 GUILFORD
DISPOSED
INDICTMENT
SHIPMAN,CHARLENE,MARIE922 A HACKETT ST
GREENSBORO NC 274 07
ICA INQUIRY 51 07CRS109880 GR FILM: 0900479999R S DOB/AGE CRS FILING DATE: 020408B F 12091984 DLS: 27584180 NC
CITS: TRIAL DATE: 051908CSLR: CSLRC: AM
DEF ATTY: WAIVED TYP: W VRA:
PLEA VER MOD FINE COSTS WCCGU GU JU $ 00100.00 $ 616.50 $CONV OFFN: F FELONY POSSESSION OF COCAINESENT LEN: 005 M - 006 M SENT TYPE: IPROB: 024 M SUPERVISED WITHDRAWN:AREA CD: ACCD: HWY: V LIC:CDL: N CMV: N HAZ: N TRP/DIST: V ST:ATTY FEE $150, SBI FEE $300/SPIVEY/GARLICK
CHG/ARRN OFFN: F FELONY POSSESSION OF COCAINE 90-95(D)(2)COMPLAINANT: GREGORY,H,K CPD ISSUED: 121907 SERVED: 121907OFFN DATE: 121907 ARRN DATE: MOTIONS DATE: 010509 DISP DATE: 072508CONT D- 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
400 GUILFORD ICA INQUIRY 01 07CR 110559 GR FILM:DEPOSED R S DOB/AGE CR FILING DATE: 122907MAGISTRATE ORDER B M 08041979 DLS: 24839995 NCSnSn JOHN, LAWRENCE CITS: TRIAL DATE: 061208305 W LEE ST CSLR: CSLRC: AMGREENSBORO NC 00000 DEF ATTY: COALTER,SCOTT TYP: A VRA:CHG/ARRN OFFN: F POSSESS STOLEN MOTOR VEHICLE 20-106 „„„„„,,COMPLAINANT: MOLSON,M,J CPD ISSUED: 122907 SERVED: 122907OFFN DATE: 122907 ARRN DATE: MOTIONS DATE: DISP DATE: 061208CONT D: 00 S: 00 C: 00 NR: 00 RSONCO: GANG REL: DV CV: N
RESTPLEA VER MOD FINE COSTS WCC RKST JUDGEGL GU JU $ $ $ LCMCONV OFFN: T SOLICIT POSSESS STOLEN MOTOR VEHICLE 20-106SENT LEN: 035 D - SENT TYPE: A CONS F/JGMT:PROB- WITHDRAWN: APPEALED TO SUPERIORAREA"CD: ACCD: HWY: V LIC: TRANS TO SUPERIORCDL: N CMV: N HAZ: N TRP/DIST: V ST: V TYP: APPELLATECREDIT TIME SERVED
STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICECOUNTY OF GUILFORD SUPERIOR COURT DIVISION
FILE NO. | i CvS
AFFIDAVIT
POLICE OFFICER J.D. BROWN
POLICE OFFICER J.D. BROWN, appearing before the undersigned notary and being duly
sworn (or affirmed), says that:
1. I am not a party in this matter.
2. I ama sworn police officer employed by theGreensboro Police Department,
Greensboro, North Carolina, and have been soemployed formore than sixyears.
3. I am currently assigned to the Vice Narcotics Unit ofthe Greensboro Police
Department.
4. I am familiar with the property housing the business known as the Greensboro
Inn, located at 135 Summit Avenue, Greensboro, Guilford County, North Carolina (hereinafter
the "Property").
5. As part ofmy duties, Imaintain regular contact with citizens who reside in or
frequently visit the community where the Property is located.
6. Citizens who reside inor frequently visit the community where the Property is located
have advised meof the general reputation of the Property.
7. The Property currently, and has for a considerable period of time, maintained a
general reputation as aplace where illegal controlled substances are repeatedly sold and used.
8. I have been advised by citizens who reside in or work in thecommunity around
the Property, that many ofthe people who visit and loiter on and about the Property have
reputations as drug dealers, drug users, and prostitutes.bAnlDI I
D
9. Ihave been advised by citizens who reside in or work in the community around
the Property that they are afraid for their safety because of the general disruptive nature ofthe
Property and the criminal element attracted to the Property.
10. I have conducted covert surveillance on the Property.
11. During the times I conducted surveillance, I observed the following:
(A) Females with reputations asprostitutes visit rooms.
(B) People arrive at the Property in cars; enter rooms for a short period of
time, leave the room, and getin the carand leave. A short time later,
another cararrives at theProperty and the occupant repeats this process.
(C) What I believe to be repeated illegal drug transactions, where persons
acting in a secretive manner make exchanges with other persons who
approach them.
12. I have worked as an undercover operative at the Property. During the time I
worked undercover, I purchased counterfeit controlled substances and crack cocaine from a
person loitering on the Property.
13. I have assisted other Greensboro Police Officers executing a search warrant at the
Property and observed crack cocaine in a room.
14. I have responded to calls for police services at the Property and observed
examples ofthe illegal and disruptive activities complained of, including assault victims and
females assaulted duringdomestic disturbances.
15. I have access to and have researched or otherwise caused to be researched,
Official Greensboro Police Department Records relating to investigations and calls for police
service to the Property, such records setting forth activities ofthe department and setting forth
matters observed pursuant to duty imposed by law as to which matters there was a duty to report.
The date and nature ofthese investigations and calls are attached to this affidavit and include but
are not limited to the information listed (see attachments 15-1).
16. Based upon reports from other officers who have responded to calls atthe
Property, my training, and reports from neighbors as described hereinabove, I feel it is not safe
for any law enforcement officer to respond to acall for service atthe Property without exposure
to inordinate and undue danger.
17. Further your affiant saith not.
AMANDA HANNANOTARY PUBLIC
GUILFORD COUNTY, NCMy Commission Expires Nov. 17,2015
Sworn to (oraffirmed) and subscribed before methis
l sV day of
(Official Seal)Notary Public
^^to^VrJAtoNA-.^1!1NOTARY PUBLIC
GUILFORD COUNTY, NCMy Commission Expires Nov. 17,2015
MyCommission expires •Moo^rvAbc:- )1 £&\
dV ( \ s^zT
J Affiant
DATE
2011
January 13,2011
January 18,2011
January 18,2011
January 18,2011
January 19,2011
January 19,2011
January 19,2011
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
DRUG ACTIVITY: Greensboro Police charged one person,observed leaving the Greensboro Inn, with possession of drugparaphernalia.
DRUG ACTIVITY: An undercover Greensboro Police Officerpurchased counterfeit crack cocaine from an occupant in room 313at the Greensboro Inn. Suspect, Johney Matthews, waschargedwith sell anddelivery of cocaine. Matthews was charged with sellanddelivery of counterfeit controlled substance.
DRUG ACTIVITY: A confidential source of information,working under the direction of the Greensboro Police Department,purchased crack cocaine from an occupant inroom 209 at theGreensboro Inn. Suspect, Javon Shields, was charged with sell anddelivery of cocaine.
DRUG ACTIVITY: Suspect infirst January 18, 2011, counterfeitdrug transaction (Johney Matthews) sold crack cocaine to anundercover police officer in a room at the Greensboro Inn.Matthews was charged with sell and delivery of a controlledsubstance.
DRUG ACTIVITY: A confidential source of information, •working under the direction of theGreensboro Police Department,purchased crack cocaine from Javon Shields in room 209 at theGreensboro Inn.
DRUG ACTIVITY: A confidential source of information,working under thedirection of the Greensboro Police Department,purchased crack cocaine from an occupant in room 216 at theGreensboro Inn. Suspect, Lance Whidbee, wascharged with selland delivery of cocaine.
DRUG ACTIVITY: A confidential source of information,working under the direction of the Greensboro Police Department,purchased crack cocaine from Lance Whidbee in room 216 at theGreensboro Inn. This transaction was the second time Whidbeesold crack cocaine in less than one hour.
DATE
January 24,2011
January 26,2011
January 26,2011
January 26,2011
January 27,2011
January 31,2011
February 5,2011
March 2,2011
March 22,2011
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
DRUG ACTIVITY: A confidential source of information,working under the direction of the Greensboro Police Department,purchased crack cocaine from an occupant in room 115 at theGreensboro Inn.
DRUG ACTIVITY: A confidential source of information,working under the direction of the Greensboro Police Department,purchased crack cocaine from Lance Whidbee in room 216 at theGreensboro Inn. Subsequent execution ofa search warrant yieldedcocaine and marijuana from the room.
DRUG ACTIVITY: Greensboro Police executed a search in room209 at the Greensboro Inn. The room was occupied by JavonShields. A search of the room yielded cocaine, hydrocodone, drugparaphernalia, and more than$800.00.
DRUG ACTIVITY: Greensboro Police executed a search in room116 at the Greensboro Inn. A search of the room yielded crackcocaine. The occupant, Tony Barfield, was charged withpossession ofcocaine with intent to sell and deliver.
ASSAULT INFLICTING SERIOUS INJURY/DOMESTICVIOLENCE: Greensboro Police responded to a complaint of a.domestic dispute which occurred inroom 115 atthe GreensboroInn. Victim reported she was assaulted in the room by a male.
NOTICE TO ABATE NUISANCE: Greensboro Police sentwritten notice to the owner of the Greensboro Inn that a publicnuisance exists on the Property.
LARCENY: Greensboro Policeresponded to room 206 at theGreensboro Inn in reference to a larceny. A laptop computer wasreported stolen from the room.
ASSAULT/DRUG ACTIVITY: Greensboro Police responded tothe Greensboro Inn in reference to a disturbance. Suspect, a renterat the Property, assaulted the desk clerk. Afterarrest, suspect wasfound in possession of marijuana and drug paraphernalia.
DRUG ACTIVITY: Greensboro Police charged one person on theparking lot at the Greensboro Innfor possession of cocaine.
ATTACHMENTS 15-1
DATE CALLS AND INVESTIGATIONS
April 2,2011 LARCENY: Greensboro Police responded to room 103 at theGreensboro Inn in reference to a larceny. A laptop computer, an I-Phone, and a wallet were reported stolen from the room.
April 5,2011 LARCENY: Greensboro Police received acomplaint reporting acellular telephone and debit card were reported stolen from room207 at the Greensboro Inn on March 31,2011.
April 14,2011 LARCENY: Greensboro Police received acomplaint reporting agym bag and wallet were reported stolen from acar in the parkinglot at the Greensboro Inn.
April 27,2011 STOLEN VEHICLE: Greensboro Police recovered astolenvehicle at the Greensboro Inn.
May 12,2011 DRUG ACTIVITY: Aconfidential source ofinformation,working under the direction of the Greensboro Police Department,purchased crack cocaine from an occupant in room 312 at theGreensboro Inn.
May 16,2011 ASSAULT ON AFEMALE/DOMESTIC VIOLENCE:Greensboro Police responded to a complaint of a domestic disputewhich occurred in room 221 at the Greensboro Inn. Victimreported she was assaulted inthe room by her male boyfriend.
May 24,2011 ASSAULT ON AFEMALE/DOMESTIC VIOLENCE:Greensboro Police responded to a complaint of a domestic disputewhich occurred in room 219 at the Greensboro Inn. Victimreported she was assaulted in the room byJohney Matthews.
June 1,2011 DRUG ACTIVITY: Greensboro Police charged one personleaving the Greensboro Inn for possession of cocaine.
June 23,2011 ASSAULT ONA FEMALE/DOMESTIC VIOLENCE:Greensboro Policeresponded to a complaint of a domestic disputeat the Greensboro Inn. Victim reported she was assaulted in theroom by Johney Matthews.
July 6,2011 STOLEN PROPERTY: Greensboro Police recovered a stolenlicense plate from a vehicleat the Greensboro Inn. The vehiclewas owned by an occupant of room 109.
DATE
September 2,2011
September 21,2011
November 14,2011
November 16,2011
November 24,2011
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
AGGRAVATED ASSAULT: Greensboro Police responded to theProperty in reference to an assault. Female victim, assaulted bymale, suffered multiple facial fractures, damaged teeth, and apossibleconcussion.
DRUG ACTIVITY: A confidential source of information,working under the direction of the Greensboro Police Department,purchased crack cocaine from a person loitering near room 119 atthe Greensboro Inn. One person wasarrested.
STOLEN PROPERTY: Greensboro Police recovered over$5,000.00 in stolen property in room 221 at the Greensboro Inn.Thestolen property included items suchas expensive bicycles.
DRUG ACTIVITY: A confidential source of information,working under the direction of the Greensboro Police Department,purchased crack cocaine from a person loitering near room 119 atthe Greensboro Inn. One person was arrested.
property from room 204at theGreensboro Inn. The stolenproperty included a handgun. Three people were arrested.
DATE
2010
January 1,2010
January 4,2010
January 6,2010
January 9,2010
February 20,2010
March 5,2010
June 14,2010
July 13,2010
ATTTACHMENTS 15-1
CALLS AND INVESTIGATIONS
DRUG ACTIVITY: Greensboro Police charged two people inroom 313 at the Greensboro Inn for possession of marijuana withintent to selland deliver and possession of cocaine.
LARCENY: Greensboro Police responded to room 204 at theGreensboro Inn in reference to a larceny. A small television wasreported stolen from the room.
LARCENY OF A MOTOR VEHICLE: Greensboro Policereceived a complaint of a motor vehicle stolen from theGreensboro Inn.
LARCENY: Greensboro Police responded to room 305 at theGreensboro Inn in reference to a larceny. A laptop computer wasreported stolen from the room.
ASSAULT/DOMESTIC VIOLENCE: Greensboro Policeresponded toa complaint of a domestic dispute which occurred inroom 112 at the Greensboro Inn. Victim reported she wasassaulted in the room by her fiance. Follow up investigationrevealed room 112 had been vandalized.
DRUG ACTIVITY: Greensboro Police charged one person on theparking lot at the Greensboro Inn for possession of marijuana andpossession ofdrug paraphernalia.
PROPERTY DAMAGE: Greensboro Police responded to room315 at the Greensboro Inn in reference to a complaint of propertydamage; Victim reported her vehicle, which was in the parking lot,was damaged when someone broke the windshield and cut all fourtires.
DRUG ACTIVITY: Greensboro Police charged one person inroom 210 at the Greensboro Inn for possession of cocaine withintent to sell and deliver and possession ofdrug paraphernalia. Atthe time of the arrest, a nine year old child and a twelve year oldchild were in the room.
DATE
July 20,2010
July 22,2010
September 22,2010
September 23,2010
September 27,2010
October 12,2010
October 14,2010
November 30,2010
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
ARMED ROBBERY: Greensboro Police responded to theGreensboro Inn in reference to an armed robbery. Suspectbrandished a handgun and demanded money from desk clerk.
COMMUNICATINGTHREATS: Greensboro Police respondedto the Greensboro Inn in reference to a disturbance. In front ofresponding officers, an occupant of room 219 threatened to kill thedesk clerk.
ASSAULT/DOMESTIC VIOLENCE: Greensboro Policeresponded toa complaint of a domestic dispute which occurred inroom 209 at the Greensboro Inn. Victim reported she wasassaulted in theroom by herboyfriend. Themale wasarrested ontwooutstanding warrants forassault by strangulation andassaulton a female.
DRUG ACTIVITY: Greensboro Police charged one person inroom 208 at the Greensboro Inn for possessionof cocaine.
DRUG ACTIVITY: A confidential source of information,working under the direction of the Greensboro Police Department,purchased crack cocaine from an occupant in room 110at theGreensboro Inn.
ASSAULT: Greensboro Police responded to room 209 at the .Greensboro Inn in reference to an assault. Female victim reportedshe was assaulted in the room by a male.
DRUG ACTIVITY: Greensboro Police charged one person inroom 109 at the Greensboro Inn for possession of MDMA(Schedule I controlled substance), Possessionof cocaine withintent to sell and deliver, possession of marijuana, and possessionofdrug paraphernalia. At the time of the arrest, a four year oldchild was in the room.
DRUG ACTIVITY: Greensboro Police charged one personleaving the Greensboro Inn for possession of cocaine. Subsequentinvestigation at the Property led to the arrest of a second person forpossession ofdrug paraphernalia.
DATE
2009
January 19,2009
January 21,2009
February 4,2009
March 24,2009
April 4,2009
June 5,2009
June 10,2009
July 8,2009
July 14,2009
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
RECOVERED STOLEN VEHICLE: Greensboro Police Officersrecovered a stolen vehicle in the parking lot of the Property. Oneperson was arrested for possession ofa stolen vehicle.
ARMED ROBBERY: Greensboro Police responded to acomplaint ofa robbery in room 208 ofthe Greensboro Inn. Thesuspects were armed with a knife anda handgun.
ASSAULT/DOMESTIC VIOLENCE: Greensboro Policeresponded toa complaint of a domestic dispute in room 212 at theGreensboro Inn. Two people were arrested for assaultwithadeadly weapon andassault by strangulation.
DRUG ACTIVITY: Greensboro Policecharged one person inroom 108 at the Greensboro Inn for possession of marijuana.
DISTURBANCE/DRUG ACTIVITY: Greensboro Police
responded to the Greensboro Inn in Reference to an intoxicatedsubject causing a disturbance. Oneperson was arrested for injuryto real property and possession of a ScheduleI controlledsubstance.
ROBBERY/PROSTITUTION: Greensboro Police received a
complaint of a robbery which occurred on June 3, 2009 at theProperty. Victimalso reportedprostitution at the Greensboro Inn.
TRESPASS: Greensboro Police received a complaint ofatrespasser at the Property. Suspect, who was hiding in room 311,was arrested for 1st degree trespass.
RECOVERED STOLEN VEHICLE:
a stolen vehicle from the Property.Greensboro Police recovered
DRUG ACTIVITY: Greensboro Police arrested one person inroom 207 at the Greensboro Inn for possession of marijuana withintent to sell and deliver and possession of cocaine.
DATE
August2,2009
December 2,2009
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
DRUG ACTIVITY: Greensboro Police went to room 309at theGreensboro Inn to serve an outstanding arrest warrant. Inadditionto the charge on the warrant, suspect was charged with possessionofmarijuana and possession ofdrug paraphernalia.
ARMED ROBBERY: A robbery wasreported to GreensboroPolice at theGreensboro Inn. Oneperson, whooccupied room206, was arrested forpossession of counterfeit money.
DATE
2008
January 24,2008
February 16,2008
March 14,2008
March 28,2008
May 25,2008
July 13,2008
August 1,2008
September 7,2008
September25,2008
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
DRUG ACTIVITY: Greensboro Police responded to theGreensboro Inn in reference to an intoxicated subject. One personinroom 317 was charged with possession of marijuana.
DRUG ACTIVITY: Greensboro Police responded to a complaintofapossible drug overdose in room 203 at the Greensboro Inn.One person was charged with possession ofmarijuana possessionand possession ofdrug paraphernalia.
RECOVERED STOLEN PROPERTY: Greensboro Policerecovered stolen registration plates from a vehicle parked at theGreensboro Inn.
ARMED ROBBERY: Greensboro Police received a complaint ofa robbery at the Greensboro Inn. The suspect, reportedly carrying ahandgun, robbed victim who was on a bicycle.
AGGRAVATED ASSAULT: Greensboro Police responded to areport ofa stabbing infront of room 204 at the Greensboro Inn.
DRUG ACTIVITY: Greensboro Police Officers served an arrestwarrant on a person in room 207 at the Greensboro Inn. Atthe timeof arrest, the person was found possessing marijuana. .
ROBBERY: Greensboro Police responded to the Property inreference to a robbery. Investigation revealed no robberyoccurred. Complainant reported robbery afterbuying counterfeitcocaine from a person at the Greensboro Inn.
TRESPASS: Greensboro Police received a complaint ofanintoxicated female trespassing at the Property. One person wasarrested for 2nd degree trespassing and resist, obstruct, and delay alaw enforcement officer.
DRUG ACTIVITY: Greensboro Police officers arrested a personin room 304 on the Property for possession ofa stolen firearm,possession of a firearm bya convicted felon, possession ofcocaine, possession of marijuana, and drug paraphernalia.
DATE
Novembers, 2008
December 5,2008
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
LARCENY: Greensboro Police responded to the Property inreference toa larceny. One person was arrested for felony larcenyafter complainant reported $1200.00 was stolen from his room.
DRUG ACTIVITY: Greensboro Police responded to theGreensboro Inn in Reference to a disturbance in room 135.person was charged with possession ofdrug paraphernalia.Another person was arrested for possession ofcocaine andpossession of drug paraphernalia.
One
DATE
2007
February 3,2007
February 10,2007
February 23,2007
March 10,2007
March 30,2007
April 7,2007
May 2,2007
May 24,2007
May 25,2007
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
DISTURBANCE/DRUG ACTIVITY: Greensboro Policeresponded to the Greensboro Inn in Reference to adisturbance inroom 107. Officers found cocaine, marijuana, andstolen creditcards in the room. Two people arrested for possession ofcocaine.One was charged with financial card theft.
ROBBERY: Greensboro Police received a complaint of a robberyat the Greensboro Inn.
ARMED ROBBERY: Greensboro Police received a complaint ofa robbery at the Greensboro Inn, which occurred on February 21,2007. The suspect was reported carrying a handgun.
DRUG ACTIVITY: Greensboro Police responded to a complaintof drug activity in room 204 at the Property. One person wasarrested for possession of marijuana.
LARCENY: Greensboro Police responded to the property inreference toa larceny. Victim reported a break in into vehicleparked at the Greensboro Inn.
ASSAULT/DOMESTIC VIOLENCE: Greensboro Police receiveda complaint ofa domestic dispute inroom 112 at the GreensboroInn. Female victim was assaulted by male companion.
ASSAULT INFLICTING SERIOUS INJURY: Greensboro Policereceived a complaint of 3 female suspects forcibly entering room305 and assaulted the female occupant, who was pregnant.
RECOVER STOLEN VEHICLE: Greensboro Police conducted aparking lot check inthe Greensboro Inn. One person was chargedfor possession of stolen property aftera stolen vehicle wasrecovered.
DRUG ACTIVITY: During a missing person investigationGreensboro Police conducted a consent search in room 221 at theGreensboro Inn. One person was arrested for possession ofdrugparaphernalia.
DATE
May 25,2007
June 8,2007
June 15,2007
June 16,2007
June 27,2007
June 30,2007
July 21,2007
August 14,2007
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
DRUG ACTIVITY: Greensboro Police received ananonymous tipoftwo people selling cocaine from room 210 at the GreensboroInn. One person was arrested for possession ofCrack Cocaine anddrug paraphernalia.
LARCENY: Greensboro Police responded to the property inreference to a larceny. Victim reported a break in into vehiclewhile parked at the Greensboro Inn. Employee ofthe GreensboroInn told investigating officers the victim spent most ofthe day "inandout" of hiscarwithprostitutes anddrug dealers.
LARCENY: Greensboro Police responded to theproperty inreference to a larceny. Victim reported a break in into vehiclewhile parked at the Greensboro Inn.
DRUGACTIVITY: GreensboroPolice received a complaint ofillegal possession ofcontrolled substances at the Greensboro Inn.One person was arrested for possession ofcocaine and drugparaphernalia.
TRESPASS: Greensboro Police receiveda complaint of a •trespasser on the premises ofthe Greensboro Inn. Suspect refusedto leave afterbeing told to do so by Arthar Khan. Suspect wasarrested for 2nd degree trespass.
ASSAULT/DOMESTIC VIOLENCE: Greensboro Policeresponded to acomplaint ofdomestic dispute in room 110 at theGreensboro Inn. A participant in the dispute threw an aerosol canwhichstrucka five year old child in the head. Suspect wasarrested for assaulton a minor under the age of 12 and assault on afemale.
ASSAULT/DOMESTIC VIOLENCE: Greensboro Policeresponded to a complaint of domestic dispute in room 319 at theGreensboro Inn. One person was arrested for domestic assault on afemale.
DRUG ACTIVITY: Greensboro Police responded to a complaintof illegal possession of controlled substances in room 204at theGreensboro Inn.Two people were arrested for possession ofcocaine and possession of drug paraphernalia.
DATE
August 24,2007
October 10,2007
October 16,2007
October 17,2007
October 18,2007
October 25,2007
November 4,2007
November 8,2007
November 16,2007
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
DRUG ACTIVITY: Greensboro Police responded to room 210 atthe Greensboro Inn inReference toa disorderly subject. Onecitation was issued for possession of marijuana.
RECOVERED DRUG PARAPHERNALIA: Greensboro Policeresponded to room 105 ofthe Greensboro Inn. Thecomplainant/occupant reported finding acrack pipe under the bedmattress. The paraphernalia was seized.
DRUG ACTIVITY: Greensboro Police responded toa complaintofcontrolled substance sold from room 109 at theGreensboro Inn.One person was arrested for possession ofcocaine with intent tosell and deliver.
DRUG ACTIVITY: Greensboro Police responded to a complaintofcontrolled substances being sold onthepremises of theGreensboro Inn. One person was arrested for possession ofcocaine.
LARCENY: Greensboro Police received a complaintof a firearmstolen from a vehicle parked at the Greensboro Inn.
ASSAULT/DOMESTIC VIOLENCE: Greensboro Policeresponded to acomplaint ofdomestic dispute in room 301 at theGreensboro Inn. One person was arrested for domestic assault onafemale.
ASSAULT/DOMESTIC VIOLENCE: Greensboro Policeresponded to acomplaint ofdomestic dispute in room 318 at theGreensboro Inn. Female victim was hit in mouth by malecompanion.
ASSAULT/DOMESTIC VIOLENCE: Greensboro Policeresponded to a complaint ofdomestic dispute in room 312 at theGreensboro Inn. One person was arrested for assault on a femaleand assault by strangulation.
ARMED ROBBERY: Greensboro Police responded to acomplaint ofa robbery in room 114 at the Greensboro Inn. Thesuspect was armed with a semi-automatic handgun. Employee toldpolice she believed the suspect and others loitering on the Propertyearlierin the day were involved in the illegal drug trade.
DATE
November 18,2007
December 17,2007
December 19,2007
December 27,2007
December 29,2007
ATTACHMENTS 15-1
CALLS AND INVESTIGATIONS
DRUG ACTIVITY: Greensboro Police recovered marijuana anddrug paraphernalia from room 218 at the Greensboro Inn.Complainant was motel manager who suspected the occupant ofthe room sold illegal drugs.
DRUG ACTIVITY: Greensboro Police officers arrested a personleaving room 214 atthe Greensboro Inn for possession ofcocaineandresist, obstruct, anddelay a lawenforcement officer.
DRUG ACTIVITY: Greensboro Police executed a search warrantin room 214 at the Greensboro Inn. Two people were arrested forpossession with intent tosell and deliver marijuana, possession ofcocaine, and drug paraphernalia.
DRUG ACTIVITY: Greensboro Police officers arrested a personleaving the Property for possession ofcocaine and drugparaphernalia.
RECOVERED STOLEN VEHICLE: Greensboro Police recovereda stolenvehicle in the parking lot of the Greensboro Inn. Theoccupant of the carand a person inRoom 215 at theGreensboroInn were arrested forpossession of a stolen vehicle, simple assault,and resisting a public officer.
STATE OF NORTH CAROLINA IN THE GENERAL COURT OFJUSTICECOUNTY OF GUILFORD SUPERIOR COURT DIVISION
FILE NO. | 1 CLVQ
AFFIDAVIT
POLICE OFFICER C.H. PEEDEN
OFFICER C.H. PEEDEN. appearing before the undersigned notary and being duly sworn
(or affirmed), says that:
1. I am not a party in this matter.
2. I am currently employed asa police officer for the Greensboro Police
Department, and have been so employed for approximately six and one halfyears.
3. For the last two years I have been assigned to the Vice Narcotics Unit ofthe
Greensboro Police Department.
4. I am familiar with the Greensboro Inn, located at 135 Summit Avenue,
Greensboro, North Carolina(hereinafter the "Property").
5. I have during the past several years visited the Property, visited the community
around the Property, and have had personal contact with citizens in and around the community
where the Property is located.
6. Based upon my personal contacts inthe community where the Property is located
Ihave come to know the general reputation ofthe Property and the general reputation ofpersons
who frequent the Property.
7. The Property currently, and has for aconsiderable period oftime, maintained a
general reputation as a place whereupon occurs:
(A) Prostitution inthe form of females engaging insexual acts with males in
exchange for money.
(B) The illegal possession and sale ofcontrolled substances as defined inthe
North Carolina Controlled Substances Act.
(C) Repeated acts which create and constitute a breach of the peace, including
fights and assaults involving drug dealer who physically attack those who
owe them money.
8. People who loiter on theProperty maintain reputations as prostitutes, drug
dealers, drugusers, and beingproneto engage in acts ofviolence.
9. Employees of theGreensboro Innmaintain reputations for:
(A) Notifying tenants when Greensboro Police conduct operations on the
Property.
(B) Allowingtenants to engage in illegal activities as longas tenants pay rent
for their rooms.
10. I have observed the following on the Property:
(A) Females with reputationsas prostitutes.
(B) Drug dealers and drug users.
(C) A person threaten to assault another usinga large piece of lumber
commonly known as a "2 by 4."
11. Since February 2011,1 have overseen a covert operation which resulted in the
purchase of crackcocaineon the Property.
12. Since February 2011,1 have arrested people on the Property for possession of
controlled substances.
13. I have been assaulted bya drug dealer on the Property.
14. During execution ofasearch warrant on the Property, aGreensboro Police Officer
stayed in the motel office with an employee to ensure the employee did not notify occupants ofa
room of theimpending search warrant execution.
15. Because ofthecriminal element attracted to theProperty, therepeated
occurrences ofdrug violations on the Property, and the violent activities which coincide with the
illegal drug trade, Ibelieve the Greensboro Inn is adetriment to the community and clearly a
publicnuisance.
16. Furtheryouraffiant saithnot.
(ViwX-Affiant
Sworn to(or affirmed) and subscribed before me this
J( Day of DdpT£rt/SJK ,^XtwW*l%,
(Official Seal) < y^J/jJ f^^yX 1Notary Public / J /^T '•'* f -*r> * :
w n • • • 7/1 AA ^BtN° /$lMy Commission expires / • /j-^&C'-tsX^ /y ^c-
*2AM cc*&y
Q,j£-w
STATE OF NORTH CAROLINA INTHE GENERAL COURTOF JUSTICECOUNTY OF GUILFORD SUPERIOR COURT DIVISION
FILE NO. | | CMS
AFFIDAVIT
SERGEANT A.H. HOLLIS
Sergeant A.H. Hollis, appearing before the undersigned notary and being duly sworn (oraffirmed), says that:
1. I am not a party in this matter.
2. I am employed by the Greensboro Police Department, Greensboro, Guilford
County, North Carolina, and have been so employed for more than twenty years. During the
majority ofmy law enforcement career, Ihave worked in the downtown area ofGreensboro.
3. Icurrently hold the rank ofSergeant and am assigned to the Greensboro Police
Department's Center City Resource Team. Members of the Center City Resource Team work
the majority oftheir shifts in the downtown area ofGreensboro.
4. I am familiar with The Greensboro Inn, 135 Summit Avenue, Greensboro, North
Carolina (hereinafter the "Property").
5. I have during the past several years responded to calls at the Property, visited the
community around the Property, and have had personal contact with citizens in and around the
community where theProperty is located.
6. Based upon my personal contacts in the community where the Property is located
Ihave come to know the general reputation ofthe Property, ofpersons who frequent the
Property, and ofthe people who own and operate the business on the Property.
7. The Property currently, and has for aconsiderable period oftime, maintained a
general reputation as a place whereupon occurs:
(A) Prostitution in the form offemales engaging in sexual acts with males in
exchange for money or controlled substances.
(B) The illegal possession and sale ofcontrolled substances as defined in the
North Carolina Controlled Substances Act.
(C) Repeated acts which create and constitute breaches ofthe peace,
including but not limited to, assaults, affrays, robberies, and disturbances.
8. Persons who commonly loiter on and about the property have general reputations
as persons who are known to engage in such acts as described in paragraph #7 hereinabove.
9. The owners and employees ofthe Greensboro Inn maintain ageneral reputation
for being unable or unwilling to prevent illegal activities on the Property.
10. I have observed the following on the Property:
(A) Females with reputations as prostitutes.
(B) Drug dealers.
(C) Assault victims.
(D) Affrays.
(E) An assault on a law enforcement officer.
11. I have seen marijuana, crack cocaine, powder cocaine, heroin, and drug
paraphernalia on the Property.
12. I have seen firearms on the Property.
13. While conducting surveillance and answering calls for police services at the
Property, Ihave observed examples of the illegal activities which citizens complain of and to
which lawenforcement authorities repeatedly respond.
14. I have spoken to Ahman Khan about the illegal and disruptive activities occurring
at the Property.
15. When assaults, robberies, or other violent crimes occur in downtown Greensboro,
police officers assigned to the Center City Resource Team respond to the Greensboro Inn to look
for suspects.
16. The illegal and disruptive activities described above at the Property, occur all
hours of the day and night.
17. Based upon reports from officers who have responded to calls at the Property, my
training, and reports from neighbors as described hereinabove, I feel it is not safe for any law
enforcement officer to respond to a call for service at the Property without exposure to inordinate
and undue danger.
18. Further your affiant saith not.
, / ) i / , /
Sworn to (oraffirmed) and subscribed before me this
/37- Day of ~Su['~? ».2M'V,,,?*''«.(OfficialSeal) < /I? / J<*)/' \$%Notary Public «// £^Z~-' ¥s^% / ^PTA^V\ \
Notary Publfc f v cft?» 1 \
MyCommission expires / - O 'U.0IA-. Q\ J. %$
'» co\J$>""i«:i»n»*»v
STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICECOUNTY OF GUILFORD SUPERIOR COURT DIVISION
FILE NO. | | C_V^
AFFIDAVIT
SERGEANT J.E. ARMSTRONG
Sergeant J.E. Armstrong, appearing before the undersigned notary and being duly sworn (oraffirmed), says that:
1. I am not a party in this matter.
2. I am employed by the Greensboro Police Department, Greensboro, Guilford
County, NorthCarolina, and have been so employed for twenty years.
3. I currently hold the rank ofSergeant and am assigned to the Greensboro Police
Department's Center City Resource Team. Members ofthe Center City Resource Team work
the majority oftheir shifts in thedowntown area ofGreensboro.
4. For more than fifteen years, I have been familiar with the Greensboro Inn, 135
Summit Avenue, Greensboro, North Carolina (hereinafter the"Property").
5. I have during the past several years responded to calls atthe Property, visited the
community around the Property, and have had personal contact with citizens in and around the
community where the Property is located.
6. Based upon my personal contacts in the community where the Property is located
Ihave come toknow the general reputation ofthe Property, ofpersons who frequent the
Property, and ofthe people who own and operate the business on the Property.
7. I have been advised bysuch citizens that the Property currently, and has fora
considerable period oftime, maintained a general reputation asa place whereon occurs:
(A) Prostitution in the form offemales engaging in sexual acts with males in
exchange for money or controlled substances.
EXHIBITCr
(B) The illegal possession and sale ofcontrolled substances as defined in the
North Carolina Controlled Substances Act.
(C) Repeated acts which create and constitute breaches ofthe peace,
including, but not limited to, assaults, affrays, domestic violence;
robberies; and other violent and disruptive acts.
8. I have been advised by such citizens, that many ofthe people who visit and loiter
on and about the Property, have reputations as persons who are known for engaging in acts
described in Paragraph #7 above.
9. I have been advised by citizens who reside in or work in the community around
the Property that they are afraid for their safety because of the general disruptive nature of the
Property and the disruptive nature ofthe people attracted to the Property.
10. The owners and operators ofthe Greensboro Inn maintain ageneral reputation