On November 9, 2005, a cargo shipment (?the cargo?) consisting of seven crates arrived at Newark International Airport in Newark, New Jersey from Great Britain on Continental Airlines Flight 27, Airbill #17626183312. The consignee listed for the cargo was ?Niiokai Adjei.? The cargo was destined to travel in bond to the Continental Airlines storage facility at John F. Kennedy International Airport (?JFK?) in Queens, New York.

On November 9, 2005, inspection of the cargo by Customs and Border Protection (?CBP?) agents at Newark Airport revealed that the cargo contained ceramics and packages of a powdery substance that field tested positive for heroin. The combined weight of the heroin is approximately 136.4 pounds, equivalent to approximately 62 kilograms.

The cargo was transported to the Continental Airlines storage facility at JFK on November 10, 2005.

On November 11, 2005, defendants ERIC AMOATENG and NIIL OKAI ADJEI, along with a third individual, were observed by ICE agents arriving at the Continental Airlines storage facility at JFK in a black van. The van was driven by the third individual, with ADJEI in the front passenger seat and AMOATENG in the back seat. AMOATENG, ADJEI and the third individual placed the cargo into the black van under surveillance of ICE. After AMOATENG, ADJEI and the third individual retrieved the cargo, the van was observed driving erratically in a manner suggesting an attempt to elude law enforcement.

The black van was thereafter observed by ICE agents entering the premises of American Self Storage, 330 Tomkins Avenue, Staten Island, New York 10304 (?American Self Storage?). Defendants ERIC AMOATENG and NIIL OKAI ADJEI, along with the third individual were subsequently observed unloading the cargo, and placing it into a storage unit. After AMOATENG and ADJEI and the third individual left the area, ICE agents were able to visually confirm from an open space that the cargo was in storage unit 3054.

Investigation has revealed that storage unit 3054 is registered to an individual named Gamelie Kuonoe, and that defendant NIIL OKAI ADJEI is listed as an individual permitted to access storage unit 3054.

On November 11, 2005, ICE agents obtained permission from the owner of American Self Storage to place video surveillance devices in the common hallway area of the American Self Storage facility.

Through the use of these video surveillance devices, on November 12, 2005, ICE agents observed defendants ERIC AMOATENG and NIIL OKAI ADJEI enter the American Self Storage facility.

Defendants ERIC AMOATENG and NIIL OKAI ADJEI opened the door to unit 3054. This door remained open during the duration of AMOATENG and ADJEI?s visit to unit 3054, and thus the video surveillance devices mounted in the common hallway were able to record AMOATENG and ADJEI?s activities in unit 3054.

Once inside unit 3054, defendants ERIC AMOATENG and NIIL OKAI ADJEI were observed opening the crates, and inspecting the contents. After a period of approximately five minutes, AMOATENG and ADJEI closed the crates and departed from unit 3054.

WHEREFORE, your deponent respectfully requests that the defendants ERIC AMOATENG and NIIL OKAI ADJEI be dealt with according to law.