Case 3:10-cv-01019-VLB Document 1 Filed 06/28/10 Page 1 of 12

UNITED STATES DISTRICT COURT

DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA,

Plaintiff,

v. Civil No.

ONE PARCEL OF PROPERTY

LOCATED AT 59 HIGHMEADOW
ROAD, WATERTOWN, CONNECTICUT, :
WITH ALL APPURTENANCES AND
IMPROVEMENTS THEREON;
$537,266.84 IN UNITED STATES
CURRENCY,

Defendants. June 28, 2010

[CLAIMANTS: SHPETIM HIDRI; VETIM :

HIDRI; JETON HIDRI; VALDRIN

HIDRI; NEBIJE HIDRI]

VERIFIED COMPLAINT OF FORFEITURE

Now comes Plaintiff, United States of America, by and through its attorneys, David B.

Fein, United States Attorney for the District of Connecticut, and David X. Sullivan, Assistant

United States Attorney, and respectfully states that:

1. This is a civil action in rem brought pursuant to 21 U.S.C. § 881 (a)(7), for the

forfeiture of real property located at 59 Highmeadow Road, Watertown, Connecticut ("Defendant

Property") which was used or intended to be used in any manner or part to commit or to facilitate

the commission of a violation of the Controlled Substances Act, 21 U.S.C. §§ 801 et seq. and

pursuant to 21 U.S.C. § 881 (a)(6) for the forfeiture of Five Hundred Thirty-Seven Thousand

Two Hundred Sixty-Six Dollars Eighty-Four Cents ($537,266.84) ("Defendant Currency") which
 Case 3:10-cv-01019-VLB Document 1 Filed 06/28/10 Page 2 of 12

was derived from the proceeds of illegal narcotics activities and/or United States Currency which

represents actual proceeds of illegal narcotics activity in violation ofthe Controlled Substances

Act, 21 U.S.c. §§ 801 et seq.

2. This Court has jurisdiction over this matter by virtue of28 U.S.C. § 1345 and § 1355.

3. Venue in the District of Connecticut is appropriate pursuant to 28 U.S.C. § 1355 and §

1395.

4. The Defendant Property is one parcel of property located at 59 Highmeadow Road,

Watertown, Connecticut, with all appurtenances and improvements thereon.

5. The United States does not request authority from the Court to seize the Defendant

Property at this time. The United States will, as provided by 18 U.S.C. §§ 985(b)(1) and (c)(l):

(a) post notice of this action and a copy of the Complaint on the Defendant Property;

(b) serve notice of this action on the record owner of the Defendant Property, and any

other person or entity who may claim an interest in the Defendant Property, along

with a copy of this Verified Complaint of Forfeiture;

(c) execute a writ of entry for the purposes of conducting an inspection and inventory

of the property; and

(d) record a lis pendens on the Watertown Records ofthe Defendant Property's status

as a defendant in this in rem action.

6. The United States will also, as provided by 19 U.S.C. § 1606, appraise the

Defendant Property when it executes the Writ of Entry.

7. The Defendant Property was acquired by Shpetim Hidri and Nebije Hidri from

Margaret Garassino, executrix of the estate of Raymond Garassino by Executor's Deed, recorded

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on August 17, 1995, at Volume 796, page 295 of the Watertown Land Records.

8. The appraised value of the Defendant Property is approximately $392,400.

9. In April of2010, law enforcement officers in Watertown, Connecticut received

information from law enforcement officers in Michigan that they uncovered an extensive

marijuana distribution ring that originates in California and has reached into Michigan and,

among other places, Watertown, Connecticut. Michigan officers told Watertown law

enforcement that a search and seizure warrant was executed on the residence of an individual

named Andrew Poag in San Francisco. Poag was described by Michigan officers as the ring

leader of a nationwide marijuana trafficking organization.

10. During the execution ofthe search warrant at Poag's residence, law enforcement

found approximately two pounds of marijuana packaged to ship and a Federal Express ("FedEx")

label addressed to Jason Schiffmiller of 161 Old Farms Road, Watertown, Connecticut.

Michigan officers told Watertown officers that Poag told them that Schiffmiller and an individual

know to them as "Vala" were actively involved in the trafficking organization. Watertown police

immediately recognized Schiffmiller's name and knew "Vala" to be an individual named Valdrin

Hidri of 59 Highmeadow Road in Watertown (the "Defendant Property"). Law enforcement has

arrested Schifmiller and Valdrin Hidri together in other cases over the last several years.

11. On April 30, 2010, Watertown officers conducted a trash pull from the curb at the

Defendant Property. Found in the garbage were several large empty FedEx boxes containing no

shipping labels and two larger FedEx boxes in which the smaller boxes had been shipped. The

larger boxes had shipping labels with a California return address. Also located in the trash pull

was an empty digital scale box.

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12. On May 1,2010, Watertown police were at a FedEx store investigating a

different drug related crime. At that time, a FedEx Operations Specialist at the store approached

the officers and informed them of suspicious activities going on at the FedEx store. The

Operations Specialist told police that on March 24, 2010, a store employee approached him with

a questionable package. The FedEx employee told the Operations Specialist that one individual

had been sending the same sized package to another person every Wednesday for months. The

package sent every Wednesday was addressed to Andrew Poag of 44 Santa Fe, San Francisco,

California. The individual sending the package every Wednesday, as represented on the airbill,

was Valdrin Hidri of 59 Highrneadow Road, Watertown, Connecticut.

13. The FedEx Operations Specialist told Watertown police that on March 24,2010,

he opened the questionable suspicious package that the employee had provided to him. Inside

the package the FedEx Operations Specialist found a three inch rectangular shaped object

wrapped in newspaper. He opened the wrapping at the comer of the object and observed a stack

of one hundred dollar and twenty dollar bills. He estimated the total amount to be approximately

$15,000. Security personnel at FedEx instructed the Operations Specialist to allow the package

to proceed but to report any more of its kind.

14. On May 12,2010, law enforcement officers executed a State of Connecticut

Search and Seizure Warrant on the Defendant Property. Arriving at the Defendant Property,

officers first attempted to place a telephone call to request that someone meet them at the front

door, but no one answered the call. Officers then noticed individuals moving within the

Defendant Property. After several knocks on the door, officers forced entry with a battering ram.

15. After entering the Defendant Property and announcing their presence, officers

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first located Jeton Hidri exiting his second floor bedroom. After a brief struggle, Jeton Hidri was

placed on the floor and handcuffed. Jeton then refused to stand up and was forcibly taken to his

feet and removed from the Defendant Property and placed in a law enforcement vehicle. He was

read his Miranda rights in the vehicle.

16. Officers next located Shpetim Hidri at the top of the front staircase and he was

handcuffed and secured without incident.

17. Officers then located Valdrin Hidri who was first observed running from his

bedroom to the garage and towards the basement. Valdrin ignored officers commands to stop

and resisted arrest. He was tasered and handcuffed.

18. Officers next located Vetim Hidri in his bedroom. Vetim ran at officers when

confronted and had to be physically placed on the ground to be handcuffed. Also located in

Vetim's room were his wife and three year old daughter.

19. All of the individuals, with the exception of Jeton Hidri who was in the police

vehicle, were seated in the kitchen and read their Miranda rights.

20. While securing the Defendant Property, officers discovered an indoor marijuana

grow in the basement that Valdrin was running towards. In the basement, police found indoor

grow lamps heating 49 marijuana plants. Also found were two scales, three plastic bottles of

Monkey Juice (a liquid plant fertilizer), vacuum seal bags, a white plastic bag which held two

plastic ziplock bags of marijuana, and a wood stove that held partially burnt, dried marijuana.

While law enforcement was discussing the marijuana grow found in the basement, Shpetim said

"I've told my boys to get rid of that stuff before."

21. Law enforcement continued their search of the Defendant Property. In Jeton

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Hidri's room, law enforcement located $9,300 in counterfeit one hundred dollar bills in the

nightstand drawer. Police also forcibly opened a safe in leton's room and found, among other

things, a digital scale. Also located in the room were a computer and printer that may have been

used to create the counterfeit currency.

22. In Valdrin Hidri's room, police found a small amount of marijuana in a white

paper fold located in a pair ofjeans, keys to a BMW and a Mercedes, which were later seized by

law enforcement. Officers found two vacuum sealers and a padded envelope from a California

address located in a shoe box.

23. In Vetim Hidri's bedroom, officers found a shotgun and ammunition, a plastic

bag with marijuana seeds, a ziplock bag containing marijuana, and a teeshirt rolled around

marijuana seeds.

24. Shpetim Hidri was arrested and charged with: Possession of Marijuana;

Possession of Marijuana with the Intent to Sell; Possession of Marijuana within 1500 feet of a

school; Operating a Drug Factory; Cultivating Marijuana; Risk ofInjury to a Minor; Possession

of Drug Paraphernalia; Forgery; and Illegal Cultivation Without a License.

25. Vetim Hidri was arrested and charged with: Possession of Marijuana; Possession

of Marijuana with the Intent to Sell; Possession of Marijuana within 1500 feet of a school;

Operating a Drug Factory; Cultivating Marijuana; Risk ofInjury to a Minor; Possession of Drug

Paraphernalia; Forgery; Illegal Cultivation Without a License; Interfering with a Search Warrant;

and Interfering with an Officer.

26. Valdrin Hidri was arrested and charged with: Possession of Marijuana;

Possession of Marijuana with the Intent to Sell; Possession of Marijuana within 1500 feet of a

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school; Operating a Drug Factory; Cultivating Marijuana; Risk ofInjury to a Minor; Possession

of Drug Paraphernalia; Forgery; Illegal Cultivation Without a License; Interfering with a Search

Warrant; and Interfering with an Officer.

27. Jeton Hidri was arrested and charged with: Possession of Marijuana; Possession

of Marijuana with the Intent to Sell; Possession of Marijuana within 1500 feet of a school;

Operating a Drug Factory; Cultivating Marijuana; Risk of Injury to a Minor; Possession of Drug

Paraphernalia; Forgery; Illegal Cultivation Without a License; Interfering with a Search Warrant;

and Interfering with an Officer.

28. On June 3, 2010, Nebije Hidri, wife ofShpetim Hidri, surrendered to Watertown

Police to be processed on an active arrest warrant. She was read her rights and charged with:

Criminal Liability for Acts of Others regarding Possession of Marijuana; Possession of

Marijuana Within 1500 Feet of a School; and Forgery.

29. On May 12 and 13,2010, law enforcement executed Search and Seizure Warrants

on bank accounts in the name of: Shpetim Hidri; Vetim Hidri; Jeton Hidri; Valdrin Hidri; and

Nebije Hidri. Law enforcement utilized bank records found during the search of the Defendant

Property to prepare the warrants.

30. Law enforcement executed warrants on account number XXXXXX1050 at

Thomaston Savings Bank, account number XXXX40 at Greater Waterbury Healthcare Federal

Credit Union, account numbers XXXXXX8891, XXXX1693, XXXXXX1640, and

XXXXX6608 at Webster Bank, and account numbers XXXXXXXXXX0802 and

XXXXXXXXXXX2079 at Wachovia Bank all in the name of Shpetim Hidri. Law enforcement

seized $213,962.1 0 from Thomaston Savings Bank, $1,431.32 from Greater Waterbury

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Healthcare Federal Credit Union, $106,506.21 from Webster Bank, and $155,833.97 from

Wachovia Bank.

31. Law enforcement executed warrants on Webster Bank, Bank of America, and TD

Bank for accounts in the name of Vetim Hidri. Law enforcement seized $151.24 from Bank of

America. Due to threshold requirements the Government will not be forfeiting this currency.

32. Law enforcement executed a warrant on Webster Bank for accounts in the name

of Jeton Hidri. Law enforcement seized $270.04 from Webster Bank. Due to threshold

requirements, the Government will not be forfeiting this currency.

33. Law enforcement executed warrants on Watertown Federal Credit Union and

Wells Fargo for accounts in the name ofValdrin Hidri. Law enforcement seized $504.10 from

Wells Fargo. Due to threshold requirements, the Government will not be forfeiting this currency.

34. Law enforcement executed a warrant on account number XXXX7680 at CSE Federal

Credit Union in the name ofNebije Hidri. Law enforcement seized $59,533.24 from CSE

Federal Credit Union.

35. The total amount of currency seized by law enforcement was $537,266.84.

CONCLUSION

36. The Defendant, one parcel of property located at 59 Highmeadow Road, Watertown,

Connecticut, with all appurtenances and improvements thereon, is real property which was used

or intended to be used in any manner or part to commit or to facilitate the commission of a

violation of the Controlled Substances Act in violation of21 U.S.C. 801 et seq., and is therefore

subject to forfeiture to the United States pursuant to 21 U.S.C. § 881(a)(7).

WHEREFORE, the United States of America respectfully asserts that there is probable

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cause to believe that the Defendant Property is forfeitable to the United States pursuant to 21

U.S.C. § 881 (a)(7); and requests,

(a) that pursuant to 18 U.S.C. § 985(b)(2), and 18 U.S.C. § 9830), which permits the

Court to "take any action to ... preserve the availability of the property subject to civil

forfeiture," the Court issue the proposed Writ of Entry attached to this Verified Complaint of

Forfeiture authorizing the United States Marshals Service, or its delegate, to enter the Defendant

Property, including any structures, on one or more occasions during the pendency ofthis in rem

forfeiture action:

(l) for the purpose of conducting an inspection and inventory and appraisal of the

Defendant Property, which inspection and inventory and appraisal may include

still and video photography;

(2) to be accompanied on any such occasion by any appraiser(s) selected by it to

appraise the condition and value of the Defendant Property pursuant to 19 U.S.C.

§ 1606;

(3) to be accompanied on any such occasion by any government or contract personnel

selected by it for the purpose of conducting an inventory of the Defendant

Property; and

(4) to be accompanied on any such occasion by any federal, state, or local law

enforcement officers selected by it to ensure the safety of any person acting under

the Writ of Entry;

(b) that the Court decree that the forfeiture of the Defendant, one parcel of property

located at 59 Highmeadow Road, Watertown, Connecticut, with all appurtenances and

 Case 3:10-cv-01019-VLB Document 1 Filed 06/28/10 Page 10 of 12

improvements thereon, to the United States under 21 U.S.C. § 881(a)(7) is confirmed, enforced,

and ordered;

37. And that the Defendant Currency totaling $537,266.84 in United States Currency

was derived from the proceeds of illegal narcotics activities and/or United States Currency which

represents actual proceeds of illegal narcotics activity, in violation of21 U.S.c. § 801 et seq.

WHEREFORE, the United States of America respectfully asserts that there is probable

cause to believe that the Defendant Currency is forfeitable to the United States pursuant to 21

U.S.C. § 881(a)(6) as described above and requests,

(a) that the Court decree that the forfeiture of the Defendant Currency totaling

$537,266.84, to the United States pursuant to 21 U.S.C. § 881(a)(6) is confirmed, enforced, and

ordered;

(b) that the Court award Plaintiff United States all other relief to which it is entitled,

including the costs of this action.

Respectfully submitted,

DAVID B. FEIN
UNITED STATES ATTORNEY

J~~
~F~DIVISION
~J;1:_EY
DAVID X. SULLIVAN
_
ASSISTANT U.S. ATTORNEY
P.O. BOX 1824
NEW HAVEN, CT 06508
(203) 821-3700
FEDERAL BAR # ct03793

10

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DECLARA nON

I am a Special Agent of the Drug Enforcement Administration, United States Department

of Justice, and the agent assigned the responsibility for this case.

I have read the contents of the foregoing Verified Complaint of Forfeiture and the

statements contained therein are true to the best of my knowledge and belief.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on this 28'...... day of June, 2010.

11

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SCHEDULE A

All that certain piece or parcel of land with all of the improvements thereon, situated on the
northwesterly side of Highmeadow Road, in the said Town of Watertown, known as Lot #54 as
shown on a map entitled "FERN-WOODS SUBDIVISION PLAN, SECTION 9, Scale 1"=100'
dated October 24, 1980" prepared by L.T. Scott-Smith Co., Surveyors, 33 Valentine Drive,
Waterbury, CT, which map is on file in the Watertown Town Clerk's Office as Map #2260,
bounded and described as follows:

Northeasterly ­ 386.24 feet by Lot#55;

Southeasterly ­ 150.00 feet by Highmeadow Road;
Southwesterly ­ 433.63 feet by Lot #53; and
Northerly ­ 157.31 feet by land designated to be deeded to the Town of
Watertown, all as shown on said map.

SUBJECT TO:

1.) Right of Way and Easement - James B. White to The Connecticut Light and Power Company
dated May 26, 1927 and recorded in Watertown Land Records, Volume 69, Page 122; and dated
February 19, 1929 and recorded in Watertown Land Records, Volume 72, Page 286. MAY
AFFECT SAID PREMISES.

2.) Right of Way and Easement - Edna L. Russin to The Connecticut Light and Power Company
dated April 3, 1962 and recorded in Watertown Land Records, Volume 140, Page 236. MAY
AFFECT SAID PRENIISES.

3.) Easement - Raymond L. Garassino to the Connecticut Light and Power Company dated
March 25, 1977, recorded March 28, 1977 in Watertown Land Records, Volume 234, Page 18.

4,) Declaration of Covenants and Restrictions by Raymond L. Garassino including approval of

plans and specifications dated January 17, 1986, recorded January 24, 1986 in Watertown Land
Records, Volume 408, Pages 250-253. See approval of plans and specifications dated June 27,
1997, recorded in Watertown Land Records, Volume 858, Page 280.