In 2006, the Defendant starred in the documentary film “Cocaine Cowboys.” The documentary focuses on the importation and trade of drugs in Miami in the 1970s and 1980s. The Defendant brags about his ability to smuggle drugs and his proficient evasion of law enforcement. For instance, the Defendant discusses his use of code words, such as “coming in the front door” or “children in the water,” to evade law enforcement. The Defendant also states that he would move contraband through the use of a tow truck, a trailer, and a work order. Further, there is video of the Defendant loading a car onto a trailer. At trial, the Government intends to offer the testimony of Messrs. Johnson and Carrington, who will discuss their use of code words with the Defendant as part of the conspiracy. For instance, if a car were to come up as stolen, the Defendant and his coconspirators would refer to it as a possible “Signal Ten.” Mr. Johnson will testify that the cars hidden at the Defendant’s house were referred to as “Orphans” and the Defendant’s house was referred to as the “Orphanage.” Similarly, if a lienholder were attempting to locate a car, the Defendant and his conspirators would refer to the car as a “Problem Child.” Here, just as in the video, the Defendant used a tow service company to serve as a cover for his illicit activity and allow him to transport contraband while maintaining, at least as to the Defendant, plausible deniability.
Mickey Munday Motion by David Oscar Markus on Scribd">